Grant v. Warner Music Group Corp. et al

Filing 86

ORDER granting 85 Letter Motion for Extension of Time to File settlement documents. The Application is granted. The clerk will terminate Dkt. No. 85. (Signed by Judge Paul G. Gardephe on 1/29/2015) (kko)

Case 1:13-cv-04449-PGG Document 85 Filed 01/22/15 Page 1of2

VIRGINIA
& AMBINDER LLP
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USDSSDNY
DOCUMENT
ELECTRONICALLY FILED
DOC#:
DATE FILED:

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40 Broad Street, 7th Floor
New York, New York 10004
Telephone: [phone]
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Lloyd R. Ambinder
212.943.9081

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January 22, 2015

The Application is granted.

VIA ECF & FACSIMILE 212 805-7986
The Honorable Paul G. Gardephe
United States District Court
Southern District of New York
40 Centre Street
New York, New York 10007
Re:

SO ORDERED:

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Paul Gfd~hr:tt.J.
Dated:

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Grant, et al. v. Warne Music Group Corp et al.
No. 13 Civ. 4449 (PG )

Henry, et al. v. Warne Music Group Corp et al.
No. 13 Civ. 5031 (PG )
Dear Judge Gardephe,
This firm, along with Leeds Brown L P, and Maurice Pianko, Esq. represent Plaintiffs in
the above-referenced wage and hour actions. I write on behalf of all parties to inform the Court of
the status of our settlement efforts, and to fespectfully request 45 additional days to move for
preliminary approval of the settlement agree ent.
On November 17, 2014, the parties eported that they had reached an agreement on the
basic parameters of a class-wide settlement, s bject to working out additional terms and subject to
documentation. In my December 23, 2014 1 tter to you, I requested a 30-day adjournment of the
deadline for Plaintiffs to publish Court-auth rized so that the parties could draft the settlement
documents, and submit them to this Court fo approval. It was our goal to publish a single notice
that would encompass the terms of the prop sed settlement, as well as provide notice regarding
the FLSA portion of this lawsuit. In light oft e complexities of the settlement, and the intervening
holidays, it appears our 30 day filing request as a bit ambitious.
The parties have agreed upon the ubstantive terms of settlement which have been
memorialized in a term sheet. Moreover, e have drafted initial versions of the settlement
agreement and release, publication order, fi al order, notice of settlement and claim form, and
expect to exchange them with Defendants' co nsel by close of business tomorrow. The details of
the settlement are somewhat complex, and it 1•s taken us a little longer than anticipated to resolve

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Case 1:13-cv-04449-PGG Do9ument 85 Filed 01/22/15 Page 2 of 2

VIRGINIA
& AMBINDER LLP
Attofot"ys

at

Law

a few legal and procedural issues, including slttlement administration. We now expect to complete
the drafting process in the next couple of w eks so that our motion for preliminary approval will
be effectuated by March 9, 2015. As indic ted by today's filings, counsel for Defendants have
recently relocated to a new firm, and thi requested extension also takes into account any
administrative challenges that may be occasi ned by that move.
Respectfully submitted,
ls/Lloyd R. Ambinder
cc:

Lyle Zuckerman, Esq. (via email)
Jeff Brown, Esq. (via email)
Maurice Pianka, Esq. (via email)