Free Motion for Settlement - District Court of Delaware - Delaware

Case 1 :05-cv-00034-KAJ Document 5 Filed 07/29/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
LAURA A. BROWN, :
Plaintifi C.A. NO. 05—O034(KA.!)
: JURY TRIAL DEMANDED
APPLIED CARD SYSTEMS, :
INC., a Delaware corporation, :
Defendant.
JOINT MOTION TO APPROVE CONFIDENTIAL SETTLEMENT
AND DISMISS CASE WITH PREJUDICE
Plaintifli LAURA A. BROWN, and Defendant APPLIED CARD SYSTEMS, INC.,
submit theirjoint motion to approve the parties’ confidential settlement, and state as follows:
1. Plaintiff tiled this action against defendants under the Fair Labor Standards Act,
A 29 U.S.C. § 201 et seq. ("FLSA") and under the Delaware Wage Payment and Collection Act,
Chapter 11, Title 19 ofthe Delaware Code pursuant to 19 Del. C. §1 1 13(a) for unpaid overtime,
liquidated damages, attorneys’ fees and costs.
2. The parties to this litigation have reached a fair and equitable resolution in this
matter, which settles all claims in this case, and other matters between the parties.
3. The settlement is fair to Plaintiff because it resolves a dispute between the parties
as to the monies she claims are owing. Defendants have raised various affirmative defenses to
Plaintit? s claims, and had taken the position that they have previously tendered to Plaintiff all
monies to which he might be entitled. Plaintiffs counsel negotiated the temis of the settlement,
and has independently verified that it is fair to her client.
4. The settlement at issue reflects a reasonable compromise of disputed issues, and

Case 1:05-cv-00034-KAJ Document 5 Filed 07/29/2005 Page 2 0f 2
should be approved by this court, reserving j urisdietion to enforce the parties’ confidential
settlement agreement in accordance with its terms.
Respectfully submitted this ___ day of July, 2005. (
Margolis Edelstcin APPLIED CARD SYSTEMS, [NC. _
Attorneys For Plaintiff In—House Counsel for Defendant
1509 Gilpin Avenue 50 Applied Card Way
Wilmington, DE 19806 Glen Mills, PA 19342
(302) 777-4680 phone (484) 840-1700 (::29802) phone
(302) 777-4682 facsimile (302) 467-4994 facsimile
4;/; E? 2 ”t).. r {
Ken L. Morris, Esquire (#4656) Frank J`. Borzio, squire . )
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