NEW YORK LABOR LAW – OVERTIME VIOLATIONS  (On Behalf of the NY Class)  194.  Plaintiffs, on behalf of themselves and all NY Class members, reallege and  incorporate by reference the paragraphs above as if they were set forth again herein.   195.  Plaintiffs were employed by Aldi within the meaning of the NYLL.  196.  At all relevant times, Defendant had a willful policy and practice of  misclassifying Plaintiffs and similarly situated Store Managers as “exempt” in order to avoid  paying them for all hours worked or appropriate overtime compensation for all hours worked in  excess of 40 hours per workweek.  197.  As a result of the Defendant’s willful failure to compensate its employees,  including Plaintiffs and the members of the NY Class, for all hours worked and at a rate not less  than one and one-half times the regular rate of pay for work performed in excess of 40 hours in a  workweek, Aldi has violated and, continues to violate, N.Y. Lab. Law Article 19 §§ 650, et seq.,  and the supporting New York State Department of Labor Regulations.   198.  Due to the Defendant’s violations of the NYLL, Plaintiffs and the members of the  NY Class are entitled to recover from the Defendant: compensation for unpaid wages; an  additional equal amount as liquidated damages; and reasonable attorneys’ fees and costs and  disbursements of this action, pursuant to N.Y. Lab. Law Article 19 § 663.    