(FLSA Overtime Wage Violations Against Defendants – Collective Action)   (NYLL Failure to Pay Wages Against Defendants – Class Action)   (NYLL Overtime Wage Violations Against Defendants – Class Action)   23. At all times relevant hereto, Defendants have committed the following acts and/or  omissions with knowledge that they have been violating federal and state laws and that Plaintiff  has been and continues to be economically injured.   46. Pursuant to the FLSA, §§ 207 and 216(b), Plaintiff brings his First cause of action  as a collective action on behalf of himself and other similarly situated employees of Defendants.   47. Defendants’ failure to comply with the FLSA extended beyond the Plaintiff to all  other similarly situated employees insofar as Defendants had a policy to not pay their New Jersey  union member employees at one and half times the New York City prevailing wage rate for all  hours over forty (40) per week for work performed on the New York side of the GWB span.   48. Plaintiff seeks certification of the First cause of action pursuant to 29 U.S.C. §  216(b) as a collective action on behalf of himself, individually, and all other similarly situated  current and former individuals New Jersey union members employed by Defendants on the Project  who have been denied payment of one and half times the New York City prevailing wage rate for  all hours over forty (40) per week for work performed on the New York side of the GWB span.   49. Upon information and belief, there are at least sixty (60) current and former New  Jersey union member employees of Defendants who have been denied payment of one and half  times the New York City prevailing wage rate for all hours over forty (40) per week for work  performed on the New York side of the GWB span while working for Defendants.   60. Plaintiff repeats and realleges all paragraphs above as though fully set forth herein.   61. Throughout the statute of limitations period covered by these claims, Plaintiff and  others similarly situated regularly worked in excess of forty (40) hours per workweek.   62. At all relevant times hereto, Defendants have had and operated under a decision,  policy and plan, and under common policies, programs, practices, procedures, protocols, routines  and rules of knowingly and willfully failing and refusing to pay Plaintiff and others similarly  situated one and a half times the statutorily required New York City prevailing wage rate for all  hours over forty (40) per week for work performed on the New York side of the GWB span in  violation of the FLSA, 29 U.S.C. § 207.   63. The foregoing conduct, as alleged, constitutes a willful violation of the FLSA  within the meaning of 29 U.S.C. § 255(a).   65. Plaintiff repeats and realleges all paragraphs above as though fully set forth herein.   66. New York law prohibits an employer from permitting an employee to work without  paying overtime wages for all hours worked in excess of forty (40) in any workweek.   67. Throughout the statute of limitations period covered by these claims, Defendants  knowingly, willfully, regularly and repeatedly have failed to pay Plaintiff and members of the  NYLL Class the required overtime rates, two (2) times their regular rate of pay, for hours worked  in excess of forty (40) per workweek and/or eight (8) hours per day.   68. Defendants’ NYLL violations have caused Plaintiff and the NYLL Class members  irreparable harm for which there is no adequate remedy at law.   69. As a direct and proximate result of Defendants’ unlawful conduct, as set forth  herein, Plaintiff and the members of the NYLL Class have sustained damages and seeks recovery  for unpaid wages in an amount to be determined at trial, attorneys’ fees, costs, liquidated damages  and prejudgment interest as provided by NYLL § 663 and supporting regulations, and such other  legal and equitable relief as this Court deems just and proper.  70. Plaintiff repeats and realleges all paragraphs above as though fully set forth herein.  