12.  Defendant PLANNERNET acts as a temporary staffing agency that provides its  clients with attendee personnel for seminars, conferences, symposia, trade shows, corporate  meetings, and dinners at various events throughout the United States and in California (hereinafter  “Client Events.”). PLANNERNET Client Events range from “small format” meetings, such as  private corporate dinners, to “Large Format” meetings such as at Oracle’s “OpenWorld,” which  draws thousands of attendees over the course of a week.    30.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   31.  During the Class Period, the Plaintiff Class worked, on many occasions, in excess  of 8 hours in a workday and/or 40 hours in a workweek. The precise number of overtime hours  will be proven at trial.    32.  During the Class Period, Defendant refused to compensate the Plaintiff Class for  all of the overtime wages earned, in violation of the applicable IWC Wage Order and provisions  of the California Labor Code.    33.  Moreover, during said time period, Plaintiff and many of the putative Class  Members were employed by and thereafter terminated or resigned from their positions with  Defendant, yet were not paid all overtime wages due upon said termination or within 72 hours of  said resignation of employment therefrom. Said non-payment of all wages due was the direct and  proximate result of a willful refusal to do so by the Defendant.   34.  At all relevant times, Defendant was aware of, and under a duty to comply with,  the overtime provisions of the California Labor Code including, but not limited to, California  Labor Code §§ 510, 1194, and 1198.   37.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   38.  Plaintiff and putative Class Members are entitled to meal periods in which they  were relieved of all job duties. Instead, Plaintiff believes, and thereupon alleges, that Defendant  did not schedule meal periods and required Plaintiff and putative Class Members to work  through their meal periods and to remain on-duty throughout their shift. Plaintiff is informed,  believes, and thereupon alleges that Defendant also interfered with putative Class Members’  ability to take timely, off-duty meal periods by refusing to allow them the freedom to leave the  premises of their assigned event, or otherwise completely relieve themselves of all duties while  at an event. Moreover, no “on duty” written meal period agreement and/or waiver, valid or  otherwise, affected Plaintiff’s and the putative Class Members’ entitlement to meal periods.  Furthermore, neither Plaintiff nor any putative Class Member ever meets any known test for  exemption from the entitlement to meal and rest periods. Thus, Defendant violated California  Labor Code §§ 226.7 and 512 and applicable Wage Orders.   39.  Plaintiff is informed and believes, and thereupon alleges, that Defendant required  Plaintiff and putative Class Members to work without receiving timely rest breaks to which they  were entitled.   42.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   43.  Wages are defined in California Labor Code section 200 and include all amounts  for labor performed.    44.  Hours worked pursuant to IWC Order No. 5-2001 includes “…time during which  an employee is subject to the control of an employer and includes all the time the employee is  suffered or permitted to work whether or not required to do so.”    45.  Plaintiff and Class Members were paid a flat rate per job, calculated by  multiplying a set number of hours by a non-negotiable hourly rate. Plaintiff and Class Members  did not receive any additional pay for any additional time they were engaged, suffered, or  permitted to work by Defendant. For example, before “large format” events, Defendant would  send Plaintiff event materials that she had to review, prepare, and bring to the event. After the  event, Plaintiff would have to mail the materials. This time was unpaid by Defendant.    46.  As an actual and proximate result of Defendant’s unlawful acts, Plaintiff and  Class Members have been deprived of compensation in an amount according to proof at the time  of trial, and are entitled to recovery of such amounts, plus interest thereon, attorneys’ fees, and  costs pursuant to Labor Code sections 218.5 and 218.6.       48.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   49.  California Labor Code section 201.3 requires payment of wages to “temporary  services workers” “no less frequently than weekly, regardless of when the assignment ends,” or  daily, if the worker’s duties meet the criteria under section 201.3(b)(1)(B)(2). California Labor  Code section 204 requires payment wages for all other workers no less than twice during each  calendar month.    50.  Defendant paid Class Members on a “Net-60” basis or no sooner than 60 days  following the completion of their temporary assignments.    51.  As a direct and proximate result of Defendant’s willful conduct in failing to  timely pay the Plaintiff Class  for all hours worked, these affected putative Class Members are  entitled to recover penalties pursuant to California Labor Code §§ 210, 558, and 2698 et seq. in  an amount to be established at trial, together with interest thereon, and attorneys’ fees and costs.  