bp settlement declaration_cameron_azari_bp_settlement_notice_administrator_4_17_2012_annotated
TRANSCRIPT
Exhibit 1
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 1 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
This is the Declaration of Cameron Azari, who administered the class action notice for the BP Deepwater Horizon Oil Spill Settlement. It explains how BP settlement members would be given notice. The "Target Audience" for the BP Settlement notice was intended to be identical to the BP Settlement Agreement's class definition. Azari's plans for sending individual notice by mail are highlighted.
DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
1
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA
In Re: Oil Spill by the Oil Rig “Deepwater Horizon” in the Gulf of Mexico, on April 20, 2010
***********
MDL NO. 2179
SECTION J
HONORABLE CARL J. BARBIER
MAGISTRATE JUDGE SHUSHAN
Bon Secour Fisheries, Inc., et al., individually and on behalf of themselves and all others similarly situated,
Plaintiffs,
v.
BP Exploration & Production Inc.; BP America Production Company; BP p.l.c.,
Defendants.
***************
Civil Action No. 12-970
SECTION: J
HONORABLE CARL J. BARBIER
MAGISTRATE JUDGE SHUSHAN
DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
I, CAMERON R. AZARI, ESQ., hereby declare and state as follows:
1. My name is Cameron R. Azari, Esq. I am over the age of twenty-one and I have
personal knowledge of the matters set forth herein, and I believe them to be true and correct.
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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2. I am a nationally recognized expert in the field of legal notice and I have served as a
media expert in dozens of federal and state cases involving class action notice plans.
3. I am the Director of Legal Notice for Hilsoft Notifications, a firm that specializes in
designing, developing, analyzing and implementing large-scale, un-biased, legal notification
plans. Hilsoft has been involved with some of the most complex and significant notices and
notice programs in recent history.
4. With experience in more than 200 cases, notices prepared by Hilsoft Notifications
have appeared in 53 languages with distribution in almost every country and territory in the
world. Judges, including in published decisions, have recognized and approved numerous notice
plans developed by Hilsoft Notifications, which decisions have always withstood collateral
reviews by other courts and appellate challenges.
EXPERIENCE RELEVANT TO THIS CASE
5. Hilsoft Notifications has served as notice expert and has been recognized and
appointed by courts to design and provide notice in many large and complex cases, including:
Schulte v. Fifth Third Bank (overdraft litigation settlement with direct mail to millions of class
members and publication in relevant local newspapers, 2011) No. 1:09-cv-6655 (N.D. Ill.); In re
Residential Schools Class Action Litigation, Canada (notice program for the landmark settlement
between the Canadian government and Aboriginal former students; Phase IV notice program is
currently being implemented, 2011/2012); In re Department of Veterans Affairs (VA) Data Theft
Litigation (notices appeared across the country in newspapers, consumer magazines and
specialty publications with a total circulation exceeding 76 million, 2009), MDL 1796 (D. D.C);
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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and Vereen v. Lowe’s Home Centers (massive combined individual and media notice effort
related to defective drywall, 2011) SU10-CV-2267B (Ga. Super. Ct.).
6. We have been recognized by courts for our testimony as to which method of
notification is appropriate for a given case, and have provided testimony on numerous occasions
on whether a certain method of notice represents the best notice practicable under the
circumstances. For example:
a) In Schulte v. Fifth Third Bank, No. 1:09-cv-6655 (N.D. Ill.), Judge Robert
M. Dow, Jr. stated on July 29, 2011: The Court has reviewed the content of all of the various notices, as well as the manner in which Notice was disseminated, and concludes that the Notice given to the Class fully complied with Federal Rule of Civil Procedure 23, as it was the best notice practicable, satisfied all constitutional due process concerns, and provided the Court with jurisdiction over the absent Class Members.
b) In Williams v. Hammerman & Gainer Inc., No. 11-C-3187-B (27th Jud. D.
Ct. La.), Judge Ellis J. Daigle stated on June 30, 2011: Notices given to Settlement Class members and all other interested parties throughout this proceeding with respect to the certification of the Settlement Class, the proposed settlement, and all related procedures and hearings—including, without limitation, the notice to putative Settlement Class members and others more fully described in this Court’s order of 30th day of March 2011 were reasonably calculated under all the circumstances and have been sufficient, as to form, content, and manner of dissemination, to apprise interested parties and members of the Settlement Class of the pendency of the action, the certification of the Settlement Class, the Settlement Agreement and its contents, Settlement Class members’ right to be represented by private counsel, at their own cost, and Settlement Class members’ right to appear in Court to have their objections heard, and to afford Settlement Class members an opportunity to exclude themselves from the Settlement Class. Such notices complied with all requirements of the federal and state constitutions, including the due process clause, and applicable articles of the Louisiana Code of Civil Procedures, and constituted the best notice practicable under the circumstances and constituted due and sufficient notice to all potential
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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members of the Settlement Class.
c) In In re: Department of Veterans Affairs (VA) Data Theft Litigation, MDL
No. 1796 (D. D.C.), Judge James Robertson stated on September 23, 2009: The Notice Plan, as implemented, satisfied the requirements of due process and was the best notice practicable under the circumstances. The Notice Plan was reasonably calculated, under the circumstances, to apprise Class Members of the pendency of the action, the terms of the Settlement, and their right to appear, object to or exclude themselves from the Settlement. Further, the notice was reasonable and constituted due, adequate and sufficient notice to all person entitled to receive notice.
d) In In re: Heartland Payment Systems, Inc. Customer Data Security Breach
Litigation, MDL 09-2046 (S.D. Tex.), Judge Lee Rosenthal stated on March 2, 2012:
The notice that has been given clearly complies with Rule 23(e)(1)’s reasonableness requirement… Hilsoft Notifications analyzed the notice plan after its implementation and conservatively estimated that notice reached 81.4 percent of the class members. (Docket Entry No. 106, ¶ 32). Both the summary notice and the detailed notice provided the information reasonably necessary for the presumptive class members to determine whether to object to the proposed settlement. See Katrina Canal Breaches, 628 F.3d at 197. Both the summary notice and the detailed notice “were written in easy-to-understand plain English.” In re Black Farmers Discrimination Litig., — F. Supp. 2d —, 2011 WL 5117058, at *23 (D.D.C. 2011); accord AGGREGATE LITIGATION § 3.04(c).15 The notice provided “satisf[ies] the broad reasonableness standards imposed by due process” and Rule 23. Katrina Canal Breaches, 628 F.3d at 197 (internal quotation marks omitted).
e) In Dolen v. ABN AMRO Bank N.V., No. 01-L-454, 01-L-493, (3rd Jud. Cir. Ill.),
Judge Barbara Crowder stated on March 23, 2009:
The Court finds that the Notice Plan is the best notice practicable under the circumstances and provides the Eligible Members of the Settlement Class sufficient information to make informed and meaningful decisions regarding their options in this Litigation and the effect of the Settlement on their rights. The Notice Plan further satisfies the requirements of due process and 735 ILCS 5/2-803. That Notice Plan is approved and accepted. This Court further finds that the Notice of Settlement and Claim Form comply with 735 ILCS 5/2-803 and are appropriate as part of the Notice Plan and the Settlement, and thus they are hereby
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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approved and adopted. This Court further finds that no other notice other than that identified in the Notice Plan is reasonably necessary in this Litigation.
7. Numerous other court opinions and comments as to our testimony, and opinions on
the adequacy of our notice efforts, are included in Hilsoft Notifications’ curriculum vitae
attached as Exhibit 1.
8. In forming my expert opinions, I and my staff draw from our in-depth class action
case experience, as well as our educational and related work experiences. I am an active member
of the Oregon State Bar, receiving my Bachelor of Science from Willamette University and my
Juris Doctor from Northwestern School of Law at Lewis and Clark College. I have served as the
Director of Legal Notice for Hilsoft Notifications since 2008 and have overseen the detailed
planning of virtually all of our court-approved notice programs since that time. Prior to
assuming my current role with Hilsoft Notifications, I served in a similar role as Director of Epiq
Legal Noticing (previously called Huntington Legal Advertising). Overall, I have twelve years
experience in the design and implementation of legal notification and claims administration
programs, having been personally involved in well over one hundred successful notice programs.
I have been directly and personally responsible for designing all of the notice planning here,
including analysis of the individual notice options and the media audience data and determining
the most effective mixture of media required to reach the greatest practicable number of Class
members.
9. This affidavit will describe the Economic and Property Damages Settlement Notice
Plan (“E&PD Notice Plan” or “Notice Plan”) and notices (the “Notice” or “Notices”) designed
by Hilsoft Notifications and proposed here for the Economic and Property Damages Settlement
(“E&PD Settlement”) with BP Exploration & Production Inc. and BP America Production
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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Company Inc. ("BP") in In re: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf of
Mexico on April 20, 2010, MDL No. 2179 Litigation, including how the Notice Plan was
developed and why it will be effective. The Notice Plan and its attachments are attached hereto
as Exhibit 2 to this affidavit. We developed the Notice Plan and Notices based on our extensive
prior experience and research into the notice issues in this case. We have analyzed the most
effective method of notice for this Class.
NOTICE PLANNING METHODOLOGY
10. Considerable efforts have been undertaken to compile names and addresses of all
known or likely Settlement Class Members. As described in the Notice Plan, the final mailing
list will include all records in the Gulf Coast Claims Facility database that do not relate solely to
a medical claim, people and entities who filed a Short Form Joinder in MDL 2179 and known
Vessels of Opportunity lists, among others. Additionally, public records were searched to
identify current postal addresses for property owners who are likely eligible to submit coastal
real property, wetlands real property and real property sales claims.
11. Rule 23 directs that the best notice practicable under the circumstances must
include “individual notice to all members who can be identified through reasonable effort.”1 The
proposed notice effort satisfies this direction. If a postal address is available or can be
ascertained for a likely Class Member, notice will be sent by first class mail. If there is an email
address available, notice will also be sent by electronic means. Address updating (both prior to
mailing and on undeliverable pieces) and re-mailing protocols will meet or exceed those used in
other class action settlements.
1 FRCP 23(c)(2)(B).
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12. Separate from the compilation of the individual notice mailing lists, data sources
and tools that are commonly employed by experts in this field were used to analyze the reach and
frequency2 of the media portion of this Notice Program. These include GfK Mediamark
Research & Intelligence, LLC (“MRI”) data,3 which provides statistically significant readership
and product usage data, and Audit Bureau Circulation (“ABC”)4 statements, which certify how
many readers buy or obtain copies of publications. Broadcast media planning data was provided
by Neilsen Media Research5 and Arbitron Inc6. Online media planning data was provided by
comScore, Inc.7 These tools, along with demographic breakdowns indicating how many people
use each media vehicle, as well as computer software that take the underlying data and factor out
the duplication among audiences of various media vehicles, allow us to determine the net
2 Reach is defined as the percentage of a class exposed to a notice, net of any duplication among people who may have been exposed more than once. Notice “exposure” is defined as the opportunity to read a notice. The average “frequency” of notice exposure is the average number of times that those reached by a notice would be exposed to a notice. 3 GfK Mediamark Research & Intelligence, LLC (“MRI”) is a leading source of publication readership and product usage data for the communications industry. MRI offers comprehensive demographic, lifestyle, product usage and exposure to all forms of advertising media collected from a single sample. As the leading U.S. supplier of multimedia audience research, MRI provides information to magazines, televisions, radio, Internet, and other media, leading national advertisers, and over 450 advertising agencies—including 90 of the top 100 in the United States. MRI’s national syndicated data is widely used by companies as the basis for the majority of the media and marketing plans that are written for advertised brands in the U.S. 4 Established in 1914, ABC is a non-profit cooperative formed by media, advertisers, and advertising agencies to audit the paid circulation statements of magazines and newspapers. ABC is the leading third party auditing organization in the U.S. It is the industry’s leading, neutral source for documentation on the actual distribution of newspapers printed and bought by readers. Widely accepted throughout the industry, it certifies over 3,000 publications, categorized by metro areas, region, and other geographical divisions. Its publication audits are conducted in accordance with rules established by its Board of Directors. These rules govern not only how audits are conducted, but also how publishers report their circulation figures. ABC’s Board of Directors is comprised of representatives from the publishing and advertising communities. 5 Nielsen ratings are the audience measurement systems developed by the Nielsen Company, in an effort to determine the audience size and composition of television programming in the United States. The Nielsen method has since become the primary source of audience measurement information in the television industry around the world. 6 Arbitron Inc. is an international media and marketing research firm serving the media—radio, television, cable and out-of-home; the mobile industry as well as advertising agencies and advertisers around the world. 7 comScore, Inc.is a global leader in measuring the digital world and a preferred source of digital marketing intelligence. In an independent survey of 800 of the most influential publishers, advertising agencies and advertisers conducted by William Blair & Company in January 2009, comScore was rated the “most preferred online audience measurement service” by 50% of respondents, a full 25 points ahead of its nearest competitor.
