United States District Court Central District of California Sammy Newman, et al. v. County of Los Angeles, et al. Case No. 2:22-cv-03467-CAS (PDx) Class Action Notice Authorized by the U.S. District Court Were you incarcerated at There is a $1.5 To be part of this the Men’s Central Million settlement settlement, you Jail in unit 2500 or of a lawsuit. should: unit 2700 on September 7, You may be Read this notice. 2021, and entitled to money. subjected to a Respond by March mass search 2, 2027. incident? Important things to know: • If you take no action, you will still be bound by the settlement, and your rights will be affected. • You can learn more at: www.LACountyMCJMassSearchSettlement.com LA County Men’s Central Jail Settlement«Case_Name» Page 1 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Table of Contents About This Notice .....................................................................................................3 Why did I get this notice? ............................................................................................... 3 What do I do next? .......................................................................................................... 3 What are the most important dates?............................................................................ 3 Learning About the Lawsuit ....................................................................................4 What is this lawsuit about? ............................................................................................ 4 Why is there a settlement in this lawsuit? .................................................................... 4 What happens next in this lawsuit? .............................................................................. 5 Learning About the Settlement............................................................................... 5 What does the settlement provide? .............................................................................. 5 How do I know if I am part of this settlement? ............................................................ 6 How much will my payment be? ................................................................................... 6 Deciding What to Do .................................................................................................6 How do I weigh my options?.......................................................................................... 6 What is the best path for me? ....................................................................................... 6 Submitting a Claim ................................................................................................... 8 How do I get a payment if I am a class member? ........................................................ 8 Do I have a lawyer in this lawsuit? ................................................................................ 8 Do I have to pay the lawyers in this lawsuit? ............................................................... 8 Opting Out .................................................................................................................9 What if I don't want to be part of this settlement?...................................................... 9 How do I opt out? ........................................................................................................... 9 Objecting ................................................................................................................. 10 What if I disagree with the settlement? ...................................................................... 10 Doing Nothing ......................................................................................................... 11 What are the consequences of doing nothing? ......................................................... 11 Key Resources ......................................................................................................... 11 How do I get more information? ................................................................................. 11 LA County Men’s Central Jail Settlement«Case_Name» Page 2 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com About This Notice Why did I get this notice? This notice is to tell you about the settlement of a class action lawsuit, Newman v. County of Los Angeles, brought on behalf of people who were subjected to a mass strip search in the Men’s Central Jail (MCJ) on September 7, 2021, by the County of Los Angeles. You received this notice because you may be a member of the group of people affected, called the “class.” This notice gives you a summary of the terms of the proposed settlement agreement, explains what rights class members have, and helps class members make informed decisions about what action to take. What do I do next? Read this notice to understand the settlement and to determine if you are a class member. Then, decide if you want to: Options More information about each option Submit a Claim You must submit a claim to receive payment. You will be Form bound by the settlement. Do Nothing Get no payment. Give up rights resolved by settlement. Opt Out Get no payment. Allows you to bring another lawsuit against the County of Los Angeles about the same issues. Object Tell the Court why you don’t like the settlement. Read on to understand the specifics of the settlement and what each choice would mean for you. What are the most important dates? Your deadline to object or opt out: March 2, 2027. Settlement approval hearing: April 26, 2027. Your deadline to submit a claim form: March 2, 2027. LA County Men’s Central Jail