(Failure to Pay Overtime in Violation of the Fair Labor Standards Act)   10.  As a MSW for Defendant, Plaintiff conducted home visits to patients receiving  home care from Defendants. Plaintiff worked for Defendant out of both its Valdosta, Georgia  office, and its Nashville, Georgia office, providing home health care to GHHS’ clients.     12.  Defendant paid Plaintiff and other home health workers a fee for each patient visit  according to a fee schedule. For example, Plaintiff earned a set fee of $65 for conducting each  patient evaluation visit and of $40 for conducting each patient routine visit.  See Exhibit B.  This  pay structure was memorialized in writing by GHHS.  See Exhibit C.     13.  Defendant also paid Plaintiff and other home health workers on an hourly basis  for time spent attending regular staff meetings, in-service training, and required office time.  The  amounts of such payments were tied to the duration of the meetings, trainings and time spent in  the office.  See Exhibit C.     14.  Plaintiff was paid on the same “per visit” basis when she worked out of the  Valdosta, Georgia office, as when she was working out of the Nashville, Georgia office.     15.  Plaintiff and other home health workers often work over 40 hours per week.  For  example, Plaintiff typically worked between 50 and 60 hours per week.     16.  Defendant did not pay Plaintiff and other home health workers overtime premium  compensation for hours worked over 40 per week.     17.  In failing to pay proper overtime compensation to Plaintiff and other home health  workers, Defendant acted knowingly and with reckless disregard of the FLSA.    18.  Plaintiff asserts her FLSA claims pursuant to 29 U.S.C. § 216(b) as a collective  action on behalf of the following potential Opt-In Plaintiffs:    All current and former home health workers employed by Defendant at any time  since August 25, 2014, who were paid, in-part, on a fee-per-visit basis.     20.  Plaintiff and the potential Opt-In Plaintiffs are “similarly situated” as that term is  defined in 29 U.S.C. § 216(b) because, among other things, Defendant did not pay Plaintiff or  the potential Opt-In Plaintiffs proper overtime when they worked more than 40 hours in a week.    21.  All previous paragraphs are incorporated as though fully set forth herein.     22.  Plaintiff and those she seeks to represent pursuant to 29 U.S.C. § 216(b) are  employees of Defendant who are entitled to the FLSA’s protections.     23.  Defendant is an employer covered by the FLSA.     24.  The FLSA requires that covered employees receive overtime compensation “not  less than one and one-half times” their regular rate of pay.  See 29 U.S.C. § 207.     25.  Defendant violated the FLSA by failing to pay overtime premium compensation  to Plaintiff and similarly situated home health employees.     26.  In violation of the FLSA, Defendant has acted willfully and with reckless  disregard of clearly applicable FLSA provisions.    9.  Plaintiff worked for Defendant as a Medical Social Worker (“MSW”) from  approximately October 2016 through approximately June 2017.    