22.  Defendant Nexen is a subcontracting company that, upon information  and belief, contracted with Defendant Amazon to provide laborers for Defendant  Amazon’s warehouses.   23.  Plaintiffs worked as warehouse laborers for Nexen and Amazon in  December 2017. (Exhibit A, ¶ 1) (Exhibit B, ¶ 1).   24.  Plaintiffs were told by Nexen managers that they would make $25.00  an hour for the work that they did in the Amazon warehouse in Hazel Park, MI.  (Exhibit A, ¶ 3) (Exhibit B, ¶ 2).   25.  When Plaintiffs arrived at the Amazon warehouse, they checked in with  employees who worked in the Amazon warehouse. (Exhibit A, ¶ 6) (Exhibit B, ¶ 6).    26.  Plaintiffs were given safety equipment by the employees at the Amazon  warehouse for them to use including safety vests and gloves. (Exhibit B, ¶ 7).   28.  While working at the Amazon warehouse, Plaintiffs used Amazon’s  equipment including hydraulic pallet jacks, large metal racks, and portable metal  lines used to load and unload products onto trucks. (Exhibit A, ¶ 6) (Exhibit B, ¶ 9).    29.  Plaintiffs did not get paid for the work that they did for Nexen and  Amazon, so they contacted Defendant Kirka, the owner of Nexen. (Exhibit A, ¶¶ 8  -9) (Exhibit B, ¶¶ 11 – 13).   30.  Plaintiffs had significant difficulties getting ahold of Defendant Kirka.  (Exhibit A, ¶ 9) (Exhibit B, ¶ 14).   31.  Plaintiff McKearnan finally got a hold of Defendant Kirka after calling  him six times. Defendant Kirka told him to come down to the Amazon warehouse  and fill out W-2 forms so that he could be paid. (Exhibit B, ¶¶ 14 – 15). Plaintiff  McKearnan filled out the paperwork as instructed. (Exhibit B, ¶ 16). Plaintiff  McKearnan still was not paid after filling out the W-2 forms, so he called Defendant  Kirka again, but Defendant Kirka never returned his calls. (Exhibit B, ¶ 18).   33.  To date, Plaintiffs have not received any compensation for the work  that they did for Defendant Nexen or Defendant Amazon. (Exhibit A, ¶ 12) (Exhibit  34.  Plaintiffs brings the FLSA claims (Counts I – III) in this action as a  collective action under 29 U.S.C. § 216(b).   35.  Plaintiffs assert these claims on behalf of themselves and on behalf of  all similarly situated laborers.   36.  Plaintiffs seek to notify the following employees of their right under  29 U.S.C. § 216(b) to join this action by filing in this Court written notice of their  consent to join the action:  All individuals who worked at any time during the past  three years for Defendant Nexen as laborers out of the  Amazon warehouse in Hazel Park, MI.   38.  Upon information and belief, Defendant Nexen has employed many  similarly situated laborers during the time period relevant to this action.   39.  The identities of these employees, as a group, are known only to  Defendants. Because the numerous members of this collective action are unknown  to Plaintiffs, joinder of each member is not practicable.   40.  Plaintiffs ask this Court to require Defendants to furnish Plaintiffs with  the contact information of other similarly situated laborers pursuant to 29 U.S.C.  § 216(b), for the purpose of collectively adjudicating their FLSA claims.   41.  Collective adjudication is appropriate in this case because the  employees who Plaintiffs wish to notify of this action have been employed in the  same position as Plaintiffs; have performed work similar to that of Plaintiffs; have  been subject to the same policies and procedures as Plaintiffs; and have been subject  to compensation practices similar to those which form the basis of Plaintiffs’ case,  including unlawful failure to pay the minimum wage under the FLSA.  47.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    48.  Plaintiffs were “employees” of Defendant Nexen as that term is defined  by the FLSA, 29 U.S.C. § 203(e), because Defendant Nexen “suffered or permitted”  them to work for it.   50.  Defendant Nexen is an “enterprise” as defined by the FLSA, 29 U.S.C.                 § 204(r)(1), and is engaged in the processing and handling of goods which move in  interstate commerce within the meaning of the FLSA. 29 U.S.C. § 203(s)(1).    51.  Defendant Nexen is required to comply with the requirements of the  56.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    57.  Plaintiffs were “employees” of Defendant Kirka as that term is defined  by the FLSA, 29 U.S.C. § 203(e), because Defendant Kirka “suffered or permitted”  them to work for him.   58.  