10.  FPR offers contract staffing for all facets of the energy industry; specializing in field  personnel for exploration, appraisal and development drilling activities on US land.   11.  FPR’s gross revenues exceeded $1,000,000 in 2014.    12.  FPR’s gross revenues exceeded $1,000,000 in 2015.    13.  FPR’s gross revenues exceeded $1,000,000 in 2016.    14.  Since at least 2014, FPR has employed at least 2 employees who handle, sell, or  otherwise work on goods or materials, such as tools, phones, computers, pens, and/or hard hats, that  have moved in, or were produced for, commerce.    15.  Since at least 2014, FPR has been an enterprise covered by the FLSA.   16.  FPR is an employer of the personnel it provides to its clients.    17.  FPR retains the right to terminate its personnel’s employment.   18.  FPR’s clients often provide pay rates and guidelines that FPR must follow in paying the  personnel.     19.  FPR’s personnel are supervised by FPR’s clients.   20.  FPR’s personnel regularly perform their job duties at locations controlled by FPR’s  clients and act as an integral part of the clients’ workforces.    21.  Thus, the personnel provided by FPR are often employees and/or joint employees of  FPR’s clients as well.   22.  Morgan is an MWD hand employed by FPR.     24.  FPR originally classified Morgan as an “independent contractor” (despite the fact he was  actually an employee).   25.  During this period, FPR paid Morgan on a day-rate basis.   26.  Morgan reported the hours he worked to FPR on a regular basis.    27.  If Morgan worked fewer than 40 hours in a week, would be paid only for the hours he  worked.   28.  But Morgan normally worked more than 40 hours in a week.    29.  In fact, Morgan often worked at least 84 hours in a week.   30.  His hours are reflected, at least in part, in FPR’s records.   31.  FPR’s records reflect Morgan worked far more than 40 hours a week.   32.  However, during the period FPR paid Morgan a day-rate, FPR never paid Morgan  overtime.   33.  FPR later switched Morgan’s classification from “independent contractor” to employee.    34.  FPR changed Morgan’s classification to “employee” at the direction of one of its clients.   35.  Following the reclassification from independent contractor to employee, FPR paid  Morgan by the hour, with overtime for hours worked in excess of 40 in a workweek.   36.  Since at least 2015, FPR was aware of the overtime requirements of the FLSA.     37.  In fact, on information and belief, FPR pays overtime to its in-house staff (such as  secretaries and receptionists).     38.  FPR nonetheless failed to pay certain employees, such as Morgan, overtime.     39.  FPR’s failure to pay overtime to its day-rate personnel was, and is, a willful violation of  the FLSA.   41.  FPR paid dozens of workers according to the same unlawful day-rate scheme.   42.  Like Morgan, FPR classified these workers as independent contractors.   43.  Like Morgan, these workers performed their work in the oilfield.   44.  If they were employed at the time of the reclassification in late 2016, FPR reclassified  these workers from so-called “independent contractors” to admitted “employees.”   45.  Any differences in job duties do not detract from the fact that the day-rate workers were  entitled to overtime pay.    46.  The workers impacted by FPR’s “day-rate” payment scheme should be notified of this  action and given the chance to join pursuant to 29 U.S.C. § 216(b).     47.  Therefore, the class is properly defined as:  All oil field workers who worked for FPR during the past 3 years while being paid on a  day-rate basis.   48.  By failing to pay Morgan and those similarly situated to him overtime at one-and-one- half times their regular rates, FPR violated the FLSA’s overtime provisions.     49.  FPR owes Morgan and those similarly situated to him the difference between the rate  actually paid and the proper overtime rate.    50.  Because FPR knew, or showed reckless disregard for whether, its pay practices violated  the FLSA, FPR owes these wages for at least the past three years.    51.  FPR is liable to Morgan and those similarly situated to him for an amount equal to all  unpaid overtime wages as liquidated damages.   52.  Morgan and those similarly situated to him are entitled to recover all reasonable  attorneys’ fees and costs incurred in this action.   