Pappas

I. BACKGROUND

17 A. Parties and Claims 18 Kaiser is a non-profit corporation that operates healthcare facilities in California. ECF No. 19 1 ¶¶ 1, 13. AMN is a “nationwide provider of temporary healthcare staffing solutions, and places 20 healthcare professionals [like traveling nurses] . . . in temporary assignments at facilities.” ECF 21 No. 21-1 ¶ 3. Healthcare facilities such as Kaiser, offer a “bill rate”––“the total amount the 22 facility is willing to pay a staffing agency such as AMN for every hour worked by a traveling 23 nurse.” ECF No. 1 ¶ 20. AMN “then deducts costs, overhead, and profit margin from the bill rate 24 and advertises the hourly rate it is willing to pay a traveling nurse to accept the facility 25 assignment.” Id. AMN uses recruiters who pitch traveling nurses on new job opportunities. 26 Id. ¶ 23. Plaintiffs Jean Pappas, Johannah Hetherington, Nikole Domke, Michelle Anderson, and 27 Jane Angell are traveling nurses. Id. ¶¶ 7–11. “Kaiser contracts with nurse staffing agencies like AMN to recruit and employ travel nurses like Plaintiffs and others similarly situated to fill certain staffing needs at Kaiser facilities.” Id. ¶ 77. …