EXHIBIT B

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UNITED STATES DISTRICT COURT – NORTHERN DISTRICT OF ILLINOIS

NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF CLASS ACTION AND

SETTLEMENT HEARING 

You must complete and return one of the attached Tier 1 or Tier 2/3 Claim Forms by 

March 17, 2008 in order to be eligible to receive money. 

Judge Wayne Andersen of The United Stated District Court for the Northern District of Illinois 

(“the Court”) has authorized this Notice. It is not a solicitation from a lawyer. 

You are not being sued.

→ There is a Proposed Settlement with CB Richard Ellis, Inc. (“CBRE”) resulting from a class 

action lawsuit pending in federal court in Chicago. The name of the lawsuit is Wiginton, et 

al. v. CB Richard Ellis, Inc., 02 CV 6832 (“The Lawsuit”). 

→ The lawsuit claims that female employees at CBRE were subjected to sexual harassment in 

violation of Title VII. CBRE has always denied, and continues to deny, all allegations of 

wrongdoing and liability in The Lawsuit. 

→ The Proposed Settlement allows eligible female employees to submit a claim in one of three 

different Tiers, which are described in detail on the following pages. The Parties have agreed 

to appoint a Special Master, which is an independent third party who is affiliated with neither 

CBRE nor Plaintiffs, who will review each claim and determine how much money each 

claimant is entitled to receive, if any. 

→ You can decide to submit a claim in one of the three following tiers: 

- Tier 1 (awards of $0 or $1,500) requires you to submit a short claim form about the 

sexual harassment you experienced. If you submit a form under this Tier, your identity 

will be kept completely confidential from CBRE. 

- Tier 2 (award range of $0 to $15,000) requires you to submit a more comprehensive 

claim form with more specific information about the sexual harassment you 

experienced. If you submit a form under this Tier, CBRE will have an opportunity to 

respond in writing. 

- Tier 3 (award range of $0 to $150,000) requires the same type of claim form and 

response from CBRE as in Tier 2, but also requires you to appear in person before the 

Special Master to offer evidence through witnesses and testimony. CBRE will also be 

allowed to present evidence supporting its position. 

If you are a female who:

□ Worked at any CB Richard Ellis, Inc. office in the United States; 

□ From January 1, 1999 to October 4, 2007; and 

□ Experienced sexual harassment

□ You may be eligible to receive up to $150,000 through a 

Proposed Class Action Settlement 

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YOUR LEGAL RIGHTS ARE AFFECTED EVEN IF YOU DO NOT ACT.

READ THIS NOTICE CAREFULLY. 

What This Notice Contains:

BASIC INFORMATION ........................................................................................................................1 

1. WHY DID I GET THIS NOTICE? .................................................................................1 

2. WHAT IS THE LAWSUIT ABOUT?...............................................................................1 

3. WHY IS THIS A CLASS ACTION SETTLEMENT? .........................................................1 

4. HOW DO I KNOW IF I AM INCLUDED IN THE PROPOSED SETTLEMENT? ....................2 

5. CAN CBRE RETALIATE AGAINST ME FOR PARTICIPATING IN THIS 

SETTLEMENT?...........................................................................................................2 

BENEFITS OF THE PROPOSED SETTLEMENT – WHAT YOU MAY GET.................................................3 

6. WHAT DOES THE PROPOSED SETTLEMENT PROVIDE? ..............................................3 

7. WHAT ARE THE BASIC DIFFERENCES BETWEEN THE THREE TIERS?.........................3 

8. WILL THE SPECIAL MASTER CONSIDER ANY EVIDENCE ASIDE FROM THE 

INFORMATION INCLUDED IN THE CLAIMS PROCESS?.................................................4

9. HOW DO I DECIDE WHICH TIER I SHOULD FILE MY CLAIM UNDER? .......................4 

10. HOW DO I FILE A CLAIM? ........................................................................................4 

SUMMARY OF THE EQUITABLE AND CHARITABLE ASPECTS OF THE SETTLEMENT...........................5 

11. WHAT IS EQUITABLE RELIEF AND WHAT WILL CBRE HAVE TO DO? .....................5 

12. WHO WILL GET THE $400,000 CHARITABLE CONTRIBUTION?.................................5 

YOUR OPTIONS AS A CLASS MEMBER..............................................................................................5 

13. WHAT ARE MY OPTIONS AS A CLASS MEMBER?.....................................................5 

14. HOW DO I REMAIN A CLASS MEMBER, AND WHAT DOES THAT MEAN?.................5 

15. CAN I OBJECT TO, OR COMMENT ON, THE PROPOSED SETTLEMENT, AND, IF 

SO, HOW DO I OBJECT OR COMMENT? .....................................................................5 

16. CAN I REQUEST EXCLUSION (“OPT-OUT”) OF THE SETTLEMENT AND, IF 

SO, HOW DO I OPT-OUT? .........................................................................................6 

THE LAWYERS REPRESENTING YOU .................................................................................................7 

17. DO I HAVE A LAWYER REPRESENTING MY INTERESTS IN THIS CASE? .....................7 

18. HOW ARE CLASS COUNSEL BEING PAID? .................................................................7 

19. ARE THE NAMED PLAINTIFFS RECEIVING ANYTHING FOR THE TIME AND 

EFFORT THEY CONTRIBUTED TO THE LAWSUIT?......................................................8 

20. WHAT ELSE DOES CBRE HAVE TO PAY? ................................................................8 

21. SHOULD I GET MY OWN LAWYER? ..........................................................................8 

THE COURT’S FINAL APPROVAL HEARING AND THE FUTURE OF THE LAWSUIT................................8 

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22. WHEN AND WHERE WILL THE COURT DECIDE ON WHETHER TO GRANT 

FINAL APPROVAL OF THE PROPOSED SETTLEMENT?.................................................8

23. DO I HAVE TO ATTEND THE FINAL APPROVAL HEARING, AND IF SO, MAY I

SPEAK?......................................................................................................................8 

24. IF THE COURT APPROVES THE SETTLEMENT, WILL THAT END THE 

LAWSUIT? .................................................................................................................9 

25. WHAT HAPPENS IF THE COURT DECIDES NOT TO GRANT FINAL APPROVAL 

OF THE PROPOSED SETTLEMENT?..............................................................................9 

26. WHERE DO I OBTAIN MORE INFORMATION / WHO CAN ANSWER MY 

QUESTION(S)?...........................................................................................................9 

27. HOW ARE THE PARTIES HANDLING PUBLICITY REGARDING THE LAWSUIT OR 

THE SETTLEMENT?..................................................................................................10 

28. WHAT ARE THE DEADLINES I NEED TO KNOW ABOUT?.........................................10 

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BASIC INFORMATION

1. WHY DID I GET THIS NOTICE? 

You were mailed this notice because, according to CBRE’s records, you are a female that has 

been employed at one of CBRE’s offices in the United States between January 1, 1999 to 

October 4, 2007. 

