On September 24, 2019 a
Complaint,Petition
was filed
involving a dispute between
Dominguez Damian,
and
Does 1 Through 25,
Lake Lindero Homeowner'S Association Inc.,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/30/2020 11:45 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Tang,Deputy Clerk
1 AARON C. GUNDZIK (State Bar No. 13213 7)
REBECCA G. GUNDZIK(StateBarNo. 138446)
2 GUNDZIK GUNDZIK HEEG ER LLP
14011 Ventura Blvd., Suite 206E
3 Sherman Oaks, CA 91423
Telephone: (818) 290-7461
4 Facsimile: (818) 918-2316
5 Attorneys for Plaintiff Damian Dominguez
6
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
10 DAMIAN DOMINGUEZ, an individual, Case No.: 19STCV33951
Assigned to Hon. Elizabeth A. White,
11 Plaintiff, Department 48
12 vs. FIRST AMENDED UNLIMITED
CIVIL COMPLAINT FOR:
13 LAKE LIND ERO HOMEOWNER'S
ASSOCIATIONINC.,aCalifomia 1. Violation of Labor Code §510
14 (Failure to Pay Overtime Premium
Corporation, and DOES 1 through 25,
15 Wages)
Defendants. 2. Violation of Labor Code §§226. 7 and
16 512(a) (Failure to Provide Meal and
Rest Breaks)
17 3. Violation of Labor Code § 226(a)
(Inaccurate Wage Statements)
18
4. Violation of Labor Code §§201 and
19 202 (Failure to Pay Unpaid Wages at
Time of Discharge)
20 5. Violation of Labor Code§ 1174
(Failure to Maintain Time Records)
21 6. Recovery of Civil Penalties, Labor
Code§§ 2698-2699.5
22
Jury Trial Demanded
23
24 PARTIES, JURJSD [CTI ON AND VENUE
25 1. Plaintiff Damian Dominguez is an individual and resident of Thousand Oaks,
26 California. Plaintiff was employed by Defendants as a groundskeeper and kitchen worker in
27 2019 in Defendant's country club.
28
1
FIRST AMENDED COMPLAINT
Document Filed Date
January 30, 2020
Case Filing Date
September 24, 2019
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 03/15/2021
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Electronically FILED by Superior Court of California, County of Los Angeles on 01/30/2020 11:45 AM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Tang,Deputy Clerk 1 AARON C. GUNDZIK (State Bar No. 13213 7) REBECCA G. GUNDZIK(StateBarNo. 138446) 2 GUNDZIK GUNDZIK HEEG ER LLP 14011 Ventura Blvd., Suite 206E 3 Sherman Oaks, CA 91423 Telephone: (818) 290-7461 4 Facsimile: (818) 918-2316 5 Attorneys for Plaintiff Damian Dominguez 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES 10 DAMIAN DOMINGUEZ, an individual, Case No.: 19STCV33951 Assigned to Hon. Elizabeth A. White, 11 Plaintiff, Department 48 12 vs. FIRST AMENDED UNLIMITED CIVIL COMPLAINT FOR: 13 LAKE LIND ERO HOMEOWNER'S ASSOCIATIONINC.,aCalifomia 1. Violation of Labor Code §510 14 (Failure to Pay Overtime Premium Corporation, and DOES 1 through 25, 15 Wages) Defendants. 2. Violation of Labor Code §§226. 7 and 16 512(a) (Failure to Provide Meal and Rest Breaks) 17 3. Violation of Labor Code § 226(a) (Inaccurate Wage Statements) 18 4. Violation of Labor Code §§201 and 19 202 (Failure to Pay Unpaid Wages at Time of Discharge) 20 5. Violation of Labor Code§ 1174 (Failure to Maintain Time Records) 21 6. Recovery of Civil Penalties, Labor Code§§ 2698-2699.5 22 Jury Trial Demanded 23 24 PARTIES, JURJSD [CTI ON AND VENUE 25 1. Plaintiff Damian Dominguez is an individual and resident of Thousand Oaks, 26 California. Plaintiff was employed by Defendants as a groundskeeper and kitchen worker in 27 2019 in Defendant's country club. 28 1 FIRST AMENDED COMPLAINT