22.  Plaintiffs incorporate by reference paragraphs 1 through 21 of the Complaint as  though fully set forth herein.   23.  Plaintiff, Angelia Ruffin has been employed as security guard with Defendant,  MotorCity Casino since on or about March 11, 2002.   24.  Plaintiff, Constance Hudson has been employed as security guard with  Defendant, MotorCity Casino since December 2002.    25.  Plaintiff, Pamela Girton-Hart has been employed as security guard with  Defendant, MotorCity Casino within the last three years.   26.  Plaintiff, Sean Baldwin has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   27.  Plaintiff, Philip Tibbs has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   28.  Plaintiff, Alan Oden has been employed as security guard with Defendant,  MotorCity Casino since 1999.   29.  Plaintiff, Gregory Mosley has been employed as security guard with Defendant,  MotorCity Casino since December 1999.    30.  Plaintiff, Charles Moses has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   31.  Plaintiff, Michaele Jackson has been employed as security guard with Defendant,  MotorCity Casino within the last three years.  2:12-cv-11683-SJM-LJM   Doc # 1   Filed 04/16/12   Pg 3 of 8    Pg ID 3 4  32.  Plaintiff, Raphael Cosby has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   33.  Plaintiff, Eugene Hickman has been employed as security guard with Defendant,  MotorCity Casino since on or about March 11, 2002.   34.   Plaintiff, Cary Bryan has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   35.  Plaintiff, Robin White has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   36.  Plaintiff, Falikau Fofana has been employed as security guard with Defendant,  MotorCity Casino within the last three years.   37.  Since 1999 Defendant, required Plaintiffs and all similarly situated current and  former security guards to arrive at Defendant’s premises fifteen (15) minutes prior to their shift  for roll call.   38.  Since 1999 Defendant routinely disciplined security guards for failure to appear  at roll call, being late for roll call and/or any other alleged misconduct during roll call.   39.  Defendant repeatedly and willfully refused to compensate Plaintiffs and all  similarly situated current and former security guards similarly situated in violation of Fair Labor  Standards Act 29 U.S.C. § 201, et seq. and of the Michigan Wages and Fringe Benefits Act  MCLA 408.471, et seq.  40.  Plaintiffs incorporate by reference paragraphs 1 through 39 of the Complaint as  though fully set forth herein.   41.   Since 1999 Defendant, required Plaintiffs and all similarly situated current and  former security guards to arrive at Defendant’s premises fifteen (15) minutes prior to their shift  for roll call.  2:12-cv-11683-SJM-LJM   Doc # 1   Filed 04/16/12   Pg 4 of 8    Pg ID 4 5  42.  Since 1999 Defendant routinely disciplined security guards for failure to appear  at roll call, being late for roll call and/or any other alleged misconduct during roll call.   43.  The Fair Labor Standard Act 29 U.S.C. § 206 requires that Defendant pay to  each of its employees in an amount at least at the current minimum wage,   44.  Defendant repeatedly and willfully refused to compensate Plaintiffs and all  similarly situated current and former security guards similarly situated in violation of Fair Labor  Standards Act 29 U.S.C. § 201, et seq. and specifically U.S.C. § 206.   45.  As a direct and proximate cause of Defendant’s repeated and willful refusal to  compensate Plaintiffs and all similarly situated current and former security guards, Plaintiffs and  all similarly situated current and former security guards have sustained damages and are  entitled to the following relief:  a.  unpaid compensation;  b.  liquidated damages;  c.  civil penalties in the amount of $1,100 per violation; and   d.   costs and attorney fees.  WHEREFORE, Plaintiffs respectfully request judgment in their favor and against  Defendant in an amount in excess of $100,000.00, plus exemplary damages, together with  costs, interest, attorney fees and punitive damages as allowed by statute and any other relief  this Honorable Court deems appropriate.  