15. The Kikka defendants form a successful restaurateur, then as a sushi supplier company with  over 25 years of experience, and several years operation and experience in the New Orleans  area.. The company currently specializes in operation of small in-store sushi restaurants and a  sushi supplier in the New Orleans metropolitan area, and beyond.    16. At all times relevant to this action, KIKKA has employed Plaintiff and other employees to  work at an hourly rate as restaurant workers, as well as in the other services listed hereinabove.   Plaintiffs and the other KIKKA workers performed most or all of their work for KIKKA within  the Eastern District of Louisiana.   18. Upon information and belief, KIKKA and/or Tonny Soesanto instigated the creation of West  Bank Holdings II with the intention that West Bank Holdings II would become the “employer”  of Plaintiffs, through check issuance on paper, and the other KIKKA workers, or some of them.     19. Plaintiffs had no knowledge of West Bank Holdings II as an employer and Plaintiffs never had  reason to believe that they were employees of any entity other than KIKKA, and in fact any  and all payment distributed to them, work assignments, hours, uniforms, tools, and otherwise  were provided by KIKKA.   20. West Bank Holdings II is an instrumentality or alter ego of KIKKA and Tonny Soesanto and  is, at most, a joint employer with those defendants.  KIKKA and Tonny Soesanto at all relevant  times continued to control the restaurant employees hiring and firing, work schedules and  employment conditions, rates and methods of payment, and employment records.   21. Although Plaintiffs were non-exempt employees under the FLSA and routinely worked in  excess of 40 hours per week, Defendants never paid Plaintiffs an overtime rate of one and one- half times their regular rate of pay for hours worked in excess of 40 hours per workweek.     22. Defendants have also willfully and improperly applied the same unlawful pay practice to many  other non-exempt employees.  Plaintiffs are aware of other current and former non-exempt  employees of Defendants who also worked overtime hours for Defendants without receiving  overtime pay.   24. Plaintiffs bring this suit as a collective action pursuant to 29 U.S.C. § 216(b) on behalf of  themselves and all others employed by Defendants as restaurant employees, chefs, cooks, and  clerical workers within three (3) years prior to the filing of this Complaint who, like Plaintiffs,  have not been compensated at one and one-half their regular rate of pay for all hours worked  in excess of forty (40) in a single workweek.   25. Plaintiffs have consented in writing to be a part of this action.  Plaintiff signed consent forms  are attached hereto as Exhibit A.   26. More than a dozen additional current and/or former employees of Defendants have signed  consent forms to join this action as “opt-in” members of the FLSA Collective.  These consent  forms will be filed at a later date.  As this case proceeds, it is likely that other individuals will  file consent forms and join this action as “opt-in” plaintiffs.   27. Defendants classify and pay all of their restaurant clerical employees, such as Plaintiff,  in the  manner described herein.  As such, Defendants maintained a common pay practice or policy  and the FLSA Collective are similarly situated to Plaintiffs.   28. Defendants’ restaurant employees all perform the same essential job functions and duties  although one employee might have more tenure, experience, or require less supervision than  another employee in the same or similar position.  As such, the FLSA Collective are similarly  situated to Plaintiffs.   29. Although the exact amount of damages may vary, damages for each individual can be  calculated using the same method and formula.   31. The FLSA Collective should be allowed to receive notice about this lawsuit and given an  opportunity to join.  Like Plaintiffs, these similarly situated employees are entitled to recover  their unpaid overtime wages, liquidated damages, attorneys’ fees, and other damages.  Therefore, notice is appropriately sent to the following class:  All individuals who were employed by   KIKKA A/K/A KIKKA SUSHI, Tonny Soesanto, or any other related entity as  restaurant employees during any workweek between JUNE 29, 2017 and up to  the time notice of this action is provided.   32. Defendants willfully engaged in a pattern of violating the FLSA as described in this Complaint  in ways including, but not limited to, failing to pay their employees overtime compensation.   Defendants’ conduct constitutes a willful violation of the FLSA within the meaning of 29  33. Plaintiffs incorporate by reference the allegations contained in all of the above paragraphs as  if fully set forth herein.   34. The FLSA applies to Defendants’ employment of Plaintiffs and the FLSA Collective.   35. The FLSA mandates that employees are entitled to overtime premium pay at a rate of no less  than one and one-half times the employee's regular rate for all hours worked in excess of 40  hours per workweek.   36. Defendants have willfully refused to pay overtime to Plaintiffs and the FLSA Collective for  hours worked in excess of 40 hours per workweek.   38. The foregoing conduct, as alleged, constitutes a willful violation of the FLSA within the  meaning of the FLSA.  Defendants knew or showed reckless disregard for the fact that their  compensation practices were in violation of the FLSA.  