Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 1 of 25 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK.

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1 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 1 of 25 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ERIC GLATT, ALEXANDER FOOTMAN, EDEN ANTALIK, and KANENE GRATTS, on behalf of themselves and all others similarly situated, Plaintiffs, No. 11-CV-6784 (WHP) v. FOX SEARCHLIGHT PICTURES, INC., and FOX ENTERTAINMENT GROUP, INC., Defendants. MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT, CONDITIONAL CERTIFICATION OF THE SETTLEMENT CLASS, APPOINTMENT OF PLAINTIFFS COUNSEL AS CLASS COUNSEL, APPROVAL OF PROPOSED NOTICE OF SETTLEMENT, AND ENTRY OF FINAL JUDGMENT WITH RESPECT TO PLAINTIFF KANENE GRATTS

2 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 2 of 25 TABLE OF CONTENTS INTRODUCTION... 1 I. FACTUAL BACKGROUND... 1 II. PROCEDURAL BACKGROUND... 2 A. Glatt... 2 B. MacKown... 4 C. Mediation and Settlement Negotiations... 4 III. SUMMARY OF THE SETTLEMENT TERMS... 4 A. Settlement Payments... 4 B. Settlement Classes... 4 C. Releases... 5 D. Attorneys Fees and Costs... 6 E. Settlement Claims Administrator... 6 IV. CLASS ACTION SETTLEMENT PROCEDURE... 7 V. PRELIMINARY APPROVAL OF THE SETTLEMENT IS APPROPRIATE... 8 A. The Settlement Is Fair, Reasonable, and Adequate Further Litigation and Trial Would Be Complex, Costly, and Long (Grinnell Factor 1) The Court Cannot Assess the Reaction of the Class Until After Notice Issues (Grinnell Factor 2) Discovery Has Advanced Far Enough to Allow the Parties to Resolve the Case Responsibly (Grinnell Factor 3) Plaintiffs Would Face Risk If the Case Proceeded (Grinnell Factors 4 and 5) Establishing and Maintaining the Class Through Trial Presents Risk (Grinnell Factor 6) Defendants Ability to Withstand a Greater Judgment Is Not Determinative (Grinnell Factor 7) ii

3 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 3 of The Settlement Fund Is Substantial, Even in Light of the Best Possible Recovery and the Attendant Risks of Litigation (Grinnell Factors 8 and 9) VI. CONDITIONAL CERTIFICATION OF THE CLASS IS APPROPRIATE A. Numerosity B. Commonality C. Typicality D. Adequacy E. Certification Is Proper Under Rule 23(b)(3) Common Questions Predominate A Class Action Is a Superior Mechanism VII. PLAINTIFFS COUNSEL SHOULD BE APPOINTED AS CLASS COUNSEL VIII. THE NOTICE PLAN AND CLAIMS PROCESS ARE APPROPRIATE CONCLUSION iii

4 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 4 of 25 TABLE OF AUTHORITIES CASES PAGE(S) Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (1997)...17 Ballinger v. Advance Magazine Publishers, Inc., HBP, No. 13 Civ. 4036, 2014 WL (S.D.N.Y. Dec. 29, 2014)... passim City of Detroit v. Grinnell Corp., 495 F.2d 448 (2d Cir. 1974), abrogated on other grounds by Goldberger v. Integrated Res., Inc., 209 F.3d 43 (2d Cir. 2000)...10, 14 Cnty. of Suffolk v. Long Island Lighting Co., 710 F. Supp (E.D.N.Y. 1989), aff d in part, rev d in part on other grounds, 907 F.2d 1295 (2d Cir. 1990)...14 Consol. Rail Corp. v. Town of Hyde Park, 47 F.3d 473 (2d Cir. 1995)...15 Cordes & Co. Fin. Servs., Inc. v. A.G. Edwards & Sons, Inc., 502 F.3d 91 (2d Cir. 2007)...17 Denney v. Deutsche Bank AG, 443 F.3d 253 (2d Cir. 2006)...16 Dziennik v. Sealift, Inc., No. 05 Civ. 4659, 2007 WL (E.D.N.Y. May 29, 2007)...16 In re EVCI Career Colls. Holding Corp. Sec. Litig., Nos. 05 Civ , 2007 WL (S.D.N.Y. July 27, 2007)...9 Frank v. Eastman Kodak Co., 228 F.R.D. 174 (W.D.N.Y. 2005)...9, 13, 15, 17 Gen. Tel. Co. of Sw. v. Falcon, 457 U.S. 147 (1982)...15 Glatt v. Fox Searchlight Pictures, Inc., 293 F.R.D. 516 (S.D.N.Y. 2013), vacated and remanded, 791 F.3d 376 (2d Cir. 2015), opinion amended and superseded, 811 F.3d 528 (2d Cir. 2016)... passim Green v. Wolf Corp., 406 F.2d 291 (2d Cir. 1968)...18 Lizondro-Garcia v. Kefi LLC, 300 F.R.D. 169 (S.D.N.Y. 2014)...9, 18 iv

