21.  This Complaint may be brought and maintained as an “opt-in”  collective action  pursuant to Section 16 of the FLSA, 29 U.S.C. § 216(b); in that the claims of Plaintiffs are  similar to the claims of the Putative Plaintiffs/Class Members.   23.  At all relevant times, Defendant has had a policy and practice of failing and  refusing to compensate class members properly for all hours worked and overtime  compensation for all hours worked in excess of forty hours per week.   24.  The Plaintiffs and all Putative Plaintiffs/Class Members were subject to  Defendant’s policies and practices of failing and refusing to properly compensate  employees their regular or statutorily required rate of pay for all hours worked.   25.  Each Putative Plaintiff /Class Member has been damaged and is entitled to  recovery by reason of Defendant’s illegal policies and/or practices of permitting, suffering  and/or failing to compensate employees for their regular or statutorily required proper rate  of pay for all hours worked.   26.  Collective action treatment will allow those similarly situated persons to litigate  their claims in the manner that is most efficient and economical for the parties and the  judicial system.   27.  Plaintiffs, on behalf of themselves and all others similarly situated, set forth  additional collective action allegations in the various counts set forth herein.  29.  Plaintiff was employed by the Defendant. During this time frame, Plaintiff  performed work for Defendant in the position of Single Job Static EMT and/or Paramedic.   30.  Prior to and during Plaintiff’s employment with Defendant, Defendant employed  numerous other individuals who had the same job duties and compensation structure as  Plaintiff (the collective class).   31.  Plaintiff brings this Complaint as a collective action pursuant to Section 16(b) of  the FLSA, 29 U.S.C. §  216(b), on behalf of all persons who were, are, or will be  employed by the Defendant as Single Job Static EMTs/Paramedics within three years  from the commencement of this action who have not been properly paid straight time for  all hours worked and overtime compensation, at one-and-one-half times the regular rate of  pay, for all work performed in excess of forty hours per week.   32.  This Complaint may be brought and maintained as an “opt-in”  collective action  pursuant to Section 16 of the FLSA, 29 U.S.C. §  216(b), for all claims asserted by the   collective class because the claims of Plaintiff are similar to the claims of the Putative  Plaintiffs of the representative action.   33.  Plaintiff and the  collective class are similarly situated, have substantially similar  job requirements and pay provisions, and are subject to Defendant’s common practice,  policy, or plan of refusing to properly pay straight time and overtime in violation of the  47.  As far as the factual allegations set forth above are applicable to the claims made  in Count II, Plaintiff Dietrick hereby incorporates all of the above paragraphs in this  Complaint as if fully set forth in this Count.   48.  Plaintiff Dietrick was employed by the Defendant. During this time frame,  Plaintiff performed work for Defendant in the positions of dual Job EMT and/or  Paramedic (“Fire Medic”).   49.  Prior to and during Plaintiff’s employment with Defendant, Defendant employed  numerous other individuals who had the same job duties and compensation structure as  Plaintiff (the collective class).   50.  Plaintiff brings this Complaint as a collective action pursuant to Section 16(b) of  the FLSA, 29 U.S.C. §  216(b), on behalf of all persons who were, are, or will be  employed by the Defendant as Fire Medics within three years from the commencement of  this action who have not been paid straight time for all hours worked and overtime  compensation, at one-and-one-half times the regular rate of pay, for all work performed in  excess of forty hours per week.   51.  This Complaint may be brought and maintained as an “opt-in”  collective action  pursuant to Section 16 of the FLSA, 29 U.S.C. §  216(b), for all claims asserted by the  collective class because the claims of Plaintiff are similar to the claims of the collective  class.   53.  The names and addresses of the putative members of the representative action are  available from Defendant. To the extent required by law, notice will be provided to said  individuals via email, First Class Mail, posting at the workplace and/or by the use of  techniques and a form of notice similar to those customarily used in representative  actions.   54.  At all relevant times, Defendant has been, and continues to be, an “employer”  within the meaning of the FLSA, 29 U.S.C. § 203.   55.  At all relevant times, Defendant has employed, and/or continues to employ,  “employee[s],” including each of the putative members of the FLSA representative action.   56.  At all times relevant herein, Defendant has had gross operating revenues in excess  of $500,000.00 (Five Hundred Thousand Dollars).   57.  The FLSA requires each covered employer, such as the Defendant, to compensate  all non-exempt employees straight time for all hours worked and overtime compensation,  at a rate of not less than one-and-one-half the regular rate of pay, for work performed in  excess of forty hours in a work week.   58.  Plaintiff and the putative members of the FLSA representative action are not  exempt from the right to receive overtime pay under the FLSA and are not exempt from  the requirement that their employer pay them overtime compensation under the FLSA.    60.  Further, Defendant cannot invoke the §  207(k) exemption for time spent in the  Fair Labor Standards Act – Scheme to Avoid Paying Overtime  (Plaintiff Zimmerli and the Single Job Static EMTs/Paramedics)  