If you are a Class Member, and you do not opt out of the Settlement, and the Settlement becomes final, you will be releasing Defendant from any liability regarding any and all claims associated with this case. You will give up your right to be part of any another lawsuit against the City regarding the claims resolved by the Settlement and released by the First Amended Stipulation of Settlement. The specific claims you will release are specified in the First Amended Stipulation of Settlement as follows:
In consideration for the Settlement it is hereby agreed that, upon the Effective Date, Class Representatives and each Class Member, on behalf of themselves and any other legal or natural persons who may claim by, through or under them, shall be deemed to have fully, finally and forever released and discharged the Released Parties from any and all Released Claims arising during the Class Period, whether known or unknown, suspected or unsuspected, contingent or non-contingent, derivative or direct, asserted or unasserted, whether based on federal, state or local law, statute, ordinance, regulation, code, contract, common law, or any other source, or any claim of any kind. Class Representatives and Class Members expressly agree that this Release, the Final Order, and/or the Final Judgment are, will be, and may be raised as a complete defense to, and will preclude any action or proceeding encompassed by, this Release.
Class Representatives and Class Members shall not, now or hereafter, institute, maintain, prosecute, and/or assert any suit, action, and/or proceeding, against the Released Parties, either directly or indirectly, on their own behalf, on behalf of a class or on behalf of any other person or entity with respect to the claims, causes of action, and/or any other matters released through this Settlement.
In connection with this Agreement, Class Representatives and Class Members acknowledge that they may hereafter discover claims presently unknown or unsuspected, or facts in addition to or different from those that they now know or believe to be true concerning the subject matter of the Action and/or the Release herein. Nevertheless, Class Representatives and Class Members intend to, and do hereby, fully, finally, and forever settle, release, discharge, and hold harmless the Released Parties from all such matters, and all claims relating thereto which exist, hereafter may exist, or might have existed (whether or not previously or currently asserted in any action or proceeding) with respect to the Action.
Without in any way limiting its scope, and, except to the extent otherwise specified in the Agreement, this Release covers by way of example and without limitation, any and all claims for attorneys’ fees, costs, expert fees, consultant fees, interest, litigation fees, costs or any other fees, and/or disbursements incurred by any attorneys, Class Counsel, Class Representatives, Settlement Administrator, or Class Members who claim to have assisted in conferring the benefits under this Settlement upon the Class.
The Class Period is April 16, 2014 through the date of entry of the Judgment.
The Released Claims are:
Any claims that were asserted, or that could reasonably have been asserted in the Action (based upon and/or arising out of the facts alleged in the Complaint), against the Released Parties, and that arise out of, or relate in any way to, any or all of the acts, omissions, facts, matters, transactions, or occurrences that were alleged in the Action (based upon and/or arising out of the facts alleged in the Complaint).
The Released Parties are:
Defendant, and each of its past, present, and future employees, officials, agents, attorneys, administrators and advisors, including, but not limited to, the Mayor of the City of Los Angeles, Members of the City Council for the City of Los Angeles, Managers of the City of Los Angeles, Clerks of the City of Los Angeles, and Finance Directors for the City of Los Angeles.