44.  On or about October 1, 2014, Plaintiff was hired by Defendant Yoh as a Hair and  Make-up Artist.    45.  At all relevant times herein, Plaintiff remained employed as a Hair and Make-up  Artist.   46.  Immediately after hiring Plaintiff, Defendant Yoh placed Plaintiff “at CNBC as a  Hair & Make-up Artist” and was directed to “report to the following address on [her] first day of  employment: CNBC, NBC-900 Sylvan Avenue, Englewood Cliffs, NJ.”   47.  Upon reporting to the office of the CNBC Defendants in Englewood Cliffs, New  Jersey, Plaintiff was instructed to report to Defendant Guzman, the Production Manager at CNBC.   48.  Plaintiff was required to undergo a 3-month probation period with the CBNC  Defendants.   50.  Plaintiff successfully completed her probation at CNBC.   51.  During her first year of employment, Plaintiff was also allowed to work overtime  hours and was paid time and a half her hourly rate for most of the overtime hours she worked.   52.  Plaintiff worked an average of 5 hours of overtime during her first year of  employment with Defendants.    53.  After the completion of her first year of employment with Defendants, Plaintiff’s  work hours were decreased to 30 hours per week.   55.  However, Plaintiff consistently worked far over 30 hours each week and has not  received the proper compensation or benefits during the remainder of her employment until the  time of her unlawful termination on February 4, 2016.    56.  As admitted by Defendant Guzman, Defendants were “carrying over” the hours that  Plaintiff worked over 30 hours each week, so that Defendants continue to avoid properly  compensating Plaintiff.    57.  In fact, during her employment, Plaintiff repeatedly worked over 40 hours but was  not paid any overtime, especially after Defendants started “carrying over” the hours that Plaintiff  worked over 30 hours each week.   58.  At all relevant times herein, Plaintiff was assigned to work a fixed schedule.   59.  After the completion of the first year of employment with Defendants, Plaintiff’s  schedule became from 8:30 a.m. to 1:30 p.m.   60.  However, as described herein, Plaintiff repeatedly worked longer than the  designated schedule.   61.  Plaintiff and the other FLSA Collective Plaintiffs have been victims of a common  policy and plan perpetrated by Defendants that has violated their rights under the FLSA and the  NYLL by denying them proper pay and benefits.    63.  Defendants failed to provide Plaintiff and the other FLSA Collective Plaintiffs with  a Notice and Acknowledgement of Wage Rate and Designated Payday Hourly Rate plus Overtime.   64.  At all relevant times herein, Defendants’ unlawful conduct, policies, patterns and/or  practices described herein have been willful.   65.  As part of their ongoing business practices, Defendants have intentionally,  willfully, and repeatedly harmed Plaintiff and the other FLSA Collective Plaintiffs by engaging in  a pattern, practice, and/or policy of violating the FLSA and the NYLL, as described herein.  This  ongoing policy, pattern or practice includes, but is not limited to:  a. CNBC Defendants unlawfully classified Plaintiff and the other FLSA Collective  Plaintiffs as independent contractors as opposed to employees;  b. CNBC Defendants failed to adopt anti-discrimination and anti-harassment policies  applicable to Plaintiff and the other FLSA Collective Plaintiffs; and  c. CNBC Defendants failed to keep accurate and adequate records of hours worked  by Plaintiff and the other FLSA Collective Plaintiffs as required by the FLSA and  the NYLL.   66.  Upon information and belief, Defendants’ unlawful conduct described herein has  been pursuant to a corporate policy or practice of minimizing labor costs by knowingly  misclassifying certain employees as independent contractors in order to deny them proper  compensation and benefits in violation of the FLSA and the NYLL.   68.  Defendants’ unlawful conduct, as set forth herein, has been intentional, willful, and  in bad faith, and has caused significant damages to Plaintiff and the other FLSA Collective  Plaintiffs.  Whistleblower Claims   69.  Plaintiff, who has over a decade of experience working as a Hair and Make-up  Artist for some the biggest agencies and television personalities, is highly experienced and  qualified in her field of work.    70.  On or about June 8, 2015, and again on June 13, 2015, due to unsafe and negligently  maintained conditions at the workplace, Plaintiff burnt her right and left hands because of  unattended equipment.   71.  Since on or about June 2015, Plaintiff repeatedly complained to her direct  supervisor Guzman about the different safety risks and violations at the workplace and the  unattended and mishandled equipment.    72.  CNBC Defendants’ violations could easily cause bodily injuries to employees and  guests, in the same manner that Plaintiff was injured, or even cause a fire.   73.  In fact, immediately following the injuries she sustained, Plaintiff contacted  Defendant Guzman and told her that she burnt her hands and asked to send an email to all the  artists telling them to pay attention with their equipment or to take the necessary measures to avoid  a catastrophic incident.    75.  Such retaliatory actions in ignoring Plaintiff and reducing her work hours continued  until her unlawful termination on February 4, 2016.   76.  Furthermore, during her employment with Defendants, Plaintiff worked primarily  from the New York Mercantile Exchange (“NYMEX”) building.   77.  Upon information and belief, the NYMEX is a commodity futures exchange owned  and operated by CME Group of Chicago, and located at One North End Avenue in Brookfield  Place in the Battery Park City section of Manhattan, New York City.   78.  At the time Plaintiff started working from the NYMEX location, the building was  undergoing a construction project.   79.  The health, safety and working conditions at NYMEX were very poor due to the  ongoing construction.    80.  