5 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 5 of 25 Lynn s Food Stores, Inc. v. United States, 679 F.2d 1350 (11th Cir. 1982)...9 Marisol A. v. Guiliani, 126 F.3d (2d Cir. 1997)...15 Mark v. Gawker Media LLC, No. 13 Civ. 4347, 2016 WL (S.D.N.Y. Mar. 29, 2016)...12 McBean v. City of New York, 228 F.R.D. 487 (S.D.N.Y. 2005)...17 Torres v. Gristede s Operating Corp., Nos. 04 Civ. 3316, 2010 WL (S.D.N.Y. June 1, 2010)...7 In re Traffic Exec. Ass n, 627 F.2d 631 (2d Cir. 1980)...9 In re Visa Check/MasterMoney Antitrust Litig., 280 F.3d 124 (2d Cir. 2001), abrogated on other grounds by Miles v. Merrill Lynch & Co., Inc. (In re Initial Pub. Offering Sec. Litig.), 471 F.3d 24 (2d Cir. 2006)...17 Wal-Mart Stores, Inc. v. Visa U.S.A. Inc., 396 F.3d 96 (2d Cir. 2005)...8, 9 In re Warfarin Sodium Antitrust Litig., 391 F.3d 516 (3d Cir. 2004)...8 OTHER AUTHORITIES Fed. R. Civ. P passim Herbert B. Newberg & Alba Conte, Newberg on Class Actions, (4th ed. 2002)...7, 9, 14 v

6 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 6 of 25 INTRODUCTION Subject to Court approval, Plaintiffs and Defendants in Glatt v. Fox Searchlight Pictures, Inc., No. 11 Civ ( Glatt ), and in the related case, MacKown v. Twenty-First Century Fox, Inc., No. 13 Civ ( MacKown ), have settled these wage and hour class and collective actions for significant relief. The Glatt action, involving claims brought on behalf of unpaid interns, was among the first to be brought nationwide and began an important discussion about the legality of unpaid internships at private employers. After several years of hard-fought litigation, including an appeal to the Second Circuit, the parties have reached a proposed agreement to resolve the claims on a classwide basis. The proposed settlement satisfies all of the criteria for preliminary approval under federal law. With this motion, the parties respectfully request that the Court: (1) grant preliminary approval of the Settlement Stipulation, attached as Exhibit A to the Declaration of Rachel Bien in Support of Plaintiffs Motion for Preliminary Approval of Settlement ( Bien Decl. ); 1 (2) certify the settlement class and appoint Plaintiffs counsel as class counsel; (3) approve the proposed Notice of Class Action Settlement, Claim Form, and Exclusion Form ( Notice Package ), attached as Exhibit A to the Settlement Stipulation, and direct its distribution; and (4) approve the proposed schedule for final settlement approval. I. FACTUAL BACKGROUND Detailed discussions of the facts underlying Plaintiffs claims are set forth in the Court s summary judgment order and the Second Circuit s opinion. See Glatt v. Fox Searchlight Pictures, Inc., 293 F.R.D. 516 (S.D.N.Y. 2013), vacated and remanded, 791 F.3d 376 (2d Cir. 2015), opinion amended and superseded, 811 F.3d 528 (2d Cir. 2016). 1 Unless otherwise stated, all exhibits are attached to the Bien Decl.

7 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 7 of 25 II. PROCEDURAL BACKGROUND A. Glatt On September 28, 2011, Eric Glatt and Alexander Footman filed a class and collective action lawsuit on behalf of unpaid interns at Fox Searchlight Pictures, Inc. ECF No. 1. After engaging in some discovery, they sought, and were granted leave to amend the complaint to add Plaintiffs Eden Antalik and Kanene Gratts, Defendant Fox Entertainment Group, Inc., and claims under California law. ECF No. 46. The parties engaged in extensive discovery, including the exchange of documents and Electronically Stored Information ( ESI ), and depositions of the Plaintiffs, Defendants corporate representatives, Defendants employees, and non-party witnesses. Bien Decl. 10. On February 15, 2013, Plaintiffs moved for certification of a New York class and nationwide FLSA collective of unpaid interns in Defendants corporate offices, ECF No. 103, and for partial summary judgment for Glatt and Footman. ECF No. 89. Plaintiffs Glatt and Footman did not move for class and/or collective certification on behalf of unpaid interns engaged at one or more of Fox Searchlight s film productions. On February 15, 2013, Defendants cross-moved for summary judgment. ECF No. 93. On June 11, 2013, the Court granted Plaintiffs motion for class and collective certification and their motion for summary judgment with respect to Glatt and Footman, holding that they were employees and that Fox Searchlight was their employer under the FLSA and NYLL. 293 F.R.D. at , The Court denied Defendants motion for summary judgment with regard to Glatt, Footman, and Antalik, but granted it with regard to Gratts, finding that her California claims were untimely. Id. at The Court granted in part Defendants motion for reconsideration by modifying the statute of limitations period for the conditionally certified collective, which would now be from January 18, 2010 through September 1, ECF No Notice was issued to 2

