IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANTONIO SOLIS et al.,

Plaintiffs,

v.

HILCO REDEVELOPMENT LLC et al.,

Defendants.

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Case No. 1:20-cv-02348

Magistrate Judge Young B. Kim

UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE

MOTION FOR PRELIMINARY APPROVAL

Plaintiffs Antonio Solis, Jose Solis, and Juan Rangel file this unopposed motion for an 

extension of time until April 15, 2024 to file their motion for final approval of the Class Action 

Settlement in this case, stating in support as follows:

1. The Court previously granted Plaintiffs’ request for an extension of time to file their 

motion for final approval, and that motion is currently due on April 11, 2024. Dkt. 259.

2. Plaintiffs respectfully request an additional short extension so that they can provide 

the Court with a fulsome report about the claims filed by Class Members, and the expected value 

of those claims, when they file their motion for final approval.

3. Specifically, more than 600,000 claims were filed after notice was provided to 

Class Members. Although we do not know the exact number of Class Members, we know that it 

is not close to 600,000. For example, approximately 90,000 postcards were mailed to likely Class 

Members, and the population of Little Village (where the underlying incident occurred), is 

estimated at between 70,000-100,000 people.

4. To ensure that valid claims are not diluted by claims submitted by individuals who 

are not Class Members, Settlement Administrator Simpluris, Inc., is diligently working on 

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identifying fraudulent or otherwise invalid claims. The company has made significant progress in 

doing so, having already identified more than 400,000 claims that are facially invalid. Simplurus 

continues to make progress analyzing the claims, but the process has taken longer than anticipated.

5. Given the volume of claims filed and the progress made to date analyzing those 

claims, Simpluris believes that it will be able to substantially complete its claims analysis by 

Monday, April 15.

6. Plaintiffs believe that it will be most efficient to file the motion for final approval 

after Simpluris substantially completes its claims analysis, so that we can provide the Court with 

a good estimate of the number of valid claims and the value of each of those claims. We also 

recognize that this Settlement has received significant attention in the community and understand 

that Class Members have been informed that the final approval hearing is scheduled for April 22. 

We do not want to jeopardize the final hearing date. Therefore, if filing the motion for final 

approval on April 15 would jeopardize the April 22 hearing date, Plaintiffs are prepared to file 

their motion for final approval on the currently scheduled date of April 11 and file a supplement 

addressing the claims after that.

7. Defendants have indicated that they do not oppose this motion.

WHEREFORE, Plaintiffs respectfully request that the Court grant their request to extend 

the deadline for filing a motion for final approval to April 15, 2023.

Respectfully submitted by

s/ Scott Rauscher 

Jon Loevy 

Michael Kanovitz 

Steve Art

Scott Rauscher

Renee Spence 

LOEVY & LOEVY

311 N. Aberdeen, 3rd Floor 

Case: 1:20-cv-02348 Document #: 260 Filed: 04/11/24 Page 2 of 3 PageID #:1729
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Chicago, Illinois 60607

Telephone: (312) 243-5900

scott@loevy.com

Attorneys for Plaintiffs

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