Case No. 24-2-16520-7
Case Information
Manuel Gonzalez Paniagua v. United Rentals (North America), Inc.
Superior Court of the State of Washington for the County of King
Who Is Included?
All current and former non-exempt employees who worked for Defendant in Washington at any time from July 23, 2021, through March 23, 2026.
What Is the Action About?
The Class Representative is a former employee of Defendant. The Class Representative alleged Defendant violated Washington labor and employment laws as follows: (1) Minimum Wage Act Violations: RCW 49.46 et seq.; (2) Failure to Pay Overtime Wages: RCW 49.46.130; (3) Meal Period Violations: RCW 49.12.020 and WAC 296-126-092; (4) Rest Break Violations: RCW 49.12.020 and WAC 296-126-092; (5) Unpaid Wages on Termination: RCW 49.48 et seq.; and (6) Willful Refusal to Pay Wages: RCW 49.52.050. Plaintiff is represented by Ferraro Vega Employment Lawyers and Rekhi & Wolk, P.S. ("Class Counsel").
Defendant denies violating any laws or failing to pay any wages and contends it complied with all applicable laws.
What Are the Proposed Settlement Terms?
At the Final Approval Hearing, the Class Representative, through Class Counsel, will ask the Court to approve a Gross Settlement Amount of $1,900,000.00 and authorize the following payments from that amount: Service Payment to the Class Representative ($10,000.00); Attorneys' Fees in the amount of $633,270.00, representing 33.33% of the Gross Settlement Amount; Litigation Costs (not to exceed $30,000.00), and the Administration Expenses to be paid to the third-party settlement administrator (not to exceed $15,000.00).
After the above deductions in amounts approved by the Court, the Administrator will calculate and distribute Individual Class Payments to Participating Class Members. One-third of each Individual Class Payment shall constitute taxable wages ("Wage Portion") and two-thirds shall constitute interest and exemplary damages ("Non-Wage Portion"). The Wage Portion is subject to withholdings and will be reported on IRS W-2 Forms. Defendant's employer payroll taxes owed on the Wage Portion will be paid by Defendant separately and in addition to the Gross Settlement Amount. The Administrator will report the Non-Wage Portions of the Individual Class Payments on IRS 1099 Forms.
You will be treated as a Participating Class Member, participating fully in the settlement, unless you submit a signed Request for Exclusion by September 21, 2026 (the "Response Deadline").
Release of Claims
After the Judgment is final and Defendant has fully funded the settlement, Participating Class Members will be legally barred from asserting any of the claims released under the settlement. In consideration for Defendant's payment of the Gross Settlement Amount, upon the Final Approval Hearing, and upon the full funding of the Gross Settlement Fund, Plaintiff and Participating Class Members shall release all claims that have been or could have been brought against the Released Parties based on the facts asserted in the Operative Complaint, including state and municipal wage and hour claims ("Class Release").
How Is My Individual Class Payment Calculated?
The Administrator obtained employment information for each Class Member, including how long they worked for Defendant. The Individual Class Payments will be calculated based on the number of weeks worked during the Class Period as a proportion of the total Net Settlement Amount.
How Will I Get Paid?
The Administrator will send, by U.S. mail, a single check to every Participating Class Member following the Effective Date of this Settlement. Your check will be sent to the same address as this notice. If you change your address, notify the Administrator as soon as possible.