8 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 8 of 25 putative members of the nationwide FLSA collective, allowing individuals to file consents to join the litigation, as well as to putative members of the Rule 23 class, providing them with the opportunity to exclude themselves from the litigation. Bien Decl. 16. When the notice period ended, 59 individuals joined the FLSA collective and 8 individuals excluded themselves from the Rule 23 class. Id at. 17. The opt-in members would have timely claims only if the Court finds that Defendants willfully violated the FLSA or grants equitable tolling. Defendants appealed the Court s class and collective certification decision and determination that Glatt and Footman were employees. 2 ECF No On July 2, 2015, the Second Circuit held, as a matter of first impression, that whether interns are employees under the FLSA depends on whether they or the company that engaged them is the primary beneficiary of the relationship. Glatt, 791 F.3d at 385. The panel vacated the Court s grant of summary judgment to Glatt and Footman and remanded to apply the primary beneficiary standard. Id. at 385. It also vacated and remanded the Court s grant of class and collective certification. Id. at Plaintiffs sought en banc review or rehearing of the panel s decision. Bien Decl. 21. On January 25, 2016, the panel amended its decision, including by altering certain language discussing how courts should analyze intern cases brought as class actions. Compare Glatt, 811 F.3d at 539 (clarifying that the primary beneficiary test is highly context specific ), with 791 F.3d at 386 (stating that the test is highly individualized ). In Plaintiffs view, this clarification, while subtle, was significant because the prior language would have made it especially difficult to certify an intern class, in this or future litigation. Defendants note that the revised opinion did not change any of the factors relevant to the primary beneficiary standard, and the panel s analysis with respect to class certification in the present matter remained the same: Antalik s alleged common evidence 2 Defendants did not appeal the Court s determination that Fox Searchlight was a joint employer of Glatt and Footman, but Defendants reserved all rights to do so after entry of final judgment. 3

9 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 9 of 25 could not resolve the claims of all class members, and defendants undisputed evidence demonstrated that the various internship programs it offered differed substantially across the many departments and four Fox divisions included in the proposed class. See Glatt, 811 F.3d at 539. B. MacKown On June 25, 2013, Plaintiff MacKown filed a class action lawsuit against Defendants on behalf of himself and a class of similarly situated unpaid interns in California. MacKown ECF No. 1. MacKown alleged violations under California law. Id. The Court stayed the case pending the Glatt appeal to the Second Circuit. MacKown ECF No. 17. C. Mediation and Settlement Negotiations The parties attempted to settle the lawsuits twice with private mediators. The first mediation took place on January 30, 2013 before class certification and summary judgment briefing. Bien Decl. 28. The parties were not able to resolve the claims at that time. The parties returned to mediation on May 13, 2016, before Dina Jansenson, Esq., and entered into a Stipulation on the material terms of a settlement. Bien Decl. 29. At all times, the negotiations occurred on an arm s length basis. Id. 30. Following the mediation, the parties negotiated the remaining terms of the settlement, which are memorialized in the Settlement Stipulation. Id. 31. III. SUMMARY OF THE SETTLEMENT TERMS A. Settlement Payments Defendants have agreed to make a settlement payment of $495 to all members of the Settlement Classes 3 (defined below) who completed an unpaid Internship for at least two weeks and submit a valid Claim Form. Ex. A (Settlement Stipulation) 5. B. Settlement Classes 3 There are two Settlement Classes: Unless otherwise indicated, all capitalized terms have the determinations set forth in the Settlement Stipulation. 4

10 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 10 of 25 The FLSA Settlement Collective includes all individuals who had an unpaid Internship for at least two weeks between January 18, 2010 and September 1, 2010, with one or more of the following divisions of FEG: Fox Filmed Entertainment, Fox Group, Fox Networks Group, and Fox Interactive Media (renamed News Corp. Digital Media), and who previously filed a consent to join in the litigation, Ex. A (Settlement Stipulation) 5(a). The NY Rule 23 Settlement Class includes all individuals who had an unpaid Internship for at least two weeks in New York State between September 28, 2005 and September 1, 2010, with the same FEG divisions, and who did not file an exclusion form in the litigation, id. 5(b). An individual may be a Settlement Class Member of the FLSA Settlement Collective and the NY Rule 23 Settlement Class; however, he or she will only receive one payment. Ex. A (Settlement Stipulation) 5. There are approximately 80 NY Rule 23 Settlement Class Members and 59 FLSA Settlement Collective Members. Bien Decl. 39. C. Releases All Settlement Class members who submit a valid Claim Form will release their FLSA claims in connection with their Internship with Defendants. Ex. A (Settlement Stipulation) 16(a). In addition, upon the Effective Date, all Settlement Class members who do not exclude themselves will release their NYLL wage and hour claims in connection with their Internship with Defendants. Id. In exchange for signing a general release of all claims, Plaintiffs Glatt, Footman and Antalik will receive the following payments: Eric Glatt ($7,500); Alexander Footman ($6,000); and Eden Antalik ($3,500). Ex. A (Settlement Stipulation) 4, 16(c). Plaintiff Kanene Gratts has elected not to participate in the settlement. Defendants respectfully request that the Court enter final judgment, pursuant to Federal Rule 58, with respect to the California claims asserted by Plaintiff Kanene Gratts, which were dismissed as untimely on June 11, Plaintiff s 5

