It denies each of the claims and contentions alleged by Plaintiff in the Lawsuit.
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Topĭefendant contends that it compensates and reimburses employees in full compliance with the law. The Parties thereafter reached the Settlement that is memorialized in the Settlement Agreement that is on file with the Court, and whose terms are generally summarized in the Notice. In Plaintiff’s complaint, he seeks recovery of allegedly unpaid wages, expense reimbursements, penalties, interest, and attorneys’ fees and costs.Īfter several months of formal litigation and the exchange of relevant information, the Parties agreed to participate in multiple private mediations to try and resolve the claims. Plaintiff alleges that the claims should be certified as a class action. Plaintiff’s claims are based on Defendant’s Alternative Flexible Grid (“AFG”) program. (“UCL”) and the California Labor Code Private Attorneys General Act of 2004 (“PAGA”), Labor Code § 2698, et seq. Plaintiff also alleged derivative claims pursuant to the California Unfair Competition Law, California Business & Professions Code § 17200, et seq.
The operative complaint alleges that Defendant failed to pay wages, made unlawful wage deductions, violated the California Employee Bond Law, failed to provide accurate itemized wage statements, and failed to indemnify all reasonable and necessary business expenses, enumerating alleged violations of Labor Code §§ 201-204.2, 221-224, 226, 400-410, 1174, 1174.5, 1198, 2802 and Cal. On or about May 14, 2018, Plaintiff Brandon Harvey filed a putative class action on behalf of himself and other employees that Defendant Morgan Stanley Smith Barney LLC employed as Financial Advisors in California from through September 5, 2019. What are my Options Under the Settlement?.What are the positions of the parties and reasons for settlement?.
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