10.  The putative collective of similarly situated employees consists of all other  Extradition Agents employed by Defendant within the last three years.  These similarly  situated persons will be referred to as “Members of the Collective” or “the Collective.”   11.  At all times material hereto, Plaintiff and Members of the Collective were  “engaged in the production of goods” for commerce within the meaning of Sections 6 and  7 of the FLSA, and as such were subject to the individual coverage of the FLSA.   13.  At all times material hereto, Defendant BREVARD EXTRADITIONS INC  d/b/a U.S. PRISONER TRANSPORT was an “employer” within the meaning of the FLSA,  29 U.S.C. § 203(d).   14.  Defendant BREVARD EXTRADITIONS INC d/b/a U.S. PRISONER  TRANSPORT continues to be an “employer” within the meaning of the FLSA.   15.  At all times material hereto, Defendant BREVARD EXTRADITIONS INC  d/b/a U.S. PRISONER TRANSPORT was and continues to be an enterprise covered by  the FLSA, as defined under 29 U.S.C. §§ 203(r) and 203(s).   16.  At  all  times  relevant  to  this  action,  Defendant  21.  Named Plaintiff KEVIN LANGELLIER began working for Defendant as  an Extradition Agent in July 2018, and he worked in this capacity until February 2019.    22.  Plaintiff’s job duties included operation of a prisoner transportation vehicle.   23.  At certain times during his employment the vehicles Plaintiff operated in  the performance of his job duties had a weight of less than ten thousand and one (10,001)  pounds.  Further, Plaintiff did not operate vehicles to transport more than eight (8)  passengers for compensation or more than fifteen passengers without compensation.    24.  At various times material hereto, Plaintiff and the Collective worked hours  in excess of forty (40) hours within a work week for Defendant, and they were entitled to  be compensated for these overtime hours at a rate equal to one and one-half times their  individual regular hourly rates.   25.  Defendant failed to pay Plaintiff and Members of the Collective an  overtime premium for all of the overtime hours that they worked, in violation of the  28.  Plaintiff brings this case as an “opt-in” collective action on behalf of  similarly situated employees of Defendant (the “Collective”) pursuant to 29 U.S.C. §  216(b).  The Collective is composed of Extradition Agents whom Defendant failed to  compensate for all overtime hours worked in accordance with the FLSA.   29.  Therefore, Notice is properly sent to: “All Extradition Agents whom  Defendant failed to compensate for all of the overtime hours that they worked from June  2016 to the present.”   30.  The total number and identities of the Collective members may be  determined from the records of Defendant, and the Collective may easily and quickly be  notified of the pendency of this action.   31.  Plaintiff is similar to the Collective because he and the Collective have been  unlawfully denied full payment of their overtime wages as mandated by the FLSA.   32.  Plaintiff’s experience with Defendant’s payroll practices is typical of the  experiences of the Collective.   33.  Defendant’s failure to pay all overtime wages due at the rates required by  the personal circumstances of the named Plaintiff or of the Collective is common to the  Collective.   35.  Specific job titles or job duties of the Collective do not prevent collective  treatment.   36.  Although the issues of damages can be individual in character, there  remains a common nucleus of operative facts concerning Defendant’s liability under the  FLSA in this case.  37.  Plaintiff realleges and readopts the allegations of Paragraphs 1 through 36  of this Complaint, as fully set forth herein.  Plaintiff brings this action on behalf of himself  and all other similarly situated employees in accordance with 29 U.S.C. § 216(b).  Plaintiff  anticipates that as this case proceeds, other individuals will sign consent forms and join  this collective action as plaintiffs.   38.  During the statutory period, Plaintiff and the Collective worked overtime  hours while employed by Defendant, and they were not properly compensated for all of  these hours under the FLSA.   39.  Defendant failed to compensate Plaintiff and the Collective for all of the  overtime hours that Plaintiff and the Collective worked.   40.  The Members of the Collective are similarly situated because they were all  employed as Extradition Agents by Defendant, were compensated in the same manner, and  were all subject to Defendant’s common policy and practice of failing to pay its Extradition  Agents for all of the overtime hours that they worked in accordance with the FLSA.   42.  All of the foregoing conduct, as alleged, constitutes a willful violation of  the FLSA, within the meaning of 29 U.S.C. § 255(a).   6.  Plaintiff has satisfied all conditions precedent, or they have been waived.    7.  Plaintiff has hired the undersigned attorneys and agreed to pay them a fee.   8.  Plaintiff requests a jury trial for all issues so triable.   9.  At all times material hereto, Named Plaintiff KEVIN LANGELLIER was  employed by Defendant as an Extradition Agent.  