Reforming PAGA: Simantob Law Group Backs New LWDA Regulations

California’s Private Attorneys General Act (PAGA) is undergoing meaningful regulatory scrutiny—and Simantob Law Group is lending its voice in strong support of reform.

On March 23, 2026, Simantob Law Group formally submitted comments to the California Labor and Workforce Development Agency (LWDA) endorsing the Agency’s proposed PAGA regulations. You can view the official rulemaking record and the list of participating stakeholders on the LWDA’s PAGA Rulemaking Page.

Drawing on decades of experience in employment law defense for California employers, the firm detailed how high-volume, low-specificity PAGA filings have distorted the statute’s original public-enforcement purpose and imposed unnecessary burdens on businesses and the courts.

The LWDA’s data reveals a troubling trend: nearly 9,000 PAGA notices were filed during the 2024–2025 fiscal year alone. A significant portion of these filings originated from a small cohort of law firms utilizing standardized, boilerplate templates.

These high-frequency filers often omit the factual particularity required by law, making it difficult—if not impossible—for the LWDA to meaningfully evaluate claims or for employers to effectively utilize the statutory cure process.

 

Feature	Current State	Proposed LWDA Regulation
Notice Specificity	Boilerplate, standardized templates	Fact-specific claimant certifications
Oversight of Repeat Filers	Minimal	Enhanced scrutiny of high-volume filers
Settlement Review	Limited LWDA involvement	Mandatory 45-day review period
Litigation Focus	Broad, high-pressure discovery	Claims grounded in personally experienced violations

 

Based on publicly available PAGA notice data, the following firms consistently file PAGA notices at unusually high volumes over extended periods. Employers facing notices from these entities should be aware of the high-volume litigation models being utilized.

1. Moon & Yang, APC

Approximately 1,763 PAGA filings since 2010.

2. Wilshire Law Firm, PLC

Approximately 1,744 PAGA filings since 2016.

3. Lawyers for Justice, PC

Approximately 1,578 PAGA filings since 2011.

4. Bibiyan Law Group, P.C.

Approximately 1,370 PAGA filings since 2016.

5. Aegis Law Firm, PC

Approximately 1,339 PAGA filings since 2008.

6. Lavi & Ebrahimian LLP

Approximately 1,309 PAGA filings since 2005.

7. Law Offices of Ramin R. Younessi, APLC

Approximately 1,266 PAGA filings since 2009.

8. Blumenthal Nordrehaug Bhowmik De Blouw LLP

Approximately 1,232 PAGA filings since 2008.

9. James Hawkins APLC

Approximately 1,144 PAGA filings since 2009.

10. Capstone Law APC

Approximately 1,051 PAGA filings since 2012.

A central concern addressed in Simantob Law Group’s comment letter is the tactical misuse of representative PAGA claims as settlement leverage. In many cases, these claims are used to secure outsized individual recoveries for a single plaintiff and counsel—often at the expense of the broader group of aggrieved employees and the State of California’s statutory right to 75% of civil penalties.

The proposed regulations restore balance by enhancing scrutiny and reinforcing PAGA’s intended purpose as a public enforcement mechanism, not a tool for private windfall.

March 23, 2026

VIA EMAIL (Danielle.West@labor.ca.gov)

Danielle West PAGA Rulemaking and Policy Analyst California Labor and Workforce Development Agency

RE: Comments on Proposed Rulemaking – Labor Code Private Attorneys General Act of 2004 (OAL Notice File Number Z2026-0121-03)

Dear Ms. West:

Simantob Law Group submits these comments in strong support of the Labor and Workforce Development Agency’s (“LWDA”) proposed regulations governing administration of the Private Attorneys General Act of 2004 (“PAGA”). As a boutique firm representing employers across California, we witness firsthand the operational, financial, and litigation burdens imposed by the current wave of high-frequency PAGA filings. The Agency’s proposed rulemaking responds appropriately and necessarily to well-documented, systemic misuse of the statute.

High-Frequency PAGA Filers Undermine PAGA’s Statutory Purpose

The LWDA’s Initial Statement of Reasons identifies a significant and troubling trend: 8,846 PAGA notices filed in FY 2024-2025, with a small cohort of law firms responsible for a disproportionately large share of all filings. This demonstrates the rise of “high-frequency filers”—practitioners who submit PAGA notices in high volumes, often using standardized templates rather than individualized factual allegations. These boilerplate notices frequently omit the factual particularity the statute requires, impeding the LWDA’s ability to meaningfully evaluate alleged violations and undermining the statutory cure process. Rather than advancing public enforcement, such filings are often generated as part of a high-volume litigation model designed to maximize settlement leverage rather than resolve bona fide Labor Code violations.

