A federal district court denied class certification to special investigators at Government Employees Insurance Company (GEICO) who alleged violations of the New York Labor Law for unpaid overtime wages, finding that while the Rule 23(a) requirements were satisfied, individual questions about each investigator’s experience with overtime approval, reporting, and compensation would predominate over common issues, and the plaintiffs’ damages expert’s methodology was unreliable and excluded under federal case law, making class certification inappropriate.
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