EXHIBIT "1"

Case: 19-30088 Doc# 4370-2 Filed: 10/21/19 Entered: 10/21/19 23:26:35 Page 1

of 12
(estimated)

under California Labor Code section 203

up to $

per putative 

class member

BIO (Official Form I 0) (04/13) 

UNITED STATES BANKRUPTCY COURT Northern District of California PROOF OF CLAIM 

Name of Debtor: Case Number: 

Pacific Gas and Electric Corporation 19-30088

COURT USE ONLY 

NOTE: Do not use this form to make a claim for an administrative expense that arises qfter the bankruptcy filing. You 

mayfile a request forpayment of an administrative expense according to 11 U.S. C. § 503. 

Name of Creditor (the person or other entity to whom the debtor owes money or property): 

Dave Alonzo. as an individual and on behalf of all similarly situated. 

Name and address where notices should be sent: 0 Check this box if this claim amends a 

John E. Lattin previously filed claim. 

OSTERGAR LAW GROUP P.C. 

9110 Irvine Center Drive, Irvine, CA 92618 Court Claim Number: 

(if known) 

Telephone number: (949) 357-2544 email: jlattin�osterqar.com

Filed on: 

Name and address where payment should be sent (if different from above): 0 Check this box if you are aware that 

anyone else has filed a proof of claim 

relating to this claim. Attach copy of 

statement giving particulars. 

Telephone number: email: 

1. Amount of Claim as of Date Case Filed: $ 1 o,uuu,uuu.uu 

If all or part of the claim is secured, complete item 4. 

If all or part of the claim is entitled to priority, complete item 5.

0 Check this box if the claim includes interest or other charges in addition to the principal amount of the claim. Attach a statement that itemizes interest or charges. 

2. Basis for Claim: Failure to pay final waqes timely and waitinq time penalties

(See instruction #2)

3. Last four digits of any number Ja. Debtor may have scheduled account as: 3b. Uniform Oaim Identifier (optional): 

by which creditor identifies debtor:

4 9 1 4 (See instruction #3a) (See instruction #3b) 

Amount of arrearage and other charges, as of the time case was filed, 

4. Secured Claim (See instruction #4) included in secured claim, if any: 

Check the appropriate box if the claim is secured by a lien on property or a right of

setoff, attach required redacted documents, and provide the requested information. $ 

Nature of property or right of setoff: 0 Real Estate □Motor Vehicle OOther Basis for perfection: 

Describe: 

Value of Property:$ Amount of Secured Claim: $ 

Annual Interest Rate ___ % OFixed or □Variable Amount Unsecured: $ 

(when case was filed) 

5. Amount of Claim Entitled to Priority under 11 U.S.C. § 507 (a). If any part of the claim falls into one of the following categories, check the box specifying

the priority and state the amount

0 Domestic support obligations under 11 i Wages, salaries, or commissions (up to $12,475*) 0 Contributions to an 

U.S.C. § 507 (a)(l)(A) or (a)(l)(B). earned within 180 days before the case was filed or the employee benefit plan - debtor's business ceased, whichever is earlier - 11 U.S.C. § 507 (a)(5). 

11 U.S.C. § 507 (a)(4). Amount entitled to priority: 

0 Up to $2, 775* of deposits toward 0 Taxes or penalties owed to governmental units - 0 Other - Specify $ 12,475.00 

purchase, lease, or rental of property or 11 U.S.C. § 507 (a)(8). applicable paragraph of 

services for personal, family, or household 11 U.S.C. § 507 (a)LJ. 

use - 11 U.S.C. § 507 (a)(7). 

*Amounts are subject to aqjustment on 4101/16 and every 3 years thereafter with respect to cases commenced on or after the date of adjustment.

6. Credits. The amount of all payments on this claim has been credited for the purpose of making this proof of claim. (See instruction #6) Case: 19-30088 Doc# 4370-2 Filed: 10/21/19 Entered: 10/21/19 23:26:35 Page 2 Case 19-30088 Claim 276-1 Filed 10/10/19 Desc Main Document Page 1 of 11

of 12
BIO (Official Fonn 1 0) (04/13) 2 

7. Documents: Attached are redacted copies of any documents that support the claim, such as promissory notes, purchase orders, invoices, itemized statements of

running accounts, contracts, judgments, mortgages, security agreements, or, in the case of a claim based on an open-end or revolving consumer credit agreement, a

statement providing the infonnation required by FRBP 300l(c)(3)(A). If the claim is secured, box 4 has been completed, and redacted copies of documents providing

evidence of perfection of a security interest are attached If the claim is secured by the debtor's principal residence, the Mortgage Proof of Claim Attachment is being

filed with this claim. (See instruction #7, and the definition of "redacted".)

