Common use of LITIGATION BACKGROUND Clause in Contracts

LITIGATION BACKGROUND. ‌ 1. On April 20, 2015, plaintiff ▇▇▇▇▇▇▇ ▇▇▇▇▇ and others, filed the Action in the United States District Court for the Northern District of Illinois on behalf of themselves and a putative class of similarly situated class members whose Fourth and Fourteenth Amendment rights were allegedly violated by the City and its CPD officers. The complaint filed in the Action has been amended from time to time. 2. The Action originally was assigned to the ▇▇▇▇▇▇▇▇▇ ▇▇▇ ▇. St. Eve and subsequently was transferred to the ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇. Wood. The Action is currently pending before the ▇▇▇▇▇▇▇▇▇ ▇▇▇▇▇▇ ▇. Wood and Magistrate Judge ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇. 3. The Complaint alleges class claims that Defendants have maintained a policy or custom of unconstitutional stops of individuals by CPD officers, without reasonable articulable suspicion in violation of the Fourth Amendment and the principles set forth in ▇▇▇▇▇ ▇. Ohio, 392 U.S. 1 (1968). The Complaint further alleges additional class claims that many of these alleged stops violated the equal protection clause of the Fourteenth Amendment. In addition to the class claims, the Individual Plaintiffs bring individual federal and state law claims stemming from their individual encounters with CPD officers. Plaintiffs contend that some of these alleged unconstitutional encounters included investigatory stops conducted during the enforcement of the Loitering Ordinances. 4. On June 27, 2017, the Defendants filed their respective answers to the Complaint, denying any and all liability and the material allegations of Plaintiffs' claims. 5. On December 10, 2015, the Court entered a discovery schedule for the Action. The Parties then commenced class, merits, and damages discovery both as to the Individual Plaintiffs and class issues. 6. The Parties have exchanged documents both informally and formally, and have conducted extensive written and oral discovery. During the course of the Action, the City produced to Plaintiffs tens of thousands of pages of documents, including the Contact Card and Investigatory Stop Report databases and other data. The City took the depositions of the four took over forty-five (45) additional depositions of various parties, third-parties and expert witnesses. 7. On November 20, 2017, the Settlement Class Representatives filed Plaintiffs’ Motion For Rule 23(b)(3)