Wherefore, the Plaintiff prays for judgment as set forth below.  52.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.    56.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   57.  California Labor Code section 2802 provides that “an employer shall indemnify  his or her employee for all necessary expenditures or losses incurred by the employee in direct  consequence of the discharge of his or her duties . . . .”   58.  In the direct discharge of their duties as employees of Defendant,  Plaintiff and  putative Class Members performed tasks and took actions for which they expended their  personal funds, including but not limited to payment of a mandatory $50 “application fee” in  order to be hired by PLANNERNET, parking fees, and use of personal cell phones for business  related communications at events. For example, on April 3-5 2016, Plaintiff incurred parking  fees of up to $20 per day, and was told to use her cell phone to text PLANNERNET employees  with any issues that came up at the event. Those steps and actions were performed in the course  and scope of her employment with Defendant.   61.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   62.  Defendant has failed to provide timely, accurate itemized wage statements to the  Plaintiff and putative Class Members in accordance with California Labor Code §§ 226 and  1174.  Plaintiff is informed and believes and, on that basis, alleges that the statements provided  by Defendant do not accurately reflect the actual gross wages earned, net wages earned, or the  appropriate deductions of such putative Class Members.   63.  Plaintiff and putative Class Members suffered injury because Defendant failed to  provide accurate itemized wage statements that gave Class Members insufficient information to  accurately monitor the number of hours worked and challenge any payments received.  Consequently, Defendant is liable to Plaintiff and the putative Class Members s for penalties  provided by California Labor Code §226(e) in amounts to be determined at trial.   64.  Plaintiff seeks to recover actual damages, costs, and attorneys’ fees under these  provisions on behalf of herself and on behalf of the Plaintiff Class.  Wherefore, Plaintiff prays for judgment as set forth below.  65.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   72.  Plaintiff incorporates in this cause of action each and every allegation of the  preceding paragraphs, with the same force and effect as though fully set forth herein.   73.   Plaintiff, as an aggrieved employee, brings this claim pursuant to California  Labor Code §§ 2698-2699 on behalf of herself and all other current or former similarly  aggrieved Plannernet employees in California at any time for which recovery is authorized under  Labor Code §§ 2698-2699, et seq. Pursuant to California Labor Code § 2699.3, On October 21,  2016, Plaintiff Champagne, by and through her counsel, filed online and sent notice by certified  mail to the Labor and Workforce Development Agency (LWDA) and Defendants of the specific  provisions of the Labor Code that have been violated (“PAGA Notice”), including the facts and  theories to support the violations. The LWDA has not responded to Plaintiff’s PAGA Notice as  of the date of this Complaint.  Plaintiff thus has complied with the PAGA notice requirement.    74.  As alleged above, Defendant has violated the provisions of the California Labor  Code, specifically the failure to pay overtime, provide meal and rest periods, reimburse business  expenses, timely pay owed wages for all hours worked, and provide accurate itemized wage  statements.  Plaintiff seeks recovery of unpaid wages and penalties resulting from said violations  on behalf of herself and all other similarly aggrieved Plannernet employees in California at any  time for which recovery is authorized under California Labor Code §§ 2698-2699.   75.  Pursuant to California Labor Code § 2699,  Plaintiff is entitled to recover civil  penalties for Defendant’s violations of Labor Code sections 201, 201.3, 204, 210, 226, 226.3,  226.7, 402, 510, 512, 558, 1174, 1174.5, 1194, 1198, and 2802.   FAILURE TO PAY OVERTIME   (Violation of California Wage Orders and Labor Code §§ 510, 1194, 1198)   FAILURE TO PAY WAGES  (California Labor Code §§ 200, 201.3, 218.6, 1194, 1194.2, 1197)   FAILURE TO PROVIDE ACCURATE ITEMIZED WAGE STATEMENTS  (California Labor Code §§ 226, 1174)   FAILURE TO TIMELY PAY ALL WAGES DUE  (California Labor Code §§ 201.3, 204)    FAILURE TO PROVIDE MEAL AND REST PERIODS OR PAY MEAL AND REST  PERIOD PREMIUMS   (California Labor Code §§ 226.7, 512)   FAILURE TO PAY WAGES UPON RESIGNATION AND TERMINATION  (California Labor Code § 203)   FAILURE TO REIMBURSE BUSINESS EXPENSES   (California Labor Code § 2802)   RECOVERY UNDER PRIVATE ATTORNEYS GENERAL ACT (PAGA)  (California Labor Code § 2698, et seq.)   UNFAIR BUSINESS PRACTICES UNDER THE UNFAIR COMPETITION LAW  (California Business & Professions Code §§ 17200-17208)  