25.  On information and belief, during the relevant time period, Weder Pereira made  or influenced key decisions regarding the business dealings of WCP, Rondon Siding, and Excel,  including decisions regarding financial and payroll matters.   26.  On information and belief, during the relevant time period, Cristina Pereira kept  the books for WCP, Rondon Siding, and/or Excel, including keeping records tracking financial  and payroll matters.   27.  During the relevant time period, the Pereira-Entity Defendants employed workers  to work on various construction jobsites, in Massachusetts (primarily) and in neighboring states.   28.  During the relevant time period, Weder and Cristina Pereira treated WCP,  Rondon Siding, and Excel interchangeably with respect to employing and paying the Plaintiffs.   For example, Jobsite Plaintiffs would be sent on projects as employees of WCP certain weeks  and Excel other weeks, without any explanation to, or action by, Plaintiffs.  Further, regardless of  whether Plaintiffs were allegedly working for WCP or Excel, paychecks would variously come  from WCP, Rondon Siding, or Excel without any pattern or explanation.      29.  During the relevant time period, Wagner Sousa approved and signed paychecks  paid by WCP to Plaintiffs and Joel Dacosta approved and signed paychecks paid by Rondon  Siding to Plaintiffs.  B.  National Lumber Arranged With the Pereira-Entity Defendants to Employ  Workers at New Bedford Lumber Yard   30.  During the relevant time period, National Lumber, through its wholly-owned  subsidiary, Reliable Truss, operated a business designing and manufacturing wood roof trusses,  wall panels, timber trusses, and floor panels (“Truss and Panel Manufacturing Business”).   32.  On information and belief, during the relevant time period, Manuel Pina  controlled significant aspects of the day-to-day operations of the Truss and Panel Manufacturing  Business.  As stated in a magazine article linked to the National Lumber website referring to the  Truss and Penal Manufacturing Business, “Pina is the company’s president and has led the way  for co-CEOs and sibling owners, Steven Kaitz and Margie Kaitz Seligman, to expand locations  and launch a number of profit centers including a turn-key division which provides framing  materials and labor for major building projects throughout the eastern U.S.  Pina convinced the  Kaitz family to begin engineering and designing truss and I-joist systems.  In-house, he hired  structural engineers, architects, expert builders and framing professionals.”   33.  On information and belief, in or about 2014, Manuel Pina, directly or indirectly,  informed Weder Pereira that National Lumber needed workers at the New Bedford Lumber Yard  to build wall panels.   34.  At this time, the Pereira-Entity Defendants employed many workers, including  some of the Named Plaintiffs and other Plaintiffs, to work at various construction jobsites in  Massachusetts and neighboring states.     36.  In arranging for the NL Plaintiffs to work at the New Bedford Lumber Yard,  Weder Pereira and the Pereira-Entity Defendants generally instructed the NL Plaintiffs, including  the Named Plaintiffs, to report to the New Bedford Lumber Yard for work at 6 a.m. on their first  day.  The Pereira-Entity Defendants did not provide tools with which they were to perform the  work or instructions regarding the work the employees were to perform.   37.  At the New Bedford Lumber Yard, the NL Plaintiffs, including the Named  Plaintiffs, reported to one of the National Lumber supervisors (the “NL Supervisors”).  The NL  Supervisors in charge of wall panel construction were David Lopes, until approximately mid- September 2015, and Victor Botelho, thereafter.  At various times, NL Supervisors Sean  O’Connell and Timothy Silva also supervised the employees.   38.  Manuel Pina also periodically spent time at the New Bedford Lumber Yard,  observing and inspecting the work being done by employees, including the NL Plaintiffs.     39.  The NL Supervisors generally directed the NL Plaintiffs to work at large tables,  usually in groups of three to six men.  The number of tables varied depending on the number of  NL Plaintiffs working and the number of projects being worked on.  The NL Supervisors  determined the group each NL Plaintiff worked with.   40.  