10. All individuals employed by Defendant as a Financial Advisor or the  functional equivalent however titled in California at any time from four  years prior to the filing of this complaint to the time the case is certified as  a class action.  As a result of Defendant’s violation of California law, Plaintiff and the other   11. members of the class were unlawfully under-compensated for their work and damaged thereby.  Numerosity. Plaintiff is informed and believes and thereon alleges that the   12. members of the class are so numerous that joinder is impractical.  Typicality and Adequacy. There are questions of law and fact common to Plaintiff   17. nationwide and in this judicial district.  Plaintiff and other Financial Advisors were primarily engaged in sales of   22. though repeated here.  California Labor Code §§ 221, 223, 400-410, 2802, and Title 8 of the California   23. Code of Regulations, § 11040(8) generally state that an employer may not deduct from or reduce  an employee’s wages for the purpose of shifting the employer’s ordinary cost of doing business  to the employee.    Plaintiff and all Morgan Stanley Financial Advisors in California routinely incur   27. though repeated here.  Labor Code § 221 provides, “It shall be unlawful for any employer to collect or   28. receive from an employee any part of wages theretofore paid by said employer to said  employee.”  Labor Code § 223 provides,  “Where any statute or contract requires an employer   29. to maintain the designated wage scale, it shall be unlawful to secretly pay a lower wage while  purporting to pay the wage designated by statute or by contract.”  Labor Code §§ 400-410 (“Employee Bond Law”) provide the limited   30. circumstances under which an employer can exact a cash bond from its employees.  These  provisions are designed to protect employees against the very real danger of an employer taking  or misappropriating employee funds held by the employer in trust.  Labor Code § 2802 provides that “[a]n employer shall indemnify his or her   31. employee for all necessary expenditures or losses incurred by the employee in direct  consequence of the discharge of his or her duties.”     Title 8 of the California Code of Regulations, § 11040(8), states, “No employer   37. though repeated here.  Defendant, as a matter of corporate policy did not maintain or provide accurate   9. to Federal Rule of Civil Procedure 23.  Plaintiff Harvey seeks certification of the following class:   Bus. & Prof. Code § 17200 et seq.  Plaintiff incorporates the allegations contained in the foregoing paragraphs as   Defendant sold and sells securities and other financial products with offices   Labor Code §§ 226, 1174, and 1174.5  Plaintiff incorporates the allegations contained in the foregoing paragraphs as   Labor Code §§ 221, 223, 400-410, 2802 and Cal. Code Reg. tit. 8, § 11040(8)  Plaintiff incorporates the allegations contained in the foregoing paragraphs as   Plaintiff brings this action on behalf of himself and on behalf of the class pursuant  