On October 04, 2021 a
Complaint,Petition
was filed
involving a dispute between
Harper, Richard,
and
Does 1 Through 20,
Hamner Towing, Inc.,
for Complex Civil Unlimited
in the District Court of San Bernardino County.
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From: GFI FaxMalmr To: 19097088586 Page: 3/36 Date: 12/6/2021 12:15:29 PM
\r \y
l L E D
supemoa COURT 0F CALIFORNIA
Brian J. Mankin, Esq. [CSB N0. 216228]
COUNTY 0F SAN BERNARmNO
bria’1@lmmrm-60m SAN BERNAnomo DISTRICT
Peter .Carlson, Esq. [CSB No. 29561 1]
peter ,1mlfirm.com DEC " 6 2021
LAU Y, MANKIN & LAUBY LLP /',
4590 Allstate Drive , \flxtjfiw a
BY
Riverside, CA 92501 /Z’Amlg PE’RRY, £55pr
Tel; (951)320—1444
Fax: (951) 320-1445
Attorneys for Plaintiff, on a representative basis and on behalf of all others similarly situated
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
RICHARD HARPER, individually,on a Case No.2 CIVSB 2127523
representative basis, and on behalfofall AW "ed ’0 H0” Judge DWid COW: Dept
26’ 0" allPurposes]
others similarly situated;
FIRSTAMENDED CLASS AND
Plaintiff, REPRESENTATIVE COMPLAINT
vs. CLASS ACTION CLAIMS
HAMNER TOWING, INC, a California (1) Failure t0 Pay Minimum Wages;
Corporation; and DOES 1 through 20, (2) Failure t0 Pay overtlme wages:
inclusivs; (3) Failure to Provide Meal Periods; Fax
(4) Failure to Provide Rest Breaks;
Failure to Reimburse Bus. Expenses;
Defendants (5)
(6) Failure to Timely Pay Final Wages; BY
(7) Failure to Provide Accurate Itemized
Wage Statements;
(8) Unfair and Unlawfill Competition;
PAGA CLAIMS
(9) Failure to Pay Minimum Wages;
(10) Failure to Pay Ovelfims Wages;
(1 1) Failure to Provide Meal Periods;
(1 2) Failure to Provide Rest Breaks;
(13) Failure to Reimburse Bus. Expenses;
(14) Failure to Timely Pay Wages;
(15) Failure t0 Timely Pay Final Wages; and
(16) Failure to Provide Accurate Itemized
Wage Statements
Complaint Filed: October 4, 2021
FIRST AMENDED CLASS AND PAGA COMPLAINT
-1-
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Document Filed Date
December 06, 2021
Case Filing Date
October 04, 2021
Category
Complex Civil Unlimited
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From: GFI FaxMalmr To: 19097088586 Page: 3/36 Date: 12/6/2021 12:15:29 PM \r \y l L E D supemoa COURT 0F CALIFORNIA Brian J. Mankin, Esq. [CSB N0. 216228] COUNTY 0F SAN BERNARmNO bria’1@lmmrm-60m SAN BERNAnomo DISTRICT Peter .Carlson, Esq. [CSB No. 29561 1] peter ,1mlfirm.com DEC " 6 2021 LAU Y, MANKIN & LAUBY LLP /', 4590 Allstate Drive , \flxtjfiw a BY Riverside, CA 92501 /Z’Amlg PE’RRY, £55pr Tel; (951)320—1444 Fax: (951) 320-1445 Attorneys for Plaintiff, on a representative basis and on behalf of all others similarly situated SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO RICHARD HARPER, individually,on a Case No.2 CIVSB 2127523 representative basis, and on behalfofall AW "ed ’0 H0” Judge DWid COW: Dept 26’ 0" allPurposes] others similarly situated; FIRSTAMENDED CLASS AND Plaintiff, REPRESENTATIVE COMPLAINT vs. CLASS ACTION CLAIMS HAMNER TOWING, INC, a California (1) Failure t0 Pay Minimum Wages; Corporation; and DOES 1 through 20, (2) Failure t0 Pay overtlme wages: inclusivs; (3) Failure to Provide Meal Periods; Fax (4) Failure to Provide Rest Breaks; Failure to Reimburse Bus. Expenses; Defendants (5) (6) Failure to Timely Pay Final Wages; BY (7) Failure to Provide Accurate Itemized Wage Statements; (8) Unfair and Unlawfill Competition; PAGA CLAIMS (9) Failure to Pay Minimum Wages; (10) Failure to Pay Ovelfims Wages; (1 1) Failure to Provide Meal Periods; (1 2) Failure to Provide Rest Breaks; (13) Failure to Reimburse Bus. Expenses; (14) Failure to Timely Pay Wages; (15) Failure t0 Timely Pay Final Wages; and (16) Failure to Provide Accurate Itemized Wage Statements Complaint Filed: October 4, 2021 FIRST AMENDED CLASS AND PAGA COMPLAINT -1- This fax was sent with GFI FaxMaker fax server. For more information, visit: httpzllwmgficom ofi?’ ’ wwe£ifi7¢$9§§zgftf§§goé§fg ll 120290 gs :30 aamaaau q I V V