 Ms. Meadows files this case as an “opt-in” collective action, as is specifically  allowed by the collective action provisions of the FLSA (See, 29 U.S.C. § 216(b)).    For purposes of this action, the “relevant period” or “class period” is the period of  time commencing on the date that is three years prior to the filing of this action, and continuing  thereafter until time of trial.    Ms. Meadows, for instance, routinely worked 42 to 44 hours a week during each  workweek of her employment with KPMG.  She was termed a “Seasonal, Professional Level”  employee, but KPMG never intended her employment to be seasonal, sporadic or part-time.    Other similarly situated employees have, and are, being denied their lawful  overtime wages by having to work hours off-the-clock and by being required to certify that they  have worked exactly 40 hours each and every week of their employment. Thus, Plaintiff’s  experience is typical of the experience of members of the Plaintiff Class as it pertains to unpaid  overtime wages and unpaid employment benefits.    The job titles or specific job requirements of the numerous members of the Plaintiff  Class do not prevent collective treatment because each non-exempt employee, regardless of job  title, job requirements, or rate of pay, who was / is denied overtime compensation for hours worked  in excess of 40 in one or more workweek is similarly situated to Plaintiff, resulting solely from  Defendant’s deliberate denial of overtime wages by way of a systematic and consistently applied  company policy in violation of the FLSA.    Further, although the quantum of damages may vary among the individual members  of the Plaintiff Class, there is no detraction from the common nucleus of liability facts.    Thus, the unpaid overtime class Ms. Meadows seeks to represent is comprised of  all current and former employees that KPMG LLP employed as hourly or non-exempt workers     1) who were categorized as “Seasonal, Professional Level” employees; 2) who were based in,  and/or worked in the United States during any workweek falling within the class period; 3) who  worked off-the-clock hours during any workweek falling within the class period; and 4) who were  not paid their overtime wages during any workweek falling within the class period.    Each individual who opts into this litigation will be added as a party, evidenced by  the timely filing of his or her written consent to join this collective action.  V.   During the relevant period, Defendant has been subject to the requirements of the  FLSA.    On October 29, 2013, KPMG offered Ms. Meadows employment (See Offer Letter  attached hereto as Exhibit – A).  Among other things, the Offer Letter stated that Ms. Meadows  would be compensated at a rate of $80.00 per hour; that she was a non-exempt employee for  purposes of federal wage-hour law; and that KPMG would deduct and withhold income, social  security and Medicare taxes from her compensation (and presumably, she would receive an IRS  Form W-2 on an annual basis, which she did). Id.    The Offer Letter further stated that “As an employee who will work less than 1,000  hours a year, you will not be eligible for firm provided benefits (unless required by applicable  law). In the event that you work 1,000 hours or more during a calendar year with approval from  your manager, your status may be changed, and you may then become eligible for firm provided  benefits.” Id.    Further, KPMG claimed to employ Ms. Meadows as a “Seasonal, Professional  Level” employee based out of Houston, Texas. However, as noted above, there was nothing  seasonal, sporadic or part-time about Ms. Meadows’ employment.    Ms. Meadows worked for KPMG from November 11, 2013, until September 30,  2016. During this time, she was termed a “Contract Recruiting Manager” (November 11, 2013 –  March 15, 2016), and as “Research Manager” (March 16, 2016 – September 30, 2016).    On average, Ms. Meadows worked between 42 and 44 hours a week, but KPMG  required her to report only 40 of those hours on her timesheet each week.  She was repeatedly,  purposefully and willfully required to underreport her weekly hours worked in violation of the  FLSA, despite knowing full well that her job duties could not be completed within 40 hours a  week.    When Ms. Meadows asked to be paid her overtime wages, KPMG’s management  refused to address the matter.    Admittedly, no FLSA exemption applied to Ms. Meadows’ employment, and  Plaintiff now sues for her unpaid wages.    Thus, as victims of a common and uniformly applied policy that violated the FLSA,  Plaintiff and all other similarly situated non-exempt employees of the Defendant may properly be  joined as a class under 29 U.S.C. § 216(b).    Plaintiff and all other similarly situated employees now sue KPMG, as a class, for  their unpaid overtime wages owed to them under the FLSA.  VI. 