throbber
Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 1 of 22 Page ID #:20
`E'lectronically FILED by Superior Court of California, County of Los Angeles on 07/30/2021 03:41 PM Sherri R, Carter, Executive Officer/Cler1< of Court, by R. Clifton,Deputy Clerk
`21STCV28197
`
`Assigned for all purposes to: Stanley Mask Courthouse, Judicial Officer: Teresa Beaudet
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`3
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`Joseph Lavi, Esq. (SBN 209776)
`jlavi@lelawfirm.com
`2 Vincent C. Granberry, Esq. (SBN 276483)
`vgranberry(mlelawfirm.com
`Pooja V. Patel, Esq. (SBN 317891)
`Kevin Joseph Farnan, Esq. (SBN 327524)
`kfarnan@lelawfirm.com
`LA VI & EBRAHIMIAN, LLP
`8889 W. Olympic Blvd., Suite 200
`Beverly Hills, California 90211
`6 Telephone: (310) 432-0000
`Facsimile: (310) 432-0001
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`4
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`5
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`7
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`8
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`9
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`10
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`11
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`Attorneys for Plaintiffs GLORIBEL TURCIOS, KAMLESH KUMAR
`and YARA MEDINA on behalf of themselves and current and former aggrieved employees
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`
`FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
`
`12 GLORIBEL TURCIOS, KAMLESH KUMAR,
`and YARA MEDINA, on behalf of themselves
`and other aggrieved employees,
`
`13
`
`CaseNo.:21STC:V28197
`
`PAGA ACTION
`
`PLAINTIFF GLORIBEL TURCIOS,
`KAMLESH KUMAR, ANDY ARA
`MEDINA'S COMPLAINT FOR
`DAMAGES AND RESTITUTION FOR:
`
`1.
`
`CIVIL PENAL TIES PURSUAN
`TO THE PRIVATE ATTORNEY
`GENERAL
`ACT
`OF
`200
`("PAGA"),
`LABOR
`COD
`SECTION 2698, et seq.
`
`Plaintiff,
`
`14
`
`15
`
`vs.
`
`16 CPE HR, INC.; WINDSOR CHEVIOT HILLS,
`LLC; WINDSOR CARE CENTER OF
`
`17
`
`~~~~:PZE~g,kJ+ 1~~!ABILITA TION
`18 CENTER OF CONCORD, LLC; WINDSOR
`COUNTRY DRIVE CARE CENTER, LLP;
`19 WINDSOR EL CAMINO CARE CENTER,
`LLC; WINDSOR ELK GROVE CARE AND
`20 REHABILITATION, LLC; WINDSOR
`ELMHAVEN CARE CENTER, LLC;
`WINDSOR CONY ALESCENT AND
`REHABILITATION CENTER OF FREMONT,
`22 LLC; WINDSOR GARDENS HEALTHCARE
`CENTER OF HAYWARD, LLC; WINDSOR
`23 HAYWARD ESTATES, LLC; WINDSOR
`HAMPTON CARE CENTER, LLC; WINDSOR
`24 MONTEREY CARE CENTER, LLC;
`WINDSOR SACRAMENTO ESTATES, LLC;
`WINDSOR THE RIDGE REHABILITATION
`CENTER, LLC; WINDSOR CONY ALESCENT
`26 AND REHABILITATION CENTER OF
`SALINAS, LLC; WINDSOR SKYLINE CARE
`27 CENTER, LLC; WINDSOR ROSEWOOD
`CARE CENTER, LLC; WINDSOR VALLEJO
`28 CARE CENTER, LLC; WINDSOR CARE
`CENTER OF PETALUMA, LLC; WINDSOR
`
`21
`
`25
`
`COMPLAINT
`1
`
`EXHIBIT 1
`
`Page 14
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 2 of 22 Page ID #:21
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`HEALTHCARE GOLDEN PALMS, LLC;
`WINDSOR TWIN PALMS HEALTHCARE
`CENTER, LLC; WINDSOR ARVIN
`2 HEALTHCARE, LLC; WINDSOR
`BAKERSFIELD HEALTHCARE, LLC;
`3 WINDSOR CYPRESS GARDENS
`HEALTHCARE LLC; WINDSOR GARDENS
`4 CONY ALESCENT CENTER OF LONG
`BEACH; WINDSOR CONY ALESCENT
`5 CENTER OF NORTH LONG BEACH;
`WINDSOR GARDENS CONY ALESCENT
`6 HOSPITAL OF LOS ANGELES; WINDSOR
`GARDENS CONY ALESCENT CENTER OF
`SAN DIEGO; WINDSOR CARE CENTER
`NATIONAL CITY, INC.; WINDSOR
`8 TERRACE HEALTHCARE, LLC; WINDSOR
`COURT ASSISTED LIVING, LLC; WINDSOR
`9 WESTLAKE HEALTHCARE, LLC; and DOES
`1 to 200, inclusive,
`
`7
`
`11
`
`12
`
`13
`
`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`26
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`27
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`28
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`Defendants.