The purpose of this Notice is to inform you, as a potential Class Member, of (a) the existence of 

The Lawsuit; (b) a proposed Class Action Settlement of The Lawsuit, described below; and (c) 

your rights with respect to the proposed settlement. Those rights include the right to be excluded 

from the Class and the settlement. If you are a Class Member and do not request to be excluded 

in compliance with the procedures and deadline set forth below, you will remain in the Class and 

be bound by the terms of the settlement. 

2. WHAT IS THE LAWSUIT ABOUT? 

The five Named Plaintiffs, all former CBRE employees, filed this lawsuit on September 25, 2002 

on behalf of a class of female employees, alleging that CBRE subjected them to sexual 

harassment in violation of Title VII. 

Throughout this Lawsuit CBRE has denied, and continues to deny any wrongdoing or liability on 

its part, and denies specifically that it subjected female employees to sexual harassment or 

condoned or tolerated any such conduct. 

Class Counsel have investigated and evaluated the claims asserted in The Lawsuit and have 

determined that the proposed settlement is fair, reasonable, and adequate for the Class as a 

whole, in light of the benefits of the settlement and the disadvantages of continuing The Lawsuit. 

The proposed settlement is a compromise of disputed claims and does not mean that CBRE has 

any liability or admitted any wrongdoing alleged in The Lawsuit. 

3. WHY IS THIS A CLASS ACTION SETTLEMENT? 

Plaintiffs filed their lawsuit as a class action, which is a lawsuit where one or more people called 

“class representatives” sue on behalf of people who have similar claims. The people together are 

a “class” or “class members.” A court must determine if it will allow a lawsuit to proceed as a 

class action. 

In 2004, the Named Plaintiffs in this case filed a motion for class certification seeking to certify a

class of female employees who were allegedly sexually harassed during their employment with 

CBRE. The Court did not rule on that motion. However, as part of the Settlement, the Parties 

asked the Court to certify a Settlement Class solely for purposes of the settlement. The Court 

agreed, and certified a class only for purposes of this settlement. 

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4. HOW DO I KNOW IF I AM INCLUDED IN THE PROPOSED SETTLEMENT? 

You are a member of the Settlement Class if you fall into this definition and do not request 

exclusion from the class: 

All female employees who were or have been employed by CBRE at any time 

during the period January 1, 1999 to October 4, 2007 (the “Class“). 

If you are a member of the Settlement Class, you may be entitled to recover money if you were 

sexually harassed at CBRE during the period January 1, 1999 to the October 4, 2007. 

However, you are not entitled to recover any money out of this settlement if (1) you previously 

released all claims (including sexual harassment claims) against CBRE for the period January 1, 

1999 to October 4, 2007, or (2) you were sexually harassed at a company or any of its 

subsidiaries that was acquired by CBRE for the time period prior to the acquisition. Such 

predecessor companies include but may not be limited to: Eberhart Co.; Boston Mortgage; 

Insignia Financial Group, LLC f/k/a Insignia Financial Group, Inc.; Trione & Gordon LLC; 

Welsh Ohio, LLC d/b/a Columbus Commercial Realty; CB Richard Ellis - Charlotte, LLC; 

Advocate Consulting Group, Inc.; Project Advantage Group, Ltd.; The Polacheck Company, 

Inc.; Management Co. and PAC, Inc.; CB Richard Ellis Hawaii, Inc.; Marshall & Stevens 

Incorporated; Trammell Crow Company; Krombach II, LLC; Krombach III, LLC; CBRE 

Technical Services, LLC a/k/a Emcor. However, if you experienced sexual harassment at CBRE 

after the effective date of acquisition, you can recover for the sexual harassment you experienced 

at CBRE. 

If you are unsure whether you are entitled to any money out of this settlement, you may submit a 

claim and should provide the Special Master with all relevant information, including, by way of 

example only, a copy of the signed release or the identity of the companies for which you 

worked, so that the Special Master can determine your eligibility. 

You do not need to do anything to become part of the Settlement Class, but you must complete 

one of the attached Claim Forms in order to be eligible to receive any money under the 

Proposed Settlement. If you do not want to part of the Settlement Class, you must complete 

a Request for Exclusion Form (which is found at the end of this packet of documents). 

5. CAN CBRE RETALIATE AGAINST ME FOR PARTICIPATING IN THIS 

SETTLEMENT? 

Absolutely not. CBRE IS PROHIBITED FROM RETALIATING AGAINST YOU FOR 

PARTICIPATING IN OR RECEIVING ANY BENEFITS FROM THIS SETTLEMENT. 

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BENEFITS OF THE PROPOSED SETTLEMENT – WHAT YOU MAY GET

6. WHAT DOES THE PROPOSED SETTLEMENT PROVIDE? 

The Proposed Settlement has three parts: (1) a 3-tiered claim structure that provides for potential 

monetary payments to former and current employees who file claims that satisfy the applicable 

Claim Standards, as defined in Paragraphs 2.33, 2.34 and 2.35 of the Consent Decree, pursuant 

to the procedures for doing so; (2) changes to CBRE’s policies and procedures for responding to 

and dealing with claims of sexual harassment; and (3) a $400,000 charitable contribution to 

provide annual scholarships over the next four years to junior and/or senior female 

undergraduate students concentrating their field of study in the real estate area in order to 

promote the entry and advancement of women in the real estate services industry. 

