11.  Plaintiffs incorporate paragraphs 1 through 10 of this complaint as if fully alleged  6  17.  Plaintiffs incorporate paragraphs 1 through 10 of this complaint as if fully alleged  25  herein.  26   18.  At all relevant times, Plaintiffs and the other members of the Rest Periods Class were  27  employees of Defendant covered by Labor Code Section 226.2.  28   19  (By Plaintiff and the Second Rest Periods Class against Defendants)  20   19.  Pursuant to Labor Code Section 226.2, Plaintiffs and the other members of the Rest  7  22  FAILURE TO PAY ALL WAGES OWED FOR REST PERIOD TIME  23  (By Plaintiff and the Rest Periods Class against Defendants)  24   23.  Plaintiffs incorporate paragraphs 1 through 10 of this complaint as if fully alleged  21  herein.  22   24.  At all relevant times, Plaintiffs and the other members of the Second Rest Periods Class  23  were employees of Defendant covered by Labor Code Section 226.7 and applicable Wage Orders.  24   25.  Pursuant to applicable Wage Orders, Plaintiff and the other members of the Second Rest  25  Periods Class were entitled to rest periods of at least 10 minutes for each four hour period of work.  26   26  FAILIRE TO PAY MINIMUM WAGES  27  (By Plaintiff and the Field Workers Class against Defendants)  28   26.  Pursuant to Labor Code Section 226.7, Defendant was required to pay Plaintiffs and  27  other members of the Second Rest Periods Class premium wages, equal to one hour of pay at their  28  regular rate of pay, for each day that a legally required rest period was not provided.  8  4   8.  Plaintiffs bring their claims on behalf of themselves and all other similarly situated  5  Field Workers (collectively the "Class") as a class action pursuant to Rule 23 of the Federal Rules of  6  Civil Procedure. The members of the Class belong to the Field Worker Class, Rest Periods Class,  7  Second Rest Periods Class, Restitution Class, Wage Statement Class and/or Final Wages Class, which  8  are defined as follows:  9  Field Workers Class: All persons who, at any time since the date three years before the filing  10  of the complaint in this action, worked for Defendant in California as a seasonal agricultural worker  11  who performed field work harvesting strawberries.  12  Rest Periods Class: All persons who, at any time since January 1, 2016, worked for  13  Defendant in California as a seasonal agricultural worker who performed field work harvesting  14  strawberries.  15  Second Rest Periods Class: All persons who, at any time since the date three years before the  16  filing of the complaint in this action, worked for Defendant in California as a seasonal agricultural  17  worker who performed field work harvesting strawberries and worked more than six hours but less  18  than seven and one half hours in a workday.  19  Restitution Class: All persons who, at any time since the date four years before the filing of  20  the complaint in this action, worked for Defendant in California as a seasonal agricultural worker who  21  performed field work harvesting strawberries.  22  Wage Statement Class: All persons who, at any time since the date one year before the filing  23  of the complaint in this action, worked for Defendant in California as a seasonal agricultural worker  24  who performed field work harvesting strawberries.  25  Final Wages Class: All persons who worked for Defendant in California as a seasonal  26  agricultural worker who performed field work harvesting strawberries who had a period of  27  employment during any harvesting season end at any time since the date three years before the filing of  28  the complaint in this action.  4 