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`COME NOW Plaintiffs GLORIBEL TURCIOS, KAMLESH KUMAR, and YARA
`
`MEDINA ("Plaintiffs"), who alleges and complains against Defendants CPE HR, INC.;
`
`WINDSOR CHEVIOT HILLS, LLC; WINDSOR CARE CENTER OF CHEVIOT HILLS;
`
`WINDSOR CONVALESCENT AND REHABILITATION CENTER OF CONCORD, LLC;
`
`WINDSOR COUNTRY DRIVE CARE CENTER, LLP; WINDSOR EL CAMINO CARE
`
`CENTER, LLC; WINDSOR ELK GROVE CARE AND REHABILITATION, LLC; WINDSOR
`
`ELMHA VEN CARE CENTER, LLC; WINDSOR CONVALESCENT AND REHABILITATION
`
`CENTER OF FREMONT, LLC; WINDSOR GARDENS HEAL TH CARE CENTER OF
`
`HAYWARD, LLC; WINDSOR HAYWARD EST ATES, LLC; WINDSOR HAMPTON CARE
`
`CENTER, LLC; WINDSOR MONTEREY CARE CENTER, LLC; WINDSOR SACRAMENTO
`
`ESTATES, LLC; WINDSOR THE RIDGE REHABILITATION CENTER, LLC; WINDSOR
`
`CONVALESCENT AND REHABILITATION CENTER OF SALINAS, LLC; WINDSOR
`
`SKYLINE CARE CENTER, LLC; WINDSOR ROSEWOOD CARE CENTER, LLC; WINDSOR
`
`VALLEJO CARE CENTER, LLC; WINDSOR CARE CENTER OF PETALUMA, LLC;
`
`WINDSOR HEALTHCARE GOLDEN PALMS, LLC; WINDSOR TWIN PALMS
`
`HEALTHCARE CENTER, LLC; WINDSOR ARVIN HEALTHCARE, LLC; WINDSOR
`
`BAKERSFIELD HEALTHCARE, LLC; WINDSOR CYPRESS GARDENS HEALTHCARE
`
`COMPLAINT
`2
`
`EXHIBIT 1
`
`Page 15
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 3 of 22 Page ID #:22
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`LLC; WINDSOR GARDENS CONVALESCENT CENTER OF LONG BEACH; WINDSOR
`
`2 CONY ALES CENT CENTER OF NORTH LONG BEACH; WINDSOR GARDENS
`
`3 CONY ALES CENT HOSPITAL OF
`
`LOS ANGELES; WINDSOR GARDENS
`
`4 CONY ALESCENT CENTER OF SAN DIEGO; WINDSOR CARE CENTER NATIONAL
`
`s CITY, INC.; WINDSOR TERRACE HEALTHCARE, LLC; WINDSOR COURT ASSISTED
`
`6
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`7
`
`8
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`9
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`LIVING, LLC; WINDSOR WESTLAKE HEALTHCARE, LLC and DOES 1 to 200, inclusive
`
`(collectively "Defendants") as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`This is a Private Attorneys' General Act of 2004, Lab. Code § 2698, et seq.
