13.  Plaintiff was employed by Defendants as an exotic dancer at Defendants’ Juliet’s  Gentlemen’s Club.   14.  Plaintiff’s dates of employment were from approximately March 2016 through  about March 2020.   15.  While in Defendants’ employ, Plaintiff performed exotic dancer work duties  primarily for the benefit of Defendants at Defendants’ Juliet’s Gentlemen’s Club in Erie,  Pennsylvania.      16.   While in Defendants’ employ, Plaintiff’s exact weekly hours worked varied  slightly from week to week.   17.  While in Defendants’ employ, Plaintiff typically and customarily worked about  20-30 hours or more per week.     18.  At all times, Defendants had knowledge of all hours Plaintiff worked per week  and suffered or permitted Plaintiff to work all hours herein alleged.   20.  At all times throughout Plaintiff’s employment, Plaintiff and all other exotic  dancer employees were employees of Defendants and were never independent contractors.   21.  While it is true that Defendants titled or classified Plaintiff and other exotic  dancer employees as independent contractors, at all times while working for Defendants,  Plaintiff and other exotic dancer employees considered themselves as employees of Defendants  and that Defendants were their employers.     22.  At all times while Plaintiff was employed by Defendants, Defendants controlled  all aspects of Plaintiff’s job duties and the job duties of other exotic dancer employees through  strictly enforced employment rules.     23.  Defendants hired Plaintiff and other exotic dancer employees and, at all times,  had the ability to discipline them, fine them, fire them, and adjust each of their schedules.     24.  Defendants, at all times, supervised Plaintiff’s work duties and the work duties of  other exotic dancer employees to make sure Plaintiff’s job performance and the job  performances of other exotic dancer employees was of sufficient quality.    25.  At all times, Plaintiff’s pay and opportunity for wages and the pay and  opportunity for wages of other exotic dancer employees have been limited to the pay method set  exclusively by Defendants.     26.  Defendants controlled all aspects of setting and enforcing the work schedule for  Plaintiff and other exotic dancer employees.   28.  At no time did Plaintiff or any other exotic dancer employee make a financial  investment in Defendants business operation or any equipment belonging to Defendants.   29.  To perform the work duties that Plaintiff and other exotic dancer employees  performed for Defendants, Plaintiff and other exotic dancer employees did not have or need any  required certificate, education, or specialized training.     30.  At all times while Plaintiff was been employed by Defendants, Defendants have  been in the business of operating a strip club featuring exotic dancers.   31.   At all times while Plaintiff was employed by Defendants, Plaintiff’s job duties  and the job duties of all other exotic dancer employees wave been directly related to exotic  dancing performances for Defendants’ customers.   32.  Plaintiff and other exotic dancer employees did not perform work that is exempt  from the minimum requirement of the FLSA or Pennsylvania law.  36.  The Class and the Class Members are defined as individuals that meet the  following definition:  48.  In addition to pursuing this action as a Class Action for Federal Rule of Civil  Procedure 23, Plaintiff is pursuing this action as an FLSA collective action on behalf of herself  and all other similarly situated individuals.   49.  The collective action includes:  i.  Current and former exotic dancer employees who worked as exotic   dancers at Juliet’s Gentlemen’s Club at any time between September 2017  and the present; and  ii.  Who were misclassified by Defendants as independent contractors; and   iii.  Who were not paid by Defendants for all hours worked at an hourly at   least equal to the Federal Minimum wage for all hours worked.   50.    In the present case, the questions of law or fact common to the members of the  collective action class predominate over any questions affecting only individual collective action  class members.     51.  The essence of this entire case is the Plaintiff and other similarly situated  individuals were improperly classified as independent contractors and were paid less than the  FLSA required minimum wage and overtime rate for all hours worked.   53.  