(FLSA Overtime – Class)   (FLSA Overtime – Individual Plaintiffs)   10.  From approximately December of 2012 until approximately June of 2013,  Plaintiff RONALD LOREDO worked as a landscape maintenance worker for the Defendant.   11.    The Defendant recruited, hired, and employed Plaintiffs and the Class Members  to perform landscaping and maintenance duties in and around Bexar County, Texas, and  surrounding counties.   12.  At all times relevant to this action, Plaintiffs and members of the Class performed  substantially similar work for the Defendant in and around Bexar County, Texas and surrounding  counties.   13.  At all times relevant to this action, the Defendant controlled and supervised the  work performed by the Plaintiffs and members of the Class.   15.   At all times relevant to this action, the Defendant knowingly, willfully, or with  reckless disregard, carried out its illegal pattern or practice of failing to pay the required overtime  compensation due to the Plaintiffs and Class Members.   16.  Defendant did not compensate Plaintiffs and Class Members for compensable  time worked at the beginning and conclusion of their daily shifts.   17.  At all times relevant to this action, the Defendant failed to maintain complete and  accurate records of the Plaintiffs’ hours of work and compensation as required by the FLSA.     18.   In each workweek in which Plaintiffs and Class Members worked in excess of  forty hours, they were not fully paid one-and-a-half times their regular hourly rate for all hours  they worked.  20.  The above-described actions by the Defendant violated the Class Members’  overtime pay rights under the Fair Labor Standards Act, 29 U.S.C. § 201 et seq., for which they  are entitled to relief pursuant to 29 USC § 216(b).  6.   Plaintiffs bring their Claims of Relief (FLSA overtime compensation)  individually, and as a collective action on behalf of all hourly employees who have performed  work as landscape maintenance workers for the Defendant in and around San Antonio, Texas  (the “Class”).   9.  From approximately November of 2012 until approximately June of 2013,  Plaintiff ANTHONY CANTU worked as a landscape maintenance worker for the Defendant.  