24.  Plaintiff brings Count I of this Complaint as a collective action on behalf of herself  and all other current and former hourly employees of Defendants who Defendants required to  perform the Unpaid Study Work described herein.     25.   25.  Plaintiff’s Counsel seeks to send notice of this lawsuit to the following described  persons:  All persons who worked for Defendants as employees who were compensated, in  part or in full, on an hourly basis in Illinois at any time between November 11, 2013  and the present who did not receive the full amount of minimum wages and/or  overtime wages earned and owed to them as a result of Defendants’ Unpaid Study  Work practice.  6   26.  There are questions of law or fact common to the employees described in paragraph   27.  Plaintiff is similarly situated to the employees described in paragraph 25, as  Plaintiff’s claims are typical of the claims of those persons.   28.  Plaintiff’s claims or defenses are typical of the claims or defenses of the persons  described in paragraph 25.   29.  This is not a collusive or friendly action.  Plaintiff has retained counsel experienced  in complex employment litigation, and Plaintiff and her counsel will fairly and adequately protect  the interests of the persons described in paragraph 25.   30.  A collective action is the most appropriate method for the fair and efficient  resolution of the matters alleged in Count I.   31.  At all relevant times, Defendants employed Plaintiff and the persons described in  paragraph 25.   32.  At all relevant times, Defendants paid Plaintiff and the persons described in  paragraph 25 to work.   33.  At all relevant times, each Defendant has been an “employer” as defined by Section  3(d) of the FLSA, 29 U.S.C. § 203(d).     34.  At all relevant times, Plaintiff and the persons described in paragraph 25 have been  “employees” of Defendants as defined by Section 3(e) of the FLSA, 29 U.S.C. § 203(e).  35.  Plaintiff brings Count II as a class action pursuant to Fed. R. Civ. P. 23 on behalf  of herself and all other current and former hourly employees of Defendants who worked for  Defendants in Illinois and were required to perform the Unpaid Study Work described herein.    7   36.  Plaintiff seeks certification of the following class pursuant to Count II:  All persons who worked for Defendants as employees who were compensated, in  part or in full, on an hourly basis in Illinois at any time between November 11, 2013  and the present who did not receive the full amount of minimum wages and/or  overtime wages earned and owed to them as a result of Defendants’ Unpaid Study  Work practice (the “IMWL Class”).   36.   37.  There are questions of law or fact common to the employees described in paragraph   38.  Plaintiff is similarly situated to the employees in paragraph 36 as Plaintiff’s claims  are typical of the claims of those persons.   39.  Plaintiff believes that the number of employees who fall within the class definition  as set forth in paragraph 36 exceeds 40.  Therefore, the number of persons in the putative IMWL  Class is so numerous that joinder of all members is impracticable.   40.  Plaintiff’s claims or defenses are typical of the claims or defenses of the persons  described in paragraph 36.   41.  This is not a collusive or friendly action.  Plaintiff has retained counsel experienced  in complex employment litigation, and Plaintiff and her counsel will fairly and adequately protect  the interests of the persons described in paragraph 36.   42.  A class action is the most appropriate method for the fair and efficient resolution of  the matters alleged in Counts II.   43.  At all relevant times, Defendants employed Plaintiff and the persons described in  paragraphs 36.   44.  At all relevant times, Defendants paid Plaintiff and the persons described in  paragraph 36 to work.  8  45.  Plaintiff re-alleges and incorporates by reference Paragraphs 1 through 34 as  Paragraph 45 of this Count I.   46.  Plaintiff and the members of the class described in paragraph 25 seek to recover  from Defendants unpaid minimum wages and/or overtime wages, liquidated damages, attorneys’  fees, and costs pursuant to Section 16 of the FLSA, 29 U.S.C. § 216.     47.  During the relevant period, and at Defendants’ request, Plaintiff and the other  members of the class described in paragraph 25 performed labor for Defendants.     48.  In exchange for said labor, Defendants promised to pay and were otherwise  obligated to pay Plaintiff and each other member of the class described in paragraph 25 the  applicable minimum wage for all hours worked up to forty hours in any given workweek, and time  and a half for all hours worked in excess of forty hours in any given workweek.   