Saunders, et al. v. The City of New York, et al.

In this FLSA collective action, employees of the New York City Department of Education sued the City alleging denial of overtime pay. This case was complicated by the differing mix and quality of various data systems. An examination of the available data that were produced by the defendants revealed four data systems–two for recording time and two for recording payroll information. The transitions from the older time and payroll systems to newer systems had occurred during the liability period. In addition, the transitions had been staggered across different employees over multiple years resulting in four possible time and payroll system combinations for any given employee at any given time. The data also were incomplete and partially available only in paper or scanned formats. Further complicating the processing of these data was that some data from the older time system were in handwritten form.

Louis Lanier (prior to joining Econ One) was retained by counsel for the plaintiffs to process the data in these data systems in order to calculate any back pay damages that may have resulted from unpaid overtime. Additionally, Dr. Lanier was asked to value stocks and flows of comp time, which allegedly was paid illegally in lieu of cash under certain circumstances. Dr. Lanier submitted several expert reports addressing back pay damages associated with both unpaid overtime and comp time.