(Plaintiff’s individual claim for unpaid wages   In violation of the Texas Labor Code, Chapter 61)   (Unpaid overtime compensation under the FLSA)   18.  Plaintiff JUAN VANZZINI files this case as an “opt in” collective action, as it is  specifically allowed by 29 U.S.C. § 216(b).   23.  At all times relevant to this action, Defendant has been subject to the requirements of  the Fair Labor Standards Act 29 U.S.C. 201 et.seq.   24.  For purposes of this action, the “relevant period” is defined as such period  commencing on the date that is three years prior to the filing of this action, and continuing thereafter.   25.  Defendants employed Plaintiff  JUAN VANZZINI  from June, 2005 until  December,,  2010 at various locations of Defendant’s facilities in Houston, Texas.    26.  During the period of employment that, Plaintiff worked for Defendant, Plaintiff was  classified as a “Puller”.   46.  Each and every allegation contained in the foregoing paragraph is re-alleged as if fully  written herein.    47.  Other employees have been victimized by this pattern, practice, and policy of the  Defendants that is in violation of the FLSA.    48.  Thus, from personal knowledge, Plaintiff is aware that the illegal practices and policies  of Defendants have been imposed on other workers.    49.  Other, similarly situated employees are being denied their lawful wages.   50.  Accordingly, each Defendant’s pattern and practice of failing to pay the overtime pay  (at time and one-half) of employees as required by the FLSA results from the Defendants’ general  application of policies and practices, and does not depend on the personal circumstances of the  members class.    51.  Plaintiff  JUAN VANZZINI’S  experience is typical of the experience of the member’s  class as it pertains to compensation.    52.  The specific job titles or job requirements of the various members of the class do not  prevent collective treatment.    53.  All employees, regardless of their job requirements or rates of pay, who are denied  overtime compensation for hour worked in excess of 40 per week, are similarly situated.    56.  Each and every allegation contained in the foregoing paragraph is re-alleged as if fully  written herein.    57.  By withholding Plaintiff   JUAN VANZZINI’S overtime wages earned during the  period of his employment until the present, Defendant’s have violated the Texas Labor Code, Chapter  61, et seq., which specifically requires the employer to pay its employees all of their wages earned.    58.  Plaintiff therefore sues for his unpaid wages and all additional damages allowed under  the Texas Labor Code, Chapter 61, and et seq. 