WILLITS, et al v. CITY OF LOS ANGELES - Notice of Proposed Settlement of Class Action Lawsuit

RELEASE OF CLAIMS

The Settlement Agreement resolves and releases for the thirty-year term of the Settlement Agreement, all claims for injunctive, declaratory or other non-monetary relief that were brought, could have been brought, or could be brought in the future under any disability and/or accessibility laws and that relate to the accessibility of any of the City’s Pedestrian Facilities to individuals with mobility disabilities. The Settlement Agreement does not provide for any monetary relief to the Settlement Class, and it does not release any damages claims that Settlement Class members may have.

The Parties shall also jointly request the Court issue the following findings:

(i) The City’s implementation of the Settlement Agreement assures that the City’s Pedestrian Facilities, when viewed in their entirety, are readily accessible to and usable by individuals with Mobility Disabilities.

(ii) The Settlement Agreement sets forth a reasonable time period and reasonable expenditures of funding for making necessary improvements to assure that the City’s Pedestrian Facilities, when viewed in their entirety, are readily accessible to and usable by individuals with Mobility Disabilities.

(iii) There is no evidence before the District Court that the City has intentionally discriminated or acted with deliberate indifference against individuals with Mobility Disabilities.

(iv) The City’s compliance with and implementation of the Settlement Agreement are sufficient to satisfy the City’s legal obligations to provide Program Access to its Pedestrian Facilities, when viewed in their entirety, for individuals with Mobility Disabilities.