20.  Plaintiff Jose Reyes was employed by Defendants from on or about December 2008 to on  or about February 2016.    21.  In the course of his employment by Defendants, Plaintiff Jose Reyes performed physical  labor including but not limited to the repair and maintenance of diesel trucks owned and  utilized by Defendants in their landscaping, snow removal and maintenance business, as  well as painting of lines in parking lots.  Plaintiff Jose Reyes performed the aforesaid  painting work in locations throughout Rhode Island, Massachusetts, Connecticut and New  York.   22.  Plaintiff Jose Reyes regularly worked more than 9 hours per day from Monday through  Friday and worked at least 4 hours on Saturday or Sunday every weekend.     23.  Plaintiff Jose Reyes occasionally worked on holidays including Christmas and New Year’s  Day.    24.  Plaintiff Jose Reyes’ regular rate of pay ranged from $11 per hour in 2008 to $13.50 per  hour at the termination of his employment in 2016.     25.  Plaintiff Jose Reyes never received a premium rate of pay for time worked in excess of 40  hours in a week and for hours worked on Sundays.   26.  On a limited number of occasions, Plaintiff Jose Reyes received a premium rate of pay for  5  hours worked on holidays.     27.  Plaintiff Jose Reyes asked Defendants why he was not paid “time and a half” for overtime  hours and, in response, was told “we don’t pay it.”  Plaintiff Cleyber Dubon   28.  Plaintiff Cleyber Dubon was employed by Defendants from on or about May 2003 to on  or about October 2015.    29.  In the course of his employment by Defendants, Plaintiff Cleyber Dubon performed  physical labor including but not limited to landscaping and snow removal work at locations  in Rhode Island, Massachusetts and Connecticut.    30.  Plaintiff Cleyber Dubon regularly worked 10-12 or more hours per day at least six days per  week and, during certain periods, seven days per week.    31.  Plaintiff Cleyber Dubon’s regular rate of pay ranged from $12 per hour in 2003 to $15 per  hour at the termination of his employment in 2016.   32.  Plaintiff Cleyber Dubon never received a premium rate of pay for time worked in excess  of 40 hours in a week and for hours worked on Sundays.   33.  Plaintiff Cleyber Dubon asked Defendants why he was not paid “time and a half” for  overtime hours and, in response, was told “in landscaping, we don’t pay overtime.”  Facts Common to Both Plaintiffs   34.  During Plaintiffs’ employment, Defendants did not post and keep posted a notice  explaining the Fair Labor Standards Act, as prescribed by the United States Department of  Labor, Wage and Hour Division, in a conspicuous place in their establishment such as  would permit Plaintiff or other employees to observe readily a copy, as required by 29  40.  Plaintiffs bring Count 1 as a collective action under the collective action provision of the  FLSA as set forth in 29 U.S.C. § 216(b) on behalf of all current and former employees  who have worked for Defendants in the State of Rhode Island within the past three years  7  of the filing of a consent to sue by such employee and the date of final judgment in this  matter and who were, are or will be eligible for but did not receive overtime  compensation.   41.  Class Plaintiffs are situated similarly to Plaintiffs within the meaning of FLSA § 216(b)  and, therefore, the First Count herein may be brought and maintained as an “opt-in”  collective action pursuant to Section 16(b) of FLSA .    42.  This action is also maintainable as a collective action pursuant to FLSA § 216(b) because  the prosecution of separate actions by individual members of the class would create a risk  of inconsistent or varying adjudications with respect to individual members of the class  which would establish incompatible standards of conduct for Defendants.    43.  Questions of law and fact common to the collective action as a whole include, but are not  limited to the following:  a. Whether Defendants unlawfully failed and continue to fail to pay overtime  compensation in violation of FLSA; and  b. Whether Defendants unlawful failure to pay overtime compensation to  Plaintiffs and Class Plaintiffs was willful.   44.  The names and addresses of the Class Plaintiffs are available from Defendants and notice  should be provided to Class Plaintiffs both by first class mail to their last known address  and by workplace posting as soon as possible.  VI.  45.  Plaintiffs restate, re-allege and incorporate by reference paragraphs 1 through 44, above.   46.  As described above, Defendants failed to pay Plaintiffs at least one and a half times a  lawful, regular hourly wage for hours over forty worked in each week.  8   47.  Defendants' failure to pay overtime wages as required by FLSA was willful and/or in bad  faith, inasmuch as Defendants were aware or reasonably should have been aware of their  obligation to pay Plaintiffs consistent with the FLSA and did not do so.   48.  As a result of Defendants' unlawful conduct as described above, Plaintiffs suffered a loss  of wages.  49.  Plaintiffs restate, re-allege and incorporate by reference paragraphs 1 through 44, above.   50.  As described above, Defendants failed to pay Plaintiffs at least one and a half times a  lawful, regular hourly wage for hours over forty worked in each week, for hours worked  on Sundays and for hours worked on holidays.   51.  Defendants’ failure to pay overtime wages as required by RIMWA was willful, inasmuch  as Defendants were aware or reasonably should have been aware of their obligation to pay  Plaintiffs consistent with RIMWA and did not do so.   52.  As a result of Defendants' unlawful conduct as described above, Plaintiffs suffered a loss  of wages.  Plaintiff Jose Reyes  