14.  At all relevant times, Plaintiff worked as a Membership Advisor for Defendant in  Defendant’s Meriden location.  Plaintiff and the other Membership Advisors were scheduled for  forty-five (45) hours per week, but frequently worked more than forty-five (45) hours.    15.  Plaintiff and Membership Advisors were paid pursuant to a common pay plan  which did not include overtime premiums in violation of state and federal law.  They were  scheduled to work forty-five (45) hours per week and frequently worked longer hours,  sometimes over fifty (50) especially at the end of the month, but were not paid overtime  premiums for those extra hours.   16.   Plaintiff’s regularly scheduled work hours varied between twelve (12) pm to nine  (9) pm or one (1) pm to ten (10) pm and she worked Monday through Wednesday, Fridays and  Saturdays.  Plaintiff was off on Thursdays and Sundays.  This scheduled totaled nine (9) hours  per day and five (5) days per week for a total of forty-five (45) hours.     17.  This pay plan included a base salary ($25,000) along with other income in the  form of bonuses and commissions.     19.  For example, during the month of November 2015, Defendant paid Plaintiff one  thousand nine hundred and twenty-three dollars and six cents ($1,923.06) in salary and one  hundred seventy dollars and fifty cents ($170.50) in commissions.    20.  Additionally, in September 2016, Defendant paid Plaintiff one thousand nine  hundred and twenty-three dollars and six cents ($1,923.06) and five hundred and eight dollars  and twenty-seven cents ($508.27) in commissions.   21.  At the beginning of 2017, Defendant changed the classification of Membership  Advisors from exempt to non-exempt.  It changed their pay plan from salary /commission to  hourly /commission.   22.  After this change in their compensation, Defendant began paying Membership  Advisors overtime but failed to include their commissions in the calculation of their overtime  pay in violation of state and federal law. Conn. Gen. Stat. § 31-76b(1); 29 U.S.C. § 207(e).    33.  Based on the foregoing, Defendant violated the FLSA as to Plaintiff and the class  of Membership Advisors who worked for Defendant from September 14, 2014 to December 31,  2016.    34.  Plaintiff and all other similarly situated individuals who opt into this litigation are  entitled to overtime compensation for all overtime hours worked, liquidated damages, attorneys’  fees and court costs.  35.  Based on the foregoing, Defendant violated the FLSA as to Plaintiff and the class  of Membership Advisors who worked for Defendant from January 1, 2017 until the date of final  judgment in this matter.    36.  Plaintiff and all other similarly situated individuals who opt into this litigation are  entitled to overtime compensation for all overtime hours worked, liquidated damages, attorneys’  fees and court costs.  37.  Based on the foregoing, Defendant violated the CWA as to Plaintiff and the class  of Membership Advisors who worked for Defendant from September 14, 2014 to December 31,  2016.    39.  Based on the foregoing, Defendant violated the CWA as to Plaintiff and the class  of Membership Advisors who worked for Defendant from January 1, 2017 to the date of final  judgment in this matter.    VIOLATION OF THE FAIR LABOR STANDARDS ACT, 29 U.S.C.  § 216(b)   VIOLATION OF THE FAIR LABOR STANDARDS ACT, 29 U.S.C.  § 216(b)   VIOLATION OF THE CONNECTICUT WAGE ACT, Conn. Gen.  Stat. §§ 31-58 et. seq.    VIOLATION OF THE CONNECTICUT WAGE ACT, Conn. Gen.  Stat. §§ 31-58 et. seq.   