 EY is an accounting and consulting firm offering services to clients throughout  the world.    Plaintiff was employed by Defendant as a non-exempt AML at all times relevant  hereto.    Plaintiff worked in this capacity from approximately September 2016 through  August 2017.    Plaintiff and those similarly situated to him, routinely worked in excess of forty  (40) hours per week as part of their regular job duties.    Despite working more than forty (40) hours per week, Defendant failed to pay  Plaintiff and those similarly situated to him, overtime compensation at a rate of time and a half  their regular rate of pay for hours worked over forty in a workweek.    Defendant has employed and is employing hundreds of other individuals as  AMLs who performed and continue to perform the same or similar job duties under the same pay  provision as Plaintiff and the class members companywide.    Defendant has violated Title 29 U.S.C. §207 and the NYLL from September 2016  and continuing to date, in that:  a.  Plaintiff worked in excess of forty (40) hours per week for the period of  employment with Defendant;  b.  No payments or provisions for payment, have been made by Defendant to  properly compensate Plaintiff at the statutory rate of one and one-half times hiss  regular rate for those hours worked in excess of forty (40) hours per work week as  provided by the FLSA and the NYLL; and  c.  Defendant has failed to maintain proper time records as mandated by the FLSA  and the NYLL.    Plaintiff and the class members were all AMLs and performed the same or  similar job duties as one another in that they performed AML duties for Defendant and its clients  as part of its anti-money laundering advisory service function.     Defendant’s failure to compensate employees for hours worked in excess of 40  hours in a work week as required by the FLSA results from a policy or practice of failure to  assure that AMLs are/were paid for overtime hours worked based on their uniform pay policy,  applicable to all putative class members herein.    This policy or practice was applicable to Plaintiff and the class members.   Application of this policy or practice does/did not depend on the personal circumstances of  Plaintiff or those joining this lawsuit.  Rather, the same policy or practice which resulted in the  non-payment of overtime to Plaintiff applies to all class members.  Accordingly, the class  members are properly defined as:   All AMLs who worked for Defendant within the last three (3) years who  were not compensated at time-and-one-half for all hours worked in excess of  40 hours in one or more work weeks    Defendant knowingly, willfully, or with reckless disregard carried out its illegal  pattern or practice of failing to pay overtime compensation with respect to Plaintiff and the class  members.    Defendant did not act in good faith nor rely upon any of the following in  formulating its pay practices: (a) case law, (b) the FLSA, 29 U.S.C. § 201, et seq., (c)  Department of Labor Wage & Hour Opinion Letters or (d) the Code of Federal Regulations.    Defendant has acted willfully in failing to pay Plaintiff and the class members in  accordance with the law.    Defendant has failed to maintain accurate records of Plaintiff’s and the class  members’ work hours in accordance with the law.   Plaintiff sues on his own behalf and on behalf of a class of persons under Rules  23(a), (b)(2) and (b)(3) of the Federal Rules of Civil Procedure.     Plaintiff brings his New York Labor Law claim on behalf of all persons who were  employed by Defendants at any time since February 2013, to the entry of judgment in this case  (the “Class Period”), who were non-exempt employees within the meaning of the New York  Labor Law and have not been paid for hours actually worked as well as overtime wages as  required in violation of the New York Labor Law (the “Class”).    The persons in the Class identified above are so numerous that joinder of all  members is impracticable.  Although the precise number of such persons is unknown, and the  facts on which the calculation of that number are presently within the sole control of the  Defendant, upon information and belief, there are thirty-five (35) or more members of the Class  during the Class Period.    The Defendant has acted or refused to act on grounds generally applicable to the  class, thereby making appropriate final injunctive relief or corresponding declaratory relief with  respect to the class as a whole.    This policy or practice was applicable to Plaintiff and the class members.   Application of this policy or practice does/did not depend on the personal circumstances of  Plaintiff or those joining this lawsuit.  Rather, the same policy or practice which resulted in the  non-payment of overtime to Plaintiff applies to all class members.  Accordingly, the class  members are properly defined as:   All AMLs who worked for Defendant within the last six (6) years who were  not compensated at time-and-one-half for all hours worked in excess of 40  hours in one or more work weeks.    Plaintiff is committed to pursuing this action and has retained competent counsel  experienced in employment law and class action litigation.    Plaintiff has the same interests in this matter as all other members of the class and  Plaintiff’s claims are typical of the Class.    Plaintiff realleges and reavers paragraphs 1 through 42 of the Complaint as if  fully set forth herein.    From at least September 2016 and continuing until August 2017, Plaintiff worked  in excess of the forty (40) hours per week for which Plaintiff was not compensated at the  statutory rate of one and one-half times Plaintiff’s regular rate of pay.    Plaintiff was, and is entitled to be paid at the statutory rate of one and one-half  times Plaintiff’s regular rate of pay for those hours worked in excess of forty (40) hours.    At all times material hereto, Defendant failed, and continues to fail, to maintain  proper time records as mandated by the FLSA.    Defendant has failed to properly disclose or apprise Plaintiff of Plaintiff’s rights  under the FLSA.    Due to the intentional, willful, and unlawful acts of Defendant, Plaintiff suffered  and continues to suffer damages and lost compensation for time worked over forty (40) hours per  week, plus liquidated damages.    Plaintiff is entitled to an award of reasonable attorney’s fees and costs pursuant to  29 U.S.C. §216(b).   Plaintiff realleges and reavers paragraphs 1 through 51 of the Complaint as if  fully set forth herein.    Defendant failed to pay Plaintiff and the Class Members overtime wages to which  they are entitled under the NYLL and the supporting New York State Department of Labor  Regulations.    Defendant failed to pay Plaintiff and the Class Members one-and-one-half times  their regular rate of pay for all work in excess of forty hours per workweek.    Through their knowing or intentional failure to pay Plaintiff and the Class  Members overtime wages for hours worked in excess of forty hours per workweek, Defendant  has willfully violated the NYLL, Article 19, §§ 650 et seq., and the supporting New York State  Department of Labor Regulations.    Plaintiff realleges and reavers paragraphs 1 through 51 of the Complaint as if  fully set forth herein.    Defendant failed to supply Plaintiff and the Class Members with accurate  statements of wages as required under the NYLL, Article 6, § 195(3).    Specifically, Defendant failed to provide an accurate number of hours worked by  Plaintiff and the Class Members because Defendant failed to list the time Plaintiff and the Class  worked, their regular rate of pay, and/or their overtime rate of pay.    Through their knowing or intentional failure to provide Plaintiff and the Class  Members with the accurate wage statements required under the NYLL, Defendant has willfully  violated NYLL, Article 6, §§ 190 et seq., and the supporting New York State Department of  Labor Regulations.    Due to Defendant’s willful violations of NYLL, Article 6, § 195(3), Plaintiff and  the Class Members are entitled to statutory penalties, reasonable attorneys’ fees, costs, and  injunctive relief and declaratory relief, as provided for by NYLL, Article 6, §198(1-d).  VIOLATION OF NEW YORK LABOR LAW  FAILURE TO PROVIDE ACCURATE WAGE STATEMENTS   VIOLATION OF 29 U.S.C. §207 OVERTIME COMPENSATION   VIOLATION OF NEW YORK LABOR LAW - UNPAID OVERTIME  