12  13  14  15  16  '7  18  '9  20  21 11   CHARLES E. WARD; FELICIA VIDRJO and )  PAUL BRADLEY, individ11y. and on behalf of )  all others similarly situated,  )  )  Plaintiffs,  )  V.  UNITED AIRLINES, INC., and Does 1 through )  25, inclusive,  )  )  Defendants.  ..  )  CaseNo.:   Pilots employed by Defendants are required to report for duty at the airport, in  60 minutes before their first flight in the duty period for domestic flights, 90 minutes before their  all flight in the duty period for international flights, and 30 minutes before each additional flight that  in the same duty period. The duty period begins when a pilot is required to report for duty and  --to  11 11  perform during the 60, 90, and 30-minute pre-flight reporting time periods. Defendants only compensal  12 the pilots for actual flight time, that is, the time beginning when all cabin and cargo doors on the airci  13 are closed and the parking brakes are released, and ending when the aircraft arrives at a passeni  14 unloading point and the first cabin or cargo door is opened. The duties performed by the pilots dun  15 the unpaid 60, 90, and 30-minute pre-flight reporting time periods include, but are not limited  160 obtaining the flight plan, loading the flight, plan onto the aircraft's computer, calculating the corr  17 amount of fuel needed f6i the flight plan, recalculating the flight plan and fuel requirements as needed  18  adjust for bad weather, checking all switches in the cockpit to ensure 'they are physically set in  correct position for the pushback sequence, input all' non-safety related repair/maintenance if  20  received from the flight attendant's cabin inspection, and conducting a physical inspection'of  21  exterior of the aircraft ('e.g. one of the,  pilots 'inspects' the tires, tire pressure, engines, lights, ft  22  . .  2311 aileron, flight service controls, pitot static system intakes, and checks for hydraulic leaks and oil leaks)  2411 The pilots receive no compensation for performing these important pre-flight duties.  14  1511  UNFAIR BUSINESS PRACTICES  16   15  WAITING TIME PENALTIES   20  UNPAID MINIMUM WAGE  21  22  11    Plaintiffs hereby incorporate by reference Paragraphs I through 24 above as though fully  4  set forth herein.    Plaintiffs rendered services to Defendants benefiting Defendants, to wit, pre-flight work  711 performed in California and on-call "reserve status" work performed in California, but were not  compensated by Defendants for sUch work. Injustice has resulted to Plaintiffs and the Class Members  III providing the bnefith of this work to Defendants without compersation,and Defendants have thereby  lOj been unjustly enriched Accordingly, Plaintiffs seek recovery for themselves and the other Class  Members for the reasonable value of the services they provided to Defendants without compensation.  1211   Plaintiffs and the other Class Members seek restitution from Defendants of all unpaid waged for pre-  13  flight work performed in California and all unpaid wages for on-call "reserve status" work performed in  14  California, and seek restitution of these unpaid wages as measured by the applicable regular hourly rates  15  16 11  listed on their wage statements multiplied by the number of unpaid hours of pre-flight work and on-call  17H reserve status work perfontied by each Class Member in California during the applicable statutory  isll period;  plus interest.  19   Plaintiffs hereby incorporate by reference Paragraphs I through 26 above as though fully  set forth herein.  23  24  25   Plaintiffs hereby incorporate by reference Paragraphs I through 28 above as though fully  17 set forth herein.  18    Labor Code 201(a) statesthat if an employer discharges an employee, all wages  20 and unpaid at the time of discharge ae due and payable immediately. Likewise pursuant to Labor Co  21 § 202(a), if an employee resigns,. the employer must pay all wages earned and unpaid not later than  22 hours after resignation: If an employer fails to comply with its obligations under Labor Code §201(  23 and 202(a), then pursuant to Labor Code § 203, the employer must pay statutory penalties to the affect(   Plaintiffs hereby incorporate by reference Patagraphs I through 32 above as though filly  17 setforthherein.  'U    California Business & Professions Code § 17200, et seq., prohibits acts of unfair  'It  competition, which includes any 'unlawful, unfair or fraudulent business act or practice..." The Class  20  21  Members, including Plaintiffs, have suffered and continue to suffer injuries in fact, due to the unfair and  22 unlawhil business practices of Defendants as alleged herein above. Defendants' conduct alleged above  2311 violated California's Labor Code and FWC Wage Order No. 9-2001.  -.  A.  Unpaid Pre-Flight Duties   Plaintiffs hereby incorporate by reference Paragraphs 1 through 16 above as though full:  set focth herein.  Class Definitions. Plaintiffs bring this action on behalf of themselves and all  similarly situated as a class action pursuant to Code of Civil Procedure §382. The Classes that  seek to represent are defined as follows:  (1)  All persons who werd employed by UNITED AIRLINES, INC. as pilots at any  time from four years before the filing of the Complaint up through the time of the  judgment in this action, who performed any unpaid pre-flight work in California.  QUANTUM MERUIT/QUASI-CONTRACT  3   STREETODRESS 400 McAllister  MAiLING cooREss-  400 lvlcAlisster, Room 103  CITYANQ1IPCOOE. San bi'ancisco, CA 94102  BRAICH NAME: Civic Center courthouse 