729 Boylston Street, Suite 2000
Boston, Massachusetts 02116
(617) 994-5800 | firstname.lastname@example.org
In Re: IBM Arbitration Agreement Litigation, No. 22-1728 (2d Cir.)
District Court Opinion
Plaintiffs’ Opening Brief
IBM’s Response Brief
Plaintiffs’ Reply Brief
Chandler v. International Business Machines Corp., No. 22-1733 (2d Cir.)
District Court Opinion
Plaintiff’s Opening Brief
IBM’s Response Brief
Plaintiff’s Reply Brief
Lodi v. International Business Machines Corp., No. 22-1737 (2d Cir.)
District Court Opinion
Plaintiff’s Opening Brief
IBM’s Response Brief
Plaintiff’s Reply Brief
Tavenner v. International Business Machines Corp., No. 22-2318 (2d Cir.)
District Court Opinion
Plaintiff’s Opening Brief
IBM’s Response Brief
Plaintiff’s Reply Brief
Jane Farrell is an associate at the firm and passionate about telling workers’ stories and holding employers accountable. Most recently, Jane clerked for the Honorable Kimberly J. Mueller, Chief Judge of the United States District Court for the Eastern District of California. Before that, she worked as an associate at a plaintiff-side employment firm in San Francisco.
As a student at UCLA School of Law, Jane specialized in public interest law and policy. She served as editor in chief of the UCLA Journal of Gender and the Law and as chair of the Race, Work, and Economic Justice Clinic, which partnered with the Los Angeles Black Worker Center and Legal Aid at Work to provide free legal services for workers. During law school, Jane also externed for the Honorable Jacqueline H. Nguyen on the U.S. Court of Appeals for the Ninth Circuit, clerked for a plaintiff-side employment firm, and worked as a research assistant for two professors.
Before law school, Jane was a policy advisor to then-Secretary Tom Perez at the U.S. Department of Labor, where she helped expand access to earned sick time and paid family and medical leave. Prior to joining the Obama Administration, she researched and wrote about the changing nature of work, rising inequality, equal pay, and women’s rights at the Center for American Progress and then the Clinton Foundation, authoring dozens of publications over five years.
Jane has published articles in three law journals, including the Berkeley Journal of Employment and Labor Law, the leading law review for employment and labor law scholarship.
UCLA School of Law, J.D.
Emory University, B.A., Political Science
Member, State Bar of California, 2021
Bradley Manewith is a partner with Lichten & Liss-Riordan, P.C. Brad has focused his career on representing workers who have been mistreated by their employers. He has extensive experience litigating and negotiating wage and hour claims on behalf of classes of employees. Brad also regularly represents individuals with issues related to unpaid commissions and other compensation, the Family and Medical Leave Act, and workplace discrimination.
Brad has represented employees in wide variety of industries, including delivery drivers, restaurant workers, food manufacturers, and exotic dancers. He has obtained class certification and summary judgment on behalf of his clients, and he has been involved in multiple successful landmark appellate cases. Brad has recovered millions of dollars for the workers he has represented.
Brad is recognized by his peers and opponents as a highly knowledgeable and effective employment law litigator. He has been named a “Super Lawyer” for employment litigation by Illinois Super Lawyers since 2019, and was recognized as a “Rising Star” from 2013 until 2018. He has also been named “Leading Lawyer.” Brad currently serves as a member of the Executive Board for the Illinois Chapter of the National Employment Lawyers Association.
Prior to joining Lichten & Liss-Riordan, P.C., Brad was a partner at a Chicago-based plaintiff employment law firm.
University of Illinois, College of Law, J.D., cum laude
University of Illinois, B.A. in political science; B.A. in History
Member, State Bar of Illinois, 2003
Member of the Trial Bar for the U.S. District Court for the Northern District of Illinois, 2013
Admitted to practice before the Illinois Supreme Court, U.S. Court of Appeals for the Seventh Circuit, and U.S. District Courts for the Northern District of Illinois and the Central District of Illinois.
O’Grady v. Merchant Exchange Prods. dba The Julia Morgan Ballroom,
CGC-15-547796 (San. Fran. Sup. Ct.)
