35.  Plaintiffs incorporate the preceding paragraphs by reference as if set forth fully in  this section.   37.  On information and belief, Rio Vista, Texas is/was the single site of employment,  as defined by the WARN Act, for employees of Defendant, such as Cole and the Rio Vista Class  Members. On information and belief, management of Defendant’s Southern U.S. District oilfield  operations in addition to management and administrative support of Cole and the Rio Vista Class  Members, is/was conducted at/from/through the Rio Vista, Texas single site of employment.   38.  Cole worked with numerous other employees of Defendant. Those employees  performed drilling operations/support of drilling operations for Defendant. Like Cole, those  workers are/were subject to Defendant’s Mass Layoff and/or Plant Closing made the subject  matter of this lawsuit.    39.  Cole was verbally notified by Defendant on or about February 12, 2015 that his  employment with Defendant was terminated or that he otherwise was subject to an employment  loss. Cole was not discharged for cause, did not voluntarily resign, and did not retire.   40.  On information and belief, the employment losses at the Rio Vista, Texas site of  employment made the subject matter of this lawsuit occurred within a 30 day period of Cole’s  employment loss. Alternatively, and on information and belief, those employment losses  occurred within a 90 day period of Cole’s employment loss, such employment losses not being  the result of separate and distinct actions and causes.   42.  The exact number of employees who experienced an employment loss at the Rio  Vista, Texas site of employment made the basis of this lawsuit within a 30 day and 90 day period  of Cole’s employment loss is information that is only known to Defendant. Similarly, the exact  number of employees employed at/from/through the Rio Vista, Texas site of employment is  information that is currently known only to Defendant.   43.  Cole and the Rio Vista Class Members were not provided with 60 days’ advance  written notice by Defendant of their employment loss, Mass Layoff and/or Plant Closing.   44.  Cole and the Rio Vista Class Members were not provided with any written notice  by Defendant prior to their employment loss, Mass Layoff and/or Plant Closing.   45.  Cole and the Rio Vista Class Members were not provided with written notice, at  any time prior to their termination, of each and every of the following items in connection with  their employment loss: (a) A statement as to whether the planned action is expected to be  permanent or temporary and, if the entire plant is to be closed, a statement to that effect;  (b) The  expected date when the plant closing or mass layoff will commence and the expected date when  the individual employee will be separated; (c) An indication whether or not bumping rights exist;  (d) The name and telephone number of a company official to contact for further information.   B.  Mandan, North Dakota   47.  Tippins worked with numerous other employees of Defendant. Those employees  performed drilling operations/support of drilling operations for Defendant. Like Tippins, those  workers are/were subject to Defendant’s Mass Layoff and/or Plant Closing made the subject  matter of this lawsuit.    48.  Tippins was verbally notified by Defendant on or about February 20, 2015 that his  employment with Defendant was terminated or that he otherwise was subject to an employment  loss. Tippins was not discharged for cause, did not voluntarily resign, and did not retire.   49.  On information and belief, the employment losses at the Mandan, North Dakota  site of employment made the subject matter of this lawsuit occurred within a 30 day period of  Tippins’ employment loss. Alternatively, and on information and belief, those employment  losses occurred within a 90 day period of Tippins’ employment loss, such employment losses not  being the result of separate and distinct actions and causes.   51.  The exact number of employees who experienced an employment loss at the  Mandan, North Dakota site of employment made the basis of this lawsuit within a 30 day and 90  day period of Tippins’ employment loss is information that is only known to Defendant.  Similarly, the exact number of employees employed at/from/through the Mandan, North Dakota  site of employment is information that is currently known only to Defendant.   52.  Tippins and the Mandan Class Members were not provided with 60 days’ advance  written notice by Defendant of their employment loss, Mass Layoff and/or Plant Closing.   53.  Tippins and the Mandan Class Members were not provided with any written  notice by Defendant prior to their employment loss, Mass Layoff and/or Plant Closing.   54.  Tippins and the Mandan Class Members were not provided with written notice, at  any time prior to their termination, of each and every of the following items in connection with  their employment loss: (a) A statement as to whether the planned action is expected to be  permanent or temporary and, if the entire plant is to be closed, a statement to that effect;  (b) The  expected date when the plant closing or mass layoff will commence and the expected date when  the individual employee will be separated; (c) An indication whether or not bumping rights exist;  (d) The name and telephone number of a company official to contact for further information.  C.  Midland, Texas   56.  Bell worked with numerous other employees of Defendant. Those employees  performed drilling operations/support of drilling operations for Defendant. Like Bell, those  workers are/were subject to Defendant’s Mass Layoff and/or Plant Closing made the subject  matter of this lawsuit.    57.  Bell was verbally notified by Defendant on or about March 6 2015 that his  employment with Defendant was terminated or that he otherwise was subject to an employment  loss. Bell was not discharged for cause, did not voluntarily resign, and did not retire.   58.  On information and belief, the employment losses at the Midland, Texas site of  employment made the subject matter of this lawsuit occurred within a 30 day period of Bell’s  employment loss. Alternatively, and on information and belief, those employment losses  occurred within a 90 day period of Bell’s employment loss, such employment losses not being  the result of separate and distinct actions and causes.   60.  The exact number of employees who experienced an employment loss at the  Midland, Texas site of employment made the basis of this lawsuit within a 30 day and 90 day  period of Bell’s employment loss is information that is only known to Defendant. Similarly, the  exact number of employees employed at/from/through the Midland, Texas site of employment is  information that is currently known only to Defendant.   61.  Bell and the Midland Class Members were not provided with 60 days’ advance  written notice by Defendant of their employment loss, Mass Layoff and/or Plant Closing.   62.  Bell and the Midland Class Members were not provided with any written notice  by Defendant prior to their employment loss, Mass Layoff and/or Plant Closing.   63.  Bell and the Midland Class Members were not provided with written notice, at  any time prior to their termination, of each and every of the following items in connection with  their employment loss: (a) A statement as to whether the planned action is expected to be  permanent or temporary and, if the entire plant is to be closed, a statement to that effect;  (b) The  expected date when the plant closing or mass layoff will commence and the expected date when  the individual employee will be separated; (c) An indication whether or not bumping rights exist;  (d) The name and telephone number of a company official to contact for further information.  IV. 