**Healthcare Provider Faces Allegations of Multiple Labor Code Violations in California**
On September 12, 2024, Lauren Zepf filed a complaint against Community Memorial Health System in the Superior Court of the State of California for the County of Ventura. The lawsuit, representing aggrieved employees under the Private Attorney General Act (PAGA), alleges numerous violations of California labor laws by the healthcare provider.
The plaintiff, Lauren Zepf, employed by Community Memorial Health System from January 2022 to September 2023, claims that she and other non-exempt employees were systematically denied proper compensation and breaks as required by law. According to the complaint, Community Memorial Health System failed to pay for all hours worked, including overtime and minimum wages. "Defendant requires Plaintiff to work while clocked out during what is supposed to be Plaintiff’s off-duty meal break," reads one part of the filing. Additionally, it alleges that employees were subjected to mandatory COVID-19 screenings off-the-clock without compensation.
The allegations extend beyond unpaid wages. The complaint details how Community Memorial Health System allegedly manipulated time records through rounding practices that favored the employer. It also claims that incentive payments were not included in calculating overtime and meal/rest break premiums, leading to further underpayment. Furthermore, Zepf accuses her former employer of failing to provide suitable seating as required by law and not reimbursing employees for business expenses such as personal cell phone use and home office costs.
Zepf seeks civil penalties on behalf of herself and other aggrieved employees for these alleged violations under PAGA. Specifically, she requests penalties for failure to provide accurate wage statements, timely payment of wages, reimbursement for business expenses, and provision of suitable seating among others. The relief sought includes civil penalties as prescribed by PAGA along with attorneys' fees and costs.
Representing Zepf are attorneys Kyle R. Nordrehaug, Aparajit Bhowmik, Jeffrey S. Herman from Blumenthal Nordrehaug Bhowmik De Blouw LLP. The case has been assigned Case No. 2024CUOE030550 in Ventura Superior Court.