19.  The claims in this Complaint arising out of the FLSA are brought by  Plaintiffs on behalf of themselves and all other similarly situated non-exempt  employees (i.e. nail technicians and employees holding other job titles whose work  duties are substantially similar to that of nail technicians) who work or have worked at  Elegant Nail during the statutory period and elect to opt-in to this action (the “FLSA  Collective”).    20.   The FLSA Collective consists of approximately six similarly situated  current and former employees of Elegant Nail, who, over the last three years have been  victims of Defendants’ common policy and practices that have violated the employees’  rights under the FLSA by, inter alia, willfully denying them wages due under the FLSA.   22.  Defendants have engaged in this unlawful conduct pursuant to a policy,  plan, or practice of minimizing labor costs and denying employees compensation by  knowingly violating the FLSA.    23.  Defendants’ unlawful conduct has been intentional, willful, and in bad  faith, and has caused significant damage to Plaintiffs and the FLSA Collective.   24.  The FLSA Collective 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 employees are known to defendants, are readily identifiable by  defendants, and are locatable through defendants’ records.   These similarly situated  employees should be notified of and allowed to opt in to this action, pursuant to 29  U.S.C. § 216(b).  25.  During their employment Plaintiffs worked primarily doing manicures  and pedicures at Elegant Nail.   26.  From approximately January 2017 through approximately July 2017,  Plaintiff Idrovo was regularly paid a salary of $50 per day.   27.  From approximately August 2017 through approximately February 2018,  Plaintiff Idrovo was regularly paid a salary of $60 per day.   28.  From in or around March 2018 through her termination in March 2019,  Plaintiff Idrovo was regularly paid a salary of $70 per day.   30.  From approximately March 2015 through approximately March 2018,  Plaintiff Becerra was regularly paid a salary of $75 per day.   31.  From approximately April 2018 through approximately July 2018, Plaintiff  Becerra was regularly paid a salary of $80 per day.   32.  From in or around September 2018 through her termination in November   2018, Plaintiff Becerra was regularly paid a salary of $90 per day.   33.  From March 2015 through March 2018, Plaintiff Becerra regularly worked  approximately fifty (50) to sixty (60) hours per week: Mondays, Tuesdays, Wednesdays,  Thursdays, Fridays and Saturdays from approximately 9:15 a.m. to 7:00 p.m. or 7:30  p.m.   34.  From April 2018 through July 2018, Plaintiff Becerra’s hours were reduced  to thirty (30) hours per week due to her pregnancy.   35.  From August 2018 through September 3, 2018, Plaintiff Becerra was out of  work due to maternity leave.   36.  From September 3, 2018 through her termination on November 28, 2018,  Plaintiff Becerra’s hours were thirty (30) hours per week.    38.  Thoguhout their employment, Plaintiffs were not permitted to take breaks  during the workday, and were not allowed to leave the nail salon for any reason during  the workday.   39.  Defendants paid Plaintiffs less than the statutorily required minimum  wage per hour that they worked each week.   40.  Defendants did not pay Plaintiffs overtime compensation at one and one  half (1½) times their regular rate of pay, as required by the FLSA and the CMWA, for  any hours they worked in excess of forty per workweek.  41.  Plaintiffs repeat and reallege all foregoing paragraphs as if fully set forth  herein.   42.  The FLSA requires that employers pay employees a minimum wage for all  hours worked weekly up to forty.   43.  Defendants are employers within the meaning of 29 U.S.C. §§ 203(e) and  206(a), and employed plaintiff and the FLSA Collective.   44.  The minimum wage provisions set forth in the FLSA, 29 U.S.C.  §§ 201, et  seq. and the supporting federal regulations, apply to Defendants.    45.  Defendants failed to pay plaintiff and the FLSA Collective the minimum  wages to which they were entitled under the FLSA.    47.  As a result of Defendants’ willful violations of the FLSA, Plaintiffs and the  FLSA Collective suffered damages by being denied minimum wages in accordance with  the FLSA in amounts to be determined at trial, and are entitled to recovery of such  amounts, liquidated damages, pre- and post-judgment interest, attorneys’ fees and costs  of this action, and other compensation pursuant to 29 U.S.C. § 216(b).  48.  Plaintiffs repeat and reallege all foregoing paragraphs as if fully set forth  herein.     49.  The CMWA requires that employers pay employees a minimum wage for  all hours worked weekly up to forty.   50.  Defendants failed to pay Plaintiffs the minimum wages to which they  were entitled to under the CMWA.   51.  Defendants have willfully violated the CMWA by knowingly and  intentionally failing to pay Plaintiffs the minimum hourly wage.   52.  Defendants willfully failed to pay Plaintiffs at least the minimum hourly  wage for all hours worked.   54.  Plaintiffs repeat and reallege all foregoing paragraphs as if fully set forth  herein.    55.  Defendants have willfully violated the FLSA by knowingly and  intentionally failing to pay Plaintiffs and the FLSA Collective overtime wages for all of  the hours they worked in excess of forty in a workweek.    56.  Defendants have not made a good faith effort to comply with the FLSA  with respect to Plaintiffs’ and the FLSA Collective’s compensation.   57.  Defendants were aware or should have been aware that the practices  described in this Complaint were unlawful and have not made a good faith effort to  comply with the FLSA with respect to the compensation of Plaintiffs and the FLSA  Collective.   58.  Due to defendants’ violations of the FLSA, Plaintiffs and the FLSA  Collective are entitled to recover their unpaid overtime wages, liquidated damages,  reasonable attorneys’ fees and costs of the action, and pre- and post-judgment interest.  Connecticut Minimum Wage Act – Unpaid Minimum Wage   Fair Labor Standards Act – Unpaid Minimum Wage   Fair Labor Standards Act – Unpaid Overtime  