18.  Pursuant to 29 U.S.C. §§ 206, 207 & 2 l 6(b), plaintiff brings her first and  second causes of action as a collective action under the FLSA on behalf of herself and the  following collective:  All persons employed by defendants at any time since June 1, 2015 and  through the entry of judgment in this case (the “collective action  period”) who worked as non-management employees for LDM and/or  CSM in New York City (the “collective action members”).   19.  A collective action is appropriate in this circumstance because plaintiff and  the collective action members are similarly situated, in that they were all subjected to  defendants’ illegal policies of failing to pay minimum wage for all hours worked and failing  to pay overtime premiums for work performed in excess of forty (40) hours each week. As a  result of these policies, plaintiff and the collective action members did not receive the  legally required minimum wage or overtime premium payments.   20.  Plaintiff and the collective action members have or had substantially similar  job duties and were paid pursuant to a similar, if not the same, payment structure.  22.  The class members are readily ascertainable. The number and identity of the  class members are determinable from the records of defendants. For purposes of notice and  other purposes related to this action, their names and addresses are readily available from  defendants. Notice can be provided by means permissible under Fed. R. Civ. P. 23.   23.  Class members are so numerous that joinder of all members is impracticable.   24.  Upon information and belief, there are an excess of forty (40) class members.   26.  Plaintiff’s claims are typical of the class members’ claims. Plaintiff, like all  class members, was a non-managerial and non-exempt employee of defendants who worked  for defendants pursuant to their corporate policies and pay practices. Plaintiff, like all class  members, was, inter alia, paid less than the statutory minimum wage for all hours worked,  was not paid overtime premium pay for hours worked over forty (40) hours in a given  workweek, did not receive proper wage notices. If defendants are liable to plaintiff for the  claims enumerated in this complaint, they are also liable to all class members.   27.  Plaintiff and her counsel will fairly and adequately represent the class. There  are no conflicts between plaintiff and the class members, and plaintiff brings this lawsuit out  of a desire to help all class members, not merely out of a desire to recover her own damages.   28.  Plaintiff’s counsels are experienced class action litigators who are well  prepared to represent the interests of the class members.   30.  Defendants are sophisticated parties with substantial resources. The  individual plaintiffs lack the financial resources to vigorously prosecute a lawsuit in federal  court against corporate defendants.   31.  The individual members of the Class have no interest or capacity to bring  separate actions; plaintiff is unaware of any other current litigation concerning this  controversy; it is desirable to concentrate the litigation in one case; and there are no likely  difficulties that will arise in managing the class action.  32.  On or about May 1, 2015 plaintiff was hired by defendants to work as an  “intern” at defendants’ New York City offices.   33.  Plaintiff worked as an intern from May 1, 2015 to mid-July 2015. During  such period, plaintiff worked approximately 40 hours per week, but was not required to  record for her working hours. During this period, plaintiff was paid a fixed salary of $500.00  per month.   34.  From mid-July 2015 to January 2017 plaintiff worked for defendants in their  New York City offices as an Account Coordinator.   35.  Plaintiff’s work as an Account Coordinator did not involve any managerial,  professional, supervisory services or independent judgment and was “non-exempt” as  provided in the FLSA and NYLL.   37.  During such period, plaintiff was paid a fixed annual salary of $38,000 from  mid-July 2015 to January 2016, and a fixed annual salary of $41,000 from January 2016 to  January 2017.   38.  During the period from January 2016 to June 30, 2017 plaintiff worked for  defendants in its New York City offices as a Senior Account Coordinator.   39.  From from January 2016 to June 30, 2017 plaintiff worked for defendants in  their New York City offices as a Senior Account Coordinator   40.  During such period, plaintiff was paid a fixed annual salary of $46,000 from  January 2017 to June 30, 2017.   41.  During plaintiff’s entire employment with defendants, she was never  provided with a wage notice as required by the NYLL.   42.  