10.  Plaintiff King began working for Defendant IBBI at the Knoxville Plasma location  on or around July 18, 2013.   11.  At the time of hiring Ms. King, Defendant told her she would become a Training  Coordinator.  This required, however, that she first train and work as a “floater” in different  positions at Knoxville Plasma.  After spending over a year as a floater, Ms. King was given the  title and position of Training Coordinator in January 2015.      12.  Ms. King worked exclusively in the position of Training Coordinator from January  2015 until May 2017.  As a Training Coordinator, Ms. King’s job duties included training all new  hires on the company’s Standard Operating Procedures (SOPs); conducting training audits and  assessments on employees; and conducting re-training for employees as needed due to errors and  accidents, changes in the company’s SOPs, or company-announced variances from the SOPs.  Ms.  King also implemented annual trainings for all staff.  All the trainings that Ms. King performed or  implemented were developed by IBBI’s corporate managers, and she followed the training  procedures, protocol, and curriculum as required by IBBI.     13.  As Training Coordinator, Ms. King did not customarily or regularly direct the work  of two or more other employees.  She did not have the authority to hire or fire employees or to  make suggestions or recommendations that are given particular weight with regard to hiring, firing,  4  or changing the status of other employees. The primary duties of a Training Coordinator do not  involve the management of the company.     14.  Ms. King’s primary duties as Training Coordinator did not include the exercise of  discretion and independent judgment with respect to matters of significance.  On the contrary, she  carried out specific tasks as required of her by her supervisors and IBBI’s corporate office.     15.  The entire time that Ms. King worked exclusively as Training Coordinator, from  2015 until May 2017, IBBI paid her an hourly wage, including overtime wages at 1.5 times her  normal hourly rate for any work done in excess of 40 hours per workweek.  The entire time that  Ms. King worked for IBBI before being appointed Training Coordinator, from July 2013 until  early 2015, IBBI paid Ms. King an hourly wage, including overtime wages at 1.5 times her normal  hourly rate.    16.  In May 2017, Ms. King was given a new position as a Quality Assurance (QA)  Coordinator in the Knoxville Plasma location.  Ms. King was told that she would continue to do  some Training Coordinator duties, assisting the one other Training Coordinator at that location,  until a permanent replacement for her was hired.     17.  Ms. King’s duties as QA Coordinator primarily involved reviewing and auditing  the plasma center’s practices to ensure that the center was operating in compliance with SOPs and  other corporate policies and mandates.  Ms. King’s daily duties included such tasks as conducting  morning “rounds” to check whether the center was properly staffed, that equipment was properly  set up, that appropriate temperatures were maintained, that necessary supplies were stocked, and  that log sheets were in place; running reports and/or reviewing reports that were run by managers  of the center to ensure that all paperwork was prepared in compliance with SOPs and other  company directives; and reviewing and/or preparing additional paperwork to ensure compliance  5  with SOPs and company directives.  Other weekly or monthly tasks that QA Coordinators perform  include such things as assessing equipment and storage conditions, reviewing the shipment process  to make sure all policies were properly followed, and completing additional paperwork.      18.  As QA Coordinator, Ms. King did not customarily or regularly direct the work of  two or more other employees.  She did not have the authority to hire or fire employees or to make  suggestions or recommendations that are given particular weight regarding hiring, firing, or  changing the status of other employees. The primary duties of a QA Coordinator do not involve  the management of the company.     19.  Ms. King’s primary duties as QA Coordinator did not include the exercise of  discretion and independent judgment with respect to matters of significance.  On the contrary, she  carried out specific tasks as required by her supervisors and IBBI’s corporate office.  Her job was  to assess whether corporate-mandated policies were being followed.     20.  As QA Coordinator, Ms. King did not have authority to formulate or interpret the  SOPs or other company polices.  She made sure policies were executed as she was instructed by  the corporate office.  She did not have the authority to waive or deviate from any policies.  She did  not have the authority to discipline or penalize employees if they did not comply with corporate  policies; instead, she reported any errors or deviations she found to her supervisors.   21.  Defendant employs at least two QA Coordinators at each of its plasma centers in  the nation.  Upon information and belief, each whole blood center also employs QA Coordinators.   The QA Coordinator job duties were approximately the same for each QA Coordinator.     22.  From May 2017 until the end of 2017, during the first few months that Ms. King  worked as a QA Coordinator, she and the one other QA Coordinator at Knoxville Plasma were  6  paid an hourly wage for all hours worked and were paid overtime wages at 1.5 times their normal  hourly rate for any hours they officially reported that were in excess of 40 hours per workweek.    23.  