35.  Brousseau Property Management is a real estate property ownership and  management company located in Baton Rouge, Louisiana.   36.  Leja began working for Brousseau Property Management in September  2015.   37.  Leja was employed as doing maintenance work.   38.  At all relevant times, Leja was an hourly employee of Brousseau Property  Management.   39.  At all relevant times, Brousseau Property Management did not pay Leja a  salary.   41.  At all relevant times, Brousseau Property Management paid Leja by the  hour.   42.  At all relevant times, Brousseau Property Management paid Leja $17 or $20  per hour.   43.  Leja reported the hours he worked to Brousseau Property Management on  a regular basis.    44.  Leja’s hours are reflected in Brousseau Property Management’s records.   45.  Brousseau Property Management paid Leja at the same hourly rate for all  hours worked, including those in excess of 40 in a workweek.   46.  Leja normally worked more than 40 hours in a week.   47.  For example, for the two-week period ending July 28, 2018, Leja worked   48.  For that pay period, Brousseau Property Management paid Leja for 52.75  hours at his hourly rate of $20 an hour.   49.  And for the two-week pay period ending October 13, 2018, Leja worked   50.  So for that pay period, Brousseau Property Management paid Leja for 72.75  hours at his hourly rate of $20 an hour.   51.  Thus, rather than receiving time-and-a-half as required by the FLSA, Leja  only received “straight-time” pay for overtime hours worked.   52.75 hours.   52.  This “straight-time-for-overtime” payment scheme violates the FLSA.   54.  Brousseau Property Management nonetheless failed to pay certain hourly  employees, such as Leja, overtime.   55.  Brousseau Property Management’s failure to pay overtime to these hourly  workers was, and is, a willful violation of the FLSA.  72.75 hours.   84.  Leja incorporates all other allegations.   85.  By failing to pay Leja overtime at 1.5 times his regular rates, Brousseau  Property Management violated the FLSA. 29 U.S.C. § 207(a).   86.  Brousseau Property Management owes Leja the difference between the rate  actually paid and the proper overtime rate.   87.  Because Brousseau Property Management knew, or showed reckless  disregard for whether, its pay practices violated the FLSA, Brousseau Property  Management owes these wages for at least the past three years.   88.  Brousseau Property Management also owes Leja an amount equal to the  unpaid overtime wages as liquidated damages.   89.  Leja is entitled to recover all reasonable attorneys’ fees, costs, and expenses  incurred in this action. 