10.  When the Plaintiff REBECCA WOLCOTT began working with the  Defendants she was told that she would be paid $10.00 per hour for all work and  Plaintiff agreed to be hired at that rate.   12.  The Defendant LISA HERRGUTH were at all times material hereto, an  owner, officer, manager, and/or employee of the Defendant AIDING HEARTS.   13.  The Defendant LISA HERRGUTH exercises significant control over  the operations of the Defendant AIDING HEARTS.  She had and has supervisory  duties, participates in and/or sets employee policies, and, at all times, acted in the  interest of the Defendant AIDING HEARTS in relation to the Plaintiff REBECCA  WOLCOTT and similarly situated persons.   14.  Each of the Defendants were individually, jointly, and/or alternatively  an employer of the Plaintiff REBECCA WOLCOTT and similarly situated persons.   15.  Defendants operated as a single enterprise or alternatively, some  combination of these Defendants operated as a single enterprise.   16.  At all times, federal and Michigan laws required that the Defendants  compensate the Plaintiff REBECCA WOLCOTT and similarly situated persons at  wage rates in amounts that met or exceeded the minimum wage rate.   17.  Under the Fair Labor Standards Act, the federal minimum wage rate is  $7.25 per hour.     19.  Defendants failed to pay Plaintiff REBECCA WOLCOTT and  similarly situated persons, for all hours worked and regularly paid her less than the  amount of wages she earned.        20.  During and after her employment with the Defendants, Plaintiff  REBECCA WOLCOTT requested that she be paid for all hours worked.   21.  Despite her requests, the Defendants refused to compensate Plaintiff  REBECCA WOLCOTT for all hours worked.   22.  Throughout the time of her employment, the Defendants failed to   maintain proper records of their employees’ work time and had a policy or practice,  which applied to all employees, of not investigating disputed hours and not paying  employees’ for those hours.   23.  As a result of not paying employees’ for all hours worked, Defendants  failed to pay Plaintiff REBECCA WOLCOTT and similarly situated persons at the  federal or state minimum wage rates.   24.  During her employment, Plaintiff REBECCA WOLCOTT and  similarly situated persons were required to travel to several different patient homes  located throughout central Michigan within a single day.     26.  Throughout the time that she worked for the Defendants, Plaintiff  REBECCA WOLCOTT and similarly situated persons were required to use their  own vehicles to drive clients to and from client appointments, meetings, errands, etc.    27.  During her employment with the Defendants, Plaintiff REBECCA  WOLCOTT requested that she be reimbursed for gas and mileage for travel to and  from work assignments.   28.  Despite her requests, the Defendants refused to reimburse Plaintiff  REBECCA WOLCOTT for gas or mileage to and from her work assignments.    29.  Throughout the time of her employment, the Defendants maintained a  policy, which applied to all employees, of not paying employees’ gas or mileage for  travel to, from, and between work assignments.   30.  As a result of Defendants’ policy, Plaintiff REBECCA WOLCOTT and  similarly situated persons incurred the costs of gas and mileage, which are a  necessary business expense of  Defendants operations.   31.  As a result of not reimbursing employees’ for gas and mileage,  Defendants failed to pay Plaintiff REBECCA WOLCOTT and similarly situated  persons at the federal or state minimum wage rates.   33.  Defendants never reimbursed Plaintiff REBECCA WOLCOTT or  similarly situated persons for the cost of the supplies.   34.    As a result of Defendants’ policy, Plaintiff REBECCA WOLCOTT  and similarly situated persons incurred the cost of supplies, which are a necessary  business expense of  Defendants operations.   35.  As a result of not reimbursing employees’ for necessary supplies,  Defendants failed to pay Plaintiff REBECCA WOLCOTT and similarly situated  persons at the federal or state minimum wage rates.   36.  Under the Fair Labor Standards Act and the Michigan Workforce  Opportunity Wage Act, Defendants are required to pay Plaintiff REBECCA  WOLCOTT and similarly situated persons compensation not less than one and one- half times the employee’s regular rate of pay for all hours worked in excess of forty  (40) hours during a single workweek.     37.  Throughout the time that she worked for the Defendants, Plaintiff  REBECCA WOLCOTT and similarly situated persons would be required to work  more than forty (40) hours in a workweek and were not paid at the required overtime  rates.   39.  When travel time is included within her workweek, Plaintiff  REBECCA WOLCOTT and similarly situated persons, regularly worked more than  40 hours during a workweek.   40.  Despite her requests, the Defendants refused to pay the Plaintiff  REBECCA WOLCOTT for travel time and as a result, failed to pay Plaintiff and  similarly situated persons compensation not less than one and one-half times the  employee’s regular rate of pay for all hours worked in excess of forty (40) hours  during a single workweek.   41.  In violation of the federal and Michigan law, Defendants failed to pay  Plaintiff REBECCA WOLCOTT and similarly situated individuals, for all hours  worked and at proper wage rates for overtime hours worked.  54.  