UNITED STATES D ISTRICT C OURT FOR THE N ORTHERN DISTRICT OF ILLINOIS

If you were in the Lake County Adult Correctional

Facility between November 8-10 of 2017, a class
action lawsuit may affect your rights.
A court authorized this notice. This is not a solicitation from a lawyer.

• Former inmates have sued Lake County, alleging violations of their constitutional rights.

• The Court has allowed the lawsuit to be a class action on behalf of all people incarcerated before
or after trial in the Lake County Adult Correctional Facility between November 8-10, 2017.

• The Court has not decided whether Lake County did anything wrong. There is no money available
now, and no guarantee there will be. However, your legal rights are affected, and you have a choice
to make now:

YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT

Stay in this lawsuit. Await the outcome. Give up certain

rights.
DO NOTHING By doing nothing, you keep the possibility of getting money or benefits
that may come from a trial or a settlement. But, you give up any rights to
sue Lake County separately about the same legal claims in this lawsuit.

Get out of this lawsuit. Get no benefits from it. Keep rights.
ASK TO BE If you ask to be excluded and money or benefits are later awarded, you
EXCLUDED won’t share in those. But, you keep any rights to sue separately about
the same legal claims in this lawsuit.

• Your options are explained in this notice. To ask to be excluded, you must act before April 23,
2021.

• Lawyers must prove the claims against Lake County. If money or benefits are obtained from Lake
County, you will be notified about how to ask for a share.

• Any questions? Visit www.koconnorlaw.com.

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BASIC INFORMATION………………………………….………………………………………………. PAGE 3
1. Why did I get this notice?
2. What is this lawsuit about?
3. What is a class action and who is involved?
4. Why is this lawsuit a class action?

THE CLAIMS IN THE LAWSUIT…………..……..…………………………………………………….. PAGE 4

5. What does the lawsuit complain about?
6. How does Lake County answer?
7. Has the Court decided who is right?
8. What are the Plaintiffs asking for?
9. Is there any money available now?

WHO IS IN THE CLASS………………………………………………………………………………… PAGE 4

10. Am I part of this Class?

11. Which inmates are included?
12. Are any inmates of the Lake County Adult Correctional Facility not included in the Class?
13. I’m still not sure if I am included.

YOUR RIGHTS AND OPTIONS………………………………………………………………………… PAGE 5

14. What happens if I do nothing at all?
15. Why would I ask to be excluded?
16. How do I ask the Court to exclude me from the Class?

THE LAWYERS REPRESENTING YOU….……………………….......................................... PAGE 6

17. Do I have a lawyer in this case?
18. Should I get my own lawyer?
19. How will the lawyers be paid?

THE TRIAL………………………………………………………………………………………………… PAGE 6

20. How and when will the Court decide who is right?
21. Do I have to come to the trial?
22. Will I get money after the trial?

GETTING MORE INFORMATION……………………………………………………………………… PAGE 7

23. Are more details available?

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 BASIC INFORMATION
1. Why did I get this notice?
Lake County’s records show that you were incarcerated at the Lake County Adult Correctional Facility
between November 8-10, 2017. This notice explains that the Court has allowed, or “certified,” a class
action lawsuit that may affect you. You have legal rights and options that you may exercise before the
Court holds a potential trial. The trial would be to decide whether the claims being made against Lake
County, on your behalf, are correct. The Honorable Judge Sharon Johnson Coleman of the United
States District Court for the Northern District of Illinois is overseeing this class action. The lawsuit is
known as Hardeman v. County of Lake, Civil Action No. 17-CV-8729.i
about?
2. What is this lawsuit about?
This lawsuit is about whether Lake County violated inmates’ constitutional right to humane conditions
of confinement during the November 2017 water shutoff. More information about the specific
allegations of the Class can be found at the website of Class Counsel, O’Connor Law Firm, Ltd.,
www.koconnorlaw.com.

3. What is a class action and who is involved?

In a class action lawsuit, one or more people called “Class Representatives” (in this case, Tapanga
Hardeman) sue on behalf of other people who have similar claims. The people together are a “Class”
or “Class Members.” The woman who sued—and all the Class Members like her—are called the
Plaintiffs. The organization they sued (in this case Lake County) is called the Defendant. One court
resolves the issues for everyone in the Class—except for those people who choose to exclude
themselves from the Class.

