15.  Work Management, Inc. provides the infrastructure to support the management and  implementation of many of the core standard nuclear performance model processes.  http://www.workmanagementinc.com/services/.    17.  WMI staffed Compton to Exelon’s Colorado Bend 1 Power Plant in Wharton, Texas;  the Southern Company’s Vogtle Power Plant in Waynesboro, Georgia; and Entergy’s Grand Gulf  Nuclear Plant in Port Gibson, Mississippi.    18.  Compton stopped working for WMI in February of 2019.   19.  Compton was a Project Controls Scheduler on behalf of WMI.   20.  Compton would provide online and outage scheduling.    21.  Compton reported the hours she worked to WMI on a regular basis.    22.  WMI did not guarantee Compton a salary.   23.  Compton was paid $58 for every approved hour worked.    24.  Compton’s offer letter listed her overtime rate at $58 per hour.    25.  If Compton worked fewer than 40 hours in a week, she was only paid only for the  hours worked.    26.  But Compton normally worked more than 40 hours in a week.    27.  Compton routinely worked 60 hours a week.    28.  The hours Compton and the Putative Class Members’ work are reflected in WMI’s  records.   29.  WMI paid Compton at the same hourly rate for all hours worked, including those in  excess of 40 in a workweek.     30.  Rather than receiving time and half as required by the FLSA, Compton only received  “straight time” pay for overtime hours worked.     31.  This “straight time for overtime” payment scheme violates the FLSA.   32.  WMI was and is aware of the overtime requirements of the FLSA.     34.  Compton and the Putative Class Members perform job duties in furtherance of the  power industry business sector and are subjected to similar compensation practices.   35.  Compton and the Putative Class Members also worked similar hours and were denied  overtime because of the same illegal pay practice.   36.  Compton and the Putative Class Members regularly worked in excess of 40 hours each  week.   37.  WMI did not pay Compton and the Putative Class Members on a salary basis.   38.  WMI paid Compton and the Putative Class Members “straight time for overtime.”   39.  WMI failed to pay Compton and the Putative Class Members overtime for hours  worked in excess of 40 hours in a single workweek.    40.  WMI knew, or acted with reckless disregard for whether, Compton and the Putative  Class Members were paid on a salary basis or were exempt from the FLSA overtime requirements.    41.  WMI’s failure to pay overtime to these hourly workers was, and is, a willful violation  of the FLSA.    42.  In March of 2019, WMI changed its straight time for overtime pay practice and started  paying overtime.   43.  WMI’s illegal “straight time for overtime” policy extends beyond Compton.   44.  It is the “straight time for overtime” payment plan that is the “policy that is alleged to  violate the FLSA” in this FLSA collective action. Bursell v. Tommy’s Seafood Steakhouse, No. CIV.A. H- 06-0386, 2006 WL 3227334, at *3 (S.D. Tex. Nov. 3, 2006); Wellman v. Grand Isle Shipyard, Inc., No.  CIV.A. 14-831, 2014 WL 5810529, at *5 (E.D. La. Nov. 7, 2014) (certifying “straight time for  overtime” claim for collective treatment).    46.  Any differences in job duties do not detract from the fact that these hourly workers  were entitled to overtime pay.    47.  The workers impacted by WMI’s “straight time for overtime” scheme should be  notified of this action and given the chance to join pursuant to 29 U.S.C. § 216(b).     48.  Therefore, the class is properly defined as:  All employees of Work Management, Inc. who were, at any point in the past 3 years,  paid “straight time for overtime.” (the “Putative Class Members”)  49.  By failing to pay Compton and the Putative Class Members overtime at one-and-one- half times their regular rates, WMI violated the FLSA’s overtime provisions.     50.  WMI owes Compton and the Putative Class Members the difference between the rate  actually paid and the proper overtime rate.    51.  Because WMI knew, or showed reckless disregard for whether its pay practices  violated the FLSA, WMI owes these wages for at least the past three years.    52.  WMI is liable to Compton and the Putative Class Members for an amount equal to all  unpaid overtime wages as liquidated damages.   53.  Compton and the Putative Class Members are entitled to recover all reasonable  attorneys’ fees and costs incurred in this action.   