 Defendants treated Plaintiff and all FLSA Plaintiffs similarly in that Plaintiff and  all FLSA Plaintiffs: (1) performed similar tasks, as described in the “Background Facts” section  below; (2) were subject to the same laws and regulations; (3) were paid in the same or similar  manner; (4) were required to work in excess of forty hours in a workweek; and (5) were not paid  the required one and one-half times their respective regular rates of pay for all hours worked per  workweek in excess of forty.    At all relevant times, Defendants are and have been aware of the requirements to  pay Plaintiff and all FLSA Plaintiffs at an amount equal to the rate of one and one-half times their  respective regular rates of pay for all hours worked each workweek above forty, yet they  purposefully and willfully chose and choose not to do so.    Thus, all FLSA Plaintiffs are victims of Defendants’ pervasive practice of willfully  refusing to pay their employees overtime compensation for all hours worked per workweek above  forty, in violation of the FLSA.   In addition, Plaintiff seeks to maintain this action as a class action pursuant to FRCP  23(b)(3), individually, on her own behalf, as well as on behalf of those who are similarly situated  who, during the applicable limitations period, were subjected to violations of the NYLL and the   On August 7, 2013, Kim Celic, SFS Director of Human Resources, hired Plaintiff  to work as a negotiator for one of SFS’s then-affiliated entities “Legal Helpers.”  In early July  2014, Defendant SFS reassigned Plaintiff to Defendant Pioneer, where Plaintiff continued working  as a negotiator until January 2015, with the exception of a four month period when Plaintiff was  on maternity leave from July 29, 2014 through October 2014.    Throughout her time working for Defendants as a negotiator, regardless of the  entity to which Defendants formally assigned her, Plaintiff’s duties consisted of assisting  Defendants’ attorney-employees by speaking with Defendants’ clients and their respective  creditors to communicate offers to settle the clients’ debts.      From the beginning of her employment through January 2015, Defendants required  Plaintiff to work five days a week, from Monday to Friday, for shifts of between nine and eleven  hours per day, with a one hour lunch break.  However, during many days, Defendants did not allow  Plaintiff to take her one-hour lunch break.  Thus, Defendants required that Plaintiff work between  forty-five and fifty hours each week.      For her pay each week, including the week described in the prior paragraph,  Defendants paid Plaintiff a flat salary of $33,500.00 that was meant to cover only her first forty  hours worked per week, and which amounts to a straight-time rate of $16.11 per hour.     Throughout her employment, Defendants paid her nothing for her time worked each  week in excess of forty hours, and thus failed to pay her at one and one-half her regular rate of  pay, or $24.17, for all hours worked over forty each week.    Defendants paid Plaintiff on a semi-monthly basis.    On each occasion when Defendants paid Plaintiff, Defendants intentionally failed  to provide Plaintiff with a wage statement that accurately listed her actual hours worked for that  week and/or her straight and overtime rates of pay for all hours worked.    Defendants also intentionally did not provide Plaintiff with a wage notice at the  time of her hire that accurately contained, inter alia, Plaintiff’s rates of pay as designated by  Defendants.    Defendants treated Plaintiff, FLSA Plaintiffs, and Rule 23 Plaintiffs in the manner  described above.    Each hour that Plaintiff, FLSA Plaintiffs, and Rule 23 Plaintiffs worked was for the  Defendants’ benefit.    Defendants acted in the manner described herein so as to maximize their profits  while minimizing labor costs and overhead.   29 U.S.C. § 207(a) requires employers to compensate their employees at a rate not  less than one and one-half times their regular rate of pay for all hours worked exceeding forty in a  workweek.    As described above, Defendants are employers within the meaning of the FLSA  while Plaintiff and FLSA Plaintiffs are employees within the meaning of the FLSA.    Plaintiff and FLSA Plaintiffs worked in excess of forty hours per week, yet  Defendants failed to compensate Plaintiff and FLSA Plaintiffs in accordance with the FLSA’s  overtime provisions.    Defendants willfully violated the FLSA.    Plaintiff and FLSA Plaintiffs are entitled to overtime pay for all hours worked per  week in excess of forty at the rate of one and one-half times their respective regular rates of pay.    Plaintiff and FLSA Plaintiffs are also entitled to liquidated damages and attorneys’  fees for Defendants’ violation of the FLSA’s overtime provisions.   Plaintiff and Rule 23 Plaintiffs repeat, reiterate and re-allege each and every  allegation set forth above with the same force and effect as if more fully set forth herein.    N.Y. Lab. Law § 160 and 12 NYCCRR § 142-2.2 require employers to compensate  their employees at a rate not less than one and one-half times their regular rates of pay for any  hours worked exceeding forty in a workweek.    Defendants are employers within the meaning of the NYLL and the NYCCRR,  while Plaintiff and Rule 23 Plaintiffs are employees within the meaning of the NYLL and the   Plaintiff and Rule 23 Plaintiffs repeat, reiterate, and re-allege each and every  allegation set forth above with the same force and effect as if more fully set forth herein.    N.Y. Lab. Law § 195(3) requires that employers furnish employees with wage  statements containing accurate, specifically enumerated criteria on each occasion when the  employer pays wages to the employee.    Defendants are employers within the meaning of the NYLL, while Plaintiff and  Rule 23 Plaintiffs are employees within the meaning of the NYLL and the NYCCRR.    As described above, Defendants, on each payday, failed to furnish Plaintiff and  Rule 23 Plaintiffs with accurate wage statements containing the criteria required under the NYLL.    Prior to February 27, 2015, pursuant to N.Y. Lab. Law § 198(1-d), Defendants are  liable to Plaintiff and Rule 23 Plaintiffs in the amount of $100.00 for each workweek that the  violation occurred, up to a statutory cap of $2,500.00.   Failure to Furnish Proper Wage Statements in Violation of the NYLL   Unpaid Overtime under the FLSA   Unpaid Overtime under the NYLL and the NYCCRR  