20.  Defendant is in the business of performing general residential construction,  including painting, roofing, tiling, pouring concrete, and other handyman work in southwestern  Louisiana.  Defendant employs several manual laborers at various job sites simultaneously.      21.  Defendant paid Plaintiff by check.   23.  Defendant never paid Plaintiff one-and-half times his hourly rate for all hours  worked in excess of forty in a workweek.   24.  Defendant willfully violated Plaintiff’s rights under the FLSA because Defendant  knew or showed reckless disregard for the fact that his compensation practices violated the FLSA.   Defendant was and is aware of the custom and practice of overtime pay from his experience and  expertise in the industry in which he works.   25.  Defendant paid the named Plaintiff and other similarly situated employees at an  hourly rate for work performed.   26.  Defendant treated the named Plaintiff and other similarly situated employees as  exempt from the FLSA’s overtime requirements.   27.  When the named Plaintiff and other similarly situated employees worked for  Defendant, they were not exempt from the FLSA’s overtime requirement.  28.  Plaintiff incorporates by reference each of the preceding allegations as though fully  set forth herein.   30.  Defendant willfully violated the overtime provisions of the FLSA, 29 U.S.C. §  207(a) by not paying Plaintiff and other similarly situated employees one-and-a-half times their  regular rate for all hours worked in excess of forty in a workweek from at least May 2013 and  continuing until the present.    31.  As a consequence of Defendant’s FLSA violations, Plaintiff and other similarly  situated employees are entitled to recover their unpaid overtime wages, plus an additional amount  in liquidated damages, pursuant to 29 U.S.C. § 216(b).  Fair Labor Standards Act – FLSA Overtime Class  