In order to complete their job duties, Ms. King and the other QA Coordinator  routinely worked overtime hours.  On numerous occasions in 2017, Knoxville Plasma’s Center  Manager, Candice Thompson, complained to Ms. King and the other QA Coordinator that they  were “working too much overtime” and that the corporate office was unhappy about this.  Ms.  King and the other QA Coordinator often worked “off the clock” so they could complete their job  duties without upsetting their supervisors, and their supervisors were aware of this.     24.  At the end of 2017, Ms. Thompson informed Ms. King and the other QA  Coordinator that, effective 2018, they would become “salaried” employees.  While their base  annual salaries were increased, they were told that they would no longer receive overtime wages  for hours worked in excess of 40 hours per week.  The reason given to them for this change was  because they were working too much overtime.     25.  The job duties of Ms. King and the other QA Coordinator did not change between  2017 and 2018, despite their classification being changed from “hourly” to “salaried.”     26.  At the time that Ms. King and the other QA Coordinator became “salaried”  employees, their supervisor, the Regional QA Manager, was paid hourly and still received  overtime wages.  She was switched to “salaried” pay sometime thereafter.     27.  In addition to Ms. King and the other “salaried” QA Coordinator, Knoxville Plasma  employed two other full-time QA Coordinators for short durations at different times in 2018 and  2019.  These other two QA Coordinators were classified as “hourly” employees and were eligible  to receive overtime pay.  The “hourly” QA Coordinators had the same QA job duties as the  7  “salaried” QA Coordinators.  All were supervised by the Regional QA Manager, as well as the  Center Manager.     28.  In addition to her QA Coordinator job duties, Ms. King continued to perform  Training Coordinator job duties.  During the entire time that Ms. King worked at Knoxville Plasma,  the center never hired another permanent “backup” Training Coordinator to take Ms. King’s place.   Therefore, she continued to perform Training Coordinator duties to assist the other Training  Coordinator.  From May 2017 until the end of her employment in October 2019, Ms. King spent  an average of approximately 25 percent of her work time performing Training Coordinator duties.     29.  The other Training Coordinator who worked throughout the time that Ms. King  worked at Knoxville Plasma continued to be paid on an hourly basis and was eligible to receive  overtime wages for working more than 40 hours in a workweek.  This Training Coordinator did  not generally work overtime hours, however.  Instead, Ms. King, who was considered “salaried”  beginning in 2018, often was expected to come into work early and stay late to complete both her  QA and Training Coordinator duties, and she was not paid any overtime wages for doing so.     30.  Both Ms. King and the other “salaried” QA Coordinator at Knoxville Plasma  regularly worked more than 40 hours per week after they were changed to “salaried” employees  and did not receive overtime wages.  Defendant was aware they worked these long hours, as they  often complained to their Center Manager and the Regional QA Manager about how long it was  taking for them to accomplish their required tasks and that they were concerned that this would  affect the quality of their work   Ms. King, in particular, complained that she was not getting paid  for all the work she was doing.  She regularly worked 10 to 12-hour shifts, sometimes up to five  times per week and occasionally on weekends.     8   31.  On a Friday in August 2018, Ms. King’s workload was so much that she needed to  work at least 14 hours that day and come in on Saturday to complete her work.  Both the other QA  Coordinator and the other Training Coordinator were on leave that day, so Ms. King had to perform  all QA and all Training duties.  Defendant had recently announced an SOP variance that it expected  the center to implement the next day, requiring Ms. King to train all employees on the new policy  right away.     32.  On that day in August 2018, after first complaining in person to Ms. Thompson,  Ms. King sent an e-mail to the Regional Quality Assurance Manager, Angie Long.  In that e-mail,  Ms. King complained that she had more work than could possibly be completed in one day, that  she was having to routinely work several extra hours to complete her workload, and that she was  required to stay late without extra compensation to do the work of the Training Coordinator.  She  also expressed concern about the quality of her work in light of the time she had to complete it.   Ms. King sent this e-mail to Ms. Long on the recommendation of the Center Manager Ms.  Thompson.     33.  On the following Monday, Ms. Long requested to meet with Ms. King.  She  expressed that she was upset about Ms. King’s e-mail and had forwarded it to Ginger Manie, the  Regional QA Director who worked in Defendant’s corporate office in Memphis.  Ms. Long told  Ms. King that Ms. Manie was “furious” about the e-mail and that Ms. Long had to talk Ms. Manie  out of taking action against Ms. King.   34.  After August 2018, Ms. King continued to work on Training Coordinator duties in  addition to QA duties and continued to work overtime hours in order to accomplish her job duties.   In 2019, Ms. Thompson decided to train two employees as Training Coordinator, in the hopes of  hiring one of them permanently to take the position still being performed by Ms. King.  