 Plaintiff Christopher Coleman files this case as an opt in collective action,  as is specifically allowed by 29 U.S.C. § 216(b).    The class that Plaintiff Christopher Coleman seeks to represent may be  described as follows:  All current and former employees of Defendant who 1) worked as a Police  Dispatcher during the class period, and 2) claims that he or she either (a)  failed to receive all of his or her overtime pay, in violation of 29 U.S.C.  201 et seq. and seeks payment for such lawfully earned overtime pay, or  (b) failed to receive all of his or her compensation for work performed, but  not recorded or paid (“off-the clock”), in violation of 29 U.S.C. 201 et seq.    Plaintiff, Christopher Coleman, seeks to represent only those members of  the above-described group who, after appropriate notice of their ability to opt in to this  action, have provided consent in writing to be represented by counsel for Plaintiff  Christopher Coleman as required by 29 U.S.C. § 216(b).    Those persons who choose to opt in, referred to as the “Plaintiff’s class”,  will be listed on subsequent pleadings and copies of their written consents to sue will be  filed with the Court.    At all times relevant to this action, Defendant has been subject to the  requirements of the Fair Labor Standards Act 29 U.S.C. 201 et seq.     For purposes of this action, the relevant period is defined as such period  commencing on the date that is three years prior to the filing of this action, and  continuing thereafter.    Defendant employed Plaintiff Christopher Coleman from March 2014  until February 2016 as a Police Dispatcher for the City of Cairo, Illinois.    As a Police Dispatcher, Coleman responded to emergency and non- emergency calls for assistance and information and provided dispatch and  communication support services for police, fire, emergency, and related services.    Only one Police Dispatcher works at the dispatch desk per shift.    Police Dispatchers work one of three shifts: 2 P.M. to 10 P.M.; 10 P.M. to  6 A.M.; or 6 A.M. to 2 P.M.    Defendant posted monthly schedules as to when each dispatcher is  scheduled to work. The shifts were indicated by a “1” “2” or “3” on the schedule.     Defendant requires Police Dispatchers to be at the dispatch desk between  fifteen and twenty minutes before each shift. Defendant requires Police Dispatchers to  stay at the dispatch desk until the end of their shift. This means that Defendant requires  Police Dispatchers to work 8 hours and 15 minutes per shift.    Defendant did not provide time sheets or a time clock for Police  Dispatchers to record the time they worked.     Defendant paid Police Dispatchers for 8 hours of time for each shift  worked, regardless of the actual time spent working.    During Plaintiff’s employment, while working for the Defendant, Plaintiff  was required to work overtime hours in excess of 40 hours worked during many seven- day workweeks.    Plaintiff often worked in excess of 40 hours per week during his  employment with the Defendant.    Defendant required Plaintiff and all others similarly situated to perform  work which routinely required them to work overtime hours as defined by 29 U.S.C. §  201 et seq., for which they failed to receive overtime compensation as required by the  Act.  VI.   Each and every allegation contained in the foregoing paragraphs is re- alleged as if fully written herein.    Plaintiff Christopher Coleman and all others similarly situated are  considered non-exempt employees under the statutory provisions of the Fair Labor  Standards Act, 29 U.S.C. 201, et seq., as well as by the administrative regulations used to  interpret the Act.    Defendant has failed to make good faith efforts to comply with the FLSA,  and have willfully and deliberately sought to evade the requirements of the federal  statute.    Defendant  has  failed  to  maintain  a  complete,  accurate,  and  contemporaneous record of the number of hours worked per workweek by Plaintiff and  by all other similarly situated employees, as required by law.    The Defendant’s conduct was willful within the meaning of 29 U.S.C. §  255(a).    No lawful exemption excused the Defendant from compensating Plaintiff  and all others similarly situated for hours worked, but not recorded or paid in a  workweek.    Defendant knowingly, willfully, or with reckless disregard carried out an  illegal pattern and practice of deceptive and fraudulent accounting practices regarding  compensation due to Plaintiff and to all others similarly situated for hours worked, but  not recorded or paid.    Plaintiff and all others similarly situated seek an amount of back-pay equal  to the unpaid compensation for hours worked, but not recorded or paid, from the date  they commenced employment for the Defendant until the date of trial.    Each and every allegation contained in the foregoing paragraphs is re- alleged as if fully written herein.    Plaintiff Christopher Coleman and all others similarly situated are  considered non-exempt employees under the statutory provisions of the Fair Labor  Standards Act, 29 U.S.C. 201, et seq., as well as by the administrative regulations used to  interpret the Act.    Plaintiff Christopher Coleman and all others similarly situated are entitled  to receive overtime pay for all hours they have worked in excess of 40 during each seven- day workweek.    Defendant failed to compensate Plaintiff and all others similarly situated,  their entitled pay (including overtime pay) for those hours they worked in excess of 40  per week.    Defendant has violated 29 U.S.C. § 201 et seq. by failing to compensate  the Plaintiff and all other similarly situated employees overtime pay for all hours worked  in excess of 40 hours per week.    Defendant has failed to make good faith efforts to comply with the FLSA,  and have willfully and deliberately sought to evade the requirements of the federal  statute.    The Defendant’s conduct was willful within the meaning of 29 U.S.C. §  255(a).    No lawful exemption excused the Defendant from compensating Plaintiff  and all others similarly situated, overtime pay for hours worked over forty per week.    Defendant knowingly, willfully, or with reckless disregard carried out an  illegal pattern and practice of deceptive and fraudulent accounting practices regarding  overtime compensation due to Plaintiff and to all others similarly situated.    Plaintiff and all others similarly situated seek an amount of back-pay equal  to the unpaid overtime compensation from the date they commenced employment for the  Defendant until the date of trial.    Plaintiff and all others similarly situated further seek an additional equal  amount as liquidated damages, as well as reasonable attorney’s fees and costs as provided  by 29 U.S.C. § 216(b), along with post-judgment interest at the highest rate allowed by  law.   Each and every allegation contained in the foregoing paragraph is re- alleged as if fully written herein.    Other employees have been victimized by this pattern, practice, and policy  of the Defendant that is in violation of the FLSA.    Thus, from personal knowledge, Plaintiff is aware that the illegal practices  and policies of Defendant has been imposed on other workers.    Accordingly, each Defendant’s pattern and practice of failing to pay the  overtime pay (at time and one-half) of employees as required by the FLSA results from  the Defendant’s general application of policies and practices, and does not depend on the  personal circumstances of the Plaintiff’s class.    Plaintiff Christopher Coleman’s experience is typical of the experience of  the Plaintiff’s class as it pertains to compensation.    The specific job titles or job requirements of the various members of the  class do not prevent collective treatment.    All employees, regardless of their job requirements or rates of pay, who  are denied overtime compensation for hours worked in excess of 40 per week, are  similarly situated.    Although the issue of damages may be individual in character, there is no  detraction from the common nucleus of liability facts.    All current and former police dispatchers, who at any time during the three  years prior to the date of filing of this action to the date of judgment who were denied  overtime pay by Defendant for hours worked in excess of forty (40) in any given  workweek are properly included as members of the class.   Collective Action Allegations   Failure to compensate for “off-the-clock” work   Unpaid overtime compensation under the FLSA  