Settlement«Case_Name» Page 3 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Learning About the Lawsuit What is this lawsuit about? In 2022, a class action lawsuit was filed against the County of Los Angeles. The Where can I learn more? lawsuit was brought on behalf of You can get a complete copy incarcerated individuals who were of the proposed settlement involved in a mass strip search incident on and other key documents in September 7, 2021. this lawsuit at: The lawsuit claims that the County of Los www.LACountyMCJMassSearch Angeles conducted a mass search of Settlement.com inmates housed in the Men’s Central Jail in units 2500 and 2700 on September 7, 2021. During the search, members were required to submit to visual body cavity inspections, after which some inmates were required to remain nude, and were restrained while being transported through the facility to body-scanning machines. The County of Los Angeles denies they did anything wrong. Why is there a settlement in this lawsuit? In 2025, the parties agreed to settle, which means they have reached an What is a class action agreement to resolve the lawsuit. Both settlement? sides want to avoid the risk and expense A class action settlement is an of further litigation. The Court has not agreement between the parties decided this case in favor of either side. to resolve and end the case. Settlements can provide money The settlement is on behalf of Plaintiff to class members and changes Newman who brought the case and all to the practices that caused the members of the settlement class. harm. LA County Men’s Central Jail Settlement«Case_Name» Page 4 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com What happens next in this lawsuit? The Court will hold a Fairness hearing to decide whether to approve the settlement. The hearing will be held at: Where: Felicitas and Gonzalo Mendez United States Courthouse, 350 West 1st Street, Los Angeles, CA 90012 When: 10:00AM on April 26, 2027. The Court has directed the parties to send you this notice about the proposed settlement. Because the settlement of a class action decides the rights of all members of the proposed class, the Court must give final approval to the settlement before it can take effect. Payments will only be made if the Court approves the settlement. You don’t have to attend, but you may at your own expense. You may also ask the Court for permission to speak and express your opinion about the settlement. If the Court does not approve the settlement or the parties decide to end it, it will be void and the lawsuit will continue. The date of the hearing may change without further notice to members of the class. To learn more and confirm the hearing date, go to www.LACountyMCJMassSearchSettlement.com. Learning About the Settlement What does the settlement provide? Los Angeles County has agreed to pay $1.5 Million into a settlement fund. Each member who files a timely claim shall receive an equal pro rata share of the settlement fund. This amount will be calculated based on the number of Timely Claims and after Class Administration costs, Plaintiff incentive awards, and attorney’s fees and costs have been paid. Members of the settlement class will “release” their claims as part of the settlement, which means they cannot sue Los Angeles County for the same issues in this lawsuit. The full terms of the release can be found at www.LACountyMCJMassSearchSettlement.com. If there is money left over after the claims process is completed, it will LA County Men’s Central Jail Settlement«Case_Name» Page 5 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com be paid to support the activities of a nonprofit, human rights organization that focuses on sexual abuse in all forms of detention. How do I know if I am part of this settlement? If you were incarcerated at the Men’s Central Jail (MCJ) in units 2500 or 2700 on September 7, 2021, and were subjected to the mass search incident, you are part of this settlement. How much will my payment be? Your payment amount will be a minimum of $5,000. Deciding What to Do How do I weigh my options? You have four options. You can stay in the settlement and submit a claim, you can opt out of the settlement, you can object to the settlement, or you can do nothing. This chart shows the effects of each option: Submit a Do Opt out Object Claim Nothing Can I receive settlement YES NO YES NO money if I . . . Am I bound by the terms YES NO YES YES of this lawsuit if I . . . Can I pursue my own NO YES NO NO case if I . . . Will the class lawyers YES NO NO YES represent me if I . . . Note: by opting out you remove yourself from the class and no longer have a legal right to object. What is the best path for me? LA County Men’s Central Jail Settlement«Case_Name» Page 6 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Are you satisfied with the proposed settlement? Yes No Do you want to Do you want to file receive a payment? your own lawsuit or not be bound by this lawsuit? Yes No Yes No Do nothing Submit a claim Opt out of form I don't like the the settlement proposed settlement Object in writing and/or appear in court to explain why you don't like it* *You can object to the settlement AND submit a claim form to receive payment. LA County Men’s Central Jail Settlement«Case_Name» Page 7 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Submitting a Claim How do I get a payment if I am a class member? If you wish to receive money, you must submit a completed claim form to the Settlement Administrator online or download a claim form at www.LACountyMCJMassSearchSettlement.com and mail to the Settlement Administrator (address below). Do