21. All previous paragraphs are incorporated as though fully set forth herein.    22. Plaintiff brings this FLSA claim as a collective action pursuant to 29 U.S.C. § 216(b)  on behalf of all persons in the United States, who, since August 2016, previously  worked or currently work for Defendants as home health caregivers, who worked in  excess of 40 hours per week, but were not paid overtime for all hours worked in  excess of 40 per week, thereby depriving them of federally mandated overtime pay  for all hours worked in excess of 40 per week.     24. Plaintiff estimates that there are dozens, if not hundreds, of members of the FLSA  Collective Classes who have been affected by Defendants’ improper policies and  practices, based upon the number of current employees of Defendants, the number of  work locations maintained by Defendants, the Defendants’ treatment of all of its  employees in the same manner, and the turnover rate of Defendants’ employees in the  last three years.  It would be impractical to join all of those employees and former  employees in this action.   25. The precise number of persons in each of the FLSA Collective Action Classes can be  easily identified and located using Defendants’ timesheets, payroll, time records and  other personnel records.    26. Given the composition and size of the FLSA Collective Classes, potential opt-in class  members may be informed of the pendency of this Collective Action by text message,  direct mail and email.    28. In addition, because Defendants applied their unlawful employment and payment  policies in the same manner to all potential members of the FLSA Collective Action  Plaintiffs, common issues of law and fact predominate, and therefore pursuing this  matter as a collective action serves as the most expeditious use of the court’s time and  resources, as well as avoiding multiple actions on these issues, with the potential for  differing or inconsistent judgments.   30. In January 2017, Plaintiff began working for Defendants as a home health caregiver.   31. She worked for Defendants until December 2017.   32. Her hourly rate of pay was $8.00.     33. While working for Defendants, Plaintiff worked 56 hours per week performing  services for Defendants’ clients.     34. However, despite the fact that Plaintiff worked in excess of 40 hours per week for  Defendants, she was not and has not been properly paid overtime for all hours she  worked in excess of 40 per week.   35. All previous paragraphs are incorporated as though fully set forth herein.    36. As a result of Defendants’ payment and scheduling policy whereby it did not pay  Plaintiff or similarly situated employees overtime for all hours worked in excess of 40  hours per week for Defendants, Plaintiffs have been deprived of federally mandated  overtime pay.   38. At all times material hereto, Defendants have failed to maintain proper time records  as mandated by the FLSA.   39. Defendants’ actions were willful and/or showed reckless disregard for the provisions  of the FLSA as evidenced by its failure to compensate Plaintiff and FLSA Collective  Action Plaintiffs at a rate equal to one and one-half times their regular rate of pay for  all of the hours they worked in excess of 40 hours per week when it knew, or should  have known, such was and is due.   40. Defendants have failed to properly disclose or apprise Plaintiff and the FLSA  Collective Action Plaintiffs of their rights under the FLSA.   41. Due to the intentional, willful, and unlawful acts of Defendants, Plaintiff and the  FLSA Collective Action Plaintiffs have suffered lost compensation for time worked  over 40 hours per week, plus liquidated damages.   42. Plaintiff and the FLSA Collective Action Plaintiffs are also entitled to an award of  reasonable attorney’s fees and costs pursuant to 29 U.S.C. §216(b).  LABOR STANDARDS ACT   