13. All previous paragraphs are incorporated as though fully set forth herein.    14. Plaintiffs bring this FLSA claim as a collective action pursuant to 29 U.S.C. § 216(b)  on behalf of all persons in the United States, who, since September 2011, previously  worked or currently work for Defendants as dispatchers or security personnel while  they reside or resided on Defendants’ premises and were compensated with ‘rent  credits’ but, through Defendants’ use of ‘rent credits’ to compensate them, were not  properly paid overtime and/or minimum wage as mandated by the FLSA.    15. Plaintiffs bring this case as a collective action under the FLSA to recover unpaid  minimum wage and/or overtime compensation, liquidated damages, statutory  penalties, attorneys’ fees and costs, and damages owed to Plaintiffs and all similarly  situated employees of Defendants.    17. The precise number of FLSA Collective Plaintiffs can be easily identified and located  using Defendants’ timesheets, payroll, rent credit records and other personnel records.   Given the composition and size of the FLSA Collective Plaintiffs, potential opt-in  class members may be informed of the pendency of this Collective Action by direct  mail.    19. In addition, because Defendants applied their unlawful employment and payment  policies in the same manner to all potential members of the FLSA Collective  Plaintiffs, common issues of law and fact predominate, and therefore pursuing this  matter as a collective action serves as the most expeditious use of the court’s time and  resources, as well as avoiding multiple actions on these issues, with the potential for  differing or inconsistent judgments.   21. Defendants are in the business of operating apartment complexes throughout the  United States, including complexes in the greater New Orleans area.   22. In September 2011, Plaintiff Smith was hired by Defendants to act as dispatcher for a  flat rate of pay of $20 per night or $40 per weekend day and night, paid to her in the  form of “rent credits.”  At that time, Plaintiff Smith was classified as Defendants’  “employee.”   23. Plaintiff Smith worked for Defendants at the Forest Isle apartment complex located  on Woodlands Drive, New Orleans, Louisiana.    24. Plaintiff Smith worked for Defendants until October 2013.    25. While Plaintiff Smith was employed by Defendants, she lived on the apartment  complex premises.     26. During Plaintiff Smith’s tenure as a dispatcher employed by Defendants, Defendants  exercised total control over the time, place and manner of Plaintiff’s work.  Plaintiff  had no ability to control her schedule, the place or time she would work or who she  would be working with during the time she spent working for Defendants. While she  was working for Defendants, Plaintiff was forbidden from leaving the premises.   27. Defendants controlled the schedule, and time place and manner of the performance of  job duties for all flat rate employees, including those who comprise the FLSA  Collective Plaintiffs.   29. In February 2012, Plaintiff Trujillo was hired by Defendants to act as dispatcher for a  flat rate of pay of $20 per night or $40 per weekend day and night, paid to her in the  form of “rent credits.”  At that time, Plaintiff Trujillo was classified as Defendants’  “employee.”   30. Plaintiff Trujillo worked for Defendants at the Forest Isle apartment complex located  on Woodlands Drive, New Orleans, Louisiana.    31. Plaintiff Trujillo worked for Defendants until April 2012.    32. While Plaintiff Trujillo was employed by Defendants, she lived on the apartment  complex premises.     33. During Plaintiff Trujillo’s tenure as a dispatcher employed by Defendants,  Defendants exercised total control over the time, place and manner of Plaintiff’s  work.  Plaintiff had no ability to control her schedule, the place or time she would  work or who she would be working with during the time she spent working for  Defendants.  While she was working for Defendants, Plaintiff was forbidden from  leaving the premises.   35. Defendants controlled the schedule, and time place and manner of the performance of  job duties for all flat rate employees, including those who comprise the FLSA  Collective Plaintiffs.   36. Other persons employed by Defendants as dispatchers, life guards and “Unit 10”  security personnel who lived on Defendants’ premises worked identical or  substantially similar schedules for flat rates of pay, without regard to how many hours  they worked, including those who comprise the FLSA Collective Plaintiffs.   37. Due to Defendants’ willful scheme to pay Plaintiffs and similarly situated members of  the FLSA Collective Plaintiffs in this manner, Plaintiffs and similarly situated  employees were paid less than the federally-mandated rate of pay of $7.25 per hour.   