During plaintiff’s entire employment with defendants she was never paid any  overtime compensation for the hours she worked in excess of forty (40) in any workweek.  43.  Plaintiff, on behalf of herself and the collective action members, repeats and  realleges each and every allegation of the preceding paragraphs hereof with the same force  and effect as though fully set forth herein.   44.  By failing to pay minimum wage for all hours worked, defendants have  violated and continue to violate the FLSA, 29 U.S.C. §§ 201 et seq., including 29 U.S.C. §§  206 and 215(a)(2).   46.  Defendants’ failure to pay minimum wages for all hours worked caused  plaintiff and the collective action members to suffer loss of wages and interest thereon.  Therefore, plaintiff and the collective action members are entitled to recover from  defendants their full unpaid minimum wages, damages for unreasonably delayed payment of  wages, liquidated damages, reasonable attorneys’ fees, and costs and disbursements of the  action pursuant to 29 U.S.C. § 216(b).  47.  Plaintiff, on behalf of herself and the collective action members, repeats and  realleges each and every allegation of the preceding paragraphs hereof with the same force  and effect as though fully set forth therein.   48.  By failing to pay overtime at a rate not less than one and one-half (1.5) times  the regular rate of pay for work performed in excess of 40 hours per week, defendants have  violated and continue to violate the FLSA, 29 U.S.C. §§ 201 et seq., including 29 U.S.C. §§  207(a)(1) and 215(a)(2).   49.  The foregoing conduct, as alleged, constitutes a willful violation of the FLSA  within the meaning of 29 U.S.C. § 255(a).   51.  Plaintiff, on behalf of herself and the class members, repeats and realleges  each and every allegation of the preceding paragraphs hereof with the same force and effect  as though fully set forth herein.   52.  Defendants willfully violated plaintiff s and class members’ rights by failing  to pay minimum wage for all hours worked, in violation of the NYLL and regulations  promulgated thereunder.   53.  Defendants’ failure to pay minimum wage for all hours worked caused  plaintiff and the class members to suffer loss of wages and interest thereon. Plaintiff and the  class members are entitled to recover from defendants their unpaid minimum wages,  damages for unreasonably delayed payment of wages, liquidated damages, reasonable  attorneys’ fees, and costs and disbursements of the action pursuant to NYLL §§ 663(1) et  seq.  54.  Plaintiff, on behalf of herself and the class members, repeats and realleges  each and every allegation of the preceding paragraphs hereof with the same force and effect  as though fully set forth herein.   56.  Defendants’ failure to pay overtime premium compensation caused plaintiff  and the class members to suffer loss of wages and interest thereon. Plaintiff and the class  members are entitled to recover from defendants their unpaid overtime compensation,  damages for unreasonably delayed payment of wages, liquidated damages, reasonable  attorneys’ fees, and costs and disbursements of the action pursuant to NYLL §§ 663(1) et  seq.  57.  Plaintiff, on behalf of herself and the class members, repeats and realleges  each and every allegation of the preceding paragraphs hereof with the same force and effect  as though fully set forth herein.   58.  Defendants have willfully failed to supply plaintiff and the class members’  notice as required by Article 6, § 195, in English or in the language identified by plaintiff as  her primary language, containing plaintiff s and the class members’ rate or rates of pay and  basis thereof, whether paid by the hour, shift, day, week, salary, piece, commission, or  other; hourly rate or rates of pay and overtime rate or rates of pay, if applicable; the regular  pay day designated by the employer in accordance with the NYLL, Article 6, § 191; the  name of the employer; or any “doing business as” names used by the employer; the physical  address of the employer’s main office or principal place of business, and a mailing address  if different; the telephone number of the employer; plus such other information as the  commissioner deems material and necessary.   FAIR LABOR STANDARDS ACT – UNPAID MINIMUM WAGE  (Brought on Behalf of plaintiff and the Collective Action Members)   FAIR LABOR STANDARDS ACT – UNPAID OVERTIME  (Brought on Behalf of plaintiff and the Collective Action Members)   NEW YORK LABOR LAW – UNPAID MINIMUM WAGE  (Brought on Behalf of plaintiff and the Collective Action Members)   NEW YORK LABOR LAW – FAILURE TO PROVIDE WAGE NOTICES  (Brought on Behalf of plaintiff and the Collective Action Members)   NEW YORK LABOR LAW – UNPAID OVERTIME  (Brought on Behalf of plaintiff and the Collective Action Members)  