Kris Carmichael ConsultingPAGA · CAL/OSHA · WORKERS' COMP 510.833.0723

For California employers who just received a PAGA notice

When PAGA happens, housekeeping is urgent.

A PAGA notice starts a clock. What you do in the next 60 days decides which penalty cap you can still argue for. Kris Carmichael, a former workers' comp claims adjuster with more than 30 years in employers' corner, gets your records in order alongside your employment counsel, so the lawyers spend their hours on the case, not on your filing cabinet.

Former WC claims adjuster 30+ years with CA employers On site, 24/7
Notice clock

Your next 65 days

  1. 33DAYSCure proposal deadline for employers with fewer than 100 employeesEnter your notice date
  2. 60DAYSReasonable steps to comply should be in place and documented to argue for the 30% capEnter your notice date
  3. 65DAYSEarliest the employee's lawyer can file the lawsuit if the state doesn't actEnter your notice date

Calendar days counted from the notice date. Your employment counsel confirms the exact deadlines for your case.

PAGA after the 2024 reform · AB 2288 / SB 92

The notice closed one door.
The next 60 days decide the other.

California's 2024 reform lets an employer's penalties be capped if it can show reasonable steps to comply. The lower 15% cap required steps taken before any notice. For you, the cap still in reach is 30%, and it depends on what gets done now.

15%

Steps taken before

Required reasonable steps in place before a notice or a records request arrived. Once the notice lands, this path is closed.

30%

Steps taken within 60 days

Reasonable steps taken within 60 days after the notice. This is the path still open to you, and the clock is already running.

The first two weeks

Four things to do this week.

Most of the damage in a PAGA case is done by what the employer does, or doesn't do, in the first few weeks after the notice.

01 · COUNSEL

Get your employment lawyer on it

Today, not next week. If you don't have one, Kris can introduce you to employment attorneys she works with.

02 · PRESERVE

Keep every record

Time records, pay stubs, schedules, policies, handbooks, texts. Don't alter, clean up, or throw anything away.

03 · STEADY

Treat the employee the same

No change in hours, duties, or attitude toward the person who filed. Retaliation creates a second, worse claim.

04 · HOUSEKEEPING

Start fixing what's broken

Correct pay practices, put policies in writing, train supervisors, and date every step. That record is what supports the 30% cap.

How Kris helps

Everything short of
attorney billable hours.

Your lawyer handles the case. Kris handles the housekeeping: the records, the fixes, and the dated proof that you took reasonable steps once you knew. She works under your counsel's direction, so the review stays inside the attorney-client relationship instead of creating new evidence.

You get an action plan in the first conversation, and Kris is on site when it matters.

  • ✓
    Records organizedTime, pay, and personnel records pulled together the way your counsel will ask for them.
  • ✓
    Pay practices reviewedMeal and rest breaks, overtime, and wage statements, reviewed under counsel's direction.
  • ✓
    Policies written and deliveredLawful wage-and-hour policies in writing, with proof your people received them.
  • ✓
    Supervisors trainedTraining on the Labor Code and the wage orders that apply to your industry.
  • ✓
    Corrective action documentedEvery fix recorded and dated, so the timeline speaks for itself.

Kris is not an attorney and does not give legal advice. She works alongside your employment counsel, and when a question is legal, she puts it in front of the lawyer.

Results for clients

What this looks like on paper.

A few outcomes from Kris's client work. Names are withheld; details are available in conversation.

$3.5MCredit won back on a $5 million paralysis claim, by showing another employer on a multi-employer site was responsible.
1.27 → 0.53Experience mod for an auto group after Kris split out a location that was carrying another store's losses.
$172KRecovered from a workers' comp carrier for one client.
$77KSaved by correcting an 11-point error in a client's experience mod.
0Violations. A Cal/OSHA inspection closed with a no-violation letter.
32 yrsHer longest-standing client relationship, a Bay Area dealership.

Past results don't predict future outcomes. Every claim and inspection turns on its own facts.

About Kris

"I'm not going to guess. I'm going to tell you what I know."Kris Carmichael

Kris started as a workers' comp claims adjuster, so she knows how carriers, adjusters, and inspectors think. She has spent more than 30 years on the employer's side of the table, mostly with construction, manufacturing, and auto dealership clients across California. She is based in Dublin, in the East Bay.

At the scene before the ambulance

When a client's driver was hit on the road, Kris got there before the police. By the time officers arrived she had photographed the scene, gathered licenses and insurance, and secured it. Then she sat in the ER waiting room with the owner until his employee was released.

Cleaning up before the customers noticed

A contractor's boom-truck cable snapped outside a dealership's front windows and injured a worker. Kris demanded the vendor's certificate of insurance, cleared the debris by hand so no customer or car would be hurt, and put the vendor's carrier on notice. The dealership never had a claim.

Saying the hard thing early

She told a dealership executive that an employee's documented threats made the company liable if it waited. The executive didn't like hearing it. Three weeks later the next incident happened, and the company did what Kris had advised.

How it starts

One conversation first.

Bring your notice. In the first call Kris tells you where you stand, what to do this week, and whether she can help. If she can't, she'll say so.

01

The notice call

A conversation about your notice, your deadlines, and the first steps. You leave with an action plan either way.

No charge
02

Notice response

The housekeeping above: records organized, practices corrected, policies delivered, supervisors trained, every step dated. Coordinated with your counsel.

Fixed fee
03

Standing advocate

Ongoing monthly support after the case: keeping records current, on-site response, claims advocacy, and supervisor training.

Monthly

Questions owners ask

Straight answers.

Is it too late to do anything?

No. The lower 15% cap is gone once a notice arrives, but the 30% cap is still available to employers who take reasonable steps to comply within 60 days after the notice. The sooner the work starts, the more of that window you have to use.

I already have a lawyer. Why would I need Kris?

Your lawyer should spend their hours on the legal case. Getting records pulled together, practices fixed, policies written and delivered, and supervisors trained is operational work. Kris does it under your counsel's direction, usually for far less than billing it at attorney rates.

We have fewer than 100 employees. Does that change anything?

Yes. Smaller employers have an extra option under the 2024 reform: a proposal to cure the alleged violations, which must be submitted within 33 days of the notice. Ask your counsel about it right away; the calculator above shows the date.

What does the first call cost?

Nothing. You'll leave the call knowing your deadlines and your first steps, whether or not you hire Kris.

Will anyone find out that we talked?

PAGA notices are public records on the state's website, which is how many people learn about them. Your conversation with Kris is private.

Why is a workers' comp person helping with wage-and-hour claims?

Because the same weak spots show up everywhere. A missed meal break, an unreported injury, and a claim reserve nobody challenged tend to come from the same gaps in how a business keeps its records. Kris has spent her career fixing those gaps from the employer's side.

Book a call · no charge

The clock started the day the notice did.

Bring your notice and your questions. Kris will tell you where you stand and what to do this week.

Phone · 24/7 for emergencies510.833.0723
OfficeDublin, California · serving the Bay Area and statewide
Book a call with Kris