21.  During the relevant time period of this action, Defendant has employed  Plaintiff and other similarly situated individuals as traveling nurses to provide nursing  services to various healthcare facilities throughout California and the United States.    22.  atient care duties that they must attend  to throughout their shifts.  They work with patients and physicians.  They also must spend  time at the start and end of their shifts on the patient handoff process, where the outgoing  shift provides information concerning the patients to the incoming shift.  In addition, the  health and recovery for review by the treating physician and other nurses.    23.  The traveling nurses employed by Defendant are not unionized, but the  permanent, non-traveling nurses employed by the hosting facilities and the other health  care systems served by Defendant typically are unionized.   24.  Defendant placed Ms. Clifford to work at the Kaiser Permanente Zion  Medical Center in San Diego, California.   25.  In California, Defendant is obligated to compensate traveling nurses an  overtime premium rate of 1.5 times the regular rate of pay for hours worked between 8 and  - he regular rate for hours worked in  excess of 12 in a day.  In California and nationally, Defendant also is obligated to  compensate traveling nurses at a rate of 1.5 times the regular rate of pay for hours worked  in excess of 40 in a week.   36.  Plaintiff brings this Complaint as a collective action pursuant to 29 U.S.C. §  216(b) on behalf of the following class of individuals:  All individuals who worked as a traveling nurse or like  hourly position for Defendant nationwide at any time  beginning during the time period three years prior to the  filing the filing of the opt- join forms, plus time for equitable tolling, until resolution of  this action, and consisting of those who submit a consent to  join the action  .   36.  Plaintiff incorporates all allegations contained in the foregoing paragraphs.    37.  Defendant has not compensated these employees for the unpaid meal breaks  -the-  38.  - ective  action for the claims asserted by Plaintiff because her claims are similar to the claims  possessed by FLSA Class members.   39.  Plaintiff has actual knowledge that FLSA Class members have been denied  compensation for time worked, including meal breaks wor -the- also been denied overtime pay for this work and would therefore likely join this collective  action if provided a notice of their rights to do so, together with a clear statement that  opting to join such an action would not result in termination or other forms of retaliation.   59.  Plaintiff hereby realleges and incorporates by reference the paragraphs above  as though fully set forth herein.   68.  Plaintiff hereby realleges and incorporates by reference the paragraphs above  as though fully set forth herein.   69.  California Labor Code §226.7 and Title 8 of the California Code of  Regulations § 11040, ¶ 12 requires Defendant to authorize and permit off-duty rest periods  to Plaintiff and members of the proposed Class at the rate of ten minutes net rest time per  four hours or major fraction thereof.   70.  Defendant does not authorize or permit such off-duty rest periods to the extent  required by law.  To the contrary, the nurses regularly work long shifts without the  opportunity to rest off-duty for even ten minutes during each of their four-hour work  periods or major fractions thereof.     71.  statutorily-mandated r monitoring, rather than to maintain a system whereby other nurses relieve them at regular  intervals throughout the day.  The nurses routinely are not authorized and permitted to  take rest breaks of at least ten minutes by the end of every fourth hour of work or major  fraction thereof.   72.  Under both California Labor Code § 226.7 and Title 8 of the California Code  of Regulations §11040, ¶ 12, an employer must pay an employee who was denied a  requi for each workday that the rest period was not provided.   73.  Plaintiff brings Causes of Action Two through Nine as a class action on behalf  of herself and all others similarly situated pursuant to Federal Rule of Civil Procedure  23(a) and/or (b)(3).  Plaintiff brings the PAGA Cause of Action as a representative law  enforcement action, but not as a class action.     76.  Plaintiff realleges and incorporates the above paragraphs as though fully set  forth below.   77.  Califor performed by employees of every description, whether the amount is fixed or ascertained   78.  California Labor Code §§ 201 and 202 require an employer to pay all wages  earned but unpaid immediately upon the involuntary discharge of an employee or within  seventy-  79.  California Labor Code §204 provides that employers must compensate   80.  California Labor Code §§221-223 prohibit employers from withholding and  deducting wages, or otherwise artificially lowering the wage scale of an employee.   85.  Plaintiff hereby realleges and incorporates by reference the paragraphs above  as though fully set forth herein.   86.  California Labor Code §1174 requires Defendant to maintain payroll records  showing, among other things, the actual hours worked daily by its employees, wages paid  to its employees, the number of piece-rate units earned by its employees, and any  applicable piece rate paid to its employees.   87.  California Labor Code §1174.5 provides that employers who willfully fail to  maintain accurate payroll records shall be subject to civil penalties.    91.  Plaintiff hereby realleges and incorporates by reference the paragraphs above  as though fully set forth herein.   Failure to Pay Overtime Compensation  California Labor Code §§ 510, 515.5, 1194, and 1198 et seq., and IWC Wage Order  No. 5.   Failure to Pay for All Hours Worked in Violation of   California Labor Code §§ 201, 202, 204, and 221-223   Failure to Furnish Accurate Wage Statements  California Labor Code § 226   Failure to Keep Accurate Payroll Records  California Labor Code §§ 1174 & 1174.5   Failure to Provide Meal Periods, or Compensation in Lieu Thereof  California Labor Code §§ 226.7 and 512; and Cal. Code Regs., Title 8 §11040 ¶¶ 7  & 11   Failure to Provide Rest Periods, or Compensation in Lieu Thereof  California Labor Code §§ 226.7 and Cal. Code Regs., Title 8 § 11040 ¶ 12   VIOLATIONS OF 29 U.S.C. § 207   FAILURE TO PAY OVERTIME COMPENSATION   (FLSA COLLECTIVE ACTION)  