 As hourly nonexempt manufacturing employees of Defendant, Plaintiff and  others similarly situated, have the primary duties of performing manual manufacturing  tasks in the production of Gates’ products.  This primary duty established the Plaintiff and  others similarly situated as being entitled to overtime pay under the FLSA and KWPA  (i.e., nonexempt employees under the FLSA and the KWPA).    On a weekly basis throughout their employment with Defendant, the  Plaintiff and others similarly situated routinely worked in excess of forty hours per  workweek without receiving proper overtime compensation for all overtime hours worked  as required under the FLSA and the KWPA.  Defendant has a policy and practice requiring  all hourly nonexempt manufacturing employees to arrive at their work station between  early before each shift (usually 10-15 minutes, but longer on other occasions) to perform  work related activities such as, but not limited to: meeting and transitioning with prior  shift on any issues regarding production, supply, maintenance, and other pre-shift  activities.  Defendant also has a policy and practice requiring hourly nonexempt  manufacturing employees to remain after their shift if necessary to perform work to assist  in the transition to the next shift.  Defendant does not permit the Plaintiff and other  similarly situated employees to report this pre-shift or post-shift time as work performed,  and in turn, they are denied overtime compensation resulting from this policy and  practice.      Regarding the allegations asserted in ¶ 15, the Plaintiff observed the other  hourly nonexempt manufacturing employees in her respective work areas throughout her  employment as being subject to the same policy of requiring pre-shift and post-shift “off  the clock” work and thereby denying these persons overtime pay.      Defendant has a policy or practice of counseling, disciplined or terminating  hourly nonexempt manufacturing employees for a failure to be present at their work  stations for the pre-shift and post-shift work described in ¶ 15.       The FLSA and KWPA requires covered employers such as Defendant to  compensate all nonexempt employees at a rate of not less than one and one-half times the  regular rate of pay for work performed in excess of forty (40) hours per workweek.  The  Defendant’s policy and practice as alleged herein violates the FLSA and the KWPA in that  Defendant knowingly allows, permits and/or requires Plaintiff, and others similarly  situated, to perform work “off the clock” which in turn denies overtime pay in violation of  the FLSA and KWPA.    Defendant’s conduct was willful and in bad faith.  Defendant was aware, or  should have been aware, that Plaintiff and others similarly situated performed work that  required payment of the correct overtime compensation for all hours actually worked, and  that its policy and practice of requiring pre-shift and post-shift “off the clock” work denied  them of such compensation required under the FLSA and KWPA.     Plaintiff, on behalf of herself and others similarly situated, re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.    The FLSA requires each covered employer, such as Defendant, to  compensate all non-exempt employees at a rate of not less than one and one-half the  regular rate of pay for work performed in excess of forty hours in a work week.      Plaintiff files this action on behalf of herself and all others similarly situated  pursuant to the FLSA, 29 U.S.C. §216(b).  The proposed collective class for the FLSA  claims is defined as follows:  All persons who worked as hourly nonexempt employees in the  manufacturing process for Defendant (including “Team Leads”) at all its  manufacturing locations within three years prior to the filing of this  Complaint (hereafter the “FLSA Collective”).    This Complaint may be brought and maintained as an “opt-in” collective  action pursuant to the FLSA, 29 U.S.C. §216(b), for all claims asserted by the Plaintiff  because the claims of the Plaintiff are similar to the FLSA Collective.    During the applicable statutory period, Plaintiff and the FLSA Collective  routinely worked in excess of forty (40) hours per workweek without receiving overtime  compensation at the proper overtime rate of pay for their overtime hours worked in  violation of the FLSA.    Defendant is liable under the FLSA, 29 U.S.C. § 201, et seq., for failing to  properly compensate Plaintiff and the FLSA Collective for overtime pay owed.     Plaintiff and the FLSA Collective are victims of Defendant’s widespread,  repeated, systematic and consistent illegal policies that have resulted in violations of their  rights under the FLSA, and that have caused significant damage to Plaintiff and the FLSA  Collective.     The foregoing conduct, as alleged, constitutes a willful violation of the FLSA  within the meaning of 29 U.S.C. § 255(a) as Defendant knew, or showed reckless disregard  for, the fact that its compensation practices were in violation of these laws.    As the direct and proximate result of Defendant’s unlawful conduct,  Plaintiff and the FLSA Collective have suffered, and will continue to suffer, a loss of  income and other damages.  Plaintiff and the FLSA Collective under § 216(b) of the FLSA  are entitled to liquidated damages and attorney’s fees and costs incurred in connection  with enforcing this claim.        The Plaintiff and the FLSA Collective have suffered from Defendant’s  common policies and would benefit from the issuance of a 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 others similarly situated, re-alleges and  incorporates by reference the above paragraphs as if fully set forth herein.    Plaintiff brings her overtime wage claim pursuant to the KWPA, Kan. Stat.  § 44-313 et seq. as a class action pursuant to Federal Rule of Civil Procedure 23, on behalf  of the following class:  All persons who worked as hourly nonexempt employees in the  manufacturing process for Defendant (including “Team Leads”) at its Iola,  Kansas plant within three years prior to the filing of this Complaint  (hereafter the “Kansas Overtime Class”).    Defendant violated the KWPA by failing to compensate Plaintiff and the  Kansas Overtime Class overtime wages due at each pay period for all overtime hours  worked as required under the FLSA.    Class action treatment of Plaintiff’s KWPA claim is appropriate because, as  alleged in paragraphs 38-43, infra, all of Federal Rule of Civil Procedure 23’s class action  requisites are satisfied.     The Kansas Overtime Class includes over fifty individuals and, as such, is so  numerous that joinder of all class members is impracticable.    Plaintiff will fairly and adequately represent the interests of the Kansas  Overtime Class, and she has retained competent and experienced counsel who will  effectively represent the interests of the Kansas Overtime Class.    Questions of law and fact are common to the class.  The Plaintiff and the  Kansas Overtime Class have been subjected to the common business practices described  in paragraph 39, supra, and the success of their claims depends on the resolution of  common questions of law and fact.  Common questions of fact include whether the  Plaintiff and the Kansas Overtime Class worked in excess of forty hours per work week,  whether they were paid overtime as required, and whether Defendant had actual or  constructive knowledge that Plaintiff and others similarly situated worked more overtime  hours than reported.  Common questions of law include, inter alia, whether Defendant’s  conduct as alleged herein violated the KWPA for failing to pay all wages due on each and  every pay period as required under the FLSA.    Class certification is appropriate under Federal Rule of Civil Procedure  23(b)(1) because the prosecution of separate actions by individual Kansas Overtime Class  members would create a risk of inconsistent or varying adjudications which would  establish incompatible standards of conduct for Defendant and/or because adjudications  with respect to individual class members would, as a practical matter, be dispositive of  the interests of non-party Kansas Overtime Class members.    The foregoing conduct, as alleged, constitutes a willful violation of the  KWPA as Defendant knew, or showed reckless disregard for, the fact that its  compensation practices were in violation of these laws.  In turn, under KWPA, Kan. Stat.  § 44-315(b), Plaintiff and the Kansas Overtime Class are also entitled to liquidated  damages set forth in this statute.  FLSA COLLECTIVE ACTION   RULE 23 CLASS UNDER KWPA FOR OVERTIME OWED  