17.  All claims set forth herein are brought by Plaintiffs on behalf of themselves and all  other similarly situated persons (hereinafter “FLSA Collective Plaintiffs”), for relief as a collective  action pursuant to 29 U.S.C. § 216(b), on behalf of all non-exempt employees employed by  Defendants throughout the State of Florida on or after the date that is three years before the filing  of the Complaint in this case, as defined herein.   18.  At all relevant times, FLSA Collective Plaintiffs are and have been similarly  situated, have had substantially similar job requirements and pay provisions, and are and have been  subject to Defendants’ decision, policy, plan and common policies, programs, practices,  procedures, protocols, routines, and rules willfully failing and refusing to pay them at overtime  compensation wages at a rate of one and one half times their hourly rate for work in excess of forty  (40) hours per workweek.  The claims of Plaintiffs stated herein are essentially the same as those  of the other FLSA Collective Plaintiffs.   19.  The records, if any, concerning the number of hours actually worked by FLSA  Collective Plaintiffs, and the compensation actually paid to them, should be in the custody of  Defendants.     21.  When some employees of the Defendants would complain about the foregoing,  Defendants would fire such employees.     22.  At all times relevant hereto, Defendants failed to comply with 29 U.S.C. §§ 201- 209 in that FLSA Collective Plaintiffs performed services and labor for Defendants for which  Defendants made no provision to pay FLSA Collective Plaintiffs the compensation to which they  were lawfully entitled for all of the hours worked in excess of forty hours per week.     23.  Based on the foregoing, the class of similarly situated employees employed by  Defendants who may become Plaintiffs in this action are current and former employees of  Defendant who were paid $10.00 an hour and who did not receive overtime pay for working in  excess of 40 hours per week.     24.  The class of similarly situated employees are readily identifiable from records  maintained by Defendants and necessarily will present legal and factual issues which are nearly  the same, if not identical, to those presented by the Plaintiffs.    25.  The Claims for Relief herein, pursuant to§ 16(b) of the FLSA, 29 U.S.C. § 216(b),  are properly brought under and maintained as an opt-in collective action.  FLSA Collective  Plaintiffs are readily ascertainable.  For purpose of notice and other purposes related to this action,  their names and addresses are readily available from the Defendants.  Notice can be provided to  FLSA Collective Plaintiffs via first class mail to the last address known to Defendants.  26.  Plaintiffs allege on behalf of themselves and the FLSA Collective Plaintiffs that  Global’s failure to pay overtime was knowing and willful.     28.  Specifically, each pay roll period Defendants, Vimos and Salazar, would go over  each employee’s total pay period hours and Vimos would arbitrarily decide how and for how many  overtime hours to compensate the Plaintiffs and FLSA Collective Plaintiffs. Upon information and  belief, Defendant Ballestero, as co-owner and/or manager, knew of this illicit practice of  deliberately failing to pay Plaintiffs and FLSA Collective Plaintiffs for all overtime hours worked.    29.  In response to inquiries from the Plaintiffs and FLSA Collective Payments  regarding how their over-time hours were being calculated and paid, Defendants misrepresented  to the Plaintiffs and FLSA Collective Plaintiffs the overtime legal requirements by stating that the  calculations were correct.      30.  Accordingly, Plaintiffs and the FLSA Collective Plaintiffs are entitled to recover  all overtime pay due from overtime hours worked for which compensation was not paid,  liquidated damages and attorneys’ fees under the FLSA’s three-year statute of limitations.   31.  All conditions precedent have been satisfied by Plaintiffs or waived by Defendants.   32.  Martin, on behalf of himself and the FLSA Collective Plaintiffs, repeats and  realleges Paragraphs 1-31 as if fully set forth herein.    33.  At all relevant times, Defendants have been and continue to be an employer  engaged in interstate commerce and/or the production of goods for commerce, within the meaning  of FLSA 29 U.S.C. §§ 206(a) and 207(a).   35.  During that time, Martin rendered services to Defendants as a warehouse employee  sorting packages, and fully performed his duties as directed.  All of the hours worked by Martin  were performed within the State of Florida.     36.  Throughout the statute of limitations period covered by this claim, Martin regularly  worked in excess of forty (40) hours per week.   37.  During his employment, Martin was regularly not paid any wages for hours worked  in excess of the forty (40) hours per week, for which Martin was compensated at an agreed rate of  $10.00 per hour from December of 2016 through March of 2019.    38.  Throughout his employment, Martin worked five (5) days per week for an average  of ten (10) hours per day.   39.  Through Martin’s employment, Defendants willfully failed to compensate him  overtime wages for hours worked in excess of forty (40) hours per week.     40.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay Martin at one and one half times his regular rate for work  in excess of forty (40) hours per workweek, even though Martin had been entitled to overtime.    41.  