I have a lawyer in this lawsuit? In a class action, the court appoints class representatives and lawyers to work on the case and represent the interests of all the class members. For this settlement, the Court has appointed the following individuals and lawyers. Your lawyers: Barrett S. Litt, Lindsay Battles and Rodrigo Padilla of McLane, Bednarski & Litt, and Jovan Blacknell of the Law Offices of Jovan Blacknell. These are the lawyers who negotiated this settlement on your behalf. If you want to be represented by your own lawyer, you may hire one at your own expense. Do I have to pay the lawyers in this lawsuit? Lawyers' fees and costs will be paid from the Settlement Fund. You will not have to pay the lawyers directly. To date, your lawyers have not been paid any money for their work or the expenses that they have paid for the case. To pay for some of their time and risk in bringing this case without any guarantee of payment unless they were successful, your lawyers will request, as part of the final approval of this Settlement, that the Court approve a payment of up to 1/3 total in attorneys’ fees plus the reimbursement of out-of- pocket expenses. Lawyers' fees and expenses will only be awarded if approved by the Court as a fair and reasonable amount. You have the right to object to LA County Men’s Central Jail Settlement«Case_Name» Page 8 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com the lawyers' fees even if you think the settlement terms are fair. Your lawyers will also ask the Court to approve a payment of $10,000 to three Named Plaintiffs for the time and effort they contributed to the case. If approved by the Court, this will be paid from the Settlement Fund. Opting Out What if I don't want to be part of this settlement? You can opt out. If you do, you will not receive payment and cannot object to the settlement. However, you will not be bound or affected by anything that happens in this lawsuit and may be able to file your own case. You cannot exclude yourself from the program changes called for by the proposed settlement. How do I opt out? To opt out of the settlement, you must complete the opt out form included with this notice and mail it by March 2, 2027, to the Settlement Administrator at: LA County Men’s Central Jail Settlement c/o Settlement Administrator P.O. Box 26170 Santa Ana, CA 92799 (833) 232-9120 Be sure to include your name, address, telephone number, and signature. LA County Men’s Central Jail Settlement«Case_Name» Page 9 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Objecting What if I disagree with the settlement? If you disagree with any part of the settlement (including the lawyers' fees) but don’t want to opt out, you may object. You must give reasons why you think the Court should not approve it and say whether your objection applies to just you, a part of the class, or the entire class. The Court will consider your views. The Court can only approve or deny the settlement — it cannot change the terms of the settlement. You may, but don’t need to, hire your own lawyer to help you. To object, you must send a letter to the Court that: (1) is postmarked by March 2, 2027; (2) includes the case name and number (Newman v. County of Los Angeles, Case No. 2:22-cv-03467-CAS(PDx)) (3) includes your full name, address and telephone number, and email address (if you have one); (4) states the reasons for your objection; (5) says whether either you or your lawyer intend to appear at the final approval hearing and your lawyer's name; (6) your signature. Mail the letter to: LA County Men’s Central Jail U.S. District Court Central District of Settlement California c/o Settlement Administrator Felicitas and Gonzalo Mendez United P.O. Box 26170 States Courthouse Santa Ana, CA 92799 350 W. 1st Street (833) 232-9120 Los Angeles, CA 90012 LA County Men’s Central Jail Settlement«Case_Name» Page 10 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com Doing Nothing What are the consequences of doing nothing? If you do nothing, you will not get any money, but you will still be bound by the settlement and its “release” provisions. That means you won’t be able to start, continue, or be part of any other lawsuit against the County of Los Angeles about the issues in this case. A full description of the claims and persons who will be released if this settlement is approved can be found on the Settlement website at www.LACountyMCJMassSearchSettlement.com Key Resources How do I get more information? This notice is a summary of the proposed settlement. The complete settlement with all its terms can be found here. To get a copy of the settlement agreement or get answers to your questions:  contact your lawyer (information below)  visit the case website at www.LACountyMCJMassSearchSettlement.com Resource Contact Information Case Website www.LACountyMCJMassSearchSettlement.com Settlement LA County Men’s Central Jail Settlement Administrator c/o Settlement Administrator P.O. Box 26170 Santa Ana, CA 92799 (833) 232-9120 Your Lawyers McLANE, BEDNARSKI & LITT, LLP 975 East Green Street Pasadena, CA 91106 LA County Men’s Central Jail Settlement«Case_Name» Page 11 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com (626) 844-7660 LAW OFFICE OF JOVAN BLACKNELL 200 Corporate Pointe #495 Culver City, CA 90230 (310) 469-9117 Court (DO NOT U.S. District Court Central District of California CONTACT) Felicitas and Gonzalo Mendez United States Courthouse 350 W. 1st Street Los Angeles, CA 90012 LA County Men’s Central Jail Settlement«Case_Name» Page 12 of 12 CaseID: 9770 Questions? Call (833) 232-9120 Toll-Free or Visit www.LACountyMCJMassSearchSettlement.com