19.  Plaintiffs Dey and Abesamis seek to bring this suit to recover from Defendants  unpaid overtime compensation, minimum wages, and liquidated damages pursuant to the  applicable provisions of the FLSA, 29 U.S.C. 216(b), on their own behalves, as well as on behalf  of those in the following two collectives:  a. Representative Plaintiff Abesamis: Collective A - - Minimum Wage  Current and former laundromat employees, who during the  applicable FLSA limitations period, performed any work for or on  behalf of Defendant Next, and who consent to file a claim to  recover damages for minimum wages that are legally due to them  (“FLSA Collective A”).  b. Representative Plaintiff Dey: Collective B - - Overtime   Current and former laundromat employees, who during the  applicable FLSA limitations period, performed any work for or on  behalf of Defendant Next, and who consent to file a claim to  recover damages for overtime wages that are legally due to them  (“FLSA Collective B”) (referred to collectively, with FLSA  Collective A, as “FLSA Plaintiffs”).   21.  At all relevant times herein, Defendants are and have been aware of the  requirements to pay Plaintiffs and all FLSA Plaintiffs at an amount equal to the rate of one and  one-half times their respective regular rates of pay, or one and one-half times the minimum wage  rate, if greater, for all hours worked each workweek above forty, and of the requirement to pay  Plaintiff and all FLSA Plaintiffs at least the statutory minimum wage rate for all hours worked,  yet they purposefully and willfully chose and choose not to do so.   22.  Thus, all FLSA Plaintiffs are victims of Defendants’ pervasive practice of  willfully refusing to pay their employees overtime compensation for all hours worked per  workweek above forty, and/or at the statutorily-set minimum wage for all hours worked, in  violation of the FLSA.   23.  In addition, Plaintiff Dey seeks to maintain this action as a class action pursuant  to FRCP 23(b)(3), individually, on his own behalf, as well as on behalf of those who are  similarly situated who, during the applicable limitations period, were subjected to violations of  the NYLL and the NYCCRR.   25.   Plaintiff Dey seeks certification of the following FRCP 23 class:  Current and former laundromat employees who performed any  work for Defendant Next during the statutory period within the  State of New York who: (1) did not receive compensation from the  Defendants at the legally-required overtime wage rate of pay for  each hour worked over forty hours; and/or (2) did not receive at  least the statutory minimum wage rate for all hours worked; and/or  (3) were not paid an additional hour’s pay at the statutory  minimum wage rate on all days where their spread of hours  exceeded ten; and/or (4) were not provided with accurate  statutorily-required wage statements on each payday pursuant to  NYLL § 195(3); and/or (5) were not provided with a wage notice  at hire containing specific categories of accurate information  pursuant to NYLL § 195(1).  Numerosity   26.  During the previous six years, the Defendants have, in total, employed at least  forty employees that are putative members of this class.  Common Questions of Law and/or Fact   29.  Plaintiff Dey, as described below, worked the same or similar hours as the Rule  23 Plaintiffs throughout his employment with the Defendants.  Defendants did not pay Dey  overtime for all hours worked over forty hours in a week, did not pay Dey at least the statutory  minimum wage rate for all hours worked, did not pay Dey an additional hour’s pay at the  minimum wage rate when his spread of hours exceeded ten, did not furnish Dey with accurate  wage statements on each payday, and did not furnish Dey with a wage notice at the time of hire  containing specific categories of accurate information, which is substantially similar to how the  Defendants paid and treated the Rule 23 Plaintiffs.  Dey fully anticipates providing discovery  responses and testifying under oath as to all of the matters raised in this Complaint and that will  be raised in the Defendants’ Answer.  Thus, Dey would properly and adequately represent the  current and former employees whom the Defendants have subjected to the treatment alleged  herein.  Superiority   31.  Any lawsuit brought by an employee of the Defendants who worked in any of  Defendants’ laundromats/dry cleaners in New York would be identical to a suit brought by any  other employee for the same violations.  Thus, separate litigation would risk inconsistent results.   32.  Accordingly, this means of protecting Rule 23 Plaintiffs’ rights is superior to any  other method, and this action is properly maintainable as a class action under FRCP 23(b)(3).   33.  Additionally, Plaintiffs’ counsel has substantial experience in this field of law.  34.  Defendant Next, as comprised as the three entities described above and at least  four other entities not currently named in this Complaint, operates as a single enterprise that  provides laundromat / dry cleaning services to its customers throughout New York City and parts  of New Jersey.   35.  The (at least) four additional unnamed entities that are included within the single  Next enterprise are: Next @ Lafayette, Inc.; Next at 1343 2nd Ave, Inc.; Next at 49th & 9th,  Inc.; and Next at 801 Amsterdam, Inc.   36.  