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(unduplicated) reach of a particular media schedule. We combine the results of this analysis to
help determine notice plan sufficiency and effectiveness.
13. Tools and data trusted by the communications industry and courts. Virtually all
of the nation’s largest advertising agency media departments utilize, scrutinize, and rely upon
such independent, time-tested data and tools, including net reach and de-duplication analysis
methodologies, to guide the billions of dollars of advertising placements that we see today,
providing assurance that these figures are not overstated. These analyses and similar planning
tools have become standard analytical tools for evaluations of notice programs, and have been
regularly accepted by courts.
14. In fact, advertising and media planning firms around the world have long relied on
audience data and techniques: ABC data has been relied on since 1914; 90-100% of media
directors use reach and frequency planning;8 all of the leading advertising and communications
textbooks cite the need to use reach and frequency planning;9 and a leading treatise says it must
be used for reach and frequency planning: “In order to obtain this essential information, we must
use the statistics known as reach and frequency.”10 Ninety of the top one hundred media firms
use MRI data, which has a 95% confidence interval, and at least 3,000 media firms in 25
different countries use media planning software for reach and frequency planning.11
8 See generally Peter B. Turk, Effective Frequency Report: Its Use And Evaluation By Major Agency Media Department Executives, 28 J. ADVERTISING RES. 56 (1988); Peggy J. Kreshel et al., How Leading Advertising Agencies Perceive Effective Reach and Frequency, 14 J.ADVERTISING 32 (1985). 9 Textbook sources that have identified the need for reach and frequency for years include: JACK S. SISSORS & JIM SURMANEK, ADVERTISING MEDIA PLANNING, 57-72 (2d ed. 1982); KENT M. LANCASTER & HELEN E. KATZ, STRATEGIC MEDIA PLANNING 120-156 (1989); DONALD W. JUGENHEIMER & PETER B. TURK, ADVERTISING MEDIA 123-126 (1980); JACK Z. SISSORS & LINCOLN BUMBA, ADVERTISING MEDIA PLANNING 93-122 (4th ed. 1993); JIM SURMANEK, INTRODUCTION TO ADVERTISING MEDIA: RESEARCH, PLANNING, AND BUYING 106-187 (1993). 10 AMERICAN ADVERTISING AGENCY ASSOCIATION, GUIDE TO MEDIA RESEARCH 25 (1987), revised 1993. 11 For example, Telmar is the world's leading supplier of media planning software and support services. Over 3,000 users in 25 countries, including 95% of the world's top agencies, use Telmar systems for media and marketing planning tools including reach and frequency planning functions. Established in 1968, Telmar was the first company to provide media planning systems on a syndicated basis.
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ECONOMIC AND PROPERTY DAMAGES NOTICE PLAN SUMMARY
15. The E&PD Settlement Agreement defines the “Class” as:
A. Individuals. Unless otherwise specified, all Natural Persons residing in the United States who, at any time between April 20, 2010 and April 16, 2012, lived in, worked in, were offered and accepted work in, owned or leased real or personal property located within, or owned or leased or worked on a vessel harbored or HOME PORTED in the States of Louisiana, Mississippi, or Alabama, the counties of Chambers, Galveston, Jefferson and Orange in the State of Texas, or the counties of Bay, Calhoun, Charlotte, Citrus, Collier, Dixie, Escambia, Franklin, Gadsden, Gulf, Hernando, Hillsborough, Holmes, Jackson, Jefferson, Lee, Leon, Levy, Liberty, Manatee, Monroe, Okaloosa, Pasco, Pinellas, Santa Rosa, Sarasota, Taylor, Wakulla, Walton and Washington in the State of Florida, including all adjacent Gulf waters, bays, estuaries, straits, and other tidal or brackish waters within the States of Louisiana, Mississippi, Alabama, or those described counties of Texas or Florida (the “GULF COAST AREAS”) (Exhibit 22), or the U.S. waters of the Gulf of Mexico and all adjacent bays, estuaries, straits, and other tidal or brackish waters within the Gulf Coast Areas, as specifically shown and described in Exhibit 23 (“SPECIFIED GULF WATERS”), or worked on a vessel in Specified Gulf Waters after April 20, 2009. With respect to SEAFOOD CREW Claims, persons must have worked on a vessel that landed SEAFOOD in the Gulf Coast Areas after April 20, 2009.
and
B. Entities. All Entities doing business or operating in the Gulf Coast Areas or Specified Gulf Waters that: a) at any time from April 20, 2010 to April 16, 2012, owned,
operated, or leased a physical facility in the Gulf Coast Areas or Specified Gulf Waters and (A) sold products in the Gulf Coast Areas or Specified Gulf Waters (1) directly to CONSUMERS or END USERS of those products or (2) to another Entity that sold those products directly to Consumers or End Users of those products, or (B) regularly purchased Seafood harvested from Specified Gulf Waters in order to produce goods for resale;
b) are service businesses with one or more full-time
employees (including owner-operators) who performed their full-time services while physically present in the Gulf Coast Areas or Specified Gulf Waters at any time from April 20, 2010 to April 16, 2012; or
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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c) owned, operated, or leased a vessel that (1) was Home Ported in the Gulf Coast Areas at any time from April 20, 2010 to April 16, 2012, or (2) landed Seafood in the Gulf Coast Areas at any time from April 20, 2009 to April 16, 2012; or
d) owned or leased REAL PROPERTY in the Gulf Coast Areas at any time from April 20, 2010 to April 16, 2012;
C. Individuals and Entities who meet the geographical descriptions of Sections A or B above are included in the Economic Class only if their Claims meet the descriptions of one or more of the Damage Categories described in the Settlement Agreement.
16. To guide the selection of measured media in reaching unknown E&PD Settlement
Class Members, the Notice Plan has a primary target audience of: all adults 18 years and older,
currently living in the Gulf Coast Areas. To further extend the reach of the Plan to unknown
Class Members who do not currently reside in the Gulf Coast Areas, the Plan includes a broad
national effort to reach adults 18 years and older across the United States.
17. To frame the local portion of the Notice Plan, local media was analyzed for each
Designated Marketing Area (“DMA”)12 in which the largest population center within each
respective DMA included a portion of the defined Gulf Coast Areas. Twenty-six (26) individual
DMAs encompassing the Gulf Coast Areas have been used to establish the geographic scope for
the local portion of the media plan. They are as follows:
Houston Mobile-Pensacola-Ft. Walton Ft. Meyers-Naples
Beaumont- Port Arthur Montgomery-Selma Panama City
New Orleans Dothan Hattiesburg-Laurel
Lake Charles Miami-Ft. Lauderdale Alexandria, LA
Lafayette, LA Tallahassee-Thomasville Monroe-El Dorado
Baton Rouge Gainesville Shreveport
12 DMA or “Designated Marketing Area” is a term used by Nielsen Media Research to identify an exclusive geographic area of counties or parishes in which the home market television stations hold a dominance of total hours viewed. There are 210 DMAs in the U.S.
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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Biloxi-Gulfport Tampa-St. Petersburg-Sarasota Jackson, MS
Columbus-Tupelo-West Point Meridian Huntsville-Decatur (FL)
Greenwood-Greenville Birmingham (Anniston and Tuscaloosa)
18. The E&PD Notice Plan includes Notice mailed to known potential Class
Members, compiled from various lists provided by the settling parties and their experts. Framed
by the 26 DMAs listed above, an extensive schedule of local newspaper, radio, television and
Internet placements has been proposed to reach Class Members in the Gulf Coast Areas. To
reach Class Members across the United States, the schedule includes well-read consumer
magazines, a national daily business newspaper, highly trafficked websites and Sunday local
newspapers (via newspaper supplements). Notice placements will also appear in non-measured
trade, business and specialty publications, African-American, Vietnamese and Spanish language
publications and Cajun radio programming. An informational release, television public service
announcements (“PSAs”), and case website will provide additional notice exposures.
19. The combined measurable effort will reach at least 95% of adults aged 18+ in the
26 identified DMAs covering the Gulf Coast Areas an average of 8.8 times each and an
estimated 83% of all U.S. adults an average of 3.8 times each.
20. In my experience, the projected reach and frequency of the Notice Plan media effort
in the Gulf Coast Areas will surpass that of the vast majority of other court-approved notice
programs, and has been designed to meet and exceed due process requirements. The reach and
frequency to all U.S. adults is also consistent with the most thorough and expansive class action
media notice efforts.
21. Hilsoft was also retained to design and implement a Notice Plan for the
contemporaneously filed Medical Benefits Settlement with BP. The two Notice Plans are
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separate and distinct. For the purposes of this affidavit, the adequacy of the E&PD Notice Plan
and notices are discussed. A separate affidavit for the Medical Benefits Settlement has been
submitted to the Court regarding the proposed Medical Benefits Notice Plan and Notices.
22. To prevent confusion over the two settlements, the proposed E&PD Notice Plan
highlights that the Court is considering two separate settlements. Each Notice Plan includes
unique individual mailing pieces, mailed separately in different colored envelopes. Print
publication notice consists of a single advertising unit with one Summary Publication Notice that
addresses the E&PD Settlement, and a separate Summary Publication Notice that addresses the
Medical Benefits Settlement. Depending on the publication, the Summary Publication Notices
will appear either side-by-side or stacked one above the other. Broadcast and Internet banner
efforts will provide the message that there is one settlement addressing economic and property
damage claims, and a separate settlement addressing medical claims.
ECONOMIC AND PROPERTY DAMAGES NOTICE PLAN
23. We designed the Notice Program to reach the greatest practicable number of E&PD
Settlement Class Members, ensuring that the Class will receive multiple opportunities to be
exposed to the Notice, to see, review, understand, and be reminded about it, and to respond
appropriately if they so choose. The E&PD Notice Plan utilizes direct mail, paid published,
broadcast, and Internet notice placements, as well as an informational release, a television PSA
and a case website, as outlined below. The Notices have been designed to provide a clear,
concise, plain language statement of Class Members’ legal rights and options. The Notices alert
Class Members that the content may affect them.
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Individual Mailed Notice
24. For each unique name and address of a known or likely Economic and Property
Damages Settlement Class Member, a Notice Packet will be mailed via first class mail in a flat
envelope. The Notice Packet will include a Cover Letter and Detailed Notice, and is expected to
include a color map folio. Potential Class Members will be directed to the settlement website
and the toll-free number for detailed information on how to file a Claim, to access Claim Forms,
and to seek assistance as needed with filing a claim. The Cover Letter and Detailed Notice are
included in the attachments to the Notice Plan (Exhibit 2 to this affidavit).
25. The mailing list has been compiled from multiple lists of known or likely
Settlement Class Members, including the following:
• Short Form Joinders filed in MDL 2179;
• The MDL 2179 Plaintiffs list;
• Gulf Coast Claims Facility (“GCCF”) list of non-medical claimants and those who requested information about the GCCF process and provided contact information to the GCCF 13;
• BP Claims Facility list of claimants who filed claims under the Oil Pollution Act of 1990, prior to the creation of the GCCF;
• Vessels of Opportunity (“VoO”) lists and lists of VoO contractors who subcontracted out to other vessels; and
• Lists of ascertainable Coastal Real Property owners, Wetlands Real Property owners and Real Property Sales owners who are presumptively members the Settlement Class and do not have to demonstrate a loss in order to be eligible to file a claim.
26. Prior to mailing, all addresses will be checked against the National Change of
Address (“NCOA”) database maintained by the United States Postal Service (“USPS”).14 If a
13 An Economic and Property Damage Settlement Notice packet will be mailed to all names and addresses in the GCCF database that do not unambiguously relate only to a medical claim. (Individuals who unambiguously relate only to a medical claim will be mailed a Notice packet related to the separate Medical Benefits Settlement). For any record in the GCCF database where there is any ambiguity as to the subject matter of that individual’s claim or request for further information, an Economic and Property Damage Notice Packet will be mailed.
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DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENT NOTICES AND NOTICE PLAN
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record is returned by NCOA as invalid, the administrator will update the address through third-
party address search services and re-mail as appropriate. Notices returned as undeliverable will
be re-mailed to any new address available through postal service information, for example, to the
address provided by the postal service on returned pieces for which the automatic forwarding
order has expired (but which is still during the period in which the postal service returns the
piece with the address indicated) or to better addresses that may be found after reasonable,
additional third-party source lookups. Upon successfully locating better addresses, Notices will
be promptly re-mailed on an ongoing basis leading up to the Fairness Hearing. Additionally, the
Notice Packet will be mailed to all persons who request one via the toll-free phone number
maintained by the administrator.