4. Why is this lawsuit a class action?

The Court decided that this lawsuit can be a class action and move toward a settlement or trial because
it meets the requirements of Federal Rule of Civil Procedure 23, which governs class actions in federal
courts. Specifically, the Court found that:
◼ There are more than 600 individuals who were present in the Lake County
Adult Correctional Facility during the water shutoff;
◼ There are legal questions and facts that are common to each of them;
◼ Tapanga Hardeman’s claims are typical of the claims of the rest of the Class;
◼ Ms. Hardeman and the lawyers representing the Class will fairly and adequately
represent the Class’ interests;
◼ The common legal questions and facts are more important than questions that
affect only individuals; and
◼ This class action will be more efficient than having many individual lawsuits.

More information about why the Court is allowing this lawsuit to be a class action is in the Court’s
Order Certifying the Class, which is available at www.koconnorlaw.com.

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 THE CLAIMS IN THE LAWSUIT
5. What does the lawsuit complain about?
In the lawsuit, the Plaintiffs say that Lake County violated inmates’ constitutional rights to humane
conditions of confinement. They claim that the conditions in the Lake County Adult Correctional
Facility during the water shutoff were inhumane. They also say that Lake County failed to provide
enough clean water for inmates to stay hydrated and healthy during the shutoff, and punished inmates
for requesting more water. You can read the Plaintiffs’ Class Action Complaint at
www.koconnorlaw.com.

6. How does Lake County answer?

Lake County denies that it did anything wrong and says that it provided enough clean water for inmates
to stay hydrated and healthy during the shutoff. Lake County says that the water shutoff and its
employees’ actions during the shutoff were all reasonable and necessary to keep the jail operating.
Lake County says the shutoff and the policies in place during the shutoff were not punishment and did
not harm the inmates. Lake County’s Answer to the Complaint is also available on the website.

7. Has the Court decided who is right?

The Court hasn’t decided whether Lake County or the Plaintiffs are correct. By establishing the Class
and issuing this notice, the Court is not suggesting that the Plaintiffs will win or lose this case. The
Plaintiffs may have to prove their claims at a trial, but as of now no trial has been scheduled. (See “The
Trial” below on page 7.)

8. What are the Plaintiffs asking for?

The Plaintiffs are asking for money for harms caused by the water shutoff and Lake County’s treatment
of inmates between November 8-10, 2017. No money or benefits are available now because the
Court has not decided whether Lake County did anything wrong, and the two sides have not
settled the case. There is no guarantee that money or benefits ever will be obtained. If they are,
you will be notified about how to ask for a share.

9. Is there any money available now?

No money or benefits are available now because the Court has not yet decided whether Lake
County did anything wrong, and the two sides have not settled the case. There is no guarantee that
money or benefits ever will be obtained. If they are, you will be notified about how to ask for a
share.

WHO IS IN THE CLASS

10. Am I part of this Class?

Judge Sharon Johnson Coleman decided that all people who were incarcerated by Lake County (pretrial
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or after a conviction) at any time from November 8-10, 2017, are Class Members. Currently
incarcerated individuals are in the Class as long as they were incarcerated in the Lake County Adult
Correctional Facility any time between November 8-10, 2017. In other words, these people are
included:
◼ People who were being held before trial in the Lake County Adult Correctional
Facility that were present in the facility during the water shutoff in November 2017.
◼ People who were serving sentences for criminal convictions in the Lake County
Adult Correctional Facility that were present in the Facility during the water
shutoff in November 2017.I

11. I’m still not sure if I am included.

If you are still not sure whether you are included, you can get free help at www.koconnorlaw.com, or
by contacting the Settlement Administrator by calling 1-877-933-2881, or write to the Hardeman
Settlement, c/o A.B. Data, Ltd., P.O. Box 170500, Milwaukee, WI 53217.

YOUR RIGHTS AND OPTIONS

12. What happens if I do nothing at all?

You have to decide whether to stay in the Class or ask to be excluded before the settlement or trial, and
you have to decide this now.

