24.  Defendants PDC and ADS are a full-service solid waste company providing waste  collection, recycling, and disposal services to a commercial, industrial, and residential customers  across the states of Illinois and Missouri.2    25.  To provide these services, Defendants employed (and continue to employ)  numerous Waste Disposal Drivers—including Plaintiff and the Putative Class Members. While  exact job titles may differ, these employees were subjected to the same or similar illegal pay  practices for similar work throughout the United States.   27.  Defendants PDC and ADS are integrated companies that share customers,  properties, employees, and all other assets.    28.  Defendant ADS is a wholly owned subsidiary of PDC, acquired in 1989.3   29.  Defendant PDC manages key internal relationships to Defendant ADS—that is, it  directs the financials of Defendant ADS and controls the pay of Plaintiff and the Putative Class  Members.    30.  Moreover, all Defendants have (or had) the power to hire and fire Plaintiff and the  Putative Class Members; supervise and control Plaintiff and the Putative Class Members’ work  schedules and conditions of their employment; determine their rate and method of payment; and,  jointly maintain their employment records.    31.  As a result, all Defendants are responsible, both individually and jointly, for  compliance with all of the applicable provisions of the FLSA and Illinois state law with respect to  the entire employment for the workweeks at issue in this case.   32.  Plaintiff and the Putative Class Members are (or were) non-exempt Waste Disposal  Drivers employed by Defendants for the relevant time-periods preceding the filing of this  Complaint through the final disposition of this matter.   33.  Importantly, none of the FLSA exemptions relieving a covered employer (such as  Defendants) of the statutory duty to pay its employees overtime at one and one-half times the  regular rate of pay apply to Plaintiff or the Putative Class Members.   35.  Defendants have a policy wherein they automatically deduct at least one, and as  many as two, 30-minute meal periods from Plaintiff and the Putative Class Members daily time.    36.  Waste Disposal Drivers, such as Plaintiff and the Putative Class Members,  automatically have thirty (30) minutes per day for a meal period deducted from his or her hours  worked if they work under twelve (12) hours in one day. Waste Disposal Drivers, such as Plaintiff  and the Putative Class members, automatically have one full hour per day for meal periods  deducted from his or her hours worked if they work over twelve (12) hours in one day.   37.  Defendants were (and continue to be) aware that Plaintiff and the Putative Class  Members regularly worked (and continue to work) through their meal periods without pay in  violation of the FLSA.   38.  When calculating Plaintiff and the Putative Class Members’ hours each workweek,  Defendants deducted (and continue to deduct) up to one hour from Plaintiff and the Putative Class  Members’ daily on-the-clock hours, in violation of the FLSA.   39.  In other words, for each 5-day workweek, Defendants deducted (and continue to  deduct) up to five (5) hours from each workweek’s total “on-the-clock” hours. For a 6-day  workweek, Defendants deducted (and continue to deduct) up to six (6) hours from each  workweek’s total “on-the-clock” hours.     41.  Defendants’ systematic deduction of the meal periods from actual hours worked in  excess of 40 hours per workweek deprived (and continues to deprive) Plaintiff and the Putative  Class Members of the required and proper amount of overtime pay in violation of the FLSA.   42.  As a result of Defendants’ failure to compensate Plaintiff and the Putative Class  Members for performing work “off-the-clock,” Plaintiff and the Putative Class Members worked  overtime hours for which they were not compensated.   43.  Defendants’ failure to compensate Plaintiff and the Putative Class Members for  their “off-the-clock” overtime hours violated (and continues to violate) the FLSA.   44.  Defendants knew or should have known that they were miscalculating Plaintiff and  the Putative Class Members’ regular rates of pay and that the proper amount of overtime  compensation was not being paid to Plaintiff and the Putative Class Members in violation of the  66.  All previous paragraphs are incorporated as though fully set forth herein.   67.  Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of all of  Defendants’ employees who have been similarly situated to Plaintiff with regard to the work they  performed and the manner in which they have not been paid.   68.  Other similarly situated employees of Defendants have been victimized by  Defendants’ patterns, practices, and policies, which are in willful violation of the FLSA.   70.  Defendants’ failure to pay Plaintiff and the FLSA Collective Members for all hours  worked and overtime compensation at the rates required by the FLSA, results from generally  applicable policies and practices of Defendants, and does not depend on the personal  circumstances of Plaintiff or the FLSA Collective Members.    71.  Thus, Plaintiff’s experiences are typical of the experiences of the FLSA Collective  Members.   72.  The specific job titles or precise job requirements of the various FLSA Collective  Members do not prevent collective treatment.    73.  All of the FLSA Collective Members—regardless of their specific job titles, precise  job requirements, rates of pay, or job locations—are entitled to be paid for all hours worked and  at the proper overtime rate for all hours worked in excess of forty (40) hours per workweek.    74.  Although the issues of damages may be individual in character, there is no  detraction from the common nucleus of liability facts.     75.  Absent a collective action, many members of the proposed FLSA collective likely  will not obtain redress of their injuries and Defendants will retain the proceeds of their rampant  violations.   76.  Moreover, individual litigation would be unduly burdensome to the judicial system.  Concentrating the litigation in one forum will promote judicial economy and parity among the  claims of the individual members of the classes and provide for judicial consistency.   77.  Accordingly, the FLSA collective of similarly situated plaintiffs should be certified  as defined as in Paragraph 49 and notice should be promptly sent.   78.  Plaintiff incorporate by reference all paragraphs and allegations set forth in the  statement of facts of this complaint as though fully and completely set forth herein.   79.  The Illinois Class is defined as:  96.  Plaintiff Stinson brings her Illinois claims pursuant to Illinois Statutes as a class  action pursuant to Rule 23 on behalf of all similarly situated individuals employed by Defendants  to work in Illinois since March 27, 2017.   97.  Class action treatment of Plaintiff Stinson and the Illinois Class Members’ claims  is appropriate because, as alleged below, all of Rule 23’s class action requisites are satisfied.   98.  The number of Illinois Class Members is so numerous that joinder of all class  members is impracticable.   99.  Plaintiff Stinson is a member of the Illinois Class, her claims are typical of the  claims of other Illinois Class Members, and she has no interests that are antagonistic to or in  conflict with the interests of other class members.  100.  Plaintiff Stinson and her counsel will fairly and adequately represent the Illinois  Class Members and their interests.  101.  Class certification is appropriate under Federal Rule of Civil Procedure 23(b)(3)  because common questions of law and fact predominate over questions affecting only individual  class members and because a class action is superior to other available methods for the fair and  efficient adjudication of this litigation.  102.  Accordingly, the Illinois Class should be certified as defined in Paragraph 79.  VI. 