For example, there were unattended dangerous equipment and tools, and the air  quality was very harming, dangerous and unhealthy.   81.  Plaintiff and the other FLSA Collective Plaintiffs were assigned to work in very  close proximity to the construction area, which was filthy, unattended, unsecured, unhealthy,  dangerous, and creating an extremely dangerous and poor air quality to the workers and guests.   82.  No precautionary or safety measures were taken by Defendants to ensure the  workers’ safety and well-being.    83.  In fact, Defendants placed, or allowed the placement, of fans on the floor where  Plaintiff and other FLSA Collective Plaintiffs were working, causing Plaintiff and others to breathe  more dust and harmful air particles.    85.  As a proximate cause of Defendants’ negligent and wrongful actions that  endangered Plaintiff’s health and well-being, Plaintiff was forced to go to Bellevue Hospital  Center approximately four (4) weeks after she started working at the NYMEX building.    86.  On June 4, 2015, Plaintiff went to the emergency room due to breathing problems  and pains in her respiratory organs, causing her a severe asthma attack.   87.  Plaintiff requested from Guzman to inquire from Duffy whether Plaintiff’s medical  expenses and costs would be covered by Defendants since her injuries were caused on the job and  due to Defendants’ negligence.   88.  However, Defendants, including Duffy and Guzman, refused to cover Plaintiff’s  medical expenses and denied Plaintiff the right to apply for Worker’s Compensation benefits.   89.  Plaintiff is still having difficulties breathing as a consequence of the working  conditions she was compelled to work in.   90.  Plaintiff was not the only person to get sick because of the air quality at the  workplace.    91.  Upon information and belief, the television personality that Plaintiff was working  on, Jackie DeAngeles, also got sick and had to go to the hospital for treatment.    93.  When Plaintiff complained to Defendant Guzman about the health and safety  violations and the horrible air quality, Defendants refused and/or failed to take any remedial action,  and instead Guzman stated to Plaintiff, “What do you want me to do. You still have to work there.”   94.  Edmond Edmundo and Jackie DeAngeles both witnessed Plaintiff complaining to  Defendant Guzman.    95.  Upon her return from the hospital in or about June 10, 2015, Plaintiff and other  FLSA Collective Plaintiffs were finally transferred to the “pit” of the NYMEX building, which is  where all the brokers work from.   96.  However, almost immediately after complaining of the health and safety violations  until her unlawful termination, and in retaliation to the repeated complaints that she made,  Defendants stopped approving Plaintiff’s requests to take time off and restricted her ability to  perform other work.    97.  Plaintiff, who was supposed to be an independent contractor, had to cancel her  business trips several times causing her significant financial losses.    98.  In further retaliation to Plaintiff’s complaints, Defendants also reduced Plaintiff’s  work hours and gave Plaintiff’s hours to another hair and make-up artist.    Color Discrimination in Violation of Administrative Code § 8-107, et seq.  Brought on behalf of Plaintiff  182.  Plaintiff repeats, reiterates, re-alleges and incorporates by reference all prior  allegations in all preceding paragraphs as though fully set forth herein.   183.  Defendants violated Administrative Code § 8-107, et seq., by engaging in,  perpetuating and permitting supervisory and decision making employees to engage in  discriminatory employment practices in which Plaintiff’s skin color was the motivating, if not the  only factor.  184.  As a result of Defendants’ aforementioned conduct, Plaintiff has suffered, and  continues to suffer, loss of past and future wages and benefits, mental anguish, severe emotional  distress, anxiety, loss of enjoyment of life, and other monetary damages connected with  Defendants’ aforementioned violations.  185.  Plaintiff continues to suffer and to incur additional damages by reason of the  foregoing.  186.  As a result of the outrageous and blatantly discriminatory conduct of Defendants,  with such conduct that contravenes public policies and statutes, Plaintiff is entitled to punitive  damages.   Misclassification of Workers   Race Discrimination in Violation of Executive Law § 296, et seq.  Brought on behalf of Plaintiff  162.  Plaintiff repeats, reiterates, re-alleges and incorporates by reference all prior  allegations in all preceding paragraphs as though fully set forth herein.   163.  Defendants violated Executive Law §296, et seq., by engaging in, perpetuating and  permitting supervisory and decision making employees to engage in discriminatory employment  practices in which Plaintiff’s race was the motivating, if not the only factor.  164.  As a result of Defendants’ aforementioned conduct, Plaintiff has suffered, and  continues to suffer, loss of past and future wages and benefits, mental anguish, severe emotional  distress, anxiety, loss of enjoyment of life, and other monetary damages connected with  Defendants’ aforementioned violations.  165.  Plaintiff continues to suffer and to incur additional damages by reason of the  foregoing.  166.  As a result of the outrageous and blatantly discriminatory conduct of Defendants,  with such conduct that contravenes public policies and statutes, Plaintiff is entitled to punitive  damages.   Violation of the New York Labor Law (“NYLL”)  Failure to Provide Itemized Wage Statements  Brought on behalf of Plaintiff and FLSA Collective Plaintiffs  158.  Plaintiff repeats, reiterates, re-alleges and incorporates by reference all prior  allegations in all preceding paragraphs as though fully set forth herein.   159.  Upon information and belief, Defendants knowingly and intentionally failed to  provide timely, accurate, and complete itemized wage statements including, inter alia, hours  worked and taxes withheld, to Plaintiff and the FLSA Collective Plaintiffs in violation of the 