Plaintiff incorporates by reference paragraphs 1 through 52 as fully  stated herein.   55.  At all times relevant to this action, Plaintiff REBECCA WOLCOTT  and similarly situated persons were Defendants’ employees within the meaning of  the Fair Labor Standards Act 29 U.S.C §201 et. seq.   57.  In violation of the Fair Labor Standards Act 29 U.S.C §201 et. seq.,  Defendants failed to pay Plaintiff REBECCA WOLCOTT and similarly situated  persons at the federal minimum wage rate.         58.  Defendants engaged in a pattern or practice of failing and/or refusing  to compensate Plaintiff REBECCA WOLCOTT and similarly situated persons at  federal minimum wage rates   59.  Defendants knowingly, intentionally, and willfully failed to pay  REBECCA WOLCOTT and similarly situated persons at the federal minimum wage  rate.   60.  As a result of Defendants conduct Plaintiff REBECCA WOLCOTT and  similarly situated persons are entitled to an award of damages including but limited  to compensatory damages, liquidated damages, punitive damages, costs, attorneys  fees, prejudgment interest and other damages as followed by law and equity.  61.  Plaintiff incorporates by reference paragraphs 1 through 59 above as  though fully stated herein.   63.  At all times relevant to this action, Defendants were the employer of  the Plaintiff REBECCA WOLCOTT and similarly situated persons within the  meaning of the Fair Labor Standards Act, 29 U.S.C. § 201 et. seq.     64.  In violation of the Fair Labor Standards Act, 29 U.S.C. § 201 et. seq.,  Defendants failed to pay Plaintiff REBECCA WOLCOTT and similarly situated  persons at the federal overtime rate of one and one-half times their normal rate of  pay when working more than forty (40) hours during a week.   65.  Defendants engaged in a pattern or practice of failing and/or refusing  to compensate Plaintiff REBECCA WOLCOTT and similarly situated persons at the  federal overtime rate of one and one-half times their normal rate of pay when  working more than forty (40) hours during a week.   66.  Defendants knowingly, intentionally, and willfully failed to pay  Plaintiff REBECCA WOLCOTT and similarly situated persons at the federal  overtime rate of one and one-half times their normal rate of pay when working more  than forty (40) hours during a week.    68.  Plaintiff incorporates by reference paragraphs 1 through 66 above as  fully stated herein.   69.  At all times relevant to this action, Plaintiff and similarly situated  persons were Defendants’ employees within the meaning of the Michigan  Workforce Opportunity Wage Act, Mich. Comp. Laws § 408.411 et seq.   70.  At all times relevant to this action, Defendants were the employer of  the Plaintiff and similarly situated persons within the meaning of the Michigan  Workforce Opportunity Wage Act, Mich. Comp. Laws § 408.411 et seq.   71.  In violation of the Michigan Workforce Opportunity Wage Act, Mich.  Comp. Laws § 408.411 et seq., Defendants failed to pay plaintiff REBECCA  WOLCOTT and similarly situated persons at the Michigan minimum wage rate for  all hours worked.     72.    Defendants engaged in a pattern or practice of failing and/or refusing  to compensate Plaintiff REBECCA WOLCOTT and similarly situated persons at  Michigan minimum wage rates.   74.  As a result of Defendants’ conduct Plaintiff REBECCA WOLCOTT  and similarly situated persons are entitled to an award of damages including but  limited to compensatory damages, liquidated damages, punitive damages, costs,  attorneys’ fees, prejudgment interest and other damages as followed by law and  equity.  75.  Plaintiff incorporates by reference paragraphs 1 through 73 above as  though fully stated herein.   76.  At all times relevant to this action, Plaintiff REBECCA WOLCOTT  and similarly situated persons were Defendants’ employees within the meaning of  the Michigan Workforce Opportunity Wage Act, Mich. Comp. Laws § 408.411 et  seq.      77.  At all times relevant to this action, Defendants were the employer of  the Plaintiff REBECCA WOLCOTT and similarly situated persons within the  meaning of the Michigan Workforce Opportunity Wage Act, Mich. Comp. Laws §  408.411 et seq.     79.  Defendants engaged in a pattern or practice of failing and/or refusing  to compensate Plaintiff REBECCA WOLCOTT and similarly situated persons at the  state’s overtime rate of one and one-half times their normal rate of pay when working  more than forty (40) hours during a week.   8.  The Defendant AIDING HEARTS is, and was engaged in the business  of providing in-home care to clients.   80.  Defendants knowingly, intentionally, and willfully failed to pay  Plaintiff REBECCA WOLCOTT and similarly situated persons at the Michigan  overtime rate of one and one-half times their normal rate of pay when working more  than forty (40) hours during a week.    81.  As a result of Defendants’ conduct, Plaintiff REBECCA WOLCOTT  and similarly situated persons are entitled to an award of damages including but not  limited to compensatory damages, liquidated damages, punitive damages, costs,  attorneys’ fees, prejudgment interest and other damages as allowed by law and  equity.  9.  In the spring and summer of 2018, Plaintiff REBECCA WOLCOTT  was employed by the Defendants as a home health aide.   FAIR LABOR STANDARDS ACT   (Overtime)   FAIR LABOR STANDARDS ACT   (Minimum Wage)   WORKFORCE OPPORTUNITY WAGE ACT  (Minimum Wage)   WORKFORCE OPPORTUNITY WAGE ACT   (Overtime)  