1. Why did I get the Notice?
2. Am I covered by this Settlement?
3. What is the lawsuit about?
4. Why is this a collective action?
5. Why is there a settlement?
6. What are the payments under the settlement?
7. How do I opt in to the FLSA Claims and Settlement?
8. When will I get my Settlement Payment?
9. What am I giving up by releasing my claims?
10. Do I have a lawyer in this case?
11. How will the lawyers be paid?
12. When and where will the Court decide whether to approve the Settlement?
13. Do I have to come to the Fairness Hearing?
14. How Do I Object To The Settlement?
15. Are there more details about the Settlement?
16. How do I get more information?
The Court ordered that you be sent the Notice because you have a right to know about the proposed settlement of the lawsuit, and about all of your options, before the Court decides whether to approve the settlement. If the Court approves the settlement, and after any appeals are heard, payments will be mailed to you.
The Notice explains the lawsuit, the settlement, your legal rights, and what benefits are available.
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If Juniper’s records state that you were employed by Juniper in an exempt commissioned sales role in the United States outside of California sometime between September 7, 2019, through March 13, 2023 (“FLSA Settlement Collective Member”), then you are covered by the Settlement.
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The lawsuit, a collective action brought under the Fair Labor Standards Act (“FLSA”), claims Juniper misclassified certain employees who worked outside of California in commissioned sales roles as exempt from federal overtime protections, and as a result failed to pay these employees overtime compensation for the hours they worked in excess of 40 hours per week. This lawsuit is also a class action brought under the California Labor Code and a representative action brought under the California Labor Code’s Private Attorneys General Act (“PAGA”), each against Juniper.
Juniper denies these allegations and believes that individuals in these roles were properly classified as exempt. The Parties have entered into this settlement solely with the intention to avoid further disputes and the inconvenience and expense of litigation. The Court has not made any ruling on the merits of the claims, and no party has prevailed in this action.
You have been identified as a FLSA Settlement Collective Member per Section 2 above if you were employed by Juniper in one of the designated commissioned sales roles in the United States outside of California sometime between September 7, 2019, through March 13, 2023. Individuals who were employed by Juniper in one of the designated exempt commissioned sales role in California sometime between October 9, 2017, through March 13, 2023, are considered Class Members. If you are determined also to be a Class Member, you will also receive a California Class Notice separately from this FLSA Collective Notice.
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In a collective action, one or more people can seek to represent a “collective” of similarly situated people. The individuals who initiated this collective action are called the “Plaintiffs.” In a collective action, the Plaintiffs ask the court to resolve the issues for every member in the collective.
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The Court did not decide in favor of Plaintiffs or Juniper. Both sides believe they will prevail in the lawsuit, but there was no decision in favor of either party. Instead, the Parties have agreed to resolve this matter solely in order to avoid the burden, expense and risks associated with continuing the lawsuit. The Plaintiffs and Class Counsel think the settlement is in the best interests of all collective members.
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The proposed Settlement was negotiated between the attorneys for Defendant and Class Counsel. Class Counsel believe this Settlement is fair, reasonable, adequate, and in the best interests of FLSA Settlement Collective Members.
Gross and Net Settlement Amounts
In connection with this Settlement, Defendant agrees to pay a maximum potential settlement amount of Three Million Eight Hundred and Fifty Thousand Dollars ($3,850,000.00) (the “Gross Settlement Amount”). The Gross Settlement Amount is inclusive of (1) any award by the Court to Plaintiffs in recognition of their efforts and work in prosecuting the FLSA Action (“Enhancement Awards”); (2) a payment associated with the representative claims brought under PAGA in the amount of $200,000; (3) the settlement administration costs; and (4) any award by the Court to Class Counsel for Attorneys’ Fees and Expenses associated with the litigation of the FLSA claims in the Action.
The remaining Gross Settlement Amount is the Net Settlement Amount. 33.34% of the Net Settlement Amount is allocated for the FLSA Settlement Payment, which will be distributed to FLSA Settlement Collective Members who timely opt in to the FLSA Action by following the procedure as described in Section 7 below. The other 66.66% of the Net Settlement Amount is allocated to the California Class Members, to be distributed to individuals who worked for Juniper in California in a commissioned sales role and who meet the definition of a California Class Member as defined in the Settlement Agreement.
Individual FLSA Settlement Payments
Your estimated payment from the Net Settlement Amount is printed on your Notice. Half of the payment is subject to payroll deductions for applicable taxes and withholdings like any other paycheck, for which you will receive a W-2, and half of the payment is not subject to deductions and will be reported on a 1099. Neither Class Counsel nor Juniper’s counsel can advise you regarding the tax consequences of the Settlement. You may wish to consult with your own personal tax advisor in connection with the Settlement.
