Sit To: LASC- HILL Page 3034 ee Shaun Setateh (SBN 204514) shaun@setarchlaw.com SETAREH LAW GROUP 9454 Wilshire Boulevard, Suite 907 Beverly Hills, Cafifornia 90212 Telephone (310) 888-7771 Feesimile (310) 888-0109 Richard Lloyd Sherman (SBN 106597) richard@shermanlaw group.com SHERMAN LAW GROU! 9454 Wilshire Boulevard, Suite 850 Beverly Hills, California 90212 ‘Telephone (310) 246-0321 Facsimile (310) 246-0305 Attorneys for Plaintiff LAURIE WOODS SUPERIOR COURT OF THE STATE OF CALIFORNIA, POR THE COUNTY OF LOS ANGELES—CENTRAL DISTRICT LAURIE WOODS, on behalf of herself, ull | others similarly situated, | i } Plaintiff ws FILM INDEPENDENT, INC. a California ‘corporation; and DOES I through 50, inclusive, Defendants, 1 CLASS ACTION COMPLAINT 2016.02.28 18.4252 (6M) See eee From: Shaun Setereh FILED ‘Superior Court of California . inty of Los Angeles FEB 23.2018 ‘Sherti 2 uClerk pent ee Case No. BC695391 CLASS ACTION COMPLAINT Failure to Provide Meal Periods (Lab. Code §§ 204, 223, 226.7, $12 and 1198), Failure to Provide Rest Periods (Lab. Code $8 204, 223. 226.7 and 1198); 4, Failure'to Pay Houdy Wages (Lab. Code §§ 223, $10, 1194, 1194.2, 1197, 1997.1 and 1198); 4. Failure to indemnify (Lab. Code § 2802); 3. Failure to Provide Accurate Written Wage 6. Statements (Lab. Code §§ 226(a); . Failure to Timely Pay All Final Wages (Lab. Cade $§ 201, 202 and 203); 7. Unfair Competition (Bus. & Prof. Code §§ 17200 et seq.y, JURY TRIAL DEMANDED 11:17:41 2018-02-23 ‘Opt-Out: Not DefinedPlaintiff Laurie Woods, on behalf of herself, all others similarly situated, complains and alleges as follows: INTRODUCTION 1. Plaintiff brings this class action against Defendant Film Independent, Inc., and DOES | through 50, inclusive as current or former unpaid volunteers (“Volunteer Employees”) for alleged violations of the California Labor Code and Business and Professions Code. As set forth below, Plaintiff alleges that Defendants have failed to provide her and all similarly situated individuals wit: (1) meal periods; (2) rest periods; (3) premium wages for missed meal and/or rest periods; (4) at least minimum wage for all hours worked; (5) overtime wages at the correct rate; (6) double time wages at the correct rate; (7) reimbursement for all necessary business expenses; (8) accurate written wage statements; and (9) all of their final wages following separation of employment, Based on these alleged Labor Code violations, Plaintiff now brings this class and representative action to recover unpaid wages, restitution and related relief on behalf of herself, and all others similarly situated. JURISDICTON AND VENUE 2. This Court has subject matter jurisdiction to hear this case because the monetary ‘damages and restitution sought by Plaintiff from Defendants exceeds the minimal jurisdiction of the Superior Court of the State of California. 3. Venue is proper in the County of Los Angeles pursuant to Code of Civil Procedure §§395(a) and 395.5 in that liability arose in this county because at least some of the transactions that are the subject matter of this Complaint occurred therein and/or each defendant is found, maintains offices, transaets business and/or has an agent therein. 1 CLASS ACTION COMPLAINT2 4, enue is also proper in the County of Los Angeles because Defendants’ principal place of business is in California, incorporated under the laws of California, and does business in 4] Los Angeles County. 5. Plaintiff'is informed and believes, and thereupon alleges that the individual claims of 6 || the class defined below are under the $75,000 threshold for federal diversity jurisdiction and the 7 |) aggregate claim is under the $5,000,000 threshold for federal jurisdiction under the Class Action 8 || Faimess Act of 2005. Further, there is no federal question at issue as the issues herein are based 9 || solely on California law. Further, Defendant is a California corporation and Plaintiff is a California 10 | resident, therefore there is no diversity of citizenship of the parties. u PARTIES 12 6. Plaintiff Laurie Woods (“Plaintiff”) is, and at all relevant times mentioned herein, an 13} individual residing in the State of California. 14 7. Plaintiffs informed and believes, and thereupon alleges that Defendant Film 15 || Independent, Inc. (“Film Independent’) is, and at all relevant times mentioned herein, a California 16 || non-profit corporation doing business in the State of California. 7 8. Plaintiff'is ignorant of the true names and capacities of the defendants sued herein as 18 || DOES | through 50, (“DOE Defendants”) and therefore sues these DOE defendants by such 19] fictitious names. Plaintiff will amend this Complaint to allege the true names and capacities of the 20 || DOE defendants when ascertained. Plaintiff is informed and believes, and thereupon alleges that 21 each of the DOE defendants are responsible in some manner for the occurrences, acts and omissions 22 [alleged herein and that Plaintiff's alleged damages were proximately caused by these DOE 23|| Defendants. Plaintiff will amend this complaint to allege both the true names and capacities of the 24 || DOE Defendants when ascertained. (Film Independent and the DOE Defendants are hereinafter collectively referred to as the “Defendants”) 26 9. Plaintiff is informed and believes, and thereupon alleges that, at all relevant times 27| mentioned herein, some or all of the Defendants were the representatives, agents, employees, 28 || partners, directors, associates, joint venturers, principals or co-participants of some or all of the ‘CLASS ACTION COMPLAINT