Raamanuj v. Zaika Food Company LLC
- Katharine Parker
- 1:20-cv-04317
- U.S. District Court · Southern District of New York
- 2
In Raamanuj v. Zaika, Judge Torres required court or Department of Labor approval before any settlement-based dismissal with prejudice.
The parties to the FLSA case, including Sharma Raamanuj and the defendants, as well as the plaintiff’s attorney regarding any fee request.
What happened
Sharma Raamanuj sued Zaika Food Company LLC, doing business as Zaika, and Mandeep S Oberoi and Pooja S Patel under the Fair Labor Standards Act. The parties informed the court that they had reached a settlement in principle.
The court said the case could not be dismissed with prejudice based on the settlement unless the court or the Department of Labor approved the agreement. It required any approval request or proof of Department of Labor approval, along with the settlement agreement, to be filed publicly by December 3, 2021.
Judge Torres also required the parties to address the settlement’s fairness, any dispute about hours worked or compensation owed, and the plaintiff’s attorney-fee request, with billing records supporting any fees. Pending motions were declared moot, and all conferences were vacated.
The detailed version
- Raamanuj v. Zaika Food Company LLC · No. 1:20-cv-04317
- Katharine Parker
- Nov. 3, 2021
Background
The opinion states that this was a Fair Labor Standards Act (FLSA) case brought by Sharma Raamanuj against Zaika Food Company LLC, doing business as Zaika, Mandeep S Oberoi, and Pooja S Patel. The parties advised the court that they had reached a settlement in principle.
Settlement approval requirements
The court ordered that the action could not be dismissed with prejudice based on the settlement unless either the court or the Department of Labor approved the settlement agreement. To seek dismissal with prejudice, the parties had to file either a joint letter motion asking the court to approve the agreement or documentation showing Department of Labor approval. The filing, including the settlement agreement, had to be made on the public docket by December 3, 2021.
The court required any joint letter motion to explain why the proposed settlement was fair and reasonable. It identified these minimum topics: the plaintiff’s possible recovery; the burdens and expenses the settlement would avoid; the seriousness of the litigation risks; whether experienced counsel negotiated the agreement at arm’s length; and the possibility of fraud or collusion. The parties also had to address whether a genuine dispute existed about the number of hours worked or the compensation owed, and how much of the settlement the plaintiff’s attorney would seek as fees.
Attorney fees and settlement terms
Any request for attorney fees had to include contemporaneous billing records showing, for each attorney, the date, hours worked, and nature of the work. The court stated that, absent special circumstances, it would not approve a settlement filed under seal or in redacted form. It also stated that, absent compelling circumstances, it would not approve an agreement containing sweeping nondisclosure provisions or broad releases of claims unrelated to FLSA issues.
Disposition
The opinion does not state that the court approved the settlement or dismissed the action. It states that any pending motions were moot and that all conferences were vacated. Judge Analisa Torres entered the order on November 3, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.