1.5 times the regular rates for which they were employed.     31.  Frontier is a provider of inspection services to pipelines, pipeline stations, terminals,  gathering, utilities, tank storage and other energy related fields.   33.  Rivera provided pipeline inspection services to Kinder-Morgan, Inc. in the Riverside  area through Frontier.   34.  Prior to being employed by Frontier, Rivera provided inspection services to Kinder- Morgan through another inspection services company.   35.  Prior to being employed by Frontier, Rivera was paid by the hour and was paid  overtime for hours worked in excess of 40 in a workweek and for hours worked in excess of 8 and 12  hours in a workday.   36.  In Summer 2018, Rivera was told that Kinder-Morgan was terminating its contract  with its previous inspection service provider.   37.  Rivera was told that he needed to sign a contract with Frontier in order to keep working  for Kinder-Morgan.   38.  The contracts provided to Rivera and other California Class Members stated that they  were now exempt employees and would not receive overtime.   39.  For example, Rivera’s contract with Frontier stated:   40.  Exhibit B to Rivera’s contract clarified his “day rate.”   42.  Rivera’s contract with Frontier became effective on July 1, 2018.   43.  After being employed by Frontier, Rivera no longer received overtime for hours  worked in excess of 40 hours per workweek or in excess of 8 or 12 hours in a workday, even though  his work duties remained the same.   44.  Rivera and the FLSA and California Class Members were misclassified as exempt  employees during the relevant statutory time period.   45.  Rivera knows other employees Frontier who are similarly situated in that they were not  properly paid overtime for the hours they worked in excess of 40 in a workweek and/or 8 and 12 in  a workday.   46.  These individuals should be notified of their right to join this lawsuit to collect back  wages.  47.  Rivera incorporates all other allegations.   48.  Frontier has violated, and is violating, section 7 of the FLSA, 29 U.S.C. § 207, by  employing day rate workers in an enterprise engaged in commerce or in the production of goods for  commerce within the meaning of the FLSA for workweeks longer than 40 hours without  compensating such day rate employees for work in excess of 40 hours per week at rates no less than   49.  Frontier knowingly, willfully, or in reckless disregard carried out this illegal pattern and  practice of failing to pay the day rate workers overtime compensation.   50.  Frontier’s failure to pay overtime compensation to these day rate workers was neither  reasonable, nor was the decision not to pay overtime made in good faith.   51.  Accordingly, Rivera and all those who are similarly situated day rate workers are entitled  to overtime wages under the FLSA in an amount equal to 1.5 times their rate of pay, plus liquidated  damages, attorney’s fees, and costs.  53.  The California Labor Code requires that all employees, including Rivera and the  California Class, receive time and one-half overtime premium compensation for hours worked over 8  in one day. CAL. LAB. CODE § 510 (2017); IWC Wage Order 16-2001.   54.  Despite working over 8 hours a day as part of their normal and regular shift, Rivera  and the California Class did not receive any overtime compensation for all hours worked over 8 in one  day.   55.  The California Labor Code also requires that all employees, including Rivera and the  California Class, receive two times the overtime premium compensation for hours worked over 12 in  one day. CAL. LAB. CODE § 510 (2017); IWC Wage Order 16-2001.   56.  Although Rivera and the California Class occasionally worked over 12 hours in one  day, they did not receive the “double time” compensation required by California law.   57.  The California Labor Code requires that all employees, including Rivera and the  California Class, receive two times the overtime premium compensation for hours worked over 8 in  one day, in the seventh day of a workweek. CAL. LAB. CODE §§ 510, 551–52 (2017); IWC Wage Order  16-2001.   58.  Although Rivera and the California Class regularly worked 7 days a week, for at least  12 hours a day, they did not receive the “double time” compensation required by California law for all  hours over 8 worked on the seventh day.   59.  This pattern, practice, and uniform administration of corporate policy regarding illegal  employee compensation is unlawful and entitles Rivera and the California Class to recover unpaid  balance of the full amount of overtime wages owing, including liquidated damages, interest, attorneys’  fees, and costs of suit pursuant to California Labor Code section 1194.  60.  Rivera incorporates all other allegations.   62.  Although the California Labor Code requires that all employees, including Rivera and  the California Class, receive two, 30-minute meal-period breaks when employed for 10 hours per day,  Rivera and the California Class did not receive two meal-period breaks for each day worked, despite  working shifts of 12 hours or more. CAL. LAB. CODE § 512; IWC Wage Order 16-2001.   63.  As a pattern and practice, Frontier did not provide Rivera and the California Class with  meal-period breaks, and did not provide proper compensation for this failure as required by California  law.   64.  Although the California Labor Code requires that all employees, including Plaintiff  and the California Class, receive a 10-minute rest period for every 4 hours worked, Rivera and the  California Class did not receive any rest periods during their shifts of 12 or more hours. CAL. LAB.  CODE § 512; IWC Wage Order 16-2001.   65.  As a pattern and practice, Frontier did not provide Rivera and the California Class with  rest-period breaks, and did not provide proper compensation for this failure as required by California  law.   66.  Rivera and the California Class are entitled to receive compensation, at their regular  rate of pay, of one hour for each day they were denied their lawfully required meal- and rest-periods.  CAL. LAB. CODE § 512; IWC Wage Order 16-2001.   67.  