`
`10
`
`("PAGA'}
`
`representative action brought by Plaintiffs on behalf of the State of California,
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`11
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`themselves and other current and former aggrieved employees of Defendants who worked as
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`12 hourly, non-exempt employees, in California during the relevant time period seeking civil
`
`13
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`penalties associated with Defendants' violation of the Labor Code based on Defendant's failure to
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`14 provide all legally required and legally compliant meal and rest periods, failure to timely pay
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`15
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`earned wages during employment, failure to provide complete and accurate wage statements, and
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`16
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`failure to timely pay all unpaid wages following separation of employment. Plaintiffs seek on a
`
`17
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`representative basis, following notice to the Labor and Workforce Development Agency, civil
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`18 penalties, reasonable attorney's fees pursuant to Labor Code section 2699(g)(l) and costs brought
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`19 on behalf of Plaintiffs, the State of California, and others aggrieved.
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`20
`
`II.
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`JURISDICTION AND VENUE
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`21
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`2.
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`This Court has jurisdiction over Plaintiffs and other current and former aggrieved
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`22 hourly non-exempt California-based employees' claims because Plaintiffs' lawsuit seeks damages
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`23
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`in excess of $25,000 and Defendants employed the aggrieved employees in California and injuries
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`24 occurred in locations in California including, but not limited to, Los Angeles County at 3533
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`25 Motor Av., Los Angeles, CA 90034.
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`26
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`II I
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`21
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`28
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`I I I
`
`I I I
`
`COMPLAINT
`3
`
`EXHIBIT 1
`
`Page 16
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`

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`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 4 of 22 Page ID #:23
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`III.
`
`PARTIES
`
`2
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`3.
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`Plaintiffs bring this action as a representative of the Labor and Workforce
`
`3 Development Agency on behalf of themselves, the State of California, and other current and
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`4
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`5
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`former employees subject to violations of the Labor Code. The named Plaintiffs and the persons
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`on whose behalf this action is filed include current, former and/or future employees of Defendants
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`6 who worked, work, or will work for Defendants as non-exempt hourly employees in California. At
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`7
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`8
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`9
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`all times mentioned herein, the currently named Plaintiffs are and were domiciled and residents
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`and citizens of California and were employed by Defendants in hourly positions at Defendants'
`
`location in Los Angeles
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`4.
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`Plaintiff GLORIBEL TURCIOS was employed by Defendants from approximately
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`11 April 3, 2019, until her termination on or about March 16, 2020.
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`12
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`5.
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`Plaintiff KAMLESH KUMAR was employed by Defendants from approximately
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`13 May 23, 2014, until her termination on or about April 12, 2021.
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`14
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`6.
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`Plaintiff YARA MADINA has been employed by Defendants since approximately
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`15 November 2019.
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`16
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`17
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`7.
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`Plaintiffs are informed and believe and thereon allege that Defendant CPE HR,
`
`INC. is authorized to do business within the State of California and is doing business in the State
`
`18 of California and/or that Defendants DOES 1-5 are, and at all times relevant hereto were persons
`
`19
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`acting on behalf of Defendant CPE HR, INC. in the establishment of, or ratification of, the
`
`20
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`aforementioned illegal wage and hour practices or policies. Defendant CPE HR, INC. operates in
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`21 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
`
`22
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`exempt California-based employees in Los Angeles County, including but not limited to, at 7590
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`23 N. Glenoaks Boulevard, Burbank CA, 91504.
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`24
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`8.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`25 CHEVIOT HILLS, LLC is authorized to do business within the State of California and is doing
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`26 business in the State of California and/or that Defendants DOES 6-10 are, and at all times relevant
`
`27 hereto were persons acting on behalf of Defendant WINDSOR CHEVIOT HILLS, LLC in the
`
`28
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`establishment of, or ratification of, the aforementioned illegal wage and hour practices or policies.
