Lyons v. IR Labs DE, LLC and SourceTek, Inc. — Joint Status Report (S.D. Iowa, Document 33)

Summary

Joint Status Report in Lyons v. IR Labs DE, LLC and SourceTek, Inc., Case 4:24-cv-00002-SHL-SBJ, Document 33, filed 01/08/25 in the Southern District of Iowa, ahead of a status conference set for January 15, 2025. The parties report that a May 22, 2024 mediation before the Honorable John A. Jarvey resolved in principle the FLSA claims of a group of IR Labs employees, that the claims of a group of SourceTek employees were resolved in principle in mid-September and the WARN claims of a group of IR Labs employees in late September, and that Plaintiffs and IR Labs reached an agreement in principle on attorneys' fees in December 2024. They expect to file a joint motion for settlement approval within the next 30 days, citing delay after a large tree fell on the house of counsel for IR Labs during Hurricane Helene.

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Case 4:24-cv-00002-SHL-SBJ Document 33 Filed 01/08/25 Page 1 of 4

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, ) JOINT STATUS REPORT
)
vs. )
)
IR LABS DE, LLC; and SOURCETEK, )
INC. )
)
Defendants. )

COME NOW Chad Lyons and Christian Taveras (“Plaintiffs”) and IR Labs, LLC (“IR

Labs”) and SourceTek, Inc. (“SourceTek”) (collectively, “Defendants”), by and through their

undersigned counsel, and provide the Court with the following Joint Status Report in advance of

the status conference scheduled for January 15, 2025.

1. Plaintiffs in this matter have asserted a class action and collective action against

Defendants for alleged violations of the federal Worker Adjustment and Retraining Notification

Act (“WARN”) and the Fair Labor Standards Act (“FLSA”), which claims Defendants deny.

2. The Parties have exchanged documents, payroll data, timekeeping data, and other

information and have thoroughly investigated the claims and defenses. The Parties have engaged

in extensive settlement negotiations, including an all-day mediation session on May 22, 2024,

presided over by an experienced third-party mediator, the Honorable John A. Jarvey, which

resulted in an agreement in principle to resolve the FLSA claims of a defined group of employees

of IR Labs. However, at the mediation, the Parties were unable to resolve any of the other claims

asserted. Thereafter, the Parties continued to exchange information and engage in extensive
Case 4:24-cv-00002-SHL-SBJ Document 33 Filed 01/08/25 Page 2 of 4

negotiations to resolve the remaining claims. In mid-September, the Parties reached an agreement

in principle to resolve the FLSA and WARN claims of a separate, defined group of employees of

SourceTek. In late September, the Parties reached an agreement in principle to resolve the WARN

claims and other claims of a separate, defined group of employees of IR Labs.

3. After all the substantive claims were resolved in principle, the Parties started to

exchange information and engage in extensive negotiations to resolve the remaining claims for

attorneys’ fees and costs. In December 2024, Plaintiffs and IR Labs reached an agreement in

principle to resolve Plaintiffs’ claims for attorneys’ fees and costs, though some issues remain.

4. Further, since the substantive claims were resolved in principle, the Parties have

prepared a formal settlement agreement and exchanged numerous drafts. The settlement agreement

is nearly finalized, though some details remain to be worked out. The Parties have also started

preparing other settlement documents, including a joint motion for settlement approval, as well as

a notice of settlement and claim form to be sent to a defined group of IR Labs employees. IR Labs

has also obtained quotes from third-party settlement administrators to perform various settlement

administration tasks set forth in the settlement agreement.

5. There has been some delay due to a large tree falling on the house of counsel for

IR Labs during Hurricane Helene, as well as typical holiday delays for the Parties during

November and December. Nevertheless, the Parties expect to finalize all the settlement documents

and submit a joint motion for settlement approval within the next 30 days.

6. The Parties leave it to the Court’s discretion whether to proceed with the status

conference scheduled for January 15, 2025.

2
Case 4:24-cv-00002-SHL-SBJ Document 33 Filed 01/08/25 Page 3 of 4

By: /s/William Robert Gignilliat, IV

William Robert Gignilliat, IV (Pro Hac Vice)
JACKSON LEWIS P.C.
15 SOUTH MAIN STREET, SUITE 700
GREENVILLE, SC 29601
Telephone: 864-232-7000
Fax: 864-235-1381
Email: robert.gignilliat@jacksonlewis.com

Sarah J. Millsap, AT0007538
Ann L. Zebrowski, AT0012033
JACKSON LEWIS P.C.
10050 Regency Circle, Suite 400
Omaha, Nebraska 68114
Telephone: 402-391-1991
Facsimile: 402-391-7363
Email: Sarah.Millsap@jacksonlewis.com
Email: Ann.Zebrowski@jacksonlewis.com

Randall D. Armentrout
Matthew A. McGuire
NYEMASTER GOODE PC
700 WALNUT STREET, SUITE 1300
DES MOINES, IA 50309-3899
Telephone: 515-283-3100
Fax: 515-283-8045
Email: mmcguire@nyemaster.com
Email: rdarmentrout@nyemaster.com

ATTORNEYS FOR IR LABS

/s/ Angel A. West
Angel Anna West
Bryony Joy Whitaker
MAYNARD NEXSEN, P.C.
801 GRAND AVENUE
SUITE 100
DES MOINES, IA 50309
Telephone: 515-686-8223
Fax: 205-254-1999
Email: awest@maynardnexsen.com
Email: bwhitaker@maynardnexsen.com

ATTORNEYS FOR SOURCETEK

3
Case 4:24-cv-00002-SHL-SBJ Document 33 Filed 01/08/25 Page 4 of 4

/s/ William “Jack” Simpson
William “Jack” Simpson
SIMPSON, PLLC
100 South Main Street
Booneville, MS 38829-0382
Email: jack@simpson-pllc.com

Timm W. Reid
REID LAW FIRM, P.L.L.C.
100 Court Avenue
Suite 315
Des Moines, Iowa 50309
Email: timm@treidlawfirm.com

ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE
I hereby certify that on January 8, 2025, I electronically filed the foregoing with the Clerk

of the Court using the CM/ECF System which sent notification of such filing to all the Parties.

/s/ Randall D. Armentrout
Randall D. Armentrout

4936-0514-6637, v. 1

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