To: All Individuals With Any Type Of mobility Disability Whatsoever Who Seek, Have Sought, Or Will Seek Access To Or Use Of Any Facility Of The University Of Southern California.

You are covered by and will be bound by the settlement of a class action lawsuit involving physical access barriers at the University of Southern California. This Notice is to inform you of facts which affect your legal rights.

The complaint on file with the Court, entitled Hahn v. University of Southern California, Case No. C99-11996 GHK (AIJx), alleges on behalf of individuals with any type of mobility disability or disabilities that the University of Southern California (the "University") is in violation of the Americans with Disabilities Act and other federal and state anti-discrimination laws affecting persons with such disabilities. The alleged violations are claimed to have occurred by the University’s failing to provide adequate access for persons with mobility disabilities to the University’s facilities. The allegations are: (1) that numerous physical access barriers exist on the University’s campus; and (2) such barriers prevented the named plaintiff Harlan Hahn, as well as other physically disabled individuals, from having equal access to various University structures and facilities. The University has denied these allegations. By entering into a settlement of this action, the University does not admit or imply that it engaged in any wrongful action or inaction, or damaged or injured anyone in any fashion.

This lawsuit has been certified by the Court as a class action for settlement purposes. The named plaintiff, Harlan Hahn, serves as class representative, and his counsel are Disability Rights Advocates, by Sid Wolinsky, and also by David Daar of the law firm, Daar & Newman. Those lawyers serve as counsel for the class. The University is represented by Joel Krischer and Daniel Martens of the law firm, Latham & Watkins.

You are a member of the class if you are an individual with any type of mobility disability whatsoever, and seek, have sought, or will seek access to or use of any facility at the University of Southern California.

The named plaintiff and the University have reached a proposed settlement of this class action lawsuit. The United States District Court has preliminarily approved that settlement, although the Court has made no findings and offers no opinion with respect to the merits of the settlement. The proposed settlement provides in substance that:

• The University currently maintains an annual budget specifically for the removal of physical access barriers on its properties. As of July 1, 1998, that budget was approximately $280,000.00.
• As part of the settlement, the University shall increase that budget pursuant to the following schedule:

• The University shall create and implement a procedure whereby it identifies and records all physical access barriers it removes as part of any remodeling or renovation project or task, or any other similar construction efforts, which is completed with funds from sources other than the annual budget the University maintains specifically for the removal of physical access barriers.
• The order of priority of the University’s barrier removal shall generally follow that provided in the University’s established Barrier Removal Plan which was prepared by ISES, an independent, professional corporation specializing in the assessment and removal of architectural barriers.
• The University shall create an advisory committee to ensure that it carries out the barrier removal efforts identified in the settlement agreement in the most advantageous and appropriate manner. The committee’s purpose shall be to offer advice and guidance with respect to the particular barriers to be removed, and to assist in establishing project priorities.
• The settlement provides monetary amounts for the removal and elimination of such physical access barriers as exist at the University, as set forth above. No monetary amount is to be paid to members of the class.

Court Hearing:

On January 29, 2001, at 9:30 a.m., the Court will hold a hearing at the United States District Court, Central District of California, Courtroom 660, located at 255 Temple Street, Los Angeles, California 90012, to determine whether the proposed settlement agreement is fair and reasonable and should be approved, and to consider the application of Hahn’s counsel for attorneys’ fees and costs.

Objections to the Settlement:

If you believe the Court should not approve the settlement, you may advise the Court of your objections. In order to be considered by the Court, your objections must be in writing, signed and sent via first-class mail to: Clerk of the United States District Court for the Central District of California, Courtroom 660, 255 Temple Street, Los Angeles, California 90012. A copy should also be mailed to counsel for the class at one of the addresses set forth below. Objections will not be considered by the Court unless postmarked on or before January 15, 2001.

Your written statement should specify in detail the factual basis and/or legal grounds on which you base your objections. Any materials you submit in support of your objections must be included with your written statement.

If you provide written objections, you may appear in person at the hearing before the Court on January 29, 2001, as described above, to express your views concerning the settlement. An attorney may also appear at the hearing on your behalf. If you and/or your attorney intend to appear at the hearing, you should so advise the Court in the written statement of your objections.

Any class member who fails to file a timely written objection may not appear before the Court at the hearing to voice objections relating to the adequacy and/or fairness of the proposed settlement.

If the settlement is approved by the Court, the order approving the proposed settlement and a judgment dismissing this action with prejudice will be entered on or after January 29, 2001. You should not expect to receive any further notices concerning the entry of such order and judgment, or of the proceedings which occur before such entry. All class members will be bound by the judgment. The judgment will bar all class members from asserting any claims against the University concerning physical access barriers. Also, pursuant to the terms of the settlement agreement in this matter, all class members are deemed to have waived the protection afforded by California Civil Code Section 1542, which provides: "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor."

The nature of this lawsuit and the proposed settlement are summarized in this Notice. More detailed information concerning the settlement of the Action, including a complete copy of the settlement agreement, may be obtained from class counsel at either of the following addresses:

or by consulting the public file on the case at the Office of the Clerk, United States District Court Central District of California at 255 Temple Street, Los Angeles, California.

Please Follow The Procedures Set out Above. Please Do Not Contact The Judge Or The Clerk Of The Court With Any Questions About The Settlement.