`Case 2:17-cv—00140-RWS—RSP Document 27-9 Filed 07/14/17 Page 1 of 2 PageID #: 598
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`EXHIBIT I
`EXHIBIT I
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`Case 2:17-cv-00140-RWS-RSP Document 27-9 Filed 07/14/17 Page 2 of 2 PageID #: 599
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`Responses2
`25. The allegations in this paragraph
`amount to legal conclusions to which no
`answer is required. To the extent that this
`paragraph contains factual allegations
`DEFENDANT denies.
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`52. The allegations in this paragraph
`amount to legal conclusions to which no
`answer is required. To the extent that this
`paragraph contains factual allegations
`DEFENDANT denies.
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`Allegation1
`25. Pursuant to California Labor Code
`§ 2699.3 and other provisions of California
`law, Plaintiffs have exhausted all
`administrative remedies and satisfied all
`private, administrative, and judicial
`prerequisites to the institution of this
`action. Specifically, on February 28, 2011
`Plaintiffs sent written notice by certified
`mail to the California Labor and Workforce
`Development Agency (LWDA) and the
`employer including specific provisions of
`the Labor Code that have been violated and
`facts and theories to support such
`violations. To-date, more than 33 calendar
`days after the postmark date of Plaintiffs
`written notice, Plaintiffs have not received a
`response from the LWDA.
`52. By effecting the above alleged unlawful
`deductions, Defendants have violated
`California Labor Code § 221 which
`provides that: “It shall be unlawful for any
`employer to collect or receive from an
`employee any part of wages theretofore
`paid by said employer to said employee.”
`This statute and other provisions of the
`California Labor and Civil Codes impose
`strict limitations on an employer’s right to
`withhold or deduct unauthorized amounts
`from employees’ wages.
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`1 Ex. D.
`2 Ex. E.
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