11.  At all times material to this action, defendants were an enterprise engaged in  commerce or in the production of goods for commerce as defined by Section 203(s)(1) of the  FLSA, and had annual gross volume of sales which exceeded $500,000.   12.  Plaintiff has been employed by defendants within the last three years before the  filing of this lawsuit.   13.  Plaintiff is employed by defendants at the MSM facility located at 1055  Ridgecrest Dr., Goodlettsville, TN 37072.   14.  At all times material, Plaintiff has been employed as a customer care specialist  and treated as an exempt employee.   15.  Plaintiff’s primary duties included answering calls from customers and receiving  relevant information which was passed on to the proper department for processing.   16.  At all times material, Plaintiff did not supervise any other employees.   17.  At all times material, Plaintiff’s primary duty did not include the exercise of  discretion and independent judgment.   18.  While Plaintiff has been employed by MSM, MSM is an “employer” of Plaintiff  as defined by Section 203(d) of the FLSA.   19.  While Plaintiff has been employed by MSM, Plaintiff is an “employee” of MSM  as defined by Section 203(e)(1) of the FLSA, and has worked for MSM within the territory of the  United States within three years preceding the filing of this lawsuit.   20.  While Plaintiff has been employed by MSM, Plaintiff is engaged in commerce or  in the production of goods for commerce as defined in Section 203(r) and 203 (s).   21.  The overtime provisions of the FLSA set forth in Section 207 applies to MSM.   22.  While Plaintiff has been employed by EEC, EEC is an “employer” of Plaintiff as  defined by Section 203(d) of the FLSA.   23.  While Plaintiff has been employed by EEC, Plaintiff is an “employee” of EEC as  defined by Section 203(e)(1) of the FLSA, and has worked for EEC within the territory of the  United States within three years preceding the filing of this lawsuit.   24.  While Plaintiff has been employed by EEC, Plaintiff is engaged in commerce or  in the production of goods for commerce as defined in Section 203(r) and 203 (s).   25.  The overtime provisions of the FLSA set forth in Section 207 applies to EEC.   26.  While Plaintiff has been employed by REMCO, REMCO is an “employer” of  Plaintiff as defined by Section 203(d) of the FLSA.   27.  While Plaintiff has been employed by REMCO, Plaintiff is an “employee” of  REMCO as defined by Section 203(e)(1) of the FLSA, and has worked for REMCO within the  territory of the United States within three years preceding the filing of this lawsuit.   28.  While Plaintiff has been employed by REMCO, Plaintiff is engaged in commerce  or in the production of goods for commerce as defined in Section 203(r) and 203 (s).   29.  The overtime provisions of the FLSA set forth in Section 207 applies to REMCO.   30.  Plaintiff regularly works five days per week.   31.  Plaintiff regularly begins working at 6:45 am and continues working until after 5  pm without an uninterrupted lunch break.   32.  During some workweeks, Plaintiff was required to answer phone calls after work  and on weekends.   33.  At all times material, Defendants regularly fail to pay Plaintiff the overtime rate  of one and on-half times her regular rate for all hours worked over 40 in some workweeks.   34.  At all times material, William Emory was and is the manager of EEC.    35.  At all times material, William Emory made and makes decisions with respect to  day-to-day operations, hiring, firing work schedules, pay policies, and compensation. Mr. Emory  was and is an employer of Plaintiff at all relevant times.   36.  At all times material, Gary Garrett has supervisory control over Plaintiff and has  knowledge of the duties performed by Plaintiff, the hours worked by Plaintiff, and knowledge  that Plaintiff was not paid the overtime premium for all hours worked over 40 in some  workweeks. Mr. Garrett was and is an employer of Plaintiff at all relevant times.  Count I  Violation of the Fair Labor Standards Act  Overtime Wage Violation   37.  As a result of Defendants’ failure to comply with Section 207 of the FLSA,  Defendants are jointly and severally liable to Plaintiff for overtime back pay.   38.  In addition to the amount of unpaid overtime wages owed to Plaintiff, Plaintiff is  also entitled to recover an equal amount of liquidated damages pursuant to 29 U.S.C.  Section 216(b).   39.  Plaintiff is entitled to an award of attorney’s fees pursuant to 29 U.S.C. § 216(b).  Collective Action Allegations   40.  Plaintiff is aware of other similarly situated individuals who have worked for the  Defendants within the last three years and who have been improperly compensated in violation  of the FLSA and who would benefit from the issuance of court-supervised notice of the present  lawsuit and the opportunity to join the lawsuit by filing a consent with the Court pursuant to  Section 216(b) of the FLSA. Specifically, Plaintiff is aware of other current and former  employees of Defendants Specifically, Plaintiff is aware of other current and former hourly  employees of Defendants whose primary duties were non-exempt and who were not paid one and  one-half times their regular hourly rate for all hours worked over 40 in a workweek.    41.  Pursuant to Section 216(b), attached hereto and filed with this Complaint as  Exhibit A is a Consent to Become Party Plaintiff.  WHEREFORE, Plaintiff, pursuant to Section 216(b) of the FLSA, prays for the following  relief:  a.  Designation of this cause as a collective action on behalf of the class and prompt  issuance of notice pursuant to 29 U.S.C. § 216(b), apprising putative members of the pendency  of this action, permitting other members of the class to assert timely FLSA claims in this action  by filing individual Consents 29 U.S.C. § 216(b);  b.  An award of compensation for unpaid overtime compensation owed to Plaintiff  and other members of the class at the applicable FLSA overtime rate of pay;  c.  An award of liquidated damages to Plaintiff and other members of the class  pursuant to 29 U.S.C. § 216(b);  d.  An award of pre-judgment and post-judgment interest at the applicable legal rate  to Plaintiff and other members of the class pursuant to 29 U.S.C. § 216(b);  e.  A ruling that the three-year statutory period for willful violations under the FLSA  shall apply;  f.  An award of reasonable attorney’s fees;  g.  An award of the costs and expenses of this action; and  h.  Such other, further general legal and equitable relief to which Plaintiff may be  entitled. 