15. Plaintiff re-avers and re-alleges Paragraphs 1 through 14 above, as though fully set forth    herein.   17.  29 U.S.C. §207(a)(1) states, inter alia, that “if an employer employs an employee for  more than 40 hours in any work week, the employer must compensate the employee for  hours in excess of 40 at the rate of at least one and one and half times the employee’s  regular rate...”   18. Plaintiff Tanti Hutapea (“Tanti”): Tanti worked for Defendants from August 2017 to  October 2019, and again from December 2019 through December 2020.    19. Tanti worked at the Iron Sushi located in downtown Miami, at 120 SE 3rd Ave., in Miami,  Florida. At all material times, Tanti was responsible for all tasks at the restaurant, including  dealing with customers, assisting with food preparation, cleaning tables, restrooms, and the  kitchen, and all other such tasks.    20. Tanti worked between 60 and 70 hours per week, every week, without breaks.    21. In 2017, she was paid $11/hour, starting in 2018, she was paid $12/hour, and from  December 2019 through December 2020, she was paid $14/hour. She was not paid time  and a half for any overtime hours.    22. Plaintiff Ferdenand Delos Santos (“Ferdenand”): Ferdenand worked for the Defendants  from 2014 through December 2020.    23. Ferdenand worked at the Iron Sushi located in Dadeland, at 9030 SW 72nd Pl., in Miami,  Florida, and sometime would work at the downtown Miami location on Friday.    24. Ferdenand was responsible for all tasks at the restaurant, including dealing with customers,  assisting with food preparation, cleaning tables, restrooms, and the kitchen, and all other  such tasks.    26. Through May 2020, Ferdenand was paid $12/hour. From May through December 2020, he  was paid $13/hour. He was not paid time and a half for any overtime hours.    27. Defendants’ failure, through today’s date, to pay amounts owed pursuant to the Fair Labor  Standards Act, is willful and intentional. Defendants knew of the overtime requirements of  the Act and either intentionally avoided or recklessly failed to investigate proper payroll  practices as they relate to the law. Accordingly, Plaintiffs are entitled, and specifically  request, liquidated damages in an amount equal to double the unpaid time and a half that  is due and owing.    28.   Further, upon information and belief, Defendants have employed other individuals during the  subject time period, and each of these individuals was not paid a full and proper overtime wage  as required by Federal law, and Plaintiff reserves the right to add additional persons to this  action plaintiffs, and to move this Court for certification of a collective action.  WHEREFORE, Plaintiffs, TANTI HUTAPEA and FERDENAND DELOS SANTOS,  respectfully request certification of a collective action of all current and former employees of  Defendants, IRON SUSHI LLC and MASAMITSU OCHI, and an award to Plaintiffs and the  collective of at least double all unpaid overtime wages as provided by the Fair Labor Standards  Act, as well as all reasonable attorney’s fees and litigation costs from the Defendants, IRON  SUSHI LLC and MASAMITSU OCHI, jointly and severally, pursuant to the Fair Labor Standards  Act, and judgment for all such other amounts as this Court may deem and equitable under the  circumstances.  30. Through the term of Plaintiffs’ employment, Defendants would keep and retain all tips received  (whether in cash or by credit card) for themselves. This was a complete retention by restaurant  ownership of tips earned by employees, without any accounting made therefor.    31. Occasionally and on their own timetable, Defendants would remit amounts to Plaintiffs  claiming that those amounts – which were clearly well short of amounts left as tips – were the  share of tips to which Plaintiffs were entitled.    32. Plaintiffs know of no tip pooling agreement (whether valid or invalid). When asked where the  rest of the money left as tips went, Plaintiffs were always told that it was needed “to pay taxes.”    33. Defendants have thus asserted dominion and control over Plaintiffs’ property (tip funds),  inconsistent with Plaintiffs’ ownership therein, and have taken and converted those tip funds  for their own purposes, improperly.    WHEREFORE, Plaintiffs, TANTI HUTAPEA and FERDENAND DELOS SANTOS,  respectfully request an award in their favor, and against Defendants, IRON SUSHI LLC and  MASAMITSU OCHI, in an amount equal to all tips improperly withheld, as well as reasonable  attorney’s fees and litigation costs, and all such other amounts as this Court may deem and  equitable under the circumstances.  CONVERSION   FEDERAL OVERTIME WAGE LAW VIOLATIONS  