Represented Installed Building Products, LLC in matters including securing a pre-certification settlement of a 100+ member, 4-year class action in Florida. Plaintiffs’ claims were based on alleged failure to pay minimum wage and overtime caused by off-the-clock work. We adopted an aggressive approach to the case, quickly producing payroll records for the named plaintiff and clearly identifying that he was a piece rate worker and only entitled to half rate premiums for overtime. We followed this limited discovery with aggressive settlement negotiations that resulted in a settlement of nuisance value.