Case 7:16-cv-00311-RAJ Document 1 Filed 08/19/16 Page 5 of 9
U.S.C. § 203(s)(1), in that said enterprise has had employees engaged in commerce or in the production of goods for commerce, or employees handling, selling, or otherwise working on goods or materials that have been moved in or produced for commerce by any person and in that said enterprise has had and has an annual gross volume of sales made or business done of not less than $500,000.00 (exclusive of excise taxes at the retail level which are separately stated). 19.
At all relevant times, Plaintiff and Class Members were individual employees
who were engaged in commerce or in the production of goods for commerce as required by 29 U.S.C. §§ 206-207. V. 20.
FACTUAL ALLEGATIONS
Plaintiff incorporates all of the allegations previously made in this Complaint.
Plaintiff brings his collective action allegations individually and on behalf of those similarly situated. 21.
Defendants have been involved in oilfield casing services in oilfields throughout
the United States, including those throughout Texas, New Mexico, Oklahoma and Louisiana over the last three years and do more than $500,000.00 per year in business. 22.
Mike Byrd and Kay Hight acted as the chief executive officer and financial
executive, respectively, of a former entity, Mike Byrd Casing Crews, Inc., f/k/a Mike Byrd Casing Crews GP, LLC and Mike Byrd Casing Crews, Ltd. Mike Byrd Casing Crews, Inc. performed the same work as the Defendants’ perform today: Providing Oilfield Casing Services. Defendant Mike Byrd and the Corporate Defendants share a mailing address located at P.O Box 7269, Abilene, TX 79608. Mike Byrd serves both in an ownership and managerial capacity of Byrd Management and BPU. Defendant BPU and Defendant Kay Hight are co-directors of Byrd Services. Mike Byrd Casing Crews, Inc. continues to operate through the named Individual
PLAINTIFF’S ORIGINAL COMPLAINT
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