Extract to table

4th 39, 43 ["[T]he complaint must contain sufficient facts to state a cause of action; each evidentiary fact that might eventually form part of the plaintiff's proof need not be alleged

5th 73, holding that a PAGA plaintiff must demonstrate that she personally suffered each type of violation for which she seeks to assert representative standing

) This exhaustion requirement is a prerequisite to suit, and it must be satisfied as to each discrete category of violation alleged

5th at pages 83–84, and the 2024 PAGA amendments, Plaintiff must have personally suffered each type of violation to have representative standing

To the extent the Seventh Cause of Action encompasses PAGA claims for second meal period violations, rounding-based underpayment, and other violations Plaintiff did not personally suffer, those claims must be dismissed for lack of standing

The Complaint's formulaic recitation that "Plaintiff was subject to each of the violations described herein" is a legal conclusion, not a factual allegation, and must be disregarded on demurrer