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NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

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United States District Court of Central California Kidd v. Noem Case No. 2:20-cv-03512-ODW-JPR

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT This notice discusses a proposed settlement agreement in a class action lawsuit, Kidd v. Noem. The purpose of this notice is to tell you about the terms of the proposed settlement, what happens next, and the options that class members have to object or not object to the settlement. The deadline to submit an objection is June 20, 2025. More information on how to submit an objection is available below.

ABOUT THE LAWSUIT What is the Kidd v. Noem lawsuit? The Kidd v. Noem lawsuit was filed in April 2020 and challenges certain alleged policies and practices of the U.S. Immigration and Customs Enforcement (ICE) when arresting or attempting to arrest community members for suspected violations of immigration law at their homes in Southern California. The lawsuit applies to ICE’s activities in seven counties in Southern California: Los Angeles, Orange, Riverside, San Bernardino, Ventura, Santa Barbara, and San Luis Obispo Counties. This area is also referred to by ICE as the Los Angeles Area of Responsibility. The lead plaintiffs for the class action part of the case are the Coalition for Humane Immigrant Rights (CHIRLA) and the Inland Coalition for Immigrant Justice (ICIJ). The organizations and law firms representing plaintiffs in the case are the American Civil Liberties Union Foundation of Southern California (ACLU SoCal), UC Irvine Immigrant Rights Clinic, and Munger, Tolles & Olson LLP (MTO). In the class action part of the lawsuit, the plaintiffs are asking the Court to declare ICE’s policies and practices unlawful, void those policies and practices, and order ICE to change its policies and practices in specific ways.

What are Ruse Class claims in the lawsuit that are being settled? Only part of the claims in the Kidd v. Noem are being resolved by settlement. The


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