14.  Defendant JPMorgan Chase Bank, N.A. is a national banking association that “is one of  the oldest financial institutions in the United States.” Defendant is a “leader in  investment banking, financial services for consumers and small businesses, commercial  banking, financial transaction processing and asset management” whose stock is traded  on the New York Stock Exchange.  https://www.jpmorganchase.com/corporate/About- JPMC/about-us.htm.   15.  At all relevant times, Defendant has been, and continues to be, an “employer” engaged  in the interstate “commerce” and/or in the production of “goods” for “commerce” within  the meaning of the FLSA, 29 U.S.C. § 203. At all relevant times, Defendant has  employed, and/or continues to employ, “employee[s],” including Plaintiff and all  similarly situated employees. At all relevant times, Defendant has had gross operating  revenues in excess of $500,000.00 which is the threshold test for the “enterprise”  requirement under the FLSA.   16.  Defendant classifies Plaintiff and other Investigators as exempt employees not entitled  to overtime and paid them a “salary.”   18.  Plaintiff originally worked as an Investigator in Defendant’s Tempe, Arizona office.   Chase classified Plaintiff as a non-exempt, hourly employee entitled to overtime during  the time she performed the Investigator job there.   19.  Subsequently, Plaintiff moved to Defendant’s Tampa, Florida office and resumed her  Investigator job.  Defendant, however, classified Plaintiff as an exempt employee not  entitled to overtime when she performed the Investigator job in Tampa, Florida.  She  performed the same or similar Investigator job when she worked Tempe, Arizona and  Tampa, Florida.   20.  Defendant uniformly applied its exempt-designated, payment structure to all  Investigators.     21.  Defendant suffered and permitted Plaintiff and other Investigators to work more than forty  hours per week without overtime compensation for all hours worked. For example,  Plaintiff and other Investigators regularly worked at least five days a week. They usually  began work in the early morning. In addition, Plaintiff and other Investigators regularly  worked into the evenings and on the weekends, causing their hours worked to exceed forty  in a week on a regular basis.   22.  For example, while an Investigator, Plaintiff’s schedule has fluctuated from day-to-day  and during the time she has worked for Defendant.  Her current regular work schedule has  her working Mondays through Fridays, generally from 6:00 am until 3:00 pm without any  breaks or meal periods.  As such, during this time period, Plaintiff’s regular schedule had  her working an average of 45 hours per week.  This has been Plaintiff’s approximate work  schedule for about the last six (6) months.   24.  On information and belief, Chase is working other Investigators long hours to meet  mandatory production quotas which includes long work hours during early morning and  later evening work, and weekend work.   25.  Defendant knows Plaintiff and other Investigators worked more than forty hours in a  week because Defendant expects Plaintiff and Investigators to be available meet  production quotas which required working in the evenings and on weekends.   Defendant’s management employees constantly communicate with Plaintiff and other  Investigators to direct them to meet production quotas and work long hours to meet these  quotas.   26.  In addition, for example, Chase knows Plaintiff and other Investigators work long hours  including overtime because Chase expects Plaintiff and the other Investigators to timely  work cases in the que to complete their quotas including working in the evenings and on  the weekends.   27.  Defendant uniformly deny Plaintiff and other Investigators overtime pay.   28.  Defendant classifies Plaintiff and other Investigators as exempt employees who are not  entitled to overtime compensation.    29.  Defendant uniformly applies this policy and practice to all Investigators nationwide.   31.  Plaintiff and the other Investigators have/had the same primary duty of applying  Defendant’s mandatory guidelines, policies, and procedures via computer data entry to  verify the accuracy of customer and/or prospective customer submissions.   32.  Plaintiff and other Investigators are and were non-exempt computer, data-entry  employees who are and were entitled to overtime pay.    33.  Plaintiff and other Investigators do not customarily and regularly make sales at their  customers’ home or place of business.   34.  Plaintiff and other Investigators do not regularly supervise the work of two or more  employees.   35.  Plaintiff and other Investigators do not exercise discretion and independent judgment as  to matters of significance.   36.  Plaintiff and other Investigators do not perform office work related to Chase’s general  business operations or its customers.   37.  Plaintiff and other Investigators had no advance knowledge in a field of science or  learning which required specialized instruction that was required to perform the job.   38.  Chase does not require Plaintiff and other Investigators to have a college degree to obtain  an Investigator job.   39.  