34.  Plaintiff brings this claim for relief for violation of the FLSA as a collective  action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of all  persons similarly situated as Mental Health Professionals who were or are employed by  Defendant and who are entitled to payment for all of their overtime wages that ,  Defendant failed to pay from three years prior to the date of the filing of this lawsuit,  through the time of the trial of this case.   35.  Plaintiff is unable to state the exact number of the class but believes that  the class's membership is more than 1000 persons.   36.  Defendant can readily identify the members of the class, who are a certain  portion of the current and former employees of Defendant.   38.  The email addresses of many of the FLSA collective action Plaintiffs are  available from Defendant, and notice should be provided to the FLSA collective action  Plaintiffs via email to their last known email addresses as soon as possible.   39.  The cellular telephone numbers of the FLSA collective action Plaintiffs are  available from Defendant, and notice should be provided to the FLSA collective action  Plaintiffs via text message as soon as possible.   40.  The proposed FLSA class members are similarly situated in that they have  been subject to uniform practices by Defendant which violated the FLSA, including:  A.  Defendant's uniform failure to compensate employees pursuant to the  requirements of the FLSA; and   41.  Plaintiff repeats and re-alleges all the preceding paragraphs of this  Original Complaint as if fully set forth in this section.   42.  Plaintiff worked for Defendant from 2010 to November of 2018 as a Mental  Health Professional in multiple locations, including locations in Marion, Jonesboro and  Trumann.   44.  Plaintiff and other similarly-situated employees performed duties such as  providing mental health treatment, contacting Defendant's clients, attending meetings,  scheduling appointments, filling out relevant paperwork, billing clients, etc.   45.  Plaintiff and other similarly-situated employees worked in excess of forty  (40) hours per week throughout their tenure with Defendant.   46.  Plaintiff and other similarly-situated employees were classified as hourly  employees and regularly worked in excess of forty (40) hours per week.   47.  Defendant did not pay Plaintiff or similarly-situated employees one and  one-half times their regular rate for hours in excess of forty (40) in a week.   48.  It was Defendant's commonly applied policy to only pay Plaintiff, other  Mental Health Professionals for the hours in which they billed Defendant's patients.   49.  The work that Plaintiff and the class members performed was not all  billable to Defendant's clients; therefore not all of the work was compensated.   50.  Defendant knew, or showed reckless disregard for whether, the way it paid  Plaintiff and other Mental Health Professionals violated the FLSA.  VI.  51.  Plaintiff repeats and re-alleges all the preceding paragraphs of this  Complaint as if fully set forth in this section.  A.  Individual Allegations under the FLSA   53.  Defendant violated Section 778.208 of Title 29 of the Code of Federal  Regulations by failing to pay Plaintiff and other similarly-situated employees the proper  overtime premium.   54.  Defendant's conduct and practice, as described above, have been and is  willful, intentional, unreasonable, arbitrary and in bad faith.   55.  By reason of the unlawful acts alleged herein, Defendant is liable to  Plaintiff for, and Plaintiff seeks, unpaid overtime wages, liquidated damages, pre- judgment interest, civil penalties and costs, including reasonable attorney's fees as  provided by the FLSA.  B.  FLSA § 216(b) Representative Action Allegations   56.  Plaintiff brings this collective action on behalf of all Mental Health  Professionals employed by Defendant to recover monetary damages owed by  Defendant to Plaintiff and members of the Putative Class for all the overtime  compensation for all the hours he and they worked in excess of forty (40) each week.   57.  Plaintiff brings this action on behalf of himself individually and all other  similarly situated employees, former and present, who were and/or are affected by  Defendant's willful and intentional violation of the FLSA.   58.  In the past three years, Defendant has employed hundreds of Mental  Health Professionals.   60.  Defendant failed to pay these employees the proper overtime wages.  Because these employees are similarly situated to Plaintiff, and because they are owed  overtime for the same reasons, the opt-in class is properly defined as:  All Mental Health Professionals or Who Worked in More Than Forty  (40) Hours in Any Week.   61.  This group includes, but is not necessarily limited to, hourly paid workers  employed in States where Defendant does business.  C.  Individual Allegations Under the AMWA   62.  Plaintiff asserts this claim for damages and declaratory relief pursuant to  the AMWA, Arkansas Code Annotated§§ 11-4-203(4).   63.  At all relevant times, Defendant was Plaintiff's "employer" within the  meaning of the AMWA, Ark. Code Ann.§ 11-4-203(4).   64.  Defendant failed to pay Plaintiff all overtime wages owed, as required  under the AMWA.   65.  Defendant's conduct and practices, as described above, were willful,  intentional, unreasonable, arbitrary and in bad faith.   66.  By reason of the unlawful acts alleged herein, Defendant is liable to  Plaintiff for monetary damages, liquidated damages, costs, and a reasonable attorney's  fee provided by the AMWA for all violations which occurred beginning at least three (3)  years preceding the filing of Plaintiff's initial complaint, plus periods of equitable tolling.   8.  Defendant's failure to pay members of the class proper overtime  compensation in violation of the FLSA, 29 U.S.C. § 201 et seq.  V. 