If you worked as banquet server or bartender at the Julia Morgan Ballroom as an employee in 2011 or 2012 (or worked banquet events at the Julia Morgan Ballroom through a staffing company), you are a member of the certified class in the O’Grady case. Plaintiff claims a service charge was imposed on banquet events held at the Julia Morgan Ballroom and was kept by defendant rather than being paid to service staff who worked there between September 8, 2011 and July 1, 2019.
In order to participate in this case, you do not need to do anything. To be excluded from this lawsuit, you must either send an e-mail to email@example.com with your name, address, and the statement, “Please exclude me from the Julia Morgan Ballroom lawsuit,” or a letter containing this information to: P.O. Box 26170 Santa Ana, CA 92799. The deadline to request exclusion is April 8, 2022.
If you have any questions about this Notice or would like more information about this lawsuit, you may write, call, or e-mail Attorney Shannon Liss-Riordan of Lichten & Liss-Riordan, P.C., at (617) 994-5800, or e-mail firstname.lastname@example.org.
As a lawyer, Mel previously worked at Make the Road New York as an Equal Justice Works Fellow, where he advocated for NYC’s restaurant delivery workers to improve working conditions in traditional and new on-demand economy through organizing, direct representation, education, and policy reform. Later he worked on the worker’s rights team at Takeroot Justice and the Gender Equality Law Center. He has also worked at Al Otro Lado and Centro de los Derechos del Migrante in Mexico, assisting asylum seekers and migrant farmworkers. Mel has published two law review articles about the intersection of bail reform and consumer protection. Before becoming a lawyer, Mel was a teacher in Chicago. Outside of work, Mel enjoys playing music and rock climbing.
Mel Gonzalez et al., Crimsumerism: Combating Consumer Abuses in the Criminal Legal System, Harvard Civil Rights-Civil Liberties Law Review, 2019
54 Harv. C.R.-C.L. L. Rev. 107 (2019)
Mel Gonzalez, Consumer Protection for Criminal Defendants: Regulating Commercial Bail in California, California Law Review, 2018
106 Calif. L. Rev. 1379 (2018)
University of California, Berkeley, J.D.
University of Illinois, Masters in Education
University of Chicago, Bachelor of Arts
Member, State Bar of New York
Matt is an employee- and union-side labor and employment lawyer who represents workers in wage and hour litigation, independent contractor misclassification actions, discrimination claims, and labor disputes. Matt has represented ride share and delivery drivers, construction laborers, grocery store workers, exotic dancers, and tech workers in class and individual actions against major corporations and other employers.
Prior to joining Lichten & Liss-Riordan, P.C., Matt practiced litigation and employment law at a major international law firm.
During law school, Matt was a research assistant at Harvard’s Labor and Worklife Program, where he worked on the Clean Slate for Worker Power project, and a regular contributor to OnLabor.org. He also represented refugee claimants in Massachusetts and at the Texas-Mexico border as a student attorney at the Harvard Immigration and Refugee Clinic and served as Co-Director of the International Refugee Assistance Project.
Harvard Law School, J.D., cum laude
New York University, M.A. Near Eastern Studies
McGill University, B.A. Middle East Studies, Dean’s Honor List; First Class Honors
Member, State Bar of Massachusetts, 2019
Admitted to practice before the U.S. District Court for the District of Massachusetts
Matthew Patton is a committed advocate for economic and social justice who represents workers in wage and hour litigation, employment discrimination matters, and labor disputes in state and federal courts and before administrative agencies. He is currently engaged in a number of collective and class actions and individual employment matters involving workers across industries in the private and public sectors.
Prior to joining Lichten & Liss-Riordan, Matt developed and litigated healthcare fraud recovery actions under the federal False Claims Act and RICO Act.
While in law school, Matt assisted the City of Boston in enforcing landlord compliance with low-income rental restrictions to ensure tenants were not being taken advantage of. Prior to practicing law, Matt worked to advance issues critical to reducing income inequality, such as an increase to the minimum wage, paid sick leave, and universal pre-kindergarten. Throughout his adult life Matt has volunteered with the Special Olympics International—including assisting in the launch of their campaign to end discrimination against individuals with intellectual disabilities–Spread the Word to End the Word.
Troopers sue Mass. State Police for alleged discrimination against new parents
Boston Globe | March, 2022
New England Law Boston, J.D., 2018
The Catholic University of America, B.A., 2005
Member, State Bar of Massachusetts, 2018
Admitted to practice before the U.S. District Court of Massachusetts
Krysten Connon is an experienced and dedicated attorney. She represents workers in disputes against their employers and primarily concentrates her practice on wage and hour class and collective actions arising under the Fair Labor Standards Act and state laws. Krysten has represented workers from a variety of backgrounds and in various industries, including cable and satellite installers, delivery drivers, and nurses.
