28. Plaintiffs and similarly situated employees work or worked for Defendants as general  laborers during the applicable statutory period.   30. Defendants compensated Plaintiffs and similarly situated employees for their work on an  hourly basis.   31. Defendants suffered and permitted Plaintiffs and similarly situated employees to work  more than forty (40) hours per workweek.   32. Defendants have a common policy of not paying Plaintiffs and similarly situated  employees at a rate of one and one-half (1.5) times their regular pay for the overtime hours  they worked as required by the FLSA.   33. In calculating Plaintiffs and similarly situated employees, Defendants only paid them their  regular rate (i.e., straight time rate), rather than the legally required one and one-half (1.5)  times their regular rate of pay for hours in excess of forty (40) per workweek.   34. Defendants willfully operated under a common scheme to deprive Plaintiffs and similarly  situated employees of overtime compensation by paying them less than what is required  under federal law.    35. As a commercial and residential construction company that has been in existence for close  to ten (10) years, Defendants were or should have been aware that Plaintiffs and similarly  situated employees performed work that required proper payment of overtime  compensation.   36. Defendants knew that Plaintiffs and similarly situated employees worked overtime hours  without receiving proper overtime pay because Defendants maintained and recorded the  hours worked by Plaintiffs and similarly situated employees.     38. Plaintiffs bring Counts I on behalf of themselves and all similarly situated individuals.  The  proposed collective class (“Class Members”) is identified as follows:  All general laborers  who worked for K & E Resources, LLC within the last three years.   39. Plaintiffs consent in writing to assert their claims for unpaid wages under the FLSA  pursuant to 29 U.S.C. § 216(b).  Plaintiffs’ signed consent forms are filed with the Court  as Exhibit 1 and Exhibit 2 to this Complaint.   40. As the case proceeds, it is likely that other individuals will file consent forms and join as  “opt-in” plaintiffs.   41. Members of the proposed Class Members are known to Defendants and are readily  identifiable through Defendants’ records.   42. Plaintiffs and the Class Members are all victims of Defendants’ widespread, repeated,  systematic, and consistent illegal policies that have resulted in willful violations of their  rights under the FLSA, 29 U.S.C. § 201, et seq., and that have cause significant damage to  Plaintiffs and the Class Members.    43. The Class Members would benefit from the issuance of court-supervised notice of this  lawsuit and an opportunity to join by filing their written consent.  44. Plaintiffs realleges and incorporates by reference the above paragraphs as if fully set forth  herein.   46. The FLSA, 29 U.S.C. § 207, requires covered employers like Defendants to pay non- exempt employees like Plaintiffs and the Class Members no less than one and one-half  (1.5) times their regular rate of pay for all hours worked in excess of forty (40) in a  workweek.   47. Plaintiffs and the Class Members regularly worked more than forty (40) hours per week  for Defendants, but Defendants did not properly compensate them for all of their overtime  hours as required by the FLSA.   48. Defendants have not made a good-faith effort to comply with the FLSA as it relates to the  compensation of Plaintiffs and the Class Members.   49. Defendants knew Plaintiffs and the Class Members worked overtime without proper  compensation, and it willfully failed and refused to pay Plaintiffs and the Class Members  wages at the required overtime rate pursuant to 29 U.S.C. § 225.   50. Defendants’ willful failure and refusal to pay Plaintiffs and the Class Members overtime  wages for time worked violates the FLSA, 29 U.S.C. § 207.   51. As a direct and proximate result of Defendants’ unlawful conduct, Plaintiffs and the Class  Members have suffered and will continue to suffer a loss of income and other damages.   Plaintiffs and the Class Members are entitled to liquidated damages and attorney’s fees and  costs incurred in connection with this claim. 