IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

Quentin Bullock and Jack Reid, individually )

and on behalf of a class, )

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)

)

, ) No. 04 C 1051

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Micheal F. Sheahan, Sheriff of Cook County )

and Cook County, Illinois, ) Magistrate: Schenkier

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)

. )

Plaintiffs, by counsel and with the agreement of defendants, move the

Court to approve the final payment of late claims.

Grounds for this motion are as follows:

1. The settlement of this class action initially required that each class

member file his claim by March 1, 2011. This deadline was subsequently extended

to April 15, 2011 by Judge Bucklo . Class counsel provided each of the fifty eight

thousand (58,000) class members with notice of the settlement by first class mail

to his last known address. (See Exhibit A.)

2. Five thousand and ninety one (5,091) claimants filed timely claim

forms. This represented an 8.7% return rate from the class.

Plaintiffs

-vs- (Judge Bucklo)

Defendants

AGREED MOTION TO APPROVE FINAL

PAYMENT OF LATE CLAIMS
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3. Defendant Cook County mailed checks to the 5,091 claimants.

Seventy five (75) checks were returned for incorrect address. Class counsel has

furnished defendants with correct address information for 40 of these misaddressed checks. Defendants have represented that they are in the process of remailing these checks.

4. Fifty-five putative class members submitted claim forms during the

period between April 16 and June 15, 2011. After receiving the late claims, class

counsel contacted the former inmates and requested a written explanation why

their claims were filed late. Class counsel received letters from 43 claimants

explaining why their claims were submitted late. Class Counsel and defense

counsel agree that the 12 late claims filed without an explanation should be

denied.

5. After reviewing the explanations provided by the 43 putative class

members, defense counsel has agreed to pay 24 of the late claims. In regards to the

remaining 19 claimants, hereafter “the challenged claimants”, defendant is

requesting the claimants to provide proof that they are eligible to be a class

member by June 15, 2012. Class counsel has agreed to write to these claimants

and request additional information to support their eligibility as a member of the

class.

6. As a condition to accepting claims filed with good cause from

eligible class members after the deadline of April 15, 2011 and prior to June 15,
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Thomas G. Morrissey

10249 S. Western Ave.

Chicago, IL 60643

773-233-7900

Attorney for the plaintiffs

2011, defendants request that the Court enter an order terminating for all time the

acceptance of any late claims submitted after June 15, 2011. Class counsel does

not oppose such an order and submits a proposed order with this motion. (Exhibit

B).

It is therefore respectfully requested that the Court approve the following

order:

a. Approving the claims of the 24 late claimants filed by class members

prior to June 15, 2011;

b. Extending to June 15, 2012 the time for the 19 challenged claimants to

submitted proof of their eligibility ;

c. Entering an order terminating for all times the acceptance of any further

late claims ;

. Respectfully submitted,

/s/ Thomas G. Morrissey