The NL Supervisors provided the initial instructions to new NL Plaintiffs.     42.  National Lumber provided all of the tools and raw materials the NL Plaintiffs  used to build the wall panels.  On information and belief, some or all of the tools and raw  materials, and some of the finished wall panels, were shipped across state lines.   43.  The NL Supervisors also determined the starting times, meal break, and ending  times worked by the NL Plaintiffs.  The NL Supervisors instructed the NL Plaintiffs when to  arrive for work, which generally was 6 a.m., and when and for how long to take an unpaid meal  break, which was generally 30 minutes around noon.  The NL Supervisors dictated when the NL  Plaintiffs left for the day, which was generally dependent on factors including the number of NL  Plaintiffs working, the number and size of the panels being worked on, and the deadline by  which National Lumber needed the panels to be completed.    44.  The NL Supervisors determined the number of days worked each week by the NL  Plaintiffs, which was generally five or six, although it could be fewer during a holiday week or  during a particularly slow period.   45.  By determining the hours each day and the number of days worked by the NL  Plaintiffs each week, the NL Supervisors controlled the total amount of time worked by the NL  Plaintiffs.   47.  Starting in or around the second week in September 2015, NL Plaintiffs started  using a National Lumber punch-clock at the New Bedford Lumber Yard, punching in and out to  indicate when they arrived at work, went to a meal break, returned from a meal break, and left  for the day.   48.  NL Supervisor Victor Botelho reviewed the punch cards each week.  The NL  Supervisor made hand-written adjustments he determined were necessary, such as to correct a  card when a NL Plaintiff forgot to punch in or out at the start or end of the day or for meal time  or to add or subtract hours for other reasons.  The NL Supervisor tallied the hours and indicated  the total hours worked by the NL Plaintiff that week.   49.  Starting in or about the second week of September, 2015, NL Supervisor Sean  O’Connell prepared and signed the weekly timesheet invoices, setting forth the total hours  worked by each NL Plaintiff working that week based on the punch-cards, as adjusted by NL  Supervisor Botelho.   50.  Starting in or about February, 2015, National Lumber conveyed the hours worked  by the NL Plaintiffs to the Pereira-Entity Defendants via the timesheet invoices.   51.  The Pereira-Entity Defendants used the timesheets prepared by the NL  Supervisors to determine the time worked by, and the wages owed to, the NL Plaintiffs.     53.  The NL Supervisors and other National Lumber employees charged with quality  control at the New Bedford Lumber Yard inspected the NL Plaintiffs’ finished products prior to  the panels being loaded on trucks for shipping to jobsites to determine if the wall panels were  satisfactory or had to be redone.   54.  The NL Supervisors frequently forced the NL Plaintiffs to lift heavy panels  manually, unassisted by tools or equipment, while simultaneously providing tools and equipment  to assist other non-immigrant National Lumber employees with similar tasks.  The NL  Supervisors often forced the NL Plaintiffs to work outside in freezing cold temperature while  simultaneously allowing other non-immigrant employees to work inside.     55.  National Lumber and the NL Supervisors supplied safety equipment to the NL  Plaintiffs, however, the equipment provided was often inadequate and unsafe.   56.  On a few occasions, the NL Supervisors directed the NL Plaintiffs to work offsite  at construction job sites other than the New Bedford Lumber Yard where the wall panels were  being installed.  On these occasions, the NL Plaintiffs went to the jobsites in National Lumber  trucks with National Lumber employees and supervisors.   58.  For example, the NL Supervisors would frequently chastise, belittle, and threaten  NL Plaintiffs with termination for working too slowly or making mistakes.  The NL Supervisors  also threatened NL Plaintiffs with termination if they asked to leave due to illness or injury, and,  on one or more occasions, terminated an NL Plaintiff for staying home or leaving early due to  illness.   59.  On occasion, the NL Supervisors asked current NL Plaintiffs to recruit new  workers and bring them to the New Bedford Lumber Yard.  