IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IGNACIO BLANCAS, PEDRO MORALES, 

SALVADOR QUINTANA, ARTURO 

AVILA, and ARTURO ORTIZ, on behalf of 

themselves and other similarly situated 

persons, 

Plaintiffs,

 v.

CAIRO & SONS ROOFING CO, INC., and 

MARIO CAIRO

Defendants.

Case No. 12 C 2636

Judge Durkin

PLAINTIFFS’ UNOPPOSED MOTION FOR FINAL 

APPROVAL OF THE STIPULATION OF SETTLEMENT BETWEEN

PLAINTIFFS AND DEFENDANTS CAIRO & SONS ROOFING CO, INC., AND MARIO 

CAIRO

Now come Plaintiffs Ignacio Blancas, Pedro Morales, Salvador Quintana, Arturo Avila,

and Arturo Ortiz, on behalf of themselves and other similarly situated persons, (collectively 

“Plaintiffs”), and move this Court for Final Approval of the Stipulation of Settlement between 

Plaintiffs and Defendants Cairo & Sons Roofing Co, Inc., and Mario Cairo (the “Settlement”). 

In support of their Unopposed Motion for Final Approval, Plaintiffs state as follows:

1. On August 20, 2013, this Court granted Preliminary Approval to the Parties’ 

Three Hundred Thousand and 00/100 Dollars ($300,000.00) settlement of Plaintiffs’ individual 

claims for alleged unpaid wages on behalf of themselves and on behalf of a class of other 

similarly situated employees of Defendants Cairo & Sons Roofing Co, Inc., (hereafter "CSR") 

and Mario Cairo (collectively “Defendants”) arising under the Fair Labor Standards Act, 29 

U.S.C. §201 et seq. (“FLSA”), the Illinois Minimum Wage Law, 820 ILCS 105/1 et seq.

Case: 1:12-cv-02636 Document #: 39 Filed: 12/06/13 Page 1 of 3 PageID #:214
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(“IMWL”), and the Illinois Wage Payment and Collection Act, 820 ILCS 115/1 et seq.

(“IWPCA”) for alleged unpaid work performed "off the clock" including overtime wages and 

other earned wages resulting from the alleged non-payment of all time worked.

2. Final approval is appropriate where the court determines that a settlement is fair, 

adequate, and reasonable. Synfuel Techs., Inc. v. DHL Express (USA), Inc., 463 F.3d 646, 652 

(7th Cir. 2005). In determining whether a settlement is fair, adequate, and reasonable, courts in 

the Seventh Circuit consider a variety of factors including:

a. the strength of plaintiffs’ case, weighed against the settlement offer;

b. the complexity, length, and expense of further litigation; 

c. the presence of collusion between the parties; 

d. the opinion of competent counsel; 

e. the reaction of class members to the proposal; and 

f. the stage of proceedings and discovery completed.

In re Mexico Money Transfer Litig., 164 F. Supp. 2d 1002, 1014 (N.D. Ill. 2000) (citing 

Donovan v. Estate of Fitzsimmons, 778 F.2d 298, 308 (7th Cir. 1985)). As explained in detail in 

Plaintiffs’ supporting memorandum of law, the Parties’ Stipulation of Settlement meets these 

factors and should be approved.

WHEREFORE, Plaintiffs respectfully request that the Court enter a Final Order 

approving the Parties’ Stipulation of Settlement. 

Case: 1:12-cv-02636 Document #: 39 Filed: 12/06/13 Page 2 of 3 PageID #:215
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Respectfully Submitted,

Dated: December 6, 2013

s/Christopher J Williams

Christopher J. Williams

Alvar Ayala

Workers’ Law Office, PC 

401 S. La Salle, Suite 1400

Chicago, Illinois 60605

(312) 795-9121

Attorneys for Plaintiffs

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