 Plaintiff was hired by Defendants in May 2016 as a Client Service  Manager Senior.  Plaintiff’s employment agreement was entered into with AJG “on  behalf of itself and its subsidiaries, divisions and affiliated and related companies”.  A  true and correct copy of Plaintiff’s “Employee Agreement” and Employment Offer  Letter are attached as Exhibits A and B respectively.    Plaintiff’s payslips list “Arthur J. Gallagher Service Company” as the  “Business Group” and list the “Employer name” as “47615 GGB US – White & Co.  Commercial.”  GGB US is believed to stand for Gallagher Global Brokerage US, which  is believed to be a division of Arthur J. Gallagher & Co.  Arthur J. Gallagher & Co.  acquired White & Company Insurance, Inc. in or around February 2016, prior to the  beginning of Plaintiff’s employment.  True and correct exemplar copies of Plaintiff’s  payslips are attached as Exhibit C (with personal information redacted).    Plaintiff has also received a document from the Employment Development  Department of the State of California which lists here employer as “Arthur J. Gallagher  Service Company LLC.”  A true and correct copy of that document is attached as  Exhibit D (with personal information redacted).    As evidenced in Plaintiff’s Employment Offer Letter, dated May 19, 2016,  Defendants falsely represented to Plaintiff that her position, Client Service Manager  Senior, was exempt.  See Exh. B, p. 1.  As such, Plaintiff received an annual salary paid  in twenty-four equal installments on a semi-monthly basis for 37.5 hours per week  without overtime compensation.    Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23  on behalf of the following Class:  a)  All persons who are or were previously employed by Defendants as  Client Service Managers in California and were classified as exempt  from overtime wages.  b)  With respect to the UCL claim, the class period is four (4) years  prior to the filing of this Complaint (the “UCL Class Period”).    c)  With respect to all other claims, the class period is three (3) years  prior to the filing of this Complaint (the “Labor Code Class Period”).  Plaintiff reserves the right to amend the class definition and class period(s).    Excluded from the proposed Class are any person(s) employed by  Plaintiff’s counsel and any judicial officers assigned to this case, as well as their staff.    Numerosity:  While the exact number of Class Members can only be  determined by appropriate discovery, membership in the Class is ascertainable based  upon the employment and payroll records maintained by Defendants.  At this time,  Plaintiff is informed and believes that the Class includes hundreds of Clients Service  Managers in California.  Therefore, the Class is sufficiently numerous that joinder of all  members of the Class in a single action is impracticable under Federal Rule of Civil  Procedure Rule 23(a)(1), and the resolution of their claims through a class action will be  of benefit to the parties and the Court.    Plaintiff, individually and on behalf of the putative Class, realleges  Paragraphs 1 through37 of this Complaint as if fully set forth herein.    Defendants routinely require Plaintiff and the Class Members to work in  excess of eight (8) hours per workday and/or in excess of forty (40) hours per  workweek.  Defendants, however, failed to pay overtime wages to Plaintiff and the  Class.  Defendants instead improperly classified Plaintiff and the Class Members as  exempt to avoid paying them overtime wages.      California Labor Code § 510 and Wage Order 4-2001 require that an  employer compensate non-exempt employees for all work performed in excess of eight  (8) hours per workday and forty (40) hours per workweek, at the rate of 1½ times the  employee’s regular rate of pay.     Plaintiff, individually and on behalf of the putative Class, realleges  Paragraphs 1 through 43 of this Complaint as if fully set forth herein.     California Labor Code § 512(a) provides, in relevant part, that “an  employer may not employ an employee for a work period of more than five hours per  day without providing the employee with a meal period of not less than 30 minutes” and  that “[a]n employer may not employ an employee for a work period of more than 10  hours per day without providing the employee with a second meal period of not less  than 30 minutes . . . .”    Plaintiff, individually and on behalf of the putative Class, realleges  Paragraphs 1 through 50 of this Complaint as if fully set forth herein.    California Labor Code § 226 provides, in relevant part, that every  employer must furnish each employee with an itemized wage statement that shows the  total number of hours worked each pay period, gross wages, net wages, all deductions,  all applicable hourly rates of pay, the name and address of the legal entity that is the  employer, the last four digits (only) of the employee’s social security number and other  information.    Plaintiff, on behalf of the putative Class, realleges Paragraphs 1 through 57  of this Complaint as if fully set forth herein.    Gallagher performs insurance brokerage services.  Clients retain  Gallagher’s experts, called Producers, to consult and develop suitable risk  management programs tailored to the individual client’s needs and requirements.   Plaintiff, individually and on behalf of the putative Class, realleges  Paragraphs 1 through 63 of this Complaint as if fully set forth herein   For Failure to Provide Accurate Wage Statements  [Cal. Lab. Code § 226]  (By Plaintiff and the Class Against All Defendants)   For Failure to Pay Wages Due At Termination   [Cal. Lab. Code §§ 201, 202 and 203]  (By Plaintiff on Behalf of the Class Against All Defendants)   For Failure to Provide Off-Duty Meal Periods  [Cal. Lab. Code §§ 512 and 226.7 and Wage Order 4-2001]  (By Plaintiff and the Class Against All Defendants)   For Failure To Pay Overtime Compensation  [Cal. Lab. Code §§ 510, 1194, et seq. and Wage Order 4-2001]  (By Plaintiff and the Class Against All Defendants)   Violation of California’s Unfair Competition Law  [Cal. Bus. And Prof. Code §§ 17200, et seq.]  (By Plaintiff and the Class Against All Defendants)  