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EXHIBIT B-1: FORM OF SUMMARY PUBLICATION NOTICE

LEGAL NOTICE OF PROPOSED CLASS ACTION
CONSENT DECREE AND HEARING
If you are a person, under the age of 21 years old, Medicaid-eligible in the State of Illinois, and
receive in-home shift nursing services a class action lawsuit may affect your rights. Or, if you have
a child who fits the description in the above paragraph, a class action lawsuit may affect the rights
of your child.
This Notice is being published by order of the United States District Court for the Northern
District of Illinois to inform you of the proposed settlement of a class action lawsuit (O.B. v.
Eagleson, Case No. 15 C 10463) set forth in a proposed Consent Decree with the Director of
the Illinois Department of Healthcare and Family Services regarding Medicaid services for
children in Illinois under the age of 21 who receive in-home shift nursing. The parties to that
lawsuit have agreed to the proposed Consent Decree that, if approved by the Court, would
provide certain rights and benefits to eligible individuals. The Court will hold a hearing to
consider whether to approve the proposed Consent Decree on November 5, 2019, at 9:30 a.m.
before the Honorable Charles P. Kocoras, United States District Judge, in the Dirksen Federal
Building, 219 S. Dearborn Street, Room 2325, Chicago, Illinois 60604.
Who is Included? You are a Class Member whose rights may be affected by the proposed
Consent Decree if you are a Medicaid-eligible child under the age of 21 years old in the State
of Illinois who receives in-home shift nursing.
What Does the Proposed Settlement Provide? The parties have asked the Court to approve a
Consent Decree that, if approved, would provide certain rights and benefits (as more fully
described in the proposed Consent Decree) to eligible Class Members.
How Can I Get More Information? A detailed Notice describing the proposed Consent
Decree, the rights of class members, and a copy of the proposed Consent Decree itself are
available on the website of the Illinois Department of Healthcare and Family Services,
www.illinois.gov/hfs/info/legal/PublicNotices, and also at and www.legalcouncil.org.
If you have any questions for plaintiffs’ lawyers, you may contact Attorney Thomas
Yates at tyates@legalcouncil.org or 312-605-1958

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