Tactical Misuse: Individual Windfalls vs. State Interest

We have observed a consistent pattern in which attorneys representing employees utilize the threat of expansive, representative PAGA actions often coupled with burdensome, large-scale discovery demands as a mechanism to exert significant settlement pressure to obtain outsized recoveries for purely individual resolutions. In these scenarios, representative PAGA claims function as bargaining instruments to secure enhanced individual payouts for the named plaintiff and their counsel. This dynamic creates a direct conflict between the individual plaintiff and the broader group of “aggrieved employees,” as well as with the State’s statutory interest in recovering 75% of civil penalties. It undermines the “private attorney general” model by prioritizing private recovery over public enforcement.

The High-Frequency Filer Framework Is Necessary and Balanced (Proposed § 17400 et seq.)

The proposed framework is a measured, evidence-based response to high-volume, low-specificity filings. The LWDA’s data reflect that a small group of firms and attorneys account for a disproportionately share of all PAGA notices filed statewide. Based on publicly available data, several firms consistently operate at these elevated volumes, including:

• Moon & Yang, APC: Approximately 1,763 filings since 2010
• Wilshire Law Firm, PLC: Approximately 1,744 filings since 2016
• Lawyers for Justice, PC: Approximately 1,578 filings since 2011
• Bibiyan Law Group, P.C.: Approximately 1,370 filings since 2016
• Aegis Law Firm, PC: Approximately 1,339 filings since 2008
• Lavi & Ebrahimian LLP: Approximately 1,309 filings since 2005
• Law Offices of Ramin R. Younessi, APLC: Approximately 1,266 filings since 2009
• Blumenthal Nordrehaug Bhowmik De Blouw LLP: Approximately 1,232 filings since 2008
• James Hawkins APLC: Approximately 1,144 filings since 2009
• Capstone Law APC: Approximately 1,051 filings since 2012

The LWDA’s proposed safeguards including claimant certifications and mandatory cover letter requirements are narrowly tailored to ensure that high-volume filers comply with core statutory requirements and that claims are grounded in actual, personally experienced Labor Code violations.

Enhanced Settlement Oversight Protects the Public Interest

The proposed 45-day settlement review period and expanded documentation requirements are critical to curbing settlement structures that prioritize individual recovery over the State’s enforcement interests. By requiring transparency in allocation and supporting documentation, the LWDA will be better positioned to identify and address settlements that do not adequately reflect the scope or merits of the alleged violations, thereby safeguarding the public interest embedded in PAGA.

Conclusion

The LWDA’s proposed regulations are thoughtful, balanced, and necessary. They protect workers, employers, the courts, and most importantly the State’s enforcement prerogatives. Simantob Law Group strongly supports adoption of the proposed rulemaking.

Sincerely,

/Lisa D. Simantob/ Lisa D. Simantob, Esq. Founder and Lead Counsel, Simantob Law Group

Read our formal comment submitted to the LWDA here

For California employers, the LWDA’s proposed PAGA regulations represent a long-needed course correction. If adopted, these rules will reduce exposure to boilerplate PAGA notices, limit settlement leverage derived from vague allegations, and bring greater predictability to settlement approval. Employers should monitor this rulemaking closely and reassess their PAGA Litigation response strategies—particularly when facing claims from high-frequency filers—working with experienced counsel to ensure early, disciplined evaluation of risk and compliance.

Facing a PAGA claim or need urgent compliance help to meet the 60-day cure deadline? Our experienced Los Angeles PAGA defense attorney team, with over twenty years employment defense experience, can help you navigate the new penalty caps and early resolution procedures.

Simantob Law Group is a law firm of business attorneys and real estate lawyers in Los Angeles. We have represented the business and real estate legal needs of individuals and companies, from start-ups to regional and national US corporations for over 20 years. Please contact us at (310) 281-0041 or complete our online contact form to discuss your PAGA Compliance or PAGA lawsuit with a Los Angeles Employer Defense Attorney

This blog post is for informational purposes only and does not constitute legal, tax, or financial advice. Reading this article does not create an attorney-client relationship. For advice specific to your situation, please consult a qualified professional.