1   21   22.  Defendant ABS is a full service contracting company that provides janitorial,  2  maintenance, general contracting, and movie production services to both small and large clients.  3  Defendant Troy Strahan is an owner of ABS.   4   23.  Defendants employ at least twenty manual laborers at each jobsite. Defendants  5  operate multiple jobsites simultaneously. Defendants required their employees to wear shirts  6  bearing the name “ABS” while working at their jobsites.   7   24.  Defendants’ employees, including Plaintiff herein, regularly handle goods that are  8  moving or have moved in interstate commerce and/or perform duties which are closely related  9  and directly essential to such interstate activities.  10   25.  Plaintiff normally worked more than forty hours a week for Defendants. On  11  average, Plaintiff worked between 50 and 55 hours per week. Defendants often required Plaintiff  12  to work at least six days per week.   13   26.  Plaintiff was paid by check.  14   27.  Defendants never paid Plaintiff one-and-half times his hourly rate for all hours  15  worked in excess of forty in a workweek.  16   28.  Defendants willfully violated Plaintiff’s rights under the FLSA because  17  Defendants knew or showed reckless disregard for the fact that their compensation practices  18  violated the FLSA.  Defendants were and are aware of the custom and practice of overtime pay  19  from their experience and expertise in the industry in which they work.   20  32.  Plaintiff incorporates by reference each of the preceding allegations as though  8  fully set forth herein.  9   33.  Plaintiff brings the claims set forth in Count I, alleging violations of the FLSA, as  10  a putative collective action on behalf of himself and an “FLSA Overtime Class,” consisting of all  11  current and former employees of Defendants who are or have been employed by Defendants  12  performing manual labor during the three years immediately preceding the filing of this suit as  13  hourly or non-exempt employees and who, during that period, worked in excess of forty hours in  14  any work week and failed to receive premium pay, at the rate of one-and-a-half times their  15  regular rate of pay, for all hours worked in excess of forty in a workweek.  16   34.  Defendants willfully violated the overtime provisions of the FLSA, 29 U.S.C. §  17  207(a) by not paying Plaintiff and other similarly situated employees one-and-a-half times their  18  regular rate for all hours worked in excess of forty in a workweek from at least April 2015 and  19  continuing until the present.   20   6  Fair Labor Standards Act – FLSA Overtime Class  7  