DO NOT SEND ORIGINAL DOCUMENTS. ATTACHED DOCUMENTS MAY BE DESTROYED AFTER SCANNING. 

If the documents are not available, please explain: 

8. Signature: (See instruction #8)

Check the appropriate box.

� I am the creditor. Cl I am the creditor's authorized agent. Cl I am the trustee, or the debtor, 

or their authorized agent 

Cl I am a guarantor, surety, indorser, or other codebtor. 

(See Bankruptcy Rule 3005.) 

(See Bankruptcy Rule 3004.) 

I declare under penalty of perjury that the infonnation provided in this claim is true and correct to the best of my knowledge, information, and reasonable belief. 

Print Name: --=D'-'a"-'v"'idc:....c...A-"--lo=--cn_z_o�._a _s_a_n _in�d _iv_ id_u_ a_ l_a_n_d_o_ n_b_e_h_a _lf_ 

Title: Cred itor 

Company: 

Address and telephone number (if different from notice address above): 

Teleohone number: email: 

(Signature) (Date) 

Penalty for presenting.fraudulent claim: Fine ofup to $500,000 or imprisonment for up to 5 years, or both. 18 U.S.C. §§ 1 52 and 3571. 

INSTRUCTIONS FOR PROOF OF CLAIM FORM 

The instructions and definitions below are general explanations of the law. In certain circumstances, such as bankruptcy cases not filed voluntarily by the debtor, 

exceptions to these general rules may apply. 

Items to be completed in Proof of Claim form 

Court. Name of Debtor, and Case Number: 

Fill in the federal judicial district in which the bankruptcy case was filed (for 

example, Central District of California), the debtor's full name, and the case 

number. If the creditor received a notice of the case from the bankruptcy court, 

all of this information is at the top of the notice. 

Creditor's Name and Address: 

Fill in the name of the person or entity asserting a claim and the name and 

address of the person who should receive notices issued during the bankruptcy 

case. A separate space is provided for the payment address if it differs from the 

notice address. The creditor has a continuing obligation to keep the court 

informed of its current address. See Federal Rule of Bankruptcy Procedure 

(FRBP) 2002(g). 

1. Amount of Claim as of Date Case Filed:

State the total amount owed to the creditor on the date of the bankruptcy filing.

Follow the instructions concerning whether to complete items 4 and 5. Check

the box if interest or other charges are included in the claim.

2. Basis for Claim:

State the type of debt or how it was incurred. Examples include goods sold,

money loaned, services perfonned, personal injury/wrongful death, car loan,

mortgage note, and credit card. If the claim is based on delivering health care

goods or services, limit the disclosure of the goods or services so as to avoid

embarrassment or the disclosure of confidential health care information. You

may be required to provide additional disclosure if an interested party objects to

the claim.

3. Last Four Digits of Any Number by Which Creditor Identifies Debtor:

State only the last four digits of the debtor's account or other number used by the

creditor to identify the debtor.

3a. Debtor May Have Scheduled Account As: 

Report a change in the creditor's name, a transferred claim, or any other 

information that clarifies a difference between this proof of claim and the claim 

as scheduled by the debtor. 

3b. Uniform Claim Identifier: 

If you use a unifonn claim identifier, you may report it here. A uniform claim 

identifier is an optional 24-character identifier that certain large creditors use to 

facilitate electronic payment in chapter 13 cases. 

4. Secured Claim:

Check whether the claim is fullv or oartiallv secured. Skio this section if the

claim is entirely unsecured. (See Definitions.) If the claim is secured, check the 

box for the nature and value of property that secures the claim, attach copies of lien 

documentation, and state, as of the date of the bankruptcy filing, the annual interest 

rate (and whether it is fixed or variable), and the amount past due on the claim. 

5. Amount of Claim Entitled to Priority Under 11 U.S.C. § 507 (a).

If any portion of the claim falls into any category shown, check the appropriate

box( es) and state the amount entitled to priority. (See Definitions.) A claim may 

be partly priority and partly non-priority. For example, in some of the categories, 

the law limits the amount entitled to priority. 

