Case: 1:18-cv-03526 Document #: 113-2 Filed: 05/08/20 Page 1 of 4 PageID #:570

EXHIBIT B
Notice of Settlement
 Case: 1:18-cv-03526 Document #: 113-2 Filed: 05/08/20 Page 2 of 4 PageID #:571

DVORAK LAW OFFICES, LLC

6262 Kingery Highway, Suite 305
Willowbrook, IL 60527
Telephone: (630) 568-3190
www.civilrightsdefenders.com

Date*, 2020

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Re: Adair et al., v. Town of Cicero, 18 CV 3526

Notice of Proposed Class Action Settlement

This is a court-authorized notice that you may be entitled to receive compensation

in a class action lawsuit against the Town of Cicero. Your rights and options are
explained in this notice. This is not a lawsuit against you.

The Lawsuit

The plaintiffs in this case claim that the Town of Cicero subjects female arrestees to
unreasonable searches in violation of the Fourth Amendment by forcing them to
expose their genitals to the view of lockup employees and male arrestees when
using the toilet.

The court certified this case as a class action on behalf of all female arrestees who
were detained at the Town of Cicero Police Department lockup facility for eight
hours or more during the time period of May 18, 2016, to March 31, 2020. You were
identified as a member of the class because the Town’s records indicate that you
were detained in the Town of Cicero’s police lockup during the relevant time period.

The Proposed Settlement

The parties have reached a proposed agreement to settle this case, which has
received the preliminary approval of the court.

The proposed settlement provides two forms of relief:

First, the Town has agreed to modify its police department General Orders to
include a directive that male arrestees shall not be allowed to walk past the cells of
the female arrestees during processing and/or transportation at the Cicero police
Department.
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Second, the Town has agreed to pay $290,000 to settle this case. From that amount,
payments will be made to each of the five named Plaintiffs for representing the
class ($4,000 per named Plaintiff, for a total of $20,000); and to Class Counsel for
attorneys’ fees, costs incurred in litigating this case, and class administration costs
($145,000).

The remainder of the settlement amount ($125,000) will remain for distribution to
class members. Each class member will be entitled to a pro-rata share of the
Settlement Fund up to a maximum of $500 per class member. The amount payable
to each class member will be calculated based on the number of class members who
submit a timely Proof of Claim.

If fewer than 250 class members submit timely claims, the funds remaining in the
Settlement Fund shall be donated to Ascend Justice, a non-profit agency that
provides legal services to women in the Chicago-land area.

Your Options

1. Participate in the Settlement

If you want to participate in the settlement, you can do so by submitting the

enclosed Proof of Claim. Instructions for participating in the settlement and
obtaining your share of the settlement fund are set forth below under the heading
How to Obtain Compensation.

Please note that claims will not be paid until 90 days after this settlement receives
final approval of the Court.

2. Comment on or Object to the Settlement

You may comment on or object to the Settlement prior to final approval.

You may submit a written comment or objection by mail to Class Counsel Dvorak
Law Offices LLC at the address below. Comments or objections must be postmarked
no later than ***date (60 days from date the notice is sent). The objection must
contain (1) your name, (2) your address, (3) the grounds for the objection; and (4) the
case name and number Adair et al. v. Town of Cicero, 18 CV 3526.

The court has set this case for a Fairness Hearing on final approval of the
settlement on date** (30 days after objection deadline) at the United States District
Court for the Northern District of Illinois, 219 S. Dearborn Street, Courtroom 2188,
Chicago, Illinois 60604. All timely written objections will be provided to the court no
later than seven days prior to the Fairness Hearing. You may appear in person at
this hearing on your own behalf or through counsel. If you intend to appear at the

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hearing through counsel, you must identify the attorney(s), who will appear and
include the attorney(s) name, address, phone number, e-mail address. Only
individuals who submit a timely written objection will be heard at the Fairness
Hearing.

If the court rejects your objection, you will still be bound by the terms of the
Settlement.

3. Exclude Yourself from the Settlement

If you ask to be excluded (or “opt out”) of the settlement, you will not be bound by
the Settlement (including the Release of Claims) but will not receive any share of
the settlement proceeds.

If you elect to be excluded from the settlement, you may file an individual action or
seek to intervene in this action. The statute of limitations, which stopped running
on May 18, 2018, when this case was filed, will begin running again upon your filing
of a request for exclusion. You will have the same number of days to file suit as you
had on May 18, 2018.

Your request to exclude yourself must be postmarked by no later than *date (60
days from date the notice is sent), and sent to Class Counsel Dvorak Law Offices
LLC at the address below. Your request to exclude yourself (or “opt out”) of the
settlement, must be made in writing and must include (1) your name, (2) your
address, (3) a statement that you are excluding yourself from the settlement; and
(4) the case name and number Adair et al. v. Town of Cicero, 18 CV 3526.

How to Obtain Compensation

The only way to receive compensation is by submitting the enclosed Proof of Claim
to Class Counsel Dvorak Law Offices, LLC at the address below. Your Proof of
Claim must be postmarked no later than *date (90 days after final approval
hearing).

Further Information

Any questions you have concerning this notice or how to submit a claim should be
directed to the Dvorak Law Offices LLC at the address and/or phone number listed
below. Do not contact the court or the judge regarding this notice.

DVORAK LAW OFFICES, LLC

6262 Kingery Highway, Suite 305
Willowbrook, IL 60527
(630) 568-3190