 VIOLATIONS OF WASHINGTON’S MEAL AND REST PERIOD REQUIREMENTS  RCW 49.12.020 AND WAC 296-126-092  (On behalf of the Washington Class Representative and the Washington Class)   20.  Plaintiff brings this action on behalf of himself and other similarly situated  employees as authorized under the FLSA, 29 U.S.C. § 216(b).  The employees similarly situated  are as follows:  FLSA Collective:  All Persons who have been employed by Defendant as mortgage  underwriters within the United States at any time starting three  years prior to the filing of the initial complaint in this action until  trial of this action.   21.  Upon information and belief, Defendant knew that Plaintiff and the FLSA  Collective performed work that required overtime pay.  Defendant operated under a scheme to  deprive these employees of overtime compensation by failing to properly compensate them for all  hours worked.   23.  Plaintiff (as “Washington Class Representative”) brings this action as a class  action pursuant to Rule 23 of the Federal Rules of Civil Procedure on behalf of the following  defined class:  Washington Class: All Persons who are, have been, or will be employed  by Defendant as mortgage underwriters within the  State of Washington at any time from three years prior  to the filing of this complaint through the trial of this  action.   24.  Numerosity: Upon information and belief, the Proposed Washington Class is so  numerous that joinder of all members is impracticable.  Plaintiffs are informed and believe, and  on that basis allege, that during the applicable statutory period, Defendant employed over forty  people who satisfy the definition of the Proposed Washington Class.     25.  Typicality:  The Washington Class Representative’s claims are typical of the  members of the Washington Class.  The Washington Class Representative, like other mortgage  underwriters, routinely worked more than forty hours per week during the Washington Class  Period.  The Washington Class Representative had the same duties and responsibilities as other  Class members. The Washington Class Representative and the Washington Class were subject to  Defendant’s policy and practice of improperly treating and classifying employees in this position  as “exempt” from wage and hour laws and failing to pay appropriate overtime compensation and  failing to provide legally required meal and rest periods.    26.  Superiority:  A class action is superior to other available methods for the fair and  efficient adjudication of the controversy, particularly in the context of wage and hour litigation  where individual plaintiffs lack the financial resources to vigorously prosecute separate lawsuits  in federal court against large corporate defendants.   32.  Plaintiff and the FLSA Collective allege and incorporate by reference the  allegations in the preceding paragraphs.   33.  At all relevant times, Defendant was an “employer” engaged in interstate  commerce and/or in the production of goods for commerce, within the meaning of the FLSA, 29  U.S.C. § 203.  At all relevant times, Defendant employed employees, including Plaintiff and each  member of the Collective.     34.  Plaintiff and additional opt-in Plaintiffs have consented in writing to be a part of  this action, pursuant to 29 U.S.C. § 216(b).  Their consent forms are attached as Exhibit A.  As  this case proceeds, it is likely that other individuals will sign consent forms and join as plaintiffs.   35.  The FLSA requires each covered employer, such as Defendant, to compensate all  non-exempt employees at a rate of not less than one and one-half times the regular rate of pay for  work performed in excess of forty hours per work week.     41.  The Washington Class Representative and the Washington Class allege and  incorporate by reference the allegations in the preceding paragraphs.   42.  RCW 49.46.130 requires employers to pay employees one and one-half times the  regular rate at which they are/were employed for all hours worked over forty (40) per work week.     43.  RCW 49.46.090 makes employers who violate RCW 49.46.130 liable to the  affected employees in the amount of unpaid wages, costs, attorney’s fees, and other appropriate  relief under the law.   44.  Defendant’s actions, policies, and/or practices as described above violate RCW    46.  The Washington Class Representative and the Washington Class allege and  incorporate by reference the allegations in the preceding paragraphs.   47.  RCW 49.12.010 provides that “[t]he welfare of the state of Washington demands  that all employees be protected from conditions of labor which have a pernicious effect on their  health.  The state of Washington, therefore, exercising herein its police and sovereign power  declares that inadequate wages and unsanitary conditions of labor exert such pernicious effect.”   48.  RCW 49.12.020 provides that “[i]t shall be unlawful to employ any person in any  industry or occupation within the state of Washington under conditions of labor detrimental to  their health.”     49.  Pursuant to RCW 49.12.005 and WAC 296-126-002, conditions of labor “means  and includes the conditions of rest and meal periods” for employees.     50.  WAC 296-126-092 provides that employees shall be allowed certain paid rest and  meal periods during their shifts.     51.  By the actions alleged above, including the failure to provide mortgage  underwriters with proper rest and meal periods, Defendant have violated the provisions of  RCW 49.12.020 and WAC 296-126-092.   FAIR LABOR STANDARDS ACT  29 U.S.C. §§ 201 et seq.  (On Behalf of Plaintiff and the FLSA Collective)   VIOLATIONS OF THE WASHINGTON MINIMUM WAGE ACT  RCW 49.46.130 & RCW 49.46.090  (On Behalf of the Washington Class Representatives and the Washington Class)  