38. Defendant has failed to pay Plaintiffs and similarly situated individuals proper overtime  compensation for hours worked in excess of forty (40) per week.   39. Defendant has a policy and practice of failing and refusing to pay Plaintiffs and all other  similarly situated employees for all hours worked in violation of the Fair Labor Standards  Act, 29 U.S.C. §§ 201, et seq.   40. Defendant’s conduct in this regard was a willful violation of the FLSA.   41. As a result of Defendant’s unlawful acts, Plaintiffs and all other similarly situated current  and former employees are being deprived of earned wages in amounts to be determined at  trial.  They are entitled to compensation for unpaid minimum wage and overtime wages,  interest, liquidated damages, attorneys’ fees and costs, and any other remedies available at  law or in equity.  8  42. Plaintiffs and the members of the putative class are employees within the meaning of the  Ohio Wage Act.   43. Defendant has failed to pay Plaintiffs and other similarly situated employees proper  compensation for all hours worked in violation of the Ohio Wage Act.   44. Defendant’s policy and practice denied and continues to deny Plaintiffs and other similarly  situated employees from receiving payment of the overtime premium for all hours worked  in excess of forty hours in a work week.      45. Defendant’s conduct in this regard is a willful violation of O.R.C. §§4111.01, 4111.03 and  4111.10.   46. Plaintiffs and other similarly situated employees who worked in Ohio are entitled to  compensation for unpaid overtime wages, interest, attorneys’ fees and costs, and any other  remedies available at law or in equity.  9  VIOLATION OF THE OHIO WAGE ACT, O.R.C. §§ 4111.01, 4111.03, 4111.10  BY PLAINTIFFS, INDIVIDUALLY AND   ON BEHALF OF ALL OTHER SIMILARLY SITUATED INDIVIDUALS   VIOLATION OF THE FAIR LABOR STANDARDS ACT  ON BEHALF OF PLAINTIFFS, INDIVIDUALLY,   AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED EMPLOYEES,    VIOLATION OF THE OHIO PROMPT PAY ACT, O.R.C. § 4113.15, FAILURE TO  PAY WAGES WITHIN THIRTY DAYS OF PERFORMING THE WORK   BY PLAINTIFFS, INDIVIDUALLY AND  