16.  Defendants own several convenience stores under a 7-Eleven® franchise and  license in Tarrant, Denton, and Dallas Counties.  Defendants are well aware of the FLSA’s  requirements.    17.  During the relevant time period, the Cashiers and the Members of the Class  worked or work on average over forty (40) hours per week.     40.  Section 7(a)(1) of FLSA, 29 U.S.C. § 207(a), provides:  “[N]o employer shall employ any of his employees who in any workweek  is engaged in commerce or in the production of goods for commerce, or is  employed in an enterprise engaged in commerce or in the production of  goods for commerce, for a workweek longer than forty hours unless such  employee receives compensation for his employment in excess of the hours  above specified at a rate not less than one and one-half times the regular  rate at which he is employed.”   41.  During the relevant period, Plaintiffs regularly worked more than forty hours in a  workweek.  They were entitled to be paid overtime compensation as provided under Section 7(a)  of the FLSA, 29 U.S.C § 207(a), for all hours worked in excess of forty hours in a workweek.   42.  No exemption excused Defendants from paying Plaintiffs overtime compensation  and Defendants have not made a good faith effort to comply with the FLSA.  Defendants instead  knowingly, willfully, or with reckless disregard carried out an illegal pattern or practice regarding  the amounts Plaintiffs were paid.  Defendants’ failure to pay Plaintiffs for all overtime worked is  and was a clear violation of the FLSA.  43.  The Members of the Class had similar schedules and responsibilities as Plaintiffs.   The Members of the Class were subjected to the same pay practices and policies as the Plaintiffs.   The Members of the Class are similarly situated cashiers.   44.  Although the amount of damages may vary from individual to individual, the  damages can be calculated by using a single mathematical formula that is individually applicable  to each Member of the Class.  The Members of the Class are similarly situated in terms of pay  provisions.   46.  No justification exists for Defendants’ failure to pay the Members of the Class for  all hours worked.  Likewise, no exemption exists to excuse Defendants’ failure to pay overtime  pay for all hours worked over forty (40) hours per workweek.  Defendants have not made a good  faith effort to comply with the FLSA with respect to the Members of the Class.  The Members of  the Class are not independent contractors.  Instead, Defendants knowingly, willfully, with intent  or with reckless disregard carried out an illegal pattern or practice regarding the amount the  Members of the Class were paid.  Defendants’ failure to pay the Members of the Class for all  overtime worked is and was a clear, willful, and intentional violation of the FLSA.   47.  Plaintiffs and the Members of the Class have consistently worked more than forty  (40) hours in most workweeks.   48.  Plaintiffs and the Members of the Class have not been paid for overtime at one  and one-half times the regular rate of pay for hours worked in excess of forty (40) hours in most  workweeks since at least summer of 2014.   49.  Plaintiffs and the Members of the Class are entitled to payment of overtime at the  rate of an additional one and one-half times their regular rate of pay for the time period of  approximately early 2014 to the present.   51.  Defendants have violated Section 207 of the FLSA, 29 U.S.C. § 207  by failing to  pay the Plaintiffs, and the Members of the Class, overtime compensation required by the FLSA in  workweeks in which they worked in excess of forty (40) hours.   52.  Defendants’ violations have been willful.   53.  There are questions of law and fact common to the class/collective.   54.  The claims or defenses of the representatives, Plaintiffs Foote and McCall, are  typical of the claims or defenses of the class/collective.   55.  The representatives, Plaintiffs Foote and McCall, will fairly and adequately  protect the interests of the class/collective.   56.  Prosecuting this case as a class/collective action for similarly situated employees  who have been unlawfully denied overtime wages will promote judicial efficiency and will best  protect the interest of the class/collective members.   57.  There are no conflicts of interest among the class/collective members.  58.  Plaintiffs incorporate the allegations in the preceding paragraphs as if fully set  forth in their entirety.   60.  Plaintiffs and the Members of the Class are therefore entitled to their unpaid  wages at one and one-half times their regular pay for all hours worked in excess of forty hours in  a workweek.   61.  Plaintiffs and the Members of the Class are entitled to an additional amount equal  to all of their unpaid overtime compensation as liquidated damages.   62.  Plaintiffs and the Members of the Class also are entitled to reasonable attorneys’  fees, costs and expenses, and pre- and post-judgment interest.  See 29 U.S.C. § 216(b).  FAILURE TO PAY OVERTIME (COLLECTIVE ACTION)  