21.  Dominion is one of the nation’s largest producers and transporters of energy.    22.  To provide its services, Dominion uses staffing companies to hire employees to  perform work.   23.  Barker was a Utility Inspector for Dominion.   24.  Barker worked for Dominion on a natural gas pipeline project in Dillon, South  Carolina.   25.  Barker would conduct inpesctions, run inspection reports, and turn them into  Dominion supervisors.   26.  Barker reported to Dominion’s Chief Inspector.    27.  Barker was staffed to Dominion by Hunt, Guillot & Associates.   28.  Hunt, Guillot & Associates is one of Dominion’s many staffing companies.   30.  Dominion supervised and controlled, set pay, determined hours, and approved pay  with respect to Barker and the Putative Class Members.   31.  Many of these individuals worked for Dominion on a day-rate basis and make up the  proposed Putative Class.    32.  While exact job titles and job duties may differ, these workers are subject to the same  or similar illegal pay practices for similar work.     33.  Dominion through its staffing companies paid Barker and the Putative Class Members  a flat sum for each day worked, regardless of the number of hours that they worked that day (or in  that workweek) and failed to provide them with overtime pay for hours that they worked in excess of  40 hours in a workweek.   34.  For example, Barker worked for Dominion from April 2017 to June 2017.    35.  During this time, Barker was paid on a day-rate basis.     36.  Barker and the Putative Class Members normally worked 12 hours a day.   37.  Dominion never guaranteed Barker and the Putative Class Members a salary.   38.  Barker and the Putative Class Members were not paid on a salary basis.   39.  The Putative Class Members worked hours similar to Barker.    40.  The Putative Class Members were denied overtime by the same illegal pay practice that  resulted in Barker being denied overtime wages.    41.  Failing to pay Barker and the Putative Class Members overtime violates the FLSA  because these workers are non-exempt.   47.  Barker incorporates all previous paragraphs and alleges that the illegal pay practices  Dominion imposed on Barker were likewise imposed on the Putative Class Members.   48.  Numerous individuals were victimized by this pattern, practice, and policy which is in  willful violation of the FLSA.    49.  Numerous other individuals who worked with Barker indicated they were 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.   51.  The Putative Class Members were all not afforded the overtime compensation when  they worked in excess of 40 hours per week.   52.  Dominion’s failure to pay wages and overtime compensation at the rates required by  law result from generally applicable, systematic policies, and practices which are not dependent on the  personal circumstances of the Putative Class Members.   53.  Barker’s experiences are therefore typical of the experiences of the Putative Class  Members.   54.  The specific job titles or precise job locations of the Putative Class Members do not  prevent collective treatment.     55.  Barker and the Putative Class Members all performed work in furtherance of the  power industry.    56.  Barker has no interests contrary to, or in conflict with, the Putative Class Members.    57.  Like each Putative Class Member, Barker has an interest in obtaining the unpaid  overtime wages owed to him under state and/or federal law.   58.  A collective action, such as the instant one, is superior to other available means for fair  and efficient adjudication of the lawsuit.    59.  Absent this action, many Putative Class Members likely will not obtain redress of their  injuries and Dominion will reap the unjust benefits of violating the FLSA.   60.  Furthermore, even if some of the Putative Class Members could afford individual  litigation against Dominion, it would be unduly burdensome to the judicial system.    62.  Barker’s claims are typical of the claims of the Putative Class Members. Barker and the  Putative Class Members sustained damages arising out of Dominion’s illegal and uniform employment  policy.    63.  Although the issue of damages may be somewhat individual in character, there is no  detraction from the common nucleus of liability facts.    64.  Therefore, this issue does not preclude collective action treatment. 