14.  Plaintiff seeks to bring this suit to recover from Defendants unpaid overtime  compensation and liquidated damages pursuant to the applicable provisions of the FLSA, 29  U.S.C. § 216(b), individually, on her own behalf, as well as on behalf of those in the following  collective:  Current and former employees of Defendants, who during the  applicable FLSA limitations period, performed any work for  Defendants as foster care case planners and/or non-managerial case  managers, and who consent to file a claim to recover damages for  overtime compensation that is legally due to them (“FLSA  Plaintiffs”).   15.  Defendants treated Plaintiff and FLSA Plaintiffs similarly in that Plaintiff and  FLSA Plaintiffs: (1) performed similar tasks, as described in the “Background Facts” section  below; (2)  were subject to the same laws and regulations; (3) were paid in the same or similar  manner; (4) were required to work in excess of forty hours in a workweek; and (5) were not paid  the required one and one-half times their respective regular rates of pay for all hours worked per  workweek in excess of forty.   17.  Thus, Plaintiff and FLSA Plaintiffs are victims of Defendants’ pervasive practice  of willfully refusing to pay their employees overtime compensation for all hours worked per  workweek above forty, in violation of the FLSA.  18.  Defendant Catholic Guardian is a New York non-profit corporation that places  undocumented children with foster care sponsors.    19.  In or around July 2007, Plaintiff commenced her employment with Defendant  Catholic Guardian Services as a foster care case planner, and she worked in that role until May 2,  2014.  The last paycheck that Plaintiff received for her work as a foster care case planner was in  the first week of May 2014.     20.  As a foster care case planner, Plaintiff worked with children’s parents to finalize  the custody process and monitored children’s health and well-being while under their parents’  care.   21.  From at least in or around April 2011 through May 2, 2014, Defendants required  Plaintiff to work, and Plaintiff did work, five to six days per week, Monday through Friday, and  at least one Saturday per month, from 9:00 a.m. until 5:00 p.m., without being permitted an  uninterrupted break each day, totaling forty-eight hours worked per week on those weeks when  she worked on Saturdays.     23.  As a second example, during the week of January 20 through January 26, 2014,  Defendants required Plaintiff to work, and she did work, six days, Monday through Saturday,  from 9:00 a.m. until 5:00 p.m.  Accordingly, Plaintiff worked forty-eight hours during this  workweek.   24.  For her work as a foster care case planner, Defendant Catholic Guardian paid  Plaintiff a bi-weekly salary of approximately $1,600.00, regardless of whether one of the weeks  during the pay-period was a week when Plaintiff worked on Saturday.  As reflected on her  paystubs, this bi-weekly salary was intended to cover only the first thirty-five hours that Plaintiff  worked each week, which amounts to an hourly rate of $22.86.   25.  From at least in or around April 2011 through May 2, 2014, Defendant Catholic  Guardian did not pay Plaintiff at any rate of pay for any hours that she worked per week in  excess of thirty-five.   26.  On May 5, 2014, Defendant Ortiz promoted Plaintiff to the position of “case  manager,” a managerial position in name only, a position she held until April 12, 2017.    27.  Plaintiff’s primary duties as case manager consisted of making foster care  arrangements for undocumented children, conducting intakes, handling tasks related to the  children’s medical care, as well as being available at all times to respond to any and all  emergencies that arise with the foster children, including but not limited to, their behavioral  problems, placement issues, and medical concerns that required immediate attention.   29.  From May 5, 2014 through the end of December 2016, Defendants required  Plaintiff to work, and Plaintiff did work, five to six days a week, from Monday through Friday,  and at least one Saturday or one Sunday a month, from 9:00 a.m. until 5:00 p.m., without being  permitted to take an uninterrupted break each day, totaling either forty or forty-eight scheduled  hours during those weeks when Plaintiff was required to work one day on the weekend.     30.  Additionally, from May 19, 2014 through July 2016, Defendants assigned  Plaintiff a company cell phone and required her to respond to any emergencies that arose after  her regular weekday schedule ended, from 5:00 p.m. through 11:00 p.m., five to six days per  week on days when she was working, meaning that Plaintiff worked between seventy and eighty- four hours per week during that time.    31.  In or around January 2017 and continuing through the end of her employment on  April 12, 2017, Defendants no longer required Plaintiff to work on the weekends as a matter of  course, yet Defendants still required Plaintiff to work weekend days, always putting her over  forty hours for the week, on one day’s advance notice.   32.  By way of example only, during the week of September 29 through October 5,  2014, Defendants required Plaintiff to work, and she did work, six days, Monday through  Saturday, from 9:00 a.m. until 5:00 p.m.  