17.  At all times for the three years prior to the filing of the Complaint in  this matter, Defendants have employed female entertainers at its nightclubs  located throughout the United States.   18.  At all times for the three years prior to the filing of the instant  complaint, Defendants have categorized all entertainers working at the  nightclubs as “independent contractors” or as “employees” but failed to pay  any wages.    19.              At all times for the three years prior to the filing of the instant  complaint, Defendants have not required entertainers to have any specialized  training or background.  Defendants have, however: established specific  work schedules for entertainers.   20.  Defendants have required entertainers to dance at specified times and  in a specified manner on stage and for customers.    22.  Defendants have set the price entertainers were allowed to charge for  dances.    23.  Defendants have required entertainers to attend meetings at  Defendants’ business.   24.  Defendants have financed all advertising and marketing efforts  undertaken on behalf of the club;    25.  Defendants have made capital investments in the facilities,  maintenance, sound system, lights, food, beverage and inventory;    26.  Defendants have required and made all hiring decisions regarding  waitstaff, security, entertainer, managerial and all other employees at the  night clubs.    28.  At all times for the three years prior to the filing of the instant  complaint, Defendants have required entertainers, including Named  Plaintiffs and all others similarly situated, to pay a specific amount, often  referred to as a “tip out” or a “bar fee” in order to work on any given shift.     29.             The specific amount entertainers, including Named Plaintiffs, were  required to pay has varied over the last three years, but a single schedule has  been in place for all entertainers at any given time.     30.  The required bar fee or tip out the Named Plaintiffs has paid generally  has been at least $60 per shift.     32.  Named Plaintiffs have been subject to a variety of these fees and  fines.    33.  The fees and fines  described in ¶¶ 28-32 constitute unlawful  “kickbacks” to the employer within the meaning of the Fair Labor Standards  Act, and Plaintiffs are entitled to restitution of all such fees and fines.   34.  Named Plaintiffs worked over forty hours in some weeks each worked  for Defendants.    35.  Named Plaintiffs and all others similarly situated were also required to  attend mandatory meetings at Defendants’ place of business, but were not  paid for their attendance at those meetings.    37.  Instead, Plaintiffs and all other similarly situated only source of work  related income were gratuities they receive from customers.   38.  Because Defendants did not pay Plaintiffs and all other similarly  situated any wages whatsoever, Defendants did not pay Plaintiffs and all  other similarly situated one-and-a-half times their regular rate of pay when  Plaintiffs and others similarly situated worked over forty hours in a given  workweek.    39.  As noted above this is the second suit over FLSA minimum wage and  overtime violations thus, Defendants knew, or showed reckless disregard for  the fact that they misclassified these individuals as independent contractors,  and accordingly failed to pay these individuals the minimum wage and failed  to pay overtime at the required rate under the FLSA.   41.  On information and belief Defendants failed to maintain records of the  number of hours worked by Plaintiffs and others similarly situated. 