26.  The Defendants are a temporary employment agency whose business is dependent upon  successfully placing its employees on assignments with its clients.    27.  The interviews arranged by Defendants between its employees and its clients are essential to  a successful job placement and paramount to the success of its business. Defendants must ensure that the  employees selected for the interview are qualified for the position and prepared for the interview.   28.  Defendants maintain near-total control over the Class Members’ engagement with the  working world.  This process begins when Defendants first recruit the Class Members to become its  employees.   29.  Defendants recruit its employees in the same manner as any other company. Potential  employees are first screened through a robust qualification process — including resume matching and  behavioral interviews for technical, business, and cultural fits, as well as detailed supervisory reference  checks.  If the screening process goes well, Class Members are then required to go to one of Defendants’  offices to complete its new hire employee orientation process.     30.  As a part of its employee orientation, the Defendants provide the candidate with its new hire  paperwork.          58.   Plaintiff brings this action on his own behalf, as well as on behalf of each and all other  persons similarly situated, and thus seeks class certification under Federal Rules of Civil Procedure,  Rule 23.     66.  Plaintiff incorporates by reference and re-alleges as if fully stated herein the material  allegations set out in paragraphs 1 through 65.   67.  California Labor Code § 218 authorizes employees to sue directly for any wages or penalties  due to them under the Labor Code.   68.  California Code of Regulations Title 8, §11000(2) and the IWC Wage Orders §4(A)  "Every  employer shall pay to each employee ... wages not less than [the applicable minimum wage] per hour for  all hours worked...". "Hours worked" is defined as means the time during which an employee is subject  to the control of an employer, including all the time the employee is suffered or permitted to work,  whether or not required to do so.   69.  California Labor Code § 1194(a) provides that notwithstanding any agreement to work for a  lesser wage, any employee receiving less than the legal minimum wage applicable to the employee is  entitled to recover in a civil action the unpaid balance of the full amount of the applicable minimum  wage, including interest thereon, reasonable attorney’s fees, and costs of suit.   79.  Plaintiff incorporates by reference and re-alleges as if fully stated herein the material  allegations set out in paragraphs 1 through 78.   84.  Plaintiff incorporates by reference and re-alleges as if fully stated herein the material  allegations set out in paragraphs 1 through 83.   85.  California Labor Code section 218 authorizes employees to sue directly for any wages or  penalties due to them under the California Labor Code.   86.  California Labor Code section 223 provides that it is unlawful for an employer to secretly  pay a lower wage while purporting to pay the wage designated by contract.   87.  During the relevant time period Plaintiff and the other Class Members contracted with  Defendant to be paid an hourly wage for all time worked.   91.  Plaintiff incorporates by reference and re-alleges as if fully stated herein the material  allegations set out in paragraphs 1 through 90.   92.  At all times herein set forth, California Labor Code § 201 provided that if an employer  discharges an employee, the wages earned and unpaid at the time of discharge are due and payable  immediately.   93.  At all times herein set forth, California Labor Code §§ 202(a) provided that if an employee  quits his or her employment, the wages earned and unpaid at the time of discharge “become payable not  later than 72 hours thereafter…”    94.  During the relevant time period, Defendant failed to pay Plaintiff and those Class Members  whose employment with the Defendants was either voluntarily or involuntarily terminated their wages,  earned and unpaid, in accordance with Labor Code §§ 201, 201.3 & 202.    95.  Defendants’ failure to pay Plaintiff and those Class Members who are no longer employed by  Defendants their wages earned and unpaid at the time of discharge or voluntary termination violates  California Labor Code §§ 201, 201.3 & 202.   98.  Plaintiff incorporates by reference and re-alleges as if fully stated herein the material  allegations set out in paragraphs 1 through 97.     Violation of California Labor Code § 223   (Failure to Pay Agreed Upon Wages)  Against All Defendants and on Behalf of Plaintiff and the Class Members   Violation of California Labor Code § 1194(a)   (Failure to Pay Minimum Wages)  Against All Defendants and on Behalf of Plaintiff and the Class Members   Violation of California Labor Code § 226(a)  (Improper Wage Statements)  Against All Defendants and on Behalf of Plaintiff and the Class Members   Violation of California Labor Code §§ 201, 201.3, 202 & 203   (Wages Not Paid Upon Termination)  Against All Defendants and on Behalf of Plaintiff and the Waiting Time Subclass Members   Violation of California Business & Professions Code § 17200, et seq.  (Unfair Competition)  Against All Defendants and on Behalf of Plaintiff and the Class Members  