Frontier’s policy fails to provide Rivera and the California Class with the legally  mandated meal period breaks. Such a pattern, practice, and uniform administration of corporate policy  as described herein is unlawful and creates an entitled to recovery by Rivera and the California Class  in a civil action, for the balance of the unpaid compensation pursuant to Labor Code sections 226.7  and 512, and applicable IWC Wage Orders.  69.  California Labor Code section 226 requires Frontier to keep accurate records regarding  the rates of pay for their California employees and provide that information to Rivera and the  California Class with their wage payment.   70.  Because Frontier pay Rivera and the California Class a day rate instead of an hourly  rate with proper overtime pay, it did not maintain accurate records of Rivera and the California Class’  daily hours, gross wages earned, net wages earned, and the applicable hourly rates, and did not provide  that information to Rivera and the California Class with their wages.   71.  This pattern, practice, and uniform administration of corporate policy is unlawful and  entitles Rivera and the California Class to recover all damages and penalties available by law, including  interest, penalties, attorney fees, and costs of suit. CAL. LAB. CODE § 226(e).  72.  Rivera incorporates all other allegations.   73.  At all relevant times, Frontier was required to pay Rivera and the California Class all  wages owed in a timely fashion at the end of employment pursuant to California Labor Code sections  201 to 204.   74.  As a result of Frontier’s alleged California Labor Code violations, Frontier regularly  failed to pay Rivera and the California Class their final wages pursuant to California Labor Code  sections 201 to 204, and accordingly Frontier owes waiting time penalties pursuant to California Labor  Code section 203.   75.  The conduct of Frontier, in violation of Rivera and the California Class’ rights, was  willful and was undertaken by the agents, employees, and managers of Frontier.   76.  Frontier’s willful failure to provide Rivera and the California Class the wages due and  owing them upon separation from employment results in a continuation of wages up to 30 days from  the time the wages were due.   77.  Therefore, Rivera and the California Class who have separated from employment are  entitled to compensation pursuant to California Labor Code section 203.  79.  Frontier has engaged, and continues to engage, in unfair and unlawful business  practices in California by practicing, employing, and utilizing the employment practices outlined above  by knowingly denying employees: (1) overtime wages required under federal law; (2) overtime wages  required by California law; (3) meal- and rest-period break wages; and (4) accurate wage statements.   80.  As a result of Frontier’s failure to comply with federal and state law, Frontier has also  violated the California Unfair Competition Law (“UCL”), CAL. BUS. & PROF. CODE § 17200, et. seq.,  which prohibits unfair competition by prohibiting any unlawful or unfair business actions or practices.   81.  The relevant acts by Frontier occurred within the 4 years preceding the filing of this  action.   82.  On information and belief, Frontier has engaged in unlawful, deceptive, and unfair  business practices, pursuant to California’s Business and Professions Code section 17200, et seq.,  including those set forth above, depriving Rivera and the California Class of minimum working  condition standards and conditions under California law and IWC Wage Orders as set forth above.   83.  Rivera and the California Class are entitled to restitution for at least the following:  restitution for unpaid overtime wages and unpaid California Labor Code § 203 continuation wages.   84.  Rivera and the California Class are also entitled to permanent injunctive and  declaratory relief prohibiting Frontier from engaging in the violations and other misconduct referred  to above.     85.  Frontier is also liable for fees and costs pursuant to California Code of Civil Procedure  section 1021.5 and other applicable law.  86.  Dozens of employees have been victimized by this pattern, practice and policy which  are in willful violation of the FLSA.   87.  Frontier required the FLSA Class Members to perform job duties similar to those  performed by Rivera, including the requirement that they work overtime without overtime pay.   88.  Frontier paid these Inspection Workers in the same manner as it paid Rivera and did  not properly compensate them for all hours worked as required by the FLSA.   90.  The FLSA Class Members were all paid on a day rate basis and were regularly required  to work in excess of 40 hours per week without payment of overtime.   91.  Accordingly, the employees who were victimized by Frontier’s unlawful compensation  practices are similarly situated to Rivera.   92.  Frontier’s failure to pay wages and overtime compensation at the rates required by the  FLSA result from generally applicable policies and practices and do not depend on the personal  circumstances of the FLSA Class Members.   93.  Thus, Rivera’s experiences are typical of the experiences of the FLSA Class Members.   94.  The specific job titles or precise job requirements of the various FLSA Class Members  do not prevent collective treatment.   95.  All of the FLSA Class Members, regardless of their precise job requirements or rates  of pay, are entitled to be properly compensated for all unpaid overtime for all hours worked in excess  of 40 hours per workweek.   96.  Although the issue of damages may be individual in character, there is no detraction  from the common nucleus of liability facts.  97.  Rivera brings this action as a class action pursuant to Rule 23 of the Federal Rules of  Civil Procedure on behalf of the California Class.   98.    Numerosity: The proposed California Class is so numerous that joinder of all  members is impracticable. Rivera is informed and believes, and on that basis alleges, that during the  relevant time period, Frontier employed dozens of people who satisfy the definition of the California  Class.   COMPENSATION FOR MISSED MEAL AND REST PERIODS  