22.  Plaintiff seeks conditional certification of this case as a collective action under        29 U.S.C. § 216(b). See also, Mooney v. Aramco Servs. Co., 54 F.3d 1207 (5th Cir. 1995).  The  “similarly situated” standard at the initial conditional certification stage is lenient, plaintiff’s  burden is not heavy, the evidence needed is minimal and the existence of some variations between  potential claimants is not determinative of lack of similarity. Prejean v. O’Brien’s Response  Mgmt., 2013 U.S. Dist. LEXIS 158948 *15.   24.  As such, class certification is appropriate for all gas station / convenience store  clerks of the Defendants, in that the Defendants controlled and operated the gas station and  convenience store businesses where Members of the Plaintiff Class (including Plaintiff Ali) were  employed during the relevant period.   25.  Plaintiff seeks notice to issue to all non-exempt employees of the Defendants who  together were victims of Defendants’ widespread and identical violations of the FLSA.   26.  Plaintiff worked overtime hours for which he received straight-time pay.   27.  Defendants’ wide-spread policy and practice violated the FLSA because it allows  the Defendants not to pay their employees’ overtime hours at the required premium overtime pay  rate at time-and-one-half of the employee’s base hourly rate. See 29 U.S.C. §207(a)(1).   28.  By failing to document the overtime pay owed to Plaintiff and to Members of the  Plaintiff Class, the Defendants also committed repeated and willful violations of the recordkeeping  requirements of the FLSA. See, 29 U.S.C. §211(c); 29 C.F.R. §516. 29; and C.F.R. §516.27.   29.  During the class period, the Defendants owned, controlled and operated the  aforementioned businesses, and they set this pay policy shared by all such businesses.   30.  The common policy of paying straight-time wages for overtime hours worked by  employees is prima facie evidence of “some identifiable facts or legal nexus [that] bind the claims  so that hearing the cases together promotes judicial efficiency.” McKnight v. D. Hous., Inc., 756  F. Supp. 2d 794, 801 (S.D. Tex. 2010) (Rosenthal, J.).   32.  Plaintiff’s experience was typical of the experiences of Members of the Plaintiff  Class as it pertains to unpaid overtime; and, the specific job titles or job requirements of the various  members of the Plaintiff Class do not prevent collective treatment because of said legal nexus  binding them together as a class.   33.  Further, although the amount of damages may vary among Members of the Plaintiff  Class, there is no detraction from the common nucleus of liability facts that render this matter  appropriate as a collective action under 29 U.S.C. § 216(b).   34.  All current and former non-exempt employees, regardless of job title, job  requirements, or rate of pay, to whom the Defendants denied overtime compensation for hours  worked in excess of 40 in one or more workweek, are similarly situated to Plaintiff, and are thus  appropriate members of the Plaintiff Class.   35.  All current and former non-exempt employees employed by business  establishments that the Defendants owned / controlled, who at any time during the three years prior  to the date of filing of this action to the date of judgment were denied overtime compensation in  any given workweek may properly be included as members of the Plaintiff Class.   36.  Thus, the class Plaintiff seeks to represent is comprised of all store clerks (a) who  were paid at a straight-time rate for hours worked in excess of forty in any workweek during the  relevant period and (b) who worked or currently work at any gasoline station and/or convenience  store owned individually or jointly and/or managed now or in the past by Defendants Muhammad  Muzaffar Ahmed, Muhammad Laique Ahmed and / or Muhammad F. Ahmed, or by any legal  entity in which one or more Defendant has an ownership interest.   38.  Defendants employed Mr. Ali as a store clerk at their gasoline station and  convenience store from November 1, 2016, until December 9, 2017.   39.  During his employment, Mr. Ali worked overtime hours.   40.  At the time Plaintiff Ali was hired, Defendants informed him that his pay rate would  be $10.00 per hour, and that Plaintiff would not receive any overtime pay.   41.  Mr. Ali in fact received no overtime pay for the overtime hours he worked on a  weekly basis, and he now sues for these unpaid wages.   42.  Mr. Ali performed duties that included operating the cash register, assisting  customers with gasoline and other purchases from the convenience store, and upkeep and cleaning  of the premises.   43.  As determined by the Defendants at the outset of Mr. Ali’s employment, he  received no overtime wages despite working well in excess of 40 hours a week.   44.  Similarly, all Members of the Plaintiff Class that seek to be a part of this collective  action received no overtime wages because Defendants have a wide-spread policy of paying  straight-time wages for overtime worked.   45.  The Defendants together controlled Plaintiff Ali’s terms and conditions of  employment, including decisions relating to payment of some but not all wages due (i.e., non- payment of overtime wages), Mr. Ali’s hourly pay rate, and the number of hours Mr. Ali worked  during each workweek.   47.  Each and every allegation contained in the foregoing paragraphs is re-alleged as if  fully rewritten herein.   48.  Defendants’ practice of failing to pay Plaintiff time-and-a-half rate for hours in  excess of forty (40) per workweek violates the FLSA.  29 U.S.C. § 207.   49.  Plaintiff and Members of the Plaintiff Class are non-exempt employees – that is,  these individuals are entitled to receive overtime wages under the FLSA for all hours they have  worked in excess of 40 during each seven-day workweek.   50.  During their employment with the Defendants, Plaintiff Ali and Members of the  Plaintiff Class worked overtime hours on a weekly basis at the request of their employer.   51.  Defendants informed Plaintiff and Members of the Plaintiff Class that no overtime  would be paid despite being required to work overtime hours on a weekly basis.   52.  Plaintiff and Members of the Plaintiff Class received no overtime wages resulting  from Defendants’ policy of paying straight-time for overtime hours worked.   53.  Because Defendants have a wide-spread policy and practice of not paying  employees’ overtime, Defendants and the businesses they controlled committed repeated and  willful violations of 29 U.S.C. § 201, et seq.   54.  As such, Plaintiff and Members of the Plaintiff Class sue for their unpaid overtime  wages falling within the three-year period preceding the filing of this civil action, and continuing  thereafter until time of jury verdict and judgment.   56.  Further, Plaintiff and Members of the Plaintiff Class seek attorney’s fees and costs  for bringing this action pursuant to the FLSA.  29 U.S.C. §216(b) states that “[t]he court in such  action shall, in addition to any judgment awarded to the plaintiff or plaintiffs, allow a reasonable  attorney’s fee to be paid by the defendant, and costs of the action.”   57.  Plaintiff and Members of the Plaintiff Class seek post-judgment interest at the  highest rate allowed by law, assessed upon all damages, including attorney’s fees and costs.  Violation of the FLSA –  Failure to pay overtime wages to Plaintiff and all others similarly situated  