Defendant  Kirka  was  an  employer  of  Plaintiffs  under  29 U.S.C. § 203(e) because he “suffered or permitted” them to work for him.   59.  Defendant Kirka, upon information and belief to be true, has ownership  interest in the enterprise Defendant Nexen, which employed Plaintiffs.    60.  Defendant Kirka has operational control of Defendant Nexen.  Defendant Kirka’s operational control includes his overseeing of the pay policies of  Defendant Nexen and the signing off on all of the payroll for Defendant Nexen.   61.  As an employer of Plaintiffs and the putative class members, Defendant  Kirka is required to comply with the requirements of the FLSA.   62.  The minimum wage provision of the FLSA requires that employers pay  at least the minimum wage to employees for all hours worked. 29 U.S.C. § 206.   64.  Defendant Kirka willfully failed to comply with the minimum wage  provision of the FLSA.   65.  In addition to compensatory damages for unpaid minimum wages,  Plaintiffs are owed liquidated damages in an amount equal to their compensatory  damages pursuant to the FLSA, 29 U.S.C. § 216(b), and their reasonable attorneys’  fees, to be paid by Defendant Kirka for his willful failure to pay at least the minimum  wage for all hours worked by Plaintiffs.   66.  Under the theory of Corporate Officer Liability adopted by this circuit  in Dole v. Elliott Travel & Tours, Inc., 942 F.2d 962, 965 (6th Cir. 1991), Defendant  Kirka is jointly and severally liable for the violations of the FLSA.  67.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    68.  Defendant Amazon was Plaintiffs’ joint employer. Defendant Amazon  contracted out work through subcontracting companies like Defendant Nexen in  order to deliver Amazon products to Amazon customers. Defendant Amazon set a  number of policies and procedures that it enforced through Defendant Nexen.   70.  Defendant Amazon is an “enterprise” as defined by the FLSA,  29 U.S.C. § 204(r)(1), and is engaged in processing and handling of goods which  move in interstate commerce within the meaning of the FLSA. 29 U.S.C.  § 203(s)(1).    71.  Defendant Amazon is required to comply with the requirements of the  78.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    79.  Plaintiffs were Defendant Nexen’s “employees” as that term is defined  by the WOWA, MCL § 408.412.    80.  Defendant Nexen was Plaintiffs’ “employer” as that term is defined by  the WOWA, MCL § 408.412.   81.  Defendant Nexen knowingly, intentionally, and willfully failed to pay  Plaintiffs and the putative class members at least the Michigan minimum wage for  all hours worked, in violation of the WOWA, MCL § 408.414.   83.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    84.  Plaintiffs were Defendant Kirka’s “employees” as that term is defined  by the WOWA, MCL § 408.412.    85.  Defendant Kirka was Plaintiffs’ “employer” as that term is defined by  the WOWA, MCL § 408.412.   86.  Defendant Kirka knowingly, intentionally, and willfully failed to pay  Plaintiffs and the putative class members at least the Michigan minimum wage for  all hours worked, in violation of the WOWA, MCL § 408.414.   88.  Plaintiffs hereby repeat and reallege all preceding paragraphs as though  fully set forth herein.    89.  Plaintiffs were Defendant Amazon’s “employees” as that term is  defined by the WOWA, MCL § 408.412.    90.  Defendant Amazon was Plaintiffs’ “employer” as that term is defined  by the WOWA, MCL § 408.412.   91.  Defendant Amazon knowingly, intentionally, and willfully failed to pay  Plaintiffs and the putative class members at least the Michigan minimum wage for  all hours worked, in violation of the WOWA, MCL § 408.414.   92.  As a result of Defendant Amazon’s failure to pay Plaintiffs the  applicable Michigan minimum wage, Plaintiffs are entitled to an award of damages,  including but not limited to, compensatory damages, liquidated damages in an  amount equal to their compensatory damages, costs of their lawsuit, and their  reasonable attorney’s fees pursuant to MCL § 408.419.  Defendant Kirka - Violation of the Minimum Wage Provision of the WOWA   Defendant Steve Kirka - Violation of the Minimum Wage Provision of the  FLSA   Defendant Amazon - Violation of the Minimum Wage Provision of the FLSA   Defendant Nexen - Violation of the Minimum Wage Provision of the WOWA   Defendant Nexen - Violation of the Minimum Wage Provision of the FLSA   Defendant Amazon - Violation of the Minimum Wage Provision of the  WOWA   FLSA Collective Action Claims Brought Pursuant to 29 U.S.C. § 216(b)  