(All Plaintiffs individually and on behalf of the FLSA collective v. All Defendants)   (All Plaintiffs individually and on behalf of the FLSA collective v. All Defendants)   (Plaintiff Muhammad on behalf of himself and similarly-situated officers v. All Defendants)   15. This is a collective action brought under the Fair Labor Standards Act by Plaintiffs on   behalf of themselves and all others similarly-situated for the recovery of compensation for time  spent engaging in washing-up activities after the end of their shifts within the Cook County  Department of Corrections (“CCDOC”), including washing and sanitizing their uniforms,  sanitizing their persons, sanitizing and maintaining personal protective equipment (“PPE”), and  showering.   16. Specifically, the activities for which minimum and overtime compensation are due to   Plaintiffs and similarly-situated officers are:  5  a. Sanitizing and washing their uniforms, gear, belts and equipment, boots and   shoes, and bags for necessary items, such as with Lysol, Clorox, or other chemicals and then  washing their uniforms after each shift;  b. Sanitizing their vehicles with Lysol, Clorox, or other chemicals either before or   after (or both) their shifts to avoid contamination within their vehicles present due to working in  51. Plaintiff Rashid Muhammad received an email on March 27, 2020 offering time-and-a-  half-pay for officers who volunteer to work at the MHTC while COVID-19 positive detainees  are housed there:  From: Rashid Muhammad (Sheriff) <Rashid.Muhammad@cookcoun tyi l.gov>  Sent: Friday, March 27, 2020 11:44:26 PM  To: Martha Yoksoulian (Sheriff) <Mart ha.Yoksoulian@ cookcount yil.gov>  Subject: Re: Mental Health Transiti on Center Assignments Available  Hello Supt. I am interested in volunteering for the 11-7 shift if and only if the time and a half is for pay. I'm not interested in putting myself in  potential harms way for time on the books.  Dep. R. Muhammad #17016  From: Martha Yoksoulian (Sheriff) <Mart ha.Yoksoulian@cookcountyi l.gov>  Sent: Friday, March 27, 2020 12:46 PM  To: Division 10 Supervisors <divison10supervi sors@ cookcounty.onmicrosoft.co m>; Division Ten Officers <divisi ontenofficers@cook county .onmicrosoft.  com>  Subject: Mental Health Transiti on  Center Assignments Available Hello all,  As some of you may have heard on the news, the sheriff is opening some of the barrack's at the Mental Health Transition Center for the inmates  that have tested  positive for the COVID-19 virus.  We are asking if anyone wants to volunteer working at MHTC for a while until we pass this crisis. It will be all three shifts 11-7, 7-3 and 3-11. 11-7 will  be placed in details 1 and 7. 7-3 will be placed in details 2 and 7 as well as 3-11 details 2 and 7. You will receive time and a half pay however, it has  not been decided if it will be in time or pay. As always you will have protective gear to protect to work with and you will be stationed a minimum of ten  feet away from the inmates. We need both officers and supervisors. We are looking from 3-5 officers per division. If you are intere sted , please reply  to this email.  Thank you,  Superintende nt Martha  Yoksoulian  Cook County  Sheriff's  Office Division  10  2700 S California Avenue  Chicago, II 60608  12  Office (773) 674-4429 Mobile (312) 758-5029  Email: Martha .Yoksoulian@cookcountyil.gov  The contents of this e-mail message and any attachments are intended solely for the addressee(s) named in this message. This communication is intended to be and to remain confidential and may be subject  to applicable work product privileges. If you are not the intended recipient of this message or if this message has been addressed to you in error, please alert the sender immediately by reply e-mail and then  delete this message and its attachments. Do not deliver, distribute or copy this message and/or any attachments and if you are not the intended recipient, do not disclose the contents or take any action in reliance upon the  information contained in this communication or any attachments. Thank you   52. As noted above, Muhammad replied to the email that he would volunteer for the MHTC   if he received pay.   53. The CCSO accepted Muhammad’s offer and transferred him to MHTC starting March   30, 2020, in the following memorandum:  57. Plaintiffs restate and incorporate by reference all other paragraphs of this Complaint in   this Count.   58. The FLSA, 29 U.S.C. § 206, requires that an employer compensate an employee a   minimum hourly rate for all hours suffered or permitted to work.   59. Defendants suffered or permitted Plaintiffs and similarly-situated officers to work at the   beginning of, and after, their shifts, in sanitizing activities, including by washing and sanitizing  their uniforms, sanitizing their persons, sanitizing and maintaining PPE, and showering.   60. Each Plaintiff, and all similarly-situated officers, are due to be paid wages for   approximately 20 - 30 minutes of sanitation activities at the beginning of, and the end of, each  shift worked between March 9, 2020 and through the cessation of the COVID-19 protocols at  62. Plaintiffs restate and incorporate by reference all other paragraphs of this Complaint in   this Count.   63. The FLSA, 29 U.S.C. § 207, requires that an employer compensate an employee one-and-  one-half-times the regular rate of pay for all hours worked over forty (40) hours in a given  workweek.   64. Defendants suffered or permitted Plaintiffs and similarly-situated officers to work at the   beginning of, and after, their shifts, in sanitizing activities, including by washing and sanitizing  their uniforms, sanitizing their persons, sanitizing and maintaining PPE, and showering without  paying them for such activities that were performed at an overtime rate of pay where the  Plaintiffs had performed over forty (40) hours of work in the workweek.   65. Each Plaintiff, and all similarly-situated officers, are due to be paid wages for   approximately 30 minutes of sanitation activities at the beginning of, and the end of, each shift  worked between March 9, 2020 and through the cessation of the COVID-19 protocols at  67. Plaintiff Muhammad restates and incorporates by reference all other paragraphs of this   Complaint in this Count.   68. Plaintiff Muhammad and similarly-situated officers entered into an agreement with   Defendant Sheriff to voluntarily work at the MHTC for time-and-a-half pay (in Muhammand’s  case), or time-and-a-half pay or comp time (in others’).   69. Via email on March 27, 2020, Plaintiff Muhammad notified the Sheriff, through his   Superintendent, that he would work at the MHTC if he received pay for doing so.   70. On March 30, 2020, Defendant Sheriff transferred Plaintiff Muhammad to MHTC, where   he then worked, including by providing safety and security, and welfare, functions for COVID- 19 positive detainees at great risk of exposure to himself.   71. As of payday on April 17, 2020, Defendant Sheriff failed to pay Plaintiff Muhammad, or   any similarly-situated officer assigned to MHTC, the time-and-a-half pay owed under the  transfer agreement.   72. Plaintiff Muhammad and similarly-situated officers are entitled to recover all amounts   owed under the transfer agreement for time spent assigned at MHTC, two percent of the amount  of such underpayments for each month they remain unpaid, costs, and reasonable attorneys’ fees.  WHEREFORE, for the foregoing reasons, Plaintiff Muhammad requests that this  Honorable Court enter judgment in his favor, and against Defendants, and order that Defendants  pay him and all similarly-situated officers for all underpaid overtime wages between March 30,  16  2020 and the date of cessation of his assignment at MHTC, two percent of the amount of such  underpayments for each month they remain unpaid, costs and reasonable attorneys’ fees, the  certification of a class for purposes of this IWPCA claim, and for such other relief as this Court  deems just and proper.  I.  FACTS RELATING TO ALL PLAINTIFFS AND SIMILARLY-SITUATED  OFFICERS.   PERSONNEL MEMORANDUM  DISTRIBUTION  A 