17.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 16.   18.  During the CLASS PERIOD, as part of DEFENDANTS’ illegal  payroll policies and practices to deprive their non-exempt employees all wages  earned and due, DEFENDANTS required, permitted or otherwise suffered  PLAINTIFF and CLASS MEMBERS to take less than the 30-minute meal period,  or to work through them, and have failed to otherwise provide the required meal  periods to PLAINTIFF and CLASS MEMBERS pursuant to California Labor Code  § 226.7, 512 and IWC Order No. 1-2001, § 11.    19.  During the CLASS PERIOD, PLAINTIFF and other CLASS  MEMBERS were required to work through or cut short their meal breaks because  DEFENDANTS failed to maintain adequate staffing levels.  DEFENDANTS  required PLAINTIFF and other CLASS MEMBERS to assist customers, respond to  emails, and answer texts during these breaks. DEFENDANTS regularly failed to  staff enough employees to assist customers while permitting PLAINTIFF and other  CLASS MEMBERS to take required meal breaks.   24.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 23.   29.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 28.   30.  Pursuant to California Labor Code §§ 1194 and 1197, and IWC Wage  Order No. 1-2001, § 4, payment to an employee of less than the applicable  minimum wage for all hours worked in a payroll period is unlawful.   31.  During the CLASS PERIOD, DEFENDANTS failed to, and continue  to fail to, pay PLAINTIFF and CLASS MEMBERS minimum wages for all hours  worked by, among other things:  requiring, suffering, or permitting PLAINTIFF  and CLASS MEMBERS to work off-the-clock; requiring, suffering, or permitting  PLAINTIFF and CLASS MEMBERS to work through meal breaks; illegally and  inaccurately recording time worked by PLAINTIFF and CLASS MEMBERS;  failing to properly maintain PLAINTIFF’s and CLASS MEMBERS’ records;  failing to provide accurate itemized wage statements to PLAINTIFF and CLASS  MEMBERS for each pay period; and other methods to be discovered.   32.  DEFENDANTS knew or should have known that PLAINTIFF and  CLASS MEMBERS worked hours for which they were not compensated.   34.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 33.   35.  Pursuant to California Labor Code §§ 510 and 1194, and IWC Wage  Order No. 1-2001, § 3, DEFENDANTS are required to compensate PLAINTIFF  and CLASS MEMBERS for all overtime, which is calculated at one and one-half (1  ½) times the regular rate of pay for all hours worked in excess of eight (8) hours per  day and/or forty (40) hours per week, and for the first eight (8) hours on the seventh  consecutive workday, with double time for all hours worked in excess of twelve  (12) hours in any workday and for all hours worked in excess of eight (8) hours on  the seventh consecutive day of work in any workweek.     36.  PLAINTIFF and CLASS MEMBERS are current and former non- exempt employees entitled to the protections of California Labor Code §§ 510 and  1194, and IWC Wage Order No. 1-2001.     41.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 40.   48.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 47.   49.  During the CLASS PERIOD, DEFENDANTS knowingly and  intentionally failed, and continue to fail, to provide PLAINTIFF and CLASS  MEMBERS with timely and accurate itemized wage statements in writing showing  each employee’s gross wages earned, total hours worked, all deductions made, net  wages earned, the inclusive dates of the period for which the employee is paid, the  name and address of the legal entity or entities employing PLAINTIFF and CLASS  MEMBERS, piece rate wages, the last four digits of PLAINTIFF’s and CLASS  MEMBERS’ social security numbers or employee identification numbers, and all  applicable hourly rates in effect during each pay period and the corresponding  number of hours worked at each hourly rate, in violation of California Labor Code  § 226 and IWC Wage Order No. 1-2001, § 7.     50.  