10.  Defendants jointly hired and fired, supervised and controlled, set pay, determined  hours, and approved time sheets with respect to Bowser and the Class Members.    11.  In each of the past three years, Duke’s revenues exceeded $500,000, Guidant’s  revenues exceeded $500,000, and Empyrean’s revenues exceeded $500,000.   13.  Over the past three years, each Defendant employed at least two individuals that  routinely handled goods or materials – such as phones, computers, and tools – that moved in, or  were produced for, interstate commerce.   14.  Each of the Defendants are a covered enterprise under the FLSA and are subject to  its requirements.   15.  Defendants, at all relevant times, paid Bowser and the Class Members at the same  hourly rate for all hours worked, including those worked in excess of forty per week. Defendants did  not pay Bowser and the Class Members at one and one-half times their regular hourly rates for  hours worked in excess of forty in a workweek.    16.  Each of the Defendants maintain employment records on Bowser and the Class  Members, and can terminate their employment.    17.  Bowser typically worked 50 hours per week at the Catawba nuclear station and a  varied amount of overtime at the Robison nuclear station. Defendants paid $75 per hour.   18.  Defendants maintained accurate records of the hours Bowser worked.   19.  Defendants knew Bowser and the Class Members routinely worked more than 40  hours in a week. Defendants’ records, which show hours worked, reflect this fact.    20.  It is well established that hourly workers – like Bowser and the Class Members – are  not exempt from the overtime provisions of the FLSA. Defendants knew Bowser and the Class  Members were not exempt from the FLSA’s overtime provisions (or the provisions of any similar  state overtime laws).   22.  Defendants received complaints about their failure to pay overtime, but failed to  correct their payroll policy.   23.  Defendants’ policy of paying non-exempt workers by the hour, with no overtime  pay, violates the FLSA.   24.  Defendants’ policy of paying straight time for overtime affects Bowser and the Class  Members in a similar manner because, as explained above, hourly workers are non-exempt from  overtime. Accordingly, they are each owed overtime pay for the same reason even though their job  duties differ. Bowser and the Class Members are similarly situated for the purposes of their overtime  claims.     25.  The Class Members include:   All current and former hourly workers employed by Duke, Guidant, and Empyrean  who were not paid at least time and one-half for hours worked in excess of forty in a  workweek during the last three years.   26.  By failing to pay Bowser and the Class Members overtime at one-and-one-half times  their regular rates, Defendants violated the FLSA’s overtime provisions.     27.  Defendants owe Bowser and the Class Members the difference between the rate  actually paid and the proper overtime rate for all overtime hours worked. Because Defendants knew,  or showed reckless disregard for whether, their pay practices violated the FLSA, they owe these  wages for at least the past three years.   28.  Defendants also owe Bowser and the Class Members an amount equal to the unpaid  overtime wages as liquidated damages.   9.  Duke employed Guidant and Empyrean to manage its workforce and to outsource  the functions traditionally performed by in-house human resource departments.  