13.  Defendant TurnCo, LLC is an oilfield services company that provides  specialized inspection services to its clients in the oil and gas industry.   14.  This lawsuit presents the fourth time in the last three years when Defendant  has been sued by an employee in its inspector workforce for failing to pay overtime.   Despite being repeatedly sued by its inspectors for failing to pay overtime and being  made aware of the law on multiple occasions, Defendant continues to ignore the  requirement under the law to pay overtime when its employees work more than 40 hours  in a workweek.    15.  Plaintiff worked for Defendant as an inspector from approximately April of  2013 to August of 2015.  4   16.  Defendant’s inspectors are responsible for performing inspections on  drilling equipment such as motors and drill collars.  Their work is primarily performed in  the warehouses or yards of Defendant’s customers.    17.  Inspectors commonly work in excess of 12 hours each day.     18.  Inspectors usually work five to six days each week.  Defendant also  required mandatory, alternating Saturdays to be worked.   19.  Inspectors are paid a salary for their labor and do not receive overtime for  those hours worked in excess of 40 in a workweek.    20.  No exemption under the FLSA law shelters Defendant from paying  overtime to its inspectors.     21.  Inspectors do not supervise other employees or manage a customarily  recognized department of Defendant’s company.   22.  Inspectors have no authority to hire or fire other employees.   23.  Inspectors are field employees, not office employees.  The perform work  related to Defendant’s core business, not the management of the company’s operations.   24.  The primary duty of an inspector does not require independent judgment or  discretion.  Instead, inspectors are required to carry out their inspections according to  detailed step-by-step procedures promulgated by Defendant or Defendant’s customers.   25.  The FLSA’s regulations even provide that inspection work is non-exempt  work:  Ordinary inspection work generally does not meet the duties  requirements for the administrative exemption.  Inspectors  normally perform specialized work along standardized lines  5  involving well-established techniques and procedures which  may have been catalogued and described in manuals and  other sources.  Such inspectors rely on techniques and skills  acquired by special training or experience.  They have some  leeway in the performance of their work but only within  closely prescribed limits.  29 C.F.R. 541.203(g).     26.  Inspectors are not computer-systems analysts, computer programmers,  software engineers, or other similar employees.     27.  Despite these facts, Defendant misclassified its inspectors as exempt from  overtime pay.   28.  As a result of Defendant’s pay policies, Plaintiff and other inspectors were  denied overtime pay.   29.  Defendant knew, or showed reckless disregard for whether Plaintiff and the  other inspectors were entitled to overtime pay under the law.  In fact, Defendant knew the  requirement to pay overtime to Plaintiff and Class Members but intentionally chose not to  do so.    30.  Defendant has effectively turned a “blind eye” to paying overtime to the  Plaintiff and Class Members. Again, This is the fourth lawsuit that has been brought  against Defendant for misclassifying its inspector workforce as exempt from overtime.   The first lawsuit was brought in November 2013 alleging that Defendant misclassified its  inspector workforce as exempt.  The second and third lawsuits were filed in 2015, again  claiming that Defendant misclassified its inspector workforce as exempt.  Defendant  settled each of these cases.  Nevertheless, Defendant continues to violate the law.   6  Turning a blind-eye to paying overtime to Plaintiff and Class Members constitutes  willfulness as a matter of law under the standard articulated by the Fifth Circuit in Ramos  v. Bataineh, 2015 WL 1412628 (5th Cir. Mar. 30, 2015).  31.   Plaintiff incorporates all allegations contained in the foregoing paragraphs.    32.   Defendant’s practice of failing to pay Plaintiff time-and-a-half for all hours  worked in excess of forty (40) per workweek violates the FLSA.  29 U.S.C. § 207.      33.   None of the exemptions provided by the FLSA regulating the duty of  employers to pay overtime at a rate not less than one and one-half times the regular rate  at which its employees are paid are applicable to Defendant, Plaintiff, or the FLSA Class  Members.    34.  Plaintiff incorporates by reference the allegations in the preceding  paragraphs.   35.  Plaintiff has actual knowledge that FLSA Class Members have also been  denied overtime pay for hours worked over forty (40) hours in a workweek as a result of  Defendant’s misclassification of its employees.     36. Plaintiff’s knowledge is based on his personal work experience and through  communications with other workers of Defendant.  Plaintiff personally worked with other  inspectors under the same compensation structure at multiple job sites for Defendant.  7   37.  Other workers similarly situated to the Plaintiff worked for Defendant  throughout the United States, but were not paid overtime at the rate of one and one-half  their regular rates of pay when those hours exceeded forty (40) hours in a workweek.     38.  Although Defendant permitted and/or required FLSA Class Members to  work in excess of forty (40) hours in a workweek, Defendant denied them full  compensation for their hours worked over forty (40).   39.  Defendant misclassified and continues to misclassify FLSA Class Members  as exempt employees.     40.  FLSA Class Members perform or have performed the same or similar work  as Plaintiff and were misclassified as exempt by Defendant.    41.  FLSA Class Members are not exempt from receiving overtime pay under  the FLSA.   42.  As such, FLSA Class Members are similar to Plaintiff in terms of relevant  job duties, pay structure, misclassification as exempt employees and/or the denial of  overtime pay.   43.  Defendant’s failure to pay overtime compensation at the rate required by  the FLSA results from generally applicable policies or practices, and does not depend on  the personal circumstances of any FLSA Class Member.   44.  The experiences of Plaintiff, with respect to his pay, hours, and duties are  typical of the experiences of the FLSA Class Members.   45.  The specific job titles or precise job responsibilities of each FLSA Class  Member does not prevent collective treatment.  8   46.  All FLSA Class Members, irrespective of their particular job requirements,  are entitled to overtime compensation for hours worked in excess of forty (40) in a  workweek.   47.  Although the exact amount of damages may vary among the FLSA Class  Members, the damages for the FLSA Class Members can be easily calculated by a simple  formula. The claims of all FLSA Class Members arise from a common nucleus of facts.   Liability is based on a systematic course of wrongful conduct by Defendants that caused  harm to all FLSA Class Members.    48.  As such, the class of similarly situated Plaintiffs for the FLSA Class is  properly defined as follows:   All current and former inspectors, and all employees with  substantially similar duties, who worked for Defendant at any  time during the three-year period before the filing of this  Complaint.     