27. For some known or likely Settlement Class Members, only a name and email
address is available and no other means exist of determining a physical address. These
individuals will be sent notice via email. For known or likely Settlement Class Members for
whom a physical address and an email address are available, notice will be sent via email in
addition to postal mail. The Email Notice will include substantially the same content as the text
of the Publication Notice that is specific to the E&PD Settlement, and will contain a link to the
settlement website where the Detailed Notice and other detailed settlement information can be
accessed. The Email Notice will be provided using an embedded HTML text format. This
format will provide text that is easy to read without graphics, tables, images and other elements
that would increase the likelihood that the message is blocked by Internet Service Providers
(ISPs) and/or SPAM filters. Prior to transmitting the Email Notice, the Claims Administrator will
14 The NCOA database contains records of all permanent change of address submissions received by the USPS for the last four years. The USPS makes this data available to mailing firms and lists submitted to it are automatically updated with any reported move based on a comparison with the person’s name and known address.
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notify major ISPs about the scheduled notification effort to get these messages “white-listed” for
delivery to recipient mailboxes.
28. Each Email Notice will be transmitted with a unique message identifier. If the
receiving email server cannot deliver the message, a “bounce code” should be returned to the
sending server along with the unique message identifier. For any Email Notice for which a
bounce code is received indicating that the message was undeliverable, at least two additional
attempts will be made to deliver the Notice by email.
29. The Notice Packet will also be sent to known attorneys who represent likely Class
Members other than Class Counsel.
Gulf Coast Areas Local Newspaper Notice
30. The Notice Plan to the Gulf Coast Areas includes notice placements in daily and
weekly newspapers covering each of the DMAs specified in paragraph 17 above. These 26
DMAs ringing the Gulf Coast Areas will be covered by a total of 347 individual, local
newspapers.
31. The Publication Notice will run in an additional 17 newspapers in the Memphis
(12), Atlanta (1) and Columbus (4) DMAs. These three DMAs lie predominately outside the
Class geography, but do have small areas carved into the states of Mississippi (Memphis DMA)
and Alabama (Atlanta and Columbus DMAs). It is these small areas that are covered by the 17
additional newspapers. Including these insertions, the Publication Notice will run in a total of
364 individual, local newspapers.
32. The Publication Notice will appear four times as a full-page ad unit in each
newspaper—twice on Sunday and twice on a weekday in daily newspapers and over four
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successive weeks in weekly newspapers for a total of 1,456 insertions. The selected newspapers
have a combined circulation of over 8 million. In most instances, the Notice will appear a fifth
or sixth time in each local newspaper via the two planned insertions in the nationwide newspaper
supplements (Parade, USA Weekend and American Profile) discussed below. When this occurs,
the Notice will appear on successive Sundays with the weekday insertion in-between the two
local newspaper Sunday insertions. As placed, the Publication Notice ad unit will include
separate Notices addressing both the E&PD Settlement, and the separate Medical Benefits
Settlement. Depending on the publication, the separate Notice text for each Settlement will
appear either side-by-side or stacked one above the other.
33. The list of selected local newspapers is included as Attachment 3 to the E&PD
Notice Plan (attached hereto as Exhibit 2).
Gulf Coast Areas Local Television Notice
34. The E&PD Notice Plan provides for 30-second television spots that will appear on
local broadcast and cable television in the same 26 DMAs as the daily and weekly newspaper
placements.
35. We conservatively estimate that 2,730 30-second spots will run over a four-week
period. Television placements will substantially occur over the initial three weeks with the
fourth week reserved for any remaining inventory. Approximately 300 Gross Rating Points
(“GRPs”)15 per market and over 67 million gross impressions will be generated. Ads are planned
to air on the top three local television stations per market and on the top six cable networks per
market. It is likely that additional spots will be negotiated at the time of the buy.
15 A “GRP” is a gross rating point. One rating point equals one percent of a target population. Gross rating points may include the same person reached more than once, so ratings can and often do exceed 100.
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36. A variety of dayparts (morning, daytime, syndicated day/prime access/early fringe,
early news, and prime/syndicated prime) will be used to increase reach among persons with
different viewing habits.
37. On its own, the Television Notice is estimated to reach an average of 83% of adults
aged 18+ in the Gulf Coast Areas with an estimated average frequency of 3.6 times each. Adults
will be exposed to the television Notice more than 67 million times during the period in which
the television schedule airs.
38. The E&PD Notice Plan also includes a television PSA effort. The Television
Notice will be distributed to over 1,200 broadcast television stations throughout the United States
with a statement to station managers on why the announcement provides important legal
information that may be relevant to their viewers.
Gulf Coast Areas Local Radio
39. The E&PD Notice Plan provides for 30-second radio units, which will appear over
a two-week schedule on selected mainstream radio stations in the same 26 DMAs as the daily
and weekly newspaper placements and television ads.
40. It is estimated that the mainstream local Radio Notice will generate approximately
180 GRPs per market. We conservatively estimate that 8,712 total spots will be run, but it is
possible that additional spots will be negotiated at the time of the buy. On its own, the
mainstream Local Radio Notice is estimated to reach an average of 45% of adults aged 18+ in
the Gulf Coast Areas with an estimated average frequency of 4 times each.
41. Targeting rural communities, the radio notice will also appear on “StateNets,” a
radio network specializing in reaching rural areas. Typical StateNets features are news, regional
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weather and other informational programs. We estimate that over 14,000 total spots will run on
approximately 200 radio stations in the 26 DMAs over a three-week period.
42. Additionally, the Radio Notice will be placed on appropriate African-American and
Spanish language stations. We estimate that 4,032 spots will run on African-American stations.
A further 936 spots will run on Spanish language stations in areas of the Gulf Coast with high
concentrations of Spanish-speaking adults. The Spanish language Radio Notice will be recorded
as a 60-second spot to accommodate the translation.
43. A radio buy will also be executed, targeted toward the Cajun population in Southern
Louisiana. Approximately 100 spots will run over a two-week period on local stations,
including: KLRZ-FM, KLEB-AM, and KANE-AM. The spot will be voiced in a Cajun dialect.
Gulf Coast Areas Foreign Language and Ethnic Publications
44. The Publication Notice will appear in publications covering ethnic and language
groups identified as having a significant presence in the Gulf Coast Areas. The Notice will
appear in 46 selected publications as a double-page spread or full-page ad unit three times in
selected daily and weekly publications and one time in selected monthly publications covering
the African-American, Vietnamese and Spanish language populations in the Gulf Coast Areas.
The Notice will be translated into Vietnamese and Spanish where appropriate. The 46 selected
publications have a combined estimated circulation of over 1.8 million.
National Newspaper Inserts and Consumer Publications
45. The E&PD Notice Plan includes highly visible notice placements in thirteen leading
weekly and monthly publications. Notices will appear twice in the national newspaper
supplements Parade and USA Weekend and once in American Profile which appear in over
2,190 Sunday newspapers nationwide with distribution in large cities and small towns. The
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newspapers appear in a wide geographic area, covering both large markets (A and B counties16
with Parade and USA Weekend) and small cities and towns (C and D counties17 with American
Profile). Combined, Parade, USA Weekend and American Profile have an estimated circulation
of more than 65 million.
46. Notices will appear twice in People, and once in Better Homes and Gardens, AARP
Bulletin, National Geographic, Cosmopolitan, Sports Illustrated, Southern Living, People en
Espanol, Ebony and Essence, for a total of 11 insertions.
47. The selected publications include the top four in the country in terms of circulation
and six of the top seven. The selected publications cover all demographic groups, specifically
targeting men’s and women’s publications, magazines aimed at older demographic segments,
Spanish-speaking readers and publications specifically targeting African-American readers.
48. The selected Sunday newspaper inserts and consumer publications have a total
circulation of over 114 million. Adults will be exposed to the Notice through these publications
alone more than 521 million times during the notice period. This includes the same reader more
than once, because readers of one publication read other publications as well. Detailed
information on each of the publications selected is included in the E&PD Notice Plan attached as
Exhibit 2.
16 “County/parish size A” is defined as highly urbanized areas and belong to the 21 largest Metropolitan Statistical Areas. The combined counties/parishes contain 40% of the United States households. “County/parish size B” is defined as counties/parishes not defined as A counties/parishes that have more than 85,000 households. The combined counties/parishes contain 30% of United States households. 17 “County/parish size C” is defined as counties/parishes not defined as A or B counties/parishes that have more than 20,000 households or are in Consolidated Metropolitan Statistical Areas or Metropolitan Statistical Areas with more than 20,000 households. “County/parish size D” is defined as all counties/parishes not classified as A, B or C counties/parishes. They are considered very rural.
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Nationwide and Regional Business and Trade Publications
49. The Publication Notice will appear once or twice as a double-page spread or
equivalent size ad unit in 34 selected publications targeted to the industries and activities most
likely to have been directly affected by the Deepwater Horizon event. The selected publications,
which include the national edition of the Wall Street Journal, have a combined circulation of
over 5 million.
Internet Banner Notices
50. The E&PD Notice Plan provides for Banner Notices measuring 728 x 90 pixels and
300 x 250 pixels, which will be placed on the following national online networks: Yahoo!, MSN,
AOL, Weather.com, and 24/7 Real Media (a network that represents over 900 websites including
those related to health, fitness, and news and information).
51. Where available, banners will also be placed on the websites of the selected trade
and specialty publications included in the print publication plan.
52. Combined, approximately 72 million adult impressions will be generated by these
banner notices over a one month period. Clicking on the banner will link the reader to the case
notice website where they can obtain information about the Settlement and link directly to the
separate claims administration websites for each Settlement.
53. To complement print notices in the selected local newspapers, digital 728 x 90 pixel
and 300 x 250 pixel banners will be placed on newspaper and local TV websites in the identified
geographies. Banner Notices will run across 31 days and deliver more than 42 million
impressions across Louisiana, Mississippi, Alabama and portions of Texas and Florida. Each
banner notice will include a clickable link to the case notice website.
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Informational Release
54. To build additional reach and extend exposures, a party-neutral informational
release will be issued to approximately 4,200 print and broadcast and 5,500 online press outlets
throughout the United States.
55. An informational release serves a potentially valuable role, providing additional
notice exposure beyond that which will be provided through paid media. There is no guarantee
that any news stories will result, but if they do, Class Members will have additional opportunities
to learn that their rights are at stake in credible news media, adding to their understanding.
Case Website
56. A neutral, informational, notice website with an easy to remember domain name
will serve as the notice page for both Settlements (the E&PD Settlement as well as the Medical
Benefits Settlement) where potential Settlement Class Members can obtain additional
information and documents including the Detailed and Summary Notices, Settlement
Agreements, Preliminary Approval Orders and any other information that the parties agree to
provide or that the Court may require. The case notice website will also include information on
how potential Settlement Class Members can opt-out of the Settlement if they choose.
57. The case notice website address will be prominently displayed in all printed notice
documents, and appear in all broadcast media including the informational release and TV PSAs.
The Banner Notices will link directly to the website.
58. Visitors to the case notice website will be able to easily link to separate claims
administration websites tailored to each Settlement via prominent buttons on the notice website
homepage (one reading “Economic and Property Damages Claims” and the other reading
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“Medical Claims”). Claim Forms and other information specific to each Settlement will be
available at these claims administration sites. The case notice website will be color-coordinated
with the claims administration websites and all pages that a visitor might see will have a
consistent look and functionality. To stress the separateness of the two Settlements, the claims
administration sites will have different, but compatible, color schemes. The case notice website
will reflect this by having the button links to each claims administration website in the specific
color scheme of the website it is linking to. Both claims administration websites will include a
prominent link to the other claims administration website for visitors interested in both
settlements.
59. The claims administrator claims filing website will include an interactive map of
the Gulf Coast where visitors will be able to input their property or residency address or select a
geographic location to assist them in determining if the address falls into one or more of the
defined Settlement “Zones.”
60. All website content (including the Notices) will be available in English, Spanish
and Vietnamese. Translated Notices may also be made available in Khmer, Lao and
Haitian/Creole if requested.
61. To facilitate locating the case notice website, sponsored search listings will be
acquired on the three most highly-visited Internet search engines: Google, Yahoo! and Bing.
When search engine visitors search on common keyword combinations such as “Deepwater
Horizon settlement,” “Gulf property settlement,” or “BP oil spill settlement,” the sponsored
search listing will display either at the top of the page prior to the search results or in the upper
right hand column.
