This excerpt taken from the ALL 10-Q filed Nov 1, 2005.
FILING OF CLASS COMPLAINT
On or before August 31, 2005, Class Counsel shall file an amended complaint, hereinabove and hereafter referred to as the Class Complaint, asserting various allegations on behalf of the Plaintiff Class (as defined in paragraph 3 above), which have been included in the ongoing negotiations, including meal and rest period violations; for all penalties, premium pay or damages associated with or related to alleged overtime violations or meal and rest period violations, including possible penalties under the PAGA; overtime violations under the federal Fair Labor Standards Act (FLSA); and for all other remedies or penalties which may or may not be available under the PAGA, the California Labor Code, or the wage orders issued by the California Industrial Welfare Commission (Wage Orders). Defendant shall stipulate to allow the filing of the Class Complaint in compliance with this provision. All the material allegations of the Class Complaint are deemed denied without the necessity of Allstate filing an Answer to the Class Complaint.
Class Action Settlement Agreement