16.  Encompass provides route reconnaissance, survey, map generation, well package  development, title research, and other services for the oil and gas industry. See  http://www.encompassservices.com/   17.  Encompass operates nationwide, with operations in Pennsylvania, Massachusetts,  Texas,  Minnesota,  Colorado,  North  Carolina,  Oklahoma,  Oregon,  and  Maine.  See  http://www.encompassservices.com/contact-us    18.  To offer these services, Encompass employs hundreds of field employees.    19.  Encompass’ field employees’ job duties involve traveling to various job sites each  day, operating oilfield related equipment, performing maintenance and troubleshooting on the  equipment, and other duties required by Encompass.    20.  These employees are paid a salary with job bonuses, day rates, or hourly with  additional compensation.     22.  The employees receiving a salary with job bonuses or day rates receive no overtime  whatsoever.    23.  The employees receiving hourly pay with additional monies do not receive overtime  at the correct rate.    24.  The FLSA, PMWA, and MA Acts require overtime to be paid at one and one half  times the applicable “regular rate” of pay.    25.  Encompass failed to include the additional money paid to hourly employees in  calculating their overtime.    26.  Plaintiff worked for Encompass in the surveying department.    27.  Plaintiff used machetes and chainsaws to clear routes for pipelines.    28.  Plaintiff walked oilfields, pastures, and farmland to assist a team in finding the path  of least resistance during the pre-construction of a pipeline.     29.  Plaintiff logged the location of obstacles, potential pipeline routes, and access points  on maps.    30.  Plaintiff operated surveying equipment.    31.  Plaintiff set up survey markers.    32.  Plaintiff manually operated survey guns.    33.  Plaintiff assembled, maintained, disassembled, and carried survey related equipment.    34.  Plaintiff used his hands and physical strength to clear obstacles from fields that may  influence the pre-construction of pipelines.    35.  Plaintiff worked long and hard hours in the field.    36.  The majority of his work was routine and manual in nature, using hand tools and  carrying heavy equipment.    38.  Beyond being routine and manual in nature, all aspects of Plaintiff’s job was  predetermined for him.    39.  Encompass trains its employees how to operate the required equipment and perform  the job.    40.  Plaintiff was required to comply with Encompass’ strict policies and procedures  governing each issue that arises throughout the job.     41.  No specific degree or background is required to perform Plaintiff’s job; Encompass  provides all the training necessary to perform the job the Encompass way.    42.  Indeed, Plaintiff and all employees like him perform non-exempt job duties under  the FLSA and related state laws.    43.  Plaintiff and individuals like him work well over 40 hours a week; however,  Encompass does not pay its employees overtime properly.    44.  For doing the same or similar job duties, Plaintiff was paid under three different pay  practices.    49.  Encompass pays all of its field employees like Plaintiff under the pay practices  described above.    50.  Regardless of location, Encompass treats these employees the same and denied  proper overtime.    52.  Therefore, Encompass owes back overtime wages to all of their employees like  Plaintiff.     V.  53.  Plaintiff incorporates all previous paragraphs and alleges that the illegal pay practices  Encompass imposed on Plaintiff were similarly imposed on the field personnel employed in  Pennsylvania, Massachusetts, and the rest of the United States.    54.  Over one hundred employees have been victimized by this pattern, practice, and  policy which are in willful violation of the FLSA, PMWA, and the MA Acts.    55.  Numerous other employees who worked with Plaintiff have indicated they were paid  in the same manner, performed similar work, and were not properly compensated properly for all  hours worked as required by federal and state wage laws.    56.  Based on his experiences and tenure with Encompass, Plaintiff is aware that  Defendant’s pay practices or policies have been imposed on the FLSA 216(b) and Rule 23 Class  Members.     57.  The FLSA 216(b) and Rule 23 Class Members all were not afforded overtime  compensation at the correct rates when they worked in excess of forty hours per week.   58.  Defendant’s failure to pay wages and overtime compensation as required by the  FLSA, PMWA, and MA Acts result from generally applicable, systematic policies and practices  which are not dependent on the personal circumstances of the class members.    59.  Plaintiff’s experiences are therefore typical of the experiences of the FLSA 216(b)  and Rule 23 Class Members.   61.  Plaintiff has no interests contrary to, or in conflict with, the FLSA 216(b) and Rule  23 Class Members, as defined herein. Like each member of the proposed classes, Plaintiff has an  interest in obtaining the unpaid overtime wages owed under federal and state wage laws.   62.  A hybrid class and collective action, such as the instant one, is superior to other  available means for fair and efficient adjudication of the lawsuit.    63.  Absent this action, many FLSA 216(b) and Rule 23 Class Members likely will not  obtain redress of their injuries and Encompass will reap the unjust benefits of violating the  applicable federal and state wage laws.   64.  Furthermore, even if some of the FLSA 216(b) and Rule 23 Class Members could  afford individual litigation against Encompass, it would be unduly burdensome to the judicial  system.    65.  Concentrating the litigation in one forum will promote judicial economy and parity  among the claims of individual members of the classes and provide for judicial consistency.   67.  Plaintiff’s claims are typical of the FLSA 216(b) and Rule 23 Class Members’ claims.  Plaintiff and the FLSA 216(b) and Rule 23 Class Members have sustained damages arising out of  Encompass’ illegal and uniform employment policies.    68.  Plaintiff knows of no difficulty that will be encountered in the management of this  litigation that would preclude its ability to go forward as a class or collective action.   69.  Although the issue of damages may be somewhat individual in character, there is no  detraction from the common nucleus of liability facts. Therefore, this issue does not preclude  collective and class action treatment.  VI. 