Wage-and-hour exposure, reconstructed from the records themselves.

Deterministic wage-and-hour reconstruction for management-side defense counsel. Every employee, every pay period, with provenance back to the source row.

Book a 20-minute call
From source to figure

01 / Source records

  • Timecards
  • Pay registers
  • Badge data
  • Wage statements

02 / Reconstruction

Every employee.
Every pay period.

Source row and applied rule

03 / Work product

  • Violation matrix
  • Cure figure
  • Exposure figure

Before the strategy, someone has to rebuild the records.

Years of records. Different systems.

Timecards, pay registers, badge records, and wage statements tell different parts of the story. A PAGA notice, class or collective action, or demand letter requires a reconstruction across years of source data.

A sample is not the full record.

Sampling and extrapolation produce an estimate. Reconstruction follows the full employee population, pay period by pay period, back to the underlying records.

Associate time belongs on strategy.

Rebuilding the data is not the defense strategy. Counsel needs record-based figures to evaluate the matter, without diverting associate hours into manual reconstruction.

Allegations in wage-and-hour class action litigation

These allegations can frame counsel's damages and exposure analysis. They are questions to evaluate against the records, not assumed findings.

  • Unlawful alternative workweek schedules
  • Unreimbursed business expenses
  • Unpaid premiums for missed meal periods
  • Unpaid premiums for missed rest periods
  • Unpaid overtime
  • Incorrect overtime-rate calculations
  • Unauthorized edits to time records
  • Misclassification of employees as exempt
  • Unpaid off-the-clock work
  • Improper automatic meal deductions

Counsel determines the applicable legal standards. Classification and policy issues require legal assessment alongside record-based calculations.

A violation matrix. A cure figure. An exposure figure.

An employee-by-pay-period matrix and two separate monetary figures, built from the same source records.

Violation matrix

A structured employee-by-pay-period matrix of identified violations. Each finding ties to the source record and the applied rule.

Illustrative structure only. No client data or calculated amounts.

Illustrative violation-matrix structure. Employee and period identifiers are fictional. No actual findings or calculated figures are shown.
EmployeePay periodRuleSource rowFigure
E-001Period ARule APR-1042Not shown
E-001Period ARule BTR-5587Not shown
E-002Period BRule APR-3301Not shown
E-003Period BRule BTR-7710Not shown
E-004Period CRule APR-6654Not shown

Cure figure

A quantified amount for counsel's cure analysis, calculated from the reconstructed records.

Counsel determines the applicable cure requirements. A calculation alone does not complete a statutory cure.

Exposure figure

A record-based measure of wage-and-hour exposure to support counsel's economic damages calculations and evaluation of the matter.

Separate from the cure figure, with an audit trail to each source row and applied rule.

Source records in. Defensible work product out.

  1. Records in

    Counsel sets the scope. We work from the dispute documents and the employer's timecards, pay registers, badge data, and wage statements to reconstruct the underlying time and pay record.

  2. Reconstruction

    We reconstruct the full employee population, punch by punch and pay period by pay period. The math is deterministic and reproducible. The same source records and rules produce the same figures.

  3. Work product out

    Counsel receives structured work product: the violation matrix, cure figure, and exposure figure. Every dollar has a reviewable path back to the source row and the rule that produced it.

Complete. Traceable. Timely.

Complete

Every punch across the full employee population, pay period by pay period. The records are reconstructed, rather than sampled and extrapolated.

Traceable

A row-level audit trail connects each figure to the source record and the applied rule. Counsel can review the calculation, not just the total.

Timely

A defensible figure within the window counsel is working to, including applicable PAGA deadlines.

Working under counsel's direction.

You refer us to your client. The employer pays for the reconstruction. We work under your direction, and you keep the client relationship.

Tally & Trace is not a law firm. We do not provide legal advice or handle privileged communications. Our role is to reconstruct the records and give counsel the math behind each figure.

How we work with counsel, in 20 minutes.

A short call about our method, our work product, and our role under your direction. No pitch. No obligation.

Calendar booking will be available soon.