2.  This Complaint challenges systemic illegal employment practices  resulting in violations of the California Labor Code against employees of  Defendants.   33.   Plaintiff re-alleges and incorporates by reference paragraphs 1  through 32 as though fully set for herein.   37.  Plaintiff re-alleges and incorporates by reference paragraphs 1 through  36 as though fully set for herein.   38.  Defendants failed in its affirmative obligation to provide accurate  itemized wage statements.  Defendants, as a matter of policy and practice, did not  provide accurate records in violation of Labor Code § 226(a).  Specifically, as a  result of Defendants’ rounding policy, the wage statements failed to accurately  identify the correct number of hours worked, as well as the accurate gross/net  wages earned.  Further, whenever employees were paid overtime wages, the wage  statements failed to accurately identify the applicable a single overtime rates of  pay.    45.   Plaintiff re-alleges and incorporates by reference paragraphs 1 through  44 as though fully set for herein.   46.      At all times relevant herein, DEFENDANTS were required to pay  Plaintiff all earned wages in a timely fashion at the end of employment pursuant to  California Labor Code §§ 201 to 203.   47.      As a pattern and practice, DEFENDANTS intentionally failed to pay  Plaintiff her final wages pursuant to Labor Code §§ 201 to 203 and accordingly  owe waiting time penalties pursuant to Labor Code § 203.    48.   The conduct of DEFENDANTS and their agents and employees as  described herein was willfully done in violation of Plaintiff’s rights, and done by  managerial employees of DEFENDANTS.     49.  Therefore, Plaintiff is entitled to compensation pursuant to Labor  Code § 203.  50.  Plaintiff re-alleges and incorporates by reference paragraphs 1 through  49 as though fully set for herein.    51. This cause of action is brought pursuant to California Labor Code § 2802  which provides that employees are entitled to be indemnified for expenses and  losses in discharging the duties of their employers.   FOR VIOLATIONS OF THE UNFAIR PRACTICES ACT, B&P § 17200 ET  SEQ.  (AGAINST ALL DEFENDANTS BY PLAINTIFF AND ON BEHALF OF  FOR VIOLATION OF LABOR CODE §§ 201-203   (AGAINST DEFENDANTS AND DOES 1-100 BY PLAINTIFF [NON- CLASS CLAIM])   VIOLATION OF LABOR CODE §§ 510, 558, 1194, 1197 AND 1197.1  (AGAINST DEFENDANTS AND DOES 1-100 BY PLAINTIFF AND THE  ROUNDING CLASS)   VIOLATION OF LABOR CODE § 2802   (AGAINST DEFENDANTS AND DOES 1-100 BY PLAINTIFF [NON- CLASS CLAIM])   VIOLATION OF LABOR CODE § 226  (AGAINST DEFENDANTS AND DOES 1-100 BY PLAINTIFF AND THE  ROUNDING AND WAGE STATEMENT CLASSES)   a mailing address in the State of California.  Thus, for citizenship purposes, THC- ORANGE COUNTY, INC. is a citizen of Kentucky.  