20.  Plaintiff files this case as an “opt-in” collective action, as is specifically allowed  by 29 U.S.C. § 216(b).   22.  The specific job titles or job requirements of the various members of the Plaintiff  Class do not prevent collective treatment.   23.  Each non-exempt employee, regardless of job title, job requirements, or rate of  pay, who is denied overtime compensation for hours worked in excess of 40 in one or more  workweek, or who has been subjected to unauthorized wage deductions, is similarly situated to  Plaintiff.   24.  Furthermore, although the amount of damages may vary among individual  employees, there is no detraction from the common nucleus of liability facts.   25.  All current and former non-exempt employees employed by Defendants’ business  establishments, who at any time during the three years prior to the date of filing of this action to  the date of judgment were denied overtime pay for hours worked in excess of forty (40) in any  given workweek may properly be included as members of the Plaintiff Class.   27.  Individuals who opt in to the collective action will be added to the litigation, and  copies of their written consents to join a collective action will be filed with the Honorable Court.  V.  28.  At all times relevant to this action, Defendants’ “enterprise” has been subject to  the requirements of the FLSA.   29.  For purposes of this action, the “relevant period” is the time-period commencing  on the date that is three years prior to the filing of this action, and continuing thereafter until time  of trial.   30.  Defendants’ “enterprise” employed Mr. Ahamed as a travel agent at their business  establishment located in Sugar Land, Texas.   31.  Mr. Ahamed began his employment with Defendants’ “enterprise” on September  1, 2015, and he is currently employed by the Defendants.   32.  At the outset of his employment with the Defendants, Mr. Ahamed was promised  a fixed wage of $3,000.00 per month. Mr. Ahamed continues to earn this sum as his fixed  monthly wage, and such wage has neither increased nor decreased during his employment with  the Defendants. Furthermore, Mr. Ahamed’s job duties as a travel agent have not changed during  his tenure with the Defendants.   33.  Despite being a non-exempt employee, Mr. Ahamed did not receive any overtime  wages in addition to his fixed monthly wage of $3,000.00.   35.  Plaintiff was required to work overtime hours in excess of 40 hours during each  workweek of his employment. Mr. Ahamed typically worked between 45 to 47 hours a week.   36.  Similarly, during at least all or part of the last three years, all non-exempt workers  employed by Defendants’ business establishments were routinely required to work in excess of  40 hours a week to perform the function of their job, which included performance of duties  otherwise typically performed by non-exempt employees because the job required it and  Defendants’ management required it.   37.  Defendants required Plaintiff and all others similarly situated to perform all  necessary work to include the performance of those duties otherwise typically performed by non- exempt employees, which duties routinely required Plaintiff and other similarly situated  employees to work “overtime” hours as defined by 29 U.S.C. § 201, et seq.   38.  Plaintiff and all other similarly situated employees were not paid at the proper  premium hourly rates for the overtime hours they worked each week.   39.  As such, Plaintiff and all other similarly situated non-exempt employees of the  Defendants were together victims of a common policy of the Defendants’ “enterprise”, which  common policy violated the FLSA.   40.  As victims of a common policy that violated the FLSA, Plaintiff and all other  similarly situated non-exempt employees of the Defendants may properly be joined as a class  under 29 U.S.C. § 216(b).   42.  Plaintiff and all other similarly situated employees also sue the Defendants’  “enterprise”, as a class, for all wages withheld or deducted from their pay. Such deductions were  made in violation of Texas law, and they resulted in non-payment of overtime and straight-time  wages.  VI. 