21.  Plaintiff incorporates the preceding paragraphs by reference as if set forth fully in  this section.   23.  On information and belief, Encinal, Texas is/was the single site of employment,  as defined by the WARN Act, for employees of Defendant, such as Martinez and the Class  Members. On information and belief, management of Defendant’s South Texas oilfield  operations in addition to management and administrative support of Martinez and the Class  members, is/was conducted at/from/through the Encinal, Texas single site of employment.    24.  Martinez worked with numerous other employees of Defendant. Those employees  performed oilfield operations/support of oilfield operations for Defendant. Like Martinez, those  workers are/were subject to Defendant’s Mass Layoff and/or Plant Closing made the subject  matter of this lawsuit.    25.  Martinez was verbally notified by Defendant on or about January 14, 2015 that  his employment with Defendant was terminated or that he otherwise was subject to an  employment loss. Martinez was not discharged for cause, did not voluntarily resign, and did not  retire.   26.  On information and belief, the employment losses at the Encinal, Texas site of  employment made the subject matter of this lawsuit occurred within a 30 day period of  Martinez’s Employment Loss. Alternatively, and on information and belief, those employment  losses occurred within a 90 day period of Martinez’s Employment Loss, such employment losses  not being the result of separate and distinct actions and causes.   28.  The exact number of employees who experienced an employment loss at the  Encinal, Texas site of employment made the basis of this lawsuit within a 30 day and 90 day  period of Martinez’s Employment Loss is information that is only known to Defendant.  Similarly, the exact number of employees employed at/from/through that site of employment is  information that is currently known only to Defendant.   29.  Martinez and the Class Members were not provided with 60 days’ advance  written notice by Defendant of their employment loss, Mass Layoff and/or Plant Closing.   30.  Martinez and the Class Members were not provided with any written notice by  Defendant prior to their employment loss, Mass Layoff and/or Plant Closing.   31.  Martinez and the 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.  51.  Martinez incorporates the preceding paragraphs by reference as if set forth fully in  this section.   52.  Martinez brings this action as a class action under Federal Rule of Civil Procedure  23(a), (b)(1) and (3) and the WARN Act 29 U.S.C. § 2104(a)(5).   53.  Martinez brings this action on behalf of himself and all other similarly situated  employees. Martinez seeks to represent a Class initially defined as: “All of Defendant’s  employees working at/from/through Defendant’s Encinal, Texas site of employment for its  drilling services operations who experienced an employment loss during the 30 or 90 day period  from January 14, 2015 without 60 days’ advance written notice required by the WARN Act.”  Martinez requests the opportunity to expand, narrow or modify the class definition pursuant to a  motion for class certification and/or amended pleading to the extent discovery reveals that there  is more than one single site of employment for Defendant’s oilfield operations.   54.  Martinez and the Class Members are “affected employee(s)” subject to an  “employment loss,” as those terms are defined in the WARN Act at 29 U.S.C. § 2101(a)(5) and  (6).   56.  On information and belief, the Class Members is so numerous that joinder is  therefore impracticable. The precise number of Class Members and their addresses are readily  determinable from Defendant’s records.   57.  There are common questions of fact and law as to the class that predominate over  any questions affecting only individual class members. The questions of law and fact common to  the class arising from Defendant’s actions/omissions include, but are not limited to, the  following:  a.   Whether the provisions of the WARN Act apply;  b. Whether Defendant’s employees at the Encinal, Texas site of  employment for Defendant’s oilfield operations experienced an  employment loss in connection with a “Mass Layoff” and/or “Plant  Closing” under the WARN Act;  c.   Whether Defendant failed to provide the notices required by  the WARN Act;   d.  Whether Defendant can avail itself of any provisions of the  WARN Act permitting lesser periods of written notice; and  e.  The appropriate method to calculate damages under the WARN  Act.   58.  The questions above predominate over any questions affecting only individual  persons, and a class action is superior with respect to considerations of consistency, economy,  efficiency, fairness and equity, to other available methods for the fair and efficient adjudication  of the WARN Act claims.   60.  Martinez is an affected former employee of Defendant who experienced an   employment loss during the relevant 30 day and 90 day “look ahead” and “look behind” periods  of the WARN Act, 20 C.F.R. § 639.5, without the required written notice. Martinez is, therefore,  a member of the class. Martinez is committed to pursuing this action and has retained counsel  with extensive experience in prosecuting complex wage, employment, and class action litigation.  Accordingly, Martinez is an adequate representative of the class and has the same interests as all  of its members. Further, Martinez’s claims are typical of the claims of all members of the Class,  and Martinez will fairly and adequately protect the interests of the absent members of the class.  Martinez and his counsel do not have claims or interests that are adverse to the Class Members.   61.  Furthermore, class action treatment of this lawsuit is authorized and appropriate  under the WARN Act, 29 U.S.C. § 2104(a)(5), which provides that a plaintiff seeking to enforce  liabilities under the Act may sue either on his or her behalf, for other persons similarly situated,  or both. 