The Tier Program will be administered by an independent and neutral expert called a “Special 

Master.” As part of the settlement process, the Parties will agree on a Special Master and then 

the Court must approve him or her. The Special Master will be responsible for collecting, 

reviewing, and ultimately determining each female employee’s claim and how much each person 

will receive, if anything, for her claim. 

7. WHAT ARE THE BASIC DIFFERENCES BETWEEN THE THREE TIERS?

The following chart provides an overview of the similarities and differences between the three 

Tiers. For detailed information on each Tier and its Claim Standards, see Exhibit B-1. 

TIER Confidentiality Summary of Claims Process 

Money Available Under 

Each Tier 

Tier 1 CBRE will not 

know that you 

have submitted a 

claim 

You must submit a brief claim form called a Tier 1 

Form including your name, employment dates, office 

of employment, and a summary of the harassment 

you believe you experienced. The Special Master 

will review the claim and make sure that it meets 

certain criteria, explained further in Exhibit B-1.

CBRE will have no opportunity to respond. If you 

meet the criteria, you will receive an automatic 

payment of $1,500. On the other hand, if the Special 

Master determines that you do not meet the Tier 1 

Claim Standard, you will receive nothing. 

$0 or $1,500 

Any award received will 

be reported to the IRS by 

the Claims Administrator 

and a 1099 form will be 

issued. 

Tier 2 CBRE will know 

that you have 

submitted a claim 

and will know the 

nature of your 

claim. 

You must provide the details of the sexual 

harassment that you believe you experienced at 

CBRE, including the “who, what, where, why, and 

when.” 

CBRE will have a chance to review your claim and 

respond in writing to your allegations. 

If the Special Master determines that you meet the

Tier 2 Claim Standard, then he/she shall determine 

the appropriate amount of money to award, if any. 

$0 - $15,000 

Any award received will 

be reported to the IRS by 

the Claims Administrator 

and a 1099 form will be 

issued. 

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Tier 3 CBRE will know 

that you have 

submitted a claim 

and will know the 

nature of your 

claim. 

You must provide the details of the sexual 

harassment that you believe you experienced at 

CBRE, including the “who, what, where, why, and 

when.” 

CBRE will have a chance to review your claim and 

respond in writing to your allegations. You may then 

submit a written rebuttal to CBRE’s written response. 

The Special Master may conduct additional 

investigation if s/he chooses. 

There will be a mandatory in-person hearing on your 

claim in Chicago, Illinois (with limited exceptions). 

Both you and CBRE may submit evidence and call 

witnesses. If the Special Master determines that you 

meet the Tier 3 Claim Standard, then he/she shall 

determine the appropriate amount of money to award,

if any. 

$0 - $150,000 

Any award received will 

be reported to the IRS by 

the Claims Administrator 

and a 1099 form will be 

issued. 

8. WILL THE SPECIAL MASTER CONSIDER ANY EVIDENCE ASIDE FROM THE 

INFORMATION INCLUDED IN THE CLAIMS PROCESS? 

Yes. Prior to reviewing any individual claims submitted under the tier process, the Special 

Master will review the class-wide materials and arguments submitted by Plaintiffs and CBRE in 

connection with briefing Plaintiffs’ motion for class certification. In addition, the Special Master 

may, at his/her discretion, request that the attorneys for CBRE and for the Class give a live 

presentation about the Plaintiffs’ claims and CBRE’s defenses. You would not be required to 

attend or otherwise participate in this presentation.

9. HOW DO I DECIDE WHICH TIER I SHOULD FILE MY CLAIM UNDER? 

That is a personal decision, one which you must make on your own based on your own 

experiences, whether you want CBRE to know about your claim, the extent to which you would 

like to participate in the claims process, whether CBRE will have the opportunity to respond to 

your claim, the level of scrutiny your claim will receive by the Special Master, and how much 

money you want to seek taking into account the ranges of possible monetary recovery and the 

caps on recovery in each tier. 

You can only select one Tier. Once you select a Tier, you cannot change it. 

10. HOW DO I FILE A CLAIM? 

Attached to this Notice are Tier 1 and Tier 2/3 Claim Forms. If you want to be eligible to 

recover money under the Proposed Settlement, you MUST FILL OUT the Claim Form and 

submit it to the Claims Administrator, postmarked by March 17, 2008, and addressed to: 

Wiginton, et al. v. CB Richard Ellis, Inc. 

 Claims Administrator 

 c/o Rust Consulting, Inc. 

P.O. Box 9388 

Minneapolis, MN 55440-9388 

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SUMMARY OF THE EQUITABLE AND CHARITABLE ASPECTS OF THE SETTLEMENT

11. WHAT IS EQUITABLE RELIEF AND WHAT WILL CBRE HAVE TO DO? 

Equitable relief is relief ordered by the Court that requires CBRE to change its conduct in the 

future. It does not involve the payment of money. 

Here, CBRE has agreed to, among other things, certain changes in its policies and procedures to 

ensure that effective mechanisms are in place to prevent unlawful sexual harassment in the 

future, to conduct additional training for its supervisors and employees on sexual harassment, to 

conduct effective investigations of sexual harassment complaints, to improve its documentation 

policies and procedures, and to implement appropriate disciplinary and/or remedial action with 

respect to violations of its harassment policy. 

CBRE must report its compliance with these terms to the Special Master for two years following 

Final Approval of the Proposed Settlement. 

12. WHO WILL GET THE $400,000 CHARITABLE CONTRIBUTION? 

If the Proposed Settlement is approved, CBRE will donate $400,000 to the Commercial Real 

Estate Women (CREW) Network, an industry advocate for the success of women in commercial 

real estate, for the creation of a Women Scholars’ Program. The purpose of the program is to 

provide annual scholarships over the next four years to junior and/or senior female 

undergraduate students concentrating their field of study in the real estate area in order to 

promote the entry and advancement of women in the real estate services industry. 

YOUR OPTIONS AS A CLASS MEMBER

13. WHAT ARE MY OPTIONS AS A CLASS MEMBER? 

You have three options as a Class Member: (1) you may remain a Class Member; (2) you may 

file an objection to or comments in support of the Proposed Settlement; or (3) you may request 

exclusion from the monetary part of the Settlement (which is known as “Opting-Out”). 

