13. Defendant Paul Didelius is the Owner and President of Frontier Rail  Corporation, Frontier Rail Group, YCR Corporation, Yakima Central Railway,  Western Washington Railroad, Kennewick Terminal Railroad, Oregon  Railconnect, Lake Railway, and Cincinnati East Terminal Railroad (“The Short  Lines”).  42. Johnson brings this action individually, and as a class representative,  pursuant to Fed. R. Civ. P. 23(a) and (b)(3) and 29 U.S.C. § 201, et seq. on behalf  of himself and others similarly situated.   43. The class, comprised of all aggrieved current and past employees of  Defendants, is so numerous that joinder of all members is impractical. The class  consists of approximately 50 or more members.  a. There are questions of law or fact common to the class that  predominate over questions affecting only individual members.  b. The claims of the named Plaintiff are typical of the claims of  the class.  c. The named Plaintiff will fairly and adequately assert and  45. Johnson re-alleges each of the foregoing paragraphs of this Complaint  as though fully set forth herein.   46. Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Plaintiff  Johnson brings this action for himself and on behalf of a class - initially defined as  follows: All current and past employees of Defendants who have been aggrieved  by the Defendants’ failure to pay wages in accordance with the provisions of the  FLSA and WMWA.  53.  Johnson re-alleges each of the foregoing paragraphs of this Complaint  as though fully set forth herein.   54.  Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Plaintiff  COMPLAINT FOR DAMAGES  Pg. 7 of 17  GILBERT LAW FIRM, P.S.  421 W. Riverside, Ste 353  Spokane, WA 99201  FAIR LABOR STANDARDS ACT, 29 U.S.C. §§ 201 et seq.  (CLASS CLAIM)   THE WASHINGTON MINIMUM WAGE ACT, RCW 49.46.050 et. seq.  (CLASS CLAIM)  