22.  Broadspectrum serves the oil drilling industry by providing clients operating oil  refineries with skilled personnel who specialize in planning, implementing, and executing safety  protocols for oil refinery operations.  Broadspectrum provides services throughout the United  States, including in California.    47.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   48.  Plaintiff brings her FLSA claims as a collective action pursuant to 29 U.S.C. § 216(b)  as to claims for failing to pay Plaintiff and Collective members for all hours worked, including  minimum wage, wages at the agreed rate, and overtime compensation for all hours worked over 40  hours per week, liquidated damages, and attorneys’ fees and costs under the FLSA.  The FLSA  Collective that Plaintiff seeks to represent is defined as follows:  All  current  and  former  hourly,  non-exempt  employees  of  Broadspectrum, Inc. in the United States during the time period three  years prior to the filing of this Complaint until the resolution of this  action.    49.  Plaintiff’s claims for violations of the FLSA may be brought and maintained as an  “opt-in” collective action pursuant to Section 216(b) of the FLSA because Plaintiff’s FLSA claims  are similar to the claims of the Collective members.     50.  The Collective members are similarly situated, as they have substantially similar job  duties and requirements and are subject to a common policy, practice, or plan that required them to  perform work without compensation and required them to perform work at an unlawfully reduced  payment rate, in violation of the FLSA.   51.  Plaintiff is representative of the Collective members and is acting on behalf of their  interests, as well as Plaintiff’s own interests, in bringing this action.   52.  Plaintiff will fairly and adequately represent and protect the interests of Collective  members.  Plaintiff has retained counsel competent and experienced in employment class action  and collective action litigation.   54.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   55.  Plaintiff brings this case as a class action on behalf of herself and all others similarly  situated pursuant to Federal Rule of Civil Procedure 23.  The putative Class that Plaintiff seeks to  represent is defined as follows:      All  current  and  former  hourly,  non-exempt  employees  of  Broadspectrum, Inc. in California during the time period four years prior  to the filing of this Complaint until the resolution of this action.   57.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   58.  The FLSA requires that covered employees receive compensation for all hours  worked and overtime compensation not less than one and one-half times the regular rate of pay for  all hours worked in excess of forty hours in a work week.  29 U.S.C. § 207(a)(1).     59.  At all times material herein, Plaintiff and the Collective are covered employees  entitled to the rights, protections, and benefits provided under the FLSA. 29 U.S.C. §§ 203(e) and  207(a).   60.  Defendant is a covered employer required to comply with the FLSA’s mandates.     61.  Defendant has violated the FLSA with respect to Plaintiff and the Collective, by, inter  alia, failing to compensate Plaintiff and the Collective for all hours worked and, with respect to  such hours, failing to pay the legally mandated overtime premium for such work and/or minimum  wage.     62.  Defendant has also violated the FLSA by failing to keep required, accurate records  of all hours worked by Plaintiff and the Collective.  29 U.S.C. § 211(c).     68.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   69.  Labor Code § 200(a) defines wages as “all amounts for labor performed by  employees of every description, whether the amount is fixed or ascertained by the standard of time,  task, piece, commission basis or other method of calculation.”   82.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   83.  During the applicable statutory period, California Labor Code §§, 1182.12 and 1197,  and the Minimum Wage Order were in full force and effect and required that Broadspectrum’s  hourly employees receive the minimum wage for all hours worked irrespective of whether  nominally paid on a piece rate, or any other bases, at the rate of ten dollars and fifty cents ($10.50)  per hour commencing January 1, 2017.    89.  Plaintiff re-alleges and incorporates the foregoing paragraphs as though fully set forth  herein.   Failure to Pay Minimum Wages Pursuant to California Labor Code §§ 1182.11, 1182.12,  1194, 1197, and 1197.1  (On Behalf of the Class)   Failure to Pay for All Hours Worked Pursuant to Labor Code § 204   (On Behalf of the Class)   Failure to Pay Overtime Wages Pursuant to Labor Code § 510   (On Behalf of the Class)   Violation of the Fair Labor Standards Act  29 U.S.C. §§ 201, et seq.  (On Behalf of the Collective)  