10.  Defendant Golden Flake employed Route Drivers, who delivered Golden Flake’s  products and other snack products to its customers including chain retail grocery stores.     11.  Plaintiff was a Route Driver employed by Golden Flake during the three-year  period preceding the filing of this Complaint.     12.  Golden Flake has a fleet of delivery vehicles for its Route Drivers to use in  delivering Golden Flake’s products and other products to its customers.  That fleet includes  trucks that weigh 10,000 pounds or less (“Small Trucks”).   13.  Plaintiff and the putative class members all drove Small Trucks during at least  part of a workweek within the last three years.   14.  At all relevant times, Plaintiff and the putative class members were non-exempt  employees and entitled to be paid for all hours worked and at a rate of one and one-half times  their regular rate for hours worked in excess of forty (40) hours per workweek.     15.  The primary duties of Route Drivers, including Plaintiff, are driving a truck,  delivering Golden Flake’s products, removing expired products, and stocking shelves, among  other non-exempt manual labor tasks.    4   16.  Route Drivers, including Plaintiff, were not paid at a rate of one and a half times  their regular rate for hours worked in excess of forty (40) in a workweek.   17.  Route Drivers, including Plaintiff, are assigned designated routes to which they  deliver Golden Flake’s products and other products to established customers day after day or  week after week.  Customer orders delivered by Route Drivers are based on the volume of the  customer’s sales.  Reordering decisions are based on anticipated sales of Golden Flake’s  products or other products by its customers.   18.  Most of Golden Flake’s revenue is generated from retail chain customers, such as  Walmart.   19.  The amount of shelf space to which Golden Flake is entitled in a retail chain  customer’s store, and other stores, is negotiated by management level employees, and not Route  Drivers, and is memorialized through “plan-o-grams” and/or merchandising plans and/or similar  documents.  Route Drivers are not permitted to vary from these “plan-o-grams” and/or  merchandising plans and/or similar documents in utilizing shelf space to stock shelves.   20.  Golden Flake’s management level employees, and not Route Drivers, negotiate  with Golden Flake’s retail chain customers, among others, concerning:  the initial or continued  right to carry Golden Flake’s products in the customer’s store; the price for Golden Flake’s  products; if and when a product promotion will run; how Golden Flake’s products are advertised;  the terms of a product promotion; how much shelf space is allocated for products; authorization  for new items; authorization for price changes; which of Golden Flake’s products are carried by  the customer; and/or, where Golden Flake products are placed in a store, among other things.  5   21.  Route Drivers, including Plaintiff, routinely work in excess of forty (40) hours in  a workweek. Plaintiff would regularly work well in excess of fifty (50) hours in a workweek  during the three-year period preceding the filing of this Complaint.   22.  Plaintiff repeats the allegations set forth above and incorporate them herein by  reference.     23.  Plaintiff brings this action on behalf of himself and all workers who were and/or  are employed by Defendant Golden Flake as a Route Driver (or similar position), spent all or  part of their workweek driving a vehicle that weighed 10,000 pounds or less, and did not receive  overtime for hours worked over forty (40) per workweek during the last three years.   24.   This action is maintainable as an “opt-in” collective action pursuant to 29 U.S.C.  § 216(b) as to claims for unpaid wages, overtime compensation, liquidated damages, attorneys’  fees and costs under the FLSA.  In addition to Plaintiff, numerous current and former employees  are similarly situated with regard to their wages and claims for unpaid wages and damages.   Plaintiff is representative of those other employees and is acting on behalf of their interests, as  well as his own, in bringing this action.   25.  These similarly-situated employees are known to Defendant and are readily  identifiable through Defendant’s business and payroll records.  These individuals may readily be  notified of this action, and allowed to opt in pursuant to 29 U.S.C. § 216(b), for the purpose of  collectively adjudicating their claims for unpaid wages, overtime compensation, liquidated  damages, attorneys’ fees and costs under the FLSA.  6  9.  Defendant Golden Flake is in the business of producing and distributing various  snack foods.  