15. Plaintiff and similarly situated employees work or worked for Defendant as maids and/or  housekeeper during the applicable statutory period.   16. Plaintiff and similarly situated employees perform room cleaning services at the hotel  operated by Defendants.   17. Defendant compensated Plaintiff and similarly situated employees for their work on an  hourly basis.   18. Defendant suffered and permitted Plaintiff and similarly situated employees to work more  than forty (40) hours per workweek.   20. In calculating Plaintiff and similarly situated employees’ wages, Defendant only paid them  their regular rate (i.e., straight time rate), rather than the legally required one and one-half  (1.5) times their regular rate of pay for hours in excess of forty (40) per workweek.   21. Defendant willfully operated under a common scheme to deprive Plaintiff and similarly  situated employees of overtime compensation by paying them less than what is required  under federal law.    22. As a large nationwide corporation, Defendant was or should have been aware that Plaintiff  and similarly situated employees performed work that required proper payment of overtime  compensation.   23. Defendant knew that Plaintiff and similarly situated employees worked overtime hours  without receiving proper overtime pay because Defendant maintained and recorded the  hours worked by Plaintiff and similarly situated employees.     24. Defendant was aware, or should have been aware, of its unlawful payment practices and  recklessly chose to disregard the consequences of its actions.  25. Plaintiff brings this action on behalf of herself and all similarly situated individuals.  The  proposed collective class (“Class Members”) is identified as follows:  All maids and/or  housekeepers who worked for LQ Management, LLC at the La Quinta Inn in Metairie,  Louisiana within the last three years.   27. As the case proceeds, it is likely that other individuals will file consent forms and join as  “opt-in” plaintiffs.   28. Members of the proposed Class Members are known to Defendant and are readily  identifiable through Defendant’s records.   29. Plaintiff and the Class Members are all victims of Defendant’s widespread, repeated,  systematic, and consistent illegal policies that have resulted in willful violations of their  rights under the FLSA, 29 U.S.C. § 201, et seq., and that have cause significant damage to  Plaintiff and the Class Members.    30. The Class Members would benefit from the issuance of court-supervised notice of this  lawsuit and an opportunity to join by filing their written consent.  31. Plaintiff realleges and incorporates by reference the above paragraphs as if fully set forth  herein.   32. Defendant is an “enterprise” as defined by the FLSA, 29 U.S.C. § 203(r)(1), and is engaged  in commerce within the meaning of the FLSA, 29 U.S.C. § 203(b), (s)(1).   33. The FLSA, 29 U.S.C. § 207, requires covered employers like Defendant to pay non-exempt  employees like Plaintiff and the Class Members no less than one and one-half (1.5) times  their regular rate of pay for all hours worked in excess of forty (40) in a workweek.   34. Plaintiff and the Class Members sometimes worked more than forty (40) hours per week  for Defendant, but Defendant did not properly compensate them for all of their overtime  hours as required by the FLSA.   36. Defendant knew Plaintiff and the Class Members worked overtime without proper  compensation, and it willfully failed and refused to pay Plaintiff and the Class Members  wages at the required overtime rate pursuant to 29 U.S.C. § 225.   37. Defendant’s willful failure and refusal to pay Plaintiff and the Class Members overtime  wages for time worked violates the FLSA, 29 U.S.C. § 207.  