18.  Ensign U.S. Drilling (SW), Inc. (“Ensign”) provides drilling operations and rig  management for the oil and gas industry throughout the State of Texas, the United States, and Canada.3   19.  To provide their services, Ensign employed (and continues to employ) numerous  oilfield workers who were paid a day rate and no overtime— including Plaintiff Ortiz and the  individuals that make up the putative or potential class.   20.  While exact job titles may differ, these workers were subjected to the same or similar  illegal pay practices for similar work in the oilfield.   21.  Plaintiff Ortiz was employed by Ensign as a Rig Manager, working on Ensign’s client’s  drilling pads located between Kenedy, Texas and Midland, Texas, from approximately 2012 until June  2019.    22.  Plaintiff and the Putative Class Members were paid a day rate but no overtime.   23.  Specifically, Plaintiff Ortiz was paid a day rate of $636.00 per day but did not receive  overtime compensation at the required rate of time-and-one-half for all hours worked over forty (40)  each week.   24.  Although it is well-known that blue-collar oilfield workers like Plaintiff and the  Putative Class Members are not exempt from overtime, Ensign did not pay Plaintiff and the Putative  Class Members the additional overtime premium required by the FLSA for hours worked in excess of  forty (40) in a workweek.   26.  Specifically, Plaintiff and the Putative Class Members’ primary job duties were to  perform oilfield drilling operations, conduct drilling operations in a safe manner to ensure jobsite  safety compliance, to point out any variances between the work performed and the plans and  specifications to the work crew in the first instance, to note the progress of the drilling project to  report to the drilling site owner and/or company contractor, and to report any variances in the work  being performed and the plans and specifications to the drill site owner and/or the drill site contractor.    27.  Plaintiff and the Putative Class Members would conduct their day-to-day activities  within designed parameters and in accordance with pre-determined operational plans coordinated by  Ensign and/or their clients.   28.  Plaintiff and the Putative Class Members did not prepare the plans and specifications  for the drilling operations coordinated by Ensign and/or their clients.    29.  Plaintiff and the Putative Class Members did not have the authority to change or  authorize changes to the pre-determined plans and specifications provided by the well site owner(s)  and/or drill site contractor(s).    30.  Plaintiff and the Putative Class Members’ daily and weekly activities were routine and  largely governed by standardized plans and procedures set by Ensign and/or their clients, the  American Petroleum Institute, the American Society of Mechanical Engineers, the American Welding  Society, and the United States Department of Transportation. See 29 C.F.R. § 541.203(g).    32.  In fact, Plaintiff and the Putative Class Members were prohibited from varying their  job duties outside of these predetermined parameters.    33.  Moreover, Plaintiff and the Putative Class Members’ job functions were primarily  routine and manual labor in nature, requiring little to no official training, much less a college education  or other advanced degree.   34.  Indeed, Plaintiff and the Putative Class Members rely on their hands, physical skills,  and energy to perform manual and routine labor in the oilfield.    35.  Plaintiff and the Putative Class Members worked long hours.    36.  Specifically, Ensign regularly scheduled Plaintiff and the Putative Class Members for  a minimum of twelve (12) hours per day and they regularly worked a minimum of 84 hours per week.   37.  The FLSA mandates that overtime be paid at one and one-half times an employee’s  regular rate of pay for all hours worked over 40 each week.    38.  Plaintiff and the Putative Class Members are non-exempt employees under the FLSA.    39.  Pursuant to 29 C.F.R. § 541.602(a), an employee will be considered to be paid on a  “salary basis” if the employee regularly receives each pay period on a weekly, or less frequent basis, a  predetermined amount constituting all or part of the employee’s compensation, which amount is not  subject to reduction because of variations in the quality or quantity of the work performed.   40.  Plaintiff and Putative Class Members were paid based on the number of days worked.   41.  Accordingly, Plaintiff and Putative Class Members only knew the amount of their pay  after the number of days they worked each week.    42.  Plaintiff and the Putative Class Members regularly worked in excess of forty (40) hours  per week but never received overtime compensation.    44.  Ensign applied this pay practice despite clear and controlling law that states that the  routine and manual labor duties which were performed by Plaintiff and the Putative Class Members  consisted of non-exempt work.   45.  Accordingly, Ensign’s pay policies and practices blatantly violated (and continue to  violate) the FLSA.  V.  46.  All previous paragraphs are incorporated as though fully set forth herein.   47.  The FLSA Collective is defined as:  66.  Pursuant to 29 U.S.C. § 216(b), this is a collective action filed on behalf of all those  who are (or were) similarly situated to Plaintiff.   67.  Other similarly situated employees have been victimized by Defendant’s patterns,  practices, and policies, which are in willful violation of the FLSA.   68.  The FLSA Collective Members are defined in Paragraph 47.   69.   Defendant’s systematic failure to timely pay overtime compensation at the rates  required by the FLSA results from generally applicable policies and practices and does not depend on  the personal circumstances of Plaintiff.   71.  The specific job titles or precise job requirements of the various FLSA Collective  Members does not prevent collective treatment.   72.  All of the FLSA Collective Members—regardless of their specific job titles, precise job  requirements, rates of pay, or job locations—are entitled to be timely and properly compensated for  all hours worked in excess of forty (40) hours per workweek.   73.  Although the issues of damages may be individual in character, there is no detraction  from the common nucleus of liability facts. Indeed, the FLSA Collective Members are non-exempt  workers entitled to be paid the proper amount of overtime compensation for all hours worked over  forty (40) each week.   74.   Defendant has employed (and continue to employ) numerous Rig Managers during  the past three years.   75.  Absent a collective action, many members of the proposed FLSA class will not likely  obtain redress of their injuries and Defendant will retain the proceeds of their rampant violations.    76.  Moreover, individual litigation would be unduly burdensome to the judicial system.  Concentrating the litigation in one forum will promote judicial economy and parity among the claims  of the individual members of the classes and provide for judicial consistency.    77.  Accordingly, the FLSA collective of similarly situated plaintiffs should be certified as  defined in Paragraph 47 and notice should be promptly sent.   78.   Defendant can readily identify the members of the class, who are a certain portion of  the current and former employees of Defendant.    80.  The email addresses or cell phone numbers of many of the putative FLSA Collective  Members are available from Defendant, and notice should be provided to the putative FLSA  Collective Members via email and text message to their last known email addresses/cell phone.    81.  Oilfield workers are by category not at their residences as frequently as many other  working-class Americans.    82.  As such, they rely on email or cell phone just as much or more so than typical wage  earners, who themselves live their lives with a growing dependence upon email and text messaging as  opposed to traditional U.S. Mail.   VI.  A.  FLSA COVERAGE  