Sablowsky

facts supporting that they were non-exempt employees. “It is the burden of an employer to show entitlement to an exemption from the FLSA.” Baldwin v. Trailer Inns, Inc., 266 F.3d 1104, 1112 (9th Cir. 2001). 2. Plaintiffs have sufficiently alleged that the FLSA violations were willful. See Compl. ¶ 72 (“Defendants have intentionally, willfully, and regularly engaged in a company-wide pol- icy, pattern, or practice of violating the FLSA with respect to the Plaintiffs . . . .”); id. ¶ 73(d) (“[Defendants] willfully fail[ed] to pay the Plaintiffs . . . overtime wages for hours in excess of 40 hours per workweek.”). “At the pleading stage, a plaintiff need not allege willfulness with specificity.” Rivera v. Peri & Sons Farms, Inc., 735 F.3d 892, 902–03 (9th Cir. 2013) (holding

that the plaintiffs “sufficiently alleged willfulness” under the FLSA when they alleged that the defendant’s violations were “deliberate, intentional, and willful”). Whiteside v. Hover-Davis, Inc., 995 F.3d 315, 320–25 (2d Cir. 2021), a decision on which defendants rely, doesn’t reflect the law of this Circuit on pleading willfulness under the FLSA. 3. Plaintiffs’ allegations support that Auto-Chlor System, LLC,…