 The Plaintiffs and members of the proposed class are (or were) cashiers at various Factor Sales’ owned grocery stores located in southwestern Arizona.  By way of example: A. Plaintiff Juvera worked as a cashier for Factor Sales at the time of his termination in August, 2011; B. Plaintiff Nunez worked as a cashier for Factor Sales from December, 2008 until she resigned her employment in October, 2011; C. Plaintiff Romero has worked as a cashier for Factor Sales from July, 2010 through the present date; and D. Plaintiff Vazquez has worked as a cashier for Factor Sales from June, 2011 through the present date.   On occasion, the cash till for the Plaintiffs and members of the proposed class does not add up correctly.  When that happens, the Defendants require the Plaintiffs and members of the proposed class to reimburse Factor Sales for any such shortage.   When the error is of the sort that the Plaintiffs and members of the proposed class collect too much money, the Defendants do not permit the Plaintiffs and members of the proposed class to keep the overage nor do they permit them to credit such overages against shortages they may have incurred on other days.   The Defendants maintain detailed logs setting forth how much each employee purportedly “owes” the Defendants.  Attached hereto as Exhibit A is an example of one such log, dated August 18, 2011, involving, inter alia, Plaintiff Vazquez.  On these forms, the “Saldo” column sets forth the balance “owed” by each employee, the “Abono” column sets forth the amounts of payments made by each employee, and the “Fecha” column sets forth the date each payment was made.  Once the employees pay back their “debt” to Factor Sales, they receive a note stating “FELICIDADES!!!”, which in Spanish means “Congratulations!!!”   When a Plaintiff and member of the proposed class receive their paycheck and they “owe” money to Factor Sales for the reasons set forth in ¶24, supra, and ¶32, infra, they are required to make a payment to Factor Sales from their earnings.  Upon information and belief, the dates of all of these payments are recorded on receipts such as the one attached hereto as Exhibit C.  Exhibit C, in fact, memorializes Plaintiff Vazquez’s $16.69 payment to Factor Sales or on or about August 18, 2011 for “Pago Faltantes”, which in Spanish means “missing payment”.   As errors of this sort seem to be commonplace at Factor Sales, the cycle set forth in ¶¶ 24 through 28, supra, repeats itself over and over.  By way of example, no sooner did Plaintiff Vazquez pay the $16.69 referenced in ¶27, supra, when she was informed that she now “owed” an additional $70.36 as set forth on attached Exhibit D.   The legal problem is, however, that once these payments are made to Factor Sales, the Plaintiffs and member of the proposed class are making less than minimum wage.  To illustrate the point, the illegality of this arrangement becomes obvious when one compares attached Exhibits B and C.   To make matters worse, the Defendants also charge the Plaintiffs and member of the proposed class twelve dollars ($12.00) for the cost of a second (or more) uniform and five dollars ($5.00) for security badges.  In select payroll periods involving particular cashiers, these charges also have the effect of making the employees work below the minimum wage.   Under a long line of established legal authority, “it is unlawful for an employer to deduct the cost of a uniform ... from an employee’s wages when the deduction reduces the wages of that employee below the minimum.”  Id. at §9.VI.F at 9-57 to 9-59.   In addition to the legal problems set forth in ¶¶30 and 32, supra, the Defendants’ policy of demanding and collecting payments from its employees as a term and condition of their employment also violates, inter alia, A.R.S. §§23-202 and 203.   Defendants have willfully failed to pay wages due the Plaintiffs and members of the proposed class in violation of the federal minimum wage law, 29 U.S.C. §206(a).  As such, the Plaintiffs and members of the proposed class are entitled to recover all unpaid wages and liquidated damages pursuant to 29 U.S.C. §216(b).  Defendants have willfully failed to pay wages at the rate of the Arizona Minimum Wage, in violation of the Arizona Minimum Wage Act, codified at A.R.S. §23-363(A).  The Plaintiffs and members of the proposed class are entitled to recover the balance of the wages owed, including interest thereon, and an additional amount equal to twice the underpaid wages pursuant to A.R.S. §23-364(G).  Defendants have willfully failed to pay wages to the Plaintiffs and members of the proposed class for labor performed as required pursuant to A.R.S. §23-351[c].   As this Court has concluded previously, the treble damages provision set forth in A.R.S. §23-355(A) may be applied to treble a liquidated damages award received under the FLSA pursuant to this Court’s supplemental jurisdiction.  Davis v. Jobs for Progress, 427 F.Supp. 479, 483 (D. Ariz. 1976). Violation of FLSA Minimum Wage Standard  Violation of Arizona Wage Law  Violation of Arizona Minimum Wage Act 