Park v. Hanpool, Inc.
- Sarah Cave
- 1:23-cv-11309
- U.S. District Court · Southern District of New York
- 2
In Park v. Hanpool, Judge Cave required counsel to document settlement costs before evaluating approval of the parties’ wage-and-hour settlement.
The plaintiffs’ counsel must provide invoices or receipts supporting the costs requested as part of the proposed FLSA settlement. The order also affects the parties’ pending request for settlement approval because the court has not completed its evaluation.
What happened
Park v. Hanpool, Inc. is a wage-and-hour case under the Fair Labor Standards Act, a federal law governing issues such as minimum wages and overtime pay. The parties asked the court to approve their proposed settlement, including payments for attorneys’ fees and costs.
The court said it needed invoices or receipts to evaluate the requested settlement costs. The materials submitted included billing records but did not include the required supporting invoices or receipts for the listed expenses.
Judge Sarah L. Cave ordered the plaintiffs’ counsel to submit invoices or receipts by May 19, 2025. The order requires more documentation; it does not state that the settlement was approved or denied.
The detailed version
- Park v. Hanpool, Inc. · No. 1:23-cv-11309
- Sarah Cave
- May 12, 2025
Background
This case concerns wage-and-hour claims under the Fair Labor Standards Act (FLSA). The parties consented to Judge Cave’s authority to decide the matter and submitted a proposed settlement, a motion asking for approval, and supporting exhibits. The request was made under the requirement that courts review FLSA settlements.
Court’s analysis
The court explained that when an FLSA settlement includes attorneys’ fees, it must evaluate whether the fee award is reasonable. Counsel must provide evidence supporting the award, including billing records showing each attorney’s work date, hours, and the nature of the work. The proposed agreement included an allocation for attorneys’ fees and costs, but the plaintiffs did not provide invoices or receipts supporting the listed disbursements. The court stated that a notation in counsel’s billing records was not enough to evaluate the requested costs.
Order
The court ordered the plaintiffs’ counsel to submit documentation of the requested costs—specifically, invoices or receipts—by Monday, May 19, 2025. The order does not state that the court approved or denied the proposed settlement or the requested fee award. It requires additional documentation before the court can evaluate the request.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.