14. HOW DO I REMAIN A CLASS MEMBER, AND WHAT DOES THAT MEAN? 

To remain a Class Member and become a member of the Settlement Class, you need not do 

anything. You must, however, submit a written claim form by the due date in order to be eligible 

to seek money from the Settlement. 

Being a Settlement Class Member means that if the Settlement is approved by the Court and the 

judgment becomes final, you will be entitled to the benefits of the Settlement and, if you submit 

a claim form and the Special Master determines your entitlement to it, you may receive money. 

In exchange for those benefits, you and your heirs, executors, administrators, representatives, 

agents, partners, successors, and assigns will be bound by any release, judgment or other 

disposition of this Litigation. 

15. CAN I OBJECT TO, OR COMMENT ON, THE PROPOSED SETTLEMENT, AND, IF 

SO, HOW DO I OBJECT OR COMMENT? 

Yes. As a Class Member, you have the right to object to or comment in support of the proposed 

Settlement, the proposed award of attorneys’ fees and expenses, or the proposed payment of 

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service awards to the Representative Plaintiffs, described in Paragraph 19 below. For more 

details on your rights if you file an objection or comments, see Paragraph 23 below. 

To file an objection to or comments on the Proposed Settlement, you must submit a written 

statement setting forth: (1) your name, address, and telephone number; (2) the reference 

“Wiginton v. CB Richard Ellis, Inc., No. 02 C 6832”; (3) your approximate dates and location of 

employment with CBRE and any other names under which you were employed at CBRE (if not 

the same as your present name); and (4) your objections, comments and any supporting 

arguments, to: 

Clerk of the Court 

United States District Court for the 

Northern District of Illinois 

219 South Dearborn Street 

Chicago, Illinois 60604 

You must also mail copies of your entire written submission to attorneys for the Class and 

CBRE’s attorneys at the following addresses: 

Lead Counsel for the Class 

Kenneth A. Wexler 

Jennifer Fountain Connolly 

Amber M. Nesbitt 

Wexler Toriseva Wallace LLP 

55 West Monroe St., Suite 3300 

Chicago, IL 60603 

Elizabeth A. Fegan 

Hagens Berman Sobol Shapiro LLP 

820 North Blvd., Suite B 

Oak Park, IL 60301 

CBRE’s counsel: 

Brenda H. Feis 

Christopher J. DeGroff 

Anne E. Duprey 

Seyfarth Shaw LLP 

131 South Dearborn St., Suite 2400 

Chicago, IL 60603-5577 

To be considered by the Court, your objections or supporting comments must be actually 

received by the Clerk of the Court, Attorneys for the Class, and CBRE’s attorneys no later than 

January 2, 2008. 

See Paragraphs 22-23 below for information on attending the Fairness Hearing to voice your 

objection to of comment on the Proposed Settlement. 

16. CAN I REQUEST EXCLUSION (“OPT-OUT”) OF THE SETTLEMENT AND, IF SO,

HOW DO I OPT-OUT? 

If you want to pursue your own case against CBRE for damages based on the conduct Plaintiffs 

have alleged in The Lawsuit, you have the right to request exclusion from the Class. If you 

request exclusion from the Class, you will not receive any money from the Settlement and may 

pursue your own claims for money damages. You may not opt-out of the equitable relief 

provisions of the settlement. If you wish to be excluded from the money damages part of the 

Class for any reason, you must complete a Request for Exclusion Form. These Forms are 

available from the Claims Administrator toll-free at (888) 764-8860, or by requesting one in writing 

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at the address below. You must submit your Request for Exclusion Form to the Claims 

Administrator, postmarked by January 2, 2008 and addressed to: 

Wiginton, et al. v. CB Richard Ellis, Inc. 

 Claims Administrator 

 c/o Rust Consulting, Inc. 

P.O. Box 9388 

Minneapolis, MN 55440-9388 

THE LAWYERS REPRESENTING YOU

17. DO I HAVE A LAWYER REPRESENTING MY INTERESTS IN THIS CASE? 

Yes. The Court has appointed the following law firms to represent you and other Settlement 

Class Members: 

Elizabeth A. Fegan 

Hagens Berman Sobol Shapiro LLP 

820 North Blvd., Suite B 

Oak Park, IL 60301 

Kenneth A. Wexler 

Jennifer Fountain Connolly 

Amber M Nesbitt 

Wexler Toriseva Wallace LLP 

55 West Monroe St., Suite 3300 

Chicago, IL 60603 

Daniel Gustafson 

Gustafson Gluek, PLLC 

650 Northstar East 

608 Second Avenue South 

Minneapolis, MN 55402 

JoDee Favre 

Favre Law Office, LLC 

5005 W. Main Street 

Belleville, IL 62226 

These lawyers are called Class Counsel. You won’t be charged personally for these lawyers, but 

they will ask the Court to award them a fee that CBRE has agreed to pay. More information is 

provided in Paragraph 18 below. However, these lawyers are not submitting your individual 

claim forms for you; you must take steps to submit your own claim form and may retain your 

own attorney to do so if you wish. 

18. HOW ARE CLASS COUNSEL BEING PAID?

Since they filed this case in 2002, Class Counsel have not received any payment for their 

services in prosecuting the lawsuit, nor have they been reimbursed for any out-of-pocket 

expenses. If the Court approves the proposed settlement, Class Counsel will ask the Court to 

award them attorneys’ fees and out-of-pocket expenses in the amount of $3,400,000. This sum is 

considerably less than the actual attorneys’ fees and expenses actually incurred by these lawyers. 

Any award of attorneys’ fees will be paid separately from and will not reduce the benefits 

provided to Settlement Class Members under the settlement. CBRE has agreed not to oppose an 

award that does not exceed $3,400,000. 

As a Class Member, you do not have to pay Class Counsel for the work that they performed on 

behalf of the Class.

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19. ARE THE NAMED PLAINTIFFS RECEIVING ANYTHING FOR THE TIME AND 

EFFORT THEY CONTRIBUTED TO THE LAWSUIT? 

