Investigation and Discovery Clause Samples
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendant produced documents relating to its wage-and-hour policies, practices, and procedures, including those regarding meal and rest periods, overtime, and other payroll and operational policies. As part of Defendant’s production, Plaintiff also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiff to understand the number of workweeks in the Class Period. Plaintiff also interviewed Class Members who worked for Defendant throughout the Class Period. The Parties agree that the above-described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendant produced documents relating to its wage-and-hour policies, practices, and procedures, including those regarding meal and rest periods, overtime, and other payroll and operational policies. As part of Defendant’s production, Plaintiff also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiff to understand the number of workweeks in the Class Period. Plaintiff also interviewed Class Members who worked for Defendant throughout the Class Period. A major catalyst to settlement was Defendant’s past and present financial condition. Defendant disclosed and Plaintiff’s expert CPA verified the financial records to determine that the settlement was fair and reasonable. The Parties agree that the above-described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.
Investigation and Discovery. The Parties conducted significant investigation and discovery of the facts and law both before and after the Action was filed. Defendant produced hundreds of documents relating to its policies, practices, and procedures regarding reimbursement of business expenses, paying non- exempt employees for all hours worked, meal and rest break policies, and payroll, timekeeping, and operational policies. As part of Defendant’s production, Plaintiffs also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiffs to understand the number of Weeks Worked during the Class Period. Plaintiffs also interviewed several Class Members who worked for Defendant throughout the Class Period. The Parties agree that the above-described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendants produced documents relating to their wage-and-hour policies, practices, and procedures, including those regarding meal and rest periods, final pay, and timekeeping. As part of Defendants’ production, Plaintiff also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiff to understand the number of workweeks and pay periods in the Class Period. The Parties agree that the above-described investigation and evaluation, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendants produced documents relating to its wage-and-hour policies, practices, and procedures, including those regarding meal and rest periods, overtime, and other payroll and operational policies. As part of Defendants’ production, Plaintiff also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiff to understand the number of workweeks in the Class Period. The Parties agree that the above-described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis. Counsel for all parties have thoroughly investigated the facts relating to the claims alleged in the Action and have made a thorough study of the legal principles applicable to the claims asserted against Defendants. Based on their investigation and evaluation of this case, Class Counsel concluded that the settlement described in this Agreement is fair, reasonable, and adequate in light of all known facts and circumstances, including the defenses asserted by Defendants, potential adverse findings regarding liability, potential recovery issues, and numerous potential appellate issues.
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendants produced documents relating to their policies, practices, and procedures regarding meal and rest periods, overtime, and other payroll and operational policies. As part of Defendants’ production, Plaintiffs also reviewed time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiffs to understand the number of workweeks in the Class Period. Plaintiffs also interviewed Class Members who worked for Defendants throughout the Class Period. The Parties agree that the above-described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.
Investigation and Discovery. The Parties conducted significant investigation and discovery of the facts and law both before and after the Cases were filed. Prior to mediation, Defendant produced documents relating to its policies, practices, and procedures regarding paying non-exempt employees for all hours worked and meal and rest period policies. Defendant also produced statements, time records, pay records, and information relating to the size and scope of the Class, as well as data permitting Plaintiffs to understand the number of
Investigation and Discovery. Prior to mediation, the Parties conducted significant investigation and discovery of the relevant facts and law. Specifically, Defendant produced documents relating to its wage-and-hour policies, practices, and procedures, including those regarding meal and rest periods, overtime, and Defendant’s timekeeping, payroll, and operational policies. As part of Defendant’s production, Plaintiffs also reviewed time records, pay records, Class Members’ personnel files, and information relating to the size and scope of the Class, as well as data permitting Plaintiffs to understand the number of workweeks in the Class Period and pay periods in the PAGA Timeframe. Plaintiffs also interviewed Class Members who worked for Defendant throughout the Class Period. The Parties agree that the above- described investigation and evaluation, as well as the information exchanged during the settlement negotiations, are more than sufficient to assess the merits of the respective Parties’ positions and to compromise the issues on a fair and equitable basis.