39.  Plaintiff and those similarly situated incorporate herein by this reference the allegations  contained in Paragraphs 1 through 38 of this Complaint as if set forth verbatim.    40.  Plaintiff brings her First Claim for Relief, the FLSA claim, as an “opt-in” collective action  pursuant to 29 U.S.C. § 216(b).  In addition to the claims of Class Representatives, Plaintiff  brings a Colorado Wage Act claim and a breach of contract claim as a collective action pursuant  to Colo. R. Civ. P. 23 and/or Fed. R. Civ. P. 23, on behalf of herself and as representatives of the  following class: all current and former non-exempt employees of Defendants who worked for the  Defendants at any time in the last three years who were not paid for all of the time they  performed work-related tasks including overtime.   41.  The FLSA claims may be pursued by those who opt-in to this case, pursuant to 29 U.S.C. §  216(b). The Colorado State law claims, if certified for class-wide treatment, may be pursued by  all similarly-situated Colorado Opt-in Plaintiffs who do not opt-out of the class.    50.  Plaintiff and those similarly situated re-allege, and incorporate here by reference, all allegations  contained in paragraphs 1 through 49 of this Complaint as if set forth verbatim.   51.  At all times material herein, Opt-in Plaintiffs have been entitled to the rights, protections, and  benefits provided under the FLSA, 29 U.S.C. §§ 201 et seq.    52.  The FLSA regulates, among other things, payment of overtime pay by employers such as the  Defendants.    53.  Defendants were, and are, subject to the recordkeeping and overtime pay requirements of the  FLSA because they are an enterprise engaged in commerce and its employees are engaged in  commerce.    54.  Defendants violated the FLSA by failing to pay Opt-in Plaintiffs for all of their time worked,  including overtime. In the course of perpetrating these unlawful practices, Defendants have also  willfully failed to keep accurate records of all hours worked by employees. Defendants have also  willfully failed to provide paystubs to their employees and/or documentation of hours worked  and monies paid to their employees.   55.  Section 13 of the FLSA, 29 U.S.C. § 213, exempts certain categories of employees from  overtime pay obligations. None of the FLSA exemptions apply to Opt-in Plaintiffs. Accordingly,  Opt-in Plaintiffs must be paid overtime pay in accordance with the FLSA.    56.  Opt-in Plaintiffs were automatically clocked out by Defendants for their meal breaks, but  were/are required to perform work-related duties during meal breaks. P Opt-in Plaintiffs were/are  not paid for work-related interruptions that occurred/occur during meal breaks during their shifts  wherein they worked more than five consecutive hours. Defendants failed to change Plaintiff’s  and those Opt-in Plaintiffs’ time records to reflect the additional time worked on behalf of the  employer even when Opt-in Plaintiffs and those similarly situated requested that their time  records be corrected by management.   62.  Plaintiff and those similarly situated re-allege, and incorporate here by reference, all allegations  contained in paragraphs 1 through 61 of this Complaint as if set forth verbatim.   63.  At all times material herein, Plaintiff, individually, is entitled to the rights, protections, and  benefits provided under the FLSA, 29 U.S.C. §§ 201 et seq.     64.  The FLSA regulates, among other things, payment of overtime pay by employers such as the  Defendants.    65.  Defendants were, and are, subject to the recordkeeping and overtime pay requirements of the  FLSA because they are an enterprise engaged in commerce and its employees are engaged in  commerce.    74.  Plaintiff and those similarly situated re-allege, and incorporate here by reference, all allegations  contained in paragraphs 1 through 73 of this Complaint as if set forth verbatim.   Violation of the Fair Labor Standards Act of 1938 and Failure to Maintain Records  (ALL CLASS MEMBERS)   Violation of the Fair Labor Standards Act of 1938 and Failure to Maintain Records  (CLASS REPRESENTATIVE, INDIVIDUALLY)   Violation of the Colorado Wage and Hour Laws and Failure to Maintain Records  (ALL CLASS MEMBERS)   