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Toll-free Telephone Number and Postal Mailing Address
62. A single toll-free number will be established for both Settlements. Callers will have
the option of selecting to listen in English, Spanish or Vietnamese. Initially, all callers will hear
an introductory message that two separate settlements related to the Deepwater Horizon oil spill -
one settlement addressing economic and property damages claims, and a separate settlement
addressing medical claims - have been reached. Callers will then have the option to continue to
get information about one or the other settlement, request a Detailed Notice by mail and have the
option to choose to speak with a live operator.
63. A postal mailing address and email address for each claims administrator will be
provided, allowing Class Members to request additional information or ask questions via these
channels.
PERFORMANCE OF E&PD NOTICE PROGRAM
Reach
64. Using standard advertising media industry methodologies to calculate the overlap
inherent in exposures to the measured publication, broadcast and Internet activity, we arrive at a
combined measurable reach of at least 95% of adults in the Gulf Coast Areas18 aged 18+ and an
estimated 83% of all U.S. adults aged 18+. Reach will be enhanced further by the Individual
Mailed Notice effort, notice placements in unmeasured trade, business and specialty
publications, African-American publications, Vietnamese and Spanish language publications,
and the informational release, television PSAs and case website.
18 While there is some variation in reach of the individual Notice Plan components from DMA to DMA, the estimated reach of the entire Notice Plan is at least 95% in each of the 26 DMAs that cover the Gulf Coast Areas.
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65. Many courts have accepted and understood that a 75 or 80 percent reach is more
than adequate. In 2010, the Federal Judicial Center issued a Judges’ Class Action Notice and
Claims Process Checklist and Plain Language Guide. This Guide states that, “the lynchpin in an
objective determination of the adequacy of a proposed notice effort is whether all the notice
efforts together will reach a high percentage of the class. It is reasonable to reach between 70–
95%. A study of recent published decisions showed that the median reach calculation on
approved notice plans was 87%.”19 Here we were able to exceed that and develop a notice plan
that will perform at the highest level of reportable reach. These statistics reinforce the fact that
the E&PD Notice Plan is broad in scope and is designed to reach the greatest practicable number
of Class Members.
Average Frequency of Exposure
66. The E&PD Notice Plan will provide Class Members with the best practicable
opportunity to view and understand the Notice and their rights, including their rights to opt-out
and object to the Settlement and their right to file a claim. A by-product of using media vehicles
necessary to achieve a broad net reach is frequency of exposure to notice stemming from
inherent audience overlap.
67. As a result, adults in the Gulf Coast Areas reached will, on average, have 8.8
exposure opportunities20 to the proposed Notice Program and each U.S. adult aged 18+ reached
will, on average, have 3.8 exposure opportunities to the proposed Notice Program. The
frequency of exposure will be further enhanced by the Individual Mailed Notice effort, notice
19 Federal Judicial Center, Judges’ Class Action Notice and Claims Process Checklist and Plain Language Guide (2010), p. 3. 20 The estimated frequency of 8.8 times is a conservative average across all 26 DMAs covering the Gulf Coast Areas. Frequency by DMA is estimated to range from a low of 7.9 times to a high of 9.6 times or more.
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placements in unmeasured trade, business and specialty publications, African-American
publications, Vietnamese and Spanish language publications, informational release, television
PSAs, and case website.
PLAIN LANGUAGE NOTICE DESIGN
68. As fully explained in the E&PD Notice Plan, the Notices themselves are designed
to be “noticed,” reviewed, and—by presenting the information in plain language— understood
by Class Members. The design of the Notices follows the principles embodied in the Federal
Judicial Center’s illustrative “model” notices posted at www.fjc.gov. Many courts, and as
previously cited, the FJC itself, have approved notices that we have written and designed in a
similar fashion. The Notices contain substantial, albeit easy-to-read, summaries of all of the key
information about Class Members’ rights and options. Consistent with our normal practice, all
notice documents will undergo a final edit prior to actual mailing and publication for
grammatical errors and accuracy. Along with our submission of the E&PD Notice Plan attached
as Exhibit 2, we have included all of the following proposed forms of notice:
• The Cover Letter and Detailed Notice that will be mailed to all known potential Settlement Class Members and to those who call to request one as well as made available at the website.
• The Email Notice that will be sent to known or likely Settlement Class Members for whom an email address is available.
• The Publication Notice as it will appear in magazines and newspapers.
• The Television Notice Script that will be produced as a 30-second unit and aired as a paid local spot and nationally via the TV PSA effort.
• The Radio Notice Script that will be produced as a 30-second spot (60-second when translated into Spanish) and aired as a paid local spot.
• The Internet Banner Notices that will be posted on a variety of web properties.
• The neutral Informational Release that will be issued to news outlets throughout the U.S.
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69. All Notices were designed to increase noticeability and comprehension. Because
mailing recipients are accustomed to receiving junk mail that they may be inclined to discard unread,
the program calls for steps to bring the mailed Notice to the attention of Settlement Class Members.
Once people “notice” the Notices, it is critical that they can understand them. As such, the Notices,
as produced, are clearly worded with an emphasis on simple, plain language to encourage readership
and comprehension.
70. The mailed Notice Packet will be inserted into a flat 9x12 envelope and will carry a
prominent callout on the front of the envelope (“DEEPWATER HORIZON – Economic and
Property Damages Settlement”) and a more descriptive callout on the back of the envelope (“If
you had economic loss or property damage because of the Deepwater Horizon oil spill, you
could get money from a class action settlement.”). To reduce confusion for people that may be
members of the E&PD Settlement Class and the Medical Benefits Settlement Class, the envelope
will coordinate with the color of the E&PD Settlement claims administration website and be distinct
from the color of the envelope containing the Medical Settlement Notice Packet (which will
coordinate with the Medical Benefits claims administration website). The Publication Notice
features a prominent headline (“Deepwater Horizon Oil Spill – Economic and Property Damages
Settlement – Providing Money to Individuals and Businesses”) in bold text. These design
elements alert recipients and readers that the Notice is an important document authorized by a court
and that the content may affect them, thereby supplying reasons to read the Notice.
71. The Detailed Notice provides substantial information to Settlement Class Members. The
E&PD Detailed Notice begins with a summary page providing a concise overview of the important
information and a table highlighting key options available to E&PD Settlement Class Members. A
table of contents, categorized into logical sections, helps to organize the information, while a
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question and answer format makes it easy to find answers to common questions by breaking the
information into simple headings.
72. The Email Notice will include substantially the same content as the text of the
Publication Notice that is specific to the E&PD Settlement, and will contain an embedded link to the
notice website where the Detailed Notice and other settlement information can be accessed. The
Email Notice will be provided using an embedded HTML text format. This format will provide text
that is easy to read without graphics, tables, images and other elements that would increase the
likelihood that the message is blocked by Internet Service Providers (ISP’s) and/or SPAM filters.
73. The ad units in which the Publication Notice will appear in will promote attention to the
E&PD Settlement. The Notices are either full-page units in the local newspapers or double-page
spreads in most print publications to promote readership.
74. The Television and Radio Notices are designed to stand apart from regular consumer
ads. Because they are designed to look and sound different from commercials selling products,
viewers and listeners will understand the Notice’s significance and take notice. Key words and
concepts will be depicted on screen. The principles of communication dictate visual and verbal
repetition of key concepts presented. A convenient response-oriented approach is provided. In the
Television Notice, the website and toll-free number will be spoken and shown on the screen long
enough to allow Class Members to write them down or remember them. The Radio Notice will
repeat the toll-free number and website if time permits. Simple information allows sufficient
understanding. Although concise, the purpose of the Notice is served by delivering the substance of
the message (that there are two separate Settlements) and prompting a response to get more
information.
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CONCLUSION
75. In class action notice planning, execution, and analysis, we are guided by due
process considerations under the United States Constitution, by federal and local rules and
statutes, and further by case law pertaining to notice. This framework directs that the notice
program be designed to reach the greatest practicable number of potential Class Members and, in
a settlement class action notice situation such as this, that the notice or notice program itself not
limit knowledge of the availability of benefits—nor the ability to exercise other options—to
Class Members in any way. All of these requirements will be met in this case.
76. Our notice effort follows the guidance for how to satisfy due process obligations
that a notice expert gleans from the United States Supreme Court’s seminal decisions, which are:
a) to endeavor to actually inform the class, and b) to demonstrate that notice is reasonably
calculated to do so:
A. “But when notice is a person’s due, process which is a mere gesture is not due
process. The means employed must be such as one desirous of actually informing the
absentee might reasonably adopt to accomplish it,” Mullane v. Central Hanover
Trust, 339 U.S. 306, 315 (1950).
B. “[N]otice must be reasonably calculated, under all the circumstances, to apprise
interested parties of the pendency of the action and afford them an opportunity to
present their objections,” Eisen v. Carlisle & Jacquelin, 417 U.S. 156 (1974) citing
Mullane at 314.
77. The Notice Program will provide the best notice practicable under the
circumstances of this case, conforms to all aspects of Federal Rule of Civil Procedure 23, and
comports with the guidance for effective notice articulated in the Manual for Complex Litigation
4th.
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78. As reported above, the E&PD Notice Plan will effectively reach at least 95% of
adults in the Gulf Coast Areas aged 18+ and no less than 83% of U.S. adults aged 18+. It will
deliver “noticeable” Notices to capture Class Members’ attention, and provide them with
information necessary to understand their rights and options.
79. The E&PD Notice Plan schedule will afford enough time to provide full and proper
notice to Class Members before any opt-out and objection deadline.
80. At the appropriate time, Hilsoft may also develop and implement subsequent notice
efforts as agreed to by the parties and/or directed by the Court, including a reminder notice effort
in advance of the claim filing deadline. Any reminder notice effort will be guided by the
performance of and response to the E&PD Notice Plan.
81. At the conclusion of the E&PD Notice Plan, we will provide a final report verifying
its effective implementation.
I declare under penalty of perjury that the foregoing is true and correct. Executed on April
17, 2012.
______________________________________
Cameron R. Azari, Esq.
© 2012 Hilsoft Notificatio
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Exhibit 1 to Declaration of Cameron Azari: Hilsoft Notifications Curriculum Vitae
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Hilsoft Notifications
Philadelphia Area Office 1420 Locust Str 30F Philadelphia, PA 19102 (215) 721-2120 (215) 721-6886 fax
Portland Area Office 10300 SW Allen Boulevard Beaverton, OR,97005 (503) 350-5822 (503) 350-5210 fax
Leading expert firm for large-scale notice plan design, implementation, and analysis, for claims processes, class actions and mass tort bankruptcies Court-approved notice plans withstood challenge to U.S. Supreme Court 50+ favorable judicial comments–0 unfavorable More than 240 cases with notices appearing in 209 countries and 53 different languages More than 20 MDL cases Equal work for defendants and plaintiffs Case examples include (also see Hwww.hilsoft.com H):
Largest discretionary class action notice campaign involving virtually every adult in the United States for the settlement of In re Trans Union Corp. Privacy Litigation.
Largest U.S. and Canadian retail consumer security breach notice program designed and implemented in the settlement of In re TJX Companies, Inc., Customer Data Security Breach Litigation.
Most complex national data theft class action settlement involving millions of class members in Lockwood v. Certegy Check Services, Inc.
Most comprehensive notice ever in a securities class action for the $1.1 billion settlement of In re Royal Ahold Securities and ERISA Litigation.
Largest and most complex class action in Canadian history. Designed/implemented groundbreaking notice to disparate, remote aboriginal people in the multi-billion dollar In re Residential Schools Litigation.
Largest race-based pricing case with national settlement notice to 25 million policyholders in Thompson v. Metropolitan Life Ins. Co., 216 F.R.D. 55, 62-68 (S.D. N.Y. 2003).
Most complex notice program in history by providing worldwide notice in the $1.25 billion settlement of In re Holocaust Victims Assets, “Swiss Banks,” No. CV-96-4849 (E.D.N.Y.). Designed/implemented all U.S. and international media notice with 500+ publications in 40 countries and 27 languages.
The largest U.S. claims process ever. Designed/implemented multi-media notice campaign for the U.S. Dept. of Agriculture’s $10 billion tobacco growers’ transition payment program.
National settlement notice to 40 million people in Scott v. Blockbuster, No. D 162-535 (Tex., 136th Jud. Dist.). Withstood collateral review, Peters v. Blockbuster, 65 S.W.3d 295, 307 (Tex. App.-Beaumont 2001).
Multi-national claims bar date notice In re The Babcock & Wilcox Co., No. 00-10992 (E.D. La.) to asbestos personal injury claimants. Opposing notice expert’s reach methodology challenge rejected by court.
