Notice of Certified
Class Action Lawsuit
Torres v. Paragon Laboratories

Records show that you currently work, or previously worked, for Paragon in California. This notice explains that the Court has allowed, or "certified," a class action lawsuit that may affect you. You have legal rights and options that you may exercise before the Court holds a trial. The trial is to decide whether the claims being made against Paragon are correct. Judge Elaine Lu of the California Superior Court for the County of Los Angeles is overseeing this class action. The lawsuit is known as Franklin Torres v. Naturalife Eco Vite Laboratories d/b/a Paragon Laboratories, Case No. 19STCV27209.

This lawsuit alleges that Paragon rounded Class Members' work times, resulting in unpaid wages and an underpayment of overtime. The lawsuit also alleges that Paragon automatically deducted a half hour from Class Members' paychecks for a meal period, resulting in a failure to provide all meal periods, and Paragon did not properly compensate Class Members for these missed meal periods. Finally, the lawsuit alleges that Paragon failed to provide third rest breaks to Class Members who worked ten (10) or more hours in a single shift, resulting in a failure to provide all rest breaks, and Paragon did not properly compensate Class Members for these missed rest breaks.

Paragon denies each of these claims. The court has not yet decided who is right nor expressed any opinion to that effect.

You can read the Plaintiffs' Class Action Complaint For Damages at www.ParagonLaboratoriesClassActionLawsuit.com.

Paragon denies that it did anything wrong and states that it paid all wages owed, provided all requisite meal periods and rest breaks, and did not engage in any unfair business practices. Paragon states that its policies and practices comply with California law and that Paragon has followed those laws.

You can read Paragon's Answer to Plaintiffs' Class Action Complaint at www.ParagonLaboratoriesClassActionLawsuit.com.

In a class action lawsuit, one or more people called Plaintiffs or Class Representatives (in this case, Franklin Torres and Soufiane Bourbia are the approved representatives) sue on behalf of other people who may have similar claims. The people together are a "Class" or "Class Members." The company they sued (in this case Paragon) is called the Defendant. The court resolves the issues that were allowed to proceed for the Class for everyone in the Class—except for those people who choose to exclude themselves from the Class.

The Court decided that this lawsuit can be a class action and move towards a trial because it meets the requirements of the California Code of Civil Procedure section 382, which governs class actions in California courts.

The Court hasn't decided whether Paragon or Plaintiffs are correct. By certifying the Class and issuing this Notice, the Court is not suggesting that Plaintiffs will win or lose their case. Plaintiffs must prove their claims to the Court at a trial. Trial in this case is set to commence on April 19, 2027.

Plaintiffs are asking for restitution, interest, costs and attorneys' fees in accordance with California law.

No money or benefits are available now because the Court has not yet decided whether Paragon did anything wrong. There is no guarantee that money or benefits ever will be obtained. If they are, you will be notified about how to ask for a share.

The Honorable Elaine Lu of the California Superior Court for the County of Los Angeles certified the following Classes:

Rounding Class: all Paragon's hourly-paid or non-exempt employees within the State of California whose work times were rounded during the period from August 5, 2015, through April 28, 2021;

Automatic Deduction of Meal Periods Class: all Paragon's hourly-pad or nonexempt employee within the State of California who had a half hour automatically deducted from their paychecks for a meal period, during the period from August 5, 2015, through May 27, 2016;

Third Rest Break Class: all Paragon's hourly-paid or non-exempt employees in the State of California who worked one or more shifts of ten or more hours in length who were not provided with a third paid 10-minute break during which they were relieved of all duties during the time period from August 15, 2015, to June 1, 2021.

The Court's Order is available at www.ParagonLaboratoriesClassActionLawsuit.com.

If you do not fit within number 9 immediately above ("Am I part of this Class?"), you are NOT part of the class.

If you are still not sure whether you are part of the Class, you can call or write to the lawyers in this case at the phone number or address listed at the end of this Notice.

