13.  Defendant DPS is a horizontal directional drilling business and does business  throughout New Mexico and the United States.  Defendants earn over $500,000.00 per year in  gross sales.     14.  Defendant Gardner holds himself out as the President of DPS in which capacity  he has controlled the day-to-day operations of Defendant DPS. Specifically, during this time  period, Gardner (1) had the power to hire and fire Plaintiff and the Class Members; (2) controlled  the amount Plaintiff and the Class Members were to be paid for each hour of work; and (3)  regularly controlled and established company rules for Plaintiff and the Class Members.    15.  Plaintiff specifically was referred to as an “Inspector” for Defendants during the  three years prior to the filing of this lawsuit, occupied this position for a period of several  consecutive years, and through 2018.    19. Plaintiffs incorporate all allegations previously made in this Complaint.    20. Plaintiffs bring their class action on behalf of the respective NM Class Members.    21. The NM Class Members are so numerous that their joinder is impracticable. While  the precise number of the NM Class Members is unknown, 300 or more Oilfield Workers  worked at least one workweek of more than 40 hours in or out of New Mexico for Defendants  over the past three years.    27.  During the relevant period, Defendants violated and are violating the provisions  of Sections 6 and 7 of the FLSA, 29 U.S.C. §§ 206-7, and 215(a)(2), by employing employees in  an enterprise engaged in commerce or in the production of goods for commerce within the  meaning of the FLSA as aforesaid, for workweeks longer than 40 hours without compensating  such employees for their work in excess of forty hours per week at rates no less than one-and-a- half times the regular rates for which they were employed or by failing to pay minimum wages to  such employees.  Defendants acted willfully in failing to pay Plaintiff and the Class Members in  accordance with the law.  ACCORDANCE WITH THE FAIR LABOR STANDARDS ACT  