Krysten graduated summa cum laude from the Drexel University Thomas R. Kline School of Law, and she is a Phi Beta Kappa graduate of the University of Maryland. Following law school, Krysten served as a federal judicial law clerk before joining the commercial litigation department of a national law firm, where she represented clients in complex commercial litigation and arbitration matters. Krysten also worked as a Staff Attorney at Women Against Abuse, where she litigated cases originating as domestic violence matters. Prior to joining Lichten & Liss-Riordan, Krysten worked as an attorney in the employment rights group of a plaintiff-side class action law firm.
Additionally, Krysten co-authored the 2015 Oxford University Press book, Living in the Crosshairs: The Untold Stories of Anti-Abortion Terrorism, which presents the results of extensive interviews with abortion providers around the intersections of law, policy, and anti-abortion violence. She regularly volunteers her time and expertise on issues related to reproductive health, rights, and justice.
Krysten was named a Pennsylvania Rising Star in 2020 and 2021 by Thomson Reuters’ Super Lawyers. .
Drexel University Thomas R. Kline School of Law, JD, summa cum laude, 2012
University of Maryland – College Park, cum laude, Phi Beta Kappa, 2009
Member, State Bar of New Jersey, 2013
Member, State Bar of Pennsylvania, 2013
Admitted to practice before the U.S. District Court of New Jersey, U.S. District Court for the Eastern District of Pennsylvania, and the U.S. Court of Appeals for the Ninth Circuit.
Sarah R. Schalman-Bergen is a partner at Lichten & Liss-Riordan P.C., who has dedicated her career to creating systemic change for workers and individuals who are not being treated fairly. She has secured numerous significant settlements for the workers she represents, totaling well over $100 million.
While representing workers in all types of industries, Sarah has successfully challenged unlawful business practices involving last-mile logistics companies, cable installation companies, home health aide companies, meat and poultry plants, landscaping companies, in white collar jobs, and in the government. This litigation has resulted both in payment of back wages and in practice changes by the companies.
Sarah also represents clients in antitrust cases involving labor markets. For example, she has prosecuted challenges to “no poach” agreements that allegedly suppressed employees’ wages, and she has defended clients against antitrust claims brought to impede their rights to organize for better working conditions. Sarah also represented the City of Philadelphia against a major bank for allegedly discriminatory practices, in violation of the Fair Housing Act.
Sarah works in partnership and routinely co-counsels with public interest law firms to lend expertise to their mission in litigation. She has served as volunteer of counsel to the AIDS Law Project of Pennsylvania for more than a decade, litigating discrimination and HIV-confidentiality cases. Sarah was honored for this work as an “Unsung Hero” by the Legal Intelligencer, Pennsylvania’s daily law journal.
Sarah conducts her practice according to the highest ethical standards, and has received high judicial praise, including being described as “ethical, talented, and motivated to help hard working men and women” and “some of the finest legal representation in the nation.”
Sarah routinely speaks at conferences on issues relating to workers’ rights. She currently serves on Cornell’s ILR-Hotel School CIHLER Advisory Board, and is a Board Member of the Keystone Research Center. Sarah was named a 2020 Pennsylvania Super Lawyer, after being named as a Rising Star in every year over the prior decade. In 2021, she was named in Best Lawyers in America. In 2015, she was honored as a “Lawyer on the Fast Track” by The Legal Intelligencer.
Prior to joining the Firm, Sarah was a partner at a plaintiff-side class action law firm, where she served as co-chair of the firm’s employment rights practice group. She has also practiced in the litigation department at a large Philadelphia firm, where she represented clients in a variety of industries in complex commercial litigation. Sarah received her J.D. cum laude from Harvard Law School and her B.A. summa cum laude from Tufts University.
