Failure to Pay Minimum Wages—C.R.S. 8-6-101, et seq.  (On Behalf of Plaintiff and the Rule 23 Class)  170. Plaintiff restates and incorporates the following allegations as if fully  rewritten herein.   171. Each Defendant has at all times been an “employer” of Plaintiff and the Rule  23 Class members within the meaning of the Colorado minimum wage law.   172. Defendants failed to pay Plaintiff and the Rule 23 Class members all  minimum wages owed.  173. Defendants conduct and practices, as described herein, were willful and  intentional.   174. By reason of the unlawful acts alleged herein, Defendants are liable to  Plaintiff the Rule 23 Class members for unpaid wages, costs, reasonable attorneys’ fees,  and pre-judgment interest for all violations which occurred within the three years prior to  the filing of the Complaint.    