41.  Defendants have intentionally and repeatedly engaged in a practice of  improperly and unlawfully failing to pay their non-exempt employees overtime pay  including, but not limited to, the Plaintiff and the collective group of similarly-situated  employees who worked for Defendants in violation of the provisions of the FLSA,  MWOWA, and corresponding federal regulations.    42.  Specifically, Defendants have intentionally and repeatedly engaged in the  practice of failing to pay their non-exempt employees, including the Plaintiff, at the  required rate of time and one-half their regular hourly rate of pay, in violation of the  provisions of the FLSA and MWOWA.   44.  Beginning in 2016, and continuing through 2018, Plaintiff was scheduled  to work either from 8 a.m. through 5 p.m., or 11 a.m. through 8 p.m., five (5) days a  week, depending on the shift she was assigned.  Customarily, Plaintiff was not able to  take an uninterrupted thirty (30) minute break during her shift.   45.  Plaintiff customarily worked past the end of her scheduled shift to  complete calls with potential customers.     46.  On days when Plaintiff worked from 8 a.m. through 5 p.m. and a fellow  Settlement Officer or a Senior Settlement Officer reported they would not be able to  work, Plaintiff would work a double shift at Defendants’ request.     48.  Beginning in November 2018, Defendants did away with the Sunday  shift, however Plaintiff was still required to work one Saturday a month from 8 a.m.  until 8 p.m.   49.  Plaintiff specifically recalls working Memorial Day weekend in both  2017 and 2018.  She was required to work from 8 a.m. to 8 p.m. on Saturday, Sunday  and Monday of Memorial Day weekend, and then resume her normal work schedule  on the Tuesday after Memorial Day.   51.  Defendants also used the application SalesForce in order to track calls  and contact with customers.  Records from SalesForce would also demonstrate when,  and for how long and how often, Plaintiff and other similarly-situated individuals  were working for Defendants.   52.  Using a program called Right Signature, Plaintiff and other similarly- situated individuals who were working for Defendants would prepare contracts for  clients to sign if they decided to retain Silver Tax Group.  Plaintiff and other similarly- situated individuals who were working for Defendants had little to no discretion to  alter these contracts.  Such contracts would then be transmitted to clients to sign  electronically using the program DocuSign, also provided by Defendants.     53.  Without providing notice, and contrary to applicable law, Defendants  recorded calls with potential clients.      54.  Plaintiff’s last day of employment with Defendant was February 15,  2019.  Plaintiff contends she was constructively discharged, while Defendants contend  she voluntarily resigned.  In a letter dated February 18, 2019, Leslie Holland  (“Holland”), Silver Tax Group’s Director of Operations, stated, in relevant part:  “Silver Tax Group and Chorus HR Group have accepted your voluntarily resignation”  (emphasis added).  A true and correct copy of this letter is attached hereto as Exhibit   55.  After Plaintiff’s employment with Defendants ceased, counsel for  Defendants instructed Plaintiff to return the following:  1) computer tower; 2)  monitor; 3) keyboard; 4) mouse; 5) desk phone; 6) headset; and 7) cell phone.  All  equipment belonging to Defendants was returned by Plaintiff on or around March 18,  2019.     56.  Many of the contracts Plaintiff and other similarly-situated individuals  who were working for Defendants drafted were to be paid to Defendants residually  over time as services were provided.  Plaintiff and other similarly-situated individuals  who were working for Defendants were entitled to commissions on these residually  paid funds.  Despite the fact that contracts Plaintiff had secured were continuing to be  paid to Defendants, Plaintiff has not received any commissions she is owed from  Defendants since December 2018.     57.  On December 10, 2018, Plaintiff emailed Holland regarding her  compensation and specifically inquired about her compensation as follows:  “Please  confirm I am supposed to be a non-exempt employee and with a small base +  commission – not a ‘bonus.’”  A true and correct copy of this email is attached hereto  as Exhibit 2.   59.  Conservatively, Plaintiff worked at least sixty (60) hours per week for  Defendants, but was not paid at time and one-half her regular hourly rate as required  by the FLSA and MWOWA for the hours she worked in excess of 40 in a workweek.   60.  Plaintiff’s experience is typical of other employees who worked for  Defendants.    77.  Plaintiff repeats and incorporates by reference the allegations contained  in Paragraphs 1-76 herein.  By their actions alleged herein, Defendants willfully,  knowingly, and/or recklessly violated the provisions of the FLSA and corresponding  federal regulations.    79.  As a result of Defendants’ violations of the FLSA, Plaintiff, as well as all  others similarly-situated, has suffered damages by failing to receive their lawful  overtime wages in accordance with §207 of the FLSA.   80.  Defendants have made no good faith effort to comply with the FLSA  with respect to their compensation of Plaintiff or other similarly-situated employees.    81.  Defendants’ willful conduct is evidenced by its treatment of Plaintiff.     82.  As a result of the unlawful acts of Defendants, Plaintiff and all persons  similarly-situated to Plaintiff have been deprived of their rightful hourly and/or  overtime compensation in an amount to be determined at trial, and are entitled to  recovery of such amounts, liquidated damages, prejudgment interest, attorneys’ fees,  costs, and all other compensation and relief permitted by applicable law.   83.  Pursuant to 29 U.S.C. §216(b), a Consent to participate in this action  signed by the Plaintiff is attached hereto as Exhibit 3.   84.  Plaintiff repeats and incorporates by reference the allegations contained  in Paragraphs 1-83 herein.  By their actions alleged herein, Defendants willfully,  knowingly, and/or recklessly violated the provisions of the MWOWA.    86.  As a result of Defendants’ violations of the MWOWA, Plaintiff, as well  as all others similarly-situated, has suffered damages by failing to receive their lawful  overtime wages in accordance with Mich. Comp. Law. § 408.414a.   87.  Defendants have made no good faith effort to comply with the MWOWA  with respect to their compensation of Plaintiff or other similarly-situated employees.    88.  Defendants’ willful conduct is evidenced by its treatment of Plaintiff.     89.  As a result of the unlawful acts of Defendants, Plaintiff and all persons  similarly-situated to Plaintiff have been deprived of their rightful hourly and/or  overtime compensation in an amount to be determined at trial, and are entitled to  recovery of such amounts, liquidated damages, prejudgment interest, attorneys’ fees,  costs, and all other compensation and relief permitted by applicable law.  91.  At present, Plaintiff brings this claim solely on behalf of herself, pending  further investigation as to whether Defendants have engaged in similar wrongful  conduct with other members of the proposed class.   92.  Plaintiff entered into a compensation agreement with Defendants  whereby Defendants agreed to pay Plaintiff a commission for all contracts she secured  from clients who decided to utilize Silver Tax Group’s services.      93.  This agreement was made between parties capable of contracting and  contained mutual obligations and valid consideration.    94.  Plaintiff performed all conditions precedent, if any, required of her under  this agreement.    95.  Defendants failed and refused to perform their obligations in accordance  with the terms and conditions of the agreement by failing to pay Plaintiff for all  commissions earned since December 2018.    96.  Plaintiff repeats and incorporates by reference the allegations contained  in Paragraphs 1-95 herein.      98.  Defendants were obligated to pay Plaintiff for all commissions earned.     99.  Because of the wrongful activities described above, Defendants have  received the benefit of Plaintiff’s work and have therefore received money belonging  to the Plaintiff.    100. Defendants were aware of and appreciated the benefit Plaintiff conferred.   101. Defendants have been unjustly enriched as a result of their retaining  commissions earned by Plaintiff.  It would be unjust to allow Defendants to enjoy the  fruits of Plaintiff’s labor without proper compensation.   