68.  Plaintiff brings the First Claim against defendants as a collective action pursuant  to the FLSA, 29 U.S.C. § 216(b) on behalf of himself and other similarly situated individuals,  which include all car wash workers employed by defendants at the Car Washes at any time three  years prior to the filing of this action through the entry of judgment in this action (the “FLSA  Collective”).    69.  The FLSA Collective consists of approximately 20 similarly situated current and  former car wash workers who have been victims of defendants’ common policy and practices  that have violated their rights under the FLSA by willfully denying them overtime pay and other  wages.     71.  This policy, pattern, or practice includes, inter alia:  a. failing to pay overtime at the rate of one and one-half times the FLSA  Collective’s regular hourly rate for hours worked in excess of 40 in a workweek.   72.  Defendants’ unlawful conduct has been intentional, willful, and in bad faith and  has caused significant damage to the FLSA Collective.          73.  The FLSA Collective would benefit from the issuance of a court-supervised  notice of the present lawsuit and the opportunity to join the present lawsuit.  Those similarly  situated employees are known to defendants and are readily identifiable and can be located  through defendants’ records, which they are required to maintain pursuant to the FLSA and  NJWHL. Those similarly situated employees should be notified of and allowed to opt into this  action pursuant to 29 U.S.C. § 216(b).  74.  Plaintiff brings the Second and Third Claims against defendants for unpaid  minimum wage and unpaid overtime on behalf of himself and other employees similarly situated  pursuant to N.J.S.A. 34:11-56a25, which provides in pertinent part, “An employee shall be  entitled to maintain such action for and on behalf of himself or other employees similarly  situated, and such employee and employees may designate an agent or representative to maintain  such action for and on behalf of all employees similarly situated.”    75.  Plaintiff is a member of a class of employees of similarly situated individuals  which includes all car wash workers employed by defendants at the Car Washes at any time two  years prior to the filing of the action through entry of judgment in this action (the “New Jersey  Class”).   77.  The identity of the New Jersey Class members is known to the defendants and is  contained in the employment records that the defendants are required to create and maintain  pursuant to the FLSA and NJWHL.   78.  Plaintiff is similarly situated to the New Jersey Class because plaintiff and the  New Jersey Class performed similar work under similar terms and conditions of employment,  and  sustained similar damages arising out of defendants’ conduct in violation of the NJWHL.     79.  The New Jersey Class members work, or have worked, for the defendants in New  Jersey as car wash workers and were not paid New Jersey State mandated minimum wage and  overtime pay by the defendants. They have sustained similar types of damages as a result of  defendants’ failure to comply with the NJWHL and supporting regulations of the New Jersey  Department of Labor and Workplace Development contained in the New Jersey Administrative  Code (NJAC).    80.  Plaintiff will fairly and adequately protect the interests of the members of the  New Jersey Class and has retained counsel competent and experienced in complex class action  litigation.   81.  Plaintiff has no interests that are contrary to or in conflict with those of the other  members of the New Jersey Class.   82.  This action is properly maintainable as a class action under N.J.S.A 34:11-56a25.  83.  At all relevant times, Shoulman operated and managed Clinton Car Wash, 45  West, and Royal Touch.   85.  Clinton Car Wash, 45 West, and Royal Touch shared car wash workers.   86.  Throughout his employment, Scarpis’s primary duties included washing, drying,  vacuuming, and cleaning motor vehicles.     87.  At all relevant times, defendants recorded Scarpis and other car wash workers’  hours of work by having car wash workers clock in and out by placing a punch card into a  machine.     88.  At all relevant times, Scarpis and other car wash workers typically worked 69  hours per workweek.   89.  Throughout his employment, Scarpis and other car wash workers generally  worked seven days per week with the following schedule: Monday through Saturday, 8:00 a.m.  to 6:00 p.m. and Sunday 8:00 a.m. to 5:00 p.m.   90.  Scarpis and other car wash workers did not receive any meal or rest breaks during  the workday.    91.  Scarpis and other car wash workers were paid on a weekly basis in cash.   92.  Effective January 1, 2015, the New Jersey hourly minimum wage became $8.38,  and effective January 1, 2017, the New Jersey hourly minimum wage became $8.44.   93.  Scarpis was paid $8.00 per hour for all hours worked, in violation of the New  Jersey state minimum wage rate.   94.  Other members of the New Jersey Class were paid equal to or less than $8.00 per  hour for all hours worked, in violation of the New Jersey State minimum wage rate.   96.  The car wash workers received tips at the end of each day, which were collected  in a box at the end of the car wash.   97.  Defendants did not provide Scarpis or the other car wash workers with the  required notice informing them of any intention of defendants to take a tip credit toward  defendants’ obligations to pay minimum wages and/or overtime pursuant to the FLSA and 