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.

)

)

)

)

)

)

)

)

)

Case No. 1:20-cv-02348

Magistrate Judge Young B. Kim

DECLARATION IN SUPPORT OF PLAINTIFFS’ MOTION FOR FINAL APPROVAL

1. I am an attorney admitted to practice before this Court and am providing this 

Declaration in support of Plaintiffs’ Motion for Final Approval of the Class Action Settlement in 

this case. 

2. I am a partner at Loevy & Loevy. I served as one of the lead lawyers in this case, 

which my firm brought on behalf of Little Village residents Antonio Solis, Jose Solis, and Juan 

Solis against Hilco Redevelopment, LLC, HRE Crawford, LLC, HRP Exchange 55, LLC 

(collectively “Hilco”), MCM Management Corp. (“MCM”), Controlled Demolition, Inc. 

(“CDI”), and Marine Technology Solutions LLC (“MTS”).

3. I submit this declaration as a supplement to the declaration that I submitted in 

support of Plaintiffs’ Motion for Attorney’s Fees, Incentive Awards, and Expenses. Dkt. 255-1. 

That declaration addresses Loevy & Loevy’s experience in general and the experience of the 

specific attorneys assigned to this case, as well as the litigation and settlement of the case. This 

declaration serves as a supplement to describe our firm’s continued efforts on behalf of Class 

Members.

4. Since the Court preliminarily approved the Settlement, our firm has continued to 

devote significant resources to this case. In particular, we have worked with Settlement 

Case: 1:20-cv-02348 Document #: 262-5 Filed: 04/15/24 Page 1 of 3 PageID #:1899
2

Administrator Simpluris, Inc. to help carry out the notice plan, and we have worked with Class 

Members and community groups to help educate Class Members about the Settlement. These 

efforts include, but are not limited to: (a) an in-person training session organized by the local 

alderman’s office where volunteers from the community received information on the claimsfiling process so that they could help other community members file claims; (b) two remote 

video town halls organized by the Little Village Environmental Justice Organization, a group 

dedicated to advocating for environmental justice in Little Village; and (c) an in-person claims 

filing event organized by Juan Rangel and staffed by Class Counsel, the Settlement 

Administrator, and certified translators, during which hundreds of individuals filed claims.

5. Mr. Rangel has continued to go above and beyond in his efforts to communicate 

with community members about the settlement, both participating in media interviews and in 

organizing and attending the claims-filing event referenced above.

6. As discussed in more detail in my declaration in support of Plaintiffs’ Motion for 

Attorney’s Fees, Incentive Awards, and Expenses, our firm was well-positioned to evaluate 

whether the mediator’s proposal made by Judge Andersen represented a fair and reasonable 

settlement. Dkt. 255-1. This was based both on our firm’s prior experience litigating and trying 

class actions and other complex litigation, and on our analysis of the facts and legal issues in this 

particular case. Id. The reaction of the Class to this Settlement confirms our opinion that the 

Settlement is fair and reasonable. Specifically, tens of thousands of people filed valid claims; no 

one objected; and only thirteen individuals out of an estimated class size of 70,000 – 100,000 

people excluded themselves from the lawsuit.

Case: 1:20-cv-02348 Document #: 262-5 Filed: 04/15/24 Page 2 of 3 PageID #:1900
3

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge.

Executed on April 15, 2024 /s/ Scott Rauscher

Scott Rauscher

Case: 1:20-cv-02348 Document #: 262-5 Filed: 04/15/24 Page 3 of 3 PageID #:1901