Additionally, Defendants required Plaintiff to respond  to emergency phone calls from 5:00 p.m. through 11:00 p.m., Monday through Saturday.   Accordingly, Plaintiff worked a total of eighty-four hours during this workweek.   34.  From May 5, 2014 through in or around October 2016, for her work as case  manager, Defendant Catholic Guardian paid Plaintiff a bi-weekly salary of $1,651.96, regardless  of whether one of the weeks during the pay-period was a week when Plaintiff worked on  Saturday or Sunday.  As reflected on her paystubs, this bi-weekly salary was intended to cover  only the first thirty-five hours that Plaintiff worked each week, which amounts to an hourly rate  of $23.60.   35.  From November 2016 through April 12, 2017, for her work as case manager,  Defendant Catholic Guardian paid Plaintiff a bi-weekly salary of $1,668.48, regardless of  whether one of the weeks during the pay-period was a week when Plaintiff worked on Saturday  or Sunday.  As reflected on her paystubs, this bi-weekly salary was intended to cover only the  first thirty-five hours that Plaintiff worked each week, which amounts to an hourly rate of  $23.84.   36.  From May 5, 2014 to April 12, 2017, Defendant Catholic Guardian did not pay  Plaintiff at any rate of pay for any hours that she worked per week in excess of thirty-five.   37.  As described above, Defendants paid Plaintiff on a bi-weekly basis.    39.  Defendants treated Plaintiff and FLSA Plaintiffs in the same manner described  herein.   40.  Defendants acted in this manner to maximize their profits and minimize their  labor costs and overhead.   41.  Each hour that Plaintiff and FLSA Plaintiffs worked was for Defendants’ benefit.   42.  Plaintiff and FLSA Plaintiffs repeat, reiterate, and re-allege each and every  allegation set forth above with the same force and effect as if fully set forth herein.   43.  29 U.S.C. § 207(a) requires employers to compensate their employees at a rate of  not less than one and one-half times their regular rates of pay for all hours worked exceeding  forty in a workweek.   44.  As described above, Defendants are employers within the meaning of the FLSA  while Plaintiff and FLSA Plaintiffs are employees within the meaning of the FLSA.   45.  As also described above, Plaintiff and FLSA Plaintiffs worked in excess of forty  hours per week, yet Defendants failed to compensate Plaintiff and FLSA Plaintiffs in accordance  with the FLSA’s overtime provisions.    46.  Defendants willfully violated the FLSA.   47.  Plaintiff and FLSA Plaintiffs are entitled to overtime pay for all hours worked per  week in excess of forty at the rate of one and one-half times their respective regular rates of pay.   49.  Plaintiff, and any FLSA Plaintiff who opts-in to this action, repeat, reiterate, and  re-allege each and every allegation set forth above with the same force and effect as if more fully  set forth herein.    50.  NYLL § 160 and 12 NYCCRR § 142-2.2 require employers to compensate their  employees at a rate not less than one and one-half times their regular rates of pay for all hours  worked exceeding forty in a workweek.   51.  As described above, Defendants are employers within the meaning of the NYLL  and the NYCCRR, while Plaintiff, and any FLSA Plaintiff who opts-in to this action, are  employees within the meaning of the NYLL and the NYCCRR.   52.  As also described above, Plaintiff, and any FLSA Plaintiff who opts-in to this  action, worked in excess of forty hours in a workweek, yet Defendants failed to compensate  them in accordance with the NYLL’s and the NYCCRR’s overtime provisions.   53.  Plaintiff, and any FLSA Plaintiff who opts-in to this action, are entitled to their  overtime pay for all hours worked per week in excess of forty at the rate of one and one-half  times their respective regular rates of pay.   55.  Plaintiff, and any FLSA Plaintiff who opts-in to this action, repeat, reiterate, and  re-allege each and every allegation set forth above with the same force and effect as if fully set  forth herein.   56.  NYLL §§ 190, 191, and 663(1) require that employers pay timely wages to their  employees in accordance with the agreed terms of employment.   57.  As described above, Defendants are employers within the meaning of the NYLL,  while Plaintiff, and any FLSA Plaintiff who opts-in to this action, are employees within the  meaning of the NYLL.   58.  As also described above, Defendants failed to compensate Plaintiff, and any  FLSA Plaintiff who opts-in to this action, at their respective regular rates of pay for each hour  that they worked in accordance with their terms of employment.    59.  At the least, Plaintiff, and any FLSA Plaintiff who opts-in to this action, are  entitled to recover for all hours worked for Defendants but for which Defendants did not provide  compensation at their respective regular rates of pay.   60.  Plaintiff, and any FLSA Plaintiff who opts-in to this action, are entitled to  liquidated damages, interest, attorneys’ fees, and costs and disbursements in this action for  Defendants’ failure to pay them their wages in accordance with the agreed terms of employment.  Failure to Pay Wages in Violation of the NYLL   Unpaid Overtime in Violation of the NYLL and NYCCRR   Unpaid Overtime in Violation of the FLSA  