J. Madison PLC is honored to announce the court's final approval of a significant settlement in Carole Keller, et al. v. Event Staging, Inc., et al. (Civil No. 2:24cv288), a victory for Virginia's theatrical production workers. On May 19, 2025, Judge Arenda L. Wright Allen of the U.S. District Court for the Eastern District of Virginia affirmed the agreement, secured through the remarkable initiative and courage of our clients, Carole Keller, Maggie Price, and Mary Givens. Their proactive efforts not only brought their own claims to light but have also created a pathway for many other crew members to recover unpaid wages.

The Plaintiffs' Stand: Challenging Unfair Pay Practices

This case was driven by the determination of Carole Keller, Maggie Price, and Mary Givens. These dedicated stage crew members bravely stepped forward to challenge the alleged unlawful pay practices of Event Staging, Inc. ("ESI"). They detailed how ESI, a company that provides local staffing for major touring Broadway shows like Wicked and Hamilton, allegedly failed to pay for all hours worked, denied overtime, made improper deductions, and, critically, retaliated against them when they spoke out.

Illustration of three silhouetted women working on laptops, with icons of documents, witness profiles, calendar entries, and location pins streaming into a pixelated storage box labeled “Keller v. ESI,” symbolizing collaborative legal case-building.
Three workers build their case together, transforming digital evidence into a powerful case file.

Empowered by Innovation: How Clients Built Their Case with Cloud Counsel

The fight for fair pay in Keller v. Event Staging was uniquely powered by the plaintiffs themselves. Carole Keller, Maggie Price, and Mary Givens utilized Cloud Counsel, an innovative online platform developed by Virginia Attorney Jacob M. Small, to meticulously construct their case file. As one of the pioneering users even before Cloud Counsel's official 2024 launch, Ms. Keller, alongside her co-plaintiffs, built an extraordinarily detailed timeline of events embedded with crucial information. Through Cloud Counsel, they documented their experiences, identified all involved parties, and uploaded crucial supporting documents, effectively teaching us, with the assistance of sophisticated AI tools integrated into the platform, how the evidence, facts, and witnesses fit together to tell their story.

As far as we are aware, Keller v. ESI represents the Nation's first settlement of a class- or collective-action lawsuit built by multiple plaintiffs working collaboratively in a law firm's proprietary cloud-based app to assemble a case file as a proposal for representation.J. Madison PLC

This client-driven approach, central to Cloud Counsel, allowed J. Madison PLC to gain a deep understanding of the case from the outset paired with a powerful tool: the Cloud Counsel timeline of events, each embedded with witness annotations and evidence. The comprehensive timeline our clients built served as a powerful application for our contingent-fee representation. J. Madison PLC then leveraged this client-built foundation to effectively advocate for our clients and the class in court.

A Victory for the Crew, Validated by the Court

Despite vigorous denials from the employer, the detailed case built by our clients led to a successful resolution through a court-supervised settlement conference. The approved $82,000 settlement provides direct payments to Ms. Keller, Ms. Price, and Ms. Givens for their claims and acknowledges their crucial role in bringing this action forward. It also includes $35,000 for J. Madison PLC’s attorneys' fees and costs.

A representation of court-approved settlement checks made out to the wardrobe stagehands.
A mock settlement check labeled “Approved by Court,” made out to “Wardrobe Stagehands” and issued by “ESI,” with illegible scribbles in place of a dollar amount.

In her Order approving the settlement, United States District Judge Arenda L. Wright Allen specifically acknowledged counsel's background, stating, "the Court is satisfied that Mr. Small has knowledge of the applicable law". Furthermore, Judge Allen found the awarded attorneys' fees to be "reasonable under these circumstances," noting that Mr. Small's $440 hourly rate "is consistent with rates in the Eastern District of Virginia". This judicial validation of our firm's experience and the fairness of our fee structure underscores the high-quality representation provided to these deserving clients.

Important Information for ESI Crew Members

This hard-won settlement extends benefits to a wider group of Event Staging, Inc. employees. If you performed hourly work for ESI in specific roles between 2021 and 2023, you may be eligible for payment.

Six diverse backstage crew members from various departments—wardrobe, props, hair & makeup, electric, audio, and fly rail—smiling together in a candid backstage moment, symbolizing solidarity and inclusion in the settlement class.
Wardrobe, props, hair & makeup, electric, audio, and fly rail crew—all united behind the scenes and now included in the settlement.

Who is Included?

  • The "Settlement Class Members" are: "Every current or former employee of ESI that performed hourly services for ESI during the calendar years 2021, 2022, and 2023 in the wardrobe, props, hair & makeup, electric, audio, and fly rail departments."

Action Required (Opt-In Process)

  • ESI is required to mail an official Notice of Opportunity to Join Settlement of Wage and Hour Lawsuit and a Consent to Join Settlement form to all eligible crew members by approximately June 18, 2025 (within 30 days of the Court's May 19, 2025, approval).
  • To receive your payment, you MUST complete, sign, and return the "Consent to Join Settlement" form by the deadline specified in your Notice. This deadline will be 60 days from when ESI mails the Notice. This deadline is critical.

Your Potential Payment

  • Eligible crew members who submit a timely and valid opt-in form will receive a payment equal to 5% of their total gross pay earned from ESI between January 1, 2021, and December 31, 2023, for work in the covered departments.

Know Your Rights

  • By joining, you release ESI from specific wage and hour claims for the 2021-2023 period, as detailed in the settlement agreement. 
  • Retaliation by ESI or any employer for participating in this settlement is illegal.

Believe You're Eligible But Didn't Receive a Notice? Don't Delay in Reaching Out.

While ESI is mailing notices, if you meet the definition of a Settlement Class Member above and have not received a Notice package in the mail by early July 2025, we encourage you to contact our firm promptly. It's important to ensure you have the opportunity to participate if eligible, and addressing potential notice issues in a timely manner is key. We can help determine if you were identified as a class member or assist with next steps.

Questions After Receiving Your Notice?

Once you have received your official Notice and Consent to Join Settlement form, if you have questions about the settlement or the opt-in process, you are encouraged to contact:

J. Madison PLC

1750 Tysons Boulevard,

Suite 1500

McLean, Virginia 22102

Email: info@jmadisonplc.com

Phone: 1-703-910-5062

Fax: 703-910-5107

J. Madison PLC: Proudly Supporting Workers Who Stand for Their Rights.

The resolution in Keller v. Event Staging is above all a victory for Carole Keller, Maggie Price, and Mary Givens, and the broader class of ESI crew members who will benefit. Their courage in stepping forward, and their diligence in building their case using tools like Cloud Counsel, were instrumental. J. Madison PLC is honored to have facilitated their fight for justice, and we deeply appreciate the Court's recognition of our firm's capabilities in achieving this outcome. We remain committed to empowering employees and holding employers accountable.

If you are an employee facing workplace injustices, J. Madison PLC offers a distinct, technology-driven path to help you organize your facts, understand your options, and seek dedicated legal representation.