234.  The foregoing paragraphs are incorporated herein as if set forth in their entirety.  235.  SFBL's practice of failing to pay the Plaintiffs and other Agents similarly situated at  a time-and-a-half rate of pay for hours in excess of 40 hours per workweek violates the FLSA.   See 29 U.S.C. § 207(a)(1).  236.  None of the exemptions provided by the FLSA regulating the duty of employers to  pay overtime at a rate of not less than one and one-half times the regular rate at which its  employees are employed are applicable to SFBL or Plaintiff and other similarly situated Agents.  237.  The Plaintiffs and others similarly situated were damaged in an amount to be  proved at trial as a result of SFBL's violations of 29 U.S.C. § 207.  246.  The foregoing paragraphs are incorporated herein as if set forth in their entirety.  247.  SFBL acted in bad faith when it failed to properly pay the Plaintiff and other  similarly situated Agents for their overtime work.  248.  SFBL knew or should have known that it was violating the FLSA when it failed to  properly pay the Plaintiffs and other similarly situated Agents for their overtime work.  249.  Accordingly, the Plaintiffs and the other putative class members are entitled to  recover double or liquidated damages from SFBL.  51.  The foregoing paragraphs are incorporated herein as if set forth in their  entirety.   52.  The Plaintiff brings this action pursuant to the FLSA, 29 U.S.C. § 216(b) (and  other applicable statutes, laws and common law) on their own behalf and on behalf of the  putative class described hereinabove.   53.  The Plaintiffs do not bring this action on behalf of any executive,  administrative or professional employee exempt from coverage under the FLSA.   54.  A collective action under the FLSA is appropriate because, under 29 U.S.C. §  216(b), the Agents described are "similarly situated" to the Plaintiffs.  The employees on  behalf of whom the Plaintiffs bring this collective action are similarly situated because  they have been or are employed in the same or similar positions; they were or are subject  to the same or similar wrongful and unlawful practices, policies and/or plans; and their  claims are based upon the same legal theories.   55.  The Plaintiffs estimate that the collective class, including both current and  former Agents over the relevant period, will include well over 400 members.  The precise  number of collective class members should be readily available from a review of the  Farm Bureau Defendants' records and from input received from the collective class  members as part of the notice and "opt-in" process provided by 29 U.S.C. § 216(b).   57.  Similarly, the classification status of the Plaintiffs and the putative class  members involve an identical legal question regarding whether the Farm Bureau  Defendants' Agents acted as employees, and not independent contractors, such that the  Defendants owed (and owe) them a minimum wage, overtime and record-keeping  obligations under the FLSA.   58.  The Plaintiffs and the putative class members share the same interest in that  the outcome of this action will determine whether they were (or are) either independent  contractors or employees under the FLSA.  Because the facts in each case are similar, if  not altogether identical, the factual assessment and legal standards lend themselves to a  collective action.  59.  The foregoing paragraphs are incorporated herein as if set forth in their  entirety.   60.  The Plaintiffs also bring this action, pursuant to Rule 23 of the Federal Rules  of Civil Procedure, on behalf of a putative class defined hereinabove.  The Plaintiffs  reserve the right to amend the putative class definition as necessary.   62.  Upon information and belief, the Farm Bureau Defendants knew that the  Plaintiffs and all similarly situated individuals performed work that required overtime  pay.   63.  The Farm Bureau Defendants have operated under a scheme to deprive the  misclassified Agents of overtime compensation by failing to properly compensate them  for all time worked.     64.  The Farm Bureau Defendants' conduct, as set forth in this Complaint, was  willful and has caused significant damage to the Plaintiffs and all similarly situated  individuals.     65.  The Plaintiffs share the same interests as the putative class members and will  be entitled to overtime compensation, liquidated damages, punitive damages, reasonable  attorney's fees, costs of prosecution of this action, and pre- and post-judgment interest  owed to them under nearly identical factual and legal standards as the remainder of the  putative class.   66.  The putative class meets the numerosity requirement of Rule 23(a)(1)  because, during the relevant time period, the Farm Bureau Defendants employed a  number of persons in all or nearly all counties in South Carolina who were all subjected  to working as Agents in excess of forty hours per work week, without being paid  overtime pay.  The precise number of class members should be readily available from a  review of the Farm Bureau Defendants' records and from input received from the putative  class members.   