As part of the Settlement, and subject to the Court’s final approval of the Settlement, the Parties 

have agreed that CBRE will pay service payments to each of the Class representatives for the 

extensive time and effort they contributed to the prosecution of The Lawsuit in the following 

amounts: Amy Wiginton $125,000; Kristine Moran $100,000; Andrea Scott f/k/a Andrea Corey 

$75,000; Norma Plank Fethler, as successor in interest to Dondi Plank $25,000; and Olivia 

Knapp $25,000. 

20. WHAT ELSE DOES CBRE HAVE TO PAY? 

CBRE has agreed to pay all costs of sending this notice to the Class, as well as the costs of 

administering the Settlement. CBRE has also agreed to pay Class Counsel certain amounts in the 

event certain fees are incurred for specified work performed after final approval of the 

Settlement, pursuant to Paragraph 14.2 of the Consent Decree. 

21. SHOULD I GET MY OWN LAWYER?

You do not need to get your own lawyer, but you do have the right to consult and/or retain an 

attorney of your choice, at your own expense, to advise you regarding the Settlement and your 

rights in connection with the Settlement. CBRE will not be responsible for any attorneys’ fees 

incurred by you, except as described in Paragraph 18 above. 

THE COURT’S FINAL APPROVAL HEARING AND THE FUTURE OF THE LAWSUIT

22. WHEN AND WHERE WILL THE COURT DECIDE ON WHETHER TO GRANT FINAL 

APPROVAL OF THE PROPOSED SETTLEMENT? 

The Court will hold a Fairness Hearing on January 9, 2008, at 9:30 a.m., before the Honorable 

Wayne Andersen, United States District Court Judge, at the United States District Court for the 

Northern District of Illinois, 219 S. Dearborn, Room 1403, Chicago, Illinois 60604, to 

determine: (1) whether the proposed settlement of The Lawsuit on the terms set forth in the 

Consent Decree is fair, reasonable, and adequate for the Class as a whole and should be granted 

final approval; (2) whether the certification of the Class for settlement purposes only should be 

made final; (3) whether the Court should enter the proposed judgment dismissing The Lawsuit 

with prejudice; (4) whether the Court should grant the application of Class Counsel for attorneys’ 

fees and reimbursement of expenses and, if so, in what amount; and (5) whether the Court should 

grant the request for incentive awards to the Representative Plaintiffs and, if so, in what amount. 

23. DO I HAVE TO ATTEND THE FINAL APPROVAL HEARING, AND IF SO, MAY I

SPEAK?

You do not have to attend the Fairness Hearing, unless you filed an objection or comment to the 

Proposed Settlement. If you decide to attend, you must do so at your own expense. 

If you filed an objection to or comments on the Proposed Settlement (see Paragraph 15 above), 

you must appear at the Fairness Hearing either in person or through your own counsel. Failure to 

attend shall be deemed a waiver of any comments and/or objections. You may ask to be heard 

by the Court on your objection or comments. The Court will not permit you to be heard unless 

you first submit your objections or comments in writing in compliance with Paragraph 15 above 

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and include in your comments a statement that you intend to appear and wish to be heard at the 

Fairness Hearing. 

If you want your own lawyer to speak on your behalf at the Fairness Hearing, you must give the 

Court a paper that is called a “Notice of Appearance.” The Notice of Appearance should use the 

following Civil Action Number: 02 CV 6832, and should include the name of the lawsuit, and 

state that you wish to enter an appearance at the Fairness Hearing. It also must include your 

name, address, telephone number and signature. Your “Notice of Appearance” must be mailed 

to and actually received by the Clerk of the Court at the address below no later than January 2, 

2008: 

Clerk of the Court 

United States District Court for the 

Northern District of Illinois 

219 South Dearborn Street 

Chicago, Illinois 60604 

Class members who have timely requested exclusion (“opted out”) from the Class may not 

participate at the Fairness Hearing. 

24. IF THE COURT APPROVES THE SETTLEMENT, WILL THAT END THE LAWSUIT? 

Yes. If the Court approves the proposed settlement, it will enter a judgment that will dismiss 

with prejudice the sexual harassment claims of Class Members, except those Class Members 

who request to be excluded from the settlement. 

25. WHAT HAPPENS IF THE COURT DECIDES NOT TO GRANT FINAL APPROVAL OF 

THE PROPOSED SETTLEMENT?

If the Settlement is not granted final approval, or if the Settlement is granted final approval but 

the judgment does not become final, the certification of the Class will be vacated and The 

Lawsuit will proceed as though no proposed Settlement had been reached. 

26. WHERE DO I OBTAIN MORE INFORMATION / WHO CAN ANSWER MY 

QUESTION(S)? 

Any questions you may have about the matters described in this Notice should be directed in 

writing to any of the Class Counsel listed in Paragraph 17 above or to the Settlement 

Administrator, Rust Consulting, at (888) 764-8860 or at the following address: 

Wiginton, et al. v. CB Richard Ellis, Inc. 

Claims Administrator 

c/o Rust Consulting, Inc. 

P.O. Box 9388 

Minneapolis, MN 55440-9388 

You may also send questions by e-mail to Class Counsel at CBRESettlement@wtwlaw.com. 

Further, the documents referenced in this Notice are available at www.cbrichardellislawsuit.com. 

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Copies of the Settlement Agreement and the pleadings and other documents filed in The Lawsuit 

are on file at the United States District Court for the Northern District of Illinois, and may be 

examined and copied during regular office hours at the Office of the Clerk of the Court, Northern 

District of Illinois, 219 South Dearborn Street, Chicago, Illinois 60604. 

Do not direct any questions to the Court.

27. HOW ARE THE PARTIES HANDLING PUBLICITY REGARDING THE LAWSUIT OR 

THE SETTLEMENT? 

The parties have agreed to a Joint Public Statement that will govern all communications with the 

media regarding The Lawsuit and the Settlement. 

Furthermore, CBRE, Class Counsel, the Named Plaintiffs and their respective agents have 

agreed that all communications with the media and other non-parties to This Case regarding This 

Case shall be limited to the Public Statement. CBRE, Class Counsel, and the Named Plaintiffs 

and their respective agents have agreed that they will not engage in any unauthorized publicity 

regarding This Case and to refrain from making any disparaging remarks or comments about 

each other. You should refrain from engaging in any unauthorized publicity regarding This 

Case. 

