10.  During much of Plaintiff’s employment, he was required to travel out of state to  perform his work.    11.  As part of Plaintiff’s work assignments, Defendants required he and a work crew  consisting of approximately six to eight individuals to report to their shop between 5:00 a.m. –  7:00 a.m. each Monday morning to acquire the necessary tools and equipment, and load the work  truck(s), to perform that particular week’s assignments.     12.  After the Plaintiff and the work crew finished loading the tools and equipment, they  would depart from Defendants’ shop in Anderson, South Carolina, i.e., (“The Shop”) and travel to  that week’s work destination in the work truck(s) and begin performing their work.    13.  Typically on Fridays, after they completed that week’s assignments, Plaintiff and  the work crew would load the tools and equipment back on the work truck(s) and depart back to  The Shop.  Upon arriving at The Shop, Plaintiff and the work crew were required to unload the  tools and equipment from the work truck(s).     14.  Defendants failed to pay Plaintiff and the work crew any monies for the travel time  going back to The Shop, and the time it took to unload the work truck(s).   15.  Plaintiff and the work crew were always required to report back to The Shop after  working at the job site in order to return Defendants’ truck(s) and equipment before retrieving their  own personal vehicles to drive home.    17.  Nor could Plaintiff be classified as an independent contractor; and therefore, is  subject to the Fair Labor Standards Act’s (“FLSA”) minimum wage and overtime requirements.    18.  Plaintiff worked for Defendants on a full time and continuing basis; Plaintiff did  not sell or advertise his services to the general public or work as a contractor for anyone other than  the above named Defendants.   19.  Plaintiff had no control over the manner and method by which they were paid.   20.  Defendants retained the right to discharge Plaintiff without cause.   21.  Plaintiff had no opportunity for profit and no risk of loss.     22.  Plaintiff is clearly not exempt from the FLSA’s minimum wage and overtime  requirements.   40.  At all relevant times, Defendants have had gross revenues in excess of $500,000.00.   41.  At all relevant times, Defendants have been, and continue to be, an employer  engaged in interstate commerce within the meaning of the FLSA, 29 U.S.C. §§ 206(a) and 207(a).    42.  At all relevant times, Defendants have employed, and/or continue to employ each  of the Collective Class members within the meaning of FLSA.   43.  At all relevant times in the period encompassed by this Complaint, Defendants had  and maintained a willful policy and practice of refusing to pay minimum wage for all hours  worked.  By failing to pay for every hour worked, it is inevitable that during certain weeks of  employment Plaintiff would have been denied overtime payments or shorted such payments when  he worked in excess of forty (40) hours per workweek.   44.  Defendants have violated, and continues to violate, the FLSA, 29 U.S.C. §§ 201 et  seq. The foregoing conduct, as alleged, constitutes a willful violation of the FLSA within the  meaning of 29 U.S.C. § 255(a).   45.  Due to Defendants’ FLSA violations, Plaintiff, on behalf of himself and the  members of the Collective Class, is entitled to recover from the Defendants compensation for  unpaid wages, an additional equal amount as liquidated damages, and reasonable attorneys’ fees  and costs of this action pursuant to 29 U.S.C. § 216(b).  46.  Plaintiff, on behalf of himself and the members of the SC Class, re-alleges and  incorporates by reference the paragraphs above as if they were set forth again herein.   48.  Plaintiff and the SC Class worked for Defendants with the clear understanding and  agreement by Defendants that their compensation would be consistent with all applicable laws,  including federal and state wage and hour laws.   49.  Pursuant to the PWA, “[a]n employer shall not withhold or divert any portion of  the employee’s wages unless the employer is required or permitted to do so by state or federal law.  . . .” S.C. Code Ann. § 41-10-40(C).    50.  Further, “any changes [to] the terms [of wages] must be made in writing at least  seven calendar days before they become effective.” S.C. Code Ann. § 41-10-30(A).     51.  Accordingly, Plaintiff and the members of the SC Class are entitled to receive all  compensation of “wages” due and owing to them.   52.  As a result of Defendants’ unlawful policies and practices as set forth above  Plaintiff and the members of the SC Class have been deprived of “wage” compensation due and  owing which Defendants promised to pay in their commitment to abide by applicable wage and  hour laws and in violation of the PWA’s mandate that no wages be withheld or diverted unless  required or permitted under applicable law.    53.  Defendants have set and withheld wages of the Plaintiff and SC Class members  without providing advance notice of such amounts and absent any lawfully sufficient reason for  such conduct.    FAIR LABOR STANDARDS ACT OVERTIME WAGE VIOLATIONS  (Collective Class)   SOUTH CAROLINA PAYMENT OF WAGES ACT  (SC Class)  