Arthur
Karadzhyan

PAGA representative actions, wage-and-hour class actions, workplace investigations, and complex employment litigation for California employers — with quantitative penalty exposure modeling at the center of every matter.

Referring attorneys, co-counsel arrangements, EPLI carriers and panel assignments, and employers directly — including compliance advisory outside litigation. Carrier-assigned defense and panel work are a core part of the practice.

On the first call: scope and deadlines. Within 24 hours: a preliminary assessment. Within 48 hours: an action plan with statutory citations. Within two weeks: a carrier-ready status report with the initial exposure model.

Every matter starts with a quantitative model that disaggregates penalties by violation category, applies per-category violation rates derived from actual time and payroll records, strips categories PAGA cannot recover under ZB, N.A. and Kirby, and produces three scenarios — plaintiff maximum, data-driven realistic, and defense best case.

Two deadlines start running on receipt. The 60-day “all reasonable steps” window that determines eligibility for the 30% penalty cap under § 2699(h) applies to every employer. The 33-day window to submit a cure proposal under § 2699.3 is narrower — it is open only to an employer that employed fewer than 100 employees in total during the period covered by the notice — a cumulative count across that period, not a headcount on any single day. Both can expire before a complaint is ever filed.

Yes. Every calculation runs entirely in your browser — no inputs, outputs, or interactions are transmitted, stored, or logged. Using the tools does not create an attorney-client relationship.