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S.D.N.Y.Procedural orderFiled Dec. 23, 2019

Saenz v. S.W. Management LLC

Judge
Barbara Moses
Docket
1:19-cv-05717
Court
U.S. District Court · Southern District of New York
Pages
2
FlsaContractCivil Procedure
In one sentence

In Saenz v. S.W. Management LLC, Judge Nathan ordered briefing on whether Saenz’s signature created an enforceable settlement contract.

Who this affects

Pedro Saenz and the defendants, including S.W. Management LLC, because the court required briefing before deciding whether their proposed settlement was enforceable and could be approved.

What happened

In Saenz v. S.W. Management LLC, the parties told the court that their Fair Labor Standards Act and New York Labor Law case had settled. The court required them to submit the settlement for fairness review, but the agreement submitted by Saenz was signed only by him.

The defendants asked the court to reject the settlement, saying it was not final and did not accurately reflect their agreement. The court identified the question whether Saenz’s November 30, 2019 signature on the agreement sent by the defendants created an enforceable contract.

Judge Alison J. Nathan ordered Saenz to file a brief by January 6, 2020, the defendants to respond by January 20, and Saenz to file a reply by January 27. The order did not decide whether the settlement was enforceable or approve the settlement.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Saenz v. S.W. Management LLC · No. 1:19-cv-05717
Judge
Barbara Moses
Date
Dec. 23, 2019

Background

Pedro Saenz brought this action under the Fair Labor Standards Act and New York Labor Law against S.W. Management LLC and other defendants. On October 30, 2019, the parties informed the court that the action had settled. The court then ordered them to submit their settlement agreement so it could review the agreement’s fairness, as required for the type of settlement at issue.

On December 9, 2019, Saenz moved for approval of the settlement and attached an agreement signed only by him. Saenz stated that he had accepted the agreement the defendants sent by email. The next day, the defendants asked the court to reject the settlement, arguing that it was not final and did not accurately reflect the parties’ agreement. Saenz filed a reply on December 11.

Issue

The court ordered briefing on whether Saenz’s signature, dated November 30, 2019, on the agreement sent by the defendants on November 25, 2019, created an enforceable contract. The court cited a prior appellate decision identifying factors that may help determine whether parties intended to be bound when both sides have not signed a document.

Order and effect

Judge Alison J. Nathan ordered Saenz to file a brief of no more than fifteen pages by January 6,

  1. The defendants were ordered to file a brief of no more than fifteen pages by January 20,
  2. Saenz could file a reply of no more than eight pages by January 27,
  3. The opinion did not decide whether the parties formed an enforceable settlement contract and did not approve or reject the settlement at that stage.
The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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