(Fair Labor Standards Act Violations)   (Violations of Ohio Revised Code 4111.03)   13.  Defendant Norman Noble manufactures products for the medical and aerospace  industries and has manufacturing facilities in Highland Heights and Cleveland, Ohio.   14.  Defendant employed Plaintiff as an hourly, non-exempt manufacturing employee  (a quality control inspector) in its Highland Heights, Ohio manufacturing facility between October  6, 1997 and January 19, 2018.   15.  Other similarly-situated employees were employed by Defendant as non-exempt  manufacturing employees in Defendant’s manufacturing facilities.   16.  Defendant paid Plaintiff and other similarly-situated non-exempt manufacturing  employees an hourly wage.  (Failure to Pay for All Hours Worked)   17.  Plaintiff and other similarly-situated non-exempt employees were only paid for  work performed between their scheduled start and stop times, and were not paid for the following  work performed before and after their scheduled start and stop times: a) changing into and out of  their uniforms and personal protective equipment, including but not limited to a shirt, pants, boots,  glasses, a hard hat, glasses and/or hearing protection; b) walking to and from their assigned area  of the production floor; and c) getting tools and equipment necessary to perform their production  work.   18.  The amount of time Plaintiff and other similarly-situated employees spent on this  required and unpaid work amounted to approximately 30 minutes each day.   (Failure to Pay For Donning Time)  4   19.  Before Plaintiff and other similarly-situated employees began their shifts, they  donned uniforms, a shirt, pants, boots, glasses, a hard hat, glasses and/or hearing protection.   20.  The time Plaintiff and other similarly-situated employees spent donning their  uniforms and personal protective equipment was an integral and indispensable part of their  principal activities, was required by Defendant and the Occupational Safety and Health  Administration (“OSHA”), and was performed for Defendant’s benefit in that it helped keep the  production floor safe and sanitary, and helped promote a more safe and efficient manufacturing  process.     21.  Plaintiff and other similarly-situated employees were not paid for time spent  donning their uniforms and personal protective equipment.   (Failure to Pay For Postdonning Walk Time)   22.  After donning their uniforms and personal protective equipment, Plaintiff and other  similarly-situated employees walked from the area in which they changed into personal protective  equipment to the production floor.  Such time constitutes “postdonning walk time.”   23.  Plaintiff and other similarly-situated employees were not paid for their postdonning  walk time.   (Failure to Pay for Time Spent Retrieving Tools)   24.  Before Plaintiff and other similarly-situated employees began their shift, they  retrieve tools necessary to perform their job duties.   25.  The time Plaintiff and other similarly-situated employees spent retrieving their  tools was an integral and indispensable part of their principal activities, was required by Defendant,  and was performed for Defendant’s benefit in that it allowed Plaintiff and other similarly-situated  employees to perform their job.  5  (Failure to Pay For Predoffing Walk Time)   26.  After the end of their shifts, Plaintiff and other similarly-situated employees walked  from the production floor to the area in which they changed out of their personal protective  equipment.  Such time constitutes “predoffing walk time.”   27.  Plaintiff and other similarly-situated employees were not paid for their predoffing  walk time.  (Failure to Pay for Doffing Time)   28.  At the end of their shifts, Plaintiff and other similarly-situated employees doffed  their personal protective equipment and uniforms.   29.  The time Plaintiff and other similarly-situated employees spent doffing their  uniforms and personal protective equipment was an integral and indispensable part of their  principal activities, was required by Defendant, and OSHA, and was performed for Defendant’s  benefit in that it helped keep the manufacturing floor safe and helped promote a more safe and  efficient manufacturing process.     30.  Plaintiff and other similarly-situated employees were not paid for time spent  doffing their personal protective equipment and uniforms.  (Failure to Pay Overtime Compensation)   31.  As a result of Plaintiff and other similarly-situated employees not being paid for all  hours worked, Plaintiff and other similarly-situated employees were not paid overtime  compensation for all of the hours they worked over 40 each workweek.   32.  Defendant knowingly and willfully engaged in the above-mentioned violations of  the FLSA.  33.  Plaintiff brings Count One of this action on her own behalf pursuant to 29 U.S.C.  § 216(b), and on behalf of all other persons similarly situated who have been, are being, or will be  adversely affected by Defendant’s unlawful conduct.   34.  The class which Plaintiff seeks to represent and for whom Plaintiff seeks the right  to send “opt-in” notices for purposes of the collective action, and of which Plaintiff is herself a  member, is composed of and defined as follows:  All former and current manufacturing employees of Norman Noble,  Inc. between February 13, 2015 and the present.   