In the Circuit Court of Cook County, Illinois
County Department--Chancery Division
DANIELLE K. SMITH,
)
Plaintiff,
)
)
)
v.
)
No. 02CH7255
)
VOLKSWAGEN OF
AMERICA, INC.,
)
)
Defendant.
)
TO:
ALL MEMBERS OF THE SETTLEMENT
CLASS AS DEFINED BELOW.
If you are in the class of people
defined below as the “Settlement Class” covered by a
proposed settlement, you are entitled to participate in a
proposed settlement of this lawsuit. The “Settlement
Class” includes: ALL PERSONS OR ENTITIES
WHICH OWNED OR LEASED, ON OR BEFORE
JANUARY 30, 2003, A 1998, 1999, 2000 OR 2001
AUDI A6 DISTRIBUTED AND WARRANTED BY
AUDI OF AMERICA, INC., BUT EXCLUDING (1)
CURRENT
EMPLOYEES,
OFFICERS,
AND
DIRECTORS OF VOLKSWAGEN OF AMERICA,
INC., AND (2) PERSONS BOUND BY PRIO R FULLY
LITIGATED JUDGMENTS OR WHO ARE
CURRENTLY REPRESENTED BY COUNSEL IN
ONGOING LITIGATION AGAINST DEFENDANT
CONCERNING THE SUBJECT MATTER OF THIS
LITIGATION. This Notice tells who is covered by the
proposed settlement, describes the case and the benefits of
the proposed settlement, and tells you that the Court will
hold a hearing to decide whether to approve the settlement.
This Notice describes your legal rights in connection with
the hearing and this lawsuit. PLEASE READ THIS
NOTICE CAREFULLY, AS ALL SETTLEMENT
CLASS MEMBERS WHO DO NOT TIMELY
EXCLUDE THEMSELVES WILL BE BOUND BY THE
RESULTING ORDERS.
No claims for personal injury, or
wrongful death resulting from accidents are being
compromised or dismissed in the Settlement.
I. THE LITIGATION
Notice is hereby given that a
putative class action lawsuit has been filed in this Court
that may affect your legal interests. A class action is a
lawsuit in which one or more persons can sue on behalf of
other persons similarly situated. The Complaint against
Audi alleges that the front bumper covers of the subject
vehicles are susceptible to damage from hooking on to
wheel stops or other parking obstructions, at an average
cost of $500 to $10