The plaintiff alleged nine categories of Labor Code violations across a hotel operation with approximately 95 aggrieved employees. The initial demand treated the entire PAGA period as a monolith — applying maximum violation rates uniformly. The analysis I built rejected that approach. By disaggregating the PAGA period into a Legacy Period (before a documented compliance transformation) and a Remedied Period (after), the model revealed that the employer had achieved a 90%+ reduction in overtime violations during the latter half of the statutory period. Each violation category was scored independently using actual time records and payroll data, with penalty stacking calculated across all nine categories. The three-scenario output — plaintiff maximum, data-driven realistic, and defense best case — provided the carrier with a defensible settlement authority range. The framework was subsequently adopted as the standard PAGA analytical methodology across the entire practice group.
Exposure Modeling
Multi-Property Hotel Operator
Nine violation categories. ~95 aggrieved employees. Created the "Two Hotels" framework.
The Transferable Point
Temporal disaggregation — splitting the PAGA period into pre-remediation and post-remediation windows — exposes compliance improvement that a monolithic penalty calculation conceals. This transforms the defense narrative from 'we violated the law' to 'we identified and fixed the problem.'
Methods Applied
- Temporal disaggregation of PAGA period into Legacy and Remedied windows
- Independent scoring of each violation category using actual time records
- Penalty stacking calculation across all nine categories
- Three-scenario modeling (plaintiff maximum, data-driven realistic, defense best case)
- 90%+ violation rate reduction documentation for Remedied Period
Governing Authorities
Framework Adopted Firm-Wide
This matter description is for illustrative purposes only. Details have been generalized to protect client confidentiality. Prior results do not guarantee a similar outcome.