Defendants’ failure to pay Martin and the FLSA Collective Plaintiffs overtime  compensation at a rate not less than one and one-half times the rate at which they are employed  for all hours worked beyond the forty (40) hour workweek, is a violation of the FLSA, in  particular 29 U.S.C. §§ 206 and 207.   42.  The foregoing alleged conduct constitutes a willful violation of the FLSA.    44.  Gutierrez, on behalf of himself and the FLSA Collective Plaintiffs, repeats and  realleges Paragraphs 1-31 as if fully set forth herein.    45.  At all relevant times, Defendants have been and continues to be an employer  engaged in interstate commerce and/or the production of goods for commerce, within the meaning  of FLSA 29 U.S.C. §§ 206(a) and 207(a).   46.  Gutierrez was employed by Defendants as a warehouse laborer from December of  2014 to November of 2018.   47.  During that time, Gutierrez rendered services to Defendants as a warehouse  manager and fully performed his duties as directed.  All of the hours worked by Gutierrez were  performed within the State of Florida.     48.  Throughout the statute of limitations period covered by this claim, Gutierrez  regularly worked in excess of forty (40) hours per week.   49.  During his employment, Gutierrez was regularly not paid any wages for hours  worked in excess of the forty (40) hours per week, for which Gutierrez was compensated at an  agreed rate of $10.00 per hour from December of 2016 through March of 2019.    50.  Throughout his employment, Gutierrez worked five (5) days per week for an  average of ten (10) hours per day.   52.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay Gutierrez at one and one half times his regular rate for work  in excess of forty (40) hours per workweek, even though Gutierrez had been entitled to overtime.   53.   Defendants’ failure to pay Gutierrez and the FLSA Collective Plaintiffs overtime  compensation at a rate not less than one and one-half times the rate at which they are employed  for all hours worked beyond the forty (40) hour workweek, is a violation of the FLSA, in  particular 29 U.S.C. §§ 206 and 207.   54.  The foregoing alleged conduct constitutes a willful violation of the FLSA.    55.  Due to Defendants’ violations, Gutierrez, on his behalf and on behalf of the FLSA  Collective Plaintiffs seeks damages in the amount of his respective unpaid overtime compensation,  liquidated (double) damages as provided by the FLSA for overtime violations, attorneys’ fees and  costs, and such other legal and equitable relief as this Court deems just and proper.  56.  Sanchez-Pino, on behalf of himself and the FLSA Collective Plaintiffs, repeats and  realleges Paragraphs 1-31 as if fully set forth herein.    57.  At all relevant times, Defendants have been and continue to be an employer  engaged in interstate commerce and/or the production of goods for commerce, within the meaning  of FLSA 29 U.S.C. §§ 206(a) and 207(a).   59.  During that time, Sanchez-Pino rendered services to Defendants as a warehouse  employee sorting packages, and fully performed his duties as directed.  All of the hours worked  by Sanchez-Pino were performed within the State of Florida.     60.  Throughout the statute of limitations period covered by this claim, Sanchez-Pino  regularly worked in excess of forty (40) hours per week.   61.  During his employment, Sanchez-Pino was regularly not paid any wages for hours  worked in excess of the forty (40) hours per week, for which Sanchez-Pino was compensated at  an agreed rate of $10.00 per hour.   62.  Throughout his employment, Sanchez-Pino worked five (5) days per week for an  average of ten (10) hours per day.   63.  Through Sanchez-Pino’s employment, Defendants willfully failed to compensate  him overtime wages for hours worked in excess of forty (40) hours per week.     64.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay Sanchez-Pino at one and one half times his regular rate for  work in excess of forty (40) hours per workweek, even though Sanchez-Pino had been entitled to  overtime.    65.  Defendants’ failure to pay Sanchez-Pino and the FLSA Collective Plaintiffs  overtime compensation at a rate not less than one and one-half times the rate at which they are  employed for all hours worked beyond the forty (40) hour workweek, is a violation of the FLSA,  in particular 29 U.S.C. §§ 206 and 207.   67.  Due to Defendants violations, Sanchez-Pino, on his behalf and on behalf of the  FLSA Collective Plaintiffs seeks damages in the amount of his respective unpaid overtime  compensation, liquidated (double) damages as provided by the FLSA for overtime violations,  attorneys’ fees and costs, and such other legal and equitable relief as this Court deems just and  proper.  68.  Sanchez-Hernandez, on behalf of himself and the FLSA Collective Plaintiffs,  repeats and realleges Paragraphs 1-31 as if fully set forth herein.    69.  At all relevant times, Defendants have been and continue to be an employer  engaged in interstate commerce and/or the production of goods for commerce, within the meaning  of FLSA 29 U.S.C. §§ 206(a) and 207(a).   70.  Sanchez-Hernandez was employed by Defendants as a warehouse laborer from  March of 2015 to April of 2018.   71.  During that time, Sanchez-Hernandez rendered services to Defendants as a  warehouse employee sorting packages, and fully performed his duties as directed.  All of the hours  worked by Sanchez-Hernandez were performed within the State of Florida.     72.  Throughout the statute of limitations period covered by this claim, Sanchez- Hernandez regularly worked in excess of forty (40) hours per week.   73.  