10.  Plaintiff brings the First Count as a collective action pursuant to  Section 216(b) of the FLSA, on behalf of himself and other similarly situated people  (the “Collective” or the “technicians”), which shall include:  All persons who work or worked for Defendant as technicians from  January 2, 2017 through the date the Court orders notice to be sent in  accordance with Section 216(b) of the FLSA (the “FLSA Class  Period”). Excluded from the Collective are Defendant, and any  corporations, partnerships or other entities affiliated with Defendant.   11.  Defendant is liable under the FLSA for, inter alia, failing to properly  compensate Plaintiff and the Collective for time worked in excess of forty (40) hours  per week. There are likely fifty (50) or more similarly situated current and former  employees of Defendant who have been underpaid in violation of the FLSA and who  would benefit from the issuance of a court-supervised notice of the present lawsuit  and the opportunity to join the present lawsuit. Those similarly situated employees  are known to Defendant, are readily identifiable, and can be located through  Defendant’s records that Defendant is required to create and maintain under  applicable federal and state law.   13.  Plaintiff brings the Second Count as a class action pursuant to Fed. R.  Civ. P. 23(a) and (b)(3) on behalf of the following class of technicians (the “Class”):  All persons who work or worked for Defendant as technicians in the  State of New Jersey from January 2, 2014 through the date a judgment  is entered in this action. Excluded from the Class are Defendant, and  any corporations, partnerships or other entities affiliated with  Defendant.   14.  The members of the Class are so numerous that joinder of all members  would be impracticable. Plaintiff estimates that there are at least fifty (50) members  of the Class.   15.  Questions of law and fact common to all the members of the Class that  predominate over any questions affecting only individual members, include:  a.  Whether Defendant failed to pay Plaintiff and the Class at  overtime rates during hours worked over forty (40) per  workweek; and  b.  Whether Defendant’s failure to pay Plaintiff and the Class at  overtime rates during hours worked over forty (40) per  workweek violated the NJWHL.   16.  The claims of Plaintiff are typical of the claims of the members of the  Class. Plaintiff has no interests antagonistic to those of the Class, and Defendant has  no defenses unique to Plaintiff.   19.  Plaintiff was employed by Pop A Lock as a technician during the  limitations period of both FLSA and the NJWHL.    20.  The nature of Defendant’s business required Plaintiff to perform shift  work for which he remained on-call at times and locations that precluded him from  making effective use of the on-call time for his own purposes.     21.  Accordingly, as a technician, Plaintiff was scheduled to, and did, work  fifty (50) hours or more per week on a regular basis.   22.  Plaintiff began his employment with Defendant in July 2019 and  ended his employment with Defendant in August 2019.   23.  During that time, he was routinely required to work more than forty  (40) hours in a week. For example, during the week of July 29, 2019 to August 2,  2019, Plaintiff worked more than forty (40) hours but was not paid at one and one-  half times his ordinary rate during hours worked in excess of forty (40).   24.  Indeed, at all times, Plaintiff was not paid at one and one-half times  his ordinary rate during hours worked over forty (40) in a workweek.    25.  Upon information and belief, all of the other technicians are similarly  required to work more than forty (40) hours per week.   27.  Defendant was aware that the members of the Collective were engaged  in work in excess of forty (40) hours per week and did not appropriately compensate  for this overtime work.  Defendant knew that this was a violation of applicable labor  laws and the failure to so compensate was therefore willful.   28.  Plaintiff incorporates and re-alleges all of the preceding paragraphs  as if they were fully set forth herein.   29.  During the FLSA Class Period, Plaintiff and others similarly situated  were “employees” of Defendant within the meaning of the FLSA, 29 U.S.C. §203(e)  and (g).   30.  At all relevant times, Defendant has been an “employer” engaged in  interstate “commerce” within the meaning of the FLSA, 29 U.S.C. §203.   31.  At all relevant times, Defendant’s business has had annual gross  revenues in excess of $500,000.   32.  Plaintiff consents in writing to be a party to this action pursuant to  29 U.S.C. §216(b). Plaintiff’s written consent is attached hereto as Exhibit A  and incorporated by reference.   34.  During the FLSA Class Period, Defendant failed to pay Plaintiff and  other technicians all wages due, including overtime wages of not less than one and  one-half times the regular rate of pay during each hour worked in excess of forty  (40) hours in a workweek, which they are entitled under the FLSA, 29 U.S.C. §207.   35.  Defendant’s violation of the overtime requirements of the FLSA was  part of its regular business practice and constituted a pattern, practice, and/or policy.   36.  Defendant was aware that this pattern, practice, and/or policy was  contrary to law, and was therefore a willful violation.   37.  As a result of Defendant’s violations of the FLSA, Plaintiff and others  similarly-situated have suffered damages by being denied overtime wages in  accordance with the FLSA in amounts to be determined at trial, and are entitled to  recovery of such amounts, liquidated damages in an amount equal to their unpaid  wages, pre-judgment and post-judgment interest, reasonable attorneys’ fees, costs,  and punitive damages pursuant to 29 U.S.C. §216(b).   39.  Defendant has not made a good faith effort to comply with the FLSA  with respect to the compensation of Plaintiff and others similarly situated.   40.  Because Defendant’s violations of the FLSA have been willful, a  three-year statute of limitations applies, pursuant to the FLSA, 29 U.S.C. §255(a).   41.  Plaintiff and the technicians seek to enjoin Defendant from its  continuing violations of 29 U.S.C. §207.  42.  Plaintiff incorporates and re-alleges all of the preceding paragraphs as  if they were fully set forth herein.   43.  At all relevant times, Plaintiff and the Class were employed by Pop A  Lock within the meaning of the NJWHL.   44.  Pop A Lock willfully violated Plaintiff’s rights, and the rights of the  members of the Class, by failing to pay them overtime compensation at rates not less  than one and one-half times their regular rate of pay during each hour worked in  excess of forty (40) hours in a work week.   Fair Labor Standards Act, 29 U.S.C. §201, et seq.: Failure to Pay Overtime  (Brought on Behalf of Plaintiff and the Collective)   NJWHL, N.J.S.A. 34 § 11-56a4, Failure to Pay Overtime  (Brought on Behalf of Plaintiff and the NJWHL Class)  