22.  Each and every allegation contained in the foregoing paragraphs is re-alleged as  if fully rewritten herein.   24.  The Named Plaintiffs and FLSA Collective Plaintiffs are similarly situated in  that they had, and have, substantially similar job requirements and pay provisions during the  statutory period, and were, and are, subjected to Defendant Versacom’s common practices as  more fully described herein, of unlawfully refusing, through various practices and policies, to  pay them all straight time and overtime pay to which they were and are entitled, in violation of  27.  Each and every allegation contained in the foregoing paragraphs is re-alleged as  if fully rewritten herein.   28.  Plaintiffs bring this action on their own behalf, as well as on behalf of each and  all other persons similarly situated, and thus, seek class certification under FRCP 23.   30.  The class that Plaintiffs seek to represent may be described as follows:  Class 1 –All current and former non-exempt employees of Versacom  who worked as a “Field Wireless Technician” or similar position  however titled and whom Versacom failed to properly compensate  for all hours worked and/or failed to compensate for overtime work  performed in excess of forty-hours (40) per work week.   31.  Plaintiffs seek to represent only those members of the above described group  “Class 1” who, after appropriate notice of their ability to opt-in to this action, have provided  consent in writing to be represented by Plaintiff’s counsel as required by 29 U.S.C. § 216(b).   32.  Those persons who choose to opt-in (hereinafter referred to as “Class  Members”) will be listed on subsequent pleadings.  Copies of their written consents to sue and  opt-in will be filed with the Court.   34.  Plaintiffs incorporate all allegations contained in the foregoing paragraphs.   35.  Defendants' practice of failing to pay Plaintiffs time-and-a-half rate for hours in  excess of forty (40) per workweek violates the FLSA. 29 U.S.C. § 207.   36.  Specifically, Defendants violated overtime rules by entering into agreements  with Plaintiffs and other Field Wireless Technicians to pay an “all inclusive” flat daily rate and  then forbidding these employees to record and/or request overtime payment.  Consequently,  the Plaintiffs are entitled to time and a half for all hours worked over forty in the past three  years.   37.  Each and every allegation contained in the foregoing paragraphs is re-alleged as  if fully rewritten herein.   37.  None of the exemptions provided by the FLSA regulating the duty of  employers to pay overtime at a rate not less than one and one-half times the regular rate at  which its employees are employed are applicable to the Defendants or the Plaintiffs.  VI.  39.  At all times relevant to this action, Defendants have been subject to the  requirements of the FLSA.    40.  Defendant Versacom employed Plaintiff Tommy Nguyen from 2007 to 2013.   41.  Defendant Versacom employed Plaintiff Paulus Niekdam in 2012.   42.  Defendant Versacom employed Plaintiff Loc Tran from on or about 2007 to  2013.   43.  Plaintiffs worked for Defendant Versacom as a Field Wireless Technician and  received a weekly salary based on an “all inclusive” daily or site wage intended to cover a sixty  (60) – seventy-two (72) hour, six-day (6) workweek.   44.  As Field Wireless Technicians, Plaintiffs performed, during a significant period  of most days, what was or is otherwise work performed by “hourly” or non-exempt employees  due to the requirements of the position and the demands of Defendant Versacom’s management.   45.  Throughout the course of their employment, Plaintiffs have been required to  work overtime hours in excess of forty (40) hours per each seven-day (7) workweek.   46.  Defendants operate a privately held information technology and services  company which offers industry certified technicians who provide onsite support for new  technology initiatives, telecom network testing, and network repair & maintenance to customers  throughout the United States.   48.  Each and every allegation contained in the foregoing paragraphs is re-alleged as  if fully rewritten herein.   49.  Defendants' practice of failing to pay Plaintiffs at the required minimum wage  rate violates the FLSA. See, 29 U.S.C. § 206.   50.  Specifically, because the Defendants failed to pay Plaintiffs and other Field  Wireless Technicians for work performed in certain workweeks, Defendants failed to pay  Plaintiffs and other Field Wireless Technicians the federally mandated minimum wage in  those weeks.  Consequently, the Plaintiffs are entitled to recover the federally mandated  minimum wage rate for all hours worked and not paid in the past three years.  