National publication notice in Avery v. State Farm, No. 97-L-114 (Cir. Ct. Ill.) withstood challenges to Illinois Supreme Court and U.S. Supreme Court, and re-affirmed in Avery v. State Farm, 321 Ill. App. 3d 269 (5th Dist. 2001). Notice program untouched when Illinois Supreme Court decertified Class.
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KEY BIO’S
Cameron Azari, Esq., Director of Legal Noticing Legal Noticing Director Cameron Azari, Esq. has nine years experience in the design and implementation of legal notification and claims administration programs. He is a nationally recognized specialist in the creation of notification campaigns in compliance with Fed R. Civ. P. 23(c)(2) (d)(2) and (e) and similar state class action statutes. Cam has been responsible for dozens of legal notice and advertising programs. High profile class actions he has been involved in include companies such as Aetna, Humana, Wells Fargo, General Motors, Goodyear, Cigna, City of Miami, Budget Rent-a-Car, AT&T, AIG and T-Mobile. He is an active author and speaker on a broad array of legal notice and class action topics ranging from amendments to FRCP Rule 23 to email noticing, response rates and optimizing settlement effectiveness. Cam is an active member of the Oregon State Bar. He received his B.S. from Willamette University and his J.D. from Northwestern School of Law at Lewis and Clark College. Cam can be reached at [email protected]. Lauran Schultz, Executive Director Lauran Schultz is responsible for overall management of Hilsoft Notifications. He consults extensively with clients on notice adequacy and innovative legal notice programs that are both efficient and informed by the many court-approved programs developed by Hilsoft Notifications over close to a decade. High profile actions he has been involved in include companies such as: TransUnion, Ford Motors, Chrysler, TJX, Certegy, AIG, Dominion Resource Services, CNA, Continental Tire, Wal-Mart, Carrier Corporation, Vivendi, Parmalat, ConAgra and Toyota. Lauran has over a dozen years of consulting and management experience developing innovative marketing programs for nationally and internationally recognized brands such as National City, HSBC and Regions Bank along with affiliates of the American Automobile Association and Better Business Bureau. Prior to joining Epiq Systems in 2005, Lauran was a Senior Vice President of National City Bank in Cleveland, Ohio. Lauran’s education includes advanced study in political science at the University of Wisconsin-Madison, Cornell University and the London School of Economics along with a Ford Foundation fellowship from the Social Science Research Council and American Council of Learned Societies. Lauran can be reached at [email protected].
ARTICLES AND PRESENTATIONS
Cameron Azari Speaker, “Class Action Litigation Trends: A Look into New Cases, Theories of Liability & Updates on the Cases to Watch.” ACI’s Consumer Finance Class Actions and Litigation, New York, NY, January, 2012.
Lauran Schultz Speaker, “Legal Notice Best Practices: Building a Workable Settlement Structure.” CLE International’s 7th Annual Class Action Conference, San Francisco, CA, May, 2011.
Cameron Azari Speaker, “Data Breaches Involving Consumer Financial Information: Litigation Exposures and Settlement Considerations.” ACI’s Consumer Finance Class Actions and Litigation, New York, NY, January, 2011.
Cameron Azari Speaker, “Notice in Consumer Class Actions: Adequacy, Efficiency and Best Practices.” CLE International’s 5th Annual Class Action Conference: Prosecuting and Defending Complex Litigation, San Francisco, CA, 2009.
Lauran Schultz Speaker, “Efficiency and Adequacy Considerations in Class Action Media Notice Programs.” Chicago Bar Association, Chicago, IL, 2009.
Cameron Azari Author, “Clearing the Five Hurdles of Email - Delivery of Class Action Legal Notices” - Thomson Reuters Class Action Litigation Reporter – June, 2008.
Cameron Azari Speaker, “Planning for a Smooth Settlement.” ACI: Class Action Defense - Complex Settlement Administration for the Class Action Litigator, Phoenix, AZ, 2007.
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Cameron Azari Speaker, Noticing and Response Rates in Class Action Settlements” – Class Action Bar Gathering, Vancouver, British Columbia, 2007.
Cameron Azari Speaker, “Structuring a Litigation Settlement.” CLE International’s 3rd Annual Conference on Class Actions, Los Angeles, CA, 2007.
Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Skadden Arps Slate Meagher & Flom, LLP, 2006.
Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Bridgeport Continuing Legal Education, Class Action and the UCL, 2006.
Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Stoel Rives litigation group, Portland/Seattle/Boise/Salt Lake City, 2005.
Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Stroock Stroock & Lavan litigation group, Los Angeles, CA, 2005.
Cameron Azari Author, “Twice the Notice or No Settlement” – Current Developments – Issue II, August, 2003.
Cameron Azari Speaker, “A Scientific Approach to Legal Notice Communication” – Weil Gotshal litigation group, New York, 2003.
JUDICIAL COMMENTS
Judge Robert M. Dow, Jr., Schulte v. Fifth Third Bank, (July 29, 2011) No. 1:09-cv-6655 (N.D. Ill.):
The Court has reviewed the content of all of the various notices, as well as the manner in which Notice was disseminated, and concludes that the Notice given to the Class fully complied with Federal Rule of Civil Procedure 23, as it was the best notice practicable, satisfied all constitutional due process concerns, and provided the Court with jurisdiction over the absent Class Members.
Judge Lee Rosenthal, In re: Heartland Payment Systems, Inc Customer Data Security Breach Litigation, (March 2, 2012) MDL 09-2046 (S.D. Tex.):
The notice that has been given clearly complies with Rule 23(e)(1)’s reasonableness requirement… Hilsoft Notifications analyzed the notice plan after its implementation and conservatively estimated that notice reached 81.4 percent of the class members. (Docket Entry No. 106, ¶ 32). Both the summary notice and the detailed notice provided the information reasonably necessary for the presumptive class members to determine whether to object to the proposed settlement. See Katrina Canal Breaches, 628 F.3d at 197. Both the summary notice and the detailed notice “were written in easy-to-understand plain English.” In re Black Farmers Discrimination Litig., — F. Supp. 2d —, 2011 WL 5117058, at *23 (D.D.C. 2011); accord AGGREGATE LITIGATION § 3.04(c).15 The notice provided “satisf[ies] the broad reasonableness standards imposed by due process” and Rule 23. Katrina Canal Breaches, 628 F.3d at 197 (internal quotation marks omitted).
Judge Barbara Crowder, Dolen v. ABN AMRO Bank N.V., (March 23, 2009) No. 01-L-454, 01-L-493, (3rd Jud. Cir. Ill.):
The Court finds that the Notice Plan is the best notice practicable under the circumstances and provides the Eligible Members of the Settlement Class sufficient information to make informed and meaningful decisions regarding their options in this Litigation and the effect of the Settlement on their rights. The Notice Plan further satisfies the requirements of due process and 735 ILCS 5/2-803. That Notice Plan is approved and accepted. This Court further finds that the Notice of Settlement and Claim Form comply with 735 ILCS 5/2-803 and are appropriate as part of the Notice Plan and the Settlement, and thus they are hereby approved and adopted. This Court further finds that no other notice other than that identified in the Notice Plan is reasonably necessary in this Litigation.
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Judge Ellis J. Daigle, Williams v. Hammerman & Gainer Inc., (June 30, 2011) No. 11-C-3187-B (27th Jud. D. Ct. La.):
Notices given to Settlement Class members and all other interested parties throughout this proceeding with respect to the certification of the Settlement Class, the proposed settlement, and all related procedures and hearings—including, without limitation, the notice to putative Settlement Class members and others more fully described in this Court’s order of 30th day of March 2011 were reasonably calculated under all the circumstances and have been sufficient, as to form, content, and manner of dissemination, to apprise interested parties and members of the Settlement Class of the pendency of the action, the certification of the Settlement Class, the Settlement Agreement and its contents, Settlement Class members’ right to be represented by private counsel, at their own cost, and Settlement Class members’ right to appear in Court to have their objections heard, and to afford Settlement Class members an opportunity to exclude themselves from the Settlement Class. Such notices complied with all requirements of the federal and state constitutions, including the due process clause, and applicable articles of the Louisiana Code of Civil Procedures, and constituted the best notice practicable under the circumstances and constituted due and sufficient notice to all potential members of the Settlement Class.
Judge Stefan R. Underhill, Mathena v. Webster Bank, N.A., (March 24, 2011) No. 3:10-cv-1448 (D. Conn.):
The form, content, and method of dissemination of Notice given to the Settlement Class were adequate and reasonable, and constituted the best notice practicable under the circumstances. The Notice, as given, provided valid, due, and sufficient notice of the proposed settlement, the terms and conditions set forth in the Settlement Agreement, and these proceedings to all persons entitled to such notice, and said notice fully satisfied the requirements of Rule 23 of the Federal Rules of Civil Procedure and due process.
Judge Ted Stewart, Miller v. Basic Research, LLC, (September 2, 2010) No. 2:07-cv-871 (D. Utah):
Plaintiffs state that they have hired a firm specializing in designing and implementing large scale, unbiased, legal notification plans.69 Plaintiffs represent to the Court that such notice will include: 1) individual notice by electronic mail and/or first-class mail sent to all reasonably identifiable Class members; 2) nationwide paid media notice through a combination of print publications, including newspapers, consumer magazines, newspaper supplements and the Internet; 3) a neutral, Court-approved, informational press release; 4) a neutral, Court-approved Internet website; and 5) a toll-free telephone number. Similar mixed media plans have been approved by other district courts post class certification. The Court finds this plan is sufficient to meet the notice requirement.
Judge Sara Loi, Pavlov v. Continental Casualty Co., (October 7, 2009) No. 5:07cv2580 (N.D. Ohio):
As previously set forth in this Memorandum Opinion, the elaborate notice program contained in the Settlement Agreement provides for notice through a variety of means, including direct mail to each class member, notice to the United States Attorney General and each State, a toll free number, and a website designed to provide information about the settlement and instructions on submitting claims. With a 99.9% effective rate, the Court finds that the notice program constituted the “best notice that is practicable under the circumstances,” Fed. R. Civ. P. 23(c)(2)(B), and clearly satisfies the requirements of Rule 23(c)(2)(B).
Judge James Robertson, In re: Department of Veterans Affairs (VA) Data Theft Litigation, (September 23, 2009) MDL No. 1796 (D. D.C.):
The Notice Plan, as implemented, satisfied the requirements of due process and was the best notice practicable under the circumstances. The Notice Plan was reasonably calculated, under the circumstances, to apprise Class Members of the pendency of the action, the terms of the Settlement, and their right to appear, object to or exclude themselves from the Settlement. Further, the notice was reasonable and constituted due, adequate and sufficient notice to all person entitled to receive notice.
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Judge Lisa F. Chrystal, Little v. Kia Motors America, Inc., (August 27, 2009) No. UNN-L-0800-01 (N.J. Super. Ct.):
The Court finds that the manner and content of the notices for direct mailing and for publication notice, as specified in the Notice Plan (Exhibit 2 to the Affidavit of Lauran R. Schultz), provides the best practicable notice of judgment to members of the Plaintiff Class.
Judge Robert W. Gettleman, In re Trans Union Corp., (September 17, 2008) MDL No. 1350 (N.D. Ill.):
The Court finds that the dissemination of the Class Notice under the terms and in the format provided for in its Preliminary Approval Order constitutes the best notice practicable under the circumstances, is due and sufficient notice for all purposes to all persons entitled to such notice, and fully satisfies the requirements of the Federal Rules of Civil Procedure, the requirements of due process under the Constitution of the United States, and any other applicable law…Accordingly, all objections are hereby OVERRULED.
Judge William G. Young, In re TJX Companies, (September 2, 2008) MDL No. 1838 (D. Mass.):
The form, content, and method of dissemination of notice provided to the Settlement Class were adequate and reasonable, and constituted the best notice practicable under the circumstances. The Notice, as given, provided valid, due, and sufficient notice of the proposed settlement, the terms and conditions set forth in the Settlement Agreement, and these proceedings to all Persons entitled to such notice, and said Notice fully satisfied the requirements of Fed. R. Civ. P. 23 and due process.
Judge Steven D. Merryday, Lockwood v. Certegy Check Services, Inc., (September 3, 2008) No. 8:07-cv-1434-T-23TGW (M.D. Fla.):
The form, content, and method of dissemination of the notice given to the Settlement Class were adequate and reasonable and constituted the best notice practicable in the circumstances. The notice as given provided valid, due, and sufficient notice of the proposed settlement, the terms and conditions of the Settlement Agreement, and these proceedings to all persons entitled to such notice, and the notice satisfied the requirements of Rule 23, Federal Rules of Civil Procedure, and due process.
