11.  At all relevant times, Defendants have been, and continue to be,  “employers”  engaged in interstate “commerce” and/or in the production of “goods” for “commerce” within  the meaning of the FLSA, 29 U.S.C. § 203.  At all relevant times, Defendants have employed,  and/or continue to employ, “employee[s],” including the Plaintiff and all similarly situated  employees.  At all relevant times, Defendants have had gross operating revenues in excess of  $500,000.00.   12.  At all relevant times, Defendants have been, and continue to be, an “employer” as  defined by the MMWL. At all relevant times, D e f e n d a n t s  h a v e  employed, and/or  continue to employ, “employee[s],” including Plaintiff and all similarly situated employees as  defined by the MMWL.   13.  The primary job of Property Managers is to manage individual apartment  complexes and affordable housing on behalf of the Defendants and others. Many Property  Managers, including Harger, supervise less than three full time employees in performance of  their job duties.   14.  All Property Managers are similarly situated in that they supervise less than three  full time employees and are all subject to Defendants’ policy and practice that designated  and/or treated them as exempt employees. Accordingly, all Property Managers perform work  without overtime compensation.   16.  Defendants require Property Managers to record their work time via  time cards, but they do not use the time cards as a basis for wage payment.  Moreover, not all time is recorded because Plaintiff and others similarly situated  engage in work away from their work location, including company meetings held in  Columbia Missouri, and additional work on the evenings and weekends.  Accordingly, while most time is recorded, Defendants fail to accurately record all of  the actual time worked by all Property Managers.  Defendants could easily and accurately  record the actual time worked by all Property Managers.   17.  Plaintiff regularly worked in excess of 50 hours per week, but she was not  compensated at a rate of at least one and one half times her regular rate for hours worked in  excess of 40 in a workweek.   18.  In light of Defendants’ failure to accurately record time worked by all Property  Managers, Defendants fails to provide accurate wage statements to all Property Managers.   19.  Harger was a Property Manager for Defendants from July 2007 through February  2015.  (I would eliminate this paragraph as it is duplicative of the info in paragraph 1)   20.  During her employment, Harger typically worked approximately 50 hours per  week in the office, and an additional 2-3 hours per week outside the office. Additionally, Harger  and others similarly situated were required to travel to Columbia, MO and other locations for  training    22.  Because Defendants misclassified Harger as an exempt employee and she worked  in excess of forty hours per week, Harger is entitled to overtime compensation.   23.  Upon information and belief, other Property Managers employed by Defendants  also are entitled to overtime compensation because Defendants improperly classified them as  exempt employees and they worked in excess of forty hours per week.   24.  The same unlawful practices and procedures described above affect all property  managers (who supervise less than three full time employees) nationwide, including in the states  of Missouri, Georgia, Iowa, Nebraska, New Mexico, South Carolina and Texas.  25.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint.   26.  During the relevant period, Plaintiff supervised less than three full time  employees. Defendants employ other Property Managers at locations throughout the United  States who like Plaintiff, supervised less than three full time employees.   27.  Defendants classify Property Managers as exempt employees under the FLSA.  Thus, Defendants does not pay Property Managers overtime compensation.   29.  All similarly situated property managers working for Defendants are similarly  situated in that they all perform essentially the same respective job functions and supervise less  than three full time employees.   30.  All similarly situated Property Managers are similarly situated in that they are  all subject to D e f e n d a n t s ’  same compensation policy, plan, or procedure that requires  them to perform work and/or requires them to be present at work without paying them  overtime. This denies the similarly situated Property Managers their overtime  compensation.    31.  Defendants’ policy and practice of classifying similarly situated Property  Managers as exempt employees and denying them overtime compensation violates the FLSA.   32.  Plaintiff brings this Complaint as a collective action pursuant to 29 U.S.C. §  216(b) of the FLSA on behalf of:   All persons nationwide who were, are or will be employed by  Defendants as Property Managers who supervised less than three  full time employees from August 24, 2012 to the present, plus  periods of tolling, who have not been compensated at one and one- half times the regular rate of pay for all services performed in  excess of forty hours per week.   33.  This claim is being brought and maintained as an “opt-in” collective action  pursuant to 29 U.S.C. § 216(b) of the FLSA for all claims asserted by Plaintiff because her  claims are similar to the claims of the similarly situated Property Managers.   34.  The number and identity of other similarly situated Property Managers yet to  opt-in and consent to be party plaintiffs may be determined from Defendants’ records, and  potential class members may easily and quickly be notified of the pendency of this action.   36.  The foregoing conduct, as alleged herein, constitutes a willful violation of the  FLSA within the meaning of 29 U.S.C. § 255(a).   37.  Plaintiff, on behalf of herself and all similarly situated employees of Defendants,  seeks damages in the amount of all respective unpaid overtime compensations at a rate of one  and one-half times the regular rate of pay for work performed in excess of forty hours in a  work week, plus liquidated damages, as provided by the FLSA, 29 U.S.C. § 216(b), and such  other legal and equitable relief as the Court deems just and proper.   38.  Plaintiff, on behalf of herself and all similarly situated employees of Defendants  who compose the similarly situated Property Managers, seek recovery of all attorneys’ fees,  costs, and expenses of this action, to be paid by Defendants, as provided by the FLSA, 29  U.S.C. § 216(b).  39.  Plaintiff incorporates by reference the foregoing paragraphs of this Complaint.   40.  Plaintiff has been entitled to the rights, protections, and benefits provided under  the MWL, codified at Mo. Rev. Stat. §§ 290.500 et seq.   42.  Defendants were the “employer” of Plaintiff within the meaning of the MWL.   43.  Plaintiff was Defendants’ “employee” within the meaning of the MWL.     44.  As set forth herein, Defendants illegally classified and/or treated the Missouri  Named Plaintiff  and the Missouri Class Members as exempt, and thus failed to pay the  Missouri Named Plaintiff and the Missouri Class Members the overtime required by Missouri  law.   45.  Pursuant to the MWL, Plaintiff and the Missouri Class Members are entitled to  be compensated at a rate of not less than one and one-half times the regular rate at which such  employees are employed for all work performed in excess of forty (40) hours in a workweek.    46.  Defendants, pursuant to its policy and practice, violated the MWL by refusing  and failing to pay Plaintiff and the Missouri Class Members overtime wages required under the  8.  Defendant Fairway is a provider of property management services to companies  such as JES Holdings, Inc.    9.  Defendant JES is a privately owned group of companies, including Fairway  Management and FWM Payroll Clearing, Inc., that employs more 600 employees and offers  clients a fully-integrated array of services from site selection to direct delivery of investor  benefits.   Violation of the Fair Labor Standards Act  (Brought by Plaintiff and the Proposed Collective Against Defendants)   Violation of the Missouri Wage Law  (Brought by Plaintiff and the Proposed Class Against Defendants)  