19.  The crux of the FLSA and NCWHA is that all employees are entitled to be paid  for all hours worked, and paid premium overtime compensation for all hours worked in excess of  forty hours per workweek, unless proven to be exempt.   20.  Contrary to these basic protections, Plaintiff and the members of the Classes were  not lawfully paid for all hours they worked above and beyond forty in any given workweek.   22.  Upon information and belief, Plaintiff and the members of the Classes had to get  approval from supervisors in order to be credited and paid for the hours they worked in excess  of forty.   23.  Due to the nature of their job responsibilities and requirements, Plaintiff and the  members of the Classes regularly worked more than forty hours a week during the course of their  employment with Defendants for which they did not receive overtime compensation.   24.  Upon information and belief, Plaintiff and the members of the Classes were  permitted and required to work hours which they were not allowed to record in order to contain  the labor hours for the given branch location.   25.  During the course of her employment with Defendants, Plaintiff and the other  members of the Classes were not credited for all the hours they worked, including but not limited  to time spent opening branch offices and attending mandatory morning meetings and  conferences.   26.  In addition, Plaintiff and the members of the Classes were subject to Defendants’  minimum sales quotas.  In order to meet these sales goals, Financial Service Representatives,  including Plaintiff, often had to work through all or part of their lunch and/or stay beyond their  scheduled shift.  Failure to meet the required sales quotas resulted in disciplinary measures taken  against the Financial Service Representative.   27.  Plaintiff was required to participate in a call night, at least  one night each week  that lasted at least an hour, during which she was required to call individuals and market  SunTrust’s products and services.  Plaintiff was not credited for all the time worked during these  call nights.     29.  In violation of the FLSA and NCWHA, Plaintiff and the members of the Classes  have not been paid overtime compensation at a rate not less than one and one-half times their  regular rate for all work performed beyond the 40 hour workweek.   30.  Plaintiff alleges that Defendants’ failure to pay all wages, including overtime, was  knowing and willful.  Accordingly, Plaintiff and the members of the Classes are entitled to  recover all wages due for overtime hours worked, for which the appropriate compensation was  not paid.   31.  Evidence reflecting the precise number of overtime hours worked by Plaintiff, as  well as the applicable compensation rates, are in the possession of Defendants.  If these records  are unavailable, Plaintiff and the members of the Classes may establish the hours they worked  solely by their testimony and the burden of overcoming such testimony shifts to Defendants.  See  Anderson v. Mt. Clemens Pottery Co., 328 U.S. 680 (1946).   32.  Each of the foregoing acts is in contravention of applicable provisions of the  FLSA and NCWHA.  33.  Plaintiff brings this action on behalf of herself and the Nationwide Collective  Class as a collective action pursuant to the FLSA, § 216(b) and on behalf of the NC Class as a  class action for claims under the NCWHA pursuant to Fed. R. Civ. P. 23.   35.  The number of individuals in each of the Classes is so numerous that joinder of all  members is impracticable.  The exact number of members of the Classes can be determined by  reviewing Defendants’ records.  Plaintiff is informed and believes and thereon alleges that there  are over a hundred individuals in each defined class.   36.  Plaintiff will fairly and adequately protect the interests of the Classes, and has  retained counsel that is experienced and competent in class action and employment litigation.   Plaintiff has no interests that are contrary to, or in conflict with, members of the Classes.   37.  A collective/class action suit, such as the instant one, is superior to other available  means for fair and efficient adjudication of this lawsuit.  The damages suffered by individual  members of the Classes may be relatively small when compared to the expense and burden of  litigation, making it virtually impossible for members of the Classes to individually seek redress  for the wrongs done to them.   38.  A collective and class action is, therefore, superior to other available methods for  the fair and efficient adjudication of the controversy.  Absent these actions, members of the  Classes likely will not obtain redress of their injuries, and Defendants will retain the proceeds of  their violations of the FLSA and NCWHA.   39.  Furthermore, even if any member of the Classes could afford individual litigation  against SunTrust, it would be unduly burdensome to the judicial system.  Concentrating this  litigation in one forum will promote judicial economy and parity among the claims of individual  members of the Classes and provide for judicial consistency.   41.  Plaintiff’s claims are typical of the claims of members of the Classes.  Plaintiff  and members of the Classes have sustained damages arising out the wrongful and uniform  employment policies of Defendant in violation of the FLSA and the NCWHA as alleged herein.   42.  Plaintiff knows of no difficulty that will be encountered in the management of this  litigation that would preclude its continued maintenance.  43.  Plaintiff incorporates the allegations contained in the previous paragraphs of this  Complaint as if fully set forth herein.   44.  At all relevant times, Defendants have been and continue to be employers  engaged in interstate commerce and/or the production of goods for commerce, within the  meaning of the FLSA, 29 U.S.C. §§ 206(a) and 207(a).   46.  At stated herein, Financial Service Representatives, including Plaintiff, regularly  and customarily worked in excess of forty hours a week, without receiving compensation for all  those hours in violation of the FLSA.   47.  Due to Defendants’ FLSA violations, Plaintiff, on behalf of herself and the  members of the Nationwide Collective Class, is entitled to recover from Defendants their unpaid  overtime compensation, an additional amount equal as liquidated damages, reasonable attorneys’  fees, and costs and disbursements of this action, pursuant to 29 U.S.C. § 216(b).  48.  Plaintiff incorporates the allegations contained in the previous paragraphs of this  Complaint as if fully set forth herein.   49.  Defendants employed Plaintiff and the members of the NC Class within the  meaning of the NCWHA.   50.  At stated herein, Financial Service Representatives, including Plaintiff, regularly  and customarily worked in excess of forty hours a week, without receiving compensation for all  those hours.   51.  At stated herein, Financial Service Representatives, including Plaintiff, regularly  and customarily worked in excess of forty hours a week, without receiving compensation for all  those hours in violation of the NCWHA.   52.  Due to Defendants’ NCWHA violations, Plaintiff, on behalf of herself and the  members of the NC Class, is entitled to recover from Defendants their unpaid overtime  compensation, an additional amount equal as liquidated damages, reasonable attorneys’ fees, and  costs and disbursements of this action, pursuant to NC Gen. Stat. § 95-25.22. 