26.  Plaintiffs bring the First Cause of Action, pursuant to FLSA, 29 U.S.C. § 216(b),  on behalf of themselves and all similarly situated persons who work or have worked for Hertz as  LMs at Defendant’s airport locations during the Relevant Period (the “FLSA Collective”).   27.  All of the work that Plaintiffs and the FLSA Collective have performed has been  assigned by Hertz, and/or Hertz has been aware of all of the work that Plaintiffs and the FLSA  Collective have performed.   29.  Hertz is aware or should have been aware that federal and state law required them  to pay employees performing non-exempt duties, including Plaintiffs and members of the FLSA  Collective, an overtime premium for hours worked in excess of 40 per workweek.     30.  Plaintiffs and the FLSA Collective all perform or performed the same primary  duties.   31.  Hertz’s unlawful conduct has been widespread, repeated, and consistent.   32.  Throughout their employment with Hertz, Plaintiffs and the members of the FLSA  Collective consistently worked more than 40 hours per week.   33.  Plaintiffs’ and the FLSA Collective’s primary duty was not management.     34.  Plaintiffs’ and the FLSA Collective’s primary duties were non-exempt duties,  including general customer service and vehicle preparation for rental.  Plaintiffs and the FLSA  Collective spent the vast majority of their time performing these non-exempt duties.     35.  During the Relevant Period, Plaintiffs and the FLSA collective were paid a weekly  salary for their services.   36.  Plaintiffs and the FLSA Collective were closely supervised by their directors,  general managers and area managers.  Area managers were responsible for the overall performance  of the sales team and for coaching and developing sales employees.   37.  Plaintiffs and the FLSA Collective did not exercise a meaningful degree of  independent discretion with respect to the exercise of their duties and were required to follow the  policies, practices, and procedures set by Hertz.  Plaintiffs and the FLSA Collective did not have  any independent discretionary authority to deviate from these policies, practices, and procedures.   39.  Plaintiffs realleges and incorporates by reference all allegations in all preceding  paragraphs.   40.  Hertz engaged in a widespread pattern and practice of violating the FLSA, as  described in this Collective Action Complaint.   41.  Plaintiffs have consented in writing to be parties to this action, pursuant to 29  U.S.C. § 216(b).    42.  At all relevant times, Plaintiffs and other similarly situated current and former  employees were engaged in commerce and/or the production of goods for commerce within the  meaning of 29 U.S.C. §§ 206(a) and 207(a).    43.  The overtime wage provisions set forth in §§ 201 et seq. of the FLSA apply to  Hertz.    44.  Hertz is an employer engaged in commerce and/or the production of goods for  commerce within the meaning of 29 U.S.C. §§ 206(a) and 207(a).   45.  At all times relevant, Plaintiffs were employees within the meaning of 29 U.S.C.  §§ 203(e) and 207(a).   46.  Hertz failed to pay Plaintiffs and other similarly situated current and former  employees the overtime wages to which they were entitled under the FLSA.    48.  Because Hertz’s violations of the FLSA were willful, a three-year statute of  limitations applies, pursuant to 29 U.S.C. § 255.   49.  As a result of Hertz’s willful violations of the FLSA, Plaintiffs and all other  similarly situated employees have suffered damages by being denied overtime wages in  accordance with 29 U.S.C. §§ 201 et seq.    50.  As a result of the unlawful acts of Hertz, Plaintiffs and other similarly situated  current and former employees have been deprived of overtime compensation and other wages in  amounts to be determined at trial, and are entitled to recovery of such amounts, liquidated  damages, prejudgment interest, attorneys’ fees, costs and other compensation pursuant to 29  U.S.C. § 216(b).   Fair Labor Standards Act – Unpaid Overtime  (Brought on behalf of Plaintiffs and the FLSA Collective)  