The NL Supervisor would then  determine whether to hire the recruit to join the group working to build the wall panels; if the  recruit was hired, the NL Supervisor included the recruit’s name and hours on the timesheet  invoice it provided to the Pereira-Entity Defendants.    60.  The NL Supervisors determined which NL Plaintiffs to lay off when work  slowed, and the NL Supervisors decided whether and when to terminate a NL Plaintiff for any  reason the NL Supervisor so decided.  D.  Plaintiffs Regularly Worked Overtime Hours at the New Bedford Lumber Yard   61.  During the relevant time period, the NL Supervisors required NL Plaintiffs to, and  NL Plaintiffs did, work more than 40 hours in one or more workweeks.   62.  During the relevant time period, the NL Supervisors required many NL Plaintiffs,  including the Named Plaintiffs, to, and many NL Plaintiffs, including the Named Plaintiffs, did,  regularly work up to fifty or sixty hours a week.   64.  During the relevant time period, most of the overtime worked by NL Plaintiffs  was recorded on timesheets or punch-cards.   65.  During the relevant time period, National Lumber and the Pereira-Entity  Defendants were aware that NL Plaintiffs frequently worked more than 40 hours a week at the  New Bedford Lumber Yard.  E.  Defendants Willfully Failed to Pay NL Plaintiffs Overtime Wages, Timely Wages,  Wages for all Time Worked, and Earned Sick Time   66.  During the relevant time period, Defendants followed a policy and practice of  paying NL Plaintiffs for their work at the New Bedford Lumber Yard via checks from WCP or  Rondon Siding and other entities.     67.  During the relevant time period, Defendants followed a policy and practice of  refusing to provide NL Plaintiffs with pay slips or earnings statements with their paychecks  showing the name of the employer and employee, the day, month, year, number of hours worked,  hourly rate, and the amounts of deductions or increases made for the pay period.     69.  On one or more occasions after their paychecks bounced, NL Plaintiffs, including  the Named Plaintiffs, complained to a NL Supervisor about not getting paid.   70.  During the relevant time period, Defendants paid NL Plaintiffs on an hourly basis.   On information and belief, the hourly rates ranged from approximately $14 to $20 (“Straight- Time Rate”).   71.  During the relevant time period, Defendants followed a policy and practice of  paying NL Plaintiffs only their Straight-Time Rate for time they worked over 40 hours in a  workweek.   72.  During the relevant time period, Defendants followed a policy and practice of not  paying NL Plaintiffs for any time they did not work.   73.  On one or more occasions, some or all of the Named Plaintiffs and other NL  Plaintiffs, complained to an NL Supervisor that they were not getting paid any overtime  premiums.   74.  On information and belief, Defendants followed a policy and practice of paying  NL Plaintiffs on a quarter-hour or half-hour basis.  However, for purposes of calculating wages,  Defendants followed a policy and practice of rounding the time NL Plaintiffs worked down more  often and more significantly than they rounded up.  Defendants followed a policy and practice of  frequently rounding down more than 8 minutes, sometimes significantly.   The time NL Plaintiffs  worked without being paid often involved time worked over 40 hours in a workweek.   76.  Defendants followed a policy and practice of failing to pay NL Plaintiffs  voluntarily leaving their employment all wages due to them within six or seven days of their last  day of work and failing to pay terminated NL Plaintiffs all wages due to them on the day of  termination.   77.  On information and belief, Defendants followed a policy and practice of failing to  ever pay many NL Plaintiffs wages due to them for their last week or two of work.   78.  At no time after July 1, 2015 (or prior thereto) did Defendants notify NL Plaintiffs  that they had the right to earn and use paid sick leave; Defendants failed to give NL Plaintiffs a  copy of a notice of a policy regarding sick leave or to include a sick time policy in a handbook  manual provided to NL Plaintiffs.   79.  During the relevant time period, including after July 1, 2015, Defendants followed  a policy and practice of refusing to allow NL Plaintiffs to earn and use paid sick leave.   