“Defendant suggests that Plaintiff’s complaint fails because he does not allege the total amount of unpaid wages that he deserves.  An FLSA plaintiff is not, however, required to plead the precise amount of unpaid wages to which he is allegedly entitled.”

Murphy v. Multi-Shot, LLC, 2014 WL 4471538, at *2 (S.D. Tex. Sep. 10,

“Plaintiff alleges that the workers are ‘hourly employees’ who ‘supply no materials or tools of their own’ and ‘are directly supervised, directed and controlled by [Owner] and [Supervisor].  These allegations, taken as true, are sufficient to overcome the instant motion to dismiss.”

Stewart v. Caton, 2013 WL 4459981, at *9 (E.D. La. Aug. 13, 2013)

“At this stage, should Plaintiffs prevail on their argument that the bonuses were non discretionary and overtime wages were improperly calculated, this finding would be applicable to a class of all operators or riggers.”

Wilson v. Anderson Perforating, Ltd., 2013 WL 3356046 at *2 (W.D. Tex. July 3, 2013) (Rodriguez, J.).

“Defendant appears to blur the distinction between incidents that may not be considered for purposes of establishing liability for damages, because they occurred outside the limitations period, and what nevertheless may be admissible and probative as background evidence to support a claim based on alleged conduct that falls within the limitations period.”

Arnett v. Sears,

“White clearly stands for the proposition that where an employer prevents its employee from reporting overtime or was otherwise on notice of the employee’s unreported work, an employee may recover damages under the FLSA, regardless of whether the employee exhausted any internal company grievance policy or time correction policy.”

Arnett v. Sears, Roebuck and Co

“[P]laintiff argues that one or two times in 2007, he told his former supervisor (Bob Perkins) hat he was not reporting all of his time and that Mr. Perkins understood and acknowledged he knew of the under-reporting.”

Arnett v. Sears, Roebuck and Co., 2013 WL 3324070 at *2 (W.D. Tex. July 1, 2013) (Rodriguez,

“As for the allegation that Defendants willfully violated the FLSA, that matter contains questions of fact, and at this pleading stage prior to discovery the motion to dismiss it is premature.”

Adkins v. United Airlines, Inc., 2014 WL 803460 at *2 (N.D. Tex. February 28, 2014) (Lynn, J.).

“As for the allegation that Defendants willfully violated the FLSA, that matter contains questions of fact, and at this pleading stage prior to discovery the motion to dismiss it is premature.”

Craven v. Excel Staffing Service, Inc., H-12-2860, 2014 WL 345682 at *6-7 (S.D. Tex. January 30, 2014) (Harmon, J.) (internal citations omitted).

“Plaintiffs’ allegations that they were nonexempt, regularly worked more than forty hours per week, and were not paid time-and-a-half to be factual allegations and not legal conclusions.”

Rodriguez v. Gold & Silver Buyers, Inc., Civ. A. No. 4:12–CV–1831, 2013 WL 5372529 at *3 (S.D.Tex. Sept.24, 2013) (Harmon, J.).

“The Court finds that [the employee] meets his burden to establish that he is similarly situated to other employees in the proposed class.  In his declaration, [the employee] states that he was required to work approximately seventy-three hours per week and was paid a flat rate of $145 per day.  He did not receive overtime