6. Credits:

An authorized signature on this proof of claim serves as an acknowledgment that

when calculating the amount of the claim, the creditor gave the debtor credit for

any payments received toward the debt

7. Documents:

Attach redacted copies of any documents that show the debt exists and a lien

secures the debt. You must also attach copies of documents that evidence perfection

of any security interest and documents required by FRBP 300l(c) for claims based

on an open-end or revolving consumer credit agreement or secured by a security

interest in the debtor's principal residence. You may also attach a summary in

addition to the documents themselves. FRBP 300l(c) and (d). If the claim is based

on delivering health care goods or services, limit disclosing confidential health care

information. Do not send original documents, as attachments may be destroyed

after scanning.

8. Date and Signature:

The individual completing this proof of claim must sign and date it FRBP 9011.

If the claim is filed electronically, FRBP S00S(a)(2) authorizes courts to establish 

local rules specifying what constitutes a signature. If you sign this form, you 

declare under penalty of perjury that the information provided is true and correct to 

the best of your knowledge, information, and reasonable belief. Your signature is 

also a certification that the claim meets the requirements of FRBP 90ll{b). 

Whether the claim is tiled electronically or in person, if your name is on the 

signature line, you are responsible for the declaration. Print the name and title, if 

any, of the creditor or other person authorized to file this claim. State the filer's 

address and telephone number if it differs from the address given on the top of the 

form for purposes of receiving notices. If the claim is filed by an authorized agent, 

provide both the name of the individual filing the claim and the name of the agent. 

If the authorized agent is a servicer, identify the corporate servicer as the company. 

Criminal penalties apply for making a false statement on a proof of claim. 

of all similarly situated

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CLASS ACTION COMPLAINT

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pursuant to California Code of Civil Procedure § 382. This Court has jurisdiction over 

Defendant’s violations of the California Labor Code because the amount in controversy 

exceeds this Court’s jurisdictional minimum.

VENUE

2. Venue is proper in this judicial district pursuant to California Code of Civil 

Procedure §§ 395(a) and 395.5, as at least some of the acts and omissions complained of herein 

occurred in the County of Monterey. Defendants own and maintain offices, transact business, 

have agents and employees within the County of San Francisco, and Defendants are within this 

jurisdiction of this Court for purposes of service of process.

PARTIES

3. Plaintiff is an individual over the age of eighteen (18). At all relevant times 

herein, Plaintiff was and currently is a California resident. During the four years immediately 

preceding the filing of the Complaint in this action and within the statute of limitations periods 

applicable to each cause of action pled herein, Plaintiff was employed by Defendants as a nonexempt employee. Plaintiff was and is a victim of Defendants’ policies and practices 

complained of herein, lost money and/or property, and has been deprived of the right 

guaranteed by Labor Code §§ 201-203, and 227.3.

4. Plaintiff is informed and believes, and based thereon alleges, that during the four 

(3) years preceding the filing of the Complaint and continuing to the present, Defendants did 

and continue to do business by operating a natural gas and electric utility, and employed 

Plaintiff and other similarly situated non-exempt employees within the State of California and 

the County of Monterey, and therefore, were and are doing business in the State of California 

and the County of Monterey. 

5. Plaintiff does not know the true names or capacities, whether individual, partner, 

or corporate, of the defendants sued herein as DOES 1 through 50, inclusive, and for that 

reason, said defendants are sued under such fictitious names, and Plaintiff will seek leave from 

this Court to amend this Complaint when such true names and capacities are discovered. 

Plaintiff is informed, and believes, and based thereon alleges, that each of said fictitious 

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defendants, whether individual, partners, or corporate, were responsible in some manner for the 

acts and omissions alleged herein, and proximately caused Plaintiff and the Class as defined in 

Paragraph 16 to be subject to the unlawful employment practices, wrongs, injuries and damages 

complained of herein.

6. Plaintiff is informed and believes, and based thereon alleges, that at all times 

mentioned herein, Defendants were and are the employers of Plaintiff all members of the Class.

7. At all times mentioned herein, each of said Defendants participated in the doing 

of the acts hereinafter alleged to have been done by the named Defendants; and furthermore, 

the Defendants, and each of them, were the agents, servants, and employees of each and every 

one of the other Defendants, as well as the agents of all Defendants, and at all time herein 

mentioned were acting within the course and scope of said agency and employment. 

Defendants, and each of them, approved of, condoned, and/or otherwise ratified each and every 

one of the acts or omissions complained of herein.

8. At all times mentioned herein, Defendants, and each of them, were members of 

and engaged in a joint venture, partnership, and common enterprise, and acting within the 

course and scope of and in pursuance of said joint venture, partnership, and common enterprise. 

Further, Plaintiff alleges that all Defendants were joint employers for all purposes of Plaintiff 

and all members of the Class.

