Resolution Services

SETTLEMENT PROGRAM DESIGN AND ALLOCATION

Simone brings meticulous attention to detail and rigorous analytical judgment to the design and implementation of complex settlement frameworks. In mass tort and commercial matters involving both current and future claims, she develops strategies and procedures that support comprehensive, durable resolutions for the benefit of the parties, insurers, and the courts.

She understands that the success of any settlement turns on its structure – including the legal vehicles employed, the financial architecture of payment terms, and the criteria and systems governing allocation and distribution. Whether crafting structured settlement mechanisms, developing fair and defensible allocation methodologies for multiple claimants, establishing eligibility standards, or refining other key settlement terms, Simone works to ensure clarity, equity, and finality. Her focus is on building systems that provide predictability in the distribution of agreed-upon funds and withstand scrutiny from all stakeholders.

At the same time, Simone approaches claims administration and allocation with a trauma-informed lens – recognizing that many large-scale disputes involve individuals who have experienced significant harm. Her training strengthens process integrity by promoting transparency, consistency, and procedural fairness, reducing unnecessary friction while preserving neutrality. The result is a disciplined, balanced framework that respects claimants, maintains the confidence of defendants and insurers, and supports the court’s mandate for efficient and equitable resolution.

Beyond high-level structural design, Simone oversees the full operational architecture of settlement programs. This work often includes the investment and safeguarding of settlement proceeds; development of allocation methodologies and claim evaluation protocols; establishment of clear eligibility criteria; staffing and training of claims personnel; preparation of notice materials, publication, advertising, and claim forms; implementation of secure online claims submission systems; distribution of funds; service as escrow or custodial agent; and the creation of hearing procedures and periodic reporting mechanisms as required. By integrating strategic design with disciplined execution, Simone ensures that settlement programs function smoothly, transparently, and in alignment with the expectations of courts, institutions, and claimants alike.

REPRESENTATIVE SETTLEMENT PROGRAM DESIGN AND ALLOCATION MATTERS

• Designed a non-litigation settlement program (set up by Columbia University and CUIMC) for the benefit of the victim-survivors who were impacted by the abuse, harm, and trauma by former gynecologist Robert Hadden
• Designed and allocated the settlement fund in Doe, et al. v. JP Morgan Chase, N.A., appointed by Judge Jed Rakoff (S.D.N.Y.)
• Designed and allocated the settlement fund in Doe, et al. v. Deutsche Bank Aktiengesellschaft, et al., appointed by Judge Jed Rakoff (S.D.N.Y.)
• Designed and allocated the Sexual Misconduct Claims Fund that was part of The Weinstein Company Bankruptcy Plan (approved by Judge Mary F. Walrath (Bankr. D. Del.))
• Special Master in the Farruggio et al. v. 918 James Receiver, LLC (rehabilitation and assisted living facility) class action settlement

MEDIATIONS

Simone has extensive experience mediating a wide range of complex disputes. In addition to matters involving sexual assault and harassment, she regularly handles Title IX proceedings, employment disputes, litigation funding matters, class and group actions, insurance coverage disputes, antitrust claims, bankruptcy-related cases, and fee disputes.

She is recognized for a pragmatic, steady, and disciplined approach to mediation. While many of these cases are emotionally charged and high-stakes, Simone balances empathy with analytical rigor – creating a process that is both humane and results-oriented. Her trauma-informed perspective enhances her ability to manage sensitive dynamics without compromising neutrality.

Simone commits herself to mastering the factual, legal, and financial issues in each matter. By thoroughly understanding the complexities at play – including risk exposure, coverage considerations, institutional concerns, and personal stakes – she helps parties navigate difficult terrain with clarity and confidence. Her goal is not simply resolution, but durable agreements reached through a process that is fair, efficient, and carefully structured.

REPRESENTATIVE MEDIATIONS

• Sexual Assault & Harassment Cases
  Hundreds of mediations including sexual assault victims/survivors on one side, and individuals, estates, organizations (and their insurers), and/or other defendants on the other side; class action settlement brought by the sexual abuse victim-survivors of Jeffrey Epstein against Deutsche Bank; class action settlement of various Plaintiffs and the NYAG against Harvey Weinstein and other Defendants, and Weinstein’s related companies; class action settlement of elder abuse claims by residents and residents’ families and estates in Farruggio et al. v. 918 James Receiver, LLC; the mediation and resolution of multiple issues related to Church abuse cases
• Title IX Matters
  Mediations with educational institutions regarding compliance with Title IX
• Litigation Funding Disputes
  Disputes about the enforceability of a litigation funding agreement 
• Coverage Litigation
  Extensive experience with GL, E&O, D&O, and Representation & Warranty policies
• Antitrust
  In re Auto Parts Antitrust Litigation; In re Broiler Chicken Antitrust Litigation
• Bankruptcy/Trustee
  The Weinstein Co. Holdings LLC et al.; In re Fresh & Easy, LLC
• Consumer Class Actions
  Kinder, Deborah, et al. vs. Meredith Corporation, et al.
• Fee Disputes
  Fee disputes among counsel post mediation; fee disputes between counsel and client post mediation
• Securities Class Actions
  Individual and class actions involving claims of fraud; cases alleging breach of fiduciary duty by financial advisors, brokers, etc.