Hickman v. TL Transportation, LLC, Amazon.com, et al., No. 2:17-cv-01038-GAM; 317 F. Supp. 3d 890; 318 F. Supp. 3d 718 (E.D. Pa. 2020) ($1.8m settlement on behalf of Delivery Associates in wage claim against third party company of Amazon; favorable opinions on liability, personal jurisdiction, individual liability, and conditional certification)
Merino v. Wells Fargo & Co., 2:16-cv-07840-ES-MAH (D.N.J. 2020) (co-lead counsel in $35 million wage and hour settlement on behalf of personal bankers)
Holbert v. Waste Management, Inc., No. 2:18-cv-02649-CMR (E.D. Pa. 2019) (lead counsel in $14.7 million FLSA nationwide settlement on behalf of 31,000 waste collectors)
Nicks v. Koch Meat Co., Inc., No. 16-cv-6446; 2016 WL 6277489; 260 F. Supp. 3d 942; 265 F. Supp. 3d 841 (N.D. Ill. 2019) ($1,832,000 settlement on behalf of chicken catchers in wage claim against national integrated poultry processor; favorable opinions on jurisdiction, corporate entity structure, certification)
City of Philadelphia v. Wells Fargo & Co., 2:17-cv-02203-AB, 2018 WL 424451 (E.D. Pa. 2019) (represented City of Philadelphia in Fair Housing Act litigation resolved for $10 million and injunctive relief for sustainable housing-related programs to promote and preserve homeownership for low- and moderate-income residents.)
Smith v. Allegheny Technologies, Inc., 754 Fed. Appx. 136 (3d Cir. 2018) (allegations by temporary workers hired to cross picket line and work in steel plant during lockout of union workers were sufficient to state claim for travel time compensation under Pennsylvania law)
Beckett v. Aetna, Inc., 2:17-cv-03864 (E.D. Pa. 2018) (Co-lead counsel with AIDS Law Project of Pennsylvania and Legal Action Center in $17 million settlement for the largest HIV confidentiality breach in U.S. on behalf of 12,000 class members)
The Broadway League v. Bernard Telsey Casting, Inc., Internat’l Brotherhood of Teamsters Theatrical Drivers and Helpers Local 817, et al., No. 1:17-cv-9515 (S.D.N.Y. 2018) (defended casting directors and union in antitrust action challenging lawfulness of organizing activity)
Smith v. Milton Hershey School, No. 11-7391, 2012 WL 1966125 (E.D. Pa. 2012) ($730,000 and injunctive relief settlement on behalf of 13 year old student alleged to have been refused enrollment in school because of his HIV status)
Canal Side Care Manor, LLC v. Pa. H.R.C., 30 A.3d 568 (Commw. Ct. 2011) (affirming $55,000 trial award on behalf of HIV positive woman denied housing at personal care home)
TIAA-CREF v. Bernardo, 683 F. Supp. 2d 344 (E.D. Pa. 2010) (summary judgment in declaratory judgment action to award retirement benefits to domestic partner of deceased doctor)
Harvard Law School, J.D., cum laude, 2007
Tufts University, B.A., summa cum laude, 2001
Member, Bar of Pennsylvania, 2007
Admitted to practice before the U.S. Supreme Court; U.S. Court of Appeals for the Third, Fourth, Sixth, Eighth and Ninth Circuits; U.S. District Courts for the Eastern, Middle, and Western Districts of Pennsylvania, District of Colorado, Eastern and Western Districts of Arkansas, Northern District of New York, Northern District of Illinois, Southern District of Indiana, Northern District of Ohio, Eastern District of Michigan, Western District of Tennessee, Southern and Eastern District of Texas, District of Nebraska; and U.S. Bankruptcy Court for the Eastern District of Pennsylvania.
Effective Date: January 1, 2020
Last Reviewed on: June 15, 2020
This Privacy Notice for California Residents supplements the information contained in Lichten & Liss-Riordan’s general privacy notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We obtain the categories of personal information listed above from the following categories of sources:
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We only share your information with service providers (such as companies who assist us in sending emails, physical mailings, text messages and/or surveys) and other law firms or vendors with whom we have partnered to litigate or investigate potential cases. These service providers and law firms may have access to personal information needed to perform their functions but are not permitted to sell, share, or use such information for any other purposes.We may also disclose your personal information:
By submitting personal information to our website, you consent to receiving emails from us in the future. If you do not wish to receive these communications, please request removal by clicking unsubscribe at the bottom of the email, or email email@example.com and ask to be placed on a “do not e-mail” list.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Toll Free Phone:
Lichten & Liss-Riordan, P.C.
Attn: Business Manager
729 Boylston Street, Suite 2000
Boston, MA 02116