A staffing firm placed healthcare workers at government worksites — county hospitals and public clinics — where the staffing firm had no operational control over scheduling, meal period timing, or rest period availability. The PAGA notice alleged meal/rest, overtime, and wage statement violations. The defense I developed argued that where the alleged violations arise from working conditions controlled by an immune public agency employer, and the staffing firm is a secondary employer without operational authority over those conditions, PAGA penalties should not attach to the staffing firm. This required distinguishing between violations attributable to the staffing firm's own payroll and administrative obligations (wage statements, timely payment) and violations attributable to the agency's worksite operations (meal timing, rest period scheduling). The multi-worksite analysis also created a strong manageability challenge — the staffing firm placed employees at 14 different government facilities, each with different scheduling practices. 132 aggrieved employees across multiple job classifications and worksites.