49.  Plaintiff and the other members of the class described in paragraph 25 are entitled  to be paid at least minimum wage for all hours worked and time and a half for all hours worked in  excess of forty hours per workweek pursuant to Sections 6 and 7 of the FLSA, 29 U.S.C. §§ 206,  207.   50.  Defendants have failed to pay Plaintiff and the other members of class described in  paragraph 25 minimum wage and the full amount due for all overtime hours worked, because  Defendants did not pay them for the Unpaid Study Work described herein, in violation of Sections  6 and 7 of the FLSA, 29 U.S.C. §§ 206, 207.   51.  Defendants’ violation of the FLSA was willful.   52.  Plaintiff and the other members of the class described in paragraph 25 have been  damaged by not being paid minimum wage and/or overtime wages due to them for all time worked  9  in excess of forty hours per workweek, in an amount not presently ascertainable, for the relevant  time period.  WHEREFORE, Plaintiff demands a trial by jury on this and all counts so triable, and prays  that this Court award her the following relief under Count I: (a) grant Plaintiff’s counsel leave to  send notice of this lawsuit to the members of the class described in paragraph 25 and allow them  the opportunity to opt-in as party plaintiffs pursuant to Section 16 of the FLSA, 29 U.S.C. § 216;  (b) award Plaintiff and all persons who opt-in all unpaid minimum or overtime wages they earned,  plus liquidated damages; (c) award Plaintiff and all persons who opt-in their attorneys’ fees and  costs; and (d) grant such further relief as this Court deems equitable and just.  53.  Plaintiff re-alleges and incorporates by reference Paragraphs 1 through 23 and 35  through 44 as Paragraph 53 of this Count II.   54.  Plaintiff, individually and on behalf of all others similarly situated, seeks to recover  from Defendants unpaid minimum and overtime wages, statutory penalties, attorneys’ fees, and  costs pursuant to Section 12(a) of the Illinois Minimum Wage Law, 820 ILCS § 105/12(a).   55.  At all times relevant, each Defendant has been an “employer” as that term is defined  by Section 3(c) of the IMWL, 820 ILCS § 105/3(c).   56.  At all times relevant, Plaintiff and the members of the putative IMWL Class have  been “employees” of Defendants, as that term is defined by Section 3(d) of the IMWL, 820 ILCS  § 105/3(d).   57.  At all times relevant, and at Defendants’ request, Plaintiff and the members of the  putative IMWL Class performed labor for Defendants.  10   58.  Defendants’ practice of requiring Plaintiff and the members of the putative IMWL  Class to work for Defendants but failing to pay the full amount of minimum wages for such time  worked up to forty hours per workweek has resulted in Plaintiff and the members of the putative  IMWL Class not being paid the full amount of minimum wages owed to them, in violation of  Section 4 of the IMWL, 820 ILCS § 105/4.     59.  Defendants’ practice of requiring Plaintiff and the members of the putative IMWL  Class to work for Defendants in excess of forty hours per workweek but failing to pay them 1.5  times their hourly rate for such time worked has resulted in Plaintiff and the members of the  putative IMWL Class not being paid the full amount of overtime wages owed to them, in violation  of Section 4a of the IMWL, 820 ILCS § 105/4a.     60.  Plaintiff and the members of the putative IMWL Class have been damaged by not  being paid the proper amount of minimum and/or overtime wages due to them, in an amount not  presently ascertainable, for the relevant time period.  WHEREFORE, Plaintiff, individually and on behalf of all others similarly situated,  demands a trial by jury on this and all counts so triable, and prays that this Court award her the  following relief under Count II: (a) certify the class defined in paragraph 36 pursuant to Fed. R.  Civ. p. 23; (b) award Plaintiff and the members of the putative IMWL Class all unpaid minimum  and overtime wages they earned, plus statutory penalties; (c) award Plaintiff and the members of  the putative IMWL Class their attorneys’ fees and costs; and (d) grant such further relief as this  Court deems equitable and just.  Dated:  November 11, 2016  11  ROBIN RAPAI, individually and on behalf of a  class of persons similarly situated  /s/ James X. Bormes  One of Plaintiff’s Attorneys  James X. Bormes  Catherine P. Sons  Law Office of James X. Bormes, P.C.  8 South Michigan Avenue  Suite 2600  Chicago, Illinois 60603  (312) 201-0575  