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FINAL JOINT STATEMENT Nearly all of the remaining plaintiffs and the City of New York have agreed

to settle outstanding claims arising out of events surrounding the 2004 Republican National Convention (RNC). In 2004, the City of New York hosted the Republican National Convention, at which George W. Bush was nominated for a second term as President. Both the plaintiffs and defendants recognize the difficulties in policing an event of this magnitude, especially in New York City. The goal is to maintain order and to prevent demonstrations from unexpectedly spiraling out of control, while ensuring that people from all walks of life can exercise their First Amendment rights. During the RNC, hundreds of thousands of people exercised their First Amendment rights without incident and the public safety was maintained. New York City police officers, on the whole, showed flexibility in handling and often facilitating demonstrations, and demonstrators, on the whole, protested lawfully and peacefully. At the same time, approximately 1,800 people were arrested, mostly on charges of parading without a permit or disorderly conduct, and the circumstances of those arrests are heavily disputed. Lawsuits followed. Over 600 individuals who had been arrested during the RNC brought or joined in individual lawsuits against the City and the police alleging violations of their constitutional rights. In addition, a class action on behalf of 1200 more individuals was filed alleging violations of rights. The City of New York and the New York City Police Department vigorously defended all these lawsuits, maintaining that the conduct of the police had at all times been constitutional. The plaintiffs just as vigorously argued that their rights had been violated. Some cases were settled over the years, and some cases and some of the issues raised in them were resolved in motion practice. After almost nine years of litigation, and with complex factual and legal issues remaining, the parties and the Court believed it was in the best interests of all involved to settle the outstanding claims at this time. This settlement comes after months of negotiations involving counsel for the City, over a dozen attorneys for the plaintiffs, and most importantly, with the assistance and guidance of the Honorable James C. Francis, IV, United States Magistrate Judge for the Southern District of New York. The settlement is not an admission of liability by the City; rather, it is a recognition by both sides that the agreed-upon settlement is a fair resolution of plaintiffs remaining claims. With the approval of United States District Judge Richard J. Sullivan, the parties have agreed to a settlement calling for the payment of $10.4 million to the individual plaintiffs and to class members, and $7.6 million for attorneys fees, costs and expenses.

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