Defendant Next, including the three named entity Defendants and the four  unnamed entities described above all: share employees and clients with one another; have the  same central cleaning facility in New Jersey; concurrently control labor relations between  employees and management; are commonly managed by the same personnel such as Defendants  Saifi, Inakavadze, and Berezov, as well as Defendant Saifi’s son Zack Saifi; and are commonly  owned and controlled financially.   38.  Plaintiff Abesamis worked for Defendants as a bicycle delivery person and store  clerk from on or around July 27, 2014 through January 2015 at Defendants’ Next Dry Cleaners  brick-and-mortar store located at 808 Columbus Avenue, New York, New York (hereinafter  “Columbus Store”).    39.  Thereafter, from in or around February 2015 through March 16, 2017, Plaintiff  Abesamis worked for Defendants as a “store manager” at the Columbus Store.   40.  Throughout his employment, Plaintiff Abesamis’s duties involved, inter alia,  delivering laundered or dry cleaned clothing to Defendants’ customers, processing clothing for  pickup or delivery, providing customer service to Defendants’ customers, and - - after becoming  “store manager” - - performing additional duties such as opening and closing Defendants’  Columbus Store.   41.  For the first six months of Plaintiff Abesamis’s employment, Defendants required  him to work, and he did in fact work, six days per week, twelve hours per day Mondays through  Fridays, and six hours every Sunday, for a total of sixty-six hours per week, without permitting  him to take any scheduled or uninterrupted breaks.   43.  In or around February 2015, Defendants changed Plaintiff Abesamis’s schedule,  requiring him to work, and Abesamis did in fact work, sixty-nine hours per week, consisting of  twelve-hour days from Monday through Friday from 7:30 a.m. through 7:30 p.m., and nine hours  every Saturday, from 8:30 a.m. through 5:30 p.m., without permitting him to take any scheduled  or uninterrupted breaks.   44.  For his pay, from approximately February 2015 through approximately June  2016, Defendants paid Plaintiff Abesamis a flat weekly salary of $600.00, which by operation of  law was solely meant to compensate him for his first forty hours of work per week, amounting to  a straight-time rate of pay of $15.00 per hour.       45.  From approximately July 2016 through the end of his employment, Defendants  paid Plaintiff Abesamis a flat weekly salary of $650.00, which by operation of law was solely  meant to compensate him for his first forty hours of work per week, amounting to a straight-time  rate of pay of $16.25 per hour.   46.  Throughout his employment, Defendants paid Plaintiff Abesamis nothing for his  time worked each week in excess of forty hours.   48.  Further, Defendants required Plaintiff Abesamis to work over ten hours for either  five or six days per week, virtually all weeks, while failing to pay him an additional hour’s pay at  the then-applicable minimum wage rate on every day on which his spread-of-hours exceeded ten.   49.  For example, during the week of August 4 through August 10, 2014, Defendants  required Plaintiff Abesamis to work, and he did in fact work, over ten hours on six separate days.   Nonetheless, despite working over ten hours on each of those days, Defendants failed to pay  Abesamis an additional hour’s pay at the then-applicable minimum wage rate for each day.  Plaintiff Dey’s Employment   50.  Plaintiff Dey worked for Defendants as a bicycle delivery person and store clerk  in Defendants’ Columbus Store from on or around July 27, 2014 through March 16, 2017.   51.  Throughout his employment, Plaintiff Dey’s duties involved delivering laundered  or dry cleaned clothing to Defendants’ customers, and performing various tasks in Defendants’  Columbus Store.    52.  For the first six months of Plaintiff Dey’s employment, Defendants required Dey  to work, and he did work, a total of thirty hours per week, without permitting him to take any  scheduled or uninterrupted breaks, as follows:  a. Mondays: 2:00 p.m. through 8:00 p.m.;  b. Tuesdays, Wednesdays, and Fridays: 3:00 p.m. through 8:00 p.m.; and  c. Saturdays: 8:30 a.m. through 5:30 p.m.    54.  In or around February of 2015, Defendants increased Plaintiff Dey’s schedule,  requiring him to work, and Dey did in fact work, sixty-six hours per week, consisting of twelve- hour days from Monday through Friday from 8:00 a.m. through 8:00 p.m., and six hours every  Sunday, from 10:30 a.m. through 4:30 p.m., without permitting him to take any scheduled or  uninterrupted breaks.   55.  For his pay, from approximately February 2015 through approximately June  2016, Defendants paid Plaintiff Dey a flat weekly salary of $488.00, which by operation of law  was solely meant to compensate him for his first forty hours of work per week, amounting to a  straight-time rate of pay of $12.20 per hour.    56.  From approximately July 2016 through the end of his employment, Defendants  paid Plaintiff Dey a flat weekly salary of $550.00, which by operation of law was solely meant to  compensate him for his first forty hours of work per week, amounting to a straight-time rate of  pay of $13.75 per hour.   57.  