24.  Defendants are an oil and natural gas exploration and production company operating  throughout the United States, including Ohio and Pennsylvania.    25.  The proposed Putative Class Members worked for Defendants as Solids Control  Technicians. Defendant paid all its Solids Control Technicians like Plaintiff a salary and no with  overtime pay for hours that they worked in excess of forty (40) hours in a workweek.   26.  As Solids Control Technicians, Plaintiff and the proposed Putative Class Members  spent their shifts separating drilling fluid from the solids crushed by the drill bit and carried up to the  surface in the drilling fluid. These individuals removed the solids at the surface using screens,  centrifuges, dryers, and shakers. The clean mud is recycled back down the hole to the drill bit and the  rock, sand, and other particles that were removed from the mud are discarded to prevent damage to  expensive equipment. 1   27.  The primary job duties of the Solids Control Technicians included setting up,  servicing, and operating mud cleaning equipment, including screens, centrifuges, dryers, and shakers.  The Solids Control Plaintiffs worked in excess of 40 hours each week while employed by Defendants,  often for weeks at time   29.  Moreover, the job functions of the Putative Class Members were primarily manual  labor/technical in nature, requiring little to no official training, much less a college education or other  advanced degree.    30.  The Putative Class Members did not have any supervisory or management duties.   31.  All of the Putative Class Members perform the same or similar job duties and are  subjected to the same or similar policies and procedures which dictate the day-to-day activities  performed by each person.   32.  The Putative Class Members also worked similar hours and were denied overtime as a  result of the same illegal pay practice.    33.  Defendants’ policy of failing to pay their Solids Control Technicians, including  Plaintiff, overtime violates the FLSA, Ohio Wage Acts, and PMWA because these workers are, for all  purposes, employees performing non-exempt job duties.  VI.  53.  Plaintiff incorporates all previous paragraphs and alleges that the illegal pay practices  Defendants imposed on Plaintiff were likewise imposed on the Putative Class Members.   54.  Numerous individuals were victimized by this pattern, practice, and policy which is in  willful violation of the FLSA, Ohio Wage Acts, and PMWA.    55.  Numerous other individuals who worked with Plaintiffs indicated they were  improperly classified as exempt, paid in the same manner, performed similar work, and were not  properly compensated for all hours worked as required by state and federal wage laws.   56.  Based on his experiences and tenure with Defendants, Plaintiff is aware that  Defendants’ illegal practices were imposed on the Putative Class Members.   57.  The Putative Class Members were all improperly classified as exempt and not paid  overtime compensation when they worked in excess of forty (40) hours per week.   58.  Defendants failure to pay wages and overtime compensation at the rates required by  state and/or federal law result from generally applicable, systematic policies, and practices which are  not dependent on the personal circumstances of the Putative Class Members.   59.  Plaintiff’s experiences are therefore typical of the experiences of the Putative Class  Members.   60.  The specific job titles or precise job locations of the Putative Class Members do not  prevent class or collective treatment.     61.  Plaintiff has no interest contrary to, or in conflict with, the Putative Class Members.  Like each Putative Class Member, Plaintiff has an interest in obtaining the unpaid overtime wages  owed to them under state and/or federal law.   63.  Absent this action, many Putative Class Members likely will not obtain redress of their  injuries and Defendants will reap the unjust benefits of violating the FLSA and applicable state labor  laws.   64.  Furthermore, even if some of the Putative Class Members could afford individual  litigation against Defendants, it would be unduly burdensome to the judicial system.    65.  Concentrating the litigation in one forum will promote judicial economy and parity  among the claims of individual members of the classes and provide for judicial consistency.   67.  Plaintiff’s claims are typical of the claims of the Putative Class Members. Plaintiff and  the Putative Class Members sustained damages arising out of Defendants’ illegal and uniform  employment policy.    68.  Plaintiff knows of no difficulty that will be encountered in the management of this  litigation that would preclude its ability to go forward as a collective or class action.   69.  Although the issue of damages may be somewhat individual in character, there is no  detraction from the common nucleus of liability facts. Therefore, this issue does not preclude  collective and class action treatment.  X. 