1.5 times his regular rate of pay, which should have included all wages received and not just those  labeled as hourly rates of pay. As a result, BAR S significantly underpaid Shaw for overtime hours  worked.  19.  Consistent with their policies and patterns or practices as described herein,  Defendant harmed Plaintiff, individually, as follows:  Kenny Shaw   20.  Shaw was employed by BAR S as a load operator from approximately October 2018  through March 23, 2020 in Wyoming.    21.  During the course of his employment, Shaw regularly worked over 40 hours per  week up to approximately 90 hours in a workweek.    22.  Despite regularly working over 40 hours per week, BAR S did not properly pay Shaw  proper overtime compensation for all hours worked over 40. In this regard, BAR S compensated  Shaw in part on an hourly basis on his paystubs. In addition to this hourly wage, Shaw would also  receive additional wages on the same or separate paystub. This additional compensation was subject  to taxes, included in his year to date wage amounts, and depended upon the hours worked by Shaw.   23.  BAR S failed to pay Shaw proper overtime compensation because it failed to pay him   24.  Plaintiff brings the First Cause of Action, an FLSA claim, on behalf of himself and  all similarly situated persons who work or have worked as Non-Exempt Laborers for BAR S  throughout the United States who elect to opt-in to this action (the “FLSA Collective”).   26.  Consistent with Defendant’s policies and patterns or practices, Plaintiff and the  FLSA Collective were not paid the proper premium overtime compensation of 1.5 times their  regular rates of pay for all hours worked beyond 40 per workweek.   27.  All of the work that Plaintiff and the FLSA Collective have performed has been  assigned by Defendant, and/or Defendant has been aware of all of the work that Plaintiff and the  FLSA Collective have performed.   28.  As part of their regular business practice, Defendant has intentionally, willfully, and  repeatedly engaged in a pattern, practice, and/or policy of violating the FLSA with respect to  Plaintiff and the FLSA Collective. This policy and pattern or practice includes, but is not limited to,  willfully failing to pay their employees, including Plaintiff and the FLSA Collective, proper premium  overtime wages for all hours worked in excess of 40 hours per workweek.    29.  Defendant’s unlawful conduct, as described in this Complaint, is pursuant to a  corporate policy or practice of minimizing labor costs by failing to properly pay overtime  compensation to its employees.   30.  Defendant is aware or should have been aware that federal law required it to pay  Plaintiff and the FLSA Collective overtime premiums for all hours worked in excess of 40 per  workweek.   31.  There are many similarly situated current and former Non-Exempt Laborers who  have been denied overtime pay in violation of the FLSA who would benefit from the issuance of a  court-supervised notice of this lawsuit and the opportunity to join it. This notice should be sent to  the FLSA Collective pursuant to 29 U.S.C. § 216(b).    33.  Plaintiff realleges and incorporates by reference all allegations in all preceding  paragraphs.   34.  The overtime wage provisions set forth in the FLSA, 29 U.S.C. §§ 201 et seq., and the  supporting federal regulations, apply to Defendant and protect Plaintiff and the members of the  FLSA Collective.    35.  During this time, Plaintiff and the FLSA Collective regularly worked in excess of 40  hours per week.   36.  Defendant failed to pay Plaintiff and the FLSA Collective the premium overtime  wages to which they were entitled under the FLSA – at a rate of 1.5 times their regular rates of pay,  which should have included all compensation earned per workweek – for all hours worked beyond  40 per workweek.   37.  As a result of Defendant’s willful violations of the FLSA, Plaintiff and the FLSA  Collective have suffered damages by being denied overtime compensation in amounts to be  determined at trial, and are entitled to recovery of such amounts, liquidated damages, attorneys’ fees,  costs, and other compensation pursuant to 29 U.S.C. §§ 201 et seq. Fair Labor Standards Act – Overtime Wages  (Brought on behalf of Plaintiff and the FLSA Collective)  