NOTICE OF PROPOSED SETTLEMENT OF CLASS SUIT

TO: All individuals with disabilities who use wheelchairs or electric scooters for
mobility who, between January 3, 2004 and October 30, 2009, were unable to use
any sidewalk constructed, installed, designed, owned, operated, or maintained by
the City and County of San Francisco, because of the condition of the curb or curb
ramp.

THIS NOTICE AFFECTS YOUR RIGHTS.

PLEASE READ IT CAREFULLY.
THIS IS NOT A LAWSUIT AGAINST YOU.
YOUR ARE NOT BEING SUED.

A class action settlement, which must be approved by the Court, was reached in connection with
a lawsuit alleging that curb ramps in the City and County of San Francisco provide inadequate
access to the City's sidewalks and public rights of way. San Francisco has maintained it is in
compliance with its obligation under the laws. The settlement binds the City to continue to
spend a minimum of $4 million per year on curb ramps.

A copy of the proposed Settlement Agreement and all other papers filed in this action is available
for your review at the office of the Clerk of the San Francisco Superior Court, at the address
listed below. In addition, the Settlement Agreement can be viewed online at
http://www.sfgov.org/site/mod index.asp.

Please review this notice, which provides you with information about the settlement of this class
action. As a class member (defined above), you may do one of three things: (1) if you are
satisfied with the proposed settlement, you may do nothing; (2) you may remain a member of the
class and hire your own attorney to represent you; (3) you may "opt-out" of the statutory damage
provisions of the proposed settlement and preserve your right to attempt to prove your individual
entitlement to statutory damages; or (4) if you object to the settlement, you may submit written
objections to the Court.

Any objections to the settlement terms must be in writing. You must write the Court Clerk at the
following address:

Clerk of the San Francisco County Superior Court

400 McAllister Street
San Francisco, CA 94102
Specifying: King v. City and County of San Francisco, Case No. 459-278

Objections must be postmarked or, if not delivered by U.S. mail, file-stamped by the Court by no
later than February 26, 20010. If you do not follow these procedures, you will be presumed to
agree with the proposed settlement. Do not telephone the Court.

On October 30, 2009, the Superior Court gave preliminary approval to the settlement of the class
action. A hearing on the fairness of this settlement shall be held at the Superior Court, at the
above address, on March 26, 2010 at 9:00 a.m., Dept. 503. As a class member, you have the
right to attend and be heard at this hearing. The settlement will not become binding on class
members unless the Court, after conducting the fairness hearing and hearing all objections,
determines that the settlement is fair to all class members.

Counsel for the plaintiffs are Law Offices of Morse Mehrban and Cable Law Office. The City
Attorney's Office represents the City and County of San Francisco. Copies of the objections
should also be mailed to counsel for plaintiffs and to counsel for the City as follows:

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 Keith Daniel Cable, Esq.
Cable Law Office
101 Parkshore Drive, Suite 100
Folsom, CA 95630

James M. Emery, Esq.

Deputy City Attorney
1390 Market Street, 7th floor
San Francisco, CA 94102

For more information about the settlement, you may contact counsel for plaintiffs at the above
address, by telephone at (916) 608-7995, or by email at cablelaw@yahoo.com. If you wish to
"opt out" of the statutory damages provisions of the class settlement, you must provide notice of
your "opt out" election in writing, including your name and address, to counsel for plaintiffs and
to counsel for the City, at the addresses provided above, by mail, postmarked no later than
February 26, 2010.

SUMMARY OF THE PROPOSED SETTLEMENT AGREEMENT

The Settlement Agreement requires the City to continue its active outreach to the disabled
community. Through public meetings of the Mayors' Disability Council and other methods, the
City will periodically confirm that its curb ramp installation program continues to reflect the
priorities of people with disabilities who live and work in San Francisco and who visit San
Francisco. As part of its outreach program, the City will make available to the public a map
indicating the location of safe and usable curb ramps.
As reflected in the City's Ten Year Capital Plan, the City anticipates total investments of more
than $70 million on curb ramp installations over a 10 year period. Recognizing the uncertain
fiscal environment, the Settlement Agreement requires the City to allocate and spend a total of at
least $4 million annually for curb ramp construction. Consistent with the City's Americans with
Disabilities Act Transition Plan for Curb Ramps and Sidewalks: Updates and Revisions 2007-
2008, dated January 9, 2008, the City will prioritize its curb ramp installations by taking into
account: (1) citizen requests; (2) the condition of the existing curb ramp (if any); and (3)
proximity to key amenities (government buildings, public accommodations, employment and
transit). The City also considers the overall efficiency of project work. In addition, the City will
continue to install curb ramps in connection with new construction and alterations of adjoining
streets and sidewalks, to the extent the law requires.
The Settlement Agreement requires the City to provide class counsel with an annual report,
identifying actual work done to implement the Settlement Agreement during the previous twelve
months and a prospective plan of projects for the upcoming year. The parties have agreed to
meet and confer over any alleged material breaches of the Settlement Agreement, followed by
mediation and if necessary, Court resolution.
Each of the named class representatives will receive a payment of five thousand dollars ($5000).
Class counsel shall receive an attorney fee payment of $38,500. The aggregate payments to the
five named plaintiffs and their counsel come to $63,500.
The Settlement Agreement binds class members to the injunctive and equitable provisions of the
Settlement Agreement, but it authorizes class members to opt out regarding any claims for
statutory damages. The Settlement Agreement explicitly preserves any class member's claim for
personal injury damages.

This notice is being sent to class members by Order of the San Francisco County Superior
Court.

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