42.  As joint employers, Defendants provide home health care services to elderly  and/or infirm individuals through home health care aides such as Plaintiff.   43.  Defendants serve clients in Connecticut.   44.  Defendants employ individuals as home health care aides within their clients'  homes.  The specific work assignments and hours of operation are determined by Defendants.   45.  Defendants assign the home health care aides employed by them to work fixed  schedules based upon the needs of Defendants’ clients.   46.  Defendants require the home health care employed by them to obtain Defendants’  approval in advance of any change to their schedule, including for vacation, personal days or  sick days.     47.  Defendants require the home health care aides employed by them to record their  hours spent at each client’s residence.      48.  Defendants require the home health care aides employed by them to address to  Defendants any concerns, complaints, requests or other issues that arise in connection with the  provision of services to Defendants’ clients; Defendants specifically prohibit the home health  care aides employed by them from bringing such matters directly to the attention of Defendants’  clients.      50.  Defendants do not require that the home health care aides employed by them  provide any financial investment in the operation of Defendants’ business.     51.  Defendants market their service through various forms of advertising, license and  insure their home health care aides in the performance of service for Defendants’ clients,  coordinate the placement of their home health care aides with specific clients, arrange for  coverage of services to clients when Defendants’ home health care aides request time off and  handle all billing and collection for home health care services performed by their home health  care aides.    52.  During her employment with Defendants, Plaintiff Scott was not entitled to earn  any incentive, bonus, commission or profit share other than the compensation paid to her by  Defendants as wages for hours worked.    53.  Upon information and belief, Defendants have never paid any other individual  employed by them as a home health care aid any incentive, bonus, commission or profit share  other than the compensation paid to them as wages for hours worked.   54.  Upon information and belief, Defendants are compensated by various payors,  including Medicaid, Medicare, private insurance companies, and directly by their clients.  The  payors are billed hourly based on the amount of time Defendants’ aides spend within the clients'  homes.  77.  For purposes of the FLSA collective action, the collective is defined as:  All home  health care aides employed by Defendants on and after three years from the date this action is  commenced who were not paid overtime for hours worked over forty in a workweek.   78.  Similarly situated former and current employees are readily identifiable through  Defendants' records.  These similarly situated employees can be located and should be notified of  and allowed to opt-in to this action pursuant to 29 U.S.C. §216(b).    79.  Plaintiff seeks certification under Rule 23 of the Federal Rules of Civil Procedure  of a class of employees who were and are employed as home health aides by Defendants from  April 7, 2011 through the present day and who were not properly paid overtime pay and/or had  unlawful deductions taken from their wages pursuant to the CGS for the period March 12, 2017.   80.  Common questions of fact exist as to all of the members of the proposed class and  predominate over the questions affecting only individual members -- namely, whether  Defendants did not pay overtime wages to and/or made unlawful wage deductions from their  employees who were and are home health care aides.   82.  Plaintiff's claims are typical of the claims of the members of the proposed class,  as Plaintiff and the other members' sustained damages arising out of the same wrongful conduct  of Defendants in failing to pay overtime wages and making unlawful wage deductions.   83.  Plaintiff is represented by [local counsel] and Charny & Wheeler P.C. which has  the resources, expertise and experience necessary to prosecute this class action and their  attorneys do not have knowledge of any conflicts among the potential members of the class or  their respective counsel.    84.  A class action is superior to other available methods for the fair and efficient  adjudication of the controversy raised in this lawsuit because:  (1) the prosecution of separate  actions would be inefficient and wasteful of judicial resources; (2) the members of the proposed  class are likely located throughout the Northeast Region and are not likely to be able to vindicate  and enforce their claims unless this action is maintained as a class action; (3) the issues raised  can be more fairly and efficiently resolved in the context of a single action rather than piecemeal  litigation in separate actions; (4) the resolution of litigation in a single forum will avoid the risk  of confusion and possible inconsistent determinations; (5) the prosecution of separate actions  would create the risk of inconsistent or varying adjudications with respect to individuals  pursuing claims against the defendants which would establish incompatible standards of conduct;  (6) the defendants have acted on grounds applicable to all class members, making final  declaratory relief on behalf of all members necessary and appropriate; and (7) questions of law  and fact common to members of the class on issues of liability predominate over any questions,  such as those of individual damages, that will affect individual class members.   86.  Plaintiff repeats and re-alleges the preceding allegations.   87.  Defendants employed Plaintiff and those similarly situated for workweeks longer  than 40 hours and willfully failed to compensate Plaintiff and other employees similarly situated   for the time worked in excess of 40 hours per week, at a rate of at least one and one-half times  the regular hourly rate, in violation of the requirements of the FLSA.   88.  As a consequence of the willful underpayment of wages, Plaintiff and those  employees similarly situated have incurred damages and Defendants are indebted to them in the  amount of the unpaid overtime compensation, together with interest, liquidated damages and  attorney's fees and costs, in an amount to be determined at trial.  89.  Plaintiff repeats and re-alleges the preceding allegations.   90.  Defendants employed Plaintiff and those similarly situated for workweeks longer  than 40 hours and willfully failed to compensate Plaintiff for the time worked in excess of 40  hours per week, at a rate of at least one and one-half times the regular hourly rate, in violation of  the requirements of the CGS.   92.  Plaintiff repeats and realleges the preceding allegations.   93.  During the term of her employment with Defendants, Defendants deducted a  meals credit from the wages of Plaintiff and other employees similarly situated.   94.  Defendants represented that the basis for such deductions was the existence of an  arrangement by which their client would provide meals to Plaintiff and others similarly situated  at a value equivalent to the amount of such deduction.     95.  By way of their complaints, Defendants had actual and constructive notice that  Plaintiffs and other employees similarly situated did not receive the meals for which the meals  credit were intended to be deducted.   96.  Notwithstanding such notice, Defendants deducted the meal credit from the wages  of Plaintiff and other employees similarly situated.       97.  Defendants' deduction of the meals credit from the wages of Plaintiff and other  employees similarly situated constitutes an unlawful deduction within the meaning of CGS.     FAILURE TO PAY OVERTIME IN VIOLATION OF THE FLSA  Collective Action   FAILURE TO PAY OVERTIME WAGES IN VIOLATION OF STATE LAW   Class Action   UNLAWFUL DEDUCTION OF WAGES IN VIOLATION OF CGS  Class Action  