Lyons v. IR Labs DE, LLC and SourceTek, Inc. — Declaration of William “Jack” Simpson (S.D. Iowa, Document 38-3)
Summary
Declaration of William 'Jack' Simpson, attorney for plaintiffs Chad Lyons and Christian Taveras in Case No. 4:24-cv-00002-SHL-SBJ in the Southern District of Iowa, filed as Exhibit C in support of the settlement with IR Labs DE, LLC and SourceTek, Inc. Simpson, managing member of Simpson, PLLC, states that Simpson has recovered over $4,000,000 for employees in settlements and that co-counsel Timm Reid has practiced law for 35 years. The declaration describes using payroll data produced by the defendants to calculate overtime owed, settling the IR Labs FLSA Settlement Group claims at mediation with John Jarvey, and later settling for the SourceTek Settlement Group, whose twenty-nine members all retained the firm. It is executed February 10, 2025.
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EXHIBIT C
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF IOWA
CENTRAL DIVISION
CHAD LYONS; and CHRISTIAN ) Case No. 4:24-cv-00002-SHL-SBJ
TAVERAS, individually and on behalf )
of others similarly situated, )
)
Plaintiffs, ) DECLARATION OF WILLIAM
) “JACK” SIMPSON
vs. )
)
IR LABS DE, LLC; and SOURCETEK, )
INC. )
)
Defendants. )
I, William “Jack” Simpson, hereby declare as follows:
1. I am the attorney representing the Plaintiffs, Chad Lyons and Christian Taveras.
2. I am the managing member of Simpson, PLLC, and I dedicate my practice to
representing employees in wage and hour and WARN Act litigation.
3. I am currently representing classes and putative classes of employees in wage and hour
and WARN litigation in ten different jurisdictions.
4. I have recovered over $4,000,000 for employees in settlements that are either already
disbursed or pending approval.
5. Timm Reid is a member of the Reid Law Firm.
6. Mr. Reid has practiced law for 35 years representing injured people and mediating in,
primarily, personal injury, medical malpractice, product liability and employment related
claims.
7. Mr. Reid has been a Martindale-Hubbell AV-rated lawyer for 20+ years.
8. Before Defendants IR Labs DE, LLC (“IR Labs”) and SourceTek, Inc., (“SourceTek”)
answered the Complaint, the Defendants produced voluminous payroll information that
allowed us to assess the validity of the claims and perform a damage analysis.
9. For example, IR Labs bi-monthly produced payroll data for the employees defined as the
“IR Labs FLSA Settlement Group” in the Settlement Agreement.
10. This payroll data provided the number of overtime hours each employee worked, the
amount of commission or milestone bonus payment received, and the number of weeks
each employee worked.
11. With this payroll data, we were able to perform calculations of how much overtime the
IR Labs FLSA Settlement Group would be owed under various circumstances.
12. After thoroughly analyzing and reviewing this data, we attended mediation with the
honorable John Jarvey.
13. At mediation, we settled the claims brought by the IR Labs FLSA Settlement Group. The
settlement provides a meaningful recovery to the members of the IR Labs FLSA
Settlement Group and allows the parties to avoid the costs of protracted litigation. The
settlement also avoids the risks that these claims would be unsuccessful at trial or through
dispositive motion practice.
14. The remaining claims brought in this litigation were not settled at mediation.
15. Following mediation, the Parties continued to exchange information informally as well as
begin written discovery.
16. The settlement conversations that began at mediation continued throughout the following
months.
17. The Defendants produced payroll information for the SourceTek Settlement Group that
allowed us to evaluate the validity of the claims brought in this litigation as well as the
potential damages that could be recovered.
18. I interviewed the members of the SourceTek Settlement Group to assess the potential
amount of overtime hours that might exist.
19. After extensive negotiations, a settlement was reached that resolved the claims brought
by the SourceTek Settlement Group. All twenty-nine members of the SourceTek
Settlement Group have individually retained my firm to represent them, and all have
agreed to the settlement and the allocations of the Settlement Fund among the SourceTek
Settlement Group.
20. I believe the terms of the Settlement Agreement to be fair and reasonable. The
Settlement Agreement provides for a meaningful recovery.
21. After the parties reached a settlement to resolve the underlying claims of the IR Labs
FLSA Settlement Group and SourceTek Settlement Group, the parties exchanged
information and initiated negotiations to resolve the remaining claims for attorneys’ fees
and costs. The settlement of the claims for attorneys’ fees and costs was negotiated
separately from the settlement of the FLSA claims.
22. To the best of my knowledge, there are no conflicts of interest between myself and any
members of the IR Labs FLSA Settlement Group and SourceTek Settlement Group.
I declare under penalty of perjury, under the laws of the United States of America, that
the foregoing is true and correct.
Executed this February 10, 2025.
/s/ William “Jack” Simpson
William “Jack” Simpson
File and source
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- CASE_IASD_4-24-cv-00002_Menaugh-v-IR-Labs_doc38-3_PROPOSED-ORDER_2025-02-14.pdf
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- 103,219 bytes
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- 3face6e4ea36964ff820e06e910b4f486490637b963cbb077e38e0342af2cac2
- Original
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