13.  Plaintiff brings this cause of action on behalf of herself and on  8 behalf of the CLASS of all persons similarly situated, as more fully explained  9 below and above. This action is brought and may properly be maintained as a  10  class action pursuant to the provisions of Federal Rules of Civil Procedure  11  ("FRCP") section 23 and other applicable law pertaining to class actions.  12   14.  The proposed Class Plaintiff seeks to represent, sometimes  13  referred to herein as the "Class Members," is presently defined as follows: all  14  current or former non-exempt employees of any of the hotels owned, managed, or  15  operated by Defendants who are, have been, or will be employed in California  16  within four years as of the filing of the lawsuit or any similar job titles. There is a  17  well defined community of interest in the litigation and THE CLASS is  18  ascertainable.  19  a.  Numerositv: THE CLASS is so numerous that individual joinder of  20  all members is impractical under the circumstances of this case. While the exact  21  number of Class Members is unknown to Plaintiff at this time, Plaintiff is informed  22  and believes and thereon alleges that it is several hundred employees or more.  23  b.  Common Questions Predominate: Common questions of law and  24  fact exist as to all Class Members, and predominate over any questions that affect  25  only individual members of THE CLASS. The common questions oflaw and fact  26  include, but are not limited to:  27  28  6  5  6  7  