During his employment, Sanchez-Hernandez was regularly not paid any wages for  hours worked in excess of the forty (40) hours per week, for which Sanchez-Hernandez was  compensated at an agreed rate of $10.00 per hour.   75.  Through Sanchez-Hernandez’s employment, Defendants willfully failed to  compensate him overtime wages for hours worked in excess of forty (40) hours per week.     76.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay Sanchez-Hernandez at one and one half times his regular  rate for work in excess of forty (40) hours per workweek, even though Sanchez-Hernandez had  been entitled to overtime.    77.  Defendants’ failure to pay Sanchez-Hernandez and the FLSA Collective Plaintiffs  overtime compensation at a rate not less than one and one-half times the rate at which they are  employed for all hours worked beyond the forty (40) hour workweek, is a violation of the FLSA,  in particular 29 U.S.C. §§ 206 and 207.   78.  The foregoing alleged conduct constitutes a willful violation of the FLSA.    79.  Due to Defendants violations, Sanchez-Hernandez, on his behalf and on behalf of  the FLSA Collective Plaintiffs seeks damages in the amount of his respective unpaid overtime  compensation, liquidated (double) damages as provided by the FLSA for overtime violations,  attorneys’ fees and costs, and such other legal and equitable relief as this Court deems just and  proper.  80.  William Sanchez, on behalf of himself and the FLSA Collective Plaintiffs, repeats  and realleges Paragraphs 1-31 as if fully set forth herein.    82.  William Sanchez was employed by Defendants as a warehouse laborer from March  of 2016 to August of 2018.   83.  During that time, William Sanchez rendered services to Defendants as a warehouse  employee sorting packages, and fully performed his duties as directed.  All of the hours worked  by William Sanchez were performed within the State of Florida.     84.  Throughout the statute of limitations period covered by this claim, William Sanchez  regularly worked in excess of forty (40) hours per week.   85.  During his employment, William Sanchez was regularly not paid any wages for  hours worked in excess of the forty (40) hours per week, for which William Sanchez was  compensated at an agreed rate of $10.00 per hour.   86.  Throughout his employment, William Sanchez worked five (5) days per week for  an average of ten (10) hours per day.   87.  Through William Sanchez’s employment, Defendants willfully failed to  compensate him overtime wages for hours worked in excess of forty (40) hours per week.     88.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay William Sanchez at one and one half times his regular rate  for work in excess of forty (40) hours per workweek, even though William Sanchez had been  entitled to overtime.    90.  The foregoing alleged conduct constitutes a willful violation of the FLSA.    91.  Due to Defendants violations, William Sanchez, on his behalf and on behalf of the  FLSA Collective Plaintiffs seeks damages in the amount of his respective unpaid overtime  compensation, liquidated (double) damages as provided by the FLSA for overtime violations,  attorneys’ fees and costs, and such other legal and equitable relief as this Court deems just and  proper.  92.  Perez-Valdes, on behalf of himself and the FLSA Collective Plaintiffs, repeats and  realleges Paragraphs 1-31 as if fully set forth herein.    93.  At all relevant times, Defendants have been and continue to be an employer  engaged in interstate commerce and/or the production of goods for commerce, within the meaning  of FLSA 29 U.S.C. §§ 206(a) and 207(a).   94.  Perez-Valdes was employed by Defendants as a warehouse laborer for  approximately fourteen (14) months.   95.  During that time, Perez-Valdes rendered services to Defendants as a warehouse  employee sorting packages, and fully performed his duties as directed.  All of the hours worked  by Perez-Valdes were performed within the State of Florida.     96.  Throughout the statute of limitations period covered by this claim, Perez-Valdes  regularly worked in excess of forty (40) hours per week.   98.  Throughout his employment, Perez-Valdes worked five (5) days per week for an  average of ten (10) hours per day.   99.  Through Perez-Valdes’ employment, Defendants willfully failed to compensate  him overtime wages for hours worked in excess of forty (40) hours per week.    100.  At all relevant times, Defendants had and operated under a decision, policy and  plan, and under common policies, programs, practices, procedures, protocols, routines and rules  of willfully failing and refusing to pay Perez-Valdes at one and one half times his regular rate for  work in excess of forty (40) hours per workweek, even though Perez-Valdes had been entitled to  overtime.   101.  Defendants’ failure to pay Perez-Valdes and the FLSA Collective Plaintiffs  overtime compensation at a rate not less than one and one-half times the rate at which they are  employed for all hours wrked beyond the forty (40) hour workweek, is a violation of the FLSA, in  particular 29 U.S.C. §§ 206 and 207.  102.  The foregoing alleged conduct constitutes a willful violation of the FLSA.   103.  Due to Defendants violations, Perez-Valdes, on his behalf and on behalf of the  FLSA Collective Plaintiffs seeks damages in the amount of his respective unpaid overtime  compensation, liquidated (double) damages as provided by the FLSA for overtime violations,  attorneys’ fees and costs, and such other legal and equitable relief as this Court deems just and  proper. 