30.  Plaintiff brings this claim for relief for violation of the FLSA as a collective  action pursuant to Section 16(b) of the FLSA, 29 U.S.C. § 216(b), on behalf of all persons  similarly situated as Hands and/or Operators and/or who were or are employed by  Defendants and who are entitled to payment for all of their overtime wages which  Defendants failed to pay from three years prior to the date of the filing of this lawsuit,  through the time of the trial of this case.   31.  Plaintiff is unable to state the exact number of the class but believes that  the classes membership exceeds 30 persons but is less than 150 persons.  Defendants  can readily identify the members of the classes, who are a certain portion of the current  and former employees of Defendants.   33.  The email addresses of many of the probable FLSA collective action  Plaintiffs are available from Defendants, and notice should be provided to the probable  FLSA collective action Plaintiffs via email to their last known email addresses as soon as  possible.   34.  Oilfield workers are by category not at their residences as frequently as  many other working-class Americans.  As such, they rely on email just as much or more  so than typical wage earners, who themselves live their lives with a growing dependence  upon email as opposed to traditional U.S. Mail.   35.  The proposed FLSA class members are similarly situated in that they have  been subject to uniform practices by Defendants which violated the FLSA, including:  A.  Defendants’ uniform failure to compensate employees pursuant to the  requirements of the FLSA; and  B.  Defendants’ failure to pay members of the class proper overtime  compensation in violation of the FLSA, 29 U.S.C. § 201 et seq.   36.  Plaintiff alleges that Defendants improperly calculated their regular rate of  pay and overtime for Plaintiff and other Hands and Operators employed by Defendants.     V.  37.  Plaintiff repeats and re-alleges all the preceding paragraphs of this Original  Complaint as if fully set forth in this section.   38.  Within the time period relevant to this case, Plaintiff worked for Defendants  as a Hand/Operator.     40.  Plaintiff and other similarly-situated employees were classified as hourly  employees.   41.  Plaintiff and other similarly-situated employees were also paid non- discretionary bonuses on a regular basis.     42.  In addition, Defendants paid Plaintiff and other similarly-situated employees  one-and-one-half of their base hourly rate for each hour they worked over forty (40) in a  workweek.   43.  However, Defendants did not include bonuses of Plaintiff and other  similarly-situated employees into their regular rate when calculating their overtime pay.   44.  Section 778.208 of Title 29 of the Code of Federal Regulations requires that  non-discretionary bonuses “must be totaled in with other earnings to determine the  regular rate on which overtime pay must be based.”    45.  Defendants violated the FLSA by not including bonuses of Plaintiff and other  similarly-situated employees into their regular rate when calculating their overtime pay.   46.  Plaintiff worked for Defendants in various places in Texas and Defendants’  pay practices were the same at all locations.   47.  Defendants knew, or showed reckless disregard for whether, the way they  paid Plaintiff and their other Hands and/or Operators violated the FLSA.    49.  Plaintiff repeats and re-alleges all the preceding paragraphs of this Original  Complaint as if fully set forth in this section.   50.  29 U.S.C. § 207 requires employers to pay employees one and one-half  times the employee’s regular rate for all hours that the employee works in excess of forty  (40) per week.  29 U.S.C.S. § 207 (LEXIS 2013).   51.  Defendants violated Section 778.208 of Title 29 of the Code of Federal  Regulations by not including bonuses of Plaintiff and other similarly-situated employees  into their regular rate when calculating their overtime pay.   52.  Defendants’ conduct and practice, as described above, has been and is  willful, intentional, unreasonable, arbitrary and in bad faith.   53.  By reason of the unlawful acts alleged herein, Defendants are liable to  Plaintiff for, and Plaintiff seeks, unpaid overtime wages, liquidated damages, pre- judgment interest, civil penalties and costs, including reasonable attorney’s fees as  provided by the FLSA.  54.  Plaintiff repeats and re-alleges all the preceding paragraphs of this Original  Complaint as if fully set forth in this section.   56.  Plaintiff brings this action on behalf of themselves individually and all other  similarly situated employees, former and present, who were and/or are affected by  Defendants’ willful and intentional violation of the FLSA.    57.  In the past three years, Defendants have employed dozens of Hands and  Operators.    58.  Like Plaintiff, these Hands and Operators regularly worked more than 40  hours in a week.    59.  Defendants failed to pay these workers at the proper overtime rate.   Because these employees are similarly situated to Plaintiff, and are owed overtime for  the same reasons, the opt-in class is properly defined as:   All  Hourly Paid Hands And/Or Operators Employed  By Defendants Within The Past Three Years.  This Group Includes, but is not necessarily limited to, hourly paid workers  employed in States where Defendants do business.  V. 