11.  Plaintiff alleges that it was Defendants’ policy not to pay overtime until you  worked 60 hours in a workweek.  Accordingly, Plaintiff contends that neither she nor the  members of the putative class were paid overtime for any hours worked over 40 in a workweek.     12.  Based upon information and belief, Defendant Old Dominion Freight Line, Inc. is  a less-than-truckload, company.  It offers regional, inter-regional and national Less than  Truckload shipping (“LTL”) service. In addition to its core LTL services, the company offers  logistics services including ground and air expedited transportation, supply chain consulting,  transportation management, truckload brokerage, container delivery and warehousing, as well as  household moving services. It contracts with freight forwarding services throughout the world.   It is headquartered in Thomasville, North Carolina.    14.   Plaintiff hereby incorporates each and every allegation contained above and re- alleges said allegations as if fully set forth herein.   15.  Plaintiff alleges that Defendants never paid her or the other members of the  putative class overtime wages when they worked in excess of forty (40) hours in a week.    16.  Plaintiffs brings this suit as a Collective Action under the Fair Labor and  Standards Act, 29 U.S.C. § 201, et seq., (“FLSA”) on behalf of the “FLSA Class” defined as:  FLSA Class:  All persons who were, are, or will be employed by Defendants as a non-exempt employee  in the United States within the applicable limitations period, which is three years preceding the  filing of the original Complaint herein plus such additional time as may be provided pursuant to  equitable tolling.   17.  Plaintiffs allege that during the FLSA Class Period, they are and were:  (A.) individuals who resided in the United States of America;  (B.) were employed as “non-exempt” employees for Defendants in the United  States within the three years preceding the filing of the complaint herein;  (C.) worked more than 40 hours in any given week;  (D.) did not receive all overtime compensation for all hours worked over 40 hours  in any given week;  (E.) did not receive reimbursement for expenses that were paid for the primary  benefit of the named Defendants.   (F.) worked regular hours for which they received no pay whatsoever;  (G.) are members of the FLSA Collective Class as defined in the preceding  paragraph in this Complaint; and,  (H.) have signed a consent to sue that shall have been filed in this court.   19.  Plaintiff incorporates all preceding paragraphs as though fully set forth herein.   20.  Plaintiff brings this action on behalf of herself and all others similarly situated as  a class action, pursuant to Federal Rule of Civil Procedure Rule 23. The classes which Plaintiff  seeks to represent are composed of, and defined as follows:  Georgia Sub-Class:  All employees who were or are employed by Defendants during the Class  Period in Georgia as “non-exempt employees” between January 25, 2015  and the date of judgment in this action.  As used in this class definition,  the term "non-exempt employee" refers to those who Defendants have  classified as non-exempt.     (Collectively “Putative Class” or “Class Members”)   21.  The class is so numerous that the individual joinder of all members is  impracticable. While the exact number and identification of class members are unknown to  Plaintiff at this time and can only be ascertained through appropriate discovery directed to  Defendants, Plaintiff is informed and believes that the class includes potentially hundreds of  members.   23.  The claims of the named Plaintiff are typical of the claims of the members of the  putative class.  Plaintiff and other class members sustained losses, injuries and damages arising  from Defendants’ common policies, practices, procedures, protocols, routines, and rules which  were applied to other class members as well as Plaintiff.  Plaintiff seeks recovery for the same  type of losses, injuries, and damages as were suffered by other members of the proposed class.   24.  Plaintiff is an adequate representative of the proposed classes because she is a  member of the class, and her interests do not conflict with the interests of the members she seeks  to represent. Plaintiff has retained competent counsel, experienced in the prosecution of complex  class actions, and together Plaintiff and her counsel intend to prosecute this action vigorously for  the benefit of the classes. The interests of the Class Members will fairly and adequately be  protected by Plaintiff and her attorneys.   25.  A class action is superior to other available methods for the fair and efficient  adjudication of this litigation since individual litigation of the claims of all Class Members is  impracticable.  It would be unduly burdensome to the courts if these matters were to proceed on  an individual basis, because this would potentially result in hundreds of individuals, repetitive  lawsuits. Further, individual litigation presents the potential for inconsistent or contradictory  judgments, and the prospect of a “race to the courthouse,” and an inequitable allocation of  recovery among those with equally meritorious claims.  By contrast, the class action device  presents far fewer management difficulties, and provides the benefit of a single adjudication,  economics of scale, and comprehensive supervision by a single court.   27.  Plaintiff re-alleges and incorporates all preceding paragraphs as though fully set  forth herein.   28.  The Fair Labor Standards Act, 29 U.S.C. §201, et. seq., states that an employee  must be compensated for all hours worked, including straight time compensation and overtime  compensation.  (29 C.F.R. §778.223 and 29 C.F.R. §778.315.)  This Court has concurrent  jurisdiction over claims involving the Fair Labor Standards Act pursuant to 29 U.S.C. §216.   29.  Plaintiff also brings this lawsuit as a collective action under the Fair Standards  Labor Act, 29 U.S.C. §201, et. seq. (the “FLSA”), on behalf of all persons who were, are, or will  be employed by Defendants in a non-exempt hourly position during the period commencing  three years prior to the filing of this Complaint to and through a date of judgment, who  performed work in excess of forty (40) hours in one week and did not receive all compensation  as required by the FLSA for the hours worked.  To the extent equitable, tolling operates to toll  claims by and against the collective employees against the Defendants, the collective statute of  limitations should be adjusted accordingly.     31.  Questions of law and fact common to collective employees as a whole include,  but are not limited to the following:  a.  Whether Defendants’ policies and practices failed to accurately record all  hours worked by Plaintiff and other collective employees;  b.  Whether Defendants failed to adequately compensate collective employees for  expenses incurred for the direct benefit of Defendants as required by the  7.  Plaintiff incorporates all preceding paragraphs as though fully set forth herein.   8.  Plaintiff was employed by Defendants as a “Dock Worker” for approximately two  and a half (2 ½) years with her employment ending on August 1, 2017.  She started off part-time  and became a full-time employee with Defendants on March 6, 2015.  Plaintiff worked 10 to 12- hour shifts averaging between 45 to 55 hours a workweek.  She was paid $24.60 an hour.    9.  Plaintiff’s “Job Summary” as a “Dock Worker” included “successfully loads and  unloads freight throughout the shift using a forklift or manually in a safe, efficient manner.”   FAILURE TO PAY ALL WAGES AND OVERTIME COMPENSATION IN  VIOLATION OF THE FAIR LABOR STANDARDS ACT  (Against Defendants on behalf of Plaintiff   And Proposed Members of the Plaintiff Class)  