17.  This action is properly maintainable as a collective action pursuant to the Fair  Labor Standards Act, 29 U.S.C. § 216(b).   18.  This action is brought on behalf of Plaintiff and a putative collective consisting  of similarly situated employees who performed work for Defendants.   20.  The claims of the Plaintiff are typical of the claims of the putative class. The  Plaintiff and putative class members were all subject to Defendants’ policies and willful  practices of failing to pay employees all earned overtime wages. The Plaintiff and putative class  members thus have sustained similar injuries as a result of Defendants’ actions.   21.  Upon information and belief, Defendants uniformly apply the same employment  policies, practices, and procedures to all employees who work at the Defendants’ valet.   22.  This action is properly maintainable as a collective action pursuant to § 216(b) of  the Act.  23.  Based upon the information preliminarily available, and subject to discovery in this  cause, the Defendants employed the Plaintiff and members of the putative class to perform  tasks in furtherance of their valet and transportation business.    24.  Based upon the information preliminarily available, and subject to discovery in this  cause, the Defendants did not properly compensate Plaintiff Mejias for his overtime hours worked  in a work week.   25.  Plaintiff Mejias was an hourly employee and his hourly rate of pay was $8.50 per  hour.    26.  During the months of October, November, December and January, on average,  Plaintiff Mejias worked (10) shifts each week. Each shift was approximately (8) hours long   28.  During the remaining months of the year, February through September, on average,  Plaintiff Mejias worked (6) to (7) shifts per week. Each shift was approximately (8) hours long.    29.  Plaintiff Mejias worked (48) or (56) hours per week during these months,  depending on the number of shifts in a given week.    30.  Plaintiff Mejias was not paid at one-and-one half times his hourly rate of pay for  his hours worked over forty (40) in a workweek.    31.  Plaintiff Mejias was only paid his regular rate of pay for all hours worked, including  those worked in excess of forty each week.    32.  Upon information and belief, employees similarly situated to Plaintiff were also  only compensated at their regular rate of pay for all hours worked, regardless of the fact that they  worked in excess of forty (40) hours in a workweek.   33.  Beginning in November, 2018, Defendants did not provide Plaintiff with paid  sick or personal time; rather, when Plaintiff took time from work, regardless of whether he was  sick, he was not paid.    34.  At all times material hereto, Plaintiff and all similarly situated employees were  performing their duties for the benefit of and on behalf of Defendants.   35.  This cause of action is brought to recover from Defendants overtime compensation,  liquidated damages, and the costs and reasonable attorneys’ fees under the provisions of 29 U.S.C.  §201,et.seq., as well as applicable provisions of the NJWHL,  and to recover unpaid sick time in  accordance with the NJWHL, on behalf of Plaintiff during the material time.   37.  Plaintiff has retained the law office of Jaffe Glenn Law Group, P.A. to represent  him individually and incurred attorneys’ fees and costs in bringing this action.  Pursuant to 29  U.S.C. § 216(b), Plaintiff is entitled to recovery of reasonable attorneys’ fees and costs.  38.  Plaintiff re-alleges, and incorporates here by reference, all allegations contained in  Paragraphs 1 through 37 above.   39.  Plaintiff is entitled to be paid additional compensation for each of his overtime  hours worked per work period.    40.  All similarly situated employees of the Defendants are also owed their overtime  rate for each and every overtime hour they worked and were not properly paid.   41.  Defendants knowingly and willfully failed to pay Plaintiff and other similarly  situated employees at time and one half of their regular rate of pay for their overtime hours worked  in a work period.     42.  By reason of the said intentional, willful, and unlawful acts of Defendants, Plaintiff  and all similarly situated employees have suffered damages plus incurring costs and reasonable  attorneys’ fees.   43.   As a result of Defendants’ willful violations of the Act, Plaintiff and those similarly  situated employees are entitled to liquidated damages.  44.  Plaintiff re-alleges, and incorporates here by reference, all allegations contained in  Paragraphs 1 through 43 above.   45.  Defendants’ afore mentioned conduct is in violation of the NJWHL.  In violation  of New Jersey Statutes §§ 34:11-56a4 et seq., the Defendants willfully failed to pay the Plaintiff  and other members of the putative class their statutorily required overtime compensation for  the time they worked in excess of forty (40) hours a week for the Defendants.   46.  Plaintiff and all similarly situated employees are entitled to one-and-one half times  their regular hourly wage for each hour of working time in excess of 40 hours in any week.    47.  Defendants’ afore mentioned conduct is in violation of the NJWHL.   48.  As a direct and proximate cause of Defendants’ actions, Plaintiff and all similarly  situated employees suffered damages, including but not limited to lost wages and liquidated  damages.  49.  Plaintiff re-alleges, and incorporates here by reference, all allegations contained in  the paragraphs above.   50.  Plaintiff was not provided sick leave.   51.  Defendants did not have a policy by which Plaintiff earned sick leave.   52.  As a result of not earning sick leave, Plaintiff suffered damages.  Plaintiff seeks  actual damages, as well as additional damages as dictated in the statute.  RECOVERY OF DAMAGES FOR DEFENDANTS’  VIOLATION OF NEW JERSEY’S PAID SICK   LEAVE STATUTE SICK LEAVE   RECOVERY OF OVERTIME COMPENSATION  PURSUANT TO THE FLSA  