GENERAL FACTUAL ALLEGATIONS

9. On or about June 30, 20106, Defendants hired Plaintiff. Over the years, Plaintiff 

was promoted and ultimately became a salaried supervisor. As a salaried supervisor, 

Defendants paid Plaintiff a base salary plus overtime. In addition, Defendants provided 

Plaintiff paid vacations pursuant to Defendants’ paid vacation policy.

10. On March 25, 2019, Defendants terminated Plaintiff’s employment for an 

alleged violation of Defendants’ company policies. Plaintiff’s termination of employment by 

Defendants was involuntary. At the time of his termination, Defendants paid Plaintiff once per 

month. 

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11. At the time of his termination of employment, Plaintiff had accrued 123 hours of 

vested vacation pay at the rate of $72.05/hour in the total amount of $8,862.15. 

12. California Labor Code Section 227.3 provides “whenever . . . employer policy 

provides for paid vacations, and an employee is terminated without having taken off his vested 

vacation time, all vested vacation shall be paid to him as wages at his final rate in accordance 

with such . . . employer policy respecting eligibility or time served; provided, however, that an . 

. . employer policy shall not provide for forfeiture of vested vacation time upon termination.” 

Under California law, earned vacation time is considered wages, and vacation is earned, or 

vests, as labor is performed. Vacation pay accrues as it is earned, and cannot be forfeited, 

regardless of the reason for termination. Saustez v. Plastic Dress Up (1982) 31 Cal.3d 774. 

13. California Labor Code Section 201(a) provides: “If an employer discharges an 

employee, the wages earned and unpaid at the time of discharge are due and payable 

immediately.” 

14. Defendants failed to pay Plaintiff’s vested vacation time immediately upon 

Plaintiff’s date of termination (i.e., March 24, 2019). Rather, Defendants created a payroll 

check issued to Plaintiff in the gross amount of $11, 023.65, which included Plaintiff’s vested 

vacation pay in the amount of $8,862.15. The “Check Date” is “3/29/2019”. However, 

Defendants failed to deliver said payroll check to Plaintiff until April 4, 2019, which was the 

following pay period. 

15. As a result of Defendants’ failure to pay all earned and vested vacation pay upon 

Plaintiff’s involuntary termination of employment, Defendant failed to pay all final wages 

owed to Plaintiff in a timely manner. 

CLASS ACTION ALLEGATIONS

16. Class Allegations: Plaintiff brings this action on behalf of himself and the 

following Class pursuant to the Code of Civil Procedure §382: All of Defendants’ former

salaried employees in California who were paid once per month and who had earned and vested 

vacation pay at the time of their separation of employment and whose during the three years 

immediately prior to the filing of the Complaint. 

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17. Numerosity. The members of the Class are so numerous that joinder of all 

members would not be feasible or practicable. The membership of the Class is unknown to 

Plaintiff at this time; however, it is estimated that the members of the Class is greater than 500 

individuals. The identity of such membership is readily ascertainable via inspection of 

Defendants’ employment records.

18. Common Questions of Law and Fact Predominate/Well Defined 

Community of Interest: There are common questions of law and fact as to Plaintiff and all 

other similarly situated employees, which predominate over questions affecting only individual 

members. Those questions include without limitation: 

a. Whether Defendants’ policies/practices for the timing and amount of payment of 

final wages to members of the Class at the time of their separation of employment 

were lawful.

b. Whether Defendants systematically failed to pay accrued and vested vacation pay to 

members of the Class immediately at time of discharge.

c. Whether Defendants systematically failed to pay accrued and vested vacation pay to 

members of the Class within 72 hours of resignation.

19. Predominance of Common Questions. Common questions of law and fact 

predominate over questions that affect only individual members of the Class. The common 

questions of law set forth above are numerous and substantial and stem from Defendants’ 

policies and/or practices applicable to each individual class member. As such, the common 

questions predominate over individual questions concerning each individual class member’s 

showing as to their eligibility for recovery or as to the amount of their damages. 

20. Typicality. The claims of Plaintiff are typical of the claims of the Class because 

Plaintiff was employed by Defendants as a non-exempt employee in California during the 

statute(s) of limitations period applicable to each cause of action pled in the Complaint. As 

alleged herein, Plaintiff, like the members of the Class, was not paid proper overtime wages, 

was not provided all required meal periods, was not authorized and permitted to take all 

required rest periods, did not receive meal and rest period premium wages when she was not 

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provided compliant meal or rest periods, was not provided complete and accurate wage 

statements, and did not receive all final wages owed to her upon her termination of employment 

from Defendants. 

