As a neutral since 2003, Deborah Haude has mediated and arbitrated class and collective actions, and has managed the settlement process of a large nationwide class action as a Special Master. In this work she draws on over 20 years of experience litigating class action and collective action lawsuits, including actions seeking hundreds of millions of dollars in pension or retiree medical benefits, under the ADEA, ERISA, the RLA and §301 of the LMRA. She also litigated or resolved severance pay, pension, WARN Act and discrimination class and collective actions, and was lead Illinois counsel and coordinating outside counsel for RIF age discrimination litigation in all other states for a major telecommunications company.
Special Master/Settlement Master
- Ms. Haude was selected by class counsel and defense counsel and approved by a federal district judge in the Northern District of Illinois to be Special Master for a large, complex and creative settlement of a nationwide class action sexual harassment lawsuit. Ms. Haude initially determined eligibility of putative class members, directed the claims and response process, conducted neutral fact‐finding, and adjudicated the claims of three tiers of claimants, including conducting hearings for one of the tiers. Following the adjudication phase, she monitored the company’s compliance with the consent decree for a two year period.
- Class A Claims Adjudicator in the settlement of a class action in which a large group of African-American Farmers alleged that the U.S. Department of Agriculture had discriminated against them with respect to government lending practices
- Mediated nationwide class action brought by management level employees claiming racial discrimination in promotions
- Mediated information exchanges and then settlement of class action brought by three subclasses of management and non‐management employees of a major nationwide home improvement chain for unpaid vacation pay and bonuses under the Illinois Wage Payment and Collection Act (IWPCA)
- Mediated collective and class action lawsuit brought by service technicians of well‐known nationwide business equipment corporation that they were due off‐the‐clock overtime under FLSA and NY state law for time spent during lunch and after work inputting data
- Mediated a number of other off‐the‐clock and/or misclassification class and collective action overtime claims and actions brought under various state laws and FLSA by employees of other industries and public employer. Addressed issues such as numerosity, commonality, manageability of hybrid FLSA/Rule 23 actions, calculation of damages, and applicability of recent case law
- Settled class gender and race discrimination actions and collective age discrimination action through mediation
- As arbitrator handled notice, release, fairness, and attorney fee determinations in a nationwide racial discrimination class action case alleging failure to promote and state law bonus and vacation pay claims
- Arbitrator in FLSA/state law wage and hour hybrid collective action involving claims of misclassification, including determinations relating to notice, conditional certification and settlement