13.  Named Plaintiffs bring this action for violations of the FLSA as a collective  action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of all persons  presently and formerly employed by Defendants who were non-exempt employees, who were  subject to Defendants’ unlawful pay practices and policies discussed herein, and who worked for  Defendants at any point in the three years preceding the date the instant action was initiated (the  members of this putative class are referred to as “Collective Plaintiffs”).   15.  Named Plaintiffs and Collective Plaintiffs are similarly situated, have  substantially similar job duties, have substantially similar pay provisions, and are all subject to  Defendants’ unlawful policies and practices as discussed herein.   16.  There are numerous similarly situated current and former employees of  Defendants who were compensated improperly for overtime work in violation of the FLSA and  who would benefit from the issuance of a Court Supervised Notice of the instant lawsuit and the  opportunity to join in the present lawsuit.    17.  There are numerous similarly situated current and former employees of  Defendants who Defendants failed to pay an overtime premium for hours worked in excess of  forty (40) per workweek, all of whom would benefit from the issuance of a Court Supervised  Notice of the instant lawsuit and the opportunity to join in the present lawsuit.    18.  Similarly situated employees are known to Defendants, are readily identifiable by  Defendants, and can be located through Defendants’ records.    19.  Therefore, Named Plaintiffs should be permitted to bring this action as a  collective action for and on behalf of themselves and those employees similarly situated (i.e.,  “Collective Plaintiffs”), pursuant to the “opt-in” provisions of the FLSA, 29 U.S.C. § 216(b).  20.  The foregoing paragraphs are incorporated herein as if set forth in full.   21.  Named Plaintiffs were hourly employees of Defendant East Coast, who within the  last three years were employed by Defendant East Coast.     23.  Collective Plaintiffs were/are hourly employees of Defendant East Coast, who  within the last three years were employed by Defendant East Coast.     24.  Upon information and belief, each paycheck issued to Collective Plaintiffs  provides that they were hourly employees and were paid an hourly wage.   25.  Defendants did not designate Named Plaintiffs as exempt employees under  federal or state law.   26.  Defendants did not designate Collective Plaintiffs as exempt employees under  federal or state law.   27.  Upon information and belief, Defendants have maintained an unlawful wage  payment system for at least the last three years and have enforced such unlawful policies.  52.  At all times relevant herein, Defendants have and continue to be employers within  the meaning of the FLSA.   53.  At all times relevant herein, Defendants were responsible for paying wages to  Named Plaintiffs and Collective Plaintiffs.   54.  At all times relevant herein, Named Plaintiffs and Collective Plaintiffs were  employed with Defendants as “non-exempt employees” within the meaning of the FLSA.   55.  Under the FLSA, an employer must pay a non-exempt employee at least one and  one half times his or her regular rate for each hour worked in excess of forty (40) hours per  workweek.   56.  Defendants’ violations of the FLSA include, but are not limited to, not paying  Named Plaintiffs and Collective Plaintiffs proper overtime compensation for hours worked in  excess of forty (40) per workweek and issuing paychecks designed to hide Defendants’ unlawful  conduct.   57.  Defendants’ conduct in failing to pay Named Plaintiffs and Collective Plaintiffs  properly is willful and not based upon any reasonable interpretation of the law.   58.  As a result of Defendants’ unlawful conduct, Named Plaintiffs and Collective  Plaintiffs have suffered damages as set forth herein.  59.  The foregoing paragraphs are incorporated herein as if set forth in full.   61.  At all times relevant herein, Defendants were responsible for paying wages to  Named Plaintiffs.   62.  At all times relevant herein, Named Plaintiffs were employed with Defendants as  “non-exempt employees” within the meaning of the New Jersey Wage Laws.   63.  Under the New Jersey Wage Laws, an employer must pay a non-exempt  employee at least one and one half times his or his regular rate for each hour worked in excess of  forty (40) hours per workweek.   64.  Defendants’ violations of the New Jersey Wage Laws include, but are not limited  to, not paying Named Plaintiffs proper overtime compensation for time worked in excess of forty  (40) hours per workweek and issuing paychecks designed to hide Defendants’ unlawful conduct.   65.  Defendants’ conduct in failing to pay Named Plaintiffs properly was willful and  not based upon any reasonable interpretation of the law.   Fair Labor Standards Act (“FLSA”)  (Failure to pay Overtime Compensation)  (Named Plaintiffs and Collective Plaintiffs v. Defendants)   New Jersey Wage Laws  (Failure to pay Overtime Compensation)  (Named Plaintiffs v. Defendants)  