(Individual Claims for Violation of the AMW A)   10.  Defendant does business in this district and a substantial part of the events  alleged herein occurred in this District.   11.  The witnesses to overtime violations alleged in this Complaint reside in this  District.   12.  The payroll records and other documents related to the payroll practices  that Plaintiffs challenges are accessible in this District.  2.  Upholding labor contracts and paying time-and-a-half for all hours over  forty disincentives employers from tiring their workers with long hours, and promotes  stability in the labor market. A forty-hour base work week leads to safer work, products and  services for students.   3.  Rather than following this longtime principle that has helped sustain our  free-market system, the Pulaski County Special School District has a common policy that  fails to pay its non-exempt contract employees the hourly amount they contract for, nor the  lawful amount of overtime. Non-exempt contract employees are prorated and not paid the  correct rate for hours they worked in the time it is due, nor paid the correct amount of  overtime, thus leading to a myriad of issues for employees and the district.   4.  Plaintiffs thus bring this action under the Fair Labor Standards Act, 29  U.S.C. § 201, et seq. ("FLSA") and the Arkansas Minimum Wage Act, Ark. Code Ann.§  11-4-201, et seq. ("AMWA"), for declaratory judgment, monetary damages, liquidated  damages, prejudgment interest, costs, including a reasonable attorney's fee as a result of  Defendant's failure to pay Plaintiffs and other non-exempt contract employees lawful  contracted rates and overtime compensation for hours worked in excess of forty (40) hours  per week.   5.  Upon information and belief, for at least three (3) years prior to the filing of  this Complaint, Defendant has willfully and intentionally committed violations of the FLSA  as described, infra.  II.  Jurisdiction and Venue   7.  Plaintiffs' claims under the AM.WA form part of the same case or  controversy and arise out of the same facts as the FLSA claims alleged in this Complaint.   71.  Plaintiffs repeat and re-allege all the preceding paragraphs of this Original  Complaint as if fully set forth in this section.   72.  Plaintiffs assert this claim for damages and declaratory relief pursuant to the  AMWA, Arkansas Code Annotated§§ 11-4-201, et seq.   73.  At all relevant times, Defendant was Plaintiffs> "employer» within the  meaning of the AMWA, Ark. Code Ann.§ 11-4-203(4).   74.  Arkansas Code Annotated§§ 11-4-210 and 211 require employers to pay all  employees a minimum wage for all hours worked up to forty ( 40) in one week and to pay one  and one-half (1.5) times regular wages for all hours worked over forty ( 40) hours in a week,  unless an employee meets the exemption requirements of 29 U.S.C. § 213 and  accompanying Department of Labor regulations.   75.  8.  Therefore, this Court has supplemental jurisdiction over Plaintiffs' AMW A  claims pursuant to 28 U.S.C. § 1367(a).   9.  The acts complained of herein were committed and had their principal  effect against Plaintiffs within the Central Division of the Eastern District of Arkansas;  therefore, venue is proper within this District pursuant to 28 U.S.C. § 1391.   DEFENDANT  Class and Collective Action Complaint  COMES NOW Plaintiffs Yolanda Richards, Norma L. Dixon, and Cynthia  D'Abadie each individually and on behalf of all others similarly situated, by and through  their attorneys Chris Burks and Brandon Haubert of WHLAW PLLC, and for their Class and  Collective Action Complaint against Defendant Pulaski County Special School District  ("Defendant"), he does hereby state and allege as follows:  I.  Introduction  