13.  Defendant Caesars Entertainment Corporation is a private gaming corporation  that owns and operates casinos, hotels, and golf courses under several brands.  The company,  based in  Nevada, is the largest gaming company in the world, with yearly revenues of  approximately 10.8 billion.  Defendant Caesars Entertainment Corporation owns and operates  the following casinos in Atlantic City: Bally’s Atlantic City, Caesars Atlantic City, Harrah’s  Atlantic City and Showboat.    14.  Defendant Bally’s Park, Inc. is a wholly owned subsidiary of Defendant  Harrah’s Operating Company, Inc., which is a direct, wholly owned subsidiary of Defendant  Caesars Entertainment Corporation.     16.  At all times mentioned in this Complaint, Defendants were engaged in the  business of legalized gambling; in connection with such business, Defendants engaged in  interstate commerce by drawing patrons from outside the state of New Jersey, purchasing  gambling equipment and other gambling paraphernalia from outside the state of New Jersey,  and conducting other such activities outside the state of New Jersey.    17.  Plaintiff ROSEMARY CLARK and all non-exempt casino employees of  Defendants were required to perform various tasks for the benefit of Defendants without  compensation, including attending meetings called “Buzz Sessions,” which were held pre-shift,  during lunch breaks or post-shift.     18.  During the relevant time period, Defendants enforced policies that required  Plaintiff ROSEMARY CLARK and others similarly situated to work off-the-clock for which  they were not compensated in violation of N.J.S.A. 34:11-56a et seq. Defendants also  employed Plaintiff, and members of the proposed class for many work weeks longer than forty  (40) hours and knowingly and willfully failed and refused to compensate each individual for  such work week in excess of forty (40) hours at rates not less than one and one-half times the  regular rates at which they were employed, contrary to provisions of N.J.S.A. 34:56a4.     20.  Plaintiff brings this action as a class action under the New Jersey Wage and  Hour Laws and Rule 23 of the Federal Rules of Civil Procedure on behalf of the following  class: All non-exempt casino employees of Defendants who, at any time during the statutory  period, were not compensated for all time worked and/or all overtime worked.   21.  Plaintiff ROSEMARY CLARK is a member of the Class she seeks to represent.     22.  Numerosity.  The potential members of the Class are so numerous that joinder  of all members would be impractical.  The precise number of potential class members has not  been determined, but there are at 7,000 employees currently employed by Defendant Bally’s  Park Place, Inc. with an unknown number of others who have been employed by Defendant  Caesars Entertainment Corporation at its Atlantic City casinos within the applicable liability  period, and who have had their rights violated by Defendants’ unlawful scheme.     24.  Typicality.  The claims of Plaintiff ROSEMARY CLARK are typical of the  claims of the Class she seeks to represent.  The illegal practices that have denied Plaintiff of  her rights under New Jersey law are the same practices that have and will continue to deny the  rights of Class members.  Plaintiff will seek the same types of damages, restitution and other  relief as the Class members.     25.  Adequacy of Class Representation.  Plaintiff will fairly and adequately represent  and protect the interests of the members of the Class.    26.  Adequacy of Class Counsel.  Plaintiff’s counsel are competent and experienced  in litigating class actions and have prosecuted labor and employment cases involving similar  issues.    28.  The allegations set forth in paragraphs 1 through 27 are incorporated herein by  reference.   29.  Plaintiff ROSEMARY CLARK brings this claim on behalf of herself and the  members of the Class for relief against Defendants pursuant to N.J.S.A. 34:11-56a for payment  of their full earned wages and all wages earned to them and on behalf of herself and members  of the Class.     30.  Pursuant to N.J.S.A. 34:11-56a4, Plaintiff and the proposed Class were entitled  to the payment of their full wages for each hour or portion thereof that they worked in the  amount promised by their contract of employment and were entitled to the full payment of any  wages required by any statute or regulation.     31.  Additionally, pursuant to N.J.S.A. 34:11-56a4, Plaintiff and the proposed Class  were entitled to the payment of not less than 1 ½ times their regular hourly rate for each hour  of working time in excess of 40 hours in any week.     32.  Further, Defendants were required by N.J.S.A. 34:11-56a20 to establish and  maintain records of the hours worked and the wages paid to each employee.   34.  Plaintiff ROSEMARY CLARK on behalf of herself  and all others similarly  situated, demands judgment against Defendants for unpaid wages, overtime wages,  compensatory damages along with reasonable attorneys’ fees and costs of suit, and such other  statutorily and other relief as the Court deems proper and just.    WHEREFORE, Plaintiff prays judgment against Defendants, as set forth herein below.  VIOLATIONS OF NEW JERSEY WAGE AND HOUR LAWS  (By Plaintiff Rosemary Clark Against All Defendants)  