[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )

COMPLAINT FOR WAGE AND HOUR VIOLATIONS

1. Parties

1.1 Plaintiff [PLAINTIFF NAME] is a former employee of Defendant.
1.2 Defendant [DEFENDANT NAME] is an employer engaged in commerce with [NUMBER] employees.

2. Jurisdiction and Venue

2.1 This Court has jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because Plaintiff worked here and the violations occurred here.

3. Factual Allegations

3.1 Plaintiff worked as [JOB TITLE] from [DATE] to [DATE].
3.2 Plaintiff regularly worked over [40] hours per week and was not paid overtime.
3.3 Defendant failed to pay minimum wages and/or failed to provide meal and rest breaks as required by law.

4. Cause of Action - Overtime and Minimum Wage (FLSA)

4.1 Plaintiff realleges the foregoing paragraphs.
4.2 Defendant violated the FLSA by failing to pay overtime and minimum wages.

5. Cause of Action - State Wage Law (Optional)

5.1 Defendant violated [STATE WAGE STATUTE] by failing to pay wages, provide statements, or reimburse expenses.

6. Collective/Class Allegations (Optional)

6.1 Plaintiff brings this action on behalf of similarly situated employees.
6.2 The putative class or collective includes [DESCRIPTION].

7. Damages

7.1 Plaintiff seeks unpaid wages, overtime, liquidated damages, statutory penalties, interest, and attorney fees.

8. Prayer for Relief

Plaintiff requests judgment against Defendant as follows:
a. Unpaid wages and overtime.
b. Liquidated damages and penalties.
c. Attorney fees and costs.
d. Declaratory and injunctive relief where permitted.
e. Any other relief the Court deems just.

9. Jury Demand

Plaintiff demands a trial by jury on all issues so triable.

10. Signature Block

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff