Defendant Jade Global, Inc. (“Defendant”) moves to strike portions of the First Amended Complaint (“FAC”) filed by plaintiff Jai Kumar (“Plaintiff”).
I. Background
A. Factual
This is a representative action under the Private Attorney General Act of 2004 (“PAGA”) for civil penalties for various Labor Code violations purportedly committed by Defendant.
According to the allegations of the FAC, Defendant is an IT Services company headquartered in San Jose. (FAC, ¶ 10.) Plaintiff was hired in November 2013 and over the course of the next six years held various positions in the company until he was terminated in December 2019. (Id., ¶ 11.) He alleges that Defendant wrongfully demanded that he not discuss concerns about his compensation with other employees on the grounds that doing so would be in violation of company policy. (Id., ¶ 15.)
On June 25, 2019, Defendant emailed a document entitled “Jade Global FY20 LOB & Practice Leaders Variable Compensation Plan (“VCP”) to Plaintiff and ot
Hearing Date
September 10, 2020
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Defendant Jade Global, Inc. (“Defendant”) moves to strike portions of the First Amended Complaint (“FAC”) filed by plaintiff Jai Kumar (“Plaintiff”).
I. Background
A. Factual
This is a representative action under the Private Attorney General Act of 2004 (“PAGA”) for civil penalties for various Labor Code violations purportedly committed by Defendant.
According to the allegations of the FAC, Defendant is an IT Services company headquartered in San Jose. (FAC, ¶ 10.) Plaintiff was hired in November 2013 and over the course of the next six years held various positions in the company until he was terminated in December 2019. (Id., ¶ 11.) He alleges that Defendant wrongfully demanded that he not discuss concerns about his compensation with other employees on the grounds that doing so would be in violation of company policy. (Id., ¶ 15.)
On June 25, 2019, Defendant emailed a document entitled “Jade Global FY20 LOB & Practice Leaders Variable Compensation Plan (“VCP”) to Plaintiff and ot