28. WHAT ARE THE DEADLINES I NEED TO KNOW ABOUT? 

If you wish to submit a claim, the deadline for submitting a claim by U.S. mail is March 17, 

2008. If you are submitting your Claim by U.S. mail, it must be postmarked by this date. 

If you wish to be excluded from the Class, you must mail your Request for Exclusion, 

postmarked no later than January 2, 2008, to the Claims Administrator at the address listed in 

No. 16 above. 

If you wish to submit objections or supportive comments, you must submit them in writing to 

the Clerk of the Court at the address listed in No. 23, with copies to both of Plaintiffs’ Co-Lead 

Counsel and CBRE’s counsel at the addresses listed in No. 17 above, such that they are received 

no later than January 2, 2008. 

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EXHIBIT B-1 

SUMMARY OF THE PROCEDURES AND CLAIMS STANDARDS 

FOR EACH OF THE 3 TIERS

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Tier 1 (awards of $0 or $1,500) With Complete Confidentiality 

If you elect Tier 1, you must complete the attached Form-T1 under penalty of perjury and submit 

it to the Claims Administrator post-marked by March 17, 2008. The Form-T1 provides the 

Special Master with basic information including your name, employment dates, office of 

employment, and a summary of the harassment you allegedly experienced. Under Tier 1, you do 

not have to specify the name of the harasser or provide specific dates for the incident(s) of when 

you were harassed. 

The information you submit in the Form-T1 will be kept confidential by the Special Master, 

including from CBRE. As a Tier 1 Claimant, your name will not be shared with anyone at 

CBRE. Your Tier 1 Form, and the fact that you even filed such a form, will be kept strictly 

confidential by the Special Master. CB Richard Ellis is prohibited from retaliating against 

you in any way for your participation in the Tier Program.

Based on the statements you make in this form, the Special Master will evaluate your claim. If 

the Special Master determines that, based on the limited information you are required to submit 

per the Settlement, you meet the Tier 1 Claim Standard, s/he will award you $1,500.00 to 

compensate you for your claim. On the other hand, if the Special Master determines that you do 

not meet the Tier 1 Claim Standard, you will receive nothing. 

Please note that the award you receive will be reported to the Internal Revenue Service 

with a Form 1099 by the Claims Administrator, but CBRE will still not be made aware of 

your name. 

Tier 2 (award range of $0-$15,000.00 with written exchange of positions) 

If you elect Tier 2, you must complete the attached Form-T2/3 under penalty of perjury and 

submit it to the Claims Administrator post-marked by March 17, 2008. The Form-T2/3 provides 

the Special Master with information including your name and your harassment allegations, 

including a detailed description of the harassing conduct which you allegedly experienced, the 

identification of any individual who participated in the alleged harassment, the identification of 

any supervisors or managers who witnessed the alleged harassment, the time period when the 

alleged incidents occurred, whether the alleged conduct was welcome or unwelcome, a detailed 

description of how the alleged harassment affected you and what injuries you allege based on the 

alleged harassment, whether each alleged incident was reported (and if so, to whom, how, and 

when it was reported) and, if not reported, the reasons why not. 

Thereafter, CBRE shall be entitled to submit a written response to the Special Master. The 

Special Master will review your claim solely based on the written submissions from the parties. 

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2 

The actual amount that you receive, if any, is up to the discretion of the Special Master. If, based 

on the information provided by the parties, the Special Master determines that you meet the Tier 

2 Claim Standard, s/he will award you an amount to compensate you for your claim, within a 

range of $0 to $15,000 per Claimant. On the other hand, if the Special Master determines that 

you do not meet the Tier 2 Claim Standard, you will receive nothing. 

CB Richard Ellis is prohibited from retaliating against you in any way for your 

participation in the Tier Program.

Please note that the award you receive will be reported by the Claims Administrator to the 

Internal Revenue Service with a Form 1099. 

Tier 3 (award range of $0-$150,000.00 with right to a 

hearing before the Special Master): 

If you elect Tier 3, you must complete a Form-T2/3 under penalty of perjury and submit it to the 

Claims Administrator post-marked by March 17, 2008. The Form-T2/3 provides the Special 

Master with information including your name and your harassment allegations, including a 

detailed description of the harassing conduct which you allegedly experienced, the identification 

of any individual who participated in the alleged harassment, the identification of any 

supervisors or managers, who witnessed the alleged harassment, whether the alleged conduct 

was welcome or unwelcome, a detailed description of how the alleged harassment affected you 

and what injuries you allege based on the alleged harassment, the approximate time period when 

the alleged incidents occurred, whether each incident was reported (and if so, to whom, how, 

and when it was reported) and, if not reported, the reasons why not. 

Thereafter, CBRE shall be entitled to submit a written response to the Special Master. The 

Special Master will then provide you with a copy of CBRE’s response, and you shall have 60 

days to prepare any rebuttal to the issues raised in CBRE’s position statement as well as identify 

any additional areas of investigation or witnesses for the Special Master. However, you are not 

required to submit a rebuttal. 

The Special Master can conduct additional investigation if s/he chooses. Once the Special 

Master completes his/her investigation, s/he will schedule a live hearing on your claim in 

Chicago, Illinois. Each side may, at her or its option and subject only to the Special Master’s 

discretion, identify one or more witnesses, including but not limited to CBRE employees, who 

may have personal knowledge of the facts or circumstances related to the Claim to testify at the 

hearing. 

If you live more than 100 miles from Chicago, you may provide testimony by telephone, but 

CBRE has the right to request that you attend the hearing if it pays for your reasonable travel and 

lodging costs. Under very limited, extenuating circumstances as described in the Consent 

Decree, the Special Master may excuse your attendance. 

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3 

The actual amount that you receive, if any, is up to the discretion of the Special Master. If, based 

on the information provided by the parties, the Special Master determines that you meet the Tier 

3 Claim Standard, s/he can award you an amount to compensate you for your claim, within a 

range of $0 to $150,000 per Claimant. On the other hand, if the Special Master determines that 

you do not meet the Claim Standard, you will receive nothing. 

CB Richard Ellis is prohibited from retaliating against you in any way for your 

participation in the Tier Program.

