21.  BCforward is a global IT consulting and workforce fulfillment firm that provides  services and resourcing for leading businesses and government organizations.    22.  In order to provide services to its clients, BCforward hires employees it pays on an  hourly basis.   23.  Westerman worked for BCforward as a Senior Project Manager.   24.  As a Senior Project Manager, Westerman had a number of job duties.   25.  Westerman would determine the scope of a project and the costs associated with  projects, review quality of work, and keep projects on time.   26.  Westerman was employed by BCforward from June of 2016 until December of 2018.   27.  Westerman was an hourly employee of BCforward.    28.  When Westerman worked for BCforward, he was paid $70 for every approved hour  that he worked.    29.  Westerman and the Putative Class Members were not paid a guaranteed salary.   4   30.  Westerman worked for BCforward in Indianapolis, Indiana.    31.  BCforward staffed Westerman to Eli Lilly and Company and OneAmerica.   32.  BCforward staffs the Putative Class Members to a wide variety of companies including  healthcare, financial institutions, advisory companies, and the power industry.    33.  Westerman reported the hours he worked to BCforward on a regular basis.    34.  If Westerman and the Putative Class Members worked under 40 hours, they were only  paid for the hours they worked.   35.  But Westerman and the Putative Class Members would regularly work more than 40  hours in a week.    36.  For example, Westerman would routinely work 45 hours every week.    37.  Westerman is paid his standard hourly rate of $70 an hour for the hours he worked  over 40 in a workweek.   38.  The hours Westerman and the Putative Class Members worked are reflected in  BCforward’s payroll records.   39.  BCforward paid Westerman and the Putative Class Members the same hourly rate for  all hours worked, including those hours in excess of 40 hours in a single workweek.   40.  BCforward did not pay Westerman and the Putative Class Members overtime for all  hours worked in excess of 40 hours in a single workweek.   41.  Rather than receiving time and half as required by the FLSA, Westerman and the  Putative Class Members only received “straight time” pay for overtime hours worked.     42.  This “straight time for overtime” payment scheme violates the FLSA.   43.  BCforward was aware of the overtime requirements of the FLSA.     44.  BCforward nonetheless failed to pay certain hourly employees, such as Westerman,  overtime.    5   45.  Westerman and the Putative Class Members also worked similar hours and were  denied overtime because of the same illegal pay practice.   46.  Westerman and the Putative Class Members regularly worked in excess of 40 hours  each week.   47.  BCforward did not pay Westerman and the Putative Class Members on a salary basis.   48.  Any purported “salary” paid to Westerman or the Putative Class Members was not  reasonably related to their actual earnings.1    49.  BCforward paid Westerman and the Putative Class Members “straight time for  overtime.”   50.  BCforward failed to pay Westerman and the Putative Class Members overtime for  hours worked in excess of 40 hours in a single workweek.    51.  BCforward knew, or acted with reckless disregard for whether, Westerman and the  Putative Class Members were paid in accordance with the FLSA.   52.  BCforward’s failure to pay overtime to these hourly workers was, and is, a willful  violation of the FLSA.  53.  Westerman expressly incorporates the preceding paragraphs.    54.  BCforward’s illegal “straight time for overtime” policy extends beyond Westerman.   55.  It is the “straight time for overtime” payment plan that is the “policy that is alleged to  violate the FLSA” in this FLSA collective action. Bursell v. Tommy’s Seafood Steakhouse, No. CIV.A. H- 06-0386, 2006 WL 3227334, at *3 (S.D. Tex. Nov. 3, 2006); Wellman v. Grand Isle Shipyard, Inc., No.  1 The reasonable-relationship test will be met if the weekly guarantee is roughly equivalent to the employee’s usual earnings  at the assigned hourly, daily, or shift rate for the employee’s normal scheduled workweek. Generally, a 1.5 to 1 ratio will  be considered reasonably related. Because BCforward cannot meet the salary-basis test or the reasonable-relationship test,  BCforward’s white-collar defenses are inapplicable.    6  CIV.A. 14-831, 2014 WL 5810529, at *5 (E.D. La. Nov. 7, 2014) (certifying “straight time for  overtime” claim for collective treatment).    56.  BCforward has paid hundreds of hourly workers using the same unlawful scheme.   57.  BCforward paid its employees straight time for overtime regardless of job position or  job duties.    58.  