19.  Plaintiff files this case as an “opt-in” collective action, as is specifically allowed  by 29 U.S.C. § 216(b).   20.  Other employees have been victimized by Defendants’ ill-conceived patterns,  practices, and policies that violate the FLSA.  As such, other similarly situated employees are  being denied their lawful wages, and Plaintiff’s experience is typical of the experience of  members of the Plaintiff Class as it pertains to unpaid wages.   21.  The specific job titles or job requirements of the various members of the Plaintiff  Class do not prevent collective treatment.   22.  Each non-exempt employee, regardless of job title, job requirements, or rate of  pay, who is denied overtime compensation for hours worked in excess of 40 in one or more  workweek, is similarly situated to Plaintiff.   23.  Furthermore, although the amount of damages may vary among individual  employees, there is no detraction from the common nucleus of liability facts.   25.  Thus, the class Plaintiff seeks to represent is comprised of all current and former  employees the Defendants’ “enterprise” employed as hourly or non-exempt salaried workers  who 1) worked at any business establishment of Defendants’ “enterprise” located in Texas that  was owned, operated and / or acquired by Defendants’ “enterprise” during the class period, and  2) claim that Defendants’ “enterprise” either (a) misclassified the employee as exempt from  overtime wages, or (b) did not misclassify the employee, but instead failed to properly and fully  compensate the employee’s overtime wages due.    26.  Individuals who opt in to the collective action will be added to the litigation, and  copies of their written consents to join a collective action will be filed with the Honorable Court.  V.  27.  At all times relevant to this action, Defendants’ “enterprise” has been subject to  the requirements of the FLSA.   28.  For purposes of this action, the “relevant period” is the time-period commencing  on the date that is three years prior to the filing of this action, and continuing thereafter until time  of trial.   29.  Defendants’ “enterprise” employed Mr. Ali as a store clerk at their business  establishment doing business as “1960 Corner Food Store”, located at 17013 Nanes Drive,  Houston, Texas 77090.   31.  During his employment with the Defendants, Mr. Ali’s was promised a fixed  wage of $4,000.00 per month.   32.  Mr. Ali did not receive any overtime wages in addition to his fixed monthly wage  of $4,000.00.   33.  When Mr. Ali complained of his unpaid overtime wages, his employment was  terminated in retaliation, and in violation of the FLSA.   34.  As Defendants’ employee, Mr. Ali was required to perform duties typically  performed by “hourly” or non-exempt employees.   35.  Further, Plaintiff was required to work overtime hours in excess of 40 hours  during each workweek of his employment.   36.  Similarly, during at least all or part of the last three years, all non-exempt workers  employed by all business establishments owned and/or operated by the Defendants were  routinely required to work in excess of 40 hours per week to perform the function of their job  which included the performance of duties otherwise typically performed by “hourly” paid non- exempt employees because the job required it and Defendants’ management required it.   37.  Defendants required Plaintiff and all others similarly situated to perform all  necessary work to include the performance of those duties otherwise typically performed by  “hourly” employees, which duties routinely required Plaintiff and other similarly situated  employees to work “overtime” hours as defined by 29 U.S.C. § 201 et seq.   38.  Plaintiff and all other similarly situated employees were not paid at the proper  premium hourly rates for the overtime hours they worked each week.   40.  As victims of a common policy that violated the FLSA, Plaintiff and all other  similarly situated non-exempt employees of the Defendants may properly be joined as a class  under 29 U.S.C. § 216(b).   41.  Plaintiff and all other similarly situated employees thus sue the Defendants’  “enterprise”, as a class, for their unpaid overtime wages owed under the FLSA.  VI. 