During the CLASS PERIOD, PLAINTIFF and CLASS MEMBERS  suffered, and continue to suffer, injury as a result of DEFENDANTS’ failure to  provide timely and accurate itemized wage statements, as PLAINTIFF and CLASS  MEMBERS could not promptly and easily determine from the wage statement  alone one or more of the following: the gross wages earned, the total hours worked,  all deductions made, the net wages earned, the name and address of the legal entity  or entities employing PLAINTIFF and CLASS MEMBERS, and/or all applicable  hourly rates in effect during each pay period and the corresponding number of  hours worked at each hourly rate.   52.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 51.   53.  During the CLASS PERIOD, as part of DEFENDANTS’ illegal  policies and practices to deprive PLAINTIFF and CLASS MEMBERS of all wages  earned and due, DEFENDANTS knowingly and intentionally failed to maintain  records as required under California Labor Code §§ 226 and 1174 and IWC Wage  Order No. 1-2001, § 7, including but not limited to the following records: total  daily hours worked by each employee; applicable rates of pay; all deductions; meal  periods; time records showing when each employee begins and ends each work  period; and accurate itemized statements.    55.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 54.    56.  California Labor Code § 2802(a) requires an employer to indemnify an  employee for all necessary expenditures or losses incurred by the employee in  direct consequence of the discharge of her his or her duties, or of his or her  obedience to the directions of the employer.   57.  During the CLASS PERIOD, DEFENDANTS knowingly and willfully  failed, and continue to fail, to indemnify PLAINTIFF and CLASS MEMBERS for  all business expenses and/or losses incurred in direct consequence of the discharge  of their duties while working under the direction of DEFENDANTS, including but  not limited to expenses for uniforms, cell phone usage, and other employment- related expenses, in violation of California Labor Code § 2802.     59.  PLAINTIFF incorporates herein by specific reference, as though fully  set forth, the allegations in paragraphs 1 through 58.    60.  Each and every one of DEFENDANTS’ acts and omissions in  violation of the California Labor Code and/or the applicable IWC Wage Order as  alleged herein, including but not limited to DEFENDANTS’ failure to provide meal  periods, DEFENDANTS’ failure to authorize and permit rest periods,  DEFENDANTS’ failure to pay minimum and overtime wages, DEFENDANTS’  failure to pay all wages due to discharged and quitting employees, DEFENDANTS’  failure to furnish accurate itemized wage statements, DEFENDANTS’ failure to  maintain required records, DEFENDANTS’ failure to indemnify PLAINTIFF and  CLASS MEMBERS for necessary expenditures and/or losses incurred in  discharging their duties, constitutes an unfair and unlawful business practice under  California Business and Professions Code § 17200, et seq.   61.  DEFENDANTS’ violations of California wage and hour laws  constitute a business practice because DEFENDANTS’ aforementioned acts and  omissions were done repeatedly over a significant period of time, and in a  systematic manner, to the detriment of PLAINTIFF and CLASS MEMBERS.   Failure to Authorize and Permit Rest Periods  [Cal. Labor Code §§ 226.7, 512; IWC Wage Order No. 1-2001, § 12]  (Against all DEFENDANTS)   Failure to Furnish Accurate Itemized Wage Statements  [Cal. Labor Code § 226; IWC Wage Order No. 1-2001, § 7]  (Against all DEFENDANTS)   Failure to Pay Overtime Wages  [Cal. Labor Code §§ 510, 1194; IWC Wage Order No. 1-2001, § 3]  (Against all DEFENDANTS)   Failure to Maintain Required Records  [Cal. Labor Code §§ 226, 1174; IWC Wage Order No. 1-2001, § 7]  (Against all DEFENDANTS)   Failure to Pay Minimum Wages  [Cal. Labor Code §§ 1194, 1197; IWC Wage Order No. 1-2001, § 4]  (Against all DEFENDANTS)   Failure to Pay All Wages Due to Discharged and Quitting Employees  [Cal. Labor Code §§ 201, 202, 203]  (Against all DEFENDANTS)   Failure to Provide Required Meal Periods  [Cal. Labor Code §§ 226.7, 510, 512, 1194, 1197; IWC Wage Order No. 1-2001,  § 11]  (Against all DEFENDANTS)   Failure to Indemnify Employees for Necessary Expenditures Incurred in  Discharge of Duties  [Cal. Labor Code § 2802]  (Against all DEFENDANTS)   Unfair and Unlawful Business Practices  [Cal. Bus. & Prof. Code § 17200, et seq.]  (Against all DEFENDANTS)  