Throughout his employment from February 2015 through the end of his  employment, Defendants paid Plaintiff Dey nothing for his time worked each week in excess of  forty hours.  Additionally, from February 2015 through the end of his employment, Defendants  paid Dey at a rate below New York’s minimum wage for all hours worked.     59.  Further, Defendants required Plaintiff Dey to work over ten hours for five days  per week, during virtually all weeks after Dey’s first six months of work, while failing to pay  him an additional hour’s pay at the then-applicable minimum wage rate on every day on which  his spread-of-hours exceeded ten.   60.  For example, during the week of January 11 through January 17, 2016,  Defendants required Plaintiff Dey to work, and he did in fact work, over ten hours on five  separate days.  Nonetheless, despite working over ten hours on each of those days, Defendants  failed to pay Dey an additional hour’s pay at the then-applicable minimum wage rate for each  day.   61.  Defendants paid both Plaintiffs on a weekly basis by check.   62.  On each occasion when Defendants paid Plaintiffs, Defendants intentionally  failed to provide Plaintiffs with a wage statement that accurately listed, inter alia: their actual  hours worked for that week and/or their straight and overtime rates of pay for all hours worked.   63.  Defendants also did not provide Plaintiffs with wage notices at the time of their  hire that accurately contained, inter alia, Plaintiffs’ rates of pay as designated by Defendants.   64.  Defendants treated Plaintiff, FLSA Plaintiffs, and Rule 23 Plaintiffs in the manner  described above.   65.  Each hour that Plaintiff, FLSA Plaintiffs, and Rule 23 Plaintiffs worked was for  Defendants’ benefit.   67.  Plaintiffs and FLSA Plaintiffs repeat, reiterate, and re-allege each and every  allegation set forth above with the same force and effect as if more fully set forth herein.   68.  29 U.S.C. § 207(a) requires employers to compensate their employees at a rate not  less than the greater of one and one-half times their regular rate of pay or one and one-half times  the minimum wage, if greater, for all hours worked exceeding forty in a workweek.   69.  As described above, Defendants are employers within the meaning of the FLSA  while Plaintiffs and FLSA Plaintiffs are employees within the meaning of the FLSA.   70.  As also described above, Plaintiffs and FLSA Plaintiffs worked in excess of forty  hours per week, yet Defendants failed to compensate Plaintiffs and FLSA Plaintiffs in  accordance with the FLSA’s overtime provisions.   71.  Defendants willfully violated the FLSA.   72.  Plaintiffs and FLSA Plaintiffs are entitled to overtime pay for all hours worked  per week in excess of forty at the rate of the greater between one and one-half times their  respective regular rates of pay or one and one-half times the minimum wage.   73.  Plaintiffs and FLSA Plaintiffs are also entitled to liquidated damages and  attorneys’ fees for Defendants’ violations of the FLSA’s overtime provisions.  74.  Plaintiff Abesamis and FLSA Plaintiffs repeat, reiterate, and re-allege each and  every allegation set forth above with the same force and effect as if more fully set forth herein.   76.  As described above, Defendants are employers within the meaning of the FLSA  while Plaintiff Abesamis and FLSA Plaintiffs are employees within the meaning of the FLSA.   77.  As also described above, Defendants did not compensate Plaintiff Abesamis and  FLSA Plaintiffs at the minimum hourly rate required by the FLSA for all hours worked.   78.  Defendants willfully violated the FLSA.   79.  At the least, Plaintiff Abesamis and FLSA Plaintiffs are entitled to the minimum  rate of pay required by the FLSA for all hours worked.   80.  Plaintiff Abesamis and FLSA Plaintiffs are also entitled to liquidated damages  and attorneys’ fees for Defendants’ violations of the FLSA’s minimum wage provisions.  81.  Plaintiffs, Rule 23 Plaintiffs, and any FLSA Plaintiff who opts-into this action,  repeat, reiterate and re-allege each and every allegation set forth above with the same force and  effect as if more fully set forth herein.    82.  N.Y. Lab. Law § 160 and 12 NYCCRR § 142-2.2 require employers to  compensate their employees at a rate not less than the greater between one and one-half times  their regular rates of pay, or one and one-half times the minimum wage, for all hours worked  exceeding forty in a workweek.   83.  As described above, Defendants are employers within the meaning of the NYLL  and the NYCCRR, while Plaintiffs, Rule 23 Plaintiffs, and any FLSA Plaintiff who opts-into this  action, are employees within the meaning of the NYLL and the NYCCRR.   85.  Plaintiffs, Rule 23 Plaintiffs, and any FLSA Plaintiff who opts-into this action, are  entitled to overtime pay for all hours worked per week in excess of forty at the rate of one and  one-half times the greater of their respective regular rate of pay or one and-one-half times the  minimum wage.   86.  Plaintiffs, Rule 23 Plaintiffs, and any FLSA Plaintiff who opts-into this action, are  also entitled to liquidated damages, interest, and attorneys’ fees for Defendants’ violations of the  NYLL’s and the NYCCRR’s overtime provisions.  Unpaid Minimum Wages under the FLSA   Unpaid Overtime under the NYLL and the NYCCRR   Unpaid Overtime under the FLSA  