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First Cause Of Action - Flsa

Decent Essays

FIRST CAUSE OF ACTION - FLSA
73. The Plaintiffs repeat, reallege, and restate each and every paragraph above as if said paragraphs were more fully set forth herein at length.
74. That at all times hereinafter mentioned, Defendants engaged in a widespread pattern and practice of violating the FLSA, as detailed in this Complaint.
75. That at all times hereinafter mentioned, Plaintiff HUDSON was employed by Defendants within the meaning of the FLSA, 29 U.S.C. § 203(e).
76. That at all times hereinafter mentioned, Plaintiff HUDSON was engaged in commerce and the corporate Defendants were enterprises engaged in commerce within the meaning of 29 U.S.C. §§ 206(a) and 207(a).
77. That at all times hereinafter mentioned, Defendants violated the Plaintiff HUDSON’s rights by failing to pay Plaintiff HUDSON the minimum wage for each hour worked in each discrete work week, in violation of the FLSA, 29 U.S.C. § 206(a)(1).
78. Defendants ' failure to pay Plaintiff HUDSON the minimum wage was willful within the meaning of the FLSA, 29 U.S.C. § 255.
79. Defendants are liable to Plaintiff HUDSON for the unpaid minimum wages, plus an additional equal amount as liquidated damages, reasonable attorney 's fees and costs, and any other appropriate relief pursuant to 29 U.S.C. § 216 (b).
SECOND CAUSE OF ACTION - FLSA OVERTIME

80. The Plaintiffs repeat, reallege, and restate each and every paragraph above as if said paragraphs were more fully set forth herein at length.
81. Defendants violated the

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