With no explanation, chose the best option from "A", "B", "C" or "D". various call centers demonstrate that Qwest has a national practice of violating the FLSA. The existence of a written policy dictating overtime pay is one factor weighing against conditional certification. West, 2006 WL 1892527, at *9. However, at this early stage of litigation, the mere fact that Qwest has a written policy does not defeat Plaintiffs’ motion in light of Plaintiffs’ countervailing evidence of a centralized policy to not pay overtime. 4. Number of Plaintiff Affidavits Defendants also claim that Plaintiffs have not identified a widespread, common policy in violation of the FLSA. They assert that declarations from 19 individual employees out of a pool of approximately 8,000 individuals, or less than 1%, do not establish a common scheme. Cf. West, 2006 WL 1892527, at *6 (<HOLDING>). Also, Defendants note, Plaintiffs have only

A: holding that employers policy which required employee to work without pay in violation of federal law was unreasonable and employees refusal to comply was not misconduct
B: holding that affidavits from 25 of the potential class did not support the plaintiffs assertion of widespread violations resulting from a common policy or plan where allegation was that individual managers required employees to work offtheclock
C: holding purchase of a policy or multiple policies covering a class of employees offers substantial evidence that a plan has been established
D: holding districtwide class certification not appropriate where the claims were based on oral conversations in which store managers allegedly deviated from company policy
B.