70.  Plaintiffs and Collective Members were at all relevant times hereto, improperly  classified and paid by the Defendants as independent contractors.    71.  Plaintiffs and Collective Members were employed by Defendants as  “Groomers” and/or “Pet Stylists.”    72.  Upon hiring Plaintiffs and Collective Members, Defendants require Plaintiffs to  sign “Contractor Agreements” as either an “Apprentice Groomer,” “Senior Groomer,” “Salon  Manager,” or “Assistant Manager.”   73.  According to the Contractor Agreement, the duties and responsibilities of an  apprentice groomer include learning to groom pets; assisting senior groomers and managers;  tracking personal payroll and sales; assisting with staff paperwork; assisting in ordering,  inventory, stock, and product review; wearing provided smocks and/or shirts in the salon;  assisting with customer service; and performing other salon duties that arise.    74.  According to the Contractor Agreement, the duties and responsibilities of a  senior groomer include assisting in daily salon management; tracking personal sales; assisting  with general salon paperwork; assisting with inventory, stock, and product review; wearing  provided smocks in the salon; assisting with customer service; and performing other salon  duties that arise.    75.  According to the Contractor Agreement, the duties and responsibilities of an  assistant manager include assisting in daily salon management; tracking personal sales;  assisting with general salon paperwork; assisting with inventory, stock, and product review;  wearing provided smocks in the salon; assisting with customer service; and performing other  salon duties that arise.    DECLARATORY RELIEF   166. Plaintiffs, on behalf of themselves and the Collective Members, reallege and  incorporate by reference all allegations in all preceding paragraphs.   167. Plaintiffs and Defendants have a FLSA dispute pending, which the Court has  jurisdiction to hear pursuant to 28 U.S.C. § 1331, as a federal question exists.   168. The Court also has jurisdiction to hear Plaintiffs’ request for declaratory relief  pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201-2202.   169. Plaintiffs may obtain declaratory relief.   170. Defendants employed Plaintiffs and others similarly situated.   171. Defendants’ business is an enterprise covered by the FLSA, as concerns its  employer-employee relationship with Plaintiffs and others similarly situated.   172. Plaintiffs were individually covered by the FLSA.   173. Plaintiffs and others similarly situated are entitled to minimum wage pursuant to  29 U.S.C. § 206 and overtime pursuant to 29 U.S.C. § 207.    174. Plaintiffs and others similarly situated are entitled to an equal amount of  liquidated damages as Defendants’ policy of failing to pay minimum wage and overtime  remain in effect.   175. The damages suffered by Plaintiffs and others similarly situated are ongoing.   176. Plaintiffs and others similarly situated will suffer future damages for which  there is no adequate remedy at law.   177. Defendants did not rely on a good faith defense in their failure to abide by the  provisions of the FLSA and failure to pay minimum wage and overtime.   178. It is in the public interest to have these declarations of rights recorded as  Plaintiffs’ declaratory judgment action serves the useful purposes of clarifying and settling the  legal relations at issue, preventing future harm, and promoting the remedial purposes of the  Misclassification of Plaintiffs and Collective Members as Independent Contractors  