10.  Plaintiff Arnicia was employed by Defendants from September 12, 2018 until  March 2019.   11.  Plaintiffs both signed a document entitled “Employee Policies and  Procedures.”   12.  The Policies and Procedures state that Plaintiffs’ pay would be “$5- checkouts/stayovers, $2.50-part cleaning, $1 extra-stripped $10 cart stock  5t, $5 cart stock 4 and under $10 any hourly” referring to cleaning windows,  chairs, conference rooms, etc.     13.  The Policies contained a section titled, Workplace Policies which sets forth  the expectation that the Plaintiffs were expected to be present during their  scheduled working times.     14.  Generally, Plaintiffs began work at 8:00 a.m. and left at 4:00 p.m.  However,  there were days that the Plaintiffs worked until 5:00 or 6:00 p.m.    15.  Plaintiffs were not required to clock in/out or provide any other type of  record of when they arrived or left.   17.  Defendants failed to keep records of the employees’ hours worked or regular  rate for any week in which overtime is worked as required by 29 C.F.R.  §516.2-516.5.     18.  Plaintiffs were not paid the required minimum wage.   19.  Defendants compensation of Plaintiffs and similarly situated employees  violated the minimum wage provisions of the FLSA.  Therefore, Plaintiffs and  similarly situated employees are entitled to minimum wage for all hours  worked.      20.  Defendants recklessly failed to investigate whether the manner in which  Plaintiffs and similarly situated employees were being paid the minimum  wage in compliance with the FLSA.   22.  Since Defendants are in possession of pay records, there may be additional  payments that violate the minimum wage overtime provision but cannot be  identified at this time.    WHEREFORE, Plaintiffs, on behalf of themselves and all other similarly  situated employees, seek judgment against the Defendants as follows:  a.  That this Court certify that action as a collection action pursuant to 29  U.S.C. §216(b);  b.  Judgment against Defendants for an amount equal to Plaintiffs’ and  similarly situated employees’ wages at the applicable minimum wage  rate;  c.  An award of liquidated damages in the amount equal to the award of  damages pursuant to 29 U.S.C. §216(b);  d.  Judgment that Defendants’ violations were willful;  e.  An award of reasonable attorney’s fees and costs incurred by Plaintiffs  and similarly situated employees in bringing this action; and  f.  All such further relief as the Court deems just and equitable.    23.  There are times where the Plaintiffs and other similarly situated employed  worked more than 40 hours in a work week and were not paid time and a  half their regular rate.    WHEREFORE, Plaintiffs, on behalf of themselves and all other similarly  situated employees, seek judgment against the Defendants as follows:  a.  That this Court certify that action as a collection action pursuant to 29  U.S.C. §216(b);  b.  Judgment against Defendants for an amount equal to Plaintiffs’ and  similarly situated employees’ overtime wages at time and one-half  their regular rate;  c.  An award of liquidated damages in the amount equal to the award of  damages pursuant to 29 U.S.C. §216(b);  d.  Judgment that Defendants’ violations were willful;  e.  An award of reasonable attorney’s fees and costs incurred by Plaintiffs  and similarly situated employees in bringing this action; and  f.  All such further relief as the Court deems just and equitable.    24.  Margarita was injured on the job on March 5, 2019.   26.  On the day Margarita was scheduled to return to work, she was still in too  much pain to return to work so she sent a text to her supervisor advising that  she would not be able to come in.   27.  Margarita received a text back that she was fired because she couldn’t work  her schedule and hadn’t responded to a prior text.    WHEREFORE, Plaintiff Margarita seeks judgment for lost wages, benefits,  front pay and other remuneration; all other compensatory damages allowable  under law; emotional distress damages, punitive damages, prejudgment and post  judgment interest and any other relief the Court deems just and proper.    9.  Plaintiff Margarita was employed by Defendants from December 20, 2017  until March 2019.   FLSA MINIMUM WAGE CLAIM  (Individual and collective claim)  The foregoing paragraphs are hereby incorporated by reference into this  Count.   VIOLATION OF FLA.STAT. §440.205  (Individual claim of Margarita Isaac)  