fails to provide accurate and complete information as required by subdivision (a) and “the employee cannot promptly and easily determine” — among other things — “the amount of gross wages ... paid to the employee during the pay period or any of the other information required ... pursuant to items ... (6) and (9) of subdivision (a).” Cal. Labor Code § 226(e)(2)(B)®. Defendant contends that because Plaintiffs claims all relate to a time period before the effective date of the amendments that they do not apply to his claims. The Court would note that the 2013 Amendment does not represent a substantive shift in Section 226 (with the possible exception of Section 226(e)(l)(2)(A) — not at issue here). See Price v. Starbucks Corp., 192 Cal.App.4th 1136, 1143, 122 Cal.Rptr.3d 174 (2011) (<HOLDING>); Torchia v. W.W. Grainger, Inc., 304 F.R.D.
holding that the defendants discovery requests were untimely because they were not served in time for the responses to be due before the discovery deadline holding attorneys must present detailed records to enable the court to determine if the services were necessary holding that records relating to a student court were not education records holding that seventeen missing records does not constitute improper record keeping because the fact that the records are not at the station does not mean that the records are incorrect or inaccurate recognizing that an injury exits where inaccurate or incomplete wage statements  require   plaintiffs to engage in discovery and mathematical computations to reconstruct time records and determine if they were correctly paid