1.  In 2013, Mercer Canyons was an agricultural employer pursuant to  the statutory definition of 29 U.S.C. §1802(2).   2.  In 2013, Plaintiff Ruiz was a seasonal agricultural worker pursuant to  the statutory definition of 29 U.S.C. §1802(10)(a).   29.  Plaintiffs Bacilio Ruiz and Jose Amador (“Representative Plaintiffs”)  bring this action on their own behalf and on behalf of a class of persons similarly  situated, pursuant to Federal Rules of Civil Procedure 23(a) and (b)(3), consisting  of all migrant and seasonal farm workers who: 1) were employed by Mercer  Canyons in 2012;  2) sought employment at Mercer Canyons in 2013 before fifty  percent of the Clearance Order period elapsed; or, 3) were hired at Mercer  Canyons in 2013 prior to fifty percent of the Clearance Order period and were not  referred by WorkSource.   3.  In 2013, at the time Plaintiff Amador applied for work at Mercer  Canyons he met the statutory definition of seasonal agricultural worker pursuant to  29 U.S.C. §1802(10)(a).  Mercer Canyon’s H-2A Application   30.  The class is so numerous that joinder of all members is impracticable.   The exact size of the class is not known; however on information and belief the  class consists of over 100 persons.   31.  Representative Plaintiffs are represented by experienced counsel who  will vigorously prosecute the litigation on behalf of the class.   32.  Questions of law and fact common to the members of the class  predominate over any questions affecting only individual members, and a class  4.  In 2013, Mercer Canyons, by and through its agent Washington Farm  Labor Association, applied to the federal Department of Labor to employ H-2A  workers.     5.  On January 16, 2013, Ryan Ayers, CFO of Mercer Canyons, signed  the H-2A application on behalf of Mercer Canyons.   6.  The application submitted by Mercer Canyons sought forty-four (44)  H-2A workers from March 24, 2013 through September 1, 2013, as set forth in the  Clearance Order (ETA 790 Form) attached to the application.  A.  PLAINTIFF CLASS – DECEIVED WORKERS   AWPA Coverage  