Judge Philip S. Gutierrez, Shaffer v. Continental Casualty Co., (June 11, 2008) SACV-06-2235-PSG (PJWx) (C.D. Cal.):
…was reasonable and constitutes due, adequate, and sufficient notice to all persons entitled to receive notice; and met all applicable requirements of the Federal Rules of Civil Procedure, the Class Action Fairness Act, the United States Constitution (including the Due Process Clauses), the Rules of the Court, and any other applicable law.
Judge Robert L. Wyatt, Gunderson v. AIG Claim Services, Inc., (May 29, 2008) No. 2004-002417 (14th Jud. D. Ct. La.):
Notices given to Settlement Class members…were reasonably calculated under all the circumstances and have been sufficient, as to form, content, and manner of dissemination…Such notices complied with all requirements of the federal and state constitutions, including the due process clause, and applicable articles of the Louisiana Code of Civil Procedure, and constituted the best notice practicable under the circumstances and constituted due and sufficient notice to all potential members of the Settlement Class.
Judge Mary Anne Mason, Palace v. DaimlerChrysler Corp., (May 29, 2008) No. 01-CH-13168 (Ill. Cir. Ct.):
The form, content, and method of dissemination of the notice given to the Illinois class and to the Illinois Settlement Class were adequate and reasonable, and constituted the best notice practicable under the circumstances. The notice, as given, provided valid, due, and sufficient
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notice of the proposed Settlement, the terms and conditions set forth in the Settlement Agreement, and these proceedings, to all Persons entitled to such notice, and said notice fully satisfied the requirements of due process and complied with 735 ILCS §§5/2-803 and 5/2-806.
Judge David De Alba, Ford Explorer Cases, (May 29, 2008) JCCP Nos. 4226 & 4270 (Cal. Super. Ct.):
[T]he Court is satisfied that the notice plan, design, implementation, costs, reach, were all reasonable, and has no reservations about the notice to those in this state and those in other states as well, including Texas, Connecticut, and Illinois; that the plan that was approved—submitted and approved, comports with the fundamentals of due process as described in the case law that was offered by counsel.
Judge Kirk D. Johnson, Webb v. Liberty Mutual Ins. Co., (March 3, 2008) No. CV-2007-418-3 (Ark. Cir. Ct.):
The Court finds that there was minimal opposition to the settlement. After undertaking an extensive notice campaign to Class members of approximately 10,707 persons, mailed notice reached 92.5% of potential Class members.
Judge Carol Crafton Anthony, Johnson v. Progressive Casualty Ins., Co., (December 6, 2007) No. CV-2003-513 (Ark. Cir. Ct.):
Notice of the Settlement Class was constitutionally adequate, both in terms of its substance and the manner in which it was disseminated…Notice was direct mailed to all Class members whose current whereabouts could be identified by reasonable effort. Notice reached a large majority of the Class members. The Court finds that such notice constitutes the best notice practicable…The forms of Notice and Notice Plan satisfy all of the requirements of Arkansas law and due process.
Judge Kirk D. Johnson, Sweeten v. American Empire Insurance Co., (August 20, 2007) No. CV-2007-154-3 (Ark. Cir. Ct.):
The Court does find that all notices required by the Court to be given to class members was done within the time allowed and the manner best calculated to give notice and apprise all the interested parties of the litigation. It was done through individual notice, first class mail, through internet website and the toll-free telephone call center…The Court does find that these methods were the best possible methods to advise the class members of the pendency of the action and opportunity to present their objections and finds that these notices do comply with all the provisions of Rule 23 and the Arkansas and United States Constitutions.
Judge Robert Wyatt, Gunderson v. F.A. Richard & Associates, Inc., (July 19, 2007) No. 2004-2417-D (14th Jud. D. Ct. La.):
Okay. Let me sign this one. This is the final Order and Judgment regarding the fairness, reasonableness and adequacy. And I am satisfied in all respects regarding the presentation that’s been made to the Court this morning in the Class memberships, the representation, the notice, and all other aspects and I’m signing that Order at this time. Congratulations, gentlemen.
Judge Lewis A. Kaplan, In re Parmalat Securities Litig., (July 19, 2007) MDL No. 1653-LAK (S.D. N.Y.):
The Court finds that the distribution of the Notice, the publication of the Publication Notice, and the notice methodology…met all applicable requirements of the Federal Rules of Civil Procedure, the United States Constitution, (including the Due Process clause), the Private Securities Litigation Reform Act of 1995 (15 U.S.C. 78u-4, et seq.) (the “PSLRA”), the Rules of the Court, and any other applicable law.
Judge Joe Griffin, Beasley v. The Reliable Life Insurance Co., (March 29, 2007) No. CV-2005-58-1 (Ark. Cir. Ct.):
[T]he Court has, pursuant to the testimony regarding the notification requirements, that were specified and adopted by this Court, has been satisfied and that they meet the requirements of due process. They are fair, reasonable, and adequate. I think the method of notification certainly
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meets the requirements of due process…So the Court finds that the notification that was used for making the potential class members aware of this litigation and the method of filing their claims, if they chose to do so, all those are clear and concise and meet the plain language requirements and those are completely satisfied as far as this Court is concerned in this matter.
Judge Lewis A. Kaplan, In re Parmalat Securities Litig., (March 1, 2007) MDL No. 1653-LAK (S.D. N.Y.):
The court approves, as to form and content, the Notice and the Publication Notice, attached hereto as Exhibits 1 and 2, respectively, and finds that the mailing and distribution of the Notice and the publication of the Publication Notice in the manner and the form set forth in Paragraph 6 of this Order…meet the requirements of Rule 23 of the Federal Rules of Civil Procedure, the Securities Exchange Act of 1934, as emended by Section 21D(a)(7) of the Private Securities Litigation Reform Act of 1995, 15 U.S.C. § 78u-4(a)(7), and due process, and is the best notice practicable under the circumstances and shall constitute due and sufficient notice to all persons and entities entitled thereto.
Judge Anna J. Brown, Reynolds v. The Hartford Financial Services Group, Inc., (February 27, 2007) No. CV-01-1529-BR (D. Ore):
[T]he court finds that the Notice Program fairly, fully, accurately, and adequately advised members of the Settlement Class and each Settlement Subclass of all relevant and material information concerning the proposed settlement of this action, their rights under Rule 23 of the Federal Rules of Civil Procedure, and related matters, and afforded the Settlement Class with adequate time and an opportunity to file objections to the Settlement or request exclusion from the Settlement Class. The court finds that the Notice Program constituted the best notice practicable under the circumstances and fully satisfied the requirements of Rule 23 and due process.
Judge Kirk D. Johnson, Zarebski v. Hartford Insurance Company of the Midwest, (February 13, 2007) No. CV-2006-409-3 (Ark. Cir. Ct.):
Based on the Court’s review of the evidence admitted and argument of counsel, the Court finds and concludes that the Class Notice, as disseminated to members of the Settlement Class in accordance with provisions of the Preliminary Approval Order, was the best notice practicable under the circumstances to all members of the Settlement Class. Accordingly, the Class Notice and Claim Form as disseminated are finally approved as fair, reasonable, and adequate notice under the circumstances. The Court finds and concludes that due and adequate notice of the pendency of this Action, the Stipulation, and the Final Settlement Hearing has been provided to members of the Settlement Class, and the Court further finds and concludes that the notice campaign described in the Preliminary Approval Order and completed by the parties complied fully with the requirements of Arkansas Rule of Civil Procedure 23 and the requirements of due process under the Arkansas and United States Constitutions.
Judge Richard J. Holwell, In re Vivendi Universal, S.A. Securities Litig., 2007 WL 1490466, at *34 (S.D.N.Y.):
In response to defendants’ manageability concerns, plaintiffs have filed a comprehensive affidavit outlining the effectiveness of its proposed method of providing notice in foreign countries. According to this…the Court is satisfied that plaintiffs intend to provide individual notice to those class members whose names and addresses are ascertainable, and that plaintiffs’ proposed form of publication notice, while complex, will prove both manageable and the best means practicable of providing notice.
Judge Samuel Conti, Ciabattari v. Toyota Motor Sales, U.S.A., Inc., (November 17, 2006) No. C-05-04289-SC (N.D. Cal.):
After reviewing the evidence and arguments presented by the parties…the Court finds as follows…The class members were given the best notice practicable under the circumstances, and that such notice meets the requirements of the Due Process Clause of the U.S. Constitution, and all applicable statutes and rules of court.
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Judge Ivan L.R. Lemelle, In re High Sulfur Content Gasoline Prods. Liability Litig, (November 8, 2006) MDL No. 1632 (E.D. La.):
This Court approved a carefully-worded Notice Plan, which was developed with the assistance of a nationally-recognized notice expert, Hilsoft Notifications…The Notice Plan for this Class Settlement was consistent with the best practices developed for modern-style “plain English” class notices; the Court and Settling Parties invested substantial effort to ensure notice to persons displaced by the Hurricanes of 2005; and as this Court has already determined, the Notice Plan met the requirements of Rule 23 and constitutional due process.
Judge Catherine C. Blake, In re Royal Ahold Securities and “ERISA” Litig., (November 2, 2006) MDL-1539 (D. Md.):
The global aspect of the case raised additional practical and legal complexities, as did the parallel criminal proceedings in another district. The settlement obtained is among the largest cash settlements ever in a securities class action case and represents an estimated 40% recovery of possible provable damages. The notice process appears to have been very successful not only in reaching but also in eliciting claims from a substantial percentage of those eligible for recovery.
Judge Elaine E. Bucklo, Carnegie v. Household International, (August 28, 2006) No. 98 C 2178 (N.D. Ill.):
[T]he Notice was disseminated pursuant to a plan consisting of first class mail and publication developed by Plaintiff’s notice consultant, Hilsoft Notification[s]…who the Court recognized as experts in the design of notice plans in class actions. The Notice by first-class mail and publication was provided in an adequate and sufficient manner; constitutes the best notice practicable under the circumstances; and satisfies all requirements of Rule 23(e) and due process.
Judge Joe E. Griffin, Beasley v. Hartford Insurance Company of the Midwest, (June 13, 2006) No. CV-2005-58-1 (Ark. Cir. Ct.):
Based on the Court’s review of the evidence admitted and argument of counsel, the Court finds and concludes that the Individual Notice and the Publication Notice, as disseminated to members of the Settlement Class in accordance with provisions of the Preliminarily Approval Order, was the best notice practicable under the circumstances…and the requirements of due process under the Arkansas and United States Constitutions.
Judge Norma L. Shapiro, First State Orthopaedics et al. v. Concentra, Inc., et al., (May 1, 2006) No. 2:05-CV-04951-NS (E.D. Pa.):
The Court finds that dissemination of the Mailed Notice, Published Notice and Full Notice in the manner set forth here and in the Settlement Agreement meets the requirements of due process and Pennsylvania law. The Court further finds that the notice is reasonable, and constitutes due, adequate, and sufficient notice to all persons entitled to receive notice, is the best practicable notice; and is reasonably calculated, under the circumstances, to apprise members of the Settlement Class of the pendency of the Lawsuit and of their right to object or to exclude themselves from the proposed settlement.
Judge Thomas M. Hart, Froeber v. Liberty Mutual Fire Ins. Co., (April 19, 2006) No. 00C15234 (Ore. Cir. Ct.):
The court has found and now reaffirms that dissemination and publication of the Class Notice in accordance with the terms of the Third Amended Order constitutes the best notice practicable under the circumstances.
Judge Catherine C. Blake, In re Royal Ahold Securities and “ERISA” Litig., (January 6, 2006) MDL-1539 (D. Md.):
I think it’s remarkable, as I indicated briefly before, given the breadth and scope of the proposed Class, the global nature of the Class, frankly, that again, at least on a preliminary basis, and I will
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be getting a final report on this, that the Notice Plan that has been proposed seems very well, very well suited, both in terms of its plain language and in terms of its international reach, to do what I hope will be a very thorough and broad-ranging job of reaching as many of the shareholders, whether individual or institutional, as possibly can be done to participate in what I also preliminarily believe to be a fair, adequate and reasonable settlement.
Judge Catherine C. Blake, In re Royal Ahold Securities & “ERISA” Litig., 437 F.Supp.2d 467, 472 (D. Md. 2006):
The court hereby finds that the Notice and Notice Plan described herein and in the Order dated January 9, 2006 provided Class Members with the best notice practicable under the circumstances. The Notice provided due and adequate notice of these proceedings and the matters set forth herein, including the Settlement and Plan of Allocation, to all persons entitled to such notice, and the Notice fully satisfied the requirements of Rule 23 of the Federal Rules of Civil Procedure and the requirements of due process.
