(Violation of California Business & Professions Code §§ 17200 et seq.)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code sections 226.7)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code § 204)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code section 1174, subdivision (d))  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code section 226.7)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code §§ 201 and 202)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code § 1198)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code sections 1194, 1197, and 1197.1)  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   (Violation of California Labor Code § 226(a))  (Against Defendant HAIR CLUB FOR MEN, LLC and DOES 1 through 100)   12.  Defendants employed Plaintiff CLEMENS as hourly-paid, non-exempt employee from  on or about April 29, 2014 to October 23, 2014 in the State of California.   33.  Plaintiffs bring this action on their own behalf and on behalf of all other members of  the general public similarly situated, and thus, seek class certification under Code of Civil Procedure  section 382.   34.  The proposed class is defined as follows:    All current and former hourly-paid or non-exempt employees employed by  Defendants within the State of California at any time during the period from  four years preceding the filing of this Complaint to final judgment.   35.  Plaintiffs reserve the right to establish subclasses as appropriate.   38.  At all times herein set forth, the Private Attorneys General Act of 2004 (“PAGA”) was  applicable to Plaintiffs’ employment by Defendants.   39.  At all times herein set forth, PAGA provides that any provision of law under the  California Labor Code that provides for a civil penalty to be assessed and collected by the LWDA for  violations of the California Labor Code may, as an alternative, be recovered through a civil action  brought by an aggrieved employee on behalf of himself and other current or former employees pursuant  to procedures outlined in California Labor Code section 2699.3.   40.  Pursuant to PAGA, a civil action under PAGA may be brought by an “aggrieved  employee,” who is any person that was employed by the alleged violator and against whom one or  more of the alleged violations was committed.   41.  Plaintiffs were employed by Defendants and the alleged violations were committed  against him during his time of employment and he is therefore, an aggrieved employee.  Plaintiffs are  “aggrieved employees” as defined by California Labor Code section 2699, subdivision (c).    44.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through  43, and each and every part thereof with the same force and effect as though fully set forth herein.   53.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through 52,  and each and every part thereof with the same force and effect as though fully set forth herein.   63.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through 62,  and each and every part thereof with the same force and effect as though fully set forth herein.   64.  At all times herein set forth, the applicable IWC Wage Order and California Labor Code  section 226.7 were applicable to Plaintiffs’ and the other class members’ employment by Defendants.   65.  At all relevant times, California Labor Code section 226.7 provides that no employer shall  require an employee to work during any rest period mandated by an applicable order of the California  72.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through 71,  and each and every part thereof with the same force and effect as though fully set forth herein.   73.  At all relevant times, California Labor Code sections 11194, 1197, and 1197.1 provide  that the minimum wage to be paid to employees, and the payment of a lesser wage than the minimum so  fixed is unlawful.   74.  During the relevant time period, Defendants regularly failed to pay minimum wage to  Plaintiffs and the other class members as required, pursuant to California Labor Code sections 11194,  1197, and 1197.1.   75.  Defendants’ failure to pay Plaintiffs and the other class members the minimum wage as  required violates California Labor Code sections 1194, 1197, and 1197.1.  Pursuant to those sections  Plaintiffs and the other class members are entitled to recover the unpaid balance of their minimum wage  compensation as well as interest, costs, and attorney’s fees, and liquidated damages in an amount equal to  the wages unlawfully unpaid and interest thereon.   76.  Pursuant to California Labor Code section 1197.1, Plaintiffs and the other class members  are entitled to recover a penalty of $100.00 for the initial failure to timely pay each employee minimum  wages, and $250.00 for each subsequent failure to pay each employee minimum wages.   77.  Pursuant to California Labor Code section 1194.2, Plaintiffs and the other class members  are entitled to recover liquidated damages in an amount equal to the wages unlawfully unpaid and interest  thereon.  78.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through  77, and each and every part thereof with the same force and effect as though fully set forth herein.   84.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through 83,  and each and every part thereof with the same force and effect as though fully set forth herein.   85.  At all times herein set forth, California Labor Code section 204 provides that all wages  earned by any person in any employment between the 1st and 15th days, inclusive, of any calendar  month, other than those wages due upon termination of an employee, are due and payable between the  16th and the 26th day of the month during which the labor was performed.   90.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through  89, and each and every part thereof with the same force and effect as though fully set forth herein.   94.  Plaintiffs incorporate by reference the allegations contained in paragraphs 1 through 93,  and each and every part thereof with the same force and effect as though fully set forth herein.   95.  Pursuant to California Labor Code section 1174, subdivision (d), an employer shall keep,  at a central location in the state or at the plants or establishments at which employees are employed,  payroll records showing the hours worked daily by and the wages paid to, and the number of piece-rate  units earned by and any applicable piece rate paid to, employees employed at the respective plants or  establishments.  These records shall be kept in accordance with rules established for this purpose by the  commission, but in any case shall be kept on file for not less than two years.   96.  Defendants have intentionally and willfully failed to keep accurate and complete payroll  records showing the hours worked daily and the wages paid, to Plaintiffs and the other class members.   97.  As a result of Defendants’ violation of California Labor Code section 1174, subdivision  (d), Plaintiffs and the other class members have suffered injury and damage to their statutorily-protected  rights.  