16. The Defendant City of Cleveland Heights, Ohio is a political subdivision.   17. At all times relevant, Plaintiff Employees and SSEs were employed by  Defendant in Bargaining Unit Positions.   18. Plaintiff Employees all currently work for Defendant in Bargaining Unit  Positions.   19. Plaintiff Employees and SSEs have been employed by Defendant in  Bargaining Unit Positions within the last three years.   20. Payment of longevity pay to Plaintiff Employees and SSEs in Bargaining    Unit Positions, under Defendant’s collective bargaining agreement with Local 860  (formerly with the National Production Workers Union, Local 707 – as noted  above) over the last three years, was mandatory in nature and, thus, was required to  be included in Plaintiff Employees and SSEs’ regular rate of pay.   21. Defendant failed to include longevity pay in Plaintiff Employees and  SSEs’ regular rates of pay.  6   22. Defendant knowingly and willfully failed to pay Plaintiff Employees and  SSEs the proper amount of overtime compensation through the date of this Complaint.  23. Plaintiff Employees bring Count I of this action on their own behalf  pursuant to 29 U.S.C. § 216(b) and on behalf of all SSEs in Bargaining Unit Positions  who have been, are being, or will be adversely affected by Defendant’s unlawful  conduct.   24. The class that Plaintiff Employees seek to represent and for whom Plaintiff  Employees seek the right to send “opt-in” notices for purposes of the collective action,  and of which Plaintiff Employees are themselves members, is composed of and  defined as follows:  All former and current employees employed by Defendant City of  Cleveland Heights in Bargaining Unit Positions that received longevity  pay at any time between January 1, 2016 and the present.   25. Plaintiff Employees are unable to state at this time the exact size of the  potential class, but upon information and belief, aver that it consists of at least 100  employees.   26. This action is maintainable as an “opt-in” collective action pursuant to  29 U.S.C.  § 216(b) as to claims for unpaid overtime compensation, liquidated  damages, attorneys’ fees, and costs under the FLSA.   27. In addition to Plaintiff Employees, numerous current and former  employees are similarly situated with regard to their wages and claims for unpaid  wages and damages.  7   28. Plaintiff Employees are representative of those other employees and are  acting on behalf of their interests as well as their own interests in bringing this action.   29. These similarly situated employees are known to Defendant and are readily  identifiable through Defendant’s payroll records. These individuals may readily be  notified of this action and allowed to opt in pursuant to 29 U.S.C. § 216(b) for the  purpose of collectively adjudicating their claims for unpaid overtime compensation,  liquidated damages, attorneys’ fees, and costs under the FLSA.  8  30. Plaintiffs incorporate by reference and re-allege the foregoing allegations  as if fully rewritten herein.   31. Defendant’s practice and policy of failing to include longevity pay in the  Plaintiff Employees and SSEs’ regular rates of pay violated the FLSA, 29 U.S.C. §§ 201- 219.   32. Defendant’s practice and policy of not paying Plaintiff Employees and SSEs  overtime compensation at a rate of one and one-half times their regular rate of pay for  the hours they work and worked in excess of 40 hours in a workweek violated the  36. Plaintiffs incorporate by reference and re-allege the foregoing allegations  as if fully rewritten herein.  9   37. Defendant failed to pay Plaintiff Employees and SSEs their proper wages  within the statutory time period under R.C. 4113.15(A).   38. To date, Defendant has failed to pay all wages due and owing to Plaintiff  Employees and SSEs.   39. Because Defendant Employer failed to pay Plaintiff Employees and SSEs  their wages within the time period specified under R.C. 4113.15(A), Plaintiff  Employees and SSEs a seek their wages that remain unpaid plus liquidated damages  required by statute. 