19.  Powerstroke is an oilfield services company.2    20.  Powerstroke bills itself as an “industry-renowned expert in snubbing and  underbalanced services.”   22.  Lechot and the Day Rate Workers are members of the crews that perform  Powerstroke’s work.    23.  Even if the precise job titles and duties of the Day Rate Workers differ somewhat,  Powerstroke subjected all its Day Rate Workers to the same, illegal, day rate plan.    24.  For example, Powerstroke paid all its Snubbing Supervisors a flat sum for each day  worked, regardless of the number of hours they worked that workweek.    25.  Powerstroke did not pay them with overtime pay for hours worked in excess of 40 in  a workweek.   26.  Lechot has worked for Powerstroke for several years.   27.  Starting in early 2018, Lechot started working for Powerstroke in the United States  (mostly Colorado).    28.  Lechot works primarily on snubbing rigs out in the oilfield.   29.  For days in the field, Lechot is paid $600 a day.    30.  He typically works at least 12 hours on each “field” days.   31.  He also works certain days in Powerstroke’s shops.    32.  For “shop days,” Powerstroke pays Lechot $200 a day.   33.  Although he regularly works 60 or more hours a week, Powerstroke never pays Lechot  any overtime.   34.  In the 2-week period ending June 1, 2019, Lechot worked 10 days (7 in the field, 3 on  the shop).    36.  Instead, Powerstroke paid him the applicable day rate times the number of days he  worked:   37.  Powerstroke paid Lechot additional compensation (such “Wet Pay”), but this  compensation simply increases Lechot’s regular rate and does not offset the overtime he is owed.   38.  The Day Rate Workers worked similar hours and were denied overtime as a result of  the same illegal pay practice.    39.  The Day Rate Workers all worked in excess of 40 hours each week and were often  scheduled for 12+hour shifts for weeks at a time.    40.  Instead of paying them overtime, Powerstroke paid the Day Rate Workers a day-rate.   41.   Powerstroke failed to pay the Day Rate Workers overtime for hours worked in excess  of 40 in a workweek.   47.  Numerous employees have been denied overtime by Powerstroke’s day rate plan.    48.  From his observations and experience at Powerstroke, Lechot is aware that the illegal  practices or policies of Powerstroke have been imposed on the Day Rate Workers.    49.  The Day Rate Workers all received a day rate, regularly worked in excess of 40 hours  per week, and were not paid overtime compensation.    50.  These employees are similarly situated to Lechot in terms of relevant job duties, pay  provisions, and employment practices.   51.  Powerstroke’s failure to pay overtime as required by the FLSA results from a generally  applicable, systematic pay plan that is not dependent on the personal circumstances of the Day Rate  Workers.    52.  Thus, Lechot’s experiences are typical of the experiences of the Day Rate Workers.   53.  The specific job titles or precise job locations of the various Day Rate Workers do not  prevent collective treatment.    54.  All Day Rate Workers, regardless of their precise job requirements or rates of pay, are  entitled to overtime for hours worked in excess of 40 in a week.  