Caduceus is an Occupational Medicine Practice with eight locations in  Georgia.  At all relevant times, Caduceus employed, and continues to employ,  “Medical Assistants.”  Caduceus employed Chavis as a “Medical Assistant.”      Chavis regularly worked more than forty (40) hours in a workweek.   Caduceus did not pay Chavis the overtime wage differential required by the  FLSA on the occasions that he worked over forty (40) hours in a workweek.   Chavis worked primarily at Caduceus’ midtown office location, but he also  floated between offices as needed.      Throughout Chavis’ employment with Caduceus, he has not been  customarily or regularly engaged away from Caduceus’ place of business.     Chavis’ job duties did not require the exercise of discretion and independent  judgment with respect to matters of significance.   Chavis did not manage any of Caduceus’ offices.   Throughout Chavis’ employment with Caduceus, he has not customarily or  regularly directed the work of at least two or more other full-time employees or  their equivalent.  Throughout Chavis’ employment with Caduceus, he has not had the  authority to hire or fire any other employee.   Throughout Chavis’ employment with Caduceus, his primary job duty has  not been, and has not included, the performance of office or non-manual work  directly related to the management or general business operations of Caduceus or  Caduceus’s clients or customers.   Throughout Chavis’ employment with Caduceus, his primary job has not  been, and has not included, the performance of work requiring advanced technical  knowledge, defined as work which has been predominately intellectual in character  and which has included work requiring the consistent exercise of discretion and  judgment.   Based upon the duties assigned to Chavis, Caduceus has willfully failed and  refused to pay Chavis one and one half times his regular rate for hours that he has  worked in excess of forty (40) hours per work week.  On or about January 26, 2010, Caduceus terminated Chavis’ employment  after Chavis went out on medical leave on December 30, 2009.  Chavis files this Complaint as a collective action pursuant to Section 16(b)  of the FLSA, 29 U.S.C. § 216(b), on behalf of himself and on behalf of the  Collective Plaintiffs.   At all relevant times Chavis and the Collective Plaintiffs are / were1 similarly situated, have / had substantially similar job requirements and pay  provisions, and are / were subject to Caduceus’ common decisions, policies, plans,  programs, practices, procedures, protocols, routines and rules.   Chavis’ claim / cause of action against Caduceus for willfully failing and  refusing to pay him one and one half times their regular rate for hours that he  worked in excess of forty (40) hours per workweek in violation of the FLSA is  essentially the same as that of the Collective Plaintiffs.   The Collective Plaintiffs’ primary or exclusive duties are / were answering  the phone, taking x-rays, taking vital signs, performing agility tests, and medical  assistant duties.  The Collective Plaintiffs’ primary job is not / was not, and does not / did not  include the exercise of discretion and independent judgment with respect to matters  of significance.   The Collective Plaintiffs do not / did not customarily or regularly direct the  work of at least two or more other full-time employees or their equivalent.     The Collective Plaintiffs do not / did not have the authority to hire or fire  any other employee.   The Collective Plaintiffs do not / did not provide suggestions or  recommendations as to the hiring, firing, advancement, promotion or any other  change of status of any other employee.   The Collective Plaintiffs’ primary job is not / was not, and does not / did not  include the performance of work requiring advanced technical knowledge, defined  as work which has been predominately intellectual in character and which has  included work requiring the consistent exercise of discretion and judgment.   The Collective Plaintiffs’ primary job is not / was not, and does not / did not  include, the performance of work requiring invention, imagination, originality or  talent in a recognized field or artistic or creative endeavor.   Caduceus regularly suffers or permits / regularly suffered or permitted the  Collective Plaintiffs to work in excess of forty (40) hours per work week.   Caduceus has willfully misclassified some Collective Plaintiffs as being  exempt from overtime.     There are at least approximately thirty (30) potential Collective Plaintiffs  (i.e., similarly situated current and former individuals employed by Caduceus with  the title / in the position “Medical Assistant” on or after the date that is three years  prior to the date of the filing of this Complaint).   Each of these potential Collective Plaintiffs would benefit from the issuance  of Notice of this Complaint and the opportunity to opt in / join this Complaint.     The potential Collective Plaintiffs’ names, current or last known telephone  numbers, and current or last known addresses are readily available from Caduceus.   Notice of this Complaint and the opportunity to opt in / join this Complaint  can be provided to all of the potential Collective Plaintiffs via first class mail to  each Collective Plaintiffs’ current or last known address. Chavis realleges and incorporates as if fully set forth herein the allegations  set forth in all of the above paragraphs.   Caduceus regularly suffers or permits / regularly suffered or permitted  Chavis and the Collective Plaintiffs to work in excess of forty (40) hours per work  week.  Caduceus has failed and refused to pay Chavis and the Collective Plaintiffs  one and one half times their regular rate for hours that they worked in excess of  forty (40) hours per work week.     Caduceus has misclassified some Collective Plaintiffs as being exempt from  overtime.     As a result of Caduceus’ violations of the FLSA, Chavis and the Collective  Plaintiffs have suffered damages.  Caduceus’ conduct in refusing to pay Chavis and the Collective Plaintiffs  overtime compensation was a willful violation of the FLSA within the meaning of  29 U.S.C. § 255(a), entitling Chavis and the Collective Plaintiffs to the benefit of  the three-year statute of limitations and unpaid compensation with interest to date  plus liquidated damages all pursuant to 29 U.S.C. §§ 207, 215, 216(b), and 255.   Caduceus’ failure or refusal to pay Chavis and the Collective Plaintiffs the  overtime compensation owed further entitles them to recover attorneys’ fees and  costs of this action pursuant to 29 U.S.C. § 216(b).   