16.  Plaintiff realleges and incorporates by reference the preceding  paragraphs.   17.  Through its Field Technicians, Defendant provides roof inspection  services, ladder assist services, direct inspections of roof damage and tarping  services, (“services”) to insurance companies nationwide.     18.  According to its website, Field Technicians are available to assist its  customers within 24-48 hours upon request.  In weather catastrophes and  emergencies, Field Technician teams traveled across the United States to assist and  expedite the services requested.   19.  During the Collective Action Period, Defendant employed Plaintiff as  a Field Technician from May 2013 to June 2014.     20.  As a Field Technician, Defendant directed Plaintiff and the Collective  Action Members to perform services to its customers in the United States,  including but not limited to, in North Carolina, South Carolina, Texas, New York,  Michigan, and Ohio.   22.  Defendant assigned all of the work that Plaintiff and the Collective  Action Members performed, and/or has been aware of it.  The exact number of  claims worked per week, and the locations they traveled to, can be ascertained  from Defendant’s records.   23.  Pursuant to its centralized, company-wide policy, pattern and/or  practice, Defendant classified Plaintiff and the Collective Action Members, as  independent contractors who were exempt from the overtime provisions of the  37.  Plaintiff, on behalf of himself and all of the Collective Action  Members, realleges and incorporates by reference all prior paragraphs as if they  were set forth again herein.   38.  During the Collective Action Period, Defendant hired Field  Technicians similarly situated to Plaintiff who performed the same work for  Defendant and were subjected to the same pay practices as Plaintiff.   39.  Plaintiff and the Collective Action Members are all victims of the  Defendant’s common policy and / or plan to violate the FLSA by (1) failing to pay  all earned wages; (2) misclassifying Plaintiff and the Collective Action Members  as exempt from minimum wage and overtime compensation; (3) failing to provide  any wages for “off the clock” work; and (4) failing to provide overtime wages for  all time worked in excess of 40 hours in any given week pursuant to 29 U.S.C. §  207.   41.  Defendant is liable under the FLSA for, inter alia, failing to properly  compensate Plaintiff and the Collective Action Members.    42.  There are many similarly situated Field Technicians employed by  Defendant who have been underpaid in violation of the FLSA and who would  benefit from the issuance of a court-supervised notice of this lawsuit and the  opportunity to join it.  Thus, Notice should be sent to the FLSA Collective  pursuant to 29 U.S.C. § 216(b).    43.  The similarly situated Field Technicians are known to Defendant, are  readily identifiable, and can be located through Defendant’s records.   45.  Plaintiff, on behalf of himself and all of the Collective Action  Members, realleges and incorporates by reference all prior paragraphs as if they  were set forth again herein.   46.  At all relevant times and continuing to the present time, Defendant’s  piece rate compensation system did not fully compensate Plaintiff and the  Collective Action Members by failing to pay them the applicable minimum wages  for all their hours worked as required by Section 206 of the FLSA.   47.  Defendant’s misclassification of Plaintiff and the Collective Action  Members as independent contractors, and Defendant’s failure to pay them in  accordance with Section 207 of the FLSA, was in willful disregard of the overtime  compensation requirements of the FLSA.   49.  As a result of Defendant’s FLSA violations, Defendant is liable to  Plaintiff and the Collective Action members for minimum wage compensation in  an amount to be determined at trial, plus liquidated damages in the amount equal to  the amount of unpaid wages, interest, attorneys’ fees and costs.  50.  Plaintiff, on behalf of himself and all of the Collective Action  Members, realleges and incorporates by reference all prior paragraphs as if they  were set forth again herein.   51.  At all relevant times and continuing to the present time, Defendant’s  piece rate compensation system did not fully compensate Plaintiff and the  Collective Action Members for all their hours worked for Defendant in excess of  forty (40) hours per week as required by Section 207 of the FLSA.   52.  Plaintiff and the Collective Action Members were victims of a policy  and plan by Defendant to classify them as independent contractors and to deny  them overtime compensation required by the FLSA.   54.  Defendant’s failure to perform a person-by-person analysis of  Plaintiff’s and the Collective Action members’ job duties to ensure that they were  properly classified as independent contractors, and its failure to compensate them  for off the clock work, was in willful violation of the FLSA to save money.   Defendant knew and/or showed reckless disregard for the matter of whether its  conduct was prohibited by the Act.  29 U.S.C. § 255(a).   55.  As a result of Defendant’s FLSA violations, Defendant is liable to  Plaintiff and the Collective Action Members for unpaid overtime compensation in  an amount to be determined at trial, plus liquidated damages in the amount equal to  the amount of unpaid wages, interest, attorneys’ fees and costs.  FLSA OVERTIME COMPENSATION  (Brought on Behalf of Plaintiff and All Collective Action Members)   FLSA MINIMUM WAGE COMPENSATION  (Brought on Behalf of Plaintiff and All Collective Action Members)  