24.    Plaintiff, GRACE LAMEY, readopts and realleges the allegations contained in  Paragraphs 1 through 23 above.   25.    Plaintiff is entitled to be paid time and one-half of her applicable regular rate of pay  for each hour she worked for Defendants in excess of Forty (40) hours per work week during the  three (3) year statute of limitations period between April 2016 and March 2017.    26.  All similarly situated employees who have worked for Defendants in the position  known as “Shuttle Experience Manager” throughout the United States are also entitled to be paid  time and one-half of their applicable regular rates of pay for each and every overtime hour they  have worked for Defendants but were not properly compensated for working on Defendants’  behalf during any work weeks within the three (3) year statute of limitations period between June  2014 and the present.   27.  Defendants have knowingly and willfully failed to pay Plaintiff and the other  employees similarly situated to her at time and one-half of their applicable regular rates of pay for  all hours worked for Defendants in excess of Forty (40) per week between June 2014 and the  8  present.     28.   At all times material to this Complaint, Defendants had constructive and/or actual  notice that Defendants’ compensation practices did not provide Plaintiff and the other “Shuttle  Experience Managers” with time and one-half wages for all of their actual overtime hours worked  between June 2014 and the present based upon, inter alia, Defendants knowingly failing to pay  time and one-half wages for all of the actual hours worked in excess of Forty (40) hours per week  by Plaintiff and other similarly situated non-exempt “Shuttle Experience Managers,” however  variously titled.   29.    By reason of the said intentional, willful and unlawful acts of Defendants, all  Plaintiffs (the named Plaintiff and those “Shuttle Experience Managers” similarly situated to her  who have worked for Defendants between June 2014 and the present) have suffered damages plus  incurring costs and reasonable attorneys’ fees.   30.    Defendants did not have a good faith basis for their failure to pay time and one-half  wages for all of the actual hours worked by Plaintiff and the other similarly situated “Shuttle  Experience Managers” in one or more weeks during the three (3) year statute of limitations period  between June 2014 and the present, as a result of which Plaintiff and those similarly situated to  her are entitled to the recovery of liquidated damages from Defendants pursuant to 29 U.S.C.  §216(b).   31.   Plaintiff has retained the undersigned counsel to represent her in this action, and  pursuant to 29 U.S.C. §216(b), Plaintiff is entitled to recover from Defendants all reasonable  attorneys’ fees and costs incurred as a result of Defendants’ violations of the FLSA.   32.    Plaintiff demands a jury trial.  WHEREFORE, Plaintiff, GRACE LAMEY, and any current or former employees  9  similarly situated to her who join this action as Opt-In Plaintiffs, demand judgment against  Defendants, jointly and severally, JETSMARTER, INC. and SERGEY PETROSSOV, for the  payment of all unpaid overtime compensation, liquidated damages, reasonable attorneys’ fees and  costs of suit, and for all proper relief including prejudgment interest.  OVERTIME VIOLATIONS OF THE FAIR LABOR STANDARDS ACT  