27.  Gen 1 provides an array of security and protection services to its clients in the Denver,  Colorado area.2   28.  Rader and Gen 1’s other Security Guards are the employees who perform the services  Gen 1’s provides to its clientele.    30.  Gen 1 pays all its Security Guards at straight-time-for-overtime regardless of the  number of hours worked that workweek.   31.  Many of Gen 1’s Security Guards also regularly work in excess of 12 hours in a day  and/or in excess of 12 consecutive hours.   32.  Gen 1 pays all its Security Guards at their straight-time rates for hours worked in excess  of 12 hours in a day and/or in excess of 12 consecutively.   33.  In January of 2019 Rader began working for Gen 1 in the Denver, Colorado area.    34.  As a Security Guard Rader spends his time patrolling the perimeter of Gen 1’s clients’  facilities and checking the identification of those who enter.    35.  Gen 1’s records reflect the hours Rader works each workweek and pay period.   36.  Gen 1 pays Rader $15.00 per hour.    37.  Although he often works more 50 or more hours per workweek, Gen 1 never pays  Rader any overtime but, rather, pays him for all hours at his regular hourly rate.   38.  Additionally, although he regularly works in excess of 12 hours in a day and/or 12  hours consecutively, Gen 1 never pays Rader more than his straight-time rate for these hours.   39.  For example, for the pay period from July 1 through July 15, 2019, Rader worked  119.90 hours and Gen 1 paid him at the same hourly rate  for all these hours:    41.  Further, on July 3, 2019 Rader worked in excess of 14 hours total:   42.  All Gen 1’s Security Guards perform duties like those Rader performs including  patrolling the perimeter of client facilities and checking the identification of those who enter.   43.  The Security Guards work similar hours and are denied overtime as a result of the  same illegal straight-time-for-overtime pay practice.    44.  All Gen 1’s Security Guards work in excess of 40 hours each workweek.   45.  Many of the Security Guards also regularly work in excess of 12 hours in a day or in  excess of 12 hours consecutively.   46.  Instead of paying Security Guards overtime, Gen 1 pays them straight-time-for- overtime for all these hours.   63.  Numerous employees have been denied overtime by Gen 1’s straight-time-for- overtime plan.    64.  From his observations and experience at Gen 1, Rader is aware that the illegal practices  or policies of Gen 1 have been imposed on the Security Guards.    66.  These employees are similarly situated to Rader in terms of relevant job duties, pay  provisions, and employment practices.   67.  Gen 1’s failure to pay overtime as required by the FLSA results from a generally  applicable, systematic pay plan that is not dependent on the personal circumstances of the Security  Guards.    68.  Thus, Rader’s experiences are typical of the experiences of the Security Guards.   69.  The specific job titles or precise job locations of the various Security Guards do not  prevent collective treatment.    70.  All Security Guards, regardless of their precise job requirements or rates of pay, are  entitled to overtime for hours worked in excess of 40 in a week.   71.  Gen 1 employs 12 Hour Guards in Colorado.   72.  Gen 1 maintains a physical location in Colorado.   73.  Gen 1 is a commercial support service company within the meaning of the CWA and  the applicable Colorado Minimum Wage Orders because it is a business or enterprise that is directly  or indirectly engaged in providing security and protection services, to other commercial firms through  the use of service employees such as Plaintiffs and the other Security Guards.   75.  Although Rader does not know the precise number of 12 Hour Guards, Rader believes  there are more than 40 individuals that fit into the class.   76.  The 12 Hour Guards are so numerous that their individual joinder is impractical.   77.  The identities of the members of the 12 Hour Guards are readily discernible from  Gen 1’s records.   78.  Rader and the 12 Hour Guards have a commonality of interest in the subject matter  and remedy sought, namely back wages plus penalties, interest, attorneys’ fees and the cost of this  lawsuit.   79.  Common questions of law and fact exist to all members of the 12 Hour Guards.    80.  These questions predominate over the questions affecting individual class members.    81.  These common legal and factual questions include, but are not limited, to the  following:  a)   Whether Rader and the 12 Hour Guards worked hours in excess of forty (40)  hours per workweek;  b)   Whether Rader and the 12 Hour Guards worked in excess of twelve (12) hours  per day or for twelve (12) consecutive hours;   c)   Whether Rader and the 12 Hour Guards were denied overtime pay at a rate  not less than one-and-one-half times their regular rates as prescribed by Colorado Law;   82.  These and other common questions of law and fact, which are common to the 12  Hour Guards, predominate over any individual questions affecting only individual members.   84.  Rader is an adequate representative of the 12 Hour Guards because his interests do  not conflict with the interests of the 12 Hour Guards.     85.  Rader has retained competent counsel, highly experienced in complex class action  litigation, and they intend to prosecute this action vigorously.    86.  The 12 Hour Guards’ interests will be fairly and adequately protected by Rader and  his counsel.   87.  A Rule class action for the Colorado state law claims is superior to other available  means of fair and efficient adjudication of the state law claims of Rader and the 12 Hour Guards.   88.  The injuries suffered by each individual class member are relatively small in  comparison to the burden and expense of individual prosecution of a complex and extensive litigation  necessitated by Gen 1’s conduct.     89.  It would be virtually impossible for the 12 Hour Guards to individually redress  effectively the wrongs done to them; even if the 12 Hour Guards could afford such individual  litigation, the court system could not.     90.  Individualized litigation presents the possibility for inconsistent or contradictory  judgments.     91.  Individualized litigation increases the delay and expense to all parties and to the court  system presented by the complex, legal and factual issues of the case.     92.  By contrast, the class action presents far fewer logistical issues and provides the  benefits of a single adjudication, economy of scale and comprehensive supervision by a single court.     94.  The operative questions in this case are whether Rader and the 12 Hour Guards were  compensated at one-and-one-half times their regular rates for all overtime hours under Colorado law.     95.  Therefore, common evidence common will be determinative of the operative  questions presented. 