14.  Plaintiff seeks to bring this suit to recover from Defendants unpaid overtime  compensation and liquidated damages pursuant to the applicable provisions of the FLSA, 29  U.S.C. § 216(b), individually, on her own behalf, as well as on behalf of those in the following  collective:  Current and former non-managerial employees of Defendants, who  during the applicable FLSA limitations period, performed any  work for Defendants as bartenders or waitresses, or in a similar  role, and who consent to file a claim to recover damages for  overtime compensation that is legally due to them (“FLSA  Plaintiffs”).    15.  Defendants treated Plaintiff and all FLSA Plaintiffs similarly in that Plaintiff and  all FLSA Plaintiffs: (1) performed similar tasks, as described in the “Background Facts” section  below; (2) were subject to the same laws and regulations; (3) were paid in the same or similar  manner; (4) were required to work in excess of forty hours in a workweek; and (5) were not paid  the required one and one-half times their respective regular rates of pay, or one and one-half  times the minimum wage rate, if greater, for all hours worked per workweek in excess of forty.   16.  At all relevant times, Defendants are and have been aware of the requirements to  pay Plaintiff and all FLSA Plaintiffs at an amount equal to the rate of one and one-half times  their respective regular rates of pay, or one and one-half times the minimum wage rate, if greater,  for all hours worked each week over forty, yet they purposefully and willfully chose and choose  not to do so.    18.  Defendant Galeas owns and operates Dyckman, a bar and restaurant located at  221 Dyckman Street, New York, New York.     19.  At all times relevant herein, Defendants have employed and continue to employee  at least eleven employees.   20.  In March 2015, Defendant Galeas, on behalf of Dyckman, hired Plaintiff to work  for Defendants as a bartender and waitress.     21.  Defendants, prior to or at Plaintiff’s hire, failed to provide Plaintiff with a written  notice of her pay rate, their intent to claim a tip credit against the minimum wage, or her regular  payday.   22.  Defendant Galeas personally hired Plaintiff and supervised Plaintiff’s day-to-day  duties at the bar and restaurant.     23.  As a bartender and waitress, as its name suggests, Plaintiff’s main duties consisted  of preparing drinks and food orders, polishing glasses, serving customers, and providing bottle  service.   25.  During the month of February 2017, Dyckman required Plaintiff to work, and  Plaintiff did work, at The Kilt (also known as The Bronx Public) in addition to her regularly  scheduled hours at Dyckman.  In February 2017, Defendants required Plaintiff to work up to  seven days per week at both The Kilt and Dyckman Bar.   26.  From the beginning of Plaintiff’s employment up until the date of filing of this  Complaint, Defendants paid and continue to pay Plaintiff an hourly rate of $7.50 for all hours  worked.  Throughout this employment, Defendants have failed to pay Plaintiff an overtime  premium of one and one-half times her regular hourly rate for any hours that she worked in a  week in excess of forty.    27.  By way of example only, during the week of February 26 through March 4, 2017,  Defendants required Plaintiff to work, and Plaintiff did work, seven days as follows: Sunday  from 4:30 p.m. until 5:00 a.m.; Monday through Thursday from 5:00 p.m. until 1:00 a.m.; and  Friday through Saturday from 4:30 p.m. until 5:00 a.m., without any scheduled or uninterrupted  breaks.  During that week, Defendants paid Plaintiff at the rate of $7.50 per hour for all hours  worked, including those that she worked in excess of forty.   28.  Additionally, throughout her employment, on every workday that Plaintiff worked  for Defendants on Friday through Sunday, her spread of hours from the beginning of each shift  to the end exceeded ten.  However, on those days, Defendants failed to compensate Plaintiff with  an additional hour’s pay at the New York State minimum wage rate.   29.  Defendants paid Plaintiff on a weekly basis by check.     31.  Additionally, Defendants did not provide Plaintiff with a wage notice at the time  of her hire that accurately contained, inter alia, Plaintiff’s rates of pay as designated by the  employer or an intent to claim a tip credit.   32.  Defendants treated Plaintiff and all FLSA Plaintiffs in the same manner described  herein.   33.  Defendants acted in the manner described herein so as to maximize their profits  and minimize their labor costs and overhead.   34.  Each hour that Plaintiff and FLSA Plaintiffs worked was for Defendants’ benefit.   35.  