However,  9  Defendant ultimately decided not to hire either as Training Coordinator, which resulted in Ms.  King still having to work two job positions.     35.  After August 2018, the other “salaried” QA Coordinator at Knoxville Plasma, who  did not have Training Coordinator duties, also continued to routinely work overtime hours.      36.  Like all other employees of IBBI, Ms. King used a payroll app set up by IBBI that  showed a list of all employees and whether they were classified as “hourly” or “salaried.”  Ms.  King observed through this app that some of IBBI’s QA Coordinators around the country were  classified as “hourly” and some as “salaried.”  Upon information and belief, “salaried” employees  are not paid overtime.   37.  Upon information and belief, although the full-time Training Coordinators at  Knoxville Plasma have been classified as “hourly” employees, Defendant classifies some of its  Training Coordinators in other centers as “salaried” and does not pay them overtime.   38.  The FLSA requires covered employers, such as Defendant, to compensate non- exempt employees at a rate of not less than 1.5 times their regular rate of pay for work performed  in excess of 40 hours per workweek.    39.  The primary job duties of QA Coordinators employed by Defendant are such that  they should be paid overtime wages for all hours worked over 40 in a workweek.   40.  The primary job duties of Training Coordinators employed by Defendant are such  that they should be paid overtime wages for all hours worked over 40 in a workweek.     41.  During the applicable statutory period, Ms. King’s primary job duties while  working for Defendant, which included both QA Coordinator and Training Coordinator duties,  were such that she should have been paid overtime wages for all hours worked over 40 in a  workweek.    10   42.  Upon information and belief, Defendant has a common policy or plan of classifying  its employees, and particularly its QA Coordinators and Training Coordinators, as “salaried” or  “hourly” depending on whether they regularly work overtime and without regard to whether their  job duties actually qualify them as exempt from overtime compensation.  As a result, several IBBI  employees who should be paid overtime are not being paid in compliance with the FLSA.       43.  In September 2019, Defendant scheduled its Regional Quality Assessment and  Development Specialist, Marlene Downey-Waterstradt, to conduct an evaluation on Ms. King.   This was Ms. King’s first formal evaluation by the corporate office.     44.  Ms. King’s Center Manager and Regional QA Manager, both of whom work from  the Knoxville Plasma center with Ms. King on a daily basis, had never counseled Ms. King about  any performance-related concerns.  At the time of Ms. King’s evaluation, she had been working  as QA Coordinator for over two years.  Defendant had previously selected her as qualified to  conduct year-end corporate audits and had once chosen her to go to another of its plasma centers  to temporarily fill in for a QA Coordinator.       45.  In her evaluation of Ms. King, however, Ms. Downey-Waterstradt indicated several  areas of concern.  One of those areas of concern had to do with alleged mistakes in Ms. King’s  personal QA training planner, in which she recorded the trainings that she completed throughout  the year.  Ms. King kept the planner for her use only, to assist her in making sure she completed  all required trainings, and she did not use it as proof that her trainings had been done.  Defendant  maintains separate records that show what trainings have been completed by each employee and  on which dates.     46.  Ms. Downey-Waterstradt unnecessarily characterized the errors on Ms. King’s  planner as “falsification,” which was an exaggeration of what was, at worst, an inadvertent and  11  irrelevant error.  Ms. Downey-Waterstradt also conducted Ms. King’s evaluation in other ways  that were less favorable as compared to how the other QA Coordinator at Knoxville Plasma had  been evaluated, and she held Ms. King to unfair performance standards.  For example, Ms.  Downey-Waterstadt criticized Ms. King for not equally sharing the QA workload with the other  QA Coordinator, disregarding the fact that Ms. King also was expected to perform Training  Coordinator duties on a daily basis, which made it impossible for her to equally share the QA  workload.     47.  Before Ms. Downey-Watershadt completed her three-day evaluation, she called  Ms. Manie to report her evaluation findings.  Ms. Downey-Watershadt and Ms. Manie decided to  end the evaluation early.  Soon thereafter, Ms. Manie, Ms. Downey-Watershadt, and Ms. Long  had a conference call about Ms. King’s evaluation.  Upon information and belief, Ms. Manie  referenced Ms. King’s prior overtime complaint in discussing what actions Defendant should take  regarding Ms. King.    48.  On October 11, 2019, Center Manager Candice Thompson called Ms. King into her  office and told her that she had received an e-mail from Ginger Manie the night before instructing  her to fire Ms. King.  The reason given by Ms. Manie for Ms. King’s discharge was “falsification  of records.”  Ms. Thompson said she had tried to convince Ms. Manie not to fire Ms. King, but to  no avail. Ms. King has never falsified any records and the reason given for her termination is a  pretext for retaliation in response to her overtime complaints.    49.  Defendant would not have discharged Ms. King but for her prior complaints related  to her work hours and not receiving adequate compensation for her hours worked.          12  V. 