13.  Plaintiff was employed by Defendants as a Warehouse Lead at their Goldstrike  Mine in Eureka County, Nevada from on or about December 4, 2014 to on or about August 2,  2016.   14.  Plaintiff was an hourly paid non-exempt employee who earned $24.75 for each  hour worked for Defendants, excluding production bonuses and overtime premium payments.     15.  Plaintiff was scheduled for, and regularly worked, at least 4 shifts per week, 10  hours per shift, and 40 hours per workweek. Plaintiff regularly worked Tuesday through Friday,  6:30 a.m. to 4:30 p.m.   16.  Defendant Barrick Corp. is an international corporation headquartered in Toronto,  Canada, and is the leading gold mining company in the world in terms of production, reserves  and market capitalization.   17.  Barrick Corp. currently owns and operates five mining projects in the United  States, including: (1) the Cortez Gold Mine in Nevada, (2) the Golden Sunlight mine in Montana,  (3) the Goldstrike mine in Nevada, (4) the Donlin Gold Project in Alaska, and (5) the Turquoise  Ridge gold mine in Nevada.   18.  In its Goldstrike and Cortez mines alone, Barrick Corp. employs more than 3000  employees. These operations utilize both open pit and underground mining methods, and host a  range of processing facilities including heap leaching, roasting, autoclaving, conventional  leaching and thiosulfate (cyanide-free) leaching. The Goldstrike and Cortez mines each produced  over one-million ounces of gold in 2016, rendering them among the largest gold mines in the  world.   19.  Defendant Barrick Goldstrike is a wholly owned and operated subsidiary of  Barrick Corp.    53.  Plaintiff realleges and incorporates by this reference all the paragraphs above in  this Complaint as though fully set forth herein.   54.  Plaintiff brings this action on behalf of himself and all other similarly situated and  typical employees as both a collective action under the FLSA and a true class action under Nevada  law.   55.  The statute of limitations under the FLSA is 3 years for willful violations.    56.  The statute of limitations for liability created by Nevada statute is 3 years.   57.  The FLSA Class is defined as follows: All persons who were employed by  Defendants as non-exempt hourly employees at any time during the applicable statute of  limitations time periods who received non-discretionary bonus payments from Defendants  that were not factored into their regular rate for purposes of calculation of overtime  payment due. The Nevada Class shall include the following sub-class:   58.  The Nevada Class is defined as follows: All persons who were employed by  Defendants within the State of Nevada as non-exempt hourly employees at any time during  the applicable statute of limitations time periods who received non-discretionary bonus  payments from Defendants that were not factored into their regular rate for purposes of  calculation of overtime payment due. The Nevada Class shall include the following sub-class:  A.  Wages Due and Owing Sub-Class: All members of the Nevada Class who  are former employees.   61.  Plaintiff realleges and incorporates by this reference all the paragraphs above in  this Complaint as though fully set forth herein.   62.  At all times relevant to this Complaint, Defendant was a covered employer under  the Family and Medical Leave Act (“FMLA”), as it was engaged in an industry affecting  commerce and it employed fifty or more employees for each working day during each of twenty  or more calendar workweeks in the current or preceding calendar year. 29 U.S.C. § 2611(4).   63.  Plaintiff was covered under the FMLA as an eligible employee employed by  Defendant for at least twelve months who had performed at least 1,250 hours of service during  the previous twelve-month period. Id. § 2611(2).   64.  Under the FMLA, “[i]t shall be unlawful for any employer to interfere with,  restrain, or deny the exercise of or the attempt to exercise, any right provided under this  subchapter.” Id. § 2615(a).   65.  The FMLA’s “prohibition against interference” prohibits an employer from  discriminating or retaliating against an employee . . . for having exercised or attempted to exercise  FMLA rights. . . .” 29 C.F.R. § 825.220(c).   66.  “[E]mployers cannot use the taking of FMLA leave as a negative factor in  employment actions, such as hiring, promotions, or disciplinary actions.” Id.   67.  Employers who violate the FMLA “may be liable for compensation and benefits  lost by reason of the violation, for other actual monetary losses sustained as a direct result of the  violation, and for appropriate equitable or other relief, including employment, reinstatement,  promotion, or any other relief tailored to the harm suffered.” Id. § 825.220(b); 29 U.S.C. § 2617.   72.  Plaintiff realleges and incorporates by this reference all the paragraphs above in  this Complaint as though fully set forth herein.   73.  29 U.S.C. Section 207(a)(1) provides as follows:  “Except as otherwise provided  in the section, no employer shall employ any of his employees who in any workweek is engaged  in commerce or in the production of goods for commerce, or is employed in an enterprise engaged  in commerce or in the production of goods for commerce, for a workweek longer than forty hours  unless such employee receives compensation for his employment in excess of the hours above  specified at a rate not less than one and one-half times the regular rate at which he is employed.”   74.  29 U.S.C. Section 207(e) defines the regular rate “at which an employee is  employed shall be deemed to include all remuneration for employment paid to, or on behalf of,  the employee” (with certain exceptions not relevant here) divided by the hours worked.     75.  By failing to include bonuses and other non-discretionary payments in the total  sum earned before dividing by hours worked, Defendants failed to pay the correct hourly rate for  overtime hours worked.   78.  Plaintiffs reallege and incorporate by this reference all the paragraphs above in this  Complaint as though fully set forth herein.   79.  NRS 608.140 provides that an employee has a private right of action for unpaid  wages.     80.  NRS 608.018(1) provides as follows:  An employer shall pay 1 1/2 times an employee’s regular wage rate  whenever an employee who receives compensation for employment  at a rate less than 1 1/2 times the minimum rate prescribed pursuant  to NRS 608.250 works: (a) More than 40 hours in any scheduled  week of work; or (b) More than 8 hours in any workday unless by  mutual agreement the employee works a scheduled 10 hours per day  for 4 calendar days within any scheduled week of work.   81.  NRS 608.018(2) provides as follows:  An employer shall pay 1 1/2 times an employee’s regular wage rate  whenever an employee who receives compensation for employment  at a rate not less than 1 1/2 times the minimum rate prescribed  pursuant to NRS 608.250 works more than 40 hours in any  scheduled week of work.   85.  Plaintiff realleges and incorporates by this reference all the paragraphs above in  this Complaint as though fully set forth herein.   86.  NRS 608.140 provides that an employee has a private right of action for unpaid  wages.     87.  NRS 608.020 provides that “[w]henever an employer discharges an employee, the  wages and compensation earned and unpaid at the time of such discharge shall become due and  payable immediately.”     88.  NRS 608.040(1)(a-b), in relevant part, imposes a penalty on an employer who fails  to pay a discharged or quitting employee: “Within 3 days after the wages or compensation of a  discharged employee becomes due; or on the day the wages or compensation is due to an  employee who resigns or quits, the wages or compensation of the employee continues at the same  rate from the day the employee resigned, quit, or was discharged until paid for 30-days, whichever  is less.”     Failure to Pay Overtime Wages at the Correct Rate in Violation of the FLSA, 29 U.S.C. § 207  (On Behalf of Plaintiff and the FLSA Class Against Defendants)   Failure to Pay Overtime Wages at the Correct Rate in Violation of NRS 608.140 and 608.018  (On Behalf of Plaintiff and the Nevada Class Against Defendants)   Failure to Timely Pay All Wages Due and Owing Upon Termination Pursuant to NRS 608.140  and 608.020-.050  (On Behalf of Plaintiff and the Wages Due and Owing Sub-Class Against Defendants)    Interference with Rights in Violation of 29 U.S.C § 2601 et seq.  (On Behalf of Plaintiff Individually Against Defendants)  