The formula that has been approved by the Court and used to calculate your payment considers the number of weeks you worked. The Settlement Agreement contains the exact allocation formula. You may obtain a copy of the Settlement Agreement online here or by contacting the Settlement Administrator at (833) 296-0894.
The Settlement Administrator used information from Juniper’s records to calculate your payment. If you have questions about your calculation, you may contact the Settlement Administrator at (833) 296-0894. If you dispute Juniper’s records and/or the calculation of your Settlement Payment, you must provide written documentation supporting your dispute and submit it to the Settlement Administrator. Juniper’s records are presumed to be correct unless you prove otherwise with documentary evidence. The Settlement Administrator will evaluate the information you provide and will make the final decision as to any dispute.
Undeliverable or Uncashed Checks
Any FLSA settlement check returned to the Settlement Administrator as undeliverable shall be sent promptly via First Class U.S. Mail to any forwarding address affixed thereto. If no forwarding address is provided, the Settlement Administrator shall promptly attempt to determine the correct address using a single skip-trace search, and it shall then perform a single re-mailing. FLSA settlement checks that remain uncashed 180 calendar days after the postmarked date of their initial mailing will be null and void.
Attorneys’ Fees and Expenses
When seeking final approval of the proposed Settlement, Class Counsel will apply to the Court for an award of Attorneys’ Fees in an amount up to one-third of the Gross Settlement Amount and an award of reasonable expenses associated with the litigation and resolution of the lawsuits subject to this Settlement.
Such payments, if approved by the Court, will be deducted from the Gross Settlement Amount before calculation of FLSA Settlement Amount to be distributed to FLSA Settlement Collective Members. If the Court does not approve or approves only a lesser amount than requested by Class Counsel for Attorneys’ Fees and Expenses, the other terms of the Settlement shall still apply. Any amount of the Attorneys’ Fees and Expenses requested by Class Counsel but unapproved by the Court will be allocated to the Net Settlement Amount.
Plaintiffs’ Enhancement Awards
When seeking final approval of the proposed Settlement, Class Counsel will apply to the Court for Enhancement Awards of up to $12,500 for Plaintiff Jamie Long and $10,000 for Plaintiff Marcus Serrano for their service in prosecuting the lawsuits subject to this Settlement. Such payments, if approved by the Court, will be deducted from the Gross Settlement Amount before calculation of FLSA Settlement Amount to be distributed to FLSA Settlement Collective Members. Any amount of the Enhancement Awards unapproved by the Court will be allocated to the Net Settlement Amount.
Settlement Administration Costs
Class Counsel intends to request that the Court approve Claims Administration Costs of up to $22,000 payable to the Settlement Administrator for administering the Settlement, including, but not limited to, printing, distributing, or tracking settlement notices, providing any required tax forms, processing any required tax payments or reporting, and calculating and distributing individual settlement payments. Any amount of Claims Administration Costs requested by Class Counsel but unapproved by the Court will be allocated to the Net Settlement Amount.
PAGA Payment
The PAGA Payment is for the resolution of the representative claims brought under PAGA in the Action, which are also subject to this Settlement. Class Counsel intends to request that the Court approve an allocation of $200,000 out of the Gross Settlement Amount to PAGA penalties. 75% of the PAGA Payment will be allocated to the LWDA and the remaining 25% will be distributed to PAGA Members on a pro rata basis based on the number of Eligible PAGA Pay Periods during the PAGA Period for each PAGA Member.
All Payments Subject to Court Approval
All of the payments listed above will be made if and only if the Court grants final approval of the Settlement and concludes it is reasonable, fair, and adequate for the resolution of the Action, and enters judgment in accordance with the terms of the Settlement. The Court may adjust the amounts of certain payments.
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You are receiving the Notice because you have been identified as a FLSA Collective Settlement Member. In order to opt into the FLSA claims and Settlement, you must return the Opt-In Consent Form enclosed with the Notice previously mailed to you via U.S. mail by June 21, 2025 or you will be excluded from the FLSA claims and Settlement, will not be bound by the release applicable to the FLSA claims in the Action, and will not receive a check.
You can also complete your Opt-In Consent Form online here using your Unique ID and PIN.
If you wish to give consent to opt in to the FLSA claims and be bound by the released FLSA claims and other terms of the Settlement, you must opt in by returning the Opt-In Consent Form enclosed with the Notice previously mailed to you or opting in electronically here no later than June 21, 2025.
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The Court will hold a hearing on October 22, 2025, at 2:30 p.m. to determine whether to finally approve the Settlement. If the Court approves the Settlement, and there are no appeals, settlement checks will be mailed within 10 days after the expiration date of the time for an appeal to have been filed. If there is an appeal, settlement checks will be mailed within 10 days after the date of the final affirmance on appeal of the Settlement or after the date of final dismissal of the appeal, whichever is later.
