12.  At all relevant times, Plaintiff and the other FLSA Collective Plaintiffs are and  have been similarly situated, have had substantially similar job requirements and pay provisions,  and are and have been subjected to Defendants’ decisions, policies, plans, programs, practices,  procedures, protocols, routines, and rules, all culminating in a willful failure and refusal to pay  them wages for all hours worked, including those at the overtime premium for hours worked in  excess of forty (40) each workweek. The claims of Plaintiff stated herein are essentially the same  as those of the other FLSA Collective Plaintiffs.             17.  The claims for relief are properly brought under and maintained as an opt-in  collective action pursuant to §16(b) of the FLSA, 29 U.S.C. 216(b). The FLSA Collective  Plaintiffs are readily ascertainable. For purposes of notice and other purposes related to this  action, their names and addresses are readily available from the Defendants. Notice can be  provided to the FLSA Collective Plaintiffs via first class mail to the last address known to  Defendants.  26.   In or around October 2017, Plaintiff RODNEY J. SANCHEZ was hired by  Defendants’ Signature Cleaning Services cleaning business as a maintenance worker and cleaner.  Plaintiff worked for Defendants until in or around March 2018, when his employment was  terminated by Defendants. Throughout Plaintiff’s employment with Defendants, Plaintiff was  employed to work predominantly at one of Defendants’ clients’ buildings, located at 11 East 52nd  Street, New York, New York 10022. However, Defendants were able to send Plaintiff to any of  Defendants’ other client locations.    27.  Throughout his employment with Defendants, Plaintiff was scheduled to work  from 8:00am until 4:00pm, from Mondays through Fridays, for forty (40) hours per week.  Plaintiff was also scheduled to work every other Saturday from 8:00am to 12:00pm, for an  additional four (4) hours of work, every other workweek. Plaintiff regularly worked without any  lunch breaks.    28.  From the start of Plaintiff’s employment through December 2017, Plaintiff was  compensated on an hourly basis of $11.00 per hour. From in or around January 2018 until the  end of Plaintiff’s employment, Plaintiff was compensated on an hourly basis of $13.00 per hour.    29.  Based on Plaintiff’s direct observations and conversations with other employees,  FLSA Collective Plaintiffs and Class members had similar work schedules and received similar  hourly rates.     31.  Because of Defendant’s policy of time-shaving, Plaintiff, FLSA Collective  Plaintiffs and Class members did not receive compensation for all of their hours worked,  including overtime hours, because the hours worked as reflected in the paystubs were incorrect.   32.  On several occasions when Plaintiff was compensated for hours that he worked in  excess of forty (40) per workweek, however, Defendants compensated such hours on a straight- time basis, through a separate check. When Plaintiff complained to the Individual Defendant,  Defendants failed to correct the underpayment. Through personal conversations with FLSA  Collective Plaintiffs and Class members, other non-exempt employees were also occasionally  paid in cash to conceal Defendants’ failure to compensate their employees for all hours worked,  including at the proper overtime premium for hours worked in excess of forty (40) per  workweek.    34.  During his employment with Defendants, Plaintiff never received a proper wage  and hour notice upon hiring or upon changes in the information on the notice, as required under  the NYLL. In fact, Plaintiff was never provided with any wage and hour notices by Defendants.  Similarly, Class Members never received proper wage and hour notices upon hiring or upon  changes in the information on the notice.   35.  Defendants failed to maintain proper employment records, as required by the  FLSA and NYLL. At all relevant times, Defendants provided fraudulent wage statements to  Plaintiff, which failed to accurately show the number of hours worked by Plaintiff in a given  workweek. Class Members received similar fraudulent wage statements due to Defendants’  policy of time shaving.    36.  Defendants knowingly and willfully operated their business with a policy of not  paying employees for all hours worked, including overtime hours, due to a policy of time- shaving, in violation of the FLSA and New York Labor Law   37.  Defendants knowingly and willfully operated their business with a policy of not  paying either the FLSA minimum wage or the New York State minimum wage, and the proper  overtime rate thereof for hours worked over forty (40) in a workweek, due to Defendants’ policy  of time-shaving.   