            16.  Plaintiffs bring claims for relief as a collective action pursuant to FLSA Section  16(b), 29 U.S.C. § 216(b), on behalf of all non-exempt employees (including tile installers, tile  installer helpers, drivers, laborers) employed by Defendants on or after the date that is six years  before the filing of the Complaint in this case as defined herein (“FLSA Collective Plaintiffs”).              17. At all relevant times, Plaintiffs and the other FLSA Collective Plaintiffs are and have  been similarly situated, have had substantially similar job requirements and pay provisions, and  are and have been subjected to Defendants’ decisions, policies, plans, programs, practices,  procedures, protocols, routines, and rules, all culminating in a willful failure and refusal to pay  them the proper overtime premium at the rate of one and one half times the regular rate for work  in excess of forty (40) hours per workweek. The claims of Plaintiffs stated herein are essentially  the same as those of the other FLSA Collective Plaintiffs.             18.  The claims for relief are properly brought under and maintained as an opt-in  collective action pursuant to §16(b) of the FLSA, 29 U.S.C. 216(b). The FLSA Collective Plaintiffs  are readily ascertainable. For purposes of notice and other purposes related to this action, their  names and addresses are readily available from the Defendants. Notice can be provided to the  FLSA Collective Plaintiffs via first class mail to the last address known to Defendants.  24.    Defendants knowingly and willfully operated their business with a policy of not  paying Plaintiffs the New York State overtime rate (of time and one-half).   25.  Defendants knowingly and willfully operated their business with a policy of not  providing a proper wage notice to Plaintiffs and other non-exempt employees at the beginning of  employment and annually thereafter, in violation of the New York Labor Law.    26.  When Defendants became aware Plaintiffs were contemplating to bring FLSA and  New York Labor Law claims Defendants retaliated against the Plaintiffs to avoid this litigation by  asking Immigration authorities to investigate Defendants immigration status and get them  deported.     27.  Plaintiffs retained Lee Litigation Group, PLLC to represent Plaintiffs, FLSA  Collective Plaintiffs and Class members, in this litigation and has agreed to pay the firm a  reasonable fee for its services.  38.  Plaintiffs reallege and reaver Paragraphs 1 through 37 of collective action  Complaint as if fully set forth herein.   39.  At all relevant times, Plaintiffs were employed by the Defendants within the  meaning of the New York Labor Law, §§2 and 651.     40.  Defendants willfully violated Plaintiffs’ rights by failing to pay them overtime  compensation at the rate of not less than one and one-half times the regular rate of pay for each  hour worked in excess of forty hours in a workweek.   41.  Defendants failed to properly notify employees of their hourly pay rate and  overtime rate, in direct violation of the New York Labor Law.   42.   Defendants failed to provide a proper wage and hour notice, at the date of hiring  and annually, to all non-exempt employees per requirements of the New York Labor Law.   44.  Defendants willfully violated Plaintiffs’ rights by paying them on a salary basis, in  violation of the New York Labor Law because Plaintiffs are non-exempt employees who must be  paid on an hourly basis.   45.  Due to the Defendants’ New York Labor Law violations, Plaintiffs are entitled to  recover from Defendants their unpaid overtime, reasonable attorneys’ fees, liquidated damages,  retaliation damages, statutory penalties and costs and disbursements of the action, pursuant to New  York Labor Law.    VIOLATION OF THE NEW YORK LABOR LAW ON BEHALF OF PLAINTIFFS  