By doing nothing you are staying in the Class. If you stay in the class and Plaintiffs obtain money or benefits, either as a result of the trial or a settlement, you will be notified about how to apply for a share (or how to ask to be excluded from any settlement). Keep in mind that if you do nothing now, regardless of whether Plaintiffs win or lose the trial, you give up the right to sue, or continue to sue, Paragon—as part of any other lawsuit—about the same legal claims that are the subject of this lawsuit for the period that this lawsuit covers the Class. You will also be legally bound by all the Orders the Court issues and judgments the Court makes in this class action.

You do not need to provide a reason if you wish to be excluded from the lawsuit. If you already have your own wage and hour lawsuit based on the same violations of the California Business and Professions Code against Paragon and want to continue with it, you need to ask to be excluded from the Class. Also, if you want to pursue recovery for claims that are not alleged in this lawsuit, you must file your own lawsuit.

If you exclude yourself from the Class—which also means to remove yourself from the Class, and is sometimes called "opting out" of the Class—you won't get any money or benefits from this lawsuit even if Plaintiffs obtain them as a result of the trial or from any settlement (that may or may not be reached) between Paragon and Plaintiffs. However, you may then be able to sue or continue to sue Paragon for wage and hour violations of the California Labor Code that apply to you and that are available to you. If you exclude yourself, you will not be legally bound by the Court's judgments in this class action.

If you start your own lawsuit against Paragon after you exclude yourself, the lawyers representing the Class in this case will not be representing you. If you want a lawyer to represent you, you'll have to hire and pay your own lawyer for that lawsuit, and you'll have to prove your claims. If you do exclude yourself so you can start or continue your own lawsuit against Paragon, you should talk to your own lawyer soon, because your claims may be subject to a statute of limitations.

To ask to be excluded, you must send an "Exclusion Request" (also called an "Opt-Out Request") in the form of a letter sent by mail, stating that you want to be excluded from Torres v. Naturalife Eco Vite Laboratories, Inc. d/b/a Paragon Laboratories. You must include your name and address and sign the letter. You must mail your Exclusion Request postmarked by May 21, 2026, to: Torres v. Paragon Exclusions, c/o ILYM Group, Inc., P.O. Box 2031, Tustin, CA 92781. You may also get an Exclusion Request form at the website, www.ParagonLaboratoriesClassActionLawsuit.com.

The Court decided that the law firm of Justice Law Corporation of Pasadena, California is qualified to represent you and all Class Members. Justice Law Corporation is hereinafter referred to as "Class Counsel." They are experienced in handling similar cases against other employers.

With respect to those claims that were certified by the Court, you do not need to hire your own lawyer because Class Counsel is working on your behalf if you do not exclude yourself from the Class. But if you want your own lawyer, you will have to pay that lawyer. For example, you can ask him or her to appear in Court for you if you want someone other than Class Counsel to speak for you.

If there is a settlement or judgment of money or benefits for the Class, Class Counsel may ask the Court for fees and expenses. If the Court grants Class Counsels' request, the fees and expenses would be either deducted from any money obtained for the Class or paid separately by Paragon to Class Counsel.

Unless the case is resolved by a settlement, decertified or otherwise resolved, Class Counsel will have to prove Plaintiffs' claims at a trial. During the trial, a Jury and/or the Judge will hear all the evidence – including testimony from class members – to help them reach a decision about whether Plaintiffs or Paragon is right about the claims in the lawsuit. There is no guarantee that Plaintiffs will win, or that they will get any money or other benefits for the Class.

You do not need to attend the trial unless you are asked to do so by Class Counsel or Paragon. Class Counsel will present the case for Plaintiffs, and Paragon will present its defenses. Trials are public and anyone, including you, is welcome to come at their own expense.

Maybe. If Plaintiffs obtain money or benefits as a result of the trial or a settlement, you will be notified about how to participate. If Plaintiffs do not obtain money or benefits on behalf of the class, you will get nothing. We do not know how long this will take.

To obtain more information, please contact one of the attorneys representing the Class.