(INDIVIDUAL AND CLASS CLAIMS)  VIOLATION OF NEW YORK EXECUTIVE LAW § 296, subd. 1(a) –  GENDER DISCRIMINATION  285.  This Cause of Action is brought on behalf of Plaintiffs and all members of the  class  286.  Defendant has discriminated against Plaintiffs and all members of the class in  violation of Section 296, subdivision 1(a) of the New York Executive Law, by subjecting them  to different treatment on the basis of their gender.  287.  Defendant has discriminated against Plaintiffs and members of the class by  treating them differently from and less preferably than similarly-situated employees of the male  dominated TED.  288.  As a result of Defendant’s conduct, Plaintiffs and the members of the class have  suffered and continue to suffer harm, including but not limited to lost earnings. Lost benefits,  other financial loss, and non-economic damages.  289.  By reason of Defendant’s discrimination, Plaintiffs and all members of the class  are entitled to all remedies available for violations of the New York Executive Law.  (INDIVIDUAL AND CLASS CLAIMS)  VIOLATION OF NEW YORK EQUAL PAY LAW –  DENIAL OF EQUAL PAY FOR EQUAL WORK  (INDIVIDUAL AND COLLECTIVE ACTION CLAIMS)  VIOLATION OF THE FAIR LABOR STANDARDS ACT OF 1938,  AS AMENDED BY THE EQUAL PAY ACT OF 1963 -  Disparate Pay  235.  NYC employs individuals classified as School Crossing Guards to ensure the safe  transit of child pedestrians to and from school.  236.  School Crossing Guard positions are predominately staffed by females.  237.  School Crossing Guards are limited to 5 hour workdays.  See Executed Contract:  School Crossing Guards, March 3, 2008 to March 2, 2010 (“Crossing Guard CBA”), attached  hereto as Exhibit A.  238.  School Crossing Guards are uniformed employees of the NYC Police Department 