Charles v. Varsity Tutors CA6
In the operative first amended complaint, Plaintiffs sought civil penalties under PAGA on behalf of themselves and “other aggrieved employees” of Varsity for alleged Labor Code violations, including the failure to pay minimum wage, overtime, and reimbursement of necessary employee expenditures; intentional misclassification of employees as independent contractors; failure to provide timely, accurate, itemized wage statements; failure to provide meal and rest breaks; and requiring employees to waive all rights to pursue any dispute on a representative basis. Plaintiffs alleged that Charles exhausted the administrative prefiling requirements by sending a notice to the Labor and Workforce Development Agency (LWDA).
Plaintiffs served Varsity with form interrogatories, requests for document production, and requests for admission. Varsity responded principally with objections.
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