20. Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set  forth herein.   21. Plaintiff and similarly-situated staff, including STNAs, work or worked for  Defendants during the past three years.   22. These STNAs and similar staff were compensated at two pay rates, one for Medicare,  $8.00 per hour (later raised to $8.50 per hour), and other for non-Medicare, $9.00 per hour.   23. During that time, Renaissance refused to pay overtime for hours worked in excess of  40 hours.    24. For example, during the workweek ending December 22, 2013, Ms. Hunt worked a  total of 42 hours (38 hours at the non-Medicare rate of $9.00 per hour and 4 hours at the  Medicare rate of $8.00 per hour.) See Ex. 3, Paystubs for Class Period, p. 1.   25. She was short paid in the following manner, because she had 2 hours of overtime:  Week Ending December 22, 2013  INCORRECT Pay Calculation  CORRECT Pay Calculation  Type  Hrs  Rate  Amt Paid  Hrs  Rate  OT  39. Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set  forth herein.   40. Plaintiff brings Count I below individually and on behalf of all individuals similarly  situated, specifically:  All persons who work(ed) as STNAs or in positions with similar titles or duties  for Defendants at any time in the last three years prior to the filing of this  Complaint (the proposed “FLSA Collective”)   41. Members of the proposed FLSA Collective are known to Defendants and are readily  identifiable through Defendant’s records.   42. Plaintiff and the FLSA Collective are all victims of Defendants’ widespread,  repeated, systematic, and consistent illegal policies that have resulted in violations of their rights  under the FLSA, 29 U.S.C. § 201, et seq., and that have caused significant damage to Plaintiff  and the FLSA Collective.  7   43. These individuals would benefit from the issuance of court-supervised notice of this  lawsuit and the opportunity to join by filing their written consent.  44. Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully set  forth herein.   45. Pursuant to Federal Rule of Civil Procedure 23(a) and 23(b),  Plaintiff brings Count II  of this Complaint on behalf of herself and the following persons:  All persons who work(ed) as STNAs, or in positions with similar titles or duties for  Defendants at any time in the last three years prior to the filing of this Complaint (the  “Putative Class”)   46. The persons in the Putative Class are so numerous that joinder of all members of the  Putative Class is impracticable. While the precise number of class members has not been  determined at this time, Defendants have employed more than three hundred (300) individuals in  positions with similar titles or duties during the statute of limitations period.   47. Plaintiff and the Putative Class have been equally affected by Defendants’ violations  of law.   48. There are questions of law and fact common to the Putative Class that predominate  over any questions affecting individual members of the Putative Class, including but not limited  to the following:  a. Whether Defendants violated Federal law for failure to pay all overtime wages at  one-and-one-half times the regular rate of pay for each hour worked over forty  hours during a workweek;  b. Whether Defendants violated Ohio law for failure to pay all overtime wages at  one-and-one-half times the regular rate of pay for each hour worked over forty  hours during a workweek;  c. The proper measure and calculation of damages; and  d. Whether Defendants’ actions were willful or in good faith.  8   49. Plaintiff’s claims are typical of those of the members of the Putative Class.   50. They have been subject to Defendants’ practices and policies described in this  Complaint. Further, Plaintiff’s job duties are typical of the Putative Class, as all class members  performed in-home care duties for the elderly or infirmed.   51. Plaintiff will fairly and adequately protect the interests of the Putative Class, and has  retained counsel experienced in complex wage and hour class and collective action litigation to  prosecute her claims.   52. This action is properly maintainable as a class action under Federal Rule of Civil  Procedure 23(b)(3) because questions of law or fact predominate over any questions affecting  individual class members, and a class action is superior to other methods in order to ensure a fair  and efficient adjudication of this controversy. Individual plaintiffs often lack the financial  resources to vigorously prosecute separate lawsuits in federal court against large corporate  defendants to recover lost wages. Class litigation is also superior because it will preclude the  need for unduly duplicative litigation resulting in inconsistent judgments pertaining to  Defendant’s policies and practices. There do not appear to be any difficulties in managing this  class action.   53. Plaintiff intends to move for certification of the Putative Class as soon as practical  under Federal Rule of Civil Procedure 23.  54. Plaintiff, individually and on behalf of the FLSA Collective, re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.  9   55. The FLSA requires covered employers to pay non-exempt employees no less than  one-and-one-half times their regular rate of pay for all hours worked in excess of forty (40) in a  workweek.  29 U.S.C. § 207.   56. Defendant Renaissance is an “enterprise” as defined by the FLSA, 29 U.S.C. §  2063(r)(1), and are engaged in commerce within the meaning of the FLSA, § 203(b), (s)(1).   57. Plaintiff and the FLSA Collective qualified as non-exempt covered employees during  the relevant time period.  29 U.S.C. § 203(e)(1).   58. Plaintiff and the FLSA Collective regularly worked more than forty (40) hours per  week for Defendants, but Defendants did not properly compensate Plaintiff and the FLSA  Collective for all of their overtime hours as required by the FLSA.   59. Defendants did not and have not made a good-faith effort to comply with the FLSA as  it relates to the compensation of Plaintiff and the FLSA Collective.   60. Defendants knew Plaintiff and the FLSA Collective worked overtime without proper  compensation, and they willfully failed and refused to pay Plaintiff and the FLSA Collective  wages at the required overtime rates.  See 29 U.S.C. § 255.   61. Defendants’ willful failure and refusal to pay Plaintiff and the FLSA Collective  overtime wages for time worked violates the FLSA.  29 U.S.C. § 207.   62. As a direct and proximate result of these unlawful practices, Plaintiff and the FLSA  Collective suffered and continue to suffer wage loss and are therefore entitled to recover unpaid  overtime wages for up to three years prior to the filing of their claims, liquidated damages or  prejudgment interest, attorneys’ fees and costs, and such other legal and equitable relief as the  Court deems just and proper.  10  63. Plaintiff incorporates the above paragraphs by reference as if fully set forth herein.   64. The OMFWSA requires employers to pay their employees for all hours worked in  excess of forty (40) hours in an individual workweek at a rate no less than one and one-half  times their regular hourly rate of pay.  R.C. § 4111.03.   65. Plaintiff and the Putative Class qualified as Defendants’ employees within during the  relevant time period the meaning of the OMFWSA, R.C. 4111.14.   66. Plaintiff and the Putative Class regularly worked more than forty (40) hours per week  for Defendants, but Defendants did not properly compensate Plaintiff and the Putative Class for  all of their overtime hours as required by the OMFWSA.   67. As a direct and proximate result of these unlawful practices, Plaintiff and the Putative  Class suffered and continue to suffer wage loss and are therefore entitled to recover unpaid back  wages for up to two years prior to the filing of their claims, liquidated damages or prejudgment  interest, attorneys’ fees and costs, and such other legal and equitable relief as the Court deems  just and proper.  FEDERAL OVERTIME  (Fair Labor Standards Act, 29 U.S.C. § 201, et seq.)  On Behalf of Plaintiff and the FLSA Collective   STATE OVERTIME  (Ohio Minimum Fair Wage Standards Act (OMFWSA), R.C. § 4111.01, et seq)  On Behalf of Plaintiff and the Putative Class  