10.   Defendant White Oak also operates both a red meat and white meat abattoir  (slaughterhouse) on the farm.  In fact, it claims to be the only farm in the United  States that has both types of abattoirs on the property.    11.   The abattoirs are solar powered and use solar thermal technology to heat  wash down water in the plants.    13.  The red meat abattoir employees work on the kill floor and in the cutting and  grinder rooms and are cross-trained in the skills necessary for each.     14.  The red meant abattoir employees work full-time in the abattoirs and do not  regularly perform any farm work.    15.  Defendant White Oak slaughters approximately 35 head of cattle per day.   16.  Although Defendant White Oak occasionally slaughters its own cattle, most  of the cattle are bought at auction or delivered from other farms to White Oak for  slaughter and processing.       18.  Plaintiff brings this action for violation of FLSA as a collective action  pursuant to FLSA Section 16(b), 29 U.S.C. § 216(b), on behalf of themselves and  all persons who are or were employed by Defendant in its red meat abattoir during  the period from September 23, 2012, to the present and who were not paid an  overtime premium for all hours worked in excess of 40 in a single workweek  (hereinafter the “Collective Plaintiffs”).    19.  Plaintiff and the Collective Plaintiffs regularly worked a schedule that began  at 7:00 am and usually ended at 5:00 or 6:00 pm, with an hour for lunch; however,  Plaintiff and the Collective Plaintiffs were required to work until all cattle were  processed.      21.  Plaintiff and the Collective Plaintiffs would also have to come in early to set  up the processing rooms, dress and sharpen their knives.     22.  The result was that Plaintiff and the Collective Plaintiffs had to work much  more than 40 hours in a single workweek.    23.  Although Plaintiff and the Collective Plaintiffs regularly worked more than  40 hours in a week, Defendant paid them only straight time for all hours worked.    24.  On information and belief, the U.S. Department of Labor has advised  Defendant White Oak that its actions in failing to pay an overtime premium are a  violation of the FLSA.    26.  By failing to pay Plaintiff and the Collective Plaintiffs an overtime premium  for time that was worked in excess of forty (40) hours in a workweek, Defendant  violated the FLSA, 29 U.S.C. §207.    27.  Defendant’s conduct in refusing to pay Plaintiff and the Collective Plaintiffs  overtime compensation is a willful violation of the FLSA within the meaning of 29  U.S.C. § 255(a), entitling Plaintiff and the Collective Plaintiffs to bring this claim  within three years of the accrual of any cause of action.     28.  Based upon the facts alleged herein, Defendant White Oak had no  reasonable grounds for believing that its refusal to pay an overtime premium to  Plaintiff and the Collective Plaintiffs was appropriate under the FLSA.  As such,  Defendant is not entitled to any reduction in the amount of liquidated damages  under 29 U.S.C. § 216(b).    30.   Upon information and belief, in failing or refusing to pay Plaintiff and the  Collective Plaintiffs overtime as required by the FLSA, Defendant has not relied  on any legal advice indicating that such practice was permitted under the FLSA.  31.   The allegations contained in paragraphs 1 through 30 are hereby  incorporated by this reference.    32.   By virtue of Defendant’s failure and refusal to pay an overtime premium to  Plaintiff and the Collective Plaintiffs, all of whom regularly worked in excess of  forty (40) hours in a single workweek, Defendant is in violation of the Fair Labor  Standards Act of 1938, 29 U.S.C. §§ 207 and 215.    8.   Defendant White Oak maintains approximately 1200 head of cattle on the  farm all of various ages including 600 heifers that are kept for raising calves.   Cattle are raised for 2 years to 1,200 lbs. or more before they are eligible for  slaughter.     9.   Approximately 100 employees work on the farm and assist in raising the  livestock and producing artisan goods and products generated by the farming  operation that are then offered for retail sale.    VIOLATION OF THE FLSA – UNPAID OVERTIME WAGES  