11 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 11 of 25 counsel does not oppose entry of final judgment. Once final judgment is entered, Defendants may file a bill of costs, which Plaintiffs reserve the right to oppose. D. Attorneys Fees and Costs Plaintiffs Counsel will apply for up to $200,000 for their attorneys fees and reimbursement of out-of-pocket costs. Ex. A (Settlement Stipulation) 9. Pursuant to Federal Rule of Civil Procedure 23(h) and 54(d)(2), Plaintiffs will move for Court approval of their attorneys fees and costs simultaneously with their Motion for Final Approval of the Settlement. E. Settlement Claims Administrator The parties have selected Rust Consulting, Inc. as the third-party settlement claims administrator ( Claims Administrator ) to send the Notice Package to Settlement Class members and distribute checks to Settlement Class members who submit Claim Forms. Ex. A (Settlement Stipulation) 10. Defendants have agreed to pay the costs of the Claims Administrator s fees of up to $20,000 for both the Glatt and MacKown actions. Id. 10(b). The Notice advises the Settlement Class Members of their right to exclude themselves from or object to the settlement and how to do so. See Ex. A (Settlement Stipulation), Ex. A (Notice Package) 9, 10. The deadline for opting out or objecting is forty-five (45) days from the mailing of the Notice, unless the Notice is returned undeliverable and an updated address is found, in which case, the deadline will be remainder of the forty-five (45) day period or twenty (20) days from the r ing, whichever is longer. Ex. A (Settlement Stipulation) 1(d), 13(f), (g). 6

12 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 12 of 25 IV. CLASS ACTION SETTLEMENT PROCEDURE Rule 23 s class action settlement procedure includes three steps: 1. Preliminary approval of the proposed settlement after submission to the Court of a written motion for preliminary approval; 2. Dissemination of mailed and/or published notice of settlement to all affected class members; and 3. A final settlement approval hearing at which class members may be heard regarding the settlement, and at which argument concerning the fairness, adequacy, and reasonableness of the settlement may be presented. See Fed. R. Civ. P. 23(e); see also Herbert B. Newberg & Alba Conte, Newberg on Class Actions ( Newberg ), 11.22, et seq. (4th ed. 2002); Torres v. Gristede s Operating Corp., Nos. 04 Civ. 3316, et al., 2010 WL , at *3-5 (S.D.N.Y. June 1, 2010). This process safeguards class members procedural due process rights and enables the Court to fulfill its role as the guardian of the class s interests. With this motion, Plaintiffs request that the Court take the first step granting preliminary approval of the Settlement Stipulation, conditionally certifying the Settlement Class under Rule 23 of the Federal Rules of Civil Procedure for settlement purposes only, approving the Parties proposed Notice Package, appointing Outten & Golden LLP as Class Counsel, and authorizing the Claims Administrator to send the proposed Notice Package to Settlement Class members. The parties respectfully submit the following proposed schedule for final resolution of this matter for the Court s consideration and approval: 1. Within 10 business days of the Preliminary Approval Order, Defendants will provide the Claims Administrator with contact information for Settlement Class Members. Ex. A (Settlement Stipulation) Within 20 business days of the Preliminary Approval Order, the Claims Administrator will mail the Notices to all Settlement Class members, via First Class Untied States mail, postage prepaid, and electronic mail (to the extent that 7

13 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 13 of 25 such addresses are available). Ex. A (Settlement Stipulation) 13(b). If any Notices are returned to the Claims Administrator as undeliverable, the Claims Administrator will attempt to locate updated contact information and will r the Notice if updated information is available. Ex. A (Settlement Stipulation) 13(d). 3. Settlement Class members will have 45 days after the date the Notices are mailed to submit a valid Claim Form, object, or exclude themselves from the settlement. Ex. A (Settlement Stipulation) 1(d), 13(c), (f), (g). 4. A final fairness hearing will be held as soon as is convenient for the Court after the end of the opt-out period. 5. Plaintiffs will file Motions for Final Approval of Settlement and for Attorneys Fees and Costs with the Court 14 days before the final fairness hearing. 6. After the final fairness hearing, if the Court grants Plaintiffs Motion for Final Approval of the Settlement, the Court will issue a Final Order and Judgment. If no party appeals the Court s Final Order and Judgment, the Effective Date of the Settlement Stipulation will be 35 days after the Court enters the Final Approval Order. Ex. A (Settlement Stipulation) 1(l). If an individual or party appeals the Court s Final Order and Judgment, the Effective Date shall be the date on which all such appeals (including, inter alia, petitions for rehearing or reargument, petitions for rehearing en banc, and petitions for certiorari or any other form of review) have been finally disposed and can no longer be appealed or reviewed. Id. 7. Within 20 days of the Effective Date, Defendants will deposit into the Qualified Settlement Fund an amount to cover the Participating Class Member Payments, Attorneys Fees, and Individual Payments to the Plaintiffs. Ex. A (Settlement Stipulation) The Claims Administrator will mail settlement checks to Settlement Class members and Plaintiffs, and wire Plaintiffs Counsel s approved attorneys fees and costs within 10 days of the Effective Date. Ex. A (Settlement Stipulation) 13(h). Settlement Class members will have 120 days to redeem their settlement payment. Id. V. PRELIMINARY APPROVAL OF THE SETTLEMENT IS APPROPRIATE. The law favors compromise and settlement of class action suits. See Wal-Mart Stores, Inc. v. Visa U.S.A. Inc., 396 F.3d 96, (2d Cir. 2005) (noting the strong judicial policy in favor of settlements, particularly in the class action context ) (internal quotation marks and citation omitted); In re Warfarin Sodium Antitrust Litig., 391 F.3d 516, 535 (3d Cir. 2004) 8