Judge Robert H. Wyatt, Jr., Gray v. New Hampshire Indemnity Co., Inc., (December 19, 2005) No. CV-2002-952-2-3 (Ark. Cir. Ct.):
Notice of the Settlement Class was constitutionally adequate, both in terms of its substance and the manner in which it was disseminated. The Notice contained the essential elements necessary to satisfy due process, including the Settlement Class definition, the identities of the Parties and of their counsel, a summary of the terms of the proposed settlement, Class Counsel’s intent to apply for fees, information regarding the manner in which objections could be submitted, and requests for exclusions could be filed. The Notice properly informed Class members of the formula for the distribution of benefits under the settlement…Notice was direct mailed to all Class members whose current whereabouts could be identified by reasonable effort. Notice was also effected by publication in many newspapers and magazines throughout the nation, reaching a large majority of the Class members multiple times. The Court finds that such notice constitutes the best notice practicable.
Judge Michael J. O’Malley, Defrates v. Hollywood Entm’t Corp., (June 24, 2005) No. 02 L 707 (Ill. Cir. Ct.):
[T]his Court hereby finds that the notice program described in the Preliminary Approval Order and completed by HEC complied fully with the requirements of due process, the Federal Rules of Civil Procedure and all other applicable laws.
Judge Wilford D. Carter, Thibodeaux v. Conoco Phillips Co., (May 26, 2005) No. 2003-481 F (14th J.D. Ct. La.):
Notice given to Class Members…were reasonably calculated under all the circumstances and have been sufficient, both as to the form and content…Such notices complied with all requirements of the federal and state constitutions, including the due process clause, and applicable articles of the Louisiana Code of Civil Procedure, and constituted the best notice practicable under the circumstances and constituted due process and sufficient notice to all potential members of the Class as Defined.
Judge Michael Canaday, Morrow v. Conoco Inc., (May 25, 2005) No. 2002-3860 G (14th J.D. Ct. La.):
The objections, if any, made to due process, constitutionality, procedures, and compliance with law, including, but not limited to, the adequacy of notice and the fairness of the proposed Settlement Agreement, lack merit and are hereby overruled.
Judge John R. Padova, Nichols v. SmithKline Beecham Corp., (April 22, 2005) No. 00-6222 (E.D. Pa.):
Pursuant to the Order dated October 18, 2004, End-Payor Plaintiffs employed Hilsoft Notifications to design and oversee Notice to the End-Payor Class. Hilsoft Notifications has extensive experience in class action notice situations relating to prescription drugs and cases in which unknown class members need to receive notice…After reviewing the individual mailed Notice, the
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publication Notices, the PSAs and the informational release, the Court concludes that the substance of the Notice provided to members of the End-Payor Class in this case was adequate to satisfy the concerns of due process and the Federal Rules.
Judge Douglas L. Combs, Morris v. Liberty Mutual Fire Ins. Co., (February 22, 2005) No. CJ-03-714 (D. Okla.):
I am very impressed that the notice was able to reach – be delivered to 97 ½ percent members of the class. That, to me, is admirable. And I’m also – at the time that this was initially entered, I was concerned about the ability of notice to be understood by a common, nonlawyer person, when we talk about legalese in a court setting. In this particular notice, not only the summary notice but even the long form of the notice were easily understandable, for somebody who could read the English language, to tell them whether or not they had the opportunity to file a claim.
Judge Joseph R. Goodwin, In re Serzone Products Liability Litig., 231 F.R.D. 221, 231 (S.D. W. Va. 2005):
The Notice Plan was drafted by Hilsoft Notifications, a Pennsylvania firm specializing in designing, developing, analyzing and implementing large-scale, unbiased legal notification plans. Hilsoft has disseminated class action notices in more than 150 cases, and it designed the model notices currently displayed on the Federal Judicial Center’s website as a template for others to follow…To enhance consumer exposure, Hilsoft studied the demographics and readership of publications among adults who used a prescription drug for depression in the last twelve months. Consequently, Hilsoft chose to utilize media particularly targeting women due to their greater incidence of depression and heavy usage of the medication.
Judge Richard G. Stearns, In re Lupron® Marketing and Sales Practice Litig., (November 24, 2004) MDL 1430 (D. Mass.):
After review of the proposed Notice Plan designed by Hilsoft Notifications…is hereby found to be the best practicable notice under the circumstances and, when completed, shall constitute due and sufficient notice of the Settlement and the Fairness Hearing to all persons and entities affected by and/or entitled to participate in the Settlement, in full compliance with the notice requirements of Rule 23 the Federal Rules of Civil Procedure and due process.
Judge Richard G. Stearns, In re Lupron Marketing and Sales Practice Litig., (November 23, 2004) MDL 1430 (D. Mass.):
I actually find the [notice] plan as proposed to be comprehensive and extremely sophisticated and very likely be as comprehensive as any plan of its kind could be in reaching those most directly affected.
Judge James S. Moody, Jr., Mantzouris v. Scarritt Motor Group Inc., (August 10, 2004) No. 8:03 CV- 0015-T-30 MSS (M.D. Fla.):
Due and adequate notice of the proceedings having been given and a full opportunity having been offered to the members of the Class to participate in the Settlement Hearing, or object to the certification of the Class and the Agreement, it is hereby determined that all members of the Class, except for Ms. Gwendolyn Thompson, who was the sole person opting out of the Settlement Agreement, are bound by this Order and Final Judgment entered herein.
Judge Robert E. Payne, Fisher v. Virginia Electric & Power Co., (July 1, 2004) No. 3:02CV431 (E.D. Va.):
The record here shows that the class members have been fully and fairly notified of the existence of the class action, of the issues in it, of the approaches taken by each side in it in such a way as to inform meaningfully those whose rights are affected and to thereby enable them to exercise their rights intelligently…The success rate in notifying the class is, I believe, at least in my experience, I share Ms. Kauffman’s experience, it is as great as I have ever seen in practicing or serving in this job…So I don’t believe we could have had any more effective notice.
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Judge John Kraetzer, Baiz v. Mountain View Cemetery, (April 14, 2004) No. 809869-2 (Cal. Super. Ct.):
The notice program was timely completed, complied with California Government Code section 6064, and provided the best practicable notice to all members of the Settlement Class under the circumstances. The Court finds that the notice program provided class members with adequate instructions and a variety of means to obtain information pertaining to their rights and obligations under the settlement so that a full opportunity has been afforded to class members and all other persons wishing to be heard…The Court has determined that the Notice given to potential members of the Settlement Class fully and accurately informed potential Members of the Settlement Class of all material elements of the proposed settlement and constituted valid, due, and sufficient notice to all potential members of the Settlement Class, and that it constituted the best practicable notice under the circumstances.
Hospitality Mgmt. Assoc., Inc. v. Shell Oil Co., 356 S.C. 644, 663, 591 S.E.2d 611, 621 (Sup. Ct. S.C. 2004):
Clearly, the Cox court designed and utilized various procedural safeguards to guarantee sufficient notice under the circumstances. Pursuant to a limited scope of review, we need go no further in deciding the Cox court's findings that notice met due process are entitled to deference.
1B
Judge Joseph R. Goodwin, In re Serzone Prods. Liability Litig., 2004 U.S. Dist. LEXIS 28297, at *10 (S.D. W. Va.):
The Court has considered the Notice Plan and proposed forms of Notice and Summary Notice submitted with the Memorandum for Preliminary Approval and finds that the forms and manner of notice proposed by Plaintiffs and approved herein meet the requirements of due process and Fed.R.Civ.P. 23(c) and (e), are the best notice practicable under the circumstances, constitute sufficient notice to all persons entitled to notice, and satisfy the Constitutional requirements of notice.
Judge James D. Arnold, Cotten v. Ferman Mgmt. Servs. Corp., (November 26, 2003) No. 02-08115 (Fla. Cir. Ct.):
Due and adequate notice of the proceedings having been given and a full opportunity having been offered to the member of the Class to participate in the Settlement Hearing, or object to the certification of the Class and the Agreement…
Judge Judith K. Fitzgerald, In re Pittsburgh Corning Corp., (November 26, 2003) No. 00-22876-JKF (Bankr. W.D. Pa.):
The procedures and form of notice for notifying the holders of Asbestos PI Trust Claims, as described in the Motion, adequately protect the interests of the holders of Asbestos PI Trust Claims in a manner consistent with the principles of due process, and satisfy the applicable requirements of the Bankruptcy Code and the Federal Rules of Bankruptcy Procedure.
Judge Carter Holly, Richison v. American Cemwood Corp., (November 18, 2003) No. 005532 (Cal. Super. Ct.):
As to the forms of Notice, the Court finds and concludes that they fully apprised the Class members of the pendency of the litigation, the terms of the Phase 2 Settlement, and Class members’ rights and options…Not a single Class member—out of an estimated 30,000—objected to the terms of the Phase 2 Settlement Agreement, notwithstanding a comprehensive national Notice campaign, via direct mail and publication Notice…The notice was reasonable and the best notice practicable under the circumstances, was due, adequate, and sufficient notice to all Class members, and complied fully with the laws of the State of California, the Code of Civil Procedure, due process, and California Rules of Court 1859 and 1860.
Judge Thomas A. Higgins, In re Columbia/HCA Healthcare Corp., (June 13, 2003) No. 3-98-MDL-1227 (M.D. Tenn.):
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Notice of the settlement has been given in an adequate and sufficient manner. The notice provided by mailing the settlement notice to certain class members and publishing notice in the manner described in the settlement was the best practicable notice, complying in all respects with the requirements of due process.
Judge Harold Baer, Jr., Thompson v. Metropolitan Life Ins. Co., 216 F.R.D. 55, 68 (S.D.N.Y. 2003):
In view of the extensive notice campaign waged by the defendant, the extremely small number of class members objecting or requesting exclusion from the settlement is a clear sign of strong support for the settlement…The notice provides, in language easily understandable to a lay person, the essential terms of the settlement, including the claims asserted…who would be covered by the settlement…[T]he notice campaign that defendant agreed to undertake was extensive…I am satisfied, having reviewed the contents of the notice package, and the extensive steps taken to disseminate notice of the settlement, that the class notice complies with the requirements of Rule 23 (c)(2) and 23(e). In summary, I have reviewed all of the objections, and none persuade me to conclude that the proposed settlement is unfair, inadequate or unreasonable.
Judge Edgar E. Bayley, Dimitrios v. CVS, Inc., (November 27, 2002) No. 99-6209; Walker v. Rite Aid Corp., No. 99-6210; and Myers v. Rite Aid Corp., No. 01-2771 (Pa. Ct. C.P.):
The Court specifically finds that: fair and adequate notice has been given to the class, which comports with due process of law.
Judge Dewey C. Whitenton, Ervin v. Movie Gallery, Inc., (November 22, 2002) No. 13007 (Tenn. Ch.):
The content of the class notice also satisfied all due process standards and state law requirements…The content of the notice was more than adequate to enable class members to make an informed and intelligent choice about remaining in the class or opting out of the class.
Judge James R. Williamson, Kline v. The Progressive Corp., (November 14, 2002) No. 01-L-6 (Ill. Cir. Ct.):
Notice to the Settlement Class was constitutionally adequate, both in terms of its substance and the manner in which it was disseminated. The notice contained the essential elements necessary to satisfy due process…
Judge Marina Corodemus, Talalai v. Cooper Tire & Rubber Co., (September 13, 2002) No. L-008830.00 (N.J. Super. Ct.):
Here, the comprehensive bilingual, English and Spanish, court-approved Notice Plan provided by the terms of the settlement meets due process requirements. The Notice Plan used a variety of methods to reach potential class members. For example, short form notices for print media were placed…throughout the United States and in major national consumer publications which include the most widely read publications among Cooper Tire owner demographic groups.
Judge Harold Baer, Jr., Thompson v. Metropolitan Life Ins. Co., (September 3, 2002) No. 00 Civ. 5071-HB (S.D. N.Y.):
The Court further finds that the Class Notice and Publication Notice provided in the Settlement Agreement are written in plain English and are readily understandable by Class Members. In sum, the Court finds that the proposed notice texts and methodology are reasonable, that they constitute due, adequate and sufficient notice to all persons entitled to be provided with notice, and that they meet the requirements of the Federal Rules of Civil Procedure (including Fed. R. Civ. P. 23(c)(2) and (e)), the United States Constitution (including the Due Process Clause), the Rules of the Court, and any other applicable law.
