41.  Defendants own and/or operate as Sevens Home Care, an enterprise  located in Denver County, Colorado.     42.  Sevens Home Care is a company headquartered in Denver, Colorado,  that offers in-home healthcare services to individuals in need of such services.   43.  In October 2017, Plaintiff began her employment with Defendants as a  Home Health Aide, performing in-home companionship services for Defendants’ clients.   44.  In her work for Defendants, Plaintiff’s job duties included, but were not  limited to, caring for clients in their homes, cooking meals for them, ensuring they took  their medications, getting their groceries, helping them with incontinence, changing  bedsheets, helping them eat, and bathing them.     45.  At all relevant times during her employment, Defendants paid Plaintiff on  an hourly basis at a rate of $12.50 or a flat daily rate, regardless of the number of hours  she worked in week.     46.  Plaintiff regularly worked approximately 50 hours per week in her  employment with Defendants.  At no time did Plaintiff receive one and one-half times  her regular rate of pay for time worked in excess of 40 hours in a given workweek.     47.  At times, the hours Plaintiff worked for Defendants substantially exceeded  50 hours in a given workweek.  Nonetheless, Defendants did not pay overtime for such  time that exceeded 40 hours.     49.  In their work for Defendants, Plaintiff and the Collective Members were  non-exempt employees.   50.  In their work for Defendants, Plaintiff and the Collective Members did not  have the authority to hire or fire other employees, nor were their suggestions or  recommendations as to the hiring, firing, advancement, promotion, or any other change  in status of other employees given particular weight.   51.  In their work for Defendants, Plaintiff and the Collective Members’ primary  duty was not the performance of office or non-manual work directly related to the  management or general business operations of Defendants’ customers.   52.  In their work for Defendants, Plaintiff and the Collective Members’ primary  duty did not include the exercise of discretion and independent judgment with respect to  matters of significance.   53.  Defendants engaged in the regular practice of willfully failing to pay  Plaintiff and the Collective Members one-and-one-half times their regular rates of pay  for all time that they suffered or permitted Plaintiffs to work in excess of forty (40) hours  per workweek.   55.  Defendants engaged in the regular practice of failing to accurately, if at all,  record the time during which Defendants suffered or permitted Plaintiff and the  Collective Members to work.  As such, Plaintiffs’ time records understate the duration of  time each workweek that Defendants suffered or permitted Plaintiffs to work.     56.  As a result of Defendants’ willful failure to compensate Plaintiff and the  Collective Members the applicable overtime wage rate for such hours worked,  Defendants have violated 29 U.S.C. § 207(a).   57.  Defendants knew that – or acted with reckless disregard as to whether –  their failure to pay to Plaintiff and the Collective Members one-and-one-half times their  regular rates of pay for all work in excess of forty (40) hours per workweek, would  violate federal law, and Defendants were aware of the FLSA overtime wage  requirements during Plaintiff’s and the Collective Members’ employment.  As such,  Defendants’ conduct constitutes a willful violation of the FLSA.    58.  Defendants have and continue to willfully violate the FLSA by not paying  Plaintiff and the Collective Members one-and-one-half times their regular rates of pay  for all time worked in excess of forty (40) hours per workweek.  59.  Plaintiff realleges and incorporates by reference all allegations in all  preceding paragraphs.   61.  Plaintiff asserts those claims on behalf of herself, and on behalf of all  similarly situated employees employed by Defendants, who were not paid all  compensation required by the FLSA during the relevant time period as a result of  Defendants’ compensation policies and practices.   62.  Plaintiff brings this action pursuant to 29 U.S.C. § 216(b) on her own  behalf and as a representative of the similarly situated Collective Members who are  current and former Companion/Homemakers, Home Health Aides, and Certified Nurse’s  Aides (“CNAs”) who are not or were not paid one-and-one-half times their regular rates  of pay for all time in excess of forty (40) hours per workweek that Defendants suffered  or permitted them to work, in violation of pursuant to 29 U.S.C. § 207(a), who agree in  writing to join this lawsuit seeking recovery under the FLSA.   64.  Plaintiff and the Collective Members worked more than forty (40) hours in  a given workweek without being compensated at a rate equal to one and one-half their  regular rates of pay for the hours worked in excess of forty (40) during that workweek.     65.  Although Defendants permitted and/or required the Collective Members to  work in excess of forty (40) hours per workweek, Defendants have denied them full  compensation for their hours worked over forty (40) in a given workweek.   66.  The Collective Members perform or have performed the same or similar  work as Plaintiff.   67.  The Collective Members are employees of Defendants.   68.  The Collective Members are not exempt from receiving overtime pay.   69.  The Collective Members are similar to Plaintiff in terms of job title, job  duties, pay structure, and/or the denial of overtime.   70.  Defendants’ failure to pay overtime compensation required by the FLSA  results from generally applicable policies or practices and does not depend on the  personal circumstances of the Collective Members.   71.  The experiences of Plaintiff, with respect to her pay, are typical of the  experiences of the Collective Members.   72.  The specific job titles or precise job responsibilities of each Collective  Member does not prevent collective treatment.   74.  Although the exact amount of damages may vary among the Collective  Members, the damages for the Collective Members can be easily calculated by a simple  mathematic formula.  The claims of all Collective Members arise from a common  nucleus of facts.  Liability is based on a systematic course of wrongful conduct by the  Defendants that caused harm to all of the Collective Members.   75.  Plaintiff seeks to notify the following employees of their rights under 29  U.S.C. § 216(b) to join this action by filing in this Court written notice of their consent to  join this action:  All current and former Companion/Homemakers, Home Health Aides, and  Certified Nurse’s Aides (“CNAs”) who were employed by Defendants at any  time starting three years before this Complaint was filed, up to the present.   76.  The FLSA provides for a three-year statute of limitations for causes of  action arising out of a willful violation of the Act. 29 U.S.C. § 255.  As alleged above,  Plaintiff and similarly situated employees’ claims arise out of Defendants’ willful  violations of the FLSA.  Accordingly, the Court should require appropriate notice of this  action be given to all such employees employed by Defendants within three years from  the filing of this Complaint.   77.  Upon information and belief, Defendants have employed more than 100  such employees during the period relevant to this action.   79.  Because these similarly situated employees are readily identifiable by  Defendants and may be located through their records, they may be readily notified of  this action and allowed to opt into it pursuant to 29 U.S.C. § 216(b), for the purpose of  collectively adjudicating their FLSA claims.   80.  Collective adjudication is appropriate in this case because the employees  whom Plaintiff wishes to notify of this action have been employed in positions similar to  Plaintiff, have performed work similar to Plaintiff, and have been subject to  compensation practices similar to those to which Plaintiff have been subjected.  81.  Plaintiff realleges and incorporates by reference all allegations in all  preceding paragraphs.   82.  At all relevant times, Defendants have required Plaintiff and the Collective  Members to perform labor each shift while not clocked in (“off-the-clock”).  This practice  most commonly, though not exclusively, occurred when Plaintiff and the Collective  Members have neared 40 hours worked in a given workweek and ostensibly in order to  avoid paying Plaintiff and the Collective Members overtime.     83.  During such time, Defendants either did not record, or shaved from  records, the time that Plaintiff or the Collective Members worked, and Defendants have  not compensated Plaintiff or the Collective Members for such time that they worked.    85.  As a result, Defendants violated the overtime provisions of the FLSA, 29  UNPAID OVERTIME  