10.  Clay Road Furniture LLC and Furniture 4 Everyone LLC paid Plaintiff  Manolo Tayum straight time, not time and a half, for the hours he worked above forty  (40) during his employment with defendants.   11.  Mr. Manolo Tayum’s job duties included delivering and setting up  furniture and performing manual labor for defendant.   12.  The work performed by plaintiff is the primary type of work that the  company provides for its customers.   13.  The work performed  by Plaintiff is an essential part of the services  provided for Defendant’s Customers.     14.  Clay Road Furniture LLC and Furniture 4 Everyone LLC’s Drivers and  Manual Laborers rely on the companies for their work.     15.  Clay Road Furniture LLC and Furniture 4 Everyone LLC determined  where its Drivers and Manual Laborers worked and how they performed their duties.   16.  Clay Road Furniture LLC and Furniture 4 Everyone LLC sets Drivers and  Manual Laborer’s hours and requires them to report to work on time and leave at the end  of their scheduled shift.     17.  Clay Road Furniture LLC and Furniture 4 Everyone LLC’s Drivers and  Manual Laborers work exclusively for Clay Road Furniture LLC and Furniture 4  Everyone LLC during their employment.  Since they work between 9 and 10 hours a day,  as a practical matter, they cannot work anywhere else.   18.  Drivers and Manual Laborers are not permitted to hire other workers to  perform their jobs for them.   20.  Clay Road Furniture LLC and Furniture 4 Everyone LLC provides all of  the machinery, equipment and supplies that its Drivers and Manual Laborers use to  perform their work.  While they are working, the Drivers and Manual Laborers use Clay  Road Furniture LLC and Furniture 4 Everyone LLC’s equipment.  Clay Road Furniture  LLC and Furniture 4 Everyone LLC’s investment in the machines and equipment used by  its Drivers and Manual Laborers far exceeds any investment by plaintiff and putative  class members.   21.  Drivers and Manual Laborers do not provide any material portion of the  required equipment or any of the necessary products to perform their jobs.   22.  Drivers and Manual Laborers are paid based upon the hours they work.   They cannot earn a “profit” by exercising managerial skill, and they are required to work  the hours required by Clay Road Furniture LLC and Furniture 4 Everyone LLC each day.   The Drivers and Manual Laborers cannot suffer a loss of capital investment.  Their only  earning opportunity was based on the number of hours they were told to work, which is  controlled exclusively by Clay Road Furniture LLC and Furniture 4 Everyone LLC.   23.  Clay Road Furniture LLC and Furniture 4 Everyone LLC pays Drivers  and Manual Laborers in return for their labor.       24.  Clay Road Furniture LLC and Furniture 4 Everyone LLC decided to treat  its Drivers and Manual Laborers as independent contractors.   26.  Clay Road Furniture LLC and Furniture 4 Everyone LLC made large  capital investments in inventory, delivery trucks, equipment, tools and supplies in order  for it to sell furniture.  Its Drivers and Manual Laborers do not. Clay Road Furniture LLC  and Furniture 4 Everyone LLC incurs operating expenses like rent, payroll, marketing,  and insurance.  Its Drivers and Manual Laborers do not incur such operating expenses.   27.  Clay Road Furniture LLC and Furniture 4 Everyone LLC keeps records of  the hours it instructed its Drivers and Manual Laborers to work.  It also keeps records of  the amount of pay plaintiffs and putative class members receive.  Plaintiff and putative  class members were paid directly via weekly pay check issued to them from Clay Road  Furniture LLC and Furniture 4 Everyone LLC.   28.   Despite knowing of the FLSA’s requirements and that plaintiff and  putative class members regularly worked more than 40 hours in a workweek, Defendant  paid them straight time instead of time and a half for the overtime hours that they  worked.   29.  Plaintiff and putative class members seek unpaid overtime wages for the  three year period of time preceding the filing of this lawsuit.   30.  In addition to Manolo Tayum, defendants employed other Drivers and  Manual Laborers who worked over forty hours per week, were paid straight time instead  of time and a half for overtime hours worked, and were misclassified as independent  contractors.  These FLSA Class Members performed the job duties described above and  they were subjected to the same unlawful policies.  The FLSA Class Members are  similarly situated to Manolo Tayum.   32.  By failing to pay Plaintiff and the FLSA Class Members overtime at one  and one-half times their regular rates, Clay Road Furniture LLC and Furniture 4  Everyone LLC violated the FLSA.   33.  Clay Road Furniture LLC and Furniture 4 Everyone LLC owes Plaintiff  and the FLSA Class Members overtime wages equal to one-half their regular rates for  each overtime hour worked during the last three years.   34.  Clay Road Furniture LLC and Furniture 4 Everyone LLC knew, or  showed reckless disregard for whether, its failure to pay overtime violated the FLSA.   Their failure to pay overtime to Plaintiffs and the FLSA Class Members is willful.   35.  Clay Road Furniture LLC and Furniture 4 Everyone LLC owes Plaintiff  and the FLSA Class Members for an amount equal to all unpaid overtime wages as well  as liquidated damages.   36.  Plaintiff and the FLSA Class Members are entitled to recover all  reasonable attorneys’ fees and costs incurred in this action.  7.  Manolo Tayum was an  employee of Clay Road Furniture LLC and  Furniture 4 Everyone LLC.   8.  Manolo Tayum was not an independent contractor.  