13.  Even though APMs primarily performed non-exempt functions, BJ’s classified all APMs  as “exempt” from the overtime requirements.  This practice of classifying all APMs as exempt  was uniformly applied regardless of store size, volume, location or any other individualized  factor.     14.  Plaintiff has filed this lawsuit to challenge BJ’s policy of improperly compensating  APMs.    15.  Numerous employees have been victimized by this pattern, practice and policy  which are in willful violation of the FLSA.  The Putative Class Members are all salaried  employees who regularly worked in excess of 40 hours per week.  These employees are victims  of Defendant’s unlawful compensation practices and are similarly situated to Plaintiff in terms of  job duties, pay provisions and employment practices.   16.  Defendant’s failure to pay wages and overtime compensation at the rates required  by the FLSA result from generally applicable, systematic policy and practice and which is not  dependent on the personal circumstances of the Putative Class Members.  Thus, Plaintiff’s  experiences are typical of the experiences of the Putative Class Members.   18.  During the relevant time period, Defendant has violated, and is violating, the provisions  of Sections 6 and/or 7 of the FLSA, 29 U.S.C. §§ 206, 207, and 215(a)(2), by employing  employees in an enterprise engaged in commerce or in the production of goods for commerce  within the meaning of the FLSA for workweeks longer than 40 hours without compensating such  employees for their employment in excess of 40 hours per week at rates no less than one and  one-half the regular rates for which they were employed.     19.  Defendant knowingly, willfully or in reckless disregard carried out its illegal pattern or  practice of failing to pay Plaintiff and the Putative Class Members overtime compensation.  The  decision by Defendant not to properly pay overtime compensation to its APMs was neither  reasonable, nor in good faith.  Accordingly, Plaintiff and the Putative Class Members are entitled  to overtime wages under the FLSA in an amount equal to one and one-half times their rate of  pay, plus liquidated damages, attorney’s fees and costs.  IX.  FLSA VIOLATIONS  