35.  Plaintiff is unable to state at this time the exact size of the potential class, but upon  information and belief, avers that it consists of at least several hundred persons.   36.  This action is maintainable as an “opt-in” collective action pursuant to 29 U.S.C. §  216(b) as to claims for unpaid 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 claims for unpaid wages and damages.  Plaintiff is  representative of those other employees and is acting on behalf of their interests as well as her own  in bringing this action.   37.  These similarly-situated employees are known to Defendant and are readily  identifiable through Defendant’s 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 overtime compensation, liquidated damages, attorneys’ fees  and costs under the FLSA.  38.  Plaintiff brings Count Two of this action pursuant to Fed. R. Civ. P. 23(a) and (b)(3)  on behalf of herself and all other members of the class (“the Ohio Class”) defined as:  7  All former and current manufacturing employees of Norman Noble,  Inc. employed in the State of Ohio between February 13, 2015 and  the present.   39.  The Ohio Class is so numerous that joinder of all class members is impracticable.   Plaintiff is unable to state at this time the exact size of the potential Ohio Class, but upon  information and belief, avers that it consists of at least several hundred persons.    40.  There are questions of law or fact common to the Ohio Class, including but not  limited to the following:  (a) whether Defendant failed to pay overtime compensation to Plaintiff  and other members of the class for hours worked in excess of 40  each workweek;  (b) whether Defendant failed to properly compensate Plaintiff and other  members of the class for donning time, postdonning walk time, time  spent retrieving tools, predoffing walk time, and doffing time; and  (c) what amount of monetary relief will compensate Plaintiff and other  members of the class for Defendant’s violation of R.C. 4111.03 and  4111.10.   41.  The claims of the named Plaintiff Khrystyne Hill are typical of the claims of other  members of the Ohio Class.  Named Plaintiff’s claims arise out of the same uniform course of  conduct by Defendant, and are based on the same legal theories, as the claims of the other Ohio  Class members.    42.  Named Plaintiff Khrystyne Hill will fairly and adequately protect the interests of  the Ohio Class.  Her interests are not antagonistic to, but rather are in unison with, the interests of  the other Ohio Class members.  The named Plaintiff’s counsel has broad experience in handling  class action wage-and-hour litigation, and is fully qualified to prosecute the claims of the Ohio  Class in this case.  8   43.  The questions of law or fact that are common to the Ohio Class predominate over  any questions affecting only individual members.  The primary questions that will determine  Defendant’s liability to the Ohio Class, listed above, are common to the class as a whole, and  predominate over any questions affecting only individual class members.   44.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy.  Requiring Ohio Class members to pursue their claims  individually would entail a host of separate suits, with concomitant duplication of costs, attorneys’  fees, and demands on court resources.  Many Ohio Class members’ claims are sufficiently small  that they would be reluctant to incur the substantial cost, expense, and risk of pursuing their claims  individually.  Certification of this case pursuant to Fed. R. Civ. P. 23 will enable the issues to be  adjudicated for all class members with the efficiencies of class litigation.  45.  Plaintiff incorporates by reference the foregoing allegations as if fully rewritten  herein.   46.  Defendant’s practice and policy of not paying Plaintiff and other similarly-situated  employees for all time worked and overtime compensation at a rate of one and one-half times their  regular rates of pay for all of the hours they worked over 40 each workweek violated the FLSA,  29 U.S.C. §§ 201-219 and 29 CFR § 785.24.   47.  Defendant’s failure to keep records of all of the hours worked each workday and  the total hours worked each workweek by Plaintiff and other similarly-situated employees violated  the FLSA, 29 U.S.C. §§ 201-219, 29 CFR 516.2(a)(7).   48.  By engaging in the above-mentioned conduct, Defendant willfully, knowingly,  and/or recklessly violated the provisions of the FLSA.   9   49.  As a result of Defendant’s practices and policies, Plaintiff and other similarly- situated employees have been damaged in that they have not received wages due to them pursuant  to the FLSA.   50.  Plaintiff incorporates by reference the foregoing allegations as if fully rewritten  herein.    51.  Defendant’s practice and policy of not paying Plaintiff and other similarly-situated  employees for all time worked and overtime compensation at a rate of one and one-half times their  regular rates of pay for all of the hours they worked over 40 each workweek violated the  6  