58.  Plaintiffs reallege and incorporate by reference all allegations in all  preceding paragraphs.   60.  Defendants employ Exotic Dancers and Drink Serving Dancers at their  aforementioned locations.   61.  “Exotic Dancers” refers to individuals who worked for Defendants as exotic  dancers, were treated as independent contractors by Defendants, and whose compensation  was through tips from Defendants’ customers.     62.  “Drink Serving Dancers” refers to individuals who worked for Defendants  as cocktail waitresses, were classified as employees when they worked as Cocktail  Waitresses but were reclassified as independent contractors for the remainder of their shift  when they worked as Exotic Dancers in a given shift–even if they returned to working as  Cocktail Servers during the same shift.   63.  Plaintiff Coll worked on a regular basis as an Exotic Dancer for Defendants’  adult entertainment club located in Tucson, Arizona.   64.  Plaintiff Coll was compensated exclusively through tips from Defendants’  customers.  That is, Defendants did not pay Plaintiff Selena Coll whatsoever for any hours  worked at their establishment.     65.  Plaintiff Nixon worked on a regular basis as a Cocktail Waitress Dancer for  Defendants’ adult entertainment club located in Tucson, Arizona.   67.  Furthermore, Defendants charged Plaintiffs Coll and Nixon a “house fee” per  shift worked.  Defendants also required Plaintiffs Coll and Nixon to share their tips with  other non-service employees who do not customarily receive tips, including the employers,  managers, disc jockeys, bouncers, and the house.   69.  Furthermore, Defendants are in violation of Arizona’s tipped employee  compensation provision, ARS ¶ 23-363(C), which provides that “the employer may pay a  wage up to $3.00 per hour less than the minimum if the employer can establish…that for  each week, when adding tips received to wages paid, the employee received not less than  the minimum wage for all hours worked.”  Defendants failed to compensate Plaintiffs Coll  and Nixon with wages for hours worked in violation of the Arizona Minimum Wage Act.   70.  Defendants illegally classified the Exotic Dancers and Drink Serving  Dancers as independent contractors.  However, at all times, the Putative Collective and  Class Members were employees of Defendants.   71.  In addition, Defendants instructed the Exotic Dancers and Drink Serving  Dancers about when, where, and how they were to perform their work.   73.  Defendants misclassified Plaintiffs Coll and Nixon and the Exotic Dancers  and Drink Serving Dancers as independent contractors to avoid Defendants’ obligation to  pay them pursuant to the FLSA and the AMWA.   74.  Plaintiffs Coll and Nixon are not exempt from the overtime and minimum  wage requirements of the FLSA and AMWA.   94.  Defendants’ practice of failing to pay Plaintiffs Coll and Nixon and the  Putative Collective and Class Members at the required minimum wage rate violates the  96.  Plaintiffs Coll and Nixon incorporate by reference all allegations in all  preceding paragraphs.   97.  Defendants’ practice of failing to pay Plaintiffs Coll and Nixon and the  Putative Collective and Class Members time-and-a-half rate for hours worked in excess of  forty (40) per workweek violates the FLSA, 29 U.S.C. § 207.     98.  None of the exemptions provided by the FLSA regulating the duty of  employers to pay all employees for all hours worked at the required minimum wage rate  are applicable to the Defendants or Plaintiffs Coll, Nixon, or the Putative Collective and  Class Members.  VIOLATION OF THE FAIR LABOR STANDARDS ACT  FAILURE TO PAY MINIMUM WAGE  (COLLECTIVE ACTION)   VIOLATION OF THE ARIZONA MINIMUM WAGE ACT  FAILURE TO PAY MINIMUM WAGE  (CLASS ACTION)  107. Plaintiffs Coll and Nixon incorporate by reference all allegations in all  preceding paragraphs.  108. Defendants’ practice of willfully failing to pay Plaintiffs Coll and Nixon and  the Putative Collective and Class Members wages at the rate of the Arizona Minimum  Wage violates the AMWA, ARS § 23-363.    VIOLATION OF THE FAIR LABOR STANDARDS ACT  FAILURE TO PAY OVERTIME  (COLLECTIVE ACTION)  