33.  Beginning on or about November 2016 through on or about February 2019,  Defendants employed Plaintiff as a non-exempt, hourly-paid employee.   34.  Plaintiff’s duties included bartending, taking food orders, and preparing drinks for  customers.   35.  Plaintiff, for some or all of the relevant time period, was not paid an hourly wage  based on the minimum wage for the work performed.   36.  Plaintiff and those similarly situated to him were/are entitled to at least the  Federal minimum wage pursuant to §206(a) of the FLSA.   37.  Plaintiff and those similarly situated to him were/are entitled to the Florida  minimum wage pursuant to §29 C.F.R §778.5.   38.  Plaintiff worked for Defendants in excess of forty (40) hours within one or more  workweeks.   39.  In one or more work weeks during their employment, Defendants failed to  compensate Plaintiff, at rate of one and one-half times their regular rate for all hours worked in  excess of forty (40) hours in a single work week.   43.  As part of the regular business practices, Defendants have intentionally, willfully  and repeatedly harmed Plaintiff and Class Members by engaging in a pattern, practice, or policy  of violating the FLSA on a class wide basis, as described above.    44.  Although Defendants permitted and/or required Class Members to work in excess  of forty (40) hours per workweek, Defendants denied them full compensation for their hours  worked over forty.  Defendants have also denied them full compensation at the federally  mandated minimum wage rate.    45.   Class Members perform or have performed the same or similar work as Plaintiffs.  In particular, Plaintiffs and Class Members all worked as employees under the same conditions  and subject to the same violations of the FLSA.   46.  Many Class Members regularly work or have worked in excess of forty (40) hours  during a workweek.   47.  Class Members are not exempt from receiving overtime pay and/or minimum  wage at the federally mandated minimum wage rate under the FLSA.   48.   As such, Class Members are similar to Plaintiffs in terms of job duties, pay  structure, and/or the denial of overtime and minimum wage.   49.   Defendants’ failure to pay overtime compensation and hours worked at the  minimum wage rate required by the FLSA results from generally applicable policies or practices,  and does not depend on the personal circumstances of the Class Members.   51.  The experience of Plaintiffs, with respect to their job duties, is typical of the  experiences of Class Members.   52.   The specific job titles or precise job responsibilities of each Class Member does  not prevent collective treatment.   53.  All Class Members, irrespective of their particular job requirements, are entitled to  overtime compensation for hours worked in excess of forty during a workweek.   54.  All Class Members, irrespective of their particular job requirements, are entitled to  compensation for hours worked at the federally mandated minimum wage rate.    55.  Although the exact amount of damages may vary among Class Members, the  damages for Class Members can be easily calculated by a formula.  The claims of all Class  Members arise from a common nucleus of facts.  Liability is based on a systematic course of  wrongful conduct by Defendants that caused harm to all Class Members.    56.  The Plaintiff and the Class Members held the same job title: restaurant employees.   57.  As such, the class of similarly situated Plaintiff is properly defined as follows:   The FLSA Collective Members are all of Defendants’ current and former  restaurant employees who worked at PMB and ASPIS at any time during the  three years before this Complaint was filed up to the present.   58.  Plaintiff reincorporates and readopts all allegations contained within  Paragraphs 1-57 above.   59.  Plaintiff, on behalf of himself and those similarly situated, was entitled to be  paid by Defendants the proper minimum wage for each hour worked per workweek.   61.  Plaintiff, on behalf of himself and those similarly situated, have not been paid  the applicable wage for each hour worked during their employment.   62.  As a direct and proximate result of Defendants’ deliberate nonpayment of  wages, Plaintiff, and those similarly situated, have been damaged in the loss of minimum  wages, plus incurring reasonable attorneys’ fees and costs.   63.  Defendants’ actions were willful and/or showed reckless disregard for the  provisions of the FLSA as evidenced by its failure to compensate Plaintiff minimum wage.   64.  Defendants’ conduct was not in good faith, and Plaintiff and those similarly  situated are therefore entitled to liquidated damages.   66.   Plaintiffs reincorporate and readopt all allegations contained within Paragraphs 1- 57 as if fully set forth herein.     67.  From at least January 2019 and continuing through approximately February 2019,  Plaintiff, and those similarly situated, worked in excess of the forty (40) hours per week for  which Plaintiff was not compensated at the statutory rate of one and one-half times Plaintiff’s  regular rate of pay.   69.  At all times material hereto, Defendants failed and continue to fail, to maintain  proper time records as mandated by the FLSA.     70.  Defendants’ actions in this regard were willful and/or showed reckless disregard  for the provisions of the FLSA as evidenced by its continued failure to compensate Plaintiff at the  statutory rate of one and one-half times Plaintiff’s regular rate of pay for the hours worked in  excess of forty (40) hours per weeks when they knew, or should have known, such was, and is  due.    71.  Defendants have failed to properly disclose or apprise Plaintiff of Plaintiff’s rights  under the FLSA.     72.  Due to the intentional, willful, and unlawful acts of the Defendants, Plaintiff  suffered and continued to suffer damages and lost compensation for time worked over forty (40)  hours per week, plus liquidated damages.     FAILURE TO PAY OVERTIME COMPENSATION IN   VIOLATION OF 29 U.S.C. §207    RECOVERY OF MINIMUM WAGE COMPENSATION  