About
Most PAGA defense is reactive. A notice arrives, counsel answers, discovery happens, and someone negotiates a number at mediation. The exposure model — if one exists — is a back-of-the-envelope calculation based on blanket assumptions. The result: settlements driven by plaintiff's framing, not by the actual data.
I do it differently. Every matter starts with a quantitative exposure model that disaggregates penalties by violation category, applies per-category violation rates derived from actual time records and payroll data, strips non-recoverable categories under the ZB, N.A. and Kirby frameworks, and produces three scenarios — plaintiff maximum, data-driven realistic, and defense best case.
I built this practice on the plaintiff side — litigating wage-and-hour class actions on behalf of employees before transitioning to defense. That foundation isn't background. It's the operating system. I evaluate claims the way opposing counsel evaluates them, anticipate certification arguments before they're filed, and identify the pressure points that actually move mediations.
The interactive tools, publications, and case law analyses on this site aren't marketing. They are the methodology, made visible.
Practice Trajectory
I started on the plaintiff side — litigating wage-and-hour class actions at a Los Angeles firm that prosecuted meal-and-rest, overtime, and off-the-clock claims against mid-market and enterprise employers. I learned how plaintiff's counsel evaluates cases, prices risk, builds class certification motions, and approaches mediation.
The transition to defense was deliberate. At a global litigation firm's employment practice group, I handled PAGA and wage-and-hour matters with a level of independence unusual for my seniority — building the quantitative exposure models, novel defense theories, and sampling methodologies that became standard analytical tools across the practice group.
Earlier, I practiced intellectual property at a boutique firm — researching cutting-edge trademark and licensing issues, drafting prosecution briefs, and producing the kind of deep analytical writing that a transactional IP practice demands.
The thread across all of it: I treat every legal problem as a system to be understood completely before a position is taken.