10.  As a matter of economic reality, Nationwide Eviction advertises, on the "About Us"  section of its website, that "owners select from a pool of experienced professionals for court  representation that are knowledgeable of the intricacies of local law and processes pertaining to  evictions, writs and collections."  Specifically, Nationwide Eviction is in the business of  providing a service to its customers—the very task that its “Agents” are hired to perform.   However, the experienced professionals that Nationwide Eviction claimed to have on staff were  not all attorneys or exempt employees.  The work performed by the non-exempt Agents is  integral to Defendant's business in that Nationwide Eviction simply could not function without  their contributions.   11.  Plaintiff and others similarly situated are entitled to overtime at one-and-one-half times  their regular rates of pay for all hours worked in excess of forty (40) in a workweek as required  by 29 U.S.C. § 207.   12.  Defendant did not pay Plaintiff and others similarly situated one-and-one-half times their  regular rates of pay for hours worked in excess of forty (40) per week.   14.  As a result, Plaintiff and others similarly situated did not receive compensation they were  legally entitled to receive.  The work performed by Plaintiff and others similarly situated was  with Defendant's knowledge.  Defendant approved the Agent’s schedules, assigned work and  supervised the work.   15.  Defendant's violations of the FLSA were committed knowingly, willfully, and/or with  reckless disregard to Plaintiff and similarly situated employees' rights.  V.  16.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   17.  Plaintiff and others similarly situated were employees of Nationwide Eviction, LLC as  set forth above.   18.  As employees of Nationwide Eviction, Plaintiff and others similarly situated were legally  entitled to be paid minimum wage and at one-and-one-half times their regular rates of pay for  hours worked in excess of forty (40) hours per each seven (7) day workweek. As employees of  Nationwide Eviction, Plaintiff and others similarly situated were legally entitled to minimum  wage.   19.  Defendant failed to pay Plaintiff and others similarly situated at one-and-one-half times  their regular rates of pay for hours worked in excess of forty (40) hours per each seven (7) day  work week in violation of the FLSA 29 U.S.C. § 207.  Defendant failed to pay Plaintiff and  others similarly situated minimum wage in violation of the FLSA 28 U.S.C. § 206(a)(1)(C).1   21.  Defendant's violations of the FLSA were committed knowingly, willfully, and/or with  reckless disregard to Plaintiff's and other similarly situated employees’ rights.    22.  As a result of Defendant's willful violations of the FLSA, Plaintiff and others similarly  situated are entitled to reimbursement of unpaid overtime, an additional equal amount as  liquidated damages, and reasonable attorneys fees, costs and disbursements incurred in this  action pursuant to 29 U.S.C. § 216(b).  VI.  23.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   24.  The FLSA requires employers to keep accurate records of hours worked by nonexempt  employees.  29 U.S.C. §211(c); 29 C.F.R. pt 516.   25.  In addition to the pay violations of the FLSA described above, Defendant also failed to  keep proper time records as required by the FLSA.  26.  Plaintiff reasserts and incorporate by reference all of the above numbered paragraphs.   27.  Upon information and belief, many other similarly situated employees employed by  Defendant over the last three (3) years have been victimized by Defendant's violations of the  3.  At all times relevant to this lawsuit, Defendant was, and remains, an enterprise engaged  in commerce within the meaning of the FLSA. 29 U.S.C. § 203, and is subject to the FLSA.   4.  Defendant, Nationwide Eviction, LLC is a service company that provides a local  presence  to real estate companies engaged in the eviction process across the United States.  The  Company markets its proprietary technology to integrate local and county eviction procedures  into its own cloud-based system.  Defendant then provides its own local employees to attend  hearings and assist with processing eviction documentation through the appropriate court system.     5.  Defendant employed Plaintiff and others similarly situated at all relevant times within the  meaning of the FLSA. 29 U.S.C. § 203(g).  Plaintiff asserts upon information and belief that  Defendant's annual revenues exceeded $500,000.00 during the relevant time period.   6.  In performing his duties for Defendant, Plaintiff and others similarly situated were  employed in an enterprise engaged in commerce or in the production of goods for commerce.  Specifically, Defendant has employees utilizing interstate telephone and broadband  communications for the commercial purposes of Defendant's enterprise.  Moreover, Defendant  required Plaintiff and other non-attorneys to prepare for and attend and court hearings requiring  them to travel through the corridors of interstate commerce.   8.  Plaintiff and others similarly situated are paid a flat fee of $50.00 for each court  appearance regardless of the amount of time it takes the Agent to perform the task.  Plaintiff and  others similarly situated were not compensated for expenses associated with using their own  vehicles, cell phone data, car insurance gas, parking, and other expenses.     9.  Upon information and belief, other similarly situated employees are also uniformly paid  in a fashion similar to Plaintiff and not compensated for the expenses associated with performing  their job duties.  