11.  Defendant owns and operates an oilfield services company that operates in this District and  throughout Texas and does more than $500,000.00 in business per year.   12.  Plaintiffs and Class Members worked as “field supervisors” for Defendant at various job  sites in this District and throughout Texas.   13.  Despite being called “supervisors,” Plaintiffs and Class Members did not have any hiring  or firing authority nor were their suggestions or recommendations as to the hiring, firing,  advancement, promotion, or any other change of status of other employees given particular weight.    18.  Plaintiffs and Class Members were subjected to the same pay provisions in that they were  paid under the same pay plan and were not paid at time-and-one-half their regular rates of pay for  hours worked in excess of 40 hours in a workweek.  Specifically, Plaintiffs and Class Members  were all paid a set salary and not paid for their overtime hours worked. Accordingly, Class  Members who were victimized by Defendant’s unlawful pattern and practices are similarly  situated to Plaintiffs.   19.  In addition to Plaintiffs, Accel employed several other field supervisors within the past  three years. These other field supervisors performed job duties similar to the field supervisor duties  performed by Plaintiffs. Accel paid all its field supervisors a salary with no overtime pay, the same  pay system that Accel applied to Plaintiffs. Therefore, the Class Members are similarly situated to  Plaintiffs.   