14 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 14 of 25 ( [T]here is an overriding public interest in settling class action litigation, and it should therefore be encouraged. ); see also Newberg ( The compromise of complex litigation is encouraged by the courts and favored by public policy. ). Preliminary approval requires only an initial evaluation of the fairness of the proposed settlement on the basis of written submissions and an informal presentation by the settling parties. Lizondro-Garcia v. Kefi LLC, 300 F.R.D. 169, 179 (S.D.N.Y. 2014) (internal quotation marks omitted). To grant preliminary approval, the court need only find that there is probable cause to submit the [settlement] proposal to class members and hold a full-scale hearing as to its fairness. In re Traffic Exec. Ass n, 627 F.2d 631, 634 (2d Cir. 1980) (internal quotation marks omitted); Newberg ( [i]f the preliminary evaluation of the proposed settlement does not disclose grounds to doubt its fairness... and appears to fall within the range of possible approval, the court should permit notice of the settlement to be sent to class members) (quoting Manual for Complex Litigation (3d ed.) 30.41). Fairness is determined upon review of both the terms of the settlement agreement and the negotiating process that led to such agreement. Frank v. Eastman Kodak Co., 228 F.R.D. 174, 184 (W.D.N.Y. 2005) (internal citation omitted). A presumption of fairness, adequacy, and reasonableness may attach to a class settlement reached in arm s-length negotiations between experienced, capable counsel after meaningful discovery. Wal-Mart Stores, 396 F.3d at 116 (internal citation and quotation marks omitted); see also Lynn s Food Stores, Inc. v. United States, 679 F.2d 1350, 1354 (11th Cir. 1982). If the settlement was achieved through arm s-length negotiations involving experienced counsel, [a]bsent fraud or collusion, [courts] should be hesitant to substitute [their] judgment for that of the parties who negotiated the settlement. In re EVCI Career Colls. Holding Corp. Sec. Litig., Nos. 05 Civ , et al., 2007 WL , at *4 (S.D.N.Y. July 27, 2007). 9

15 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 15 of 25 Preliminary approval is the first step in the settlement process. It simply allows notice to issue and for class members to object to or opt out of the settlement. After notice issues, the Court will be able to evaluate the settlement with the benefit of class members input. A. The Settlement Is Fair, Reasonable, and Adequate. In evaluating a class action settlement, courts in the Second Circuit generally consider the nine factors set forth in City of Detroit v. Grinnell Corp., 495 F.2d 448, 463 (2d Cir. 1974), abrogated on other grounds by Goldberger v. Integrated Res., Inc., 209 F.3d 43 (2d Cir. 2000). The Grinnell factors are: (1) the complexity, expense and likely duration of the litigation; (2) the reaction of the class to the settlement; (3) the stage of the proceedings and the amount of discovery completed; (4) the risks of establishing liability; (5) the risks of establishing damages; (6) the risks of maintaining the class action through the trial; (7) the ability of the defendants to withstand a greater judgment; (8) the range of reasonableness of the settlement fund in light of the best possible recovery; and (9) the range of reasonableness of the settlement fund to a possible recovery in light of all the attendant risks of litigation. 495 F.2d at 463. Here, seven of the Grinnell factors weigh in favor of approval of the Settlement Stipulation and two are neutral. 1. Further Litigation and Trial Would Be Complex, Costly, and Long (Grinnell Factor 1). This lawsuit raised novel issues that very few courts had addressed. It required the parties to expend significant time and effort litigating over the appropriate standard to evaluate an unpaid intern s status under the FLSA a complex question on which courts and the U.S. Department of Labor have differed. In addition to this question, under any standard, the issues are fact-intensive, requiring substantial discovery and making class and collective certification challenging. Under these circumstances, the case was highly complex. Although Glatt settled the question of the proper intern standard in the Second Circuit, if the parties had not settled, 10

