NOTICE OF PROPOSED SETTLEMENT OF CLASS ACTION LAWSUIT

CONCERNING THE ABATEMENT OF MOLD AND MOISTURE

FROM NYCHA APARTMENTS OF RESIDENTS WHO HAVE ASTHMA
If you live in a New York City Housing Authority (NYCHA) apartment that has mold and moisture problems, and you or someone in
your household has asthma, you should read this notie! It provides information about the settlement of a lawsuit onerning the alleged
failure of NYCHA poliies and praties for removing mold and e"essive moisture to aommodate residents with asthma!
BACKGROUND
In #eember, $%&', a lawsuit, Baez v. NYCHA, &' CI(! )*&+ (,H-), was filed in federal ourt , laiming that NYCHA fails to make
reasonable aommodations and modifiations to its poliies and praties to effetively abate mold and moisture for its residents with
asthma, as re.uired by federal and state law! NYCHA denies any wrongdoing, and the Court has not made any final deisions about the
laims in the lawsuit! /he parties have agreed to a settlement in the ase, whih must be approved by the Court!
PROPOSED SETTLEMENT
You an read the proposed settlement on the websites of National Center for 0aw and 1onomi 2ustie and the Natural 3esoures
#efense Counil, the legal organi4ations that represent the plaintiff lass! /he websites an be aessed at www!nle5!org and
www!nrd!org!
/he basi terms of the settlement are6
&! &/he individuals that have made the laim will represent a 7plaintiff lass8 that will onsist of 7Current and future residents of
NYCHA who have asthma that substantially limits a ma5or life ativity (for e"ample, walking, speaking, breathing, eating, sleeping,
standing, lifting, bending, reading, onentrating, thinking, and ommuniating) and who have mold and9or e"essive moisture in their
NYCHA housing!8

$! NYCHA:s mold poliy will provide for effetive and safe abatement of mold and e"essive moisture and the elimination of their
underlying auses! ,hen residents provide NYCHA with aess to their apartments, NYCHA shall, on average, omplete simple repairs
for mold and e"essive moisture within seven (;) days and more omple" repairs within fifteen (&<) days (e"luding apital
improvements)! =ollowing repairs, NYCHA shall make a good>faith attempt to ontat residents to determine if mold and e"essive
moisture problems and their underlying problems have been effetively addressed!
'! NYCHA will modify its forms and informational materials related to disabilities and mold to inform residents that asthma may be a
disability entitling residents to aommodations in NYCHA poliies, praties, and proedures, and that mold and9or e"essive moisture
may aggravate asthma symptoms! ?uh aommodations may inlude the right to install and operate an additional air onditioner if the
eletrial system permits, transfer to a temporary loation during the proess to improve the mold9moisture situation, permanent
reloation to another NYCHA apartment if the apartment is annot be lived in due to its ondition, and another apartment is available, use
of low>to"iity substanes to destroy or stop the growth of mold, to, and9or the use of dust ontrol methods during mold removal!
@! & NYCHA will periodially report to the plaintiffs: lawyers information about re.uests for aommodations, the time it takes NYCHA
to respond to omplaints and omplete work to eliminate mold and moisture, and the effetiveness of work performed!
<! /he Court will enfore the settlement for at least '% months!
RIGHT TO OBJECT
Any lass member has the right to ob5et to the proposed settlement as not fair, reasonable and ade.uate, by appearing and stating his9her
ob5etions at the hearing, in person or by ounsel! /he Court has set a hearing for this purpose on Aarh $;, $%&@, at '6%% p!m! at the
following address6
Honorable Wlla! H" Pa#le$% Un&e' S&a&e( D(&r)& J#'*e
Un&e' S&a&e( D(&r)& Co#r& +or &,e So#&,ern D(&r)& o+ Ne- Yor.
Danel Pa&r). Mo$n,an Un&e' S&a&e( Co#r&,o#(e
/00 Pearl S&"% Roo! 10B% Ne- Yor.% NY 20003
Class members may also ob5et to the settlement by sending a letter marked 7Bae4 ?ettlement8 and postmarked by Aarh $$, $%&@, to the
Court at the address listed above!