Plaintiff Alleges Violations Against Former Employers Stacks Group Inc & Allitcon Inc Under PAGA

Santa Clara County Court House
Santa Clara County Court House
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In a significant legal move, a former employee has filed a lawsuit against her previous employers, alleging widespread violations of California labor laws. Miriam Castrejon lodged the complaint on October 23, 2025, in the Superior Court of California for the County of Santa Clara against Stacks Group Inc., Allitcon Inc., and several unnamed defendants. The case brings to light serious allegations concerning labor code violations that affect not only Castrejon but also other aggrieved employees.

Miriam Castrejon’s lawsuit represents herself and the State of California as a private attorney general under the Private Attorneys General Act (PAGA) of 2004. She claims that during her employment with Stacks Group Inc. and Allitcon Inc., she and other non-exempt employees were subjected to numerous labor law violations. These include failure to pay minimum wages, unpaid overtime, denial of meal and rest breaks, failure to reimburse business expenses, and improper wage statements. “Defendants engaged in a pattern and practice of failing to pay all wages due,” alleges Castrejon in her complaint. The lawsuit outlines various infractions such as off-the-clock work, unpaid mandatory meetings, unlawful meal period agreements, and uncredited sick pay.

The complaint details how Castrejon was employed as an hourly server at Stacks Breakfast restaurant from 2016 until May 1, 2025. Throughout this period, she experienced systematic underpayment practices including time rounding that favored the employer, denial of legally required breaks despite being reprimanded for attempting to take them, and improper calculation of overtime by excluding bonuses from regular rate calculations. Additionally, she accuses the companies of failing to pay out accrued vacation time upon termination—a violation of Labor Code section 227.3—and denying sick leave benefits contrary to Labor Code section 246.

Castrejon seeks penalties under PAGA for these alleged violations amounting to significant financial restitution for affected employees. Specifically, she requests civil penalties per infraction which could total substantial sums given the multiple breaches cited across numerous labor code sections such as 201-203 (timely payment), 226 (wage statement accuracy), and others related to overtime and minimum wage requirements. The suit also calls for injunctive relief to prevent further illegal practices by the defendants.

Represented by Melmed Law Group P.C., attorneys Jonathan Melmed, Kyle D. Smith, and Rachel Jo are spearheading this legal battle on behalf of Castrejon and similarly aggrieved workers seeking justice for their grievances against their former employers. The case is presided over by Judge S. Rodriguez under Case Number: 25CV478393.

Source: 25CV478393_Miriam_Castrejon_v_Stacks_Group_Complaint_County_of_Santa_Clara_California..pdf



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