11.  For at least four years prior to the filing of Plaintiff’s Prior Action on  October 6, 2014, and continuing to the present Defendants have had a consistent  policy of failing to pay all wages due, including overtime at premium rates and failing  to provide and pay wages due for meal breaks and rest breaks to all of their security  guard employees.     21.  During the four-year period preceding the filing of the Prior Action on  October 6, 2014 and continuing to the present, Plaintiff and the Class members were  employed by Defendants as security guards in the State of California.  The terms and  conditions of employment between Plaintiff and the Class members on the one hand,  and Defendants on the other hand, were and are governed by the California Labor  Code, Title 8, California Code of Regulations, §§ 11000, et seq., and Industrial  Welfare Commission Wage Order 4-2001. Pursuant to such statutes, regulations and  Wage Order, Plaintiff and the Class members are classified as non-exempt employees  and, based thereon, are entitled to overtime pay for hours worked in excess of eight  (8) hours in any workday or more than 40 hours in any workweek.  Plaintiff is  informed and believes and based thereon alleges that the Class Period for this action  is the period commencing four years prior to the filing of Plaintiff’s Prior Action on  October 6, 2014 through and including the date judgment is entered herein.   22.  During the Class Period, Defendants have failed to pay Plaintiff and the  Class members for all hours worked and, as a result, have required Plaintiff and the  Class members to work for less than the legal minimum wage.   34.  Plaintiff realleges and incorporates herein by reference each of the  allegations set forth in the preceding paragraphs as though fully set forth herein.   35.  California Labor Code § 204 requires Defendants to pay Plaintiff and the  Class members all wages due and owing no less than twice during each calendar  month, on days designated in advance by Defendants as regular paydays.   36.  Plaintiff is informed and believes and based thereon alleges that  Defendants had a policy and practice of failing to pay Plaintiff and the Class members  all wages due and owing on the regular paydays and/or at any time thereafter. Based  thereon, Defendants failed to pay Plaintiff and the Class members in accordance with  California Labor Code § 204.   37.  As a proximate result of Defendants’ violation of California Labor Code  § 204, Plaintiff and the Class members have been damaged in an amount to be proven  at the time of trial. Plaintiff seeks recovery of all earned but unpaid wages.   38.  Pursuant to California Labor Code §§ 218.5 and 218.6, Plaintiff, on  behalf of himself and the Class members, is entitled to recovery of attorneys’ fees and  costs.  44.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   45.  During the Class period, California Labor Code Sections 226.7 and 512  and the applicable IWC order applied to Defendants’ employment of Plaintiff and the  Class members. At all times relevant hereto, California Labor Code Section 226.7  provided that no employer such as Defendants could require employees such as the  Plaintiff and Class members to work during any meal period mandated by an  applicable order of the IWC.    50.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   56.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   57.  During the Class period, California Labor Code Sections 201 and 202  applied to Defendants’ employment of Plaintiff and the Class members. At all times  relevant hereto, California Labor Code § 201 requires that if an employer discharges a  member of the Class, the wages earned and unpaid at the time of discharge are due  and payable immediately.  Further, California Labor Code Section 202 provides that,  if an employee such as a member of the Class voluntarily leaves his or her  employment, the wages earned and unpaid must be paid by the employer within  seventy-two (72) hours thereafter, unless the employee had given seventy-two (72)  hours pervious notice of this or her intention to leave in which case the employee is  entitled to receive his or her wages immediately at the time of quitting.   58.  Plaintiff is informed and believes and based thereon alleges that during  the Class Period, Defendants willfully failed to pay Plaintiff and the Class members,  who are former employees, their earned and unpaid wages, either at the time of their  discharge or within seventy-two (72) hours of their quitting. Defendant therefore  violated California Labor Code Sections 201 and 202.    61.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   62.  California Labor Code § 226(a) requires Defendants to furnish to each  employee at the time of each payment of wages an accurate itemized statement  showing (1) gross wages earned, (2) total hours worked by the employee . . . (3) the  number of piece-rate units earned and any applicable piece rate if the employees is  paid on a piece-rate basis . . . (4) all deductions, (5) net wages earned, (6) the  inclusive dates of the period for which the employee is paid, (7) the name of the  employee and identifying number, (8) name and address of the legal entity that is the  employer, and (9) all applicable hourly rates in effect during the pay period and the  corresponding number of hours worked at each hourly rate by the employees.   Subdivision (a) of California Labor Code section 226 further requires the employer to  keep a record or copy of the itemized wage statement on file for at least three years at  the place of employment or at a central location within the State of California.   68.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   76.  Plaintiff realleges and incorporates herein by this reference each of the  allegations set forth in the above paragraphs as though fully set forth herein.   77.  Based on the acts alleged above, and on behalf of himself, the Class  members, and the Labor and Workforce Development Agency (“LWDA”), Plaintiff  seeks penalties under California Labor Code §§ 2698 and 2699, et seq., for  Defendants’ violation of California Labor Code §§ 201- 204, 226(a), 226.7, and (e),  510, 512, and 1194.   78.  For each such violation, Plaintiff and the Class members are entitled to  penalties in an amount to be shown at the time of trial calculated as follows:  a.  For $100 for the initial violation per employee per pay payment;  and  b.  For $200 for each subsequent violation per employee per pay  period.   79.  In compliance with California Labor Code § 2698, Plaintiff  KARAPETYAN sent a certified letter on September 8, 2014 to the Labor and  Workforce Development Agency and Defendant setting forth the facts and theories  supporting Plaintiff KARAPETYAN’s allegation of the California Labor Code  violations by Defendants.     FOR FAILURE TO PROVIDE LAWFUL REST BREAKS AND  FAILURE TO PAY REST BREAK WAGES DUE  (By Plaintiff and All Classes Against All Defendants)   FOR FAILURE TO PROVIDE LAWFUL MEAL PERIODS AND  FAILURE TO PAY MEAL PERIOD WAGES DUE  (By Plaintiff and All Classes Against All Defendants)   FOR FAILURE TO PAY WAGES TIMELY ON TERMINATION  (By Plaintiff and the Terminated Security Guard Subclass Against All  Defendants)   FOR FAILURE TO PAY OVERTIME WAGES  (By Plaintiff and All Classes Against All Defendants)   FOR FAILURE TO PROVIDE ACCURATE WAGE STATEMENTS  (By Plaintiff and All Classes Against All Defendants)   FOR FAILURE TO PAY ALL WAGES  (By Plaintiff and All Classes Against All Defendants)   FOR PENALTIES PURSUANT TO THE LABOR CODE  PRIVATE ATTORNEY GENERAL ACT  (By Plaintiff and All Classes Against All Defendants)   FOR VIOLATION OF BUSINESS & PROFESSIONS CODE §§ 17200, et seq.  (By Plaintiff and All Classes Against All Defendants)  