![]() ![]() Plaintiff Marcie Hamilton filed this lawsuit against her former employer, Defendant Juul Labs, Inc. ("Juul"), seeking civil penalties and injunctive relief related to alleged unlawful policies and various employment agreements. copy of the Termination Certification is attached as Exhibit A to a declaration in support of Juul's. Juul also seeks judicial notice of California Senate Judiciary Committee Bill Analysis for Senate Bill 1300. This Court GRANTS Juul's request with respect to these two items. Hamilton alleges that these policies and agreements violated the California Labor Code. Juul serial codes code The Termination Certification is referenced throughout the compliant, see Compl. With the exception of her Unfair Competition Law ("UCL") claim, all her causes of action are pursuant to the California Private Attorneys General Act ("PAGA"). Pending before the Court is Juul's motion to dismiss for failure to state a claim or, alternatively, to strike certain factual allegations and prayers for relief. For the reasons discussed below, the Court GRANTS in part and DENIES in part Juul's motion without prejudice. Hamilton worked for Juul as a Director of Program Management from April 2018 to March 2019. Hamilton had to sign Juul's standard non-disclosure agreement entitled the Proprietary Information and Invention Assignment Agreement (the "NDA"). ![]() Hamilton of her termination and required her to sign a document entitled Termination Certification.
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