38.  Defendants unlawfully failed to provide Plaintiff and Class Members with wage  and hour notices upon hiring, as required under the NYLL.   40. Plaintiff retained Lee Litigation Group, PLLC to represent Plaintiff, FLSA  Collective Plaintiffs and Class members, in this litigation and have agreed to pay the firm a  reasonable fee for its services.  41.  Plaintiff realleges and reavers Paragraphs 1 through 40 of this class and collective  action Complaint as if fully set forth herein.   42.  At all relevant times, Defendants were and continue to be employers engaged in  interstate commerce and/or the production of goods for commerce within the meaning of the  FLSA, 29 U.S.C. §§ 206(a) and 207 (a).  Further, Plaintiff and FLSA Collective Plaintiffs are  covered individuals within the meaning of the FLSA, 29 U.S.C. §§ 206(a) and 207 (a).   43.  At all relevant times, Defendants employed Plaintiff and FLSA Collective  Plaintiffs within the meaning of the FLSA.   44.  At all relevant times, the Corporate Defendant had gross annual revenues in  excess of $500,000.00.   45.  At all relevant times, Defendants had a policy and practice of failing to pay wages  for all hours worked.    47.  Defendants willfully violated Plaintiff’s and FLSA Collective Plaintiffs’ rights by  failing to pay them the statutory minimum wage rate due to time-shaving.    48.  Defendants willfully violated Plaintiff’s and FLSA Collective Plaintiffs’ rights by  failing to pay them for all overtime hours worked at the rate of not less than one and one-half  times the regular rate of pay for each hour worked in excess of forty hours in a workweek,  including overtime wages owed due to Defendants’ policy of time-shaving   49.  Records, if any, concerning these matters should be in the possession and custody  of the Defendants. Plaintiff intends to obtain all records by appropriate discovery proceedings to  be taken promptly in this case and, if necessary, will then seek leave of Court to amend this  Complaint to set forth the precise amount due.    50.  Defendants failed to properly disclose or apprise Plaintiff and FLSA Collective  Plaintiffs of their rights under the FLSA.   51.  As a direct and proximate result of Defendants’ willful disregard of the FLSA,  Plaintiff and FLSA Collective Plaintiffs are entitled to liquidated (i.e., double) damages pursuant  to the FLSA.   52.  Due to the intentional, willful and unlawful acts of Defendants, Plaintiff and  FLSA Collective Plaintiffs suffered damages in an amount not presently ascertainable of unpaid  wages, plus an equal amount as liquidated damages.   54.   Plaintiff realleges and reavers Paragraphs 1 through 53 of this class and collective  action Complaint as if fully set forth herein.   55.  At all relevant times, Plaintiff and Class members were employed by the  Defendants within the meaning of the New York Labor Law, §§2 and 651.   56.  At all relevant times, Defendants had a policy and practice of refusing to pay  Plaintiff and Class Members for all hours worked, including at the statutory rate of time and one- half the regular rate for overtime hours worked, due to Defendants’ policy of time-shaving.   57.  Defendants willfully violated Plaintiff’s and Class members’ rights by failing to  pay them wages in the lawful amount for all hours worked due to time shaving.   58.  Defendants willfully violated Plaintiffs’ and Class members’ rights by failing to  pay them the statutory minimum wage rate due to time-shaving.   59.  Defendants willfully violated Plaintiff’s and Class members’ rights by failing to  pay them for all overtime hours worked at the rate of not less than one and one-half times the  regular rate of pay for each hour worked in excess of forty hours in a workweek, including  overtime wages owed due to Defendants’ policy of time-shaving.   60.  Defendants failed to properly notify employees of their hourly pay rate and  overtime rate, in direct violation of the New York Labor Law.   62.  Defendants failed to provide proper wage statements with every payment as  required by New York Labor Law  § 195(3).   63.  Due to the Defendants’ New York Labor Law violations, Plaintiff and Class  members are entitled to recover from Defendants their unpaid wages, damages for unreasonably  delayed payments, reasonable attorneys’ fees, liquidated damages, statutory penalties and costs  and disbursements of the action, pursuant to New York Labor Law.    VIOLATION OF THE NEW YORK LABOR LAW ON BEHALF OF PLAINTIFF AND  CLASS MEMBERS   VIOLATION OF THE FAIR LABOR STANDARDS ACT ON BEHALF OF PLAINTIFF  AND FLSA COLLECTIVE PLAINTIFFS  