I am writing this post to give an example of the type of allegations made in an oil field overtime lawsuit.  Here is language from a lawsuit regarding top-drive technicians in an oil field overtime lawsuit.

Oil Field Overtime Lawsuit

• Defendant has approximately 330 marketable land-based drilling rigs that operate primarily in oil and natural gas producing regions of Texas, New Mexico, Oklahoma, Arkansas, Louisiana, Mississippi, Colorado, Utah, Wyoming, Montana, North Dakota, Pennsylvania, West Virginia, Ohio and Western Canada.
• Plaintiff worked for Defendant at its Springtown, Texas location as a top drive maintenance technician from approximately July, 2011 to November 2, 2012.
• During the time period, Plaintiff’s’ job responsibilities consisted of addressing, as directed by Defendant, the maintenance of the top drive motors on the drilling rigs at Defendant’s work locations and drilling rigs in or near Springtown, Texas.
• Plaintiff’s primary job duties consisted of manual labor tasks in the form of repair, maintenance and other non-office, manual labor work.  Plaintiff was also responsible for various other non-discretionary tasks.  These other non-discretionary tasks Plaintiff performs are routine and do not require the exercise of independent judgment or discretion.
• At all times during his employment, Plaintiff was treated as an exempt employee for purposes of the FLSA, was paid a salary for his work, and was not paid time and one-half his regular rate of pay for hours worked in excess of 40 hours in a work week.
• Defendant knowingly, willfully, or with reckless disregard carried out its illegal pattern or practice of failing to pay overtime compensation with respect to Plaintiff.
• The FLSA requires employers to keep accurate time records of hours worked by nonexempt employees.  29 U.S.C. § 211 (c).
• In addition to the pay violations of the FLSA identified above, Defendant also failed to keep proper time records as required by the FLSA.
• Plaintiff has retained the Law Office of Chris R. Miltenberger, PLLC to represent him in this litigation and has agreed to pay a reasonable fee of its services.

This is the type language included in oil field overtime lawsuit.