17.  Defendant conducts business in El Paso, Texas.  The primary job duties of the  “Maintenance Technicians,” “Lead Maintenance Technicians,” and “Maintenance Supervisors” are  the same.  Plaintiffs and Class Members worked as “Maintenance Technicians,” “Lead Maintenance  Technicians,” and “Maintenance Supervisors”, but essentially performed duties relating to installing,  repairing, and maintaining apartments at Defendant’s complexes.  Specifically, “Maintenance  21.  Plaintiffs have actually knowledge that Class Members have also denied overtime pay  for hours worked over forty hours in a week.  35.  Plaintiffs re-allege and incorporate by reference the facts asset forth above.   36.  Defendant violated 29 U.S.C. 207(a) by failing to pay Plaintiffs and Class members  time and one-half the regular rate of pay for all hours worked in excess of 40 hours during a  workweek.   37.   Defendant did not adequately keep track of Plaintiffs’ work hours, even though  Plaintiffs were non-exempt employees for overtime purposes as outlined under the Fair Labor  Standards Act, 29 U.S.C. §§ 201 et. seq. (“FLSA”).   38.  Plaintiffs and Class members have been damaged by these violations of 29 U.S.C.  207(a).   39.  Defendant’s violations of U.S.C. 207(a) were repeated, willful and intentional.   40.  Plaintiffs and the Class members are entitled to an amount equal to all their unpaid  regular and overtime wages as liquidated damages.  29 U.S.C. 216(b).   41.  Additionally, Plaintiffs and Class Members are entitled to recover attorneys’ fees and  costs as required by the FLSA.  29 U.S.C. 216(b). 