Teitelbaum v. Springs Window Fashions, LLC

Background

The parties reached a settlement in principle. The case was brought under the Fair Labor Standards Act, a federal law governing issues such as minimum wages and overtime pay. Under Second Circuit law, the court must review the settlement, including any proposed attorney-fee award, to determine whether it is fair.

Required Submission

Judge Liman ordered the parties to submit a joint letter by January 20, 2023, explaining the basis for the proposed settlement and why the court should approve it as fair and reasonable. The letter must address the fairness factors identified in Wolinsky v. Scholastic, Inc. and any confidentiality provisions, non-disparagement provisions, or releases in the settlement agreement.

If the proposed 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 requested fee as a percentage of the settlement amount is insufficient. The fee analysis should ordinarily include contemporaneous time records showing, for each attorney, the date, hours worked, and nature of the work. Insufficient documentation could lead the court to reject the proposed fee award.

Ruling and Next Step

The court did not approve or reject the settlement in this order. It required additional information and directed the parties to appear by telephone for a settlement-approval hearing on January 24, 2023, at noon. The plaintiff was required to attend and, if necessary, to do so with an interpreter.