16.  HukariAscendent is a technical consulting and engineering company specializing in  engineering and technical services associated with the nuclear industry and power generation facilities.1   17.  McClure was an hourly employee of HukariAscendent.     18.  McClure was hired around November 2016.    19.  McClure left HukariAscendent’s employment near the end of February 2017.   20.  HukariAscendent paid McClure by the hour.   21.  HukariAscendent paid McClure $70 per hour.   22.  McClure reported the hours he worked to HukariAscendent on a regular basis.    23.  If McClure worked fewer than 40 hours in a week, would be paid only for the hours  he worked.  1 www.hukari.com/about-us/  Case: 1:18-cv-00873-SJD-SKB Doc #: 1 Filed: 12/11/18 Page: 3 of 9  PAGEID #: 3 4   24.  But McClure normally worked more than 40 hours in a week.    25.  The hours McClure worked are reflected in HukariAscendent’s records.   26.  HukariAscendent paid McClure at the same hourly rate for all hours worked, including  those in excess of 40 in a workweek.     27.  Rather than receiving time and half as required by the FLSA, McClure did not receive  any pay for overtime hours worked.     28.  This payment scheme violates the FLSA.   29.  HukariAscendent was aware of the overtime requirements of the FLSA.     30.  HukariAscendent nonetheless failed to pay certain hourly employees, such as McClure,  overtime.     31.  HukariAscendent’s failure to pay overtime to these hourly workers was, and is, a willful  violation of the FLSA.  