Suzanne Hawk v. Dog Sciences, LLC, d/b/a Unleashed Academy and Mary Davies

Case No.  23-2-00428-32

UNLEASHED ACADEMY / DOG SCIENCES, LLC

WAGE AND HOUR / OVERTIME LITIGATION

NOTICE OF CLASS ACTION SETTLEMENT & HEARING

On February 1, 2023, Plaintiffs filed the above-captioned action.  On February 23, 2023, Defendants answered and filed a counterclaim against Ms. Hawk personally. On April 10, 2023, Plaintiffs filed the Amended Complaint. On August 11, 2023, the Court certified the above-captioned action as a Class Action under the auspices of CR 23. On July 19, 2024, the Court denied Defendants’ motion to decertify the class as well as Plaintiffs’ motions for summary judgment as to class and individual claims.

Between February 2, 2023, and July 19, 2024, the Parties engaged in discovery on both liability and damages.  This discovery included over fifteen depositions, the retention of two experts, and the exchange of thousands of pages of discovery documents.

On June 26, 2024, the Parties engaged in a mediation before mediator Peter Erbland. The mediation was unsuccessful. After several follow-up communications and conversations, the Parties reached an oral agreement as to the essential terms of a settlement and memorialized that oral understanding and negotiated the written terms of a written Settlement Agreement in Principle which was fully-executed on August 23, 2024. As part of the settlement process Ms. Davies has signed a statement under oath affirming she has no other money than what has been offered to settle this case.

The Amended Complaint alleged, inter alia, that, as of the date of the Lawsuit’s commencement, the Defendants misclassified Behaviorists/dog trainers as independent contractors depriving them of minimum wages and overtime under the MWA and WPA. 

Unless otherwise stated herein, the Parties intend this Settlement Agreement to be a final and complete resolution of all Claims asserted in this Lawsuit.  The Parties agree that the terms of the Settlement were negotiated in good faith at arm's length by the Parties and were reached voluntarily after consultation with competent legal counsel.

The Court has preliminarily approved the Settlement. The Settlement will not become final unless and until the Court issues final approval after a hearing, which is currently scheduled for December 13, 2024 at 9:00 a.m. in Courtroom 407 of Spokane County Superior Court, 1116 W Broadway Ave., Spokane, Washington 99260. Pursuant to the Court’s Order Granting Preliminary Approval of the Settlement Agreement, Plaintiff was required to establish a website where class members can review the following documents:

  1. Motion for Preliminary Approval (Here)

  2. Settlement Agreement (Here) (also attached as Exhibit A to the Motion for Preliminary Approval)

  3. Plan of Allocation (Here) (also attached as Exhibit C to the Motion for Preliminary Approval)

  4. Order Granting Preliminary Approval (Here)

  5. Motion for Attorneys’ Fees and Service Award (Here)

  6. Motion for Final Approval (Here)