16. Plaintiff worked for Defendant as a construction worker. Plaintiffs’ primary   duty was to travel to job sites in Defendant’s company truck and complete heavy construction  work using rigs, cement, and steel.   17. From the beginning of Plaintiff’s employment to present, Defendant paid Plaintiff  an hourly rate of $20 an hour.   19.  Defendant tracks Plaintiff’s hours by requiring him to punch in and out   on a time card.   20. Additionally, Plaintiff is allowed to punch in before driving the company truck to the   job site, but is required to punch out right after leaving the job site and before dropping the truck  back off- leaving morning travel time paid, but travel time home unpaid.   21. At all relevant times, Plaintiff and other construction workers were paid on a hourly   basis, and were not paid overtime compensation for hours they worked over 40 in a workweek.  They were only paid overtime compensation for hours they worked over 45 in a workweek.   22. During the relevant time period, as a matter of company policy and practice, Plaintiff   and other construction workers regularly worked more than 40 hours per week and were not paid  the correct overtime compensation.   23. Through its unlawful actions, Defendant deprived Plaintiff and other construction   workers of overtime wages owed to them.   24. Defendant acted willfully in failing to pay overtime compensation to Plaintiff and   other construction workers for hours they worked over 40 in a workweek. Defendant knew or  should have known that construction workers were required to be classified as non-exempt  employees under the FLSA and paid overtime compensation for hours worked over 40 in a  workweek.  24.  As set forth above, Defendant’s failure to pay overtime compensation to  employees who have worked for Defendant as construction workers and who have not received  overtime compensation during the three-year period preceding the filing of this Complaint  violates the Fair Labor Standards Act, 29 U.S.C. § 207.  This claim is brought by the named  Plaintiff on behalf of himself and all other similarly situated employees pursuant to 29 U.S.C. §  216(b).   26. The claims under the FLSA meet the requirements for collective action certification  set forth in 29 U.S.C. § 216(b).   27. Dynasty has engaged in a widespread pattern and practice of violating the FLSA, as  detailed in this Complaint.   28. All potential opt-in plaintiffs are similarly situated, because they were all employed  by Dynasty as construction workers, primarily performed the same or similar job duties, Dynasty  classified all of them as exempt under the FLSA and did not pay them overtime, and Dynasty’s  compensation practices are uniform as to all potential plaintiffs, and result in the alleged  violation of the FLSA.  29. Plaintiff realleges and incorporates by reference Paragraphs 1-28 as if alleged fully   here.  