6.12  Plaintiff and the Class Members were at all times “non-exempt” employees and eligible  to receive overtime pay pursuant to Section 207 of the FLSA.   6.14  Plaintiff and the Class Members worked/work over forty hours per work week and  Defendant fails/failed to pay Plaintiff and the Class Members any overtime  compensation.    6.13  Defendant improperly classified Plaintiff and the Class Members as exempt from  receiving overtime compensation.   6.1  Defendant JSE is an engineering company that offers a range of engineering services.     6.10  As plumbing, HVAC, and electrical designers, Plaintiff and Class Members regularly  work/worked more than forty (40) hours per workweek.  Neither he nor any of the other  Class Members had authority to (nor did they): manage an enterprise, hire or fire other  employees, set the pay rates of other employees, create policies or procedures to govern  Defendant’s employees, handle employee grievances, determine the type of equipment or  materials that Defendant could use in its operations, enter into contracts on behalf of  Defendant or otherwise have operational control over Defendant’s business operations  and practices.  Moreover, Plaintiff and the Class Members did not perform office or non- manual work directly related to the management or general business operations of  Defendant or its customers, nor did they exercise discretion and independent judgment  with respect to matters of significance in the conduct of Defendant’s business.   6.15  During his employment, there were approximately eight (8) plumbing designers, twelve  (12) electrical designers and five (5) HVAC designers at any given time   who were/are  subject to the same pay policy/plan described herein, work/worked overtime hours, and  were/are not compensated in accordance with the FLSA by Defendant.  Throughout  Plaintiff’s employment, Plaintiff was aware of multiple other individuals who worked as  plumbing, HVAC and/or electrical designers and were not compensated in accordance  with the FLSA for hours worked in excess of forty-hours per work week.    6.2  Plaintiff worked as a plumbing designer for Defendant JSE.  Plaintiff was told by  Defendant that his position as a plumbing designer is exempt from overtime  compensation however he is expected to work over forty (40) hours per week if  Defendant’s business demands require a quick turn-around or short deadline.  The  electrical and HVAC designers that Plaintiff worked with also worked over forty (40)  hours per week and did not receive overtime compensation in accordance with the FLSA.   6.4  Defendant dictated what hours Plaintiff works, provided the tools for him to do his job,  told him what work he is required to complete and the specifications on how the work  was to be completed.  On multiple weeks during his employment over the last three (3)  years Plaintiff worked from 20-35 hours over 40 hours per work week.   6.5  Defendant controlled all the conditions of Plaintiff’s employment.  Defendant determined  Plaintiff’s pay rate, the schedule he worked, and the policies and procedures Plaintiff and  the other Class Members are/were required to follow.   6.6  Defendant also required Plaintiff and the Class Members to fill out a timesheet recording  the hours they work on a daily basis.  Defendant required that timesheets be submitted to  the team leader, division leader, and/or office manager on scheduled due dates and if  Plaintiff and the Class Members were going to be absent on a timesheet due date, they  were required to submit their timesheet early.   6.7  As a plumbing designer, Plaintiff’s primary duties included, performing calculations and  sizing pipe.  Electrical designers’ primary duties included sizing wires and circuits.   HVAC designers’ primary duties included sizing duct work and equipment. Plaintiff and  the Class Members worked in Defendant’s office as well as occasionally performed site  visits for projects he was assigned by Defendant.   6.9  Plaintiff and Class Members do/did not have authority to hire or fire any of Defendant’s  employees and do not have authority to set pay.   7.  7.2   Defendant classified/classifies and paid/pays all of its plumbing, HVAC and/or electrical  designers in the manner described above.  Defendant maintained a common pay practice  or policy and the Class Members are similarly situated to Plaintiff.   7.3  Defendant’s plumbing, HVAC and/or electrical designers all performed the same/similar  essential job functions and duties of performing calculations and/or sizing pipe  (plumbing), duct work and equipment (HVAC) or wires and circuits (electrical),  notwithstanding the fact that one employee might have more tenure or experience than  another employee in the same or similar position.  Therefore, the Class Members are  similarly situated to Plaintiff.     7.4  The damages for each individual can easily be calculated using the same methodology  and formula although the exact amount of the damages may vary.   7.5  Defendant possesses the names and addresses of Class Members in its records.  The Class  Members should be allowed to receive notice about this lawsuit and given an opportunity  to join.  Like Plaintiff, these similarly situated workers are entitled to recover their unpaid  wages, overtime wages, liquidated damages, attorneys’ fees and other damages.  Therefore, notice is appropriately sent to the following class:  All plumbing, HVAC or electrical designers that worked for  Defendant at any time from [three years before date of mailing of  Notice and Consent] up to [the date of mailing of Notice and Consent].   8. 