1465A FLATBUSH AVE  BROOKLYN, NY 11210  JOEL GOLDSTEIN  244 E 117 LLC, DDEH 311 E. 109 LLC, DDEH 312  E 106 LLC, DDEH 411 E 114 LLC, DDEH 411  E118LLC, DDEH 417E 114ST LLC, DDEH 421  FLSA Minimum Wage Violations, 29 U.S.C. §§ 201 et seq.  (FLSA Class)  310.  The Representative Plaintiffs, on behalf of themselves and the FLSA Class  members, incorporate in this cause of action each and every allegation of the preceding  paragraphs, with the same force and effect as though fully set forth herein.  311.  Defendants’ failure to compensate the Representative Plaintiffs and other  members of the FLSA class at the FLSA minimum wage rate of pay violates 29 U.S.C § 206.    312.  As a result of the foregoing, the Representative Plaintiffs demand judgment  against Defendants on their own behalf, and on behalf of those FLSA Class Members similarly  situated who file written consents to joinder in this action, for all unpaid wages, including  minimum wage and overtime wages owed by Defendants to the Representative Plaintiffs and the  FLSA Class, pursuant to 29 U.S.C. §§ 206 and 207, together with an award of an additional  equal amount as liquidated damages, costs, interest, and reasonable attorneys’ fees, as provided  for under 29 U.S.C. § 216(b).  313.  Defendants’ violations of the FLSA were willful, thus the three year statute of  limitations of 29 U.S.C. § 255 applies.   Illegal Deductions, New York Labor Law, Article 19 § 193  12 N.Y.C.R.R. § 2.10(a).  (New York Class)  321.  The Representative Plaintiffs incorporate in this cause of action each and every  allegation of the preceding paragraphs, with the same force and effect as though fully set forth  herein.  322.  In violation of the New York Labor Law, Article 19, § 193, Defendants  unlawfully deducted wages from the Representative Plaintiffs, including inter alia, deductions  by requiring Superintendents to spend their own money on work-related expenses, which further  reduced their wages below the required minimum wage, including but not limited to, cellular  telephone expenses, supplying their own tools and supplies to complete mandated work,  and  requiring Representative Plaintiffs and those similarly situated to hire and pay from their own  income laborers to assist in performing certain work, including workers to perform their duties  while they took time off.   323.  As a result of the foregoing, the Representative Plaintiffs seek judgment against  Defendants on their own behalf, and on behalf of those New York Class Members similarly  situated who file written consents to joinder in this action, for reimbursement of unlawful  deductions, as well as liquidated damages, and interest, and such other legal and equitable relief  from Defendants’ unlawful and willful conduct as the Court deems just and proper.  LLC, DDEH 216 E 118 LLC, DDEH 2171 THIRD  LLC, DDEH 291 PLEASANT LLC, DDEH 231 E  117 LLC, DDEH 233 E 111 STREET LLC, DDEH  LLC  150 WEST 30TH ST,  2ND FL  LLC  1465A FLATBUSH AVE  BROOKLYN, NY 11210  NYLL Wage Theft Prevention Act – Failure to Provide Wage Statements   (New York Class)  328.  Plaintiffs, on behalf of themselves and the New York Class members, repeat  and  re-allege and incorporate each and every allegation of the preceding paragraphs, with the same  force and effect as though fully set forth herein.  329.  The NYLL and Wage Theft Prevention Act (“WTPA”) require employers to  provide employees with an accurate wage statement each time they are paid.  330.  Throughout Plaintiffs’ employment with Defendants, Defendants willfully failed  to provide Plaintiffs and the New York Class with wage statements at the end of every pay  period that correctly identified the name of the employer; address of employer; rates of pay or  basis thereof; regular hourly rate; whether paid by the hour, shift, day, week, salary, piece,  commission, or other; number of overtime hours worked; gross wages; deductions; allowances, if  any, claimed as part of the minimum wage; net wages; and such other information as required by 