Making matters much worse, in a letter dated July 11, 2017, Plaintiff complained  to Defendants, in writing, about Defendants’ failure to pay her for all overtime hours worked, as  well as Defendants’ failure to pay Plaintiff at the minimum wage or provide Plaintiff with spread  of hours premiums, proper wage statements on each payday, or a proper wage notice at the time  of hire, all as the NYLL requires.  Immediately upon receiving this letter, Defendants retaliated  against Plaintiff by cutting her schedule from five days per week to one day per week, effectively  cutting her hours from fifty-three and one-half hours to eight hours per week.  As a result,  Defendants reduced Plaintiff’s pay from approximately $300.00 per week to approximately  $60.00 per week, and Plaintiff lost approximately $240.00 in her weekly income.   37.  Defendants did not allow Plaintiff to cover coworkers’ shifts on approximately  five subsequent occasions, to wit on August 19, 2017; August 31, 2017; September 2, 2017;  September 3, 2017; and September 9. 2017.   38.  Moreover, on August 22, 2017, Defendant Galeas called Plaintiff’s employer  from another establishment, Jeffrey Pichardo, and said he should hire Plaintiff full-time as an  additional act of retaliation.   39.  Defendants never refused Plaintiff permission to cover coworkers’ shifts prior to  receiving Plaintiff’s complaint about Defendants’ unlawful payroll practices.  40.  Plaintiff and FLSA Plaintiffs repeat, reiterate, and re-allege each and every  allegation set forth above with the same force and effect as if more fully set forth herein.   41.  29 U.S.C. § 207(a) requires employers to compensate their employees at a rate not  less than not less than the greater between one and one-half times their regular rates of pay, or  one and one-half times the minimum wage, for all hours worked exceeding forty in a workweek .     42.  As described above, Defendants are employers within the meaning of the FLSA,  while Plaintiff and FLSA Plaintiffs are employees within the meaning of the FLSA.   43.  As also described above, Plaintiff and FLSA Plaintiffs worked in excess of forty  hours per week, yet Defendants failed to compensate Plaintiff and FLSA Plaintiffs in accordance  with the FLSA’s overtime provisions.    44.  Defendants willfully violated the FLSA.   46.  Plaintiff and FLSA Plaintiffs are also entitled to liquidated damages and  attorneys’ fees for Defendants’ violation of the FLSA’s overtime provisions.  47.  Plaintiff, and any FLSA Plaintiff that opts in to this action, repeat, reiterate, and  re-allege each and every allegation set forth above with the same force and effect as if more fully  set forth herein.    48.  N.Y. Lab. Law § 160 and 12 NYCCRR § 142-2.2 require employers to  compensate their employees at a rate not less than the greater between one and one-half times  their regular rates of pay, or one and one-half times the minimum wage, for all hours worked  exceeding forty in a workweek.   49.  As described above, Defendants are employers within the meaning of the NYLL  and the NYCCRR, while Plaintiff, and any FLSA Plaintiff that opts in to this action, are  employees within the meaning of the NYLL and the NYCCRR.   50.  As also described above, Plaintiff, and any FLSA Plaintiff that opts in to this  action, worked in excess of forty hours per week, yet Defendants failed to compensate them in  accordance with the NYLL’s and the NYCCRR’s overtime provisions.   51.  Plaintiff, and any FLSA Plaintiff that opts in to this action, are entitled to their  overtime pay for all hours worked per week in excess of forty at the rate of one and one-half  times their respective regular rates of pay, one and one-half times the minimum wage rate, if  greater.   53.  Plaintiff, and any FLSA Plaintiff that opts in to this action, repeat, reiterate, and  re-allege each and every allegation set forth above with the same force and effect as if more fully  set forth herein.    54.  N.Y. Lab. Law § 652 and 12 NYCCRR § 146-1.2 prescribe a minimum wage that  employers must pay to their employees for each hour worked.    55.  As described above, Defendants are employers within the meaning of the NYLL  and the NYCCRR, while Plaintiff, and any FLSA Plaintiff that opts in to this action, are  employees within the meaning of the NYLL and the NYCCRR.    56.  As also described above, Defendants did not compensate Plaintiff, or any FLSA  Plaintiff that opts in to this action, at the minimum hourly rate required by the NYLL and  NYCCRR for all hours worked.    57.  At the least, Plaintiff, and any FLSA Plaintiff that opts in to this action, are  entitled to the minimum rate of pay required by the NYLL and NYCCRR for all hours worked.    58.  Plaintiff, and any FLSA Plaintiff that opts in to this action, are also entitled to  liquidated damages, interest, and attorneys’ fees for Defendants’ violations of the NYLL’s and  NYCCRR’s minimum wage provisions.  Failure to Pay Minimum Wages under the NYLL and the NYCCRR   Unpaid Overtime Under the NYLL and the NYCCRR   Unpaid Overtime Under the FLSA  