Laliberte v. Intercon Security Systems - PAGA Action - Investigation

Quintilone & Associates has filed a PAGA action where Plaintiff Tyler Laliberte (“Plaintiff”) seeks payment for unpaid wages, meal and rest periods and reimbursement for expenses incurred while working as a a security officer. for recovery of civil penalties against Inter-Con Security Systems Inc. a California corporation, and any parents, subsidiaries or affiliated companies, (“Inter-Con” or “Defendants”), within the State of California. The Complaint alleges “aggrieved employees” and/or “employees” and/or “PAGA Members” were not provided with compliant off-duty meal and rest periods, or one-hour of pay in lieu thereof. Aggrieved employees were required to respond to calls off the clock at all times of the day on their personal cell phones. It was Defendants policy to not pay overtime for these calls and to not reimburse for the cell phone use. As a result for the failure to pay all wages and to provide meal and rest period premiums, aggrieved employees received inaccurate wage statements and did not timely receive all wages due at the time of their separation/termination during the applicable limitations period for this action. For each pay period or as required by statute, Plaintiff files this action as a Representative action under PAGA and seeks to recover all civil penalties permitted by law.

Plaintiff seeks to represent the following proposed group of Aggrieved Employees: "All of Defendant’s employees who were referred to as “Security Officer” (and/or similar position titles performing similar work duties) in the State of California at any time from 1 year prior to the Plaintiff’s Notice to the LWDA (January 30, 2019) to commencement of trial (the proposed “PAGA PERIOD”) as determined from Defendant’s corporate records and payment records."

The Labor Code Private Attorneys General Act (PAGA) authorizes aggrieved employees to file lawsuits to recover civil penalties on behalf of themselves, other employees, and the State of California for Labor Code violations. Those who intend to pursue PAGA cases must follow the requirements specified in Labor Code Sections 2698 - 2699.5.

PAGA requires that new claim notices, responses, and certain court documents be filed with the Labor and Workforce Development Agency (LWDA). 

This case is filed in the Los Angeles Superior Court, Burbank Division and has LASC Case No.: 20STCV15080. It is currently assigned to the Hon. William D. Stewart. 

Investigation and Counsel Involved

In furtherance of our investigation efforts, we are looking to interview other employees who experienced similar mistreatment or former employees or former assistant managers who have information regarding this conduct. If you would like a copy of the Complaint or have any questions regarding this case please contact:

Richard E. Quintilone II, Esq.
Jeffrey T. Green Esq.
Kyle J. Gallego Esq. 
Quintilone & Associates
22974 El Toro Road, Suite 100
Lake Forest, CA 92630-4961
Telephone: 949.458.9675
Facsimile: 949.458.9679
Email: req@quintlaw.com    

California employers are prohibited from retaliating against employees who participate in wage and hour complaints or investigations. If you feel you have been retaliated against, please feel free to contact any of the above-listed law firms or the California Department of Industrial Relations, Division of Labor Standards Enforcement for information. http://www.dir.ca.gov/dlse/HowToFileRetaliationComplaint.htm

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