You don’t have to do anything now if you want to keep the possibility of getting money or benefits
from this lawsuit. By doing nothing you are staying in the Class. If you stay in and the Plaintiffs obtain
money or benefits, either as a result of a trial or a settlement, you will be notified about how to apply
for a share (or how to ask to be excluded from any settlement). Keep in mind that if you do nothing
now, regardless of whether the Plaintiffs win or lose the trial, you will not be able to sue, or continue to
sue, Lake County—as part of any other lawsuit—about the same legal claims that are the subject of
this lawsuit. This means that if you do nothing, you may only be able to sue for civil rights violations
that occurred before November 8, 2017, or after November 10, 2017, only. You will also be legally
bound by all of the orders the Court issues and judgments the Court makes in this class action.

13. Why would I ask to be excluded?

If you exclude yourself from the Class—which also means to remove yourself from the Class, and is
sometimes called “opting-out” of the Class—you won’t get any money or benefits from this lawsuit
even if the Plaintiffs obtain them as a result of the trial or from any settlement (that may or may not be
reached) between Lake County and the Plaintiffs. If you exclude yourself, you will not be legally bound
by the Court’s judgments in this class action.

If you start your own lawsuit against Lake County after you exclude yourself, you’ll have to hire and
pay your own lawyer for that lawsuit, and you’ll have to prove your claims. If you do exclude yourself
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so you can start or continue your own lawsuit against Lake County, you should talk to your own lawyer
soon, because your claims may be subject to a statute of limitations.

14. How do I ask the Court to exclude me from the Class?

To ask to be excluded, you must send an “Exclusion Request” in the form of a letter sent by mail,
stating that you want to be excluded from Hardeman v. County of Lake. Be sure to include your name
and address, and sign the letter. You must mail your Exclusion Request postmarked by April 23, 2021,
to:

Hardeman Settlement
c/o A.B. Data, Ltd.
P.O. Box 170500
Milwaukee, WI 53217

THE LAWYERS REPRESENTING YOU

15. Do I have a lawyer in this case?

The Court decided that the law firm of O’Connor Law Firm, Ltd., of Chicago, IL, is qualified to
represent you and all Class Members. The law firm is called “Class Counsel.” They are experienced in
handling similar cases against other organizations. More information about the law firm, their practices,
and their lawyers’ experience is available at www.koconnorlaw.com.

16. Should I get my own lawyer?

You do not need to hire your own lawyer because Class Counsel is working on your behalf. But, if you
want your own lawyer, you will have to pay that lawyer. For example, you can ask him or her to appear
in Court for you if you want someone other than Class Counsel to speak for you.

17. How will the lawyers be paid?

If Class Counsel get money or benefits for the Class, they may ask the Court for fees and expenses.
You won’t have to pay these fees and expenses. If the Court grants Class Counsels’ request, the fees
and expenses would be either deducted from any money obtained for the Class or paid separately by
Lake County.

THE TRIAL
18. How and when will the Court decide who is right?

The Court has not scheduled a trial to decide who is right in this case.

QUESTIONS ? VISIT WWW.KOCONNORLAW.COM.

As long as the case isn’t resolved by a settlement or otherwise, Class Counsel will have to prove
the Plaintiffs’ claims at a trial. During the trial, a Jury or the Judge will hear all of the evidence to
help them reach a decision about whether the Plaintiffs or Defendant are right about the claims in
the lawsuit. There is no guarantee that the Plaintiffs will win, or that they will get any money for
the Class.

19. Do I have to come to the trial?

You do not need to attend the trial. Class Counsel will present the case for the Plaintiffs, and Lake
County will present the defenses. You or your own lawyer are welcome to come at your own expense.

20. Will I get money after the trial?

If the Plaintiffs obtain money or benefits as a result of the trial or a settlement, you will be notified
about how to participate. We do not know how long this will take.

GETTING MORE INFORMATION

21. Are more details available?

Visit the website www.koconnorlaw.com, where you will find the Court’s Order Certifying the Class,
the Complaint that the Plaintiffs submitted, the Defendant’s Answer to the Complaint, as well as an
Appellate Court’s Decision to deny Defendants’ Appeal. You may also speak to one of the case
administrators by calling 1-877-933-2881, or by writing to Hardeman Settlement, c/o A.B. Data,
Ltd., P.O. Box 170500, Milwaukee, WI 53217.

DATE: February 22, 2021

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