P0938 In an action for unpaid overtime wages, certain statutory penalties, and civil penalties available under sections of the Labor Code that authorize private action for such civil penalties after compliance with certain administrative procedures with which plaintiffs did not comply, claims for civil penalties should be stricken from causes of action that combine them with claims for unpaid wages or other statutory penalties, causes of action seeking only civil penalties should have been dismissed altogether, and the rest of the action should have been permitted to proceed.

CALIBER v SUPERIOR COURT (Labor Penalties) 134 CA4 365 [See: LabC 2698 etseq; CCP 436; Kong v City 108 CA4 1028]