13. One of AWG’s distribution centers is located in Pearl River, Louisiana.   14. The Pearl River facility is extremely busy and employs regularly over 300 employees at a  time. The work is fast paced and the vast majority of the workers work well over 40 hours  per workweek.   15. Piazza worked for AWG as a laborer until his improper termination.   16. Piazza’s job duties included unloading product from delivery trucks and placing the products  in the warehouse, repackaging product pallets to prepare for shipment, and loading delivery  trucks with products.   17. Piazza was compensated at an hourly rate, and he worked regularly worked significant hours  in excess of 40 hours in a workweek.   18. Piazza was regularly scheduled to work exactly 8 hours a day and 40 hours every work week,  and he was required to take paid time off if he was not going to work his scheduled hours.   19. During his tenure with Defendant, Piazza regularly and routinely arrived at work and began  working before his scheduled shift time, worked through his scheduled lunch break, and  worked after his scheduled shift end time and on weekends.   20. Piazza regularly worked 60 to 70 hours per workweek.   21. Due to Defendant’s record-keeping and compensation policies, Piazza did not report this  time on a time sheet, and consequently, he was not compensated for this time.   22. Piazza’s time sheet was controlled and manipulated by his supervisors and managers.   24. AWG deducted the time from Piazza’s time sheet even if Piazza did not take a lunch break.   25. Piazza rarely took a lunch break of more than a few minutes because his performance was  based on production numbers that incentivized him to work through lunch.   26. Piazza frequently worked 12 to 14-hour days and 65 to 80 hours per workweek.   27. Piazza’s co-workers worked similar work hours and also worked through lunch or took a  short lunch break of less than 20 minutes.   28. Even though Defendant used a timekeeping system that could accurately record their  employee’s work hours, Defendant instructed their employees not to clock out for lunch so  that AWG could automatically deduct 30 minutes per workday.   29. On several occasions, Plaintiff determined that he worked substantially more hours than were  recorded on his paycheck. Plaintiff complained about the discrepancy, and Defendant  promised to correct the issue.   30. Upon information and belief, Defendant routinely edited Plaintiff's time records by reducing  his reported work hours and thus not compensating him for all hours he actually worked.    31. Defendant also implemented a policy and procedure in which it gave Plaintiff cash or gift  cards as incentive to work extra hours, extraordinary overtime or at unpopular times. This  extra compensation was not included in Plaintiff's regular rate of pay or overtime rate of pay  calculations.   32. Defendant’s record-keeping and compensation policies and practices mandated that  employees not accurately record their actual work hours.   34. No manager for Defendant ever ordered Plaintiff to cease working hours outside of and in  excess of his scheduled work hours; rather, Defendant knowingly allowed Plaintiff to suffer  or permitted him to work hours outside of and in excess of his scheduled work time.   35. No supervisor or manager for Defendant ever investigated or ensured that Plaintiff was being  compensated for all hours worked, including the hours worked outside and in excess of his  scheduled work time.   36. Defendant developed and implemented the time-keeping policy to avoid incurring any  overtime compensation obligations.   37. Plaintiff witnessed other misclassified employees arrive at work and begin working before  their scheduled shift times, work through their scheduled lunch breaks, and work after their  scheduled shift end times.   38. Upon information and belief, Defendant’s record-keeping and compensation policies were  dictated and issued by Defendant’s senior management and issued to all of Defendant’  departments.   39. Defendant’s record-keeping policy promoted the falsification of employee time sheets by  prohibited employees from reporting their work hours properly.   40. Consequently, all hourly employees who were subject to AWG’s policy that did not allow  employees to accurately record start times, end times and lunch breaks, and who had time  deducted from their time sheet even if they did not take a break are similarly situated to  Plaintiff.   41. Defendant has gross annual sales equal to or greater than $500,000.   43. Plaintiff, as an employee of Defendant, engaged in interstate commerce including but not  limited to allowing its employees to handle, sell, produce, or otherwise work on goods or  materials that came from a state other than Louisiana.   44. At all relevant times, Plaintiff was compensated at an hourly rate.   45. Defendant failed to keep accurate payroll records showing the total hours worked each day  and week by its employees.   46. Defendant refused to pay employees for lunch breaks even if the employee did not take a  break of more than 20 minutes in a day.   47. Plaintiff regularly worked time that he was not permitted to record properly and for which he  was not compensated properly or at all.   48. Plaintiff regularly worked time in excess 40 hours in a workweek for which he was not  compensated.   49. Defendant did not compensate Plaintiff properly for all hours worked.   50. Defendant did not compensate Plaintiff at a rate of one and one-half times Plaintiff’ regular  rate of pay for all hours Plaintiff worked more than 40 hours in a workweek.   51. Defendant violated 29 U.S.C. §§ 206 & 207 by failing to compensate Plaintiff properly.   52. Defendant knew that Plaintiff worked hours for which Plaintiff was not compensated  properly.   53. Defendant failed to act in good faith when they promoted falsification of payroll records and  refused to pay employees properly for time worked.   55. Defendant’ actions constitute knowing, intentional and willful violations of the FLSA.   56. Plaintiff was damaged as a direct and proximate result of Defendant’s actions, policies and  practices and failure to compensate them properly.   57. Defendant has many other misclassified employees who worked at the same location  operated by Defendant and were subjected to the same improper record-keeping and  compensation policies as Plaintiff. These employees are similarly situated to Plaintiff  because they were prohibited from recording their work hours properly and worked hours for  which they were not compensated properly.   58. Pursuant to 29 U.S.C. § 216(b), Plaintiff maintains this collective action on behalf of Plaintiff  and other similarly situated employees.   59. Defendant maintains records identifying the names, addresses and other contact information  of putative collective class members who are similarly situated to Plaintiff.   60. To the extent required by law, notice will be provided to putative collective class members  who are similarly situated to Plaintiff.    61. Plaintiff and other similarly situated individuals are entitled to recover from Defendant their  unpaid minimum wages, unpaid overtime wages, liquidated damages, punitive damages,  reasonable attorney’s fees and costs and judicial interest. 