Plaintiff, Defense Counsel Worked with the Court to Agree on Form Agreement Terms

Together with a committee of plaintiff and defense counsel, the Court has developed three form wage and hour settlement agreements designed to streamline the parties’ negotiation process, help them come to an agreement on proposed settlements faster and make it easier for judges to review and approve them more efficiently, Presiding Judge Eric C. Taylor announced today.

“These comprehensive settlement forms provide a template allowing attorneys to more easily draft class action settlement agreements, with content they know is likely to be approved by the Court,” Presiding Judge Taylor said. “I want to extend my sincere gratitude to Judge Amy Hogue for spearheading this efficiency with the support of Supervising Judge of Civil David J. Cowan and Administrative Assistant Supervising Judge of the Complex Civil Litigation Program David S. Cunningham III. Together they worked collaboratively with 16 attorneys to draft these model forms so we can resolve these cases with the utmost economy.” Judge Cunningham and Judge Hogue, as co-chairs of the Ad Hoc Wage and Hour Committee, thanked the attorneys for their work on the forms, particularly Eric B. Kingsley of Kingsley & Kingsley who chaired the 8-member plaintiff attorneys’ group and Allison S. Wallin of Raines Feldman who chaired the 8-member defense attorneys’ group. Together, the committee drafted and approved:

The Court is encouraging counsel to draft their settlement agreements using the appropriate form as the basis and to support their motions for approval by filing a redlined version comparing their agreement to the form agreement.

“Up to now, the Court has had to evaluate lengthy settlement agreements and proposed class notices filed with various formats, organization, and content unique to each attorney,” Judge Hogue said. “If we can receive form agreements and notices with redlined versions for comparison, we can basically eliminate the Court’s tedious paragraph-by-paragraph review. The attorneys are enthusiastic because they see tangible benefits to their clients such as less back-and-forth negotiation, less wordsmithing, and improved chances of success on their motions for court approval.”

The optional forms are available on the Court’s website as of June 29, 2022.

You can see the full notice here.

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