`
`COMPLAINT
`4
`
`EXHIBIT 1
`
`Page 17
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 5 of 22 Page ID #:24
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`Defendant WINDSOR CHEVIOT HILLS, LLC operates in Los Angeles County and employed
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`Plaintiffs and other current and former aggrieved hourly non-exempt California-based employees
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`in Los Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
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`9.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
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`2
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`3
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`4
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`5 CARE CENTER OF CHEVIOT HILLS is authorized to do business within the State of California
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`6
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`7
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`and is doing business in the State of California and/or that Defendants DOES 11-15 are, and at all
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`times relevant hereto were persons acting on behalf of Defendant WINDSOR CARE CENTER OF
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`8 CHEVIOT HILLS in the establishment of, or ratification of, the aforementioned illegal wage and
`
`9
`
`hour practices or policies. Defendant WINDSOR CARE CENTER OF CHEVIOT HILLS operates
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`10
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`11
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`in Los Angeles County and employed Plaintiff and other current and former aggrieved hourly non-
`
`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
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`12 Motor Ave, Los Angeles, CA 90034.
`
`13
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`10.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`14 CONVALESCENT AND REHABILITATION CENTER OF CONCORD, LLC is authorized to
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`15 do business within the State of California and is doing business in the State of California and/or
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`16
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`that Defendants DOES 16-20 are, and at all times relevant hereto were persons acting on behalf of
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`17 Defendant WINDSOR CONVALESCENT AND REHABILITATION CENTER OF CONCORD,
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`18 LLC in the establishment of, or ratification of, the aforementioned illegal wage and hour practices
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`19 or policies. Defendant WINDSOR CONVALESCENT AND REHABILITATION CENTER OF
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`20 CONCORD, LLC operates in Los Angeles County and employed Plaintiffs and other current and
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`21
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`former aggrieved hourly non-exempt California-based employees in Los Angeles County,
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`22
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`including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
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`23
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`11.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
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`24 COUNTRY DRIVE CARE CENTER, LLP is authorized to do business within the State of
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`25 California and is doing business in the State of California and/or that Defendants DOES 21-25 are,
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`26
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`and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR
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`27 COUNTRY DRIVE CARE CENTER, LLP in the establishment of, or ratification of, the
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`28
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`aforementioned illegal wage and hour practices or policies. Defendant WINDSOR COUNTRY
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`COMPLAINT
`5
`
`EXHIBIT 1
`
`Page 18
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`

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`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 6 of 22 Page ID #:25
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`DRIVE CARE CENTER, LLP operates in Los Angeles County and employed Plaintiff and other
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`2
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`current and former aggrieved hourly non-exempt California-based employees in Los Angeles
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`3 County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
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`4
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`12.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`s EL CAMINO CARE CENTER, LLC is authorized to do business within the State of California
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`6
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`7
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`and is doing business in the State of California and/or that Defendants DOES 26-30 are, and at all
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR EL CAMINO
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`8 CARE CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage
`
`9
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`and hour practices or policies. Defendant WINDSOR EL CAMINO CARE CENTER, LLC
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`10 operates in Los Angeles County and employed Plaintiffs and other current and former aggrieved
`
`11
`
`12
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`13
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`hourly non-exempt California-based employees in Los Angeles County, including but not limited
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`to, at 3533 Motor Ave, Los Angeles, CA 90034.