16 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 16 of 25 they would have engaged in further litigation and possibly a trial. Bien Decl Before they mediated, the parties were prepared to move again for summary judgment with respect to Glatt, Footman, and Antalik under the primary beneficiary test. Bien Decl. 54. Because few courts have applied the Second Circuit s test, this would also have required extensive briefing by the parties. On the other hand, the settlement will provide all class members relief promptly, avoiding the significant risk that each side faces, particularly the Plaintiffs. Therefore, the first Grinnell factor weighs in favor of preliminary approval. 2. The Court Cannot Assess the Reaction of the Class Until After Notice Issues (Grinnell Factor 2). Because class members have not been notified of the settlement at this stage, the Court will be in a better position to more fully analyze this factor after notice issues and class members have had an opportunity to opt out or object to the settlement. Thus, this factor is neutral and does not preclude the Court from granting preliminary approval. 3. Discovery Has Advanced Far Enough to Allow the Parties to Resolve the Case Responsibly (Grinnell Factor 3). The parties have engaged in significant discovery, including exchanging tens of thousands of pages of documents and conducting multiple depositions. Bien Decl. 55. Although Plaintiffs would have sought some additional discovery relating to the MacKown case if litigation had proceeded, they had already obtained a great deal of information from the Glatt case relating to the policies and practices that applied to all unpaid interns, including those in California. Bien Decl. 56. Thus, Plaintiffs were sufficiently informed of the strengths and weaknesses of the claims before they resolved them. 11

17 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 17 of Plaintiffs Would Face Risk If the Case Proceeded (Grinnell Factors 4 and 5). The Second Circuit s primary beneficiary standard and its decertification of the class and collective present significant risk to Plaintiffs on the merits and with regard to certification. Although Plaintiffs believe that they would have prevailed on summary judgment again with regard to Glatt and Footman, and could have avoided summary judgment with regard to Antalik, the Second Circuit s standard is largely untested. At least a few courts have granted summary judgment to employers under the standard, and as of the filing of this motion, no courts have granted summary judgment in favor of an unpaid intern. See, e.g., Mark v. Gawker Media LLC, No. 13 Civ. 4347, 2016 WL , at *12 (S.D.N.Y. Mar. 29, 2016). The Second Circuit s decision, despite its revised language in the amended opinion, makes class and collective certification extremely challenging. The Settlement Class Members were engaged in various divisions, performing different duties, and reporting to different supervisors. While they were subject to some common policies, including the one that the Court held predominated under the Department of Labor s test, under the primary beneficiary test, the Court could conclude that the differences among interns exceed their similarities. This risk strongly supports the settlement because, under it, all class members who make a claim will be paid. In addition, Defendants believe that the individuals who filed consents to join the FLSA collective would not have timely claims because there was no willful violation under the statute. This factor weighs in favor of preliminary approval. 5. Establishing and Maintaining the Class Through Trial Presents Risk (Grinnell Factor 6). As discussed above, this is probably the strongest factor favoring the settlement. While the Second Circuit did not rule out that the Plaintiffs could re-certify a class, it expressed doubt 12

18 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 18 of 25 that they would be able to do so. See Glatt, 811 F.3d at 539. Accordingly, this factor favors preliminary approval. 6. Defendants Ability to Withstand a Greater Judgment Is Not Determinative (Grinnell Factor 7). While Defendants may have been able to pay a greater judgment, defendant s ability to withstand a greater judgment, standing alone, does not suggest that the settlement is unfair. Frank, 228 F.R.D. at 186 (internal brackets, citation, and quotation marks omitted). Accordingly, this factor is neutral and does not preclude the Court from granting preliminary approval. 7. The Settlement Fund Is Substantial, Even in Light of the Best Possible Recovery and the Attendant Risks of Litigation (Grinnell Factors 8 and 9). The $495 that Defendants will pay to each Settlement Class Member who submits a claim is substantial given the risks of litigation discussed above, even though the recovery would be greater if Plaintiffs prevailed and maintained a class through trial and on appeal. While the amount is at the low end of the range that courts have approved in other unpaid intern settlements the payments range from about $500 to $1,900 4 these cases were resolved before the Second Circuit adopted the primary beneficiary standard. In light of this, the payments in this case fall within the range of reasonableness justifying preliminary approval. See Frank, 228 F.R.D. at 186 (the range [of reasonableness]... recognizes the uncertainties of law and fact in any particular case and the concomitant risks and costs necessarily inherent in taking any litigation to completion ) (quoting Newman v. Stein, 464 F.2d 689, 693 (2d Cir. 1972)). By Class Counsel s estimate, $495 constitutes about 25% of what Settlement Class Members would have received if they prevailed on their minimum wage claims at trial and 4 See Bien Decl

19 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 19 of 25 through an appeal. Bien Decl. 33. This is a reasonable percentage. See Grinnell, 495 F.2d at 455 n.2 ( [T]here is no reason, at least in theory, why a satisfactory settlement could not amount to a hundredth or even a thousandth part of a single percent of the potential recovery. ) Weighing the benefits of the settlement against the risks associated with proceeding in the litigation, Grinnell factors 8 and 9 favor preliminary approval. VI. CONDITIONAL CERTIFICATION OF THE CLASS IS APPROPRIATE. For settlement purposes, Plaintiffs seek to certify a class under Federal Rule of Civil Procedure 23(e). As discussed below, in the context of settlement and for purposes of settlement only, the NY Rule 23 Settlement Class meets all of the requirements for class certification, and Defendants do not oppose certification for settlement purposes only. Ex. A (Settlement Stipulation) 3; see also Newberg ( When the court has not yet entered a formal order determining that the action may be maintained as a class action, the parties may stipulate that it be maintained as a class action for the purpose of settlement only. ); Cnty. of Suffolk v. Long Island Lighting Co., 710 F. Supp. 1422, 1424 (E.D.N.Y. 1989), aff d in part, rev d in part on other grounds, 907 F.2d 1295 (2d Cir. 1990) ( It is appropriate for the parties to a class action suit to negotiate a proposed settlement of the action prior to certification of the class. ). Under Rule 23, a class action may be maintained if all of the prongs of Rule 23(a) are met, as well as one of the prongs of Rule 23(b). Rule 23(a) requires that: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class. Fed. R. Civ. P. 23(a). Rule 23(b)(3) requires the court to find that: 14

