WILLITS, et al v. CITY OF LOS ANGELES - Settlement Agreement and Release of Claims

U. "Settlement Class" means the class of all persons (including, without limitation, residents of and visitors to the City) with any Mobility Disability, who, at any time from the beginning of time through the term of this Settlement Agreement (as set forth in Section 8 below):

(i) accessed or attempted to access a Pedestrian Facility located in the City but were impaired or unable to do so due to any barrier or condition rendering such Pedestrian Facility not suitable or sufficient for use; or

(ii) allege that they would have accessed or attempted to access a Pedestrian Facility located in the City but for allegedly being denied such access due to any barrier or condition rendering such Pedestrian Facility not suitable or sufficient for use.