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`13.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
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`14 ELK GROVE CARE AND REHABILITATION, LLC is authorized to do business within the
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`15 State of California and is doing business in the State of California and/or that Defendants DOES
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`16 31-35 are, and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR
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`17 ELK GROVE CARE AND REHABILITATION, LLC in the establishment of, or ratification of,
`
`18
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`the aforementioned illegal wage and hour practices or policies. Defendant WINDSOR ELK
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`19 GROVE CARE AND REHABILITATION, LLC operates in Los Angeles County and employed
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`20 Plaintiffs and other current and former aggrieved hourly non-exempt California-based employees
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`21
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`in Los Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`22
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`14.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
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`23 ELMHA VEN CARE CENTER, LLC is authorized to do business within the State of California
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`24
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`and is doing business in the State of California and/or that Defendants DOES 36-40 are, and at all
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`25
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`times relevant hereto were persons acting on behalf of Defendant WINDSOR ELMHA VEN
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`26 CARE CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage
`
`27
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`and hour practices or policies. Defendant WINDSOR ELMHA VEN CARE CENTER, LLC
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`28 operates in Los Angeles County and employed Plaintiffs and other current and former aggrieved
`
`COMPLAINT
`6
`
`EXHIBIT 1
`
`Page 19
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 7 of 22 Page ID #:26
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`hourly non-exempt California-based employees in Los Angeles County, including but not limited
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`to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`15.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`2
`
`3
`
`4 CONVALESCENT AND REHABILITATION CENTER OF FREMONT, LLC is authorized to
`
`5
`
`6
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`do business within the State of California and is doing business in the State of California and/or
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`that Defendants DOES 41-45 are, and at all times relevant hereto were persons acting on behalf of
`
`7 Defendant WINDSOR CONVALESCENT AND REHABILITATION CENTER OF FREMONT,
`
`8 LLC in the establishment of, or ratification of, the aforementioned illegal wage and hour practices
`
`9
`
`or policies. Defendant WINDSOR CONY ALESCENT AND REHABILITATION CENTER OF
`
`10 FREMONT, LLC operates in Los Angeles County and employed Plaintiffs and other current and
`
`11
`
`12
`
`13
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`former aggrieved hourly non-exempt California-based employees in Los Angeles County,
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`including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`16.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`14 GARDENS HEALTHCARE CENTER OF HAYWARD, LLC is authorized to do business within
`
`15
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`the State of California and is doing business in the State of California and/or that Defendants
`
`16 DOES 46-50 are, and at all times relevant hereto were persons acting on behalf of Defendant
`
`17 WINDSOR GARDENS HEALTHCARE CENTER OF HAYWARD, LLC in the establishment
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`18 of, or ratification of, the aforementioned illegal wage and hour practices or policies. Defendant
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`19 WINDSOR GARDENS HEALTHCARE CENTER OF HAYWARD, LLC operates in Los
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`20 Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
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`21
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`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
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`22 Motor Ave, Los Angeles, CA 90034.
`
`23
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`17.
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`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`24 HAYWARD ESTA TES, LLC is authorized to do business within the State of California and is
`
`25 doing business in the State of California and/or that Defendants DOES 51-55 are, and at all times
`
`26
`
`relevant hereto were persons acting on behalf of Defendant WINDSOR HAYWARD ESTA TES,
`
`27 LLC in the establishment of, or ratification of, the aforementioned illegal wage and hour practices
`
`28 or policies. Defendant WINDSOR HAYWARD ESTATES, LLC operates in Los Angeles County
`
`COMPLAINT
`7
`
`EXHIBIT 1
`
`Page 20
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 8 of 22 Page ID #:27
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`1
`
`2
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`and employed Plaintiffs and other current and former aggrieved hourly non-exempt California-
`
`based employees in Los Angeles County, including but not limited to, at 3533 Motor Ave, Los
`
`3 Angeles, CA 90034.
`
`4
`
`18.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`5 HAMPTON CARE CENTER, LLC is authorized to do business within the State of California and
`
`6
`
`7
`
`is doing business in the State of California and/or that Defendants DOES 56-60 are, and at all
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR HAMPTON CARE
`
`8 CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage and
`
`9
`
`hour practices or policies. Defendant WINDSOR HAMPTON CARE CENTER, LLC operates in
`
`10 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non(cid:173)
`
`ll exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`12 Motor Ave, Los Angeles, CA 90034.
`
`13
`
`19.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`14 MONTEREY CARE CENTER, LLC is authorized to do business within the State of California
`
`15
`
`16
`
`and is doing business in the State of California and/or that Defendants DOES 61-65 are, and at all
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR MONTEREY
`
`17 CARE CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage
`
`18
`
`and hour practices or policies. Defendant WINDSOR MONTEREY CARE CENTER, LLC
`
`19 operates in Los Angeles County and employed Plaintiffs and other current and former aggrieved
`
`20 hourly non-exempt California-based employees in Los Angeles County, including but not limited
`
`21
`
`to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`22
`
`20.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`23 SACRAMENTO ESTATES, LLC is authorized to do business within the State of California and
`
`24
`
`is doing business in the State of California and/or that Defendants DOES 66-70 are, and at all
`
`25
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR SACRAMENTO
`
`26 EST A TES, LLC in the establishment of, or ratification of, the aforementioned illegal wage and
`
`27 hour practices or policies. Defendant WINDSOR SACRAMENTO ESTATES, LLC operates in
`
`28 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
`
`COMPLAINT
`8
`
`EXHIBIT 1
`
`Page 21
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 9 of 22 Page ID #:28
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`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`2 Motor Ave, Los Angeles, CA 90034.
