19. Cesar Gomez was an employee of Honghua America LLC., Nabors Corporate  Services Inc., and Nabors Industries Inc.     20. Cesar Gomez was not an independent contractor.   21. No exemption to the provisions of the FLSA excused defendants from its  obligation under the FLSA to pay Cesar Gomez and putative class members time and a  half for the hours worked past forty (40) each week while employed by defendants.   22. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. paid Plaintiff Cesar Gomez straight time, not time and a half, for the hours he  worked above forty (40) during his employment with defendants.   23. Cesar Gomez worked for Honghua America LLC., Nabors Corporate Services  Inc., and Nabors Industries Inc. as a Welder from June of 2014 to January of 2015.   24. The work performed by Plaintiff was the primary type of work that the defendants  provide for their respective customers.   25. The work performed by Plaintiff was an essential part of the services provided for  Defendants’ Customers.     26. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc.’s Welders relied on Defendants for their work.     28. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. set Welders’ hours and required them to report to work on time and leave at the end  of their scheduled hours.     29. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. Welders at all locations work(ed) exclusively for Honghua America LLC., Nabors  Corporate Services Inc., and Nabors Industries Inc. since they work between 10 and 12  hours a day, as a practical matter, they cannot work anywhere else.   30. Defendants’ Welders are not permitted to hire other workers to perform their jobs  for them.   31. Defendants’ Welders do not employ staff, nor do they maintain independent  places of business.   32. Welders employed by defendants are paid based upon the hours they work.  They  cannot earn a “profit” by exercising managerial skill, and they are required to work the  hours required by Honghua America LLC., Nabors Corporate Services Inc., and Nabors  Industries Inc. each day.     33. The Welders employed by Defendants cannot suffer a loss of capital investment.   Their only earning opportunity is based on the number of hours they were told to work,  which is controlled exclusively by Honghua America LLC., Nabors Corporate Services  Inc., and Nabors Industries Inc.   34. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. pays Welders in return for their labor.       35. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. deducted taxes from the paychecks of Plaintiff and similarly situated employees.   37. Plaintiffs and putative class members were paid directly via weekly pay check.   38. Despite knowing of the FLSA’s requirements and that Plaintiff and putative class  members regularly worked more than 40 hours in a workweek, Defendants paid them  straight time instead of time and a half for the overtime hours that they worked.   39. Plaintiff and putative class members seek unpaid overtime wages for the three  year period of time preceding the filing of this lawsuit.   40. In addition to Cesar Gomez, defendants employed more than fifty (50+) other  Welders at the location where Plaintiff worked and at other locations. These Welders  worked over forty hours per week and were paid straight time instead of time and a half  for overtime hours worked.  These FLSA Class Members performed similar job duties  and they were subjected to the same unlawful pay policies.   41. The FLSA Class Members are similarly situated to Cesar Gomez.   42. The FLSA Class Members should be notified of this action and given the chance  to join pursuant to 29 U.S.C. § 216(b).  Therefore, the class is properly defined as:  All Welders who worked for Honghua America LLC., Nabors  Corporate Services Inc., and Nabors Industries Inc. at all of its  locations throughout the United States while receiving straight time  instead of time and a half for overtime hours worked in the last three  years.  43. By failing to pay Plaintiff and the FLSA Class Members overtime at one and one- half times their regular rates, Honghua America LLC., Nabors Corporate Services Inc.,  and Nabors Industries Inc. violated the FLSA.   44. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. owes Plaintiff and the FLSA Class Members overtime wages equal to one-half their  regular rates for each overtime hour worked during the last three years.   46. Honghua America LLC., Nabors Corporate Services Inc., and Nabors Industries  Inc. owes Plaintiff and the FLSA Class Members an amount equal to all unpaid overtime  wages as well as liquidated damages.   47. Plaintiff and the FLSA Class Members are entitled to recover all reasonable  attorneys’ fees and costs incurred in this action. 