68.  The statuses of all individuals similarly situated to the Plaintiffs raise an  identical legal question:  whether the Farm Bureau Defendants' Agents acted as  independent contractors or employees to whom the Farm Bureau Defendants owed, owe  or would owe a minimum wage, overtime, and record-keeping obligations under the  76.  The foregoing paragraphs are incorporated herein as if set forth in their  entirety.   77.  The Plaintiffs and all similarly situated individuals have all been victimized  by the Farm Bureau Defendants' common policies and plans to violate their rights under  the FLSA by refusing or failing to keep proper records and denying them proper overtime  compensation.   79.  The Plaintiffs and the other putative class members were (and are), as a  matter of economic reality, reliant upon the Farm Bureau Defendants to earn a living.   They were neither self-reliant nor independent.   80.  The Plaintiffs and the other putative class members' work was (and is) an  integral part of the Farm Bureau Defendants' businesses.  Their services were integrated  into the Farm Bureau Defendants' business operations of soliciting, selling and servicing  insurance products, which is consistent with an employee classification and not an  independent contractor classification.     81.  The Plaintiffs and the other putative class members' investments into the  Farm Bureau Defendants' Agencies was (and is) miniscule compared to the Farm Bureau  Defendants' investments.  The Farm Bureau Defendants' investments in the infrastructure  designed to underwrite, administer and pay claims of insurance products sold by the  Plaintiffs and other putative class members far exceed any investment by them.     82.  The Plaintiffs and other putative class members had or have indefinite,  lengthy and ongoing working relationships with the Farm Bureau Defendants and  received (and/or continue to receive) promotions and advanced (and/or continue to  advance) along career paths as is typical for employees.     83.  The Farm Bureau Defendants' practice has been to hire, train, promote and  retain their Agents for numerous years.     85.  The Plaintiffs and other putative class members worked exclusively for the  Farm Bureau Defendants for years and even decades.     86.  Some putative class members were required to adjust claims in the manners  detailed in the Farm Bureau Defendants' guidelines, instructions, and Agents' Manuals.   87.  The Plaintiffs and the other putative class members solicited, sold and  serviced, personally and through Farm Bureau-appointed agents, insurance policies  exclusively from the Farm Bureau Defendants.  They were prohibited from soliciting,  selling and/or servicing insurance from other companies while working for the Farm  Bureau Defendants unless they obtained prior written consent and authorization to do so.     88.  Alternatively, the Farm Bureau Defendants limited and controlled the  policies, products, and services the Plaintiffs and the other putative class members could  solicit, sell and/or service, personally or through Farm Bureau-appointed agents.    90.  The Plaintiffs and the other putative class members were (and are) prohibited  from representing any insurance company, other than a Farm Bureau insurance company,  unless they first obtained the Farm Bureau Defendants' written consent to do so.   91.  The Farm Bureau Defendants prohibited the Plaintiffs and the other putative  class members from claiming any right to any of the books of business they wrote for the  Farm Bureau Defendants and expressly stated that the entire books of business written by  their Agents, together with all rights of renewal or expiration thereof, "shall be and  remain the sole and exclusive property of the [Farm Bureau] Companies."     92.  The Plaintiffs and the other putative class members were required to  surrender their entire books of business to the Farm Bureau Defendants upon their  termination or departure, whether voluntary or involuntary, from the Farm Bureau  Defendants.     93.  The Farm Bureau Defendants claimed ownership of and prohibited the  Plaintiffs and other putative class members from claiming ownership of or any right to  any information regarding persons to whom they sold or serviced insurance including "all  information, names, addresses and ages of policy holders and contract holders."     95.  The Farm Bureau Defendants required the Plaintiffs and others similarly  situated to pay commissions to their predecessors for prior work they rendered to Farm  Bureau.     96.  The Farm Bureau Defendants required Plaintiff and other putative class  members to authorize it to print their names and to utilize their electronic signatures on  various insurance documents.     97.  The Farm Bureau Defendants expressly limited the authority of the Plaintiffs  and other putative class members in a number of ways as detailed in its Agent’s Contracts  and in its advertising and social media policies.   