A former employee has taken legal action against her previous employers, accusing them of multiple labor law violations and fraudulent activities. Danielle Vasquez filed a complaint in the Superior Court of California, County of San Francisco, on April 8, 2025, against Factorial Diagnostics, Inc., Factorial Biotechnologies, and John Wells. The lawsuit outlines numerous allegations including unpaid wages, breach of contract, fraud, and wrongful termination.
According to the complaint filed by Vasquez, she was employed by Factorial Diagnostics and Factorial Biotechnologies from May 16, 2022, until December 23, 2024. During this period, she alleges that the companies failed to pay her due wages timely and adequately. The complaint states that "Defendants knowingly and intentionally failed to remit required withholdings to the appropriate government agencies," thereby keeping these funds for themselves. This alleged misconduct not only affected her financially but also disrupted her healthcare coverage due to non-payment of insurance premiums by the defendants.
Vasquez's lawsuit highlights a pattern of behavior by John Wells, who is accused of using company assets for personal gain and failing to maintain proper corporate records. She claims that Wells paid some wages from his personal accounts while failing to fulfill corporate financial obligations. The complaint further alleges that the companies operated as mere shells without adequate capitalization intended to shield Wells from individual liability.
The plaintiff seeks a variety of remedies from the court. These include general damages amounting to $2 million for emotional distress and economic losses incurred due to the alleged unlawful conduct. Additionally, Vasquez demands unpaid wages totaling $450,000 and punitive damages worth $5 million as a deterrent against future misconduct by the defendants or others in similar positions. She also requests statutory penalties under various sections of the California Labor Code along with reasonable attorney fees.
Representing Danielle Vasquez are attorneys Mark C. Le Clerc and Christopher R. Le Clerc from Le Clerc & Le Clerc LLP based in San Francisco. The case is presided over by Judge Sahar Enayati under Case No. CGC-25-624153.