The proposed Settlement, if approved, would provide an all-inclusive Settlement Fund of $59 million to pay eligible Class Members’ Claims, as well as certain fees and expenses. If approved, the proposed Settlement will provide compensation to Class Members who experienced 16 or more staffing-related lockdowns, calculated in accordance with the Settlement Agreement:

• between August 15, 2014 and November 27, 2017, for current or former inmates; or

• between August 11, 2014 and November 27, 2017, for current or former immigration detainees.

Depending on the number of staffing-related lockdowns and the nature of harm suffered, eligible Claimants could receive between $2,000 and $68,000 (subject to a pro rata reduction, if necessary).

Class Members who experienced staffing-related lockdowns after May 30, 2009 but before the dates set out above may still be eligible for compensation if they can show that they were legally incapable of starting a lawsuit during that time, or, in limited circumstances, may be eligible to receive limited compensation from an Exceptional Circumstances Fund of $2 million.

If approved, the proposed Settlement will provide the following types of compensation to Eligible Claimants:

Who is Eligible	How Amount is Determined	Possible Award Amount
Basic Recovery Award
All Eligible Claimants (those who experienced 16 or more staffing-related lockdowns, calculated in accordance with the Compensation Protocol).	Determined by the Administrator through the use of the Basic Recovery Grid, based on the total number of staffing-related lockdowns that the Claimant experienced, calculated in accordance with the Compensation Protocol.	$2,000 to $28,000*
Differential Impact Award
Eligible Claimants who have at least one mental health alert or suicide alert in their OTIS record that does not post-date the last staffing-related lockdown that they experienced.	Determined by the Administrator through the use of the Enhanced Recovery Grid, based on the total number of staffing-related lockdowns that the Claimant experienced, calculated in accordance with the Compensation Protocol.	$3,000 to $15,000*
Serious Harm Award – Level One
Eligible Claimants who experienced, within 120 days of a staffing-related lockdown, substantial degradation in an existing Mental Disorder, development of a new Mental Disorder, or self-injurious behaviour (not including body modification or protest actions, such as hunger strikes), or, during a staffing-related lockdown, violence causing serious physical injuries requiring medical attention.	Determined by the Adjudicator on a paper record, which will include the Claimant's written statement and supporting documents.	$20,000*
Serious Harm Award – Level Two
Eligible Claimants who experienced either a documented suicide attempt during or within 120 days of a staffing-related lockdown, or violence causing permanent impairment during a staffing-related lockdown.	Determined by the Adjudicator on a paper record, which will include the Claimant's written statement and supporting documents.	$40,000*

* All awards will be subject to pro rata reductions, if necessary.

Eligible Claimants who qualify may receive either a Differential Impact Award or a single Serious Harm Award (either at Level One or Level Two), but not both.

For a Serious Harm Award, “Mental Disorder” means the diagnosis by a medical doctor, psychologist, or nurse practitioner (or the identification by a social worker, counsellor, therapist or registered nurse of a diagnosis by a medical doctor, psychologist or nurse practitioner) of the existence of one of the following disorders, as defined in the relevant Diagnostics and Statistics Manual of Mental Disorders, either the Fourth Edition (“DSM-4”) or Fifth Edition (“DSM-5”): schizophrenia (all sub-types), delusional disorder, schizophreniform disorder, schizoaffective disorder, brief psychotic disorder, substance-induced psychotic disorder (excluding intoxications and withdrawal), psychotic disorder not otherwise specified, major depressive disorders, bipolar disorder I, bipolar disorder II, neurocognitive disorders and/or delirium, dementia and amnestic and other cognitive disorders, post-traumatic stress disorder, obsessive compulsive disorder, or borderline personality disorder, and excludes substance-use disorder.

Some Class Members may be eligible for additional compensation from the Exceptional Circumstances Fund, assessed by the Administrator in accordance with the Exceptional Circumstances Protocol.