14.  Throughout the relevant time period, CSRs were employed by Defendant at their  Dallas, Texas Customer Service Department.   50.  Plaintiff seeks to bring this suit as a collective action pursuant to 29 U.S.C. § 216(b)  on her own behalf as well as those in the following collective:   All persons employed by Defendant as Customer Service  Representatives within Dallas, Texas during the relevant time  period, who have been subject to Defendant’s policy “on call”  policy.   51.  At all relevant times, Plaintiff was similarly situated to all such individuals in the  FLSA Collective1 because while employed by Defendant, Plaintiff and all FLSA Plaintiffs  performed similar tasks, were subject to the same laws and regulations, were paid in the same or  substantially similar manner, were paid the same or similar rate, were required to work in excess  of forty (40) hours per work week, and were subject to Defendant’s unlawful “on call” policies  and practices of willfully failing to pay them at the statutorily required rate of one and a half (1½)  times their hourly rate for all hours worked in excess of forty (40) per week.   52.  Defendant is and has been aware of the requirement to pay Plaintiff and the FLSA  Plaintiffs at a rate of one and a half (1½) times their hourly rate for all hours worked in excess of  forty (40) per week, yet willfully failed to do so.   53.  The FLSA Plaintiffs, under Plaintiff’s FLSA claim, are readily discernable and  ascertainable. All FLSA Plaintiff’s contact information is readily available in Defendant’s  records.  Notice of this collective action can be made as soon as the Court preliminarily certifies  the collective.   AS AND FOR A FIRST CAUSE OF ACTION FOR A VIOLATION OF  The Fair Labor Standards Act, 29 U.S.C. §§ 201 et seq., Made by Plaintiff on Behalf of All  FLSA Plaintiffs   I.  General Facts.  