Any differences in job duties do not detract from the fact that these hourly workers  were entitled to overtime pay.    59.  Accordingly, the illegal pay practices BCforward imposed on Westerman were  imposed on the Putative Class Members because they were all paid straight time for overtime.   60.  Numerous individuals were victimized by this pattern, practice, and policy which is in  willful violation of the FLSA.    61.  Numerous other individuals who worked with Westerman were paid in the same  manner and were not properly compensated for all hours worked as required by federal wage laws  regardless of job position or job duties.    62.  Based on his experiences and tenure with BCforward, Westerman is aware that  BCforward’s illegal practices were imposed on the Putative Class Members.     63.  The Putative Class Members were not paid overtime when they worked more than 40  hours per week.   64.  BCforward’s failure to pay overtime at the rates required by federal law result from  generally applicable, systematic policies, and practices which are not dependent on the personal  circumstances of the Putative Class Members.   65.  Westerman’s experiences are therefore typical of the experiences of the Putative Class  Members.  7   66.  The specific job titles or precise job locations of the various members of the Putative  Class Members do not prevent collective treatment.     67.  Westerman has no interests contrary to, or in conflict with, the Putative Class  Members.   68.  Like each Putative Class Member, Westerman has an interest in obtaining the unpaid  overtime wages owed under federal law.   69.  The precise number and the identity of other Putative Class Members is ascertainable  from the business records, tax records, and/or employee or personnel records maintained by  BCforward.    70.  A collective action, such as the instant one, is superior to other available means for fair  and efficient adjudication of the lawsuit.    71.  Absent a collective action, many Putative Class Members will not obtain redress of  their injuries and BCforward will reap the unjust benefits of violating the FLSA.   72.  Furthermore, even if some Putative Class Members could afford individual litigation  against BCforward, it would be unduly burdensome to the judicial system.   73.  If individual actions were required to be brought by each Putative Class Member, it  would necessarily result in a multiplicity of lawsuits and would create hardship to Putative Class  Members, to BCforward, and to the Court.   74.  Concentrating the litigation in one forum will promote judicial economy and parity  among the claims of the Putative Class Members and provide for judicial consistency.   75.  The questions of law and fact common to each of Putative Class Members  predominate over any questions affecting solely the individual members. Among the common  questions of law and fact are:  8  a.  Whether BCforward required Westerman and the Putative Class Members to  work more than 40 hours during individual work weeks;  b.  Whether BCforward’s decision to pay Westerman and the Putative Class  Members straight time for overtime was made in good faith;   c.  Whether BCforward paid Westerman and the Putative Class Members on a  salary basis;  d.  Whether BCforward failed to pay Westerman and the Putative Class Members  at a rate of one and one-half times their regular rate of pay when they worked  more than 40 hours in a single workweek;  e.  Whether BCforward’s violation of the FLSA was willful; and   f.  Whether BCforward’s illegal pay practices were applied to Westerman and the  Putative Class Members.   76.  Westerman and the Putative Class Members sustained damages arising out of  BCforward’s illegal and uniform employment policy.    77.  Westerman 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 action.   78.  Westerman will fairly and adequately represent and protect the interests of the Putative  Class Members.   79.  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 action treatment.  80.  By failing to pay Westerman and the Putative Class Members overtime at one-and- one-half times their regular rates, BCforward violated the FLSA’s overtime provisions.    9   81.  BCforward owes Westerman and the Putative Class Members overtime pay at the  proper overtime rate.    82.  Because BCforward knew, or showed reckless disregard for whether, its pay practices  violated the FLSA, BCforward owes these wages for at least the past three years.    83.  BCforward is liable to Westerman and the Putative Class Members for an amount  equal to all unpaid overtime wages as liquidated damages.   84.  Westerman and the Putative Class Members are entitled to recover all reasonable  attorneys’ fees and costs incurred in this action.   