46.  Plaintiffs incorporate by reference paragraphs 1 through 45 of the Complaint as  though fully set forth herein.   47.   Since 1999 Defendant, required Plaintiffs and all similarly situated current and  former security guards to arrive at Defendant’s premises fifteen (15) minutes prior to their shift  for roll call.  2:12-cv-11683-SJM-LJM   Doc # 1   Filed 04/16/12   Pg 5 of 8    Pg ID 5 6  48.  Since 1999 Defendant routinely disciplined security guards for failure to appear  at roll call, being late for roll call and/or any other alleged misconduct during roll call.   49.  The Michigan Wages and Fringe Benefits Act MCLA 408.471, et seq. requires  that Defendant pay to each of its employees in an amount at least at the current minimum wage,   50.  Defendant repeatedly and willfully refused to compensate Plaintiffs and all  similarly situated current and former security guards similarly situated in violation of Michigan  Wages and Fringe Benefits Act MCLA 408.471, et seq.   51.  As a direct and proximate cause of Defendant’s repeated and willful refusal to  compensate Plaintiffs and all similarly situated current and former security guards, Plaintiffs and  all similarly situated current and former security guards have sustained economic and non- economic damages.   WHEREFORE, Plaintiffs respectfully request judgment in their favor and against  Defendant in an amount in excess of $100,000.00, plus exemplary damages, together with  costs, interest, attorney fees and punitive damages as allowed by statute and any other relief  this Honorable Court deems appropriate.  52.  Plaintiffs incorporate by reference paragraphs 1 through 51 above as though  more fully set forth herein.   53.  Defendant repeatedly and willfully refused to compensate Plaintiffs, Angelia  Ruffin, Philip Tibbs, Constance Hudson, Pamela Girton-Hart, Cary Bryan, Alan Oden, Charles  Moses, Michaele Jackson, Sean Baldwin, Raphael Cosby, Eugene Hickman, Gregory Mosley,  Robin White and Falikau Fofana and all similarly situated current and former security guards in  accordance with the Fair Labor Standards Act and the Michigan Wages and Fringe Benefits Act  which creates a class so numerous that joinder of all numbers is impractical. (FRCP 23A1).  2:12-cv-11683-SJM-LJM   Doc # 1   Filed 04/16/12   Pg 6 of 8    Pg ID 6 7  54.  The question of whether the Defendant repeatedly and willfully refused to  compensate Plaintiffs, Angelia Ruffin, Philip Tibbs, Constance Hudson, Pamela Girton-Hart,  Cary Bryan, Alan Oden, Charles Moses, Michaele Jackson, Sean Baldwin, Raphael Cosby,  Eugene Hickman, Gregory Mosley, Robin White and Falikau Fofana and all similarly situated  current and former security guards involves questions of law or fact which are common to the  entire class.     55.  The claims or defenses of the representative class parties are typical of the  claims or defenses of the entire class.   56.  The prospective Plaintiffs class representatives, Angelia Ruffin, Philip Tibbs,  Constance Hudson, Pamela Girton-Hart, Cary Bryan, Alan Oden, Charles Moses, Michaele  Jackson, Sean Baldwin, Raphael Cosby, Eugene Hickman, Gregory Mosley, Robin White and  Falikau Fofana, will fairly and adequately protect the interest of the entire class.   57.  Prosecuting the multitude of separate actions by or against individual class  members would create a risk of inconsistent or variant adjudications with respect to individual class  members and would establish incompatible standards of conduct for the party opposing the class.   58.  The questions of law or fact common to class members predominate over any  questions effecting only individual members and that a class action is superior to other available  methods for fairly and efficiently adjudicating the controversy.  CLASS ACTION ALLEGATIONS   VIOLATIONS OF THE MICHIGAN WAGES AND FRINGE  BENEFITS  ACT, MCLA 408.471, et seq.    VIOLATIONS OF THE FAIR LABOR STANDARDS ACT, 29 U.S.C. § 201, et seq.  