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complaint is not an accurate measure of the good faith of a settlement.” Johnson, 203 Ill. 2d at 136-

37, 784 N.E.2d at 823; see Smith v. Texaco, Inc., 232 Ill. App. 3d 463, 469, 597 N.E.2d 750, 755

(1992) (“[i]t has been recognized that settlements may be substantially different from the results of

litigation because damages are often speculative and the probability of liability uncertain”). “Nor

does the small amount of the settlement, alone, require a finding of bad faith.” Johnson, 203 Ill. 2d

at 137, 784 N.E.2d at 823. As discussed, the circuit court was familiar with the history of the case

and had before it the facts, arguments, pleadings, and motions of each party when it considered and

granted Buffalo Grove’s motion for a good-faith finding. Further, the circuit court was aware of the

tort immunity defenses raised by Buffalo Grove in response to Cellini’s third amended complaint

and heard oral arguments on the issue of good faith. At the July 23, 2009 hearing on the motion for

a good faith finding, the circuit court made its finding on the “basis in the record,” and thus, we must

presume that the circuit court relied on the information available to it in concluding that the

settlement was made in good faith. We find no evidence in the record to suggest that the circuit

court’s approval of the $1 million settlement, in a multidefendant lawsuit in which Cellini alleged

an amount “in excess of $50,000" against Buffalo Grove, was “arbitrary, fanciful, or unreasonable,”

or that “no reasonable person would take the same view.” Favia, 381 Ill. App. 3d at 815, 886 N.E.2d

at 1187. The U-Haul entities’ dissatisfaction with the amount of the settlement between Buffalo

Grove and Cellini, along with the speculation that the jury will likely be requested to award $10 to

$20 million in damages against the U-Haul entities, is simply insufficient to establish bad faith. We

remind the parties that the standard which the objectors needed to meet in opposing the good-faith

finding is a preponderance of the evidence. Nothing in the record before the circuit court and now


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