80.  NL Supervisors even threatened to terminate NL Plaintiffs who requested to leave  early due to illness or injury.  F.  Pereira-Entity Defendants Willfully Failed to Pay Jobsite Plaintiffs Overtime  Wages, Timely Wages, Wages for all Time Worked, and Earned Sick Time   81.  During the relevant time period, the Pereira-Entity Defendants sent Jobsite  Plaintiffs, including the Named Plaintiffs, to perform construction laborer and carpentry work at  jobsites, primarily in Massachusetts.   83.  During the relevant time period, Pereira-Entity Defendants applied the same wage  policies and practices to all Plaintiffs, regardless of where they worked, and followed the same  wage policies and practices for the Jobsite Plaintiffs as they followed with the NL Plaintiffs.   84.  During the relevant time period, Pereira-Entity Defendants followed a policy and  practice of requiring Jobsite Plaintiffs to work more than 40 hours in a workweek, and many  Jobsite Plaintiffs, including the Named Plaintiffs, worked up to fifty, sixty, and even seventy  hours in many workweeks.   85.  During the relevant time period, Pereira-Entity Defendants followed a policy and  practice of paying Jobsite Plaintiffs on an hourly basis, but failing to pay Jobsite Plaintiffs  premium pay for any time they worked over 40 hours in a workweek.   86.  During the relevant time period, Pereira-Entity Defendants followed a policy and  practice of failing to provide Jobsite Plaintiffs with any earnings statements or pay slips showing  the name of the employer and employee, the day, month, year, number of hours worked, hourly  rate, and the amounts of deductions or increases made for the pay period.   87.  During the relevant time period, Pereira-Entity Defendants generally paid Jobsite  Plaintiffs on a weekly basis, with the week ending on Saturday.   89.  On information and belief, Pereira-Entity Defendants followed a policy and  practice of paying NL Plaintiffs on a quarter-hour or half-hour basis.  However, for purposes of  calculating wages, Pereira-Entity Defendants followed a policy and practice of rounding the time  Jobsite Plaintiffs worked down more often and in greater amounts than they rounded up.   Pereira-Entity Defendants followed a policy and practice of frequently rounding down more than  8 minutes, sometimes significantly.  The time Jobsite Plaintiffs worked without pay often  involved time worked over 40 hours in a workweek.   90.  Pereira-Entity Defendants followed a policy and practice of failing to pay Jobsite  Plaintiffs voluntarily leaving their employment all wages due to them within six or seven days of  their last day of work and failing to pay terminated Jobsite Plaintiffs all wages due to them on the  day of termination   91.  On information and belief, Pereira-Entity Defendants also followed a policy and  practice of failing to pay many Jobsite Plaintiffs wages for their last one or two weeks of work.   92.  At no time after July 1, 2015, (or prior thereto) did Pereira-Entity Defendants  notify Jobsite Plaintiffs that they had the right to earn and use paid sick leave; Pereira-Entity  Defendants failed to give Jobsite Plaintiffs a copy of a notice of a policy regarding sick leave or  to include a sick time policy in a handbook manual provided to Jobsite Plaintiffs.   93.  During the relevant time period, including after July 1, 2015, Pereira-Entity  Defendants followed a policy and practice of refusing to allow Jobsite Plaintiffs to earn and use  paid sick leave.  G.  Wage Complaints Filed with Massachusetts Attorney General   95.  After the AG Complaint was filed, the AG began an investigation of the wage  practices of the Pereira-Entity Defendants and National Lumber in connection with the work of  the NL Plaintiffs and the Jobsite Plaintiffs.   96.  On information and belief, representatives from the AG’s office held a meeting  with certain Defendants and their attorneys (the “AG Meeting”).   97.  Soon after the AG Meeting, National Lumber began terminating NL Plaintiffs that  were still working at the New Bedford Lumber Yard.   98.  An NL Supervisor complained to Plaintiff Pinto about Plaintiff Rodrigues filing  the AG Complaint and stated something to the effect that many people were losing their jobs all  because one person had to go and complain.   A.  Pereira-Entity Defendants  