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COMPLAINT
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County of _________, State of California.
9 information and belief, is now, and at all times mentioned herein was, a corporation, organized and
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existing under the laws of the State of California, doing business in City of _________, County of
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_________, State of California.
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3. This court is the proper court for trial in this action in that the actions and omissions of
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14 Defendant as alleged herein were made within this Courts jurisdictional area.
15 4. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious
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names and will seek leave of this Court to insert true names and capacities once they have been
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ascertained.
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20 5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
21 1 through 50, were authorized and empowered by each other to act, and did so act, as agents of each
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other, and all of the things herein alleged to have been done by them were done in the capacity of
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such agency. Upon information and belief, all Defendants are responsible in some manner for the
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events described herein and are liable to Plaintiff for the damages they have incurred.
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COMPLAINT
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Plaintiff was paid by the job.
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4 time they worked for Defendant, they were regularly and systematically required to work in excess of
5 eight hours and sometimes twelve hours per day and forty hours per week without receiving any
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overtime compensation therefore. Plaintiff was required to wear a uniform provided by Defendant
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during the entire time they were employed by them, they were told that they had to finish a particular
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job in so many hours, one day, etc. Further Defendant supplied the tools and supplies for Plaintiff and
11 9. Similarly, despite working at least eight hours on each day of work, Defendant did not
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always allow Plaintiff to take a meal break as required by law.
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10. Furthermore, Plaintiff was never allowed to take any statutorily mandated rest breaks
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during the entire time they were employed by Defendant. Further, in or about _____ Plaintiff was told
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16 by Defendant that if a city representative came to the job site where they were working that they were
17 to tell them they were an employee of Defendant and were being paid $____ per hour.
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complaint-for-unpaid-wages-failure-to-pay-overtime-or-provide-meal-
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COMPLAINT