61. At all times relevant. Defendant engaged in a pattern or practice of not paying employees overtime for working more than 40 hours per week, including altering Plaintiffs' time records, setting an artificial ceiling for hours ofpay. automatically deducting 30 minutes each day. and refusing to pay for time spent in broken-down trucks.  62. Plaintiffs worked more than 40 hours per week without overtime compensation for all hours worked over 40.  63. At all times relevant. Defendant knew, or should have known, that the FLSA applied to Plaintiffs and others similarly situated.  FLSA Violation 