Payne & Fears represented a large, multi‐facility healthcare organization which provides residential, rehabilitative, nursing and mental healthcare services to a wide range of patients. The plaintiff alleged she and hundreds of other employees were harmed by the employer’s failure to provide complete and accurate wage statements.
Before the answer was due, we took an aggressive, creative approach by rolling out a new employee handbook, updated policies, and a mutual agreement to arbitrate. We obtained signed arbitration agreements from 75% of the putative class. We also successfully argued that the named plaintiff was not a proper class representative for the organization’s affiliated entities, thereby further reducing the potential class size. The case, which had potential exposure of $800,000, ultimately settled for $75,000.