 At all times relevant herein, Defendant operated a willful scheme to deprive their  ANCs and others similarly situated of overtime compensation.      Plaintiff and the similarly situated individuals worked or work as ANCs or other  job positions performing similar duties for Defendant.  As ANCs, their primary job duty was  non-exempt work consisting of applying pre-determined criteria and guidelines to medical  authorization request appeals for health insurance coverage and payment purposes.     Plaintiff and the similarly situated individuals were paid a salary with no overtime  pay.      Defendant suffered and permitted Plaintiff and the similarly situated individuals  to work more than forty (40) hours per week without overtime pay.     Defendant also employed licensed practical nurses (“LPNs”) or licensed  vocational nurses (“LVNs”) who had the same principle job duties as ANCs.  Unlike the ANCs,  however, LPNs or LVNs, were paid hourly and eligible for overtime wages.      Defendant has been aware, or should have been aware, that Plaintiff and the  similarly situated individuals performed non-exempt work that required payment of overtime  compensation.  For instance, Defendant set productivity goals for Plaintiff and other similarly  situated individuals.  Plaintiff and the similarly situated individuals were required to work long  hours, including overtime hours, to complete all of their job responsibilities and to meet and/or  exceed their goals.    Defendant did not make, keep, or preserve accurate records of the hours worked  by Plaintiff and the similarly situated individuals.    Plaintiff, on behalf of herself and all similarly situated individuals, restates and  incorporates by reference the above paragraphs as if fully set forth herein.      Plaintiff files this action on behalf of herself and all similarly situated individuals.   The proposed collective class for the FLSA claims is defined as follows:   All persons who worked as Appeals Nurse Consultants (or other job positions  performing similar duties) for Defendant at any time from three years prior to the  filing of this Complaint through the entry of judgment (the “FLSA Collective”).    Plaintiff has consented in writing to be a part of this action pursuant to 29 U.S.C.  § 216(b).  Plaintiff’s signed consent form is attached as Exhibit A.   As this case proceeds, it is  likely that other individuals will file consent forms and join as “opt-in” Plaintiffs.    During the applicable statutory period, Plaintiff and the FLSA Collective  routinely worked in excess of forty (40) hours per workweek without receiving overtime  compensation for their overtime hours worked.  Plaintiff estimates that she typically worked on  average between fifty and sixty hours per week.    Defendant willfully engaged in a pattern of violating the FLSA, 29 U.S.C. § 201  et seq., as described in this Complaint in ways including, but not limited to, failing to pay its  employees overtime compensation.  Defendant knew that it was subject to the FLSA; it knew  that its ANCs worked more than forty-hours per week; and it knew that they were not receiving  overtime premiums for this work.    Defendant is liable under the FLSA for failing to properly compensate Plaintiff  and the similarly situated individuals.  Accordingly, notice should be sent to the FLSA  Collective.  There are numerous similarly situated current and former employees of Defendant  who have suffered from the Defendant’s practice of denying overtime pay, and who would  benefit from the issuance of court-supervised notice of this lawsuit and the opportunity to join.   Those similarly situated employees are known to Defendant, and are readily identifiable through  Defendant’s records.    Plaintiff, on behalf of herself and all members of the FLSA Collective, restates  and incorporates by reference the above paragraphs as if fully set forth herein.      The FLSA, 29 U.S.C. § 207, requires employers to pay employees one and one- half (1.5) times the regular rate of pay for all hours worked over forty (40) hours per workweek.      Defendant suffered and permitted Plaintiff and the FLSA Collective to routinely  work more than forty (40) hours per week without overtime compensation.      Defendant’s actions, policies, and practices described above violate the FLSA’s  overtime requirement by regularly and repeatedly failing to compensate Plaintiff and the FLSA  Collective overtime compensation.    Defendant knew, or showed reckless disregard for the fact, that it failed to pay  these individuals overtime compensation in violation of the FLSA.      By failing to accurately record, report, and/or preserve records of hours worked  by Plaintiff and the FLSA Collective, Defendant has failed to make, keep, and preserve records  with respect to each of its employees sufficient to determine their wages, hours, and other  conditions and practice of employment, in violation of the FLSA, 29 U.S.C. § 201, et seq.   FAILURE TO PAY OVERTIME  (on behalf of Plaintiff and the FLSA Collective)  