21CV00200
REED v. RAMANUJAM et al.
PLAINTIFF REED’S MOTION FOR SUMMARY JUDGMENT/ADJUDICATION
As explained below, Plaintiff’s motion for summary adjudication as to liability is granted
as to causes of action for (1) failure to pay overtime, (2) failure to provide meal periods or
additional wages, (3) failure to provide rest periods or additional wages, (4) failure to issue
accurate wage statements, (5) failure to timely pay wages upon termination, and 11 claims for
civil penalties under the Labor Code. Plaintiff’s motion is also granted as to personal liability by
Dr. Thalia Ramanujam for violations of the Labor Code as to the aforementioned claims.
Defendants’ remaining claims of theft, conversion and deceit in their First Amended
Cross-Complaint are subject to summary judgment since no reasonable jury could find evidence
that Plaintiff falsified her time records.
I. INTRODUCTION
This is an action for wage and hour violations brought by an infusion nu