All Investigators are similarly situated in that they share common job duties and  descriptions, Chase treated them as exempt employees, and were all subject to Chase’s  misclassification policy and practice that failed to pay them overtime compensation.   41.  Defendant did not provide Plaintiff and the other Investigators with accurate paychecks.   42.  Defendant did not pay Plaintiff and other Investigators for all their overtime hours.  Accordingly, Defendant did not provide Plaintiff and other Investigators with all  compensation owed to them, including their unpaid overtime, at the time they separated  from the company.   43.  Defendant is aware of wage and hour laws, as evidenced by the fact that Defendant is a  large, sophisticated employer who employees have previously sued multiple times for  wage and hour violations, and Defendant provides minimum wage and overtime  compensation to other employees who are not Investigators.    44.  Defendant’s conduct, as set forth in this Complaint, was willful and in bad faith, and has  caused significant damages to Plaintiff and other Investigators.  FLSA Collective   45.  Plaintiff brings Count I on behalf of herself and other similarly situated employees as  authorized under the FLSA, 29 U.S.C. § 216(b). The similarly situated employees are:  All persons who are, have been, or will be employed by Defendant as “Investigators”  “Investigations Specialists,” and other similar investigation employees in similar job  titles in Chase’s Fraud Compliance Operations and Investigations (“FCOI”) Division  within the United States at any time during the last three years through the entry of  judgment in this case (“FLSA Collective”).  Plaintiff will subclass the FLSA Collective as necessary for certification and/or litigation  purposes.   47.  Defendant’s exempt classification of Plaintiff and other Investigators is a uniform policy,  decision, and/or plan that applies to all Investigators.   48.  Defendant’s failure to pay for work hours over 40 per week is a uniform policy, decision,  and/or plan that applies to all Investigators.   49.  Accordingly, Plaintiff and the FLSA Collective are subject to Defendant’s policy,  decision, and/or plan of failing to pay appropriate overtime compensation at the  appropriate rates.   50.  Defendant’s unlawful FLSA conduct has been widespread, repeated, and consistent.   51.  Upon information and belief, Defendant knows that Plaintiff and the FLSA Collective  performed work that required overtime pay. Defendant requires them to work long hours  and weekends to hit production quotas without the proper pay, and Plaintiff and/or those  similarly situated complained to Defendant about these practices.  Defendant operates  under a scheme to deprive these employees of overtime compensation by misclassifying  them as exempt and failing to properly compensate them for all overtime hours worked.   52.  Defendant’s conduct, as set forth in this Complaint, is and was willful and in bad faith,  and has caused significant damages to Plaintiff and the FLSA Collective.   54.  Plaintiff hereby incorporate by reference the foregoing paragraphs of this Complaint into  this count.   55.  The FLSA requires each covered employer such as Defendant to compensate all non-  exempt employees at a rate of not less than one and one-half times the regular rate of pay  for work performed in excess of forty hours per work week.   56.  The FLSA requires each covered employer such as Defendant to include all  compensation paid to employees such as incentive compensation and/or bonuses into the  employees’ regular rate of pay unless that compensation is specifically excluded.  The  FLSA does not exclude Defendant’s incentive compensation and/or bonus payments.   57.  Plaintiff and the FLSA Collective are entitled to be paid overtime compensation for all  hours worked at the appropriate rates of pay.   58.  Defendant, pursuant to its policies and practices, fails and refuses to pay overtime  premiums to Plaintiff and the FLSA Collective for all of their hours worked.   59.  Defendant violated the FLSA, 29 U.S.C. § 201 et seq. by failing to compensate Plaintiff  and the FLSA Collective for all overtime compensation at the legally required rates.   60.  By failing to record, report, and/or preserve accurate records of hours worked by Plaintiff  and the FLSA Collective, Defendant failed to make, keep, and preserve records with  respect to each of their employees sufficient to determine their wages, hours, and other  conditions and practice of employment, in violation of the FLSA, 29 U.S.C. § 201 et seq.   62.  Plaintiff, on behalf of herself and the FLSA Collective, seeks damages in the amount of  all respective unpaid overtime compensation at a rate of one and one-half times the  regular rate of pay for work performed in excess of forty hours in a work week, plus  liquidated damages as provided by the FLSA, 29 U.S.C. § 216(b), interest, and such  other legal and equitable relief as the Court deems just and proper.   Collective Action under §216(b) of the FAIR LABOR STANDARDS  ACT Overtime Claims  