14. Ramirez was hired by the Company in Victoria, Texas, as an equipment operator.  After working for the Company in Victoria, Texas,  Ramirez  was  transferred  to  San  Antonio,  Texas. Unfortunately, the Company failed to pay Ramirez for all hours worked in both Victoria and San Antonio, Texas, including overtime hours.  Similarly, other hourly employees, including without limitation, equipment operators, surveyors and laborers in both Victoria and San Antonio, Texas, were not paid for all hours worked, including overtime hours sy time-and-one-half their regular rate for all such hours worked. 15. At all times material to their employment, the Plaintiffs regularly worked more than forty (40) hours in a workweek for which they were entitled to be paid overtime compensation at one and one- half (1½) times their regular rate of pay.  29 U.S.C. § 207 (2016).  16. No exemption excuses the Company from paying the Plaintiffs overtime compensation nor has the Company made a good faith effort to comply with the FLSA.  Instead, the Company knowingly, willfully, or with reckless disregard carried out an illegal pattern or practice regarding the manner in which the Plaintiffs were compensated.  18.  Other hourly employees, including equipment operators, surveyors and laborers, both in Victoria and San Antonio, Texas, have been subjected to the Company’s pay practices and policies which are in willful violation of the FLSA.  Further, each member of the Class is or has been paid according to the same payment scheme.  Thus, although the amount of damages may vary from individual to individual, the damages can be calculated by using a single mathematical formula that is individual1y applicable to each Member of the Class.  The Members of the Class are, therefore, similarly situated in terms of pay provisions.  19. The Company’s failure to pay overtime compensation as required by the FLSA results from a generally applicable policy and job requirements that do not depend on the personal circumstances of the Members of the Class.  This generally applicable policy is specifically prohibited by the FLSA.  Thus, the Plaintiffs’ experiences are typical of the experiences of the Members of the Class.  21.  Accordingly, the class of similarly situated Plaintiffs is properly defined as: All current and former hourly employees of the Company, including without limitation, equipment operators, surveyors, and laborers, working in Victoria and San Antonio, Texas, and the surround areas, during the three- year period preceding the filing of this complaint. 22. The Plaintiffs incorporates the allegations contained in paragraphs 1 through 21.  23. The Company’s practice of failing to pay the Plaintiffs and the Members of the Class overtime compensation for overtime hours worked at one and one-half (1½) times their regular rate of pay, was and is in violation of the FLSA.  24.  Accordingly, the Plaintiffs and the Members of the Class are entitled to unpaid overtime compensation in an amount which is one and one-half times (1½) their appropriate regular rate of pay.  26. Finally, the Plaintiffs and the Members of the Class are entitled to reasonable attorneys' fees and costs of this action. 29 U.S.C. Section 216(b)(2016).  Failure to Pay Overtime  Violations of the FLSA 