An S+O Coaching LLC intervention California employers

You have 60 days.
Let's cap the damage.

You just received a PAGA notice or a records request. The clock is running. The 2024 reform (AB 2288) created a lifeline: if you take all reasonable steps to come into compliance within 60 days of the notice, your maximum penalty exposure can be capped at 30%. Your attorney fights the lawsuit. I step in immediately to build the documented operational proof that supports that cap.

Led by O. Lee Mincey — 30 years in operations and HR leadership across Disney, Universal, Live Nation, Six Flags, and Coca-Cola. The operator who fixes your floor so your lawyer can defend your case.

Why this matters now

The reform created a strict 60-day window.

For twenty years, PAGA rewarded lawsuits. The 2024 reforms (AB 2288 / SB 92) flipped the incentive. Once you're served a notice, you have a narrow window to act: take all reasonable steps to come into compliance within 60 days, and your exposure can be capped at 30%. Separately, if you have under 100 employees, you may file a cure proposal with the LWDA within 33 days. Two different clocks, both short. Move fast and you negotiate from strength.

The old posture

Hand the notice to a lawyer, wait two years, pay a heavy settlement. Nothing changes on the floor, and the underlying exposure keeps compounding.

The 30% cap strategy

Rapidly deploy systemic operational fixes — payroll mapping, fifth-hour meal-break hard stops, supervisor retraining — inside the 60-day window. You hand your defense attorney a dated, documented remediation file that positions you to claim the 30% cap. Small employers move on the 33-day cure path in parallel.

See your own number

What a wage-and-hour claim could cost — with and without intervention.

Set your headcount and a realistic exposure window. The left number is roughly what you'd face unprepared. The right is what a successful 60-day remediation can do to it. The gap is what the intervention protects.

Exposure estimator

Your back-of-napkin PAGA math

A rough, illustrative model — not a legal opinion or a guarantee. It's here to show the shape of the risk and what a capped posture changes.

Everyone who could be an "aggrieved employee"
12employees
Roughly one year of exposure = ~26 bi-weekly periods
26pay periods
An honest gut check — drives the share of periods likely to draw a penalty
Unprepared exposure
$0
Full default penalties, no reasonable-steps defense on record
With 60-day remediation (30% cap)
$0
The statutory cap if the required operational fixes are successfully executed and documented before the 60-day window closes.
Set your numbers to see the gap.

Illustrative only. Uses the $100-per-employee-per-pay-period default as the baseline and applies the 30% post-notice cap as the remediated case. Whether a court accepts "all reasonable steps" depends on the specific violations, your records, and counsel — the cap is not guaranteed. This tool is not legal advice and creates no attorney relationship.

How it works

One emergency response. Three phases.

A notice has landed, so the sequence is fixed. The Rapid Diagnostic tells us where the exposure is. The 60-Day Sprint executes the fixes that support the 30% cap. The Post-Crisis Shield keeps you protected once the window closes.

i

The Rapid Diagnostic

Days 1–3. We ingest your raw time punches and payroll CSVs, run the mathematical audit, and flag the exact meal-break and regular-rate-of-pay violations driving your exposure. You get a color-coded one-page roadmap of what must be fixed immediately.

Who: Every employer served with a notice starts here. It's the map for the next 57 days.
$3,500
flat fee
The intervention
ii

The 60-Day Sprint

Days 4–60. The core intervention. We reconfigure your payroll systems, rewrite the failed policies, run mandatory supervisor training (English/Spanish), and build the dated documentation packet your attorney uses to argue the 30% cap.

Who: Any employer inside the 60-day window who wants to cap exposure, not just litigate it.
$10,000+
project fee
iii

The Post-Crisis Shield

Once the window closes and the file is built, we transition into your fractional compliance partner so the next notice never lands. Continuous policy updates, quarterly audits, and a living reasonable-steps record.

Who: Sprint clients who want the protection to stay current.
$1,500
per month
The risk surface

The same five gaps trigger most of it.

Whether you're remediating a live notice or preventing the next one, the violations cluster in the same five places. Fix them under deadline now; document them continuously after.

1
Wage statementsThe Labor Code §226 details that are the most-filed PAGA trigger
2
Meal & rest periodsTiming, premiums, and the records that prove compliance
3
Overtime & minimum wageRegular-rate math, off-the-clock risk, local minimums
4
Expense reimbursementThe §2802 obligations small teams routinely miss
5
Worker classificationExempt vs. non-exempt and 1099 vs. W-2 — the costliest to get wrong
+
Onboarding & policy hygieneHandbooks and notices that keep the file clean

Where I stop, and where your attorney starts

This is compliance operations and documentation — building the systems, running the audits, and maintaining the evidence file that demonstrates reasonable steps. It is not the practice of law. Legal opinions, representation, and active litigation route to a partner employment attorney. That clean line is what makes the service safe to buy and lets your counsel do far less expensive work, because the file is already built.

Find out exactly where your exposure is.

Start with the Rapid Diagnostic. In three days you'll know your real number and exactly what has to change before the 60-day window closes.

Book an emergency assessment
A mincey.co system · O. Lee Mincey · operating through S+O Coaching LLC
Compliance operations and documentation. Not legal advice. Not a law firm.