`
`3
`
`21.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`4 THE RIDGE REHABILITATION CENTER, LLC is authorized to do business within the State of
`
`5 California and is doing business in the State of California and/or that Defendants DOES 71-75 are,
`
`6
`
`and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR THE
`
`7 RIDGE REHABILITATION CENTER, LLC in the establishment of, or ratification of, the
`
`8
`
`aforementioned illegal wage and hour practices or policies. Defendant WINDSOR THE RIDGE
`
`9 REHABILITATION CENTER, LLC operates in Los Angeles County and employed Plaintiffs and
`
`10
`
`other current and former aggrieved hourly non-exempt California-based employees in Los
`
`11 Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`12
`
`22.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`13 CONVALESCENT AND REHABILITATION CENTER OF SALINAS, LLC is authorized to do
`
`14
`
`business within the State of California and is doing business in the State of California and/or that
`
`15 Defendants DOES 76-80 are, and at all times relevant hereto were persons acting on behalf of
`
`16 Defendant WINDSOR CONVALESCENT AND REHABILITATION CENTER OF SALINAS,
`
`17 LLC in the establishment of, or ratification of, the aforementioned illegal wage and hour practices
`
`18 or policies. Defendant WINDSOR CONVALESCENT AND REHABILITATION CENTER OF
`
`19 SALINAS, LLC operates in Los Angeles County and employed Plaintiffs and other current and
`
`20
`
`former aggrieved hourly non-exempt California-based employees in Los Angeles County,
`
`21
`
`22
`
`including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`23.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`23 SKYLINE CARE CENTER, LLC is authorized to do business within the State of California and is
`
`24 doing business in the State of California and/or that Defendants DOES 81-85 are, and at all times
`
`25
`
`relevant hereto were persons acting on behalf of Defendant WINDSOR SKYLINE CARE
`
`26 CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage and
`
`27 hour practices or policies. Defendant WINDSOR SKYLINE CARE CENTER, LLC operates in
`
`28 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
`
`COMPLAINT
`9
`
`EXHIBIT 1
`
`Page 22
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 10 of 22 Page ID #:29
`
`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`2 Motor Ave, Los Angeles, CA 90034.
`
`3
`
`24.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`4 ROSEWOOD CARE CENTER, LLC is authorized to do business within the State of California
`
`5
`
`6
`
`and is doing business in the State of California and/or that Defendants DOES 86-90 are, and at all
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR ROSEWOOD
`
`7 CARE CENTER, LLC in the establishment of, or ratification of, the aforementioned ilJegal wage
`
`8
`
`9
`
`and hour practices or policies. Defendant WINDSOR ROSEWOOD CARE CENTER, LLC
`
`operates in Los Angeles County and employed Plaintiff and other current and former aggrieved
`
`lO
`
`hourly non-exempt California-based employees in Los Angeles County, including but not limited
`
`U
`
`to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`12
`
`25.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`13 VALLEJO CARE CENTER, LLC is authorized to do business within the State of California and
`
`14
`
`15
`
`is doing business in the State of California and/or that Defendants DOES 91-95 are, and at all
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR VALLEJO CARE
`
`16 CENTER, LLC in the establishment of, or ratification of, the aforementioned illegal wage and
`
`17 hour practices or policies. Defendant WINDSOR VALLEJO CARE CENTER, LLC operates in
`
`18 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
`
`19
`
`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`20 Motor Ave, Los Angeles, CA 90034.
