15. Enterprise Restoration provides a variety of services to its clients in the state of Louisiana  and nationwide. Enterprise Restoration utilizes manual laborers to provide these services.   17. John W. Adams, III was also an employer, for FLSA purposes, of Plaintiffs and the other  manual laborers. John W. Adams, III at all times relevant to this action owned and operated  Enterprise Restoration and exercised control over the day-to-day operations and finances  of Enterprise Restoration. Specifically, as to Plaintiffs and the other manual laborers, John  W. Adams, III (1) held the power to hire and fire; (2) managed and controlled work  schedules and employment conditions; (3) determined rates and methods of payment; and  (4) maintained employment records.   18. Although Plaintiffs were non-exempt employees under the FLSA and routinely worked in  excess of 40 hours per week, Defendants did not pay Plaintiffs an overtime rate of one and  one-half times their regular rate of pay for hours worked in excess of 40 hours per  workweek.   19. Defendants have also willfully and improperly applied the same unlawful pay practice to  many other non-exempt employees. Plaintiffs are aware of scores of other current and  former non-exempt employees of Defendants who also worked overtime hours for  Defendants without receiving overtime pay.   20. Any records concerning the number of hours worked by and amounts paid to Plaintiffs and  the other manual laborers are in the possession and custody of Defendants.  21. Plaintiffs bring this suit as a collective action pursuant to 29 U.S.C. § 216(b) on behalf of  themselves and all others employed by Defendants as manual laborers paid by the hour  within three years prior to the filing of this Complaint who, like Plaintiffs, have not been  compensated at one and one-half their regular rate of pay for all hours worked in excess of  40 in a single workweek.   22. Plaintiffs have consented in writing to be a part of this action. Plaintiffs’ signed consent  forms are attached hereto as Exhibit A.   23. Plaintiffs are aware that this practice has not been limited to payment of their wages, but it  a practice within the operations of Defendants’ business.    24. Defendants classify and pay all of their manual laborers in the manner described herein.  As such, Defendants maintained a common pay practice or policy and the FLSA Collective  are similarly situated to Plaintiffs.   25. Defendants’ manual laborers all perform similar job functions and duties although one  employee might have more tenure, experience, or require less supervision than another  employee in the same or similar position. As such, the FLSA Collective are similarly  situated to Plaintiffs.   27. Defendants possess the names and contact information of the FLSA Collective in their  records.   28. The FLSA Collective should be allowed to receive notice about this lawsuit and given an  opportunity to join. Like Plaintiffs, these similarly situated employees are entitled to  recover their unpaid overtime wages, liquidated damages, attorneys’ fees, and other  damages. Therefore, notice is appropriately sent to the following class:  All individuals who were employed by Enterprise Restoration, L.L.C. and/or John W.  Adams, III, as manual laborers and paid by the hour during any workweek from within  three (3) years of the filing of this action, through the time notice of this action is provided.   29. Defendants willfully engaged in a pattern of violating the FLSA as described in this  Complaint in ways including, but not limited to, failing to pay their employees overtime  compensation. Defendants’ conduct constitutes a willful violation of the FLSA within the  meaning of 29 U.S.C. § 255.   30. Plaintiffs incorporate by reference the allegations contained in all of the above paragraphs  as if fully set forth herein.   31. The FLSA applies to Defendants’ employment of Plaintiffs and the FLSA Collective.   32. The FLSA mandates that employees are entitled to overtime premium pay at a rate of no  less than one and one-half times the employee's regular rate for all hours worked in excess  of 40 hours per workweek.   33. Defendants have willfully refused to pay overtime to Plaintiffs and the FLSA Collective  for hours worked in excess of 40 hours per workweek.   34. As the direct and proximate result of Defendants’ unlawful conduct, Plaintiffs and the  FLSA Collective have suffered and will continue to suffer a loss of income and other  damages. Plaintiffs and the FLSA Collective are entitled to liquidated damages and  attorneys’ fees and costs incurred in connection with this claim.   35. The foregoing conduct, as alleged, constitutes a willful violation of the FLSA within the  meaning of the FLSA. Defendants knew or showed reckless disregard for the fact that their  compensation practices were in violation of the FLSA. 