Haddoumi v. Ambiance Wine LLC
- Edgardo Ramos
- 1:18-cv-08651
- U.S. District Court · Southern District of New York
- 3
In Haddoumi v. Ambiance Wine LLC, Judge Ramos denied without prejudice approval of a $45,000 labor settlement because counsel lacked billing records.
The ruling affected the two named plaintiffs, the defendants, and plaintiffs’ attorneys by withholding approval of their proposed $45,000 settlement until the requested attorney’s fees could be evaluated or the parties chose to continue to trial.
What happened
Haddoumi v. Ambiance Wine LLC involved Maryem Haddoumi and Andrea Vugec’s request to approve a settlement with Ambiance Wine LLC and the other defendants. The parties previously submitted a settlement proposal that the court declined to approve because its release was too broad and lacked support for the settlement amount and attorney-fee request.
In the revised agreement, the release covered only state and federal labor-law claims that were or could have been raised in this case. The agreement provided $15,000 to each named plaintiff from a $45,000 settlement and $15,000 to their attorneys. Counsel did not provide billing records needed to evaluate whether the requested fees were reasonable.
Judge Ramos denied without prejudice the request to approve the settlement. He allowed the parties to submit billing documentation by June 23, 2020, or jointly state that they were abandoning the settlement and continuing to trial.
The detailed version
- Haddoumi v. Ambiance Wine LLC · No. 1:18-cv-08651
- Edgardo Ramos
- June 9, 2020
Background
Maryem Haddoumi and Andrea Vugec, on behalf of themselves and others similarly situated, and the defendants requested approval of a revised settlement agreement. The defendants were Ambiance Wine LLC, doing business as Vella Wine Bar, Evgenia Huldisch, and Vladislav (“Billy”) Karasik.
The court had declined to approve the parties’ first settlement application on June 21, 2019. It identified two problems: the proposed release of claims was too broad, and the parties had not submitted documentation supporting the settlement amount or the requested attorney’s fees.
Revised Settlement
The revised agreement narrowed the release to state and federal labor-law claims that were or could have been raised in this action. The total settlement amount was $45,000. Each named plaintiff was to receive $15,000. Counsel stated that the plaintiffs’ actual compensatory damages were approximately $15,200 and $10,300, respectively, and that their maximum recoveries were approximately $42,000 and $33,000, respectively.
The agreement allocated $15,000, or one third of the settlement, to plaintiffs’ attorneys. The court explained that it could not determine whether that fee was reasonable without contemporaneous billing records showing, for each attorney, the date, hours worked, and nature of the work. The court also stated that it must independently evaluate fee reasonableness even when fees are calculated as a percentage of the settlement.
Ruling
The court denied without prejudice the parties’ request for approval of the settlement agreement. This ruling did not approve the settlement and did not permanently bar the parties from pursuing approval.
The court gave the parties two options by June 23, 2020: (1) submit a revised letter with billing documentation supporting the requested attorney’s fees, or (2) submit a joint letter stating that they intended to abandon the settlement and continue to trial. If they chose the second option, the court would reopen the case and schedule a pretrial conference.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.