That the defendants' violations of the FLSA were willful. Plaintiffs repeat each and every allegation previously made herein. That the persons similarly situated to plaintiff Hallissey and described in paragraph 47 constitute a class of persons that is so numerous that joinder of all such persons individually is impractical. The claims of the plaintiff Hallissey are typical of the claims of the above described class, in that the interests of the plaintiff Hallissey are co-extensive with the interests of the other members of the class, there is a lack of adverse interests between the plaintiff Hallissey and the other members of the class, and common questions exist. The plaintiff Hallissey will fairly and adequately protect the interests of said class.
Plaintiffs demand a trial by jury on all issues so triable.