In addition, these employees, including Plaintiffs, were not paid overtime for their  work for Defendants in excess of 40 hours per week.   38. Documentation concerning the number of hours actually worked by Plaintiffs Smith  and Trujillo and other similarly situated employees and the compensation actually  paid to Plaintiffs Smith and Trujillo and other similarly situated employees, including  those who comprise the FLSA Collective Plaintiffs, should be in the possession and  custody and control of Defendants.   40.  In violating the FLSA, Defendants acted willfully and with reckless disregard of  clearly applicable FLSA provisions with respect to Plaintiffs and the FLSA Collective  Plaintiffs for reasons including but not limited to the fact that Defendants paid non- residents at a rate of one and one-half times their regular rate for those hours worked in  excess of forty (40) hours per workweek and paid non-residents at a rate of pay that was  at least the federally-mandated minimum wage rate for each hour that they worked.  41. Plaintiffs re-allege and re-aver all previous paragraphs of the Collective Action  Complaint as if fully set forth herein.   42. Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs worked in excess of  forty (40) hours per week for Defendants, but Plaintiffs and the FLSA Collective  Plaintiffs were not compensated at the statutory rate of one and one-half times their  regular rate of pay for these overtime hours.   44. At all times material hereto, Defendants failed to comply with Title 29 and United  States Department of Labor Regulations, 29 C.F.R. §§516.2 and 516.4, by  implementing a management policy, plan or decision that intentionally provided for  the compensation of Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs  as if they were exempt from coverage under 29 U.S.C. §§201 through 219,  disregarding the fact that they were not exempt.    45. At all times material hereto, Defendants failed to maintain proper time records as  mandated by the FLSA.   46. Defendants’ actions were willful and/or showed reckless disregard for the provisions  of the FLSA as evidenced by their failure to compensate Plaintiffs Smith and Trujillo  and the FLSA Collective Plaintiffs at the statutory rate of one and one-half times their  regular rate of pay for the hours worked in excess of forty (40) hours per week when  they knew, or should have known, such was and is due.   47. Defendants have failed to properly disclose or apprise Plaintiffs Smith and Trujillo  and the FLSA Collective Plaintiffs of their rights under the FLSA.   48. Due to the intentional, willful, and unlawful acts of Defendants, Plaintiffs Smith and  Trujillo and the FLSA Collective Plaintiffs have suffered lost compensation for time  worked over forty (40) hours per week and are entitled to be paid this amount, plus  liquidated damages.   50. Plaintiffs re-allege and re-aver all previous paragraphs of the Collective Action  Complaint as if fully set forth herein.   51. Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs worked for  Defendants for a flat rate of pay each night or shift that did not compensate them in  an amount equal to or in excess of the federal minimum wage rate of pay for all hours  worked.   52. Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs were, and are,  entitled to be paid at a rate equal to or in excess of the federally-mandated minimum  wage rate as set forth in the FLSA.   53. At all times material hereto, Defendants failed to comply with Title 29 and United  States Department of Labor Regulations, 29 C.F.R. §§516.2 and 516.4, by  implementing a management policy, plan or decision that intentionally provided for  the compensation of Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs  as if they were exempt from coverage under 29 U.S.C. §§201 through 219,  disregarding the fact that they were not exempt.    54. At all times material hereto, Defendants failed to maintain proper time records as  mandated by the FLSA.   56. Defendants have failed to properly disclose or apprise Plaintiffs Smith and Trujillo  and the FLSA Collective Plaintiffs of their rights under the FLSA.   57. Due to the intentional, willful, and unlawful acts of Defendants, Plaintiffs Smith and  Trujillo and the FLSA Collective Plaintiffs have suffered lost minimum wage  compensation for time worked and are entitled to be paid this amount, plus liquidated  damages.   58. Plaintiffs Smith and Trujillo and the FLSA Collective Plaintiffs are entitled to an  award of reasonable attorney’s fees and costs pursuant to 29 U.S.C. §216(b).  FAIR LABOR STANDARDS ACT 29 U.S.C. § 201 ET. SEQ.   LABOR STANDARDS ACT 29 U.S.C. § 201 ET. SEQ.  