(29 U.S.C. § 216(b) Individual Claim)  Violation of the Fair Labor Standards Act, 29 U.S.C. § 201, et seq.  FAILURE TO PAY OVERTIME   (Nev. Rev. Stat. Ann. § 608.018, Individual Claim)  FAILURE TO PAY OVERTIME  116.  Plaintiff re-alleges and incorporates all previous paragraphs herein.  117.  N.R.S. § 608.018(2) provides:  An employer shall pay 1 1/2 times an employee’s regular wage  rate whenever an employee who receives compensation for  employment at a rate not less than 1 1/2 times the minimum rate  prescribed pursuant to NRS 608.250 works more than 40 hours in  any scheduled week of work.  118.  Plaintiff regularly worked over forty (40) hours a week as required by Defendant.  119.  Defendant failed to pay Plaintiff for the time spent performing pre-shift and post- shift work at the state mandated overtime compensation at a rate not less than time-and-a-half  (1.5) of Plaintiff’s regular rate of pay for hours worked in excess of forty (40) in a workweek.  120.  In addition, Defendant failed to incorporate compensation paid to Plaintiff as shift  differentials into her regular rate of pay, for purposes of calculating her hourly overtime rate.  121.  As a result of the foregoing, Plaintiff was illegally denied proper overtime  compensation, in such amounts to be determined at trial, and is entitled to recovery of such total  unpaid wages and reasonable attorneys’ fees and costs pursuant to N.R.S. § 608.140.  21.  Defendant is an employer as defined under Nev. Rev. Stat. Ann. § 608.011 and 29  U.S.C. § 203(d) of the FLSA.    22.  Plaintiff and other Dispatcher were “employees” of Defendant within the meaning  of Nev. Rev. Stat. Ann. § 608.011 and 29 U.S.C. § 203(e)(1) of the FLSA.    23.  Defendant was and continues to be “an enterprise engaged in commerce” within  the meaning of the FLSA.    24.  Defendant’s annual sales exceed $500,000 and it has more than two employees,  so the FLSA applies in this case on an enterprise basis.    25.  Defendant “suffered or permitted” Plaintiff and other Dispatcher to work and thus  “employed” them within the meaning of 29 U.S.C. § 203(g) of the FLSA.   26.  Defendant’s Dispatchers are hourly-paid, non-exempt employees.   27.  In addition to their hourly rates, Dispatchers receive shift differential for working  certain shifts.   73.  Plaintiff re-alleges and incorporates all previous paragraphs herein.   74.  Plaintiff asserts the foregoing violations not only individually, but collectively  pursuant to 29 U.S.C. 216(b) on behalf of the “FLSA Collective,” defined as:   All Dispatchers who worked for the Defendant at any time during  the period of three (3) years prior to the commencement of this  action through the date of judgment.  (hereinafter referred to as the “FLSA Collective”). Plaintiff reserves the right to amend this  definition as necessary.   75.  Members of the FLSA collective are all improperly compensated for the time  spent performing pre-shift and post-shift work.   84.  Plaintiff re-alleges and incorporates all previous paragraphs herein.   95.  Plaintiff re-alleges and incorporates all previous paragraphs herein.  