`
`21
`
`26.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`22 CARE CENTER OF PETALUMA, LLC is authorized to do business within the State of
`
`23 California and is doing business in the State of California and/or that Defendants DOES 96-100
`
`24
`
`are, and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR CARE
`
`25 CENTER OF PETALUMA, LLC in the establishment of, or ratification of, the aforementioned
`
`26
`
`illegal wage and hour practices or policies. Defendant WINDSOR CARE CENTER OF
`
`27 PETALUMA, LLC operates in Los Angeles County and employed Plaintiffs and other current and
`
`28
`
`former aggrieved hourly non-exempt California-based employees in Los Angeles County,
`
`COMPLAINT
`10
`
`EXHIBIT 1
`
`Page 23
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 11 of 22 Page ID #:30
`
`including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`2
`
`27.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`3 HEAL TH CARE GOLDEN PALMS, LLC is authorized to do business within the State of
`
`4 California and is doing business in the State of California and/or that Defendants DOES 101-105
`
`5
`
`are, and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR
`
`6 HEALTHCARE GOLDEN PALMS, LLC in the establishment of, or ratification of, the
`
`7
`
`aforementioned
`
`illegal wage and hour practices or policies. Defendant WINDSOR
`
`8 HEALTHCARE GOLDEN PALMS, LLC operates in Los Angeles County and employed
`
`9
`
`Plaintiffs and other current and former aggrieved hourly non-exempt California-based employees
`
`10
`
`in Los Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`11
`
`28.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`12 TWIN PALMS HEALTHCARE CENTER, LLC is authorized to do business within the State of
`
`13 California and is doing business in the State of California and/or that Defendants DOES 106-110
`
`14
`
`are, and at alJ times relevant hereto were persons acting on behalf of Defendant WINDSOR TWIN
`
`15 PALMS HEALTHCARE CENTER, LLC in the establishment of, or ratification of, the
`
`16
`
`aforementioned illegal wage and hour practices or policies. Defendant WINDSOR TWIN PALMS
`
`17 HEALTHCARE CENTER, LLC operates in Los Angeles County and employed Plaintiffs and
`
`18
`
`other current and former aggrieved hourly non-exempt California-based employees in Los
`
`19 Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`20
`
`29.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`21 ARVIN HEALTHCARE, LLC is authorized to do business within the State of California and is
`
`22 doing business in the State of California and/or that Defendants DOES 111-115 are, and at all
`
`23
`
`times relevant hereto were persons acting on behalf of Defendant WINDSOR ARVIN
`
`24 HEALTHCARE, LLC in the establishment of, or ratification of, the aforementioned illegal wage
`
`25
`
`and hour practices or policies. Defendant WINDSOR ARVIN HEALTHCARE, LLC operates in
`
`26 Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly non-
`
`27
`
`exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`28 Motor Ave, Los Angeles, CA 90034.
`
`COMPLAINT
`11
`
`EXHIBIT 1
`
`Page 24
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 12 of 22 Page ID #:31
`
`30.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`2 BAKERSFIELD HEAL TH CARE, LLC is authorized to do business within the State of California
`
`3
`
`4
`
`and is doing business in the State of California and/or that Defendants DOES 116-120 are, and at
`
`all times relevant hereto were persons acting on behalf of Defendant WINDSOR BAKERSFIELD
`
`5 HEALTHCARE, LLC in the establishment of, or ratification of, the aforementioned illegal wage
`
`6
`
`7
`
`8
`
`9
`
`10
`
`and hour practices or policies. Defendant WINDSOR BAKERSFIELD HEALTHCARE, LLC
`
`operates in Los Angeles County and employed Plaintiffs and other current and fonner aggrieved
`
`hourly non-exempt California-based employees in Los Angeles County, including but not limited
`
`to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`31.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`11 CYPRESS GARDENS HEALTHCARE LLC is authorized to do business within the State of
`
`12 California and is doing business in the State of California and/or that Defendants DOES 121-125
`
`13
`
`are, and at all times relevant hereto were persons acting on behalf of Defendant WINDSOR
`
`14 CYPRESS GARDENS HEAL TH CARE LLC in the establishment of, or ratification of, the
`
`15
`
`aforementioned illegal wage and hour practices or policies. Defendant WINDSOR CYPRESS
`
`16 GARDENS HEALTHCARE LLC operates in Los Angeles County and employed Plaintiffs and
`
`17 other current and former aggrieved hourly non-exempt California-based employees in Los
`
`18 Angeles County, including but not limited to, at 3533 Motor Ave, Los Angeles, CA 90034.
