21. Swift is a multinational corporation that operates an international trucking  terminal network, and provides long-haul transportation services and other logistics  services throughout the continental United States, Mexico, and Canada, and in this  Judicial District.   22. Swift operates nearly 18,000 trucks, and its terminal network includes  over 40 full-service facilities.   23. Swift currently employs hundreds of Trainees in the United States.   Trainees are assigned to drive a truck with a “mentor” trucker for 4-6 weeks.  All  Trainees have shared a common job description.  The principal job duties of Plaintiff  and the other Trainees has been to drive a truck, assist their mentors with navigation  and operation of the truck, conduct pre- and post-trip inspections, communicate and  conduct business with short-haul and local delivery agents, and load and unload cargo,  among other things.  Trainees also must learn how to operate the truck’s controls,  learn safe driving practices, how to log hours of service and how to conduct pre- and  post-trip inspections, among other things.   24. The mentors also have typically instructed the Trainees regarding the  driving of the truck, operating the truck’s controls, the logging of hours of service for  regulatory purposes, loading and unloading, and communicating with short-haul and  local delivery agents, among other things.  The mentor has also been responsible for  tracking the hours worked by the Trainees, and inputting that information into the  computer timekeeping system located on the truck.   25. Swift has paid its Trainees by the hour and has classified them as “non- exempt” employees who are entitled to minimum wage and overtime compensation as  defined by the FLSA.   40. Plaintiffs bring all counts herein as an “opt-in” collective action pursuant  to 29 U.S.C. § 216(b), on behalf of herself and a proposed Collective of similarly  situated employees defined as:  “All individuals currently or formerly employed by Swift as a Trainee or other  equivalent hourly position in the United States at any time from three years  before the filing of this Complaint and/or the filing of consents to become party  plaintiffs, plus additional time for periods of equitable tolling, through  resolution of this action.”   41. Plaintiff, individually, and on behalf of other similarly situated employees  defined above, seeks relief on a collective basis challenging Swift’s policy and  practice of failing to compensate its hourly, non-exempt Trainees for work Swift  suffers and permits them to perform for its own benefit, including overtime  compensation.  The number and identity of other similarly situated persons yet to opt- in and consent to be party-plaintiffs may be determined from the records of Swift, and  potential opt-ins may be easily and quickly notified of the pendency of this action.  42. Plaintiff re-alleges and incorporates herein the allegations contained in  Paragraphs 1-39.   43. At all times relevant to this action, Swift has been an “employer” under  the FLSA, 29 U.S.C. § 203(d), subject to the provisions of 29 U.S.C. § 201, et seq.   44. At all times relevant to this action, Plaintiff and the other Trainees have  been “employees” of Swift within the meaning of the FLSA, 29 U.S.C. § 203(e)(1).   63. Plaintiff re-alleges and incorporates herein the allegations contained in  Paragraphs 1-60.   80. Plaintiff re-alleges and incorporates herein the allegations contained in  Paragraphs 1-77.   VIOLATION OF THE FAIR LABOR STANDARDS ACT,  29 U.S.C. § 201, et seq. FAILURE TO PAY MINIMUM WAGES   VIOLATION OF THE FAIR LABOR STANDARDS ACT,   29 U.S.C. § 201, et seq. FAILURE TO COMPENSATE FOR ALL HOURS  WORKED   VIOLATION OF THE FAIR LABOR STANDARDS ACT,   29 U.S.C. § 201, et seq. FAILURE TO PAY OVERTIME WAGES  