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You are releasing all federal wage and hour claims, obligations, demands, rights, causes of action, and liabilities, of whatever kind and nature, character and description, that arise out of or are reasonably related to any facts, transactions, events, policies, occurrences, acts, disclosures, statements, omissions, or failures to act pleaded in the lawsuit, including, but are not limited to, claims for overtime wages, damages, unpaid costs, penalties, liquidated damages, punitive damages, interest, attorneys’ fees, litigation costs, restitution, or equitable relief, based on any and all claims arising under the Fair Labor Standards Act of 1938 (“FLSA”), as amended, 29 U.S.C. §201, et seq. that have been or would have been asserted between September 7, 2019, through March 13, 2023.
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The Court has decided that the lawyers at the law firm of Lebe Law, APLC are qualified to represent you and all class members. You will not be charged for these lawyers. You do not need to retain your own attorney in order to participate in the settlement. If you want to be represented by your own lawyer, you may hire one at your own expense.
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The attorneys for the Plaintiffs will ask the Court to approve payment of up to one-third of the Gross Settlement Amount for their attorneys’ fees. These fees would compensate these attorneys for investigating the facts, litigating the case, and negotiating the settlement. Class Counsel will also ask the Court to approve payment of up to $20,000.00 for the out-of-pocket costs they incurred litigating the case. The Court may award less than these amounts. Juniper has agreed not to oppose the fee and cost requests provided the request is consistent with the Settlement Agreement.
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The Court will hold the Fairness Hearing on October 22, 2025, at 2:30 p.m., at the Santa Clara County Superior Court, at 191 N. First Street, San Jose, CA 95113.
At the hearing, the Court will determine whether the settlement is fair, adequate, and reasonable.
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No. The attorneys will attend to answer questions the Court may have. But you are welcome to come at your own expense. You may also pay your own lawyer to attend, but it is not necessary.
FLSA Settlement Collective Members may appear at the final approval hearing in person or remotely using the Microsoft Teams link for Department 19 (Afternoon Session), and should review the remote appearance instructions beforehand: https://www.scscourt.org/general_info/ra_teams/video_hearings_teams.shtml
FLSA Settlement Collective Members who wish to appear remotely are encouraged to contact Class Counsel at least three days before the hearing, if possible, so that potential technology or audibility issues can be avoided or minimized.
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You may object to the Settlement by mailing a written objection to the Settlement Administrator at the address below in Section 16 by June 21, 2025. The written objection must contain: (1) the name and case number of the Long Action (Long v. Juniper Networks (US), Inc., Superior Court of Santa Clara County, California, Case No. 22CV396462); (2) the full name and current address of the FLSA Settlement Collective Member making the objection; (3) the specific reason(s) for the objection; and, (4) any and all evidence and supporting papers (including, without limitation, all briefs, written evidence, and declarations).
A FLSA Settlement Collective Member who objected and did not opt into the Settlement by June 21, 2025, will be excluded from the FLSA claims and Settlement, will not be bound by the release applicable to the FLSA claims in the Action, and will not receive a check.
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This website and the Notice are a summary of the basic terms of the Settlement. For the precise terms and conditions of the Settlement, you are referred to the detailed Settlement Agreement, which is on file with the Clerk of the Court. The pleadings and other records in this litigation, including the Settlement Agreement, may be examined (a) online on the Superior Court of California, County of Santa Clara’s Electronic Filing and Service Website at www.scefiling.org or (b) in person at Records, Superior Court of California, County of Santa Clara, 191 N. 1st Street, San Jose, California 95113, between the hours of 8:30 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays and closures, or you may contact Class Counsel.
You also can get a copy of the Settlement Agreement here, from the Settlement Administrator or Class Counsel using the contact information below.
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If you have other questions about the Settlement, or you would like a copy of the Settlement Agreement you can access it here or contact the Settlement Administrator at:
Long v. Juniper Networks (US), Inc.
c/o Settlement Administrator
P.O. Box 26170
Santa Ana, CA 92799
Telephone: (888) 369-3780
Email: info@JuniperSettlement.com
You can also contact Plaintiffs’ attorneys at the addresses and/or telephone numbers below.
Jonathan M. Lebe (State Bar No. 284605)
Jon@lebelaw.com
Lebe Law, APLC
3900 W Alameda Avenue, 15th Floor
Burbank, California 91505
Telephone: (213) 444-1973
PLEASE DO NOT CONTACT THE COURT OR DEFENDANT’S COUNSEL FOR INFORMATION REGARDING THIS SETTLEMENT OR THE CLAIM PROCESS.
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