Welcome to the Settlement Website for the
Bogdanyi v. Health Advocates, LLC

A class action settlement has been reached between Plaintiff Karen Bogdanyi (“Plaintiff”) and Defendant Health Advocates, LLC (“Defendant”) (Plaintiff and Defendant are collectively referred to as the “Parties”) in the class action case, Bogdanyi v. Health Advocates LLC, originally filed on September 24, 2018 in the Superior Court of California, County of San Francisco Case No. CGC-18-570033 (the “Action”), which may affect your legal rights. On July 9, 2024, the Court granted preliminary approval of the settlement and scheduled a hearing on January 10, 2025 at 10:00 a.m. (“Final Approval Hearing”) to determine whether or not the Court should grant final approval of the settlement.

On September 24, 2018, Plaintiff filed a Class Action Complaint for Damages in the San Francisco County Superior Court, Case No. CGC-18-570033 (the “Action”). On December 14, 2018, Plaintiff filed a First Amended Complaint, which added a cause of action seeking civil penalties under PAGA (Labor Code sections 2699, et seq.). On May 30, 2019, Plaintiff filed her Second Amended Complaint to provide additional information in support of her claims. A class action case resolves the claims of absent parties on a representative basis, whereas a PAGA case is brought on behalf of the state to recover civil penalties.

Plaintiff alleges Defendant failed to properly pay minimum and overtime wages, provide compliant meal and rest breaks and associated premiums, timely pay wages during employment and upon termination of employment and associated waiting-time penalties, provide compliant wage statements, keep requisite payroll records, reimburse business expenses, and thereby engaged in unfair business practices in violation of California Business and Professions Code section 17200, et seq. Plaintiff also asserts a claim for civil penalties under PAGA based on the foregoing alleged violations by Defendant. Plaintiff seeks, among other things, recovery of unpaid wages and meal and rest period premiums, unreimbursed business expenses, restitution, penalties, interest, and attorneys’ fees and costs.

Defendant denies all of the allegations in the Action and denies that it violated any laws.

After investigation and analysis of the claims, the Parties engaged in good faith, arm’s-length negotiations, and, as a result, the Parties reached a settlement. The Parties have since entered into the First Amended Class and PAGA Action Settlement and Release Agreement (“Agreement,” “Settlement” or “Settlement Agreement”).

On July 9, 2024, the Court entered an order preliminarily approving the Settlement. The Court has appointed Simpluris, Inc., as the administrator of the Settlement (“Settlement Administrator”), Plaintiff Karen Bogdanyi as representative of the Class (“Plaintiff” or “Class Representative”), and Lawyers for Justice, PC as counsel for the Class (“Class Counsel”).

A Class Member means all current and former hourly-paid or non-exempt employees of Defendant within the State of California employed at any time from September 24, 2024 through June 26, 2024.

If you are a Class Member, you do not need to take any action to receive an Individual Settlement Payment, but you have the opportunity to request exclusion from the Class Settlement (in which case you will not receive an Individual Settlement Payment), object to the Class Settlement, and/or dispute the Workweeks credited to you, if you so choose, as explained more fully in Sections III and IV of the Notice.

Aggrieved Employees means all current and former employees of Defendant on whose behalf Plaintiff sought civil penalties under the Labor Code Private Attorneys General Act of 2004 (Cal. Lab. Code §§ 2698, et seq., “PAGA”) who worked for Defendant as non-exempt or hourly paid employees within the State of California at any time from September 17, 2017 through June 26, 2024.

Because this Settlement resolves claims brought pursuant to PAGA by Plaintiff acting as a representative and as a Private Attorney General of and for the State of California and the Labor and Workforce Development Agency (“LWDA”), an Aggrieved Employee cannot opt out of the release of the claims for PAGA civil penalties set forth in the Settlement Agreement. All Aggrieved Employees will release the Released PAGA Claims, and will be paid their respective shares of the PAGA Fund.

The Settlement represents a compromise and settlement of highly disputed claims. Nothing in the Settlement is intended to or will be construed as an admission by Defendant that the claims in the Actions have merit or that Defendant has any liability to Plaintiff, Class Members, and Aggrieved Employees. Plaintiff and Defendant, and their respective counsel, have concluded and agree that, in light of the cost, risks and uncertainties to each side of continued litigation, the Settlement is fair, reasonable, and adequate, and is in the best interests of the Class Members. The Court has made no ruling on the merits of the claims asserted in the Actions and has determined only that certification of the Class for settlement purposes is appropriate under California law.

Defendant maintains that it complied at all times with California law, and denies that it did anything wrong. Defendant disputed and still disputes the claims made against it.

If you have additional questions, you may also contact Class Counsel:

Edwin Aiwazian, Esq.
Arby Aiwazian, Esq.
Joanna Ghosh, Esq.
Vartan Madoyan, Esq.
Helene Mayer, Esq.
Lawyers for Justice, PC
410 West Arden Avenue, Suite 203
Glendale, California 91203
Telephone: (818) 265-1020
Fax: (818) 265-1021