23.  Williams claims that “For more than a century, [Williams] has provided valuable energy  infrastructure that Americans count on every day. [Williams] has a long successful history of doing  things right—[Williams] doesn’t take shortcuts and [Williams] treats people, the environment, and  communities with respect.”1 To complete their business objectives, Williams hires inspector personnel  (like Fairchild) to perform work.   24.  Many of these individuals worked for Williams on a day-rate basis and make up the  proposed Putative Class. While exact job titles and job duties may differ, these employees are subjected  to the same or similar illegal pay practices for similar work.     25.  Williams paid 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 forty (40) hours in a workweek.   26.  For example, Fairchild worked for Williams throughout 2019. During his employment  with Williams, he was paid on a day-rate basis.     27.  Fairchild normally worked 10 to 12 hours a day for six days a week.   28.  Fairchild was never guaranteed a salary when he worked for Williams.   30.  The work Fairchild performed was an essential and integral part of Williams’ core  business.   31.  During Fairchild’s employment with Williams, it and/or the company Williams  contracted with exercised control over all aspects of his job.     32.  Williams and/or the company it contracted with controlled all the significant or  meaningful aspects of the job duties performed by Fairchild.   33.  Even though Fairchild often worked away from Williams’ offices, Williams still  controlled all aspects of Fairchild’s job activities by enforcing mandatory compliance with Williams’  and/or its client’s policies and procedures.   34.  Williams directly determined Fairchild’s rates of pay, his work schedule, and prohibited  him from working other jobs for other companies while he was working on jobs for Williams.   35.  Very little skill, training, or initiative was required of Fairchild to perform his job duties.   36.  Indeed, the daily and weekly activities of the Putative Class Members were routine and  largely governed by standardized plans, procedures, and checklists created by Williams and/or its  clients. Virtually every job function was pre-determined by Williams and/or its clients, including the  tools to use at a job site, the data to compile, the schedule of work, and related work duties. The  Putative Class Members were prohibited from varying their job duties outside of the pre-determined  parameters.    37.  Moreover, the job functions of the Putative Class Members were primarily manual  labor/technical in nature, requiring no college education or other advanced degree.    39.  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.   40.  The Putative Class Members also worked similar hours and were denied overtime as a  result of the same illegal pay practice.    41.  Williams’ policy of failing to pay its inspectors, including Fairchild, overtime violates  the FLSA and PMWA because these workers are performing non-exempt job duties.   42.  It is undisputed that Fairchild and the Putative Class Members are performing manual  labor and working long hours out in the field.   43.  Williams’ day-rate system violates the FLSA and PMWA because Fairchild and those  similarly situated did not receive any overtime pay for hours worked over 40 hours each week.  VI.  55.  Fairchild incorporates all previous paragraphs and alleges that the illegal pay practices  Williams imposed on Fairchild were likewise imposed on the Putative Class Members.   57.  Numerous other individuals who worked with Fairchild 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.   58.  Based on his experiences and tenure with Williams, Fairchild is aware that Williams’  illegal practices were imposed on the Putative Class Members.   59.  The Putative Class Members were all not afforded the overtime compensation when  they worked in excess of forty (40) hours per week.   60.  Williams’ 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.   61.  Fairchild’s experiences are therefore typical of the experiences of the Putative Class  Members.   62.  The specific job titles or precise job locations of the Putative Class Members do not  prevent class or collective treatment.     63.  Fairchild has no interests contrary to, or in conflict with, the Putative Class Members.  Like each Putative Class Member, Fairchild has an interest in obtaining the unpaid overtime wages  owed to him under state and/or federal law.   64.  A collective action, such as the instant one, is superior to other available means for fair  and efficient adjudication of the lawsuit.    65.  Absent this action, many Putative Class Members likely will not obtain redress of their  injuries and Williams will reap the unjust benefits of violating the FLSA, PMWA, and any other  applicable state labor laws.   67.  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.   68.  The questions of law and fact common to the Putative Class Members predominate  over any questions affecting solely the individual members. Among the common questions of law and  fact are:  a.  Whether Williams employed the Putative Class Members within the meaning  of the applicable state and federal statutes, including the FLSA and PMWA;  b.  Whether Williams’ day rate pay practice meets the salary-basis test;   c.  Whether Williams’ decision to not pay time and a half for overtime to the  Putative Class Members was made in good faith;   d.  Whether Williams’ violation of the FLSA was willful; and   e.  Whether Williams’ illegal pay practices were applied uniformly across the  nation to all Putative Class Members.   69.  Fairchild’s claims are typical of the claims of the Putative Class Members. Fairchild  and the Putative Class Members sustained damages arising out of Williams’ illegal and uniform  employment policy.    70.  Fairchild knows of no difficulty that will be encountered in the management of this  litigation that would preclude its ability to go forward as a class or collective action.   71.  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. 