Specifically, Plaintiff and each collective action class member are seeking the  difference between their net-negative regular hourly rates and the FLSA required rate and  statutory damages under the FLSA.    54.    In the present case, the number of collective action class members is believed to  exceed fifty (50) current and former exotic dancer employees.    55.  All class members are readily identifiable from information and records, on  information and belief, in the possession and control of the Defendants.  56.  Plaintiff re-alleges and reasserts each and every allegation set forth in the  paragraphs above as if each were set forth herein.   57.  Section 206(a)(1) of the FLSA provides that no employer shall employ any  employee for an hourly wage of less than the federal minimum wage, currently $7.25 per hour.     58.  At all times, Plaintiff and other exotic dancer employees were “employees”  covered by the FLSA, 29 U.S.C. § 206(a)(1).   59.  At all times, Defendants were Plaintiff’s “employers” and the employers of other  exotic dancer employees under the FLSA.     60.  Defendants, as employers for Plaintiff and other exotic dancer employees, were  obligated to compensate Plaintiff and other exotic dancer employees for all hours worked at an  hourly rate not less than the Federal Minimum Wage.    62.  More exactly, when the fees and fines that Defendants deducted from Plaintiff’s  personal monies and the personal monies of other exotic dancers are factored in, Defendants paid  Plaintiff and other exotic dancer employees a net negative regular hourly rate.   63.  The net negative hourly rate paid by Defendants to Plaintiff and other exotic  dancer employees fell below the applicable Federal Minimum Wage.    64.   At all times, Defendants had actual knowledge that Plaintiff and other exotic  dancers were in fact employees and were never contractors.   65.  At all times, Defendants had actual knowledge that the compensation method and  amount that Defendants paid Plaintiff and other exotic dancers was less than the compensation  method and amount required by the FLSA.   66.  Defendants’ failure to pay compensation to Plaintiff and other exotic dancer  employees as required by the FLSA was willful and intentional, and not in good faith.  WHEREFORE, Defendants are liable, jointly and severally, to Plaintiff (and all others  similarly situated who have joined in this suit) for unpaid minimum wages in such amounts as  are proven at trial, plus an equal amount in liquidated damages, interest (both pre- and post- judgment), attorney’s fees, the costs of this action, and any other and further relief this Court  deems appropriate.  68.     At all  relevant  times relevant,  Defendants  employed,  and/or  continues  to   employ, Plaintiff and each of the Class Members within the meaning of the PMWA.   69.     At relevant times relevant, Defendants have perpetrated a willful policy and  practice of improperly classifying Plaintiff and other exotic dancer employees as independent  contractors and, consequently, failing to pay these individuals the applicable minimum wage for  each hour worked.   70.     Pursuant to Defendants’ compensation policies, Defendants improperly classified  Plaintiff and other exotic dancer employees as independent contractors rather than pay Plaintiff  and other exotic dancer employees the Pennsylvania minimum wage.   71.  Defendants have violated and, continues to violate, the PMWA, 43 Pa. C.S.C. §  333.101 et seq.  WHEREFORE, Defendants are liable, jointly and severally, to Plaintiff (and all other  class members) for unpaid minimum wages in such amounts as are proven at trial, statutory  liquidated damages, interest (both pre- and post-judgment), attorney’s fees, the costs of this  action, and any other and further relief this Court deems appropriate.  72.  Plaintiff re-alleges and reasserts each and every allegation set forth in the  paragraphs above as if each were set forth herein.   74. Pursuant to the WPCL, 43 Pa. S. § 260.1 et seq. Plaintiff and all other exotic dancer employees were entitled to receive all compensation due and owing to them on their  regular payday.   75. As a result of Defendants’ unlawful policies, Plaintiff and all other exotic dancer employees have been deprived of compensation due and owing.   VIOLATION OF THE PENNSYLVANIA WAGE PAYMENT  AND COLLECTION LAW  (CLASS ACTION)   VIOLATION OF THE FEDERAL FAIR LABOR STANDARDS ACT   MINIMUM WAGE VIOLATIONS  (COLLECTIVE ACTION)   VIOLATION OF THE PENNSYLVANIA MINIMUM WAGE ACT  MINIMUM WAGE VIOLATIONS  (CLASS ACTION)  