29.  EQT is “the largest producer of natural gas in the United States … with emphasis in the  Appalachian Basin and operations in Pennsylvania, West Virginia, and Ohio[.]”1   30.  To complete its business objectives, EQT hires personnel, such as Heaster, to perform  inspection services.   31.  EQT considers Heaster and the Putative Class Members to be contractors.   32.  But EQT does not hire these workers on a project-by-project basis.   33.  Rather, EQT hires and treats these workers just like regular, even if sometimes short term,  employees.   34.  Many of these individuals worked for EQT on a day rate basis (without overtime pay).    35.  These workers make up the proposed Putative Class.     36.  For example, Heaster worked for EQT as a Landman from approximately October 2016  until April 2018.   37.  As a Landman, Heaster’s primary job duties include making phone calls to land and  mineral rights owners, setting up appointments with these owners, visiting the land to facilitate contracts  and lease agreements, and submitting paperwork.   38.  Heaster did not have any supervisory duties.    39.  Heaster did not hire for fire employees.    41.  Heaster was a blue-collar worker.   42.  Throughout his employment with EQT, he was classified as an independent contractor  and paid on a day rate basis.   43.  Heaster and the Putative Class Members work for EQT under its day rate pay scheme.   44.  Heaster and the Putative Class Members do not receive a salary.   45.  If Heaster and the Putative Class Members did not work, they did not get paid.   46.  Heaster and the Putative Class Members receive a day rate.   47.  Heaster and the Putative Class Members do not receive overtime pay.   48.  This is despite the fact that Heaster and the Putative Class Members often work more than  10 hours a day, for as many as 7 days a week, for weeks at a time.   49.  Although Heaster typically worked up to 7 days a week, for 10 or more hours a day, he  did not receive any overtime pay.   50.  Heaster and the Putative Class Members received the day rate regardless of the number of  hours they worked, and even if they worked more than 40 hours in a workweek.   51.  Without the job performed by Heaster and the Putative Class Members, EQT would not  be able to complete its business objectives.   52.  Heaster and the Putative Class Members relied on EQT for work and compensation.    53.  Heaster and the Putative Class Members worked in accordance with the schedule set by  EQT and/or its clients.    54.  Heaster and the Putative Class Members cannot subcontract out the work they are  assigned by EQT.    56.  Heaster and the Putative Class Members’ work must adhere to the quality standards put  in place by EQT and/or its clients.    57.  Heaster and the Putative Class Members did not substantially invest in the tools required  to complete the overall job to which they were assigned.    58.  Heaster and the Putative Class Members did not market their services while employed by  92.  Heaster brings this claim as a collective action under the FLSA.   93.  The Putative Class Members were victimized by EQT’s pattern, practice, and/or policy  which is in willful violation of the FLSA.   94.  Other Putative Class Members worked with Heaster and indicated they were paid in the  same manner (a day rate with no overtime) and performed similar work.    95.  Based on his experiences with EQT, Heaster is aware that EQT’s illegal practices were  imposed on the Putative Class Members.   96.  The Putative Class Members are similarly situated in all relevant respects.    97.  The Putative Class Members are blue-collar workers.   98.  Even if their precise job duties might vary somewhat, these differences do not matter for  the purposes of determining their entitlement to overtime.   