21. Adequacy of Representation. Plaintiff is prepared to take all necessary steps 

to represent fairly and adequately the interests of the members of the Class. Moreover, 

Plaintiff’s attorneys are ready, willing and able to represent the members of the Class and 

Plaintiff. Plaintiff’s attorneys have litigated numerous wage-and-hour class actions in state and 

federal courts and are committed to vigorously prosecuting the action on behalf of the members 

of the Class. 

22. Superiority. The California Labor Code is broadly remedial in nature and 

serves an important public interest in establishing minimum working conditions and standards 

in California. These laws and labor standards protect the average working employee from 

exploitation by employers who have the responsibility to follow the laws and who may seek to 

take advantage of superior economic and bargaining power in setting onerous terms and 

conditions of employment. The nature of this action and the format of laws available to 

Plaintiff and members of the Class make the class action format an efficient and appropriate 

procedure to redress the violations alleged herein. If each employee were required to file an 

individual lawsuit, Defendants would gain an unconscionable advantage since they would be 

able to exploit and overwhelm the limited resources of each individual plaintiff with their 

vastly superior economic and legal resources. Moreover, requiring each individual member of 

the Class to pursue an individual remedy would discourage the assertion of lawful claims by 

employees who would be disinclined to file an action against their former or current employer 

for real and justifiable fear of retaliation and damage to their careers. Further, the prosecution 

of separate actions by the individual class members, even if possible, would create a substantial 

risk of inconsistent or varying verdicts or adjudications with respect to the individual class 

members against Defendants; and which would establish potentially incompatible standards of 

conduct for Defendants; and/or legal determinations with respect to individual class members 

which would, as a practical matter, be dispositive of the interests of other class members not 

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parties to adjudications or which would substantially impair or impede the ability of the class 

members to protect their interests. Further, the claims of the individual members of the Class

are not sufficiently large to warrant vigorous individual prosecution considering all the 

concomitant costs and expenses attending thereto. As such, the Class identified in paragraph 

16 are maintainable as a Class under the Code of Civil Procedure § 382. 

FIRST CAUSE OF ACTION

WAITING TIME PENALTIES

(Against All Defendants)

23. Plaintiff re-alleges and incorporates by reference all previous paragraphs.

24. This cause of action is brought pursuant to Labor Code §§ 201-203, which 

require an employer to pay all wages immediately at the time of separation of employment in 

the event the employer fires the employee or the employee provides at least 72 hours of notice 

of their intent to quit. In the event the employee provides less than 72 hours of notice of their 

intent to quit, the employee’s final wages become due and payable not later than 72 hours of 

the employee’s last date of employment.

25. Plaintiff is informed and believes, and based thereon alleges, that Defendant 

failed to pay timely Plaintiff and the members of the Class all final wages due to them at their 

separation from employment, including earned and vested vacation pay. 

26. Further, Plaintiff is informed and believes, and based thereon alleges, that as a 

matter of policy/practice, Defendants continue to fail to pay Plaintiff and the members of the 

Class all earned wages at the end of employment in a timely manner. 

27. Defendants’ failure to pay final wages was willful within the meaning of Labor 

Code § 203. Defendants’ willful failure to pay timely Plaintiff and the members of the Waiting 

Time Class their earned wages upon separation from employment results in a continued 

payment of wages for up to thirty days from the time the wages were due. 

28. Therefore, Plaintiff and the members of the Waiting Time Class are entitled to 

compensation pursuant to Labor Code § 203. 

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PRAYER 

WHEREFORE, Plaintiff prays for judgment herself and for all others on whose behalf 

this suit is brought against Defendants, as follows: 

1. An order certifying the proposed Class; 

2. An order appointing Plaintiff as representative of the Class; 

3. An order appointing Counsel for Plaintiff as Counsel for the Class; 

4. Declaratory judgment that Defendants’ practices alleged herein are unlawful; 

5. Upon the First Cause of Action, for statutory waiting penalties pursuant to Labor 

Code § 203; 

6. Prejudgment interest.

7. On all causes of action for attorneys’ fees and costs; and 

8. For such other and further relief the Court deems just and proper. 

DATE: June 17, 2019 OSTERGAR LAW GROUP, P.C.

By: _____________________________________

JOHN E. LATTIN

Attorneys for Plaintiff

DAVE ALONZO

DEMAND FOR JURY TRIAL

 Plaintiff hereby demands a jury trial with respect to all issues triable by jury. 

DATE: June 17, 2019 OSTERGAR LAW GROUP, P.C.

By: _____________________________________

JOHN E. LATTIN

Attorneys for Plaintiff

DAVE ALONZO

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