25.  Pursuant to 29 U.S.C. §§ 207 and 216(b), Plaintiffs seek to prosecute their FLSA  claims as a collective action on behalf of themselves and the Collective Action Members.   26.  Defendants are liable under the FLSA for, inter alia, failing to properly  compensate Plaintiffs and the Collective Action Members.  There are many similarly situated  current and former COSs who have been underpaid in violation of the FLSA and who would  benefit from the issuance of a court-supervised notice of the present lawsuit and the opportunity  to join the present lawsuit.  Those similarly situated COSs are known to Defendants, are readily  identifiable, and can be located through Defendants’ records.  Notice should be sent to the  Collective Action Members pursuant to 29 U.S.C. § 216(b).  27.  Plaintiffs and the Collective Action Members worked for Defendants as COSs  and regularly worked more than 40 hours a week.   29.  Throughout the relevant period, it has been Defendants’ policy, pattern or practice  to require, suffer, or permit Plaintiffs and the Collective Action Members to work in excess of 40  hours per week without paying them premium overtime compensation for all of the overtime  hours they worked.   30.  Defendants failed to pay Plaintiffs and the Collective Action Members all  overtime compensation due and owing to them for the hours they worked in excess of 40 in a  workweek as outlined in this Collective Action Complaint.     31.  Defendants assigned all of the work that Plaintiffs and the Collective Action  Members performed and/or Defendants were aware of the work that they performed.   32.  Defendants failed to keep accurate records of the hours worked by Plaintiffs and  the Collective Action Members.   33.  Plaintiffs and the Collective Action Members performed the same or similar  primary job duties, which are non-exempt in nature.      35.  Defendants are aware or should have been aware that federal law required them to  pay their employees performing non-exempt duties an overtime premium for all hours worked in  excess of 40 hours per workweek.   36.  Defendants’ unlawful conduct has been widespread, repeated, and consistent.  37.  Plaintiffs reallege and incorporate by reference the allegations in all preceding  paragraphs.   38.  Defendants have engaged in a widespread policy, pattern or practice of violating  the FLSA in regard to Plaintiffs and the Collective, as detailed in this Collective Action  Complaint.   39.  At all relevant times, Plaintiffs and the Collective Action Members 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).    40.  The overtime wage provisions set forth in §§ 201 et seq. of the FLSA apply to  Defendants.   41.  Defendants were employers of Plaintiffs and the Collective Action Members and  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.  Defendants failed to pay Plaintiffs and the Collective Action Members all  overtime compensation to which they are/were entitled under the FLSA.   44.  Defendants failed to keep accurate records of time worked by the Plaintiffs and  the Collective Action Members.   45.  Defendants’ violations of the FLSA, as described in this Collective Action  Complaint, have been, and continue to be, willful and intentional.     46.  Defendants are aware of their obligations under the FLSA, but did not make a  good faith effort to comply with the FLSA with respect to their time keeping and compensation  of Plaintiffs and the Collective Action Members.   47.  Because Defendants’ violations of the FLSA have been willful, a three-year  statute of limitations applies pursuant to 29 U.S.C. § 255.   48.  As a result of Defendants’ willful violations of the FLSA, Plaintiffs and the  Collective Action Members have suffered damages by being denied overtime wages in  accordance with the FLSA, in amounts to be determined at trial, and are entitled to recovery of  such amounts, liquidated damages, prejudgment interest, attorney’s fees, costs and expenses  pursuant to 29 U.S.C. § 216(b).  Fair Labor Standards Act:  Unpaid Overtime Wages  Brought on Behalf of Plaintiffs and Similarly Situated Current and Former   COSs Against Defendants  