 Matador is an independent energy company engaged in the exploration, development,  production and acquisition of oil and natural gas resources in the United States.     Its operations “are focused primarily on the oil and liquids-rich portion of the  Wolfcamp and Bone Spring plays in the Delaware Basin in Southeast New Mexico and West Texas”  and “in the Eagle Ford shale play in South Texas and the Haynesville shale and Cotton Valley plays  in Northwest Louisiana and East Texas.”1    To complete its business objectives, Matador hires personnel to perform the necessary  work.     Over the past three years, Matador employed dozens of individuals – including Martin  – as Rig Hands, Directional Drillers, Mud Engineers, Mud Loggers, and Drilling Superintendents (or  similar positions) in several states.      While exact job titles and job duties may differ, these oilfield workers are subjected to  the same illegal pay practice for similar work.     Specifically, Matador paid these workers a flat sum for each day worked, regardless of  the number of hours that they worked that day (or in that workweek) and failed to pay them overtime  for hours worked in excess of 40 hours in a workweek.    For example, Matador employed Martin as a Drilling Superintendent from  approximately June 2016 through February 2018.     As a Drilling Superintendent, Martin’s primary job duties included observing drilling  operations on the rig and ensuring that the team followed safety protocol.     Martin worked well in excess of 40 hours each week while employed by Matador.    The work Martin performed was an essential part of Matador’s core business.    During Martin’s employment with Matador while he was classified as an independent  contractor, Matador exercised control over all aspects of his job.     Matador did not require any substantial investment by Martin for him to perform the  work required of him.    Matador determined Martin’s opportunity for profit and loss.     Indeed, Matador controlled all the significant or meaningful aspects of the job duties  performed by Martin.    Matador controlled the hours and locations Martin worked, the tools he used, and the  rate of pay he received.    Matador controlled all aspects of Martin’s job activities by enforcing mandatory  compliance with Matador’s policies and procedures.    He worked on Matador’s well sites and utilized equipment and software provided by  Matador to perform his job duties on Matador’s behalf.    Martin did not provide the equipment he used on a day-to-day basis.     Matador made the large capital investments in buildings, machines, drilling equipment,  personnel, tools, and supplied in the business in which Martin worked.    Martin did not incur operating expenses like rent, payroll, and marketing.    Martin was economically dependent on Matador during his employment.    Matador directly determined Martin’s opportunity for profit and loss.     Very little skill, training, or initiative was required of Martin to perform his job duties.    Martin performed routine duties that were largely dictated by Matador.    Martin was not employed by Matador on a project-by-project basis.    In fact, while Martin was classified as an independent contractor, he was regularly on  call for Matador and was expected to drop everything and work whenever needed.    The daily and weekly activities of the Day Rate Workers were routine and largely  governed by standardized plans, procedures, and checklists created by Matador.     Virtually every job function was pre-determined by Matador, including the tools to use  at a job site, the data to compile, the schedule of work, and related work duties.     The Day Rate Workers were prohibited from varying their job duties outside of the  pre-determined parameters.     Moreover, the job functions of the Day Rate Workers were primarily manual  labor/technical in nature, requiring little to no official training, much less a college education or other  advanced degree.    For the purposes of an FLSA overtime claim, the Day Rate Workers performed  substantially similar job duties related to servicing oil and gas operations in the field.    The Day Rate Workers also worked similar hours and were denied overtime as a result  of the same illegal pay practice.     The Day Rate Workers all worked in excess of 40 hours each week and were often  scheduled for daily 12-hour shifts for weeks at a time.     Instead of paying them overtime, Matador paid the Day Rate Workers a day-rate.    Matador’s policy of failing to pay its independent contractors, including Martin,  overtime violates the FLSA because these workers are, for FLSA purposes, non-exempt employees.    It is undisputed that the contractors are maintaining and working with oilfield  machinery, performing manual labor, and working long hours out in the field.    These Day Rate Workers carry out the hands-on, day-to-day production work of  Matador.    Because Martin and the other Day Rate Workers were misclassified as an independent  contractors, Matador owes them overtime for all hours worked in excess of 40 hours in a workweek.     Despite knowing the FLSA and NMMWA’s requirements, Matador failed to pay  Martin and the Day Rate Workers overtime for hours worked in excess of 40 hours in a single  workweek.   Numerous individuals were victimized by this pattern, practice, and policy which is in  willful violation of the FLSA and the NMMWA.    Dozens of other individuals who worked with Martin indicated they were improperly  classified as contractors, paid in the same manner, performed similar work, and were not properly  compensated for all hours worked as required by state and federal wage laws.     Matador employed dozens of Day Rate Workers across New Mexico, Texas, and  Louisiana. As a result, joinder of their individual claims is impracticable, and a class and collective  action serves the interests of judicial economy.    Based on his experiences and tenure with Matador, Martin is aware that Matador’s  illegal practices were imposed on other Day Rate Workers.      Matador used day rate contractors across the United States.     The Day Rate Workers (including the subset that makes up the NMMWA Class) were  all improperly classified as contractors and not afforded overtime compensation when they worked in  excess of forty 40 hours per week.    Matador is an “employer” of Martin and the Day Rate Workers.     Matador’s failure to pay wages and overtime compensation at the rates required by  state and/or federal law result from generally applicable, systematic policies, and practices which are  not dependent on the personal circumstances of the Day Rate Workers.      Martin’s experiences are therefore typical of the experiences of the Day Rate Workers.     The specific job titles or precise job locations of the Day Rate Workers do not prevent  class or collective treatment.     Martin has no interests contrary to, or in conflict with, the members of the class.     A class and collective action, such as the instant one, is superior to other available  means for fair and efficient adjudication of the lawsuit.     Absent this action, many members of the class likely will not obtain redress of their  injuries and Matador will reap the unjust benefits of violating the FLSA and the NMMWA.  