(Oregon Regular, Overtime, and Termination Wages)   19.  Plaintiff incorporates and realleges the allegations contained in ¶¶1-18 as though fully set forth herein.    42.  Plaintiff incorporates and realleges the allegations contained in ¶¶1-32 as though fully set forth herein.  43.  Plaintiff and the similarly-situated employees have been and are entitled to the rights, protections, and benefits provided under Oregon State wage and hour laws.   44.  As the employer, Defendant is required to maintain and preserve records for the hours worked by each employee for each workday and the total hours worked for each workweek; and the total regular time earnings for each employee for hours worked for each workweek, exclusive of overtime hours.  Defendant is required to maintain a regular payday at which date all employees shall be paid the wages due and owing them.    7.  Defendant is a regional healthcare provider managing hospitals and related service departments in Deschutes, Crook, and Jefferson counties, to include Pioneer Memorial Hospital; St. Charles Medical Center - Bend; St. Charles Medical Center - Redmond; and St. Charles - Madras. Headquartered in Bend, Oregon, Defendant has 2,978 or more employees.  During 2010, Defendant had $496,697,733.00 in total revenue, with $475,549,705.00 in total expenses, for an annual net profit of over $21 million dollars.   8.  Defendant is subject to the FLSA and Oregon State wage and hour laws.   COMPLAINT  FLSA COLLECTIVE ACTION; RULE 23 CLASS ACTION  (FLSA; Oregon Wage and Hour Law)  h.  For such other and further relief as the Court finds just and proper.   DEMAND FOR JURY TRIAL Plaintiff hereby demands a jury trial on all issues triable by jury.  DATED: January 4, 2013.