Please note that the award you receive will be reported by the Claims Administrator to the 

Internal Revenue Service with a Form 1099. 

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EXHIBIT B-2 

T-1 CLAIM FORM

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

AMY WIGINTON, KRISTINE MORAN, 

NORMA PLANK FETHLER, as Successor in 

Interest to Dondi Plank, ANDREA COREY 

and OLIVIA KNAPP, individually and on 

behalf of all persons similarly situated, 

Plaintiffs, 

v. 

CB RICHARD ELLIS, INC., 

Defendant. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Case No. 02 CV 6832 

CLAIM FORM FOR TIER 1 CLAIMS 

FORM T-1

TO CLAIMANT: PLEASE BE ASSURED THAT THE INFORMATION YOU SUBMIT 

WITH THIS FORM T-1 WILL BE KEPT STRICTLY CONFIDENTIAL FROM CBRE. 

It will not be shared with anyone at CB Richard Ellis. The information you provide will be 

viewed only by a neutral Special Master for the purposes of verifying that you are (or were) a CB 

Richard Ellis employee, that you worked at the facility you identify above and whether your 

claim is eligible for an award. CB Richard Ellis is prohibited from retaliating against you in 

any way for your participation in the Tier Program. 

Name: Daytime Phone Number Alternate Phone Number 

Mailing Address E-mail address (if this is a 

convenient way to reach you): 

If you are represented by an attorney, the name and contact information for your attorney: 

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2 

If you have used any other name during or since 

your employment at CBRE (i.e. maiden or married 

name), please provide that here: 

Social Security Number: 

CB Richard Ellis location where you currently work and/or any CB Richard Ellis location 

where you worked between January 1, 1999-October 4, 2007. Specify the approximate 

dates you were employed at each location. 

Location From (mm/dd/yyyy) To (mm/dd/yyyy)

[PLEASE USE ADDITIONAL SHEETS OF PAPER AS NECESSARY] 

READ THE INSTRUCTIONS FOR THIS FORM CAREFULLY

FIRST: Complete the identification section above. 

SECOND: Describe in detail the alleged harassment you experienced, how the harassment 

affected you, and any complaints you made to CBRE about the harassment. BE AS SPECIFIC 

AS POSSIBLE IN YOUR ANSWERS. Please use additional sheets of paper as necessary. 

Note that the harassment you claim to have experienced must have taken place while you were 

working at CB Richard Ellis. 

You are not entitled to recover any money if: (1) you previously released all claims (including 

sexual harassment claims) against CBRE for the period January 1, 1999 to October 4, 2007, or 

(2) you were sexually harassed at a company or any of its subsidiaries that was acquired by 

CBRE for the time period prior to the effective date of acquisition. Such predecessor companies 

include but may not be limited to: Eberhart Co.; Boston Mortgage; Insignia Financial Group, 

LLC f/k/a Insignia Financial Group, Inc.; Trione & Gordon LLC; Welsh Ohio, LLC d/b/a 

Columbus Commercial Realty; CB Richard Ellis - Charlotte, LLC; Advocate Consulting Group, 

Inc.; Project Advantage Group, Ltd.; The Polacheck Company, Inc.; Management Co. and PAC, 

Inc.; CB Richard Ellis Hawaii, Inc.; Marshall & Stevens Incorporated; Trammell Crow 

Company; Krombach II, LLC; Krombach III, LLC; CBRE Technical Services, LLC a/k/a 

Emcor. However, if you experienced sexual harassment at CBRE after the effective date of 

acquisition, you can recover for the sexual harassment you experienced at CBRE. 

If you are unsure whether you are entitled to any money out of this settlement, you may submit a 

claim and should provide the Special Master with all relevant information, including, by way of 

example only, a copy of the signed release or the identity of the companies for which you 

worked, so that the Special Master can determine your eligibility. 

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3 

Describe the alleged harassment. 

 You must provide approximate dates / time periods during which the alleged 

harassment took place; these do not have to be specific, just your best guess. 

 You do not have to specify the name of your harasser, however you may if you chose to 

do so.

Indicate whether the alleged harassment affected your ability to do your job and/or 

whether it affected you personally. If so, describe how. 

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4 

Identify any complaints you made about the alleged harassment. 

For each incident of alleged harassment identified above, state whether you made a 

complaint to a supervisor, CBRE management or human resources. If so, identify 

when you made the report(s), to whom, how you made the complaint (for example, 

in person, in writing, via e-mail), and the result(s). If you did not complain, please 

detail the reasons why you did not. 

THIRD: Sign and date the form. 

I declare, under penalty of perjury, that the foregoing statements are true and correct to the best 

of my personal knowledge and belief. 

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5 

I further certify that, to the best of my personal knowledge and belief, I have not previously 

released all claims (including sexual harassment claims) against CBRE for the period January 1, 

1999 to October 4, 2007. 

Date Signature 

FOURTH: Mail your claim form to Wiginton, et al. v. CB Richard Ellis, Inc., Claims 

Administrator, c/o Rust Consulting, Inc., P.O. Box 9388, Minneapolis, MN 55440-9388. Your 

mailing must be post-marked no later than March 17, 2008 to be valid for consideration. It 

is recommended that you send your claim form by certified or registered mail so that you have 

proof of delivery. 

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EXHIBIT B-3 

T-2/3 CLAIM FORM

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

AMY WIGINTON, KRISTINE MORAN, 

NORMA PLANK FETHLER, as Successor in 

Interest to Dondi Plank, ANDREA COREY 

and OLIVIA KNAPP, individually and on 

behalf of all persons similarly situated, 

Plaintiffs, 

v. 

CB RICHARD ELLIS, INC., 

Defendant. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

Case No. 02 CV 6832 

CLAIM FORM FOR TIER 2 and TIER 3 CLAIMS 

FORM T-2/3

TO CLAIMANT: PLEASE BE ASSURED THAT CB RICHARD ELLIS IS 

PROHIBITED FROM RETALIATING AGAINST YOU IN ANY WAY FOR YOUR 

PARTICIPATION IN THE TIER PROGRAM. 