20 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 20 of 25 Id. at (b)(3). [Q]uestions of law or fact common to class members predominate over any questions affecting only individual members, and that a class action is superior to other available methods for fairly and efficiently adjudicating the controversy. A. Numerosity [N]umerosity is presumed at a level of 40 members. Consol. Rail Corp. v. Town of Hyde Park, 47 F.3d 473, 483 (2d Cir. 1995) (citation omitted). Here, there are approximately 80 NY Rule 23 Settlement Class Members. Bien Decl. 39. B. Commonality The Settlement Class also satisfies the commonality requirement, the purpose of which is to test whether the named plaintiff s claim and the class claims are so interrelated that the interests of the class members will be fairly and adequately protected in their absence. Gen. Tel. Co. of Sw. v. Falcon, 457 U.S. 147, 157 n.13 (1982). Plaintiff challenges a common policy of classifying all Settlement Class Members as nonemployees who are not entitled to the minimum wage. This question is sufficient to satisfy commonality for settlement purposes. See, e.g., Ballinger v. Advance Magazine Publishers, Inc., No. 13 CIV HBP, 2014 WL , at *4-5 (S.D.N.Y. Dec. 29, 2014) (finding commonality met for settlement purposes in unpaid intern case brought under the NYLL). C. Typicality Rule 23 requires that the claims of the representative party be typical of the claims of the class. Like the commonality requirement, typicality does not require the representative party s claims to be identical to those of all class members. Frank, 228 F.R.D. at 182. Typicality is satisfied when each class member s claim arises from the same course of events, and each class member makes similar legal arguments to prove the defendant s liability. Marisol A. v. 15

21 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 21 of 25 Guiliani, 126 F.3d, 372, 376 (2d Cir. 1997) (internal quotation marks omitted) (quoting In re Drexel Burnham Lambert Group, Inc., 960 F.2d 285, 291 (2d Cir. 1992)). Antalik s NYLL claims arise from the same alleged factual and legal circumstances that underlie the class s claims that Defendants misclassified interns as non-employees and failed to pay them minimum wages. See Ballinger, 2014 WL , at *12. D. Adequacy Rule 23(a)(4) requires that the representative parties will fairly and adequately protect the interests of the class. Fed. R. Civ. P. 23(a)(4). The adequacy requirement exists to ensure that the named representative will have an interest in vigorously pursuing the claims of the class, and... have no interests antagonistic to the interests of other class members. Denney v. Deutsche Bank AG, 443 F.3d 253, 268 (2d Cir. 2006). [O]nly a conflict that goes to the very subject matter of the litigation will defeat a party s claim of representative status. Dziennik v. Sealift, Inc., No. 05 Civ. 4659, 2007 WL , at *6 (E.D.N.Y. May 29, 2007) (internal quotation marks omitted). Antalik does not have interests that are antagonistic to or at odds with the class s interests. See Ballinger, 2014 WL , at *5 (adequacy satisfied where, inter alia, there was no evidence that named plaintiffs and class members interests were at odds). In addition, Plaintiff has selected counsel who are adequate to represent the class s interests. See Glatt, 293 F.R.D. at (appointing Outten & Golden LLP as class counsel); see also Ballinger, 2014 WL , at *1 (Outten & Golden LLP is generally (and appropriately) regarded as being among the top employment law firms in the [Southern] District. ). E. Certification Is Proper Under Rule 23(b)(3). Rule 23(b)(3) requires that the common questions of law or fact predominate over any questions affecting only individual members, and that a class action is superior to other available 16

22 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 22 of 25 methods for fairly and efficiently adjudicating the controversy. Fed. R. Civ. P. 23(b)(3). This inquiry examines whether proposed classes are sufficiently cohesive to warrant adjudication by representation. Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 623 (1997). For the purposes of settlement only, these requirements are met in this case. 1. Common Questions Predominate To establish predominance, Plaintiff must demonstrate that the issues in the class action that are subject to generalized proof, and thus applicable to the class as a whole,... predominate over those issues that are subject only to individualized proof. Cordes & Co. Fin. Servs., Inc. v. A.G. Edwards & Sons, Inc., 502 F.3d 91, (2d Cir. 2007) (internal quotation marks omitted). The predominance requirement is more demanding than the Rule 23(a) commonality inquiry and is designed to determine whether proposed classes are sufficiently cohesive to warrant adjudication by representation. Frank, 228 F.R.D. at 183 (internal quotation marks omitted) (quoting Amchem, 521 U.S. at 623). The essential inquiry is whether liability can be determined on a class-wide basis, even when there are some individualized damage issues. In re Visa Check/MasterMoney Antitrust Litig., 280 F.3d 124, 139 (2d Cir. 2001) (internal quotation marks omitted), abrogated on other grounds by Miles v. Merrill Lynch & Co., Inc. (In re Initial Pub. Offering Sec. Litig.), 471 F.3d 24 (2d Cir. 2006). Some courts have held that where plaintiffs are unified by a common legal theory and by common facts, the predominance requirement is satisfied. McBean v. City of New York, 228 F.R.D. 487, 502 (S.D.N.Y. 2005). For settlement purposes, Plaintiff s common contention that interns were employees entitled to minimum wage protections predominates over any individualized issues. Ballinger, 2014 WL , at *6. 17

