(FLSA Overtime Violations)   11.  At all times relevant to this Complaint, Defendant employed Plaintiff and other  similar situated correctional officers in a non-exempt hourly capacity.   13.  Defendant’s correctional officers are responsible for the custody and discipline  of detainees held at Defendant’s facilities.   14.  Among other duties, the correctional officers search for contraband and provide  security, count, feed, and supervise detainees.  Defendant Fails to Compensate Correctional Officers  for Completing Security Screenings Before Each Shift   15.  At the beginning of each shift, prior to clocking in, Defendant requires Plaintiff  and other similarly situated correctional officers to undergo a security screening.     16.  During the security screening the correctional officers empty their pockets,  remove their shoes, belts, and jackets and all metal objects, empty their bags, and submit any  personal items in their possession for inspection.   17.  The correctional officers then walk through a metal detector before reclaiming  their possessions and donning their shoes, belts, and jackets.    18.  Defendant requires the correctional officers to undergo this screening for the  purposes of safety, and to prevent officers from inadvertently or intentionally bringing contraband  into the prison.   19.  Keeping weapons and other contraband out of the prison is necessarily tied to the  correctional officers’ work of providing prison security and searching for contraband.      20.  Thus, undergoing security screenings is integral and indispensable to the officers’  principal job-related activities.   21.  Defendant, however, fails to compensate Plaintiff and similarly situated  correctional officers for time spent undergoing pre-shift security screenings.   23.  Defendant’s failure to compensate Plaintiff and the similarly situated correctional  officers resulted in unpaid overtime in violation of the FLSA. See, Aguilar, et al. v. Management  & Training Corporation, 2020 U.S. App. LEXIS 3339 (10th Cir. Feb. 4, 2020) (pre-shift security  screenings of corrections officers are integral and indispensable under Busk and therefore must be  counted as hours worked for purposes of computing overtime).  24.  Plaintiff incorporates by reference the foregoing allegations as if fully rewritten  herein.   25.  Defendant maintains private prison facilities nationwide.    26.  Plaintiff bring this case as an FLSA “collective action” pursuant to 29 U.S.C.  § 216(b), which provides that an action to recover the liability prescribed by the FLSA may be  maintained against any employer by any one or more employees for and in behalf of himself or  themselves and other employees similarly situated.   27.  The Potential Opt-Ins who are “similarly situated” to Plaintiff with respect to  Defendant’s FLSA violations consist of:  All current and former correctional officers employed by Defendant  at any of its locations in Colorado within the three years preceding  this action.   29.  Conditional certification of this case as a collective action pursuant to 29 U.S.C.  § 216(b) is proper and necessary so that such persons may be sent a Court-authorized  notice informing them of the pendency of this action and giving them the opportunity to “opt  in.”   30.  The persons similarly situated to Plaintiff are readily identifiable through the  payroll records Defendant was required to maintain pursuant to the FLSA.  31.  Plaintiff incorporates by reference the foregoing allegations as if fully rewritten  herein.   32.  Plaintiff brings this claim for violation of the FLSA’s overtime provisions on  behalf of himself and the Potential Opt-Ins who may join this case pursuant to 29 U.S.C. §  216(b). Plaintiff’s written consent to become a party to this action pursuant to § 216(b) is being  filed with the Court as Exhibit 1 to this Complaint.    33.  The FLSA requires that Defendant’s non-exempt hourly employees receive  overtime compensation for all hours worked in excess of 40 in a workweek.   34.  Plaintiff and the Potential Opt-Ins should have been paid overtime  compensation at the rate of one-half times their regular rate of pay for all hours worked in  excess of 40 hours per workweek.   35.  Defendant failed to pay the overtime compensation to Plaintiff and the Potential  Opt-Ins.   37.  As a result of Defendant’s violations of the FLSA, Plaintiff and the Potential  Opt-Ins were injured in that they did not receive overtime compensation due to them pursuant  to the FLSA. 29 U.S.C. § 216(b) entitles them to an award of “unpaid overtime compensation”  as well as “an additional equal amount as liquidated damages.” Section 216(b) further  provides that “[t]he court … shall, in addition to any judgment awarded to the plaintiff or  plaintiffs, allow a reasonable attorney’s fee to be paid by the Defendants, and costs of the  action.” 