Name: Daytime Phone Number Alternate Phone Number 

Mailing Address E-mail address (if this is a 

convenient way to reach you): 

If you are represented by an attorney, the name and contact information for your attorney: 

If you have used any other name during or since 

your employment at CBRE (i.e. maiden or married 

name), please provide that here: 

Social Security Number: 

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2 

CB Richard Ellis location where you currently work and/or any CB Richard Ellis location where 

you worked between January 1, 1999-October 4, 2007. Specify the dates you were employed at 

each location. 

Location Position Held From (mm/dd/yyyy) To (mm/dd/yyyy)

[PLEASE USE ADDITIONAL SHEETS OF PAPER AS NECESSARY]

READ THE INSTRUCTIONS FOR THIS FORM CAREFULLY

FIRST: Complete the identification section above. 

SECOND: Decide whether you wish to participate in Tier 2 or Tier 3 (if you wish to participate 

in Tier 1, do not complete this form. You must complete Form T-1). 

Tier 2 will be decided on the written submissions of the parties. If the Special Master 

determines that you meet the Tier 2 Claim Standard, then he/she can award you money in 

an amount ranging from $0 to $15,000.00. If the Special Master determines that you do 

not meet the Tier 2 Claim Standard, then you will not receive any money. 

Tier 3 requires an in-person hearing in Chicago, IL (except under very limited, 

extenuating circumstances), and you have the option of filing a rebuttal to CBRE’s 

response and position statement. If the Special Master determines that you meet the Tier 

3 Claim Standard, then he/she can award you money in an amount ranging from $0 to 

$150,000.00. If the Special Master determines that you do not meet the Tier 3 Claim 

Standard, then you will not receive any money. For additional information on the 

differences between Tiers 2 and 3, refer back to Paragraph 7 of the Notice of Pendency 

and Approval of Class Action Settlement or the Consent Decree. 

Select only one of the following two options: 

I want to participate in Tier 2 

- OR - 

I want to participate in Tier 3

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3 

THIRD: Describe in detail the alleged harassment you experienced, how the harassment 

affected you, and any complaints you made to CBRE about the harassment. BE AS SPECIFIC 

AS POSSIBLE IN YOUR ANSWERS. Please use additional sheets of paper as necessary. 

Note that the harassment you claim to have experienced must have taken place while you were 

working at CB Richard Ellis. You are not entitled to recover any money if (1) you previously 

released all claims (including sexual harassment claims) against CBRE for the period January 1, 

1999 to October 4, 2007, or (2) you were sexually harassed at a company or any of its 

subsidiaries that was acquired by CBRE for the time period prior to the effective date of 

acquisition. Such predecessor companies include but may not be limited to: Eberhart Co.; Boston 

Mortgage; Insignia Financial Group, LLC f/k/a Insignia Financial Group, Inc.; Trione & Gordon 

LLC; Welsh Ohio, LLC d/b/a Columbus Commercial Realty; CB Richard Ellis - Charlotte, LLC; 

Advocate Consulting Group, Inc.; Project Advantage Group, Ltd.; The Polacheck Company, 

Inc.; Management Co. and PAC, Inc.; CB Richard Ellis Hawaii, Inc.; Marshall & Stevens 

Incorporated; Trammell Crow Company; Krombach II, LLC; Krombach III, LLC; CBRE 

Technical Services, LLC a/k/a Emcor. However, if you experienced sexual harassment at CBRE 

after the effective date of acquisition, you can recover for the sexual harassment you experienced 

at CBRE. 

If you are unsure whether you are entitled to any money out of this settlement, you may submit a 

claim and should provide the Special Master with all relevant information, including, by way of 

example only, a copy of the signed release or the identity of the companies for which you 

worked, so that the Special Master can determine your eligibility. 

Describe the alleged harassment. 

Describe in detail the alleged harassment you experienced or observed, including each incident 

of harassment and type of harassment that you recall experiencing or observing. You should 

specify, to the best of your recollection each of the following: 

• a detailed description of the sexually harassing conduct or incident(s), 

• the identity of those who participated in the harassment, 

• the identity of any supervisors or managers who witnessed the alleged harassment (even 

if they did not directly participate in it), 

• the location(s) of the harassment; 

• the approximate date(s) of the harassment. 

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4 

State whether the alleged harassment was welcome or unwelcome and detail the 

reasons why. 

Indicate whether the alleged harassment affected your ability to do your job and/or 

whether it affected you personally. If the harassment affected your ability to do 

your job or you personally, describe how. 

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5 

Identify any complaints you made about the alleged harassment. 

For each incident of alleged harassment identified above, state whether you made a 

complaint to a supervisor, CBRE management or human resources. If so, identify 

when you made the report(s), to whom, how you made the complaint (for example, 

in person, in writing, via e-mail), and the result(s). If you did not complain, please 

detail the reasons why you did not. 

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FOR TIER 3 CLAIMANTS ONLY: You may also, but do not have to, submit preexisting documents that support the basis for your Claim with this Form. 

Please list below any documents you are submitting with this Claim Form that 

support your claim. You may only submit pre-existing documents, which are 

defined as documents that were not created for purposes of submitting your Tier 3 

Claim, including, by way of example only, inappropriate e-mails circulated in the 

workplace, photographs of inappropriate conduct in the office, etc.

Note: The Special Master who evaluates your claim has the discretion to follow up with you for 

additional information regarding any vague or speculative statements that you make, but also 

may take the lack of specificity into account when making the final determination. Thus, you 

should be as specific as possible when submitting your initial claim. If you need additional room, 

you may attach additional separate pages. 

FOURTH: Sign and date the form. 

I declare, under penalty of perjury, that the foregoing statements are true and correct to the best 

of my personal knowledge and belief. 

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7 

I further certify that, to the best of my personal knowledge and belief, I have not previously 

released all claims (including sexual harassment claims) against CBRE for the period January 

1, 1999 to October 4, 2007. 

Date Signature 

FIFTH: Mail your claim form to Wiginton, et al. v. CB Richard Ellis, Inc., Claims 

Administrator, c/o Rust Consulting, Inc., P.O. Box 9388, Minneapolis, MN 55440-9388. Your 

mailing must be post-marked no later than March 17, 2008 to be valid for consideration. It 

is recommended that you send your claim form by certified or registered mail so that you have 

proof of delivery. 

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