Gonzalez v. Quadrant Capital Advisors, Inc.

Background

Monica Gonzalez brought this Fair Labor Standards Act case against Quadrant Capital Advisors, Inc. and Carla Brillembourg. The parties reported that they had reached a settlement in principle. The opinion does not state the settlement’s terms.

Court’s analysis

Under Second Circuit law, the court must review a Fair Labor Standards Act settlement, including any proposed award of attorney’s fees, to determine whether it is fair. The court directed the parties to submit a joint letter by January 31, 2025, explaining the basis for the proposed settlement and why it should be approved as fair and reasonable. The letter must address confidentiality provisions, non-disparagement provisions, and releases. If the settlement includes an attorney-fee award, the parties must address that award and provide supporting documentation when appropriate. The court stated that merely identifying the fee’s proportion of the settlement is insufficient; adequate support generally includes contemporaneous records showing each attorney’s date of work, hours spent, and work performed. Insufficient documentation could lead the court to reject the proposed fee award.

Order and next steps

The court directed the parties to appear by telephone for a settlement fairness hearing on February 5, 2025, at 2:00 p.m. Gonzalez was requested to attend and, if necessary, to use an interpreter. Any pending motions were dismissed as moot, and all conferences and deadlines—including trial and pretrial deadlines—were canceled. The order did not approve or reject the proposed settlement at this stage.