17.  Plaintiffs bring claims for relief as a collective action pursuant to FLSA Section  16(b), 29 U.S.C. §216(b), on behalf of all non-exempt front-of-house and back-of-house  employees (including delivery persons, servers, runners, bussers, porters, cooks, line-cooks, food  preparers and dishwashers) employed by Defendants on or after the date that is six years before  the filing of the Complaint in this case as defined herein (herein, “FLSA Collective Plaintiffs”).    19.  The claims for relief are properly brought under and maintained as an opt-in  collective action pursuant to §16(b) of the FLSA, 29 U.S.C. 216(b). The FLSA Collective  Plaintiffs are readily ascertainable. For purposes of notice and other purposes related to this  action, their names and addresses are readily available from the Defendants. Notice can be  provided to the FLSA Collective Plaintiffs via first class mail to the last address known to  Defendants.   20.  Plaintiffs bring claims for relief pursuant to the Federal Rules of Civil Procedure  (“F.R.C.P”) Rule 23, on behalf of all non-exempt front-of-house and back-of-house employees  (including delivery persons, servers, runners, bussers, porters, cooks, line-cooks, food preparers,  and dishwashers) employed by Defendants on or after the date that is six years before the filing  of the Complaint in this case as defined herein (the “Class Period”).    22.  The proposed Class is so numerous that a joinder of all members is impracticable,  and the disposition of their claims as a class will benefit the parties and the Court. Although the  precise number of such persons is unknown. As the facts on which the calculation of that number  is presently within the sole control of Defendants, there is no doubt that there are more than forty  (40) members of the Class.    23.  Plaintiffs’ claims are typical of those claims that could be alleged by any member  of the Class, and the relief sought is typical of the relief that would be sought by each member of  the Class in separate actions. All the Class members were subject to Defendants’ same corporate  practices of (i) failing to pay proper wages for all hours worked, including their overtime  premium at one and one half times the regular rate for all hours worked over forty (40) in a  workweek, (ii) deducting an improper meal credit, (iii) failing to provide wage statements per the  requirements of the NYLL, and (iv) failing to properly provide wage notices to Class members,  at date of hiring and annually, per the requirements of the NYLL.   24.  Defendants’ corporate wide policies and practices affected all Class members  similarly, and Defendants benefited from the same type of unfair and/or wrongful acts as to each  Class member. Plaintiffs and other Class members sustained similar losses, injuries and damages  arising from the same unlawful policies, practices and procedures.    26.  A class action is superior to other available methods for the fair and efficient  adjudication of the controversy – particularly in the context of the wage and hour litigation  where individual class members lack the financial resources to vigorously prosecute a lawsuit  against corporate defendants. Class action treatment will permit a large number of similarly  situated persons to prosecute common claims in a single forum simultaneously, efficiently, and  without the unnecessary duplication of efforts and expense that numerous individual actions  engender. Because of losses, injuries and damages suffered by each of the individual Class  members are small in the sense pertinent to a class action analysis, the expenses and burden of  individual litigation would make it extremely difficult or impossible for the individual Class  members to redress the wrongs done to them. On the other hand, important public interests will  be served by addressing the matter as a class action. The adjudication of individual litigation  claims would result in a great expenditure of Court and public resources; however, treating the  claims as a class action would result in a significant saving of these costs. The prosecution of  separate actions by individual members of the Class would create a risk of inconsistent and/or  varying adjudications with respect to the individual members of the Class, establishing  incompatible standards of conduct for Defendant and resulting in the impairment of class  members’ rights and the disposition of their interests through actions to which they were not  parties. The issues in this action can be decided by means of common, class-wide proof. In  addition, if appropriate, the Court can, and is empowered to, fashion methods to efficiently  manage this action as a class action.   30.  Plaintiff VICTOR BRAVO:    a. In or around March 2019, Plaintiff, VICTOR BRAVO was by Individual  Defendants to work as a cook for Defendants at 1556 2nd Avenue New York,  39.  Plaintiffs reallege each and every previously mentioned allegation of this Class  and Collective Action complaint as fully set forth herein.   40.  At all relevant times, Individual Defendants were and continue to be employers  engaged in interstate commerce and/or the production of goods for commerce within the  meaning of the FLSA, 29 U.S.C. §§ 206(a) and 207(a). Further, Plaintiffs and FLSA Collective  Plaintiffs are covered individuals within the meaning of the FLSA, 29 U.S.C. §§ 206(a) and  207(a).   41.  At all relevant times, Defendants employed Plaintiffs and FLSA Collective  Plaintiffs within the meaning of the FLSA.   42.  At all relevant times, Corporate Defendants had gross annual revenues in excess  of $500,000.   43.  At all relevant times, the Defendants had a policy and practice that failed to pay  Collective Plaintiffs their proper wages for all hours, including overtime for hours worked in  excess of forty (40) hours per workweek, due to a policy of time-shaving.    45.  Defendants failed to properly disclose or apprise Plaintiffs and FLSA Collective  Plaintiffs of their rights under the FLSA.   46.  As a direct and proximate result of Defendants’ willful disregard of the FLSA,  Plaintiffs and FLSA Collective Plaintiffs are entitled to liquidated (i.e., double) damages  pursuant to the FLSA.   47.  Due to the intentional, willful and unlawful acts of Defendants, Plaintiffs and  FLSA Collective Plaintiffs suffered damages in an amount not presently ascertainable of unpaid  wages and unpaid overtime, plus an equal amount as liquidated damages.   48.  Plaintiffs and FLSA Collective Plaintiffs are entitled to an award of their  reasonable attorneys’ fees and costs pursuant to 29 U.S.C. §216(b).   49.  Plaintiffs reallege each and every previously mentioned allegation of this Class  and Collective Action complaint as fully set forth herein.    50.  At all relevant times, Plaintiffs and other Class member were employed by the  Defendants within the meaning of the NYLL, §§2 and 651.   51.  Throughout their employment, Plaintiffs and other Class members were not paid  their proper wages for all hours worked, including those exceeding forty (40) hours per  workweek.    53.  Defendants knowingly and willfully operated their business with a policy of not  providing all non-exempt employees proper wage notice, at the date of hiring and annually  thereafter, as required under the NYLL.     54.  Due to the Defendants’ NYLL violations, Plaintiffs and other Class members are  entitled to recover from Defendants unpaid overtime, damages for unreasonably delayed  payments, reasonable attorneys’ fees, liquidated damages, statutory penalties, and costs and  disbursements of the action, pursuant to the NYLL.   VIOLATION OF THE FAIR LABOR STANDARDS ACT   VIOLATION OF THE NEW YORK LABOR LAW  