23 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 23 of A Class Action Is a Superior Mechanism The second part of the Rule 23(b)(3) analysis examines whether the class action device [is] superior to other methods available for a fair and efficient adjudication of the controversy. Green v. Wolf Corp., 406 F.2d 291, 301 (2d Cir. 1968). The class action device is superior because Settlement Class members have limited financial resources with which to prosecute individual actions. See Fed. R. Civ. P. 23(b)(3); see also Glatt, 293 F.R.D. at 516 ( the relatively small recoveries available to individual plaintiffs make a class action a more efficient mechanism ). Employing the class device here will achieve economies of scale, will conserve the resources of the judicial system, and will avoid the waste and delay of repetitive proceedings and inconsistent adjudications of similar issues and claims. See Lizondro-Garcia, 300 F.R.D. at 177 (class action more economical due to plaintiffs limited financial resources and the relatively modest size of any individual s recovery ); Ballinger, 2014 WL , at *6 (same). VII. PLAINTIFFS COUNSEL SHOULD BE APPOINTED AS CLASS COUNSEL. Rule 23(g), which governs the standards and framework for appointing class counsel for a certified class, sets forth four criteria courts must consider in evaluating the adequacy of proposed counsel: (1) the work counsel has done in identifying or investigating potential claims in the action; (2) counsel s experience in handling class actions, other complex litigation, and the types of claims asserted in the action; (3) counsel s knowledge of the applicable law; and (4) the resources that counsel will commit to representing the class. Fed. R. Civ. P. 23(g)(1)(A). The Court may also consider any other matter pertinent to counsel s ability to fairly and adequately represent the interests of the class. Fed. R. Civ. P. 23(g)(1)(B). The Advisory Committee has noted that [n]o single factor should necessarily be determinative in a given case. Fed. R. Civ. P. 23(g) advisory committee s note. 18

24 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 24 of 25 Plaintiff s counsel satisfy these criteria. They have done substantial work identifying, investigating, litigating, negotiating, and settling Plaintiff s and Settlement Class members claims. Bien Decl. 55. See also Glatt, 293 F.R.D. at ; Ballinger, 2014 WL , at *1. VIII. THE NOTICE PLAN AND CLAIMS PROCESS ARE APPROPRIATE. The Notice fully complies with due process and Federal Rule of Civil Procedure 23. Pursuant to Rule 23(c)(2)(B), the notice must provide: the best notice that is practicable under the circumstances, including individual notice to all members who can be identified through reasonable effort. The notice must clearly and concisely state in plain, easily understood language: (i) (ii) (iii) (iv) (v) (vi) (vii) the nature of the action; the definition of the class certified; the class claims, issues, or defenses; that a class member may enter an appearance through an attorney if the member so desires; that the court will exclude from the class any member who requests exclusion; the time and manner for requesting exclusion; and the binding effect of a class judgment on members under Rule 23(c)(3). Fed. R. Civ. P. 23(c)(2)(B). The Notice satisfies each of these requirements. It is written in plain English and organized and formatted so as to be as clear as possible. It also describes the terms of the settlement, informs class members about the allocation of attorneys fees and costs, and provides specific information regarding the date, time, and place of the final approval hearing. See Ex. A (Settlement Stipulation); Ex. A (Notice Package) 14. The Settlement Stipulation provides that the Claims Administrator will mail the Notice Package to the last known address of each Settlement Class member within 20 business days of the Court s preliminary approval order. Ex. A (Settlement Stipulation) 13(b). The Claims Administrator will take reasonable steps to obtain the correct addresses of any Settlement Class 19

25 Case 1:11-cv WHP Document 264 Filed 07/12/16 Page 25 of 25 member whose Notice Package is returned as undeliverable and will attempt up to additional attempts to locate correct addressed and perform r ings. Id. 13(d). CONCLUSION For the foregoing reasons, Plaintiffs respectfully request that the Court grant their Motion for Preliminary Approval of Settlement and enter the Proposed Order. Dated: July 12, 2016 New York, New York Respectfully submitted, OUTTEN & GOLDEN LLP /s/ Rachel Bien Rachel Bien Rachel Bien Sally J. Abrahamson 3 Park Avenue, 29th Floor New York, New York Telephone: (212) Facsimile: (646) Attorneys for Plaintiffs 20

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