`
`19
`
`32.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`20 GARDENS CONY ALESCENT CENTER OF LONG BEACH is authorized to do business within
`
`21
`
`the State of California and is doing business in the State of California and/or that Defendants
`
`22 DOES 126-130 are, and at all times relevant hereto were persons acting on behalf of Defendant
`
`23 WINDSOR GARDENS CONVALESCENT CENTER OF LONG BEACH in the establishment
`
`24 of, or ratification of, the aforementioned illegal wage and hour practices or policies. Defendant
`
`25 WINDSOR GARDENS CONY ALESCENT CENTER OF LONG BEACH operates in Los
`
`26 Angeles County and employed Plaintiffs and other current and fonner aggrieved hourly non-
`
`27 exempt California-based employees in Los Angeles County, including but not limited to, at 3533
`
`28 Motor Ave, Los Angeles, CA 90034.
`
`COMPLAINT
`12
`
`EXHIBIT 1
`
`Page 25
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 13 of 22 Page ID #:32
`
`33.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`2 CONVALESCENT CENTER OF NORTH LONG BEACH is authorized to do business within the
`
`3
`
`4
`
`State of California and is doing business in the State of California and/or that Defendants DOES
`
`131-135 are, and at all times relevant hereto were persons acting on behalf of Defendant
`
`s WINDSOR CONY ALESCENT CENTER OF NORTH LONG BEACH in the establishment of, or
`
`6
`
`ratification of, the aforementioned illegal wage and hour practices or policies. Defendant
`
`7 WINDSOR CONY ALESCENT CENTER OF NORTH LONG BEACH operates in Los Angeles
`
`8 County and employed Plaintiffs and other current and former aggrieved hourly non-exempt
`
`9 California-based employees in Los Angeles County, including but not limited to, at 3533 Motor
`
`to Ave, Los Angeles, CA 90034.
`
`11
`
`34.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`12 GARDENS CONVALESCENT HOSPITAL OF LOS ANGELES is authorized to do business
`
`13 within the State of California and is doing business in the State of California and/or that
`
`14 Defendants DOES 136-140 are, and at all times relevant hereto were persons acting on behalf of
`
`15 Defendant WINDSOR GARDENS CONVALESCENT HOSPITAL OF LOS ANGELES in the
`
`16
`
`establishment of, or ratification of, the aforementioned illegal wage and hour practices or policies.
`
`17 Defendant WINDSOR GARDENS CONVALESCENT HOSPITAL OF LOS ANGELES operates
`
`18
`
`in Los Angeles County and employed Plaintiffs and other current and former aggrieved hourly
`
`19 non-exempt California-based employees in Los Angeles County, including but not limited to, at
`
`20 3533 Motor Ave, Los Angeles, CA 90034.
`
`21
`
`35.
`
`Plaintiffs are informed and believe and thereon allege that Defendant WINDSOR
`
`22 GARDENS CONVALESCENT CENTER OF SAN DIEGO is authorized to do business within
`
`23
`
`the State of California and is doing business in the State of California and/or that Defendants
`
`24 DOES 141-145 are, and at all times relevant hereto were persons acting on behalf of Defendant
`
`25 WINDSOR GARDENS CONY ALESCENT CENTER OF SAN DIEGO in the establishment of,
`
`26 or ratification of, the aforementioned illegal wage and hour practices or policies. Defendant
`
`27 WINDSOR GARDENS CONVALESCENT CENTER OF SAN DIEGO operates in Los Angeles
`
`28 County and employed Plaintiffs and other current and former aggrieved hourly non-exempt
`
`COMPLAINT
`13
`
`EXHIBIT 1
`
`Page 26
`
`

`

`Case 2:21-mc-01089 Document 1-1 Filed 10/29/21 Page 14 of 22 Page ID #:33
`
`California-based em

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