19.  Defendants operate an American gourmet grocery store located in Morris County in  New Jersey.   21. Defendants are associated and joint employers, act in the interest of each other with respect to employees, pay employees by the same method, and share control over the employees.   22. Each Defendant possessed substantial control over Plaintiff Naula’s (and other similarly situated employees’) working conditions, and over the policies and practices with respect  to the employment and compensation of Plaintiff Naula, and all similarly situated individuals,  referred to herein.   23. Defendants jointly employed Plaintiff Naula (and all similarly situated employees) and are Plaintiff Naula’s (and all similarly situated employees’) employers within the meaning of 29  U.S.C. 201 et seq.   24. In the alternative, Defendants constitute a single employer of Plaintiff Naula and/or similarly situated individuals.   25. During 2020 Defendants had a gross annual volume of sales of not less than $500,000 (exclusive of excise taxes at the retail level that are separately stated).   26. In addition, upon information and belief, Defendants and/or their enterprise were directly engaged in interstate commerce. As an example, numerous items that were used in the  gourmet grocery store on a daily basis are goods produced outside of the State of New Jersey.  Individual Plaintiff   27. Plaintiff Naula is a former employee of Defendants who was employed as a line cook and a pizza maker.   29. Plaintiff Naula was employed by Defendants from approximately February 9, 2020 until on or about March 31, 2020.   30. Defendants employed Plaintiff Naula as a line cook and a pizza maker.  31. Plaintiff Naula regularly handled goods in interstate commerce, such as produce and other supplies produced outside the State of New Jersey.   32. Plaintiff Naula’s work duties required neither discretion nor independent judgment.  33. Throughout his employment with Defendants, Plaintiff Naula regularly worked in excess of 40 hours per week.   34. From approximately February 9, 2020 until on or about March 31, 2020, Plaintiff Naula worked from approximately 9:00 a.m. until on or about 10:00 p.m., Mondays through  Thursdays and from approximately 9:00 a.m. until on or about 10:30 p.m. to 11:00 p.m., Fridays  through Sundays (typically 92 to 93 hours per week).   35. From approximately February 9, 2020 until on or about March 31, 2020, Defendants did not pay Plaintiff Naula for any of his hours worked.   36. For approximately seven weeks, Defendants did not pay Plaintiff Naula any wages for his hours worked.   37. Defendants never granted Plaintiff Naula any breaks or meal periods of any kind.  38. Plaintiff Naula was not required to keep track of his time, nor to his knowledge, did the Defendants utilize any time tracking device such as punch cards, that accurately reflected his  actual hours worked.  Defendants’ General Employment Practices   40. Plaintiff Naula was a victim of Defendants’ common policy and practices which violate his rights under the FLSA and New Jersey Labor Law by, inter alia, not paying him the  wages he was owed for the hours he worked.   41. Defendants’ pay practices resulted in Plaintiff Naula not receiving payment for any of his hours worked, and resulted in Plaintiff Naula’s effective rate of pay falling below the required  minimum wage rate.   42. Defendants habitually required Plaintiff Naula to work additional hours beyond his regular shifts but did not provide him with any additional compensation.   43. Defendants willfully disregarded and purposefully evaded recordkeeping requirements of the FLSA by failing to maintain accurate and complete timesheets and payroll  records.    44. Upon information and belief, these practices by Defendants were done willfully to disguise the actual number of hours Plaintiff Naula (and similarly situated individuals) worked, and  to avoid paying Plaintiff Naula properly for his full hours worked.    45. Defendants engaged in their unlawful conduct pursuant to a corporate policy of minimizing labor costs and denying employees compensation by knowingly violating the FLSA.   46. Defendants’ unlawful conduct was intentional, willful, in bad faith, and caused significant damages to Plaintiff Naula and other similarly situated former workers.  50. Plaintiff Naula repeats and realleges all paragraphs above as though fully set forth herein.   51. At all times relevant to this action, Defendants were Plaintiff Naula’s employers within the meaning of the Fair Labor Standards Act, 29 U.S.C. § 203(d).  Defendants had the power  to hire and fire Plaintiff Naula (and the FLSA Class Members), controlled the terms and conditions  of their employment, and determined the rate and method of any compensation in exchange for their  employment.   52. At all times relevant to this action, Defendants were engaged in commerce or in an industry or activity affecting commerce.   54. Defendants failed to pay Plaintiff Naula (and the FLSA Class members) at the applicable minimum hourly rate, in violation of 29 U.S.C. § 206(a).   55. Defendants’ failure to pay Plaintiff Naula (and the FLSA Class members) at the applicable minimum hourly rate was willful within the meaning of 29 U.S.C. § 255(a).   56. Plaintiff Naula (and the FLSA Class members) were damaged in an amount to be determined at trial.  57. Plaintiff Naula repeats and realleges all paragraphs above as though fully set forth herein.   58. Defendants, in violation of 29 U.S.C. § 207(a)(1), failed to pay Plaintiff Naula (and the FLSA Class members) overtime compensation at a rate of one and one-half times the regular  rate of pay for each hour worked in excess of forty hours in a work week.   59. Defendants’ failure to pay Plaintiff Naula (and the FLSA Class members), overtime compensation was willful within the meaning of 29 U.S.C. § 255(a).   60. Plaintiff Naula (and the FLSA Class members) were damaged in an amount to be determined at trial.  Defendants Constitute Joint Employers   VIOLATION OF THE MINIMUM WAGE PROVISIONS OF THE FLSA   VIOLATION OF THE OVERTIME PROVISIONS OF THE FLSA  