(Cal. Wage Order No. 4-2001; Cal. Labor Code §§ 510, 1194,  Brought by Plaintiff on Behalf of Herself and the California Class)   (California Wage Payment Provisions, Cal. Labor Code §§ 201, 202, & 203,  Brought by Plaintiff on Behalf of Herself and the California Class)   (Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq.,  Brought by Plaintiff on Behalf of Herself and the FLSA Collective)   17.  Plaintiff brings this action on behalf of herself and all persons who have  worked for Defendant as Recruiters in any state other than Pennsylvania, at any time  within the three years prior to the filing of this Complaint through the date of the  final disposition of this action (the “FLSA Period”). This group is hereinafter  referred to as the “FLSA Collective.”   18.  The proposed FLSA Collective includes: all current and former  Recruiters who performed recruiting services for Defendant and were or are  classified as exempt from overtime within three years of the filing of their consent to  join.   19.  Plaintiff also brings this action on behalf of all persons who have  worked for Defendant in California as exempt-classified Recruiters at any time  within the four years prior to the date of the filing of this Complaint through the date  of the final disposition of this action (the “California Class Period”).   20.  The California Class is hereinafter referred to as the “State Law Class.”  31.  Defendant employs Account Managers who are responsible for working  directly with Defendant’s clients. Account Managers obtain all of the information  regarding the position that a client is trying to fill.  Clients advise Account Managers  of the specific credentials and qualifications required of a candidate.  Account  Managers in turn provide this information to Talent Acquisition Managers and  Recruiting Managers.     32.  Defendant’s Talent Acquisition Managers and Recruiting Managers  supervise Recruiters and inform Recruiters of a client’s hiring needs.    48.  Plaintiff brings the Second, Third, Fourth, Fifth, and Sixth Claims for  Relief for violation of California’s wage and hour and unfair competition laws as a  class action, pursuant to Fed. R. Civ. P. 23(a) and (b)(3), on behalf of all California  class members, defined in paragraph 19.   49.  Numerosity (Fed. R. Civ. P. 23(a)(1)) – The California Class is so  numerous that joinder of all members is impracticable.  Plaintiff is informed and  believes, and on that basis alleges, that during the California Class Period, Defendant  has employed at least 50 persons who satisfy the definition of the California Class.   67.  Plaintiff, on behalf of herself and all members of the California Class,  realleges and incorporates by reference all other paragraphs as if they were set forth  again herein.   68.  California law requires an employer, such as Defendant, to pay  overtime compensation to all nonexempt employees for all hours worked over 40 per  week, or over eight per day.   69.  Under California law, Plaintiff and the California Class are nonexempt  employees entitled to be paid overtime compensation for all overtime hours worked.   70.  Throughout the California Class Period, and continuing through the  present, Plaintiff and the California Class worked in excess of eight hours in a  workday and/or 40 hours in a workweek.   71.  During the California Class Period, Defendant misclassified Plaintiff  and the California Class as exempt from overtime pay entitlement and failed and  refused to pay them overtime premium pay for their overtime hours worked.   73.  Plaintiff, on behalf of herself and the California Class, realleges and  incorporates by reference all other paragraphs as if they were set forth again herein.   74.  California Labor Code §§ 201 and 202 require Defendant to pay its  employees all wages due within the time specified by law.  California Labor Code §  203 provides that if an employer willfully fails to timely pay such wages, the  employer must continue to pay the subject employees’ wages until the back wages  are paid in full or an action is commenced, up to a maximum of 30 days of wages.   75.  Plaintiff and all California Class members who ceased employment  with Defendant are entitled to unpaid compensation, but to date have not received  such compensation.   76.  More than 30 days have passed since Plaintiff and certain California  Class members left Defendant’s employ.   77.  As a consequence of Defendant’s willful conduct in not paying  compensation for all hours worked, Plaintiff and California Class members whose  employment ended during the class period are entitled to 30 days’ wages under  Labor Code § 203, together with interest thereon and attorneys’ fees and costs. 