Judge Milton Gunn Shuffield, Scott v. Blockbuster Inc., (January 22, 2002) No. D 162-535 (Tex. Jud. Dist. Ct.) Ultimately withstood challenge to Court of Appeals of Texas. Peters v. Blockbuster 65 S.W.3d 295, 307 (Tex. App.-Beaumont, 2001):
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In order to maximize the efficiency of the notice, a professional concern, Hilsoft Notifications, was retained. This Court concludes that the notice campaign was the best practicable, reasonably calculated, under all the circumstances, to apprise interested parties of the settlement and afford them an opportunity to present their objections…The notice campaign was highly successful and effective, and it more than satisfied the due process and state law requirements for class notice.
Judge Marina Corodemus, Talalai v. Cooper Tire & Rubber Co., (October 30, 2001) No. MID-L-8839-00-MT (N.J. Super. Ct.):
The parties have crafted a notice program which satisfies due process requirements without reliance on an unreasonably burdensome direct notification process…The form of the notice is reasonably calculated to apprise class members of their rights. The notice program is specifically designed to reach a substantial percentage of the putative settlement class members.
Judge Marina Corodemus, Talalai v. Cooper Tire & Rubber Co., (October 29, 2001) No. L-8830-00-MT (N.J. Super. Ct.):
I saw the various bar graphs for the different publications and the different media dissemination, and I think that was actually the clearest bar graph I’ve ever seen in my life…it was very clear of the time periods that you were doing as to each publication and which media you were doing over what market time, so I think that was very clear.
Judge Stuart R. Pollak, Microsoft I-V Cases, (April 1, 2001) J.C.C.P. No. CJC-00-004106 (Cal. Super. Ct.):
[C]oncerning dissemination of class notice; and I have reviewed the materials that have been submitted on that subject and basically I’m satisfied. I think it’s amazing if you’re really getting 80 percent coverage. That’s very reassuring. And the papers that you submitted responded to a couple things that had been mentioned before and I am satisfied with all that.
Judge Stuart R. Pollak, Microsoft I-V Cases, (March 30, 2001) J.C.C.P. No. 4106 (Cal. Super. Ct.):
Plaintiffs and Defendant Microsoft Corporation have submitted a joint statement in support of their request that the Court approve the plan for dissemination of class action notice and proposed forms of notice, and amend the class definition. The Court finds that the forms of notice to Class members attached hereto as Exhibits A and B fairly and adequately inform the Class members of their rights concerning this litigation. The Court further finds that the methods for dissemination of notice are the fairest and best practicable under the circumstances, and comport with due process requirements.
LEGAL NOTICE CASES
Hilsoft Notifications has served as notice expert for planning, implementation and/or analysis in the following partial listing of cases:
Andrews v. MCI (900 Number Litig.) S.D. Ga., CV 191-175
Harper v. MCI (900 Number Litig.) S.D. Ga., CV 192-134
In re Bausch & Lomb Contact Lens Litig. N.D. Ala., 94-C-1144-WW
In re Ford Motor Co. Vehicle Paint Litig. E.D. La., MDL 1063
Castano v. Am. Tobacco E.D. La., CV 94-1044
Cox v. Shell Oil (Polybutylene Pipe Litig.) Tenn. Ch., 18,844
In re Amino Acid Lysine Antitrust Litig. N.D. Ill., MDL 1083
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In re Dow Corning Corp. (Breast Implant Bankruptcy) E.D. Mich., 95-20512-11-AJS
Kunhel v. CNA Ins. Companies N.J. Super. Ct., ATL-C-0184-94
In re Factor Concentrate Blood Prods. Litig. (Hemophiliac HIV)
N.D. Ill., MDL 986
In re Ford Ignition Switch Prods. Liability Litig. D. N.J., 96-CV-3125
Jordan v. A.A. Friedman (Non-Filing Ins. Litig.) M.D. Ga., 95-52-COL
Kalhammer v. First USA (Credit Card Litig.) Cal. Cir. Ct., C96-45632010-CAL
Navarro-Rice v. First USA (Credit Card Litig.) Ore. Cir. Ct., 9709-06901
Spitzfaden v. Dow Corning (Breast Implant Litig.) La. D. Ct., 92-2589
Robinson v. Marine Midland (Finance Charge Litig.) N.D. Ill., 95 C 5635
McCurdy v. Norwest Fin. Alabama Ala. Cir. Ct., CV-95-2601
Johnson v. Norwest Fin. Alabama Ala. Cir. Ct., CV-93-PT-962-S
In re Residential Doors Antitrust Litig. E.D. Pa., MDL 1039
Barnes v. Am. Tobacco Co. Inc. E.D. Pa., 96-5903
Small v. Lorillard Tobacco Co. Inc. N.Y. Super. Ct., 110949/96
Naef v. Masonite Corp (Hardboard Siding Litig.) Ala. Cir. Ct., CV-94-4033
In re Synthroid Mktg. Litig. N.D. Ill., MDL 1182
Chisolm v. Transouth Fin. 4th U.S. Cir. Ct., 97-1970
Raysick v. Quaker State Slick 50 Inc. D. Tex., 96-12610
Castillo v. Mike Tyson (Tyson v. Holyfield Bout) N.Y. Super. Ct., 114044/97
Avery v. State Farm Auto. Ins. (Non-OEM Auto Parts Litig.) Ill. Cir. Ct., 97-L-114
Walls v. The Am. Tobacco Co. Inc. N.D. Okla., 97-CV-218-H
Tempest v. Rainforest Café (Securities Litig.) D. Minn., 98-CV-608
Stewart v. Avon Prods. (Securities Litig.) E.D. Pa., 98-CV-4135
Goldenberg v. Marriott PLC Corp (Securities Litig.) D. Md., PJM 95-3461
Delay v. Hurd Millwork (Building Products Litig.) Wash. Super. Ct., 97-2-07371-0
Gutterman v. Am. Airlines (Frequent Flyer Litig.) Ill. Cir. Ct., 95CH982
Hoeffner v. The Estate of Alan Kenneth Vieira (Un-scattered Cremated Remains Litig.)
Cal. Super. Ct., 97-AS 02993
In re Graphite Electrodes Antitrust Litig. E.D. Pa., MDL 1244
In re Silicone Gel Breast Implant Prods. Liability Litig., Altrichter v. INAMED
N.D. Ala., MDL 926
St. John v. Am. Home Prods. Corp. (Fen/Phen Litig.) Wash. Super. Ct., 97-2-06368
Crane v. Hackett Assocs. (Securities Litig.) E.D. Pa., 98-5504
In re Holocaust Victims Assets Litig. (Swiss Banks Litig.) E.D. N.Y., CV-96-4849
McCall v. John Hancock (Settlement Death Benefits) N.M. Cir. Ct., CV-2000-2818
Williams v. Weyerhaeuser Co. (Hardboard Siding Litig.) Cal. Super. Ct., CV-995787
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Kapustin v. YBM Magnex Int’l Inc. (Securities Litig.) E.D. Pa., 98-CV-6599
Leff v. YBM Magnex Int’l Inc. (Securities Litig.) E.D. Pa., 95-CV-89
In re PRK/LASIK Consumer Litig. Cal. Super. Ct., CV-772894
Hill v. Galaxy Cablevision N.D. Miss., 1:98CV51-D-D
Scott v. Am. Tobacco Co. Inc. La. D. Ct., 96-8461
Jacobs v. Winthrop Fin. Assocs. (Securities Litig.) D. Mass., 99-CV-11363
Int’l Comm’n on Holocaust Era Ins. Claims – Worldwide Outreach Program
Former Secretary of State Lawrence Eagleburger Commission
Bownes v. First USA Bank (Credit Card Litig.) Ala. Cir. Ct., CV-99-2479-PR
Whetman v. IKON (ERISA Litig.) E.D. Pa., 00-87
Mangone v. First USA Bank (Credit Card Litig.) Ill. Cir. Ct., 99AR672a
In re Babcock and Wilcox Co. (Asbestos Related Bankruptcy) E.D. La., 00-10992
Barbanti v. W.R. Grace and Co. (Zonolite / Asbestos Litig.) Wash. Super. Ct., 00201756-6
Brown v. Am. Tobacco Cal. Super. Ct., J.C.C.P. 4042, 711400
Wilson v. Servier Canada Inc. (Canadian Fen/Phen Litig.) Ont. Super. Ct., 98-CV-158832
In re Texaco Inc. (Bankruptcy) S.D. N.Y. 87 B 20142, 87 B 20143, 87 B 20144.
Olinde v. Texaco (Bankruptcy, Oil Lease Litig.) M.D. La., 96-390
Gustafson v. Bridgestone/Firestone, Inc. (Recall Related Litig.) S.D. Ill., 00-612-DRH
In re Bridgestone/Firestone Tires Prods. Liability Litig. S.D. Ind., MDL 1373
Gaynoe v. First Union Corp. (Credit Card Litig.) N.C. Super. Ct., 97-CVS-16536
Carson v. Daimler Chrysler Corp. (Fuel O-Rings Litig.) W.D. Tenn., 99-2896 TU A
Providian Credit Card Cases Cal. Super. Ct., J.C.C.P. 4085
Fields v. Great Spring Waters of Am., Inc. (Bottled Water Litig.) Cal. Super. Ct., 302774
Sanders v. Great Spring Waters of Am., Inc. (Bottled Water Litig.)
Cal. Super. Ct., 303549
Sims v. Allstate Ins. Co. (Diminished Auto Value Litig.) Ill. Cir. Ct., 99-L-393A
Peterson v. State Farm Mutual Auto. Ins. Co. (Diminished Auto Value Litig.)
Ill. Cir. Ct., 99-L-394A
Microsoft I-V Cases (Antitrust Litig. Mirroring Justice Dept.) Cal. Super. Ct., J.C.C.P. 4106
Westman v. Rogers Family Funeral Home, Inc. (Remains Handling Litig.)
Cal. Super. Ct., C-98-03165
Rogers v. Clark Equipment Co. Ill. Cir. Ct., 97-L-20
Garrett v. Hurley State Bank (Credit Card Litig.) Miss. Cir. Ct., 99-0337
Ragoonanan v. Imperial Tobacco Ltd. (Firesafe Cigarette Litig.)
Ont. Super. Ct., 00-CV-183165 CP
Dietschi v. Am. Home Prods. Corp. (PPA Litig.) W.D. Wash., C01-0306L
Dimitrios v. CVS, Inc. (PA Act 6 Litig.) Pa. C.P., 99-6209
Jones v. Hewlett-Packard Co. (Inkjet Cartridge Litig.) Cal. Super. Ct., 302887
In re Tobacco Cases II (California Tobacco Litig.) Cal. Super. Ct., J.C.C.P. 4042
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Scott v. Blockbuster, Inc (Extended Viewing Fees Litig.) 136th Tex. Jud. Dist., D 162-535
Anesthesia Care Assocs. v. Blue Cross of Cal. Cal. Super. Ct., 986677
Ting v. AT&T (Mandatory Arbitration Litig.) N.D. Cal., C-01-2969-BZ
In re W.R. Grace & Co. (Asbestos Related Bankruptcy) Bankr. D. Del., 01-01139-JJF
Talalai v. Cooper Tire & Rubber Co. (Tire Layer Adhesion Litig.)
N.J. Super. Ct.,, MID-L-8839-00 MT
Kent v. Daimler Chrysler Corp. (Jeep Grand Cherokee Park-to-Reverse Litig.)
N.D. Cal., C01-3293-JCS
Int’l Org. of Migration – German Forced Labour Compensation Programme
Geneva, Switzerland
Madsen v. Prudential Federal Savings & Loan (Homeowner’s Loan Account Litig.)
3rd Jud. Dist. Ct. Utah, C79-8404
Bryant v. Wyndham Int’l., Inc. (Energy Surcharge Litig.) Cal. Super. Ct., GIC 765441, GIC 777547
In re USG Corp. (Asbestos Related Bankruptcy) Bankr. D. Del., 01-02094-RJN
Thompson v. Metropolitan Life Ins. Co. (Race Related Sales Practices Litig.)
S.D. N.Y., 00-CIV-5071 HB
Ervin v. Movie Gallery Inc. (Extended Viewing Fees) Tenn. Ch., CV-13007
Peters v. First Union Direct Bank (Credit Card Litig.) M.D. Fla., 8:01-CV-958-T-26 TBM
National Socialist Era Compensation Fund Republic of Austria
In re Baycol Litig. D. Minn., MDL 1431
Claims Conference–Jewish Slave Labour Outreach Program German Government Initiative
Wells v. Chevy Chase Bank (Credit Card Litig.) Md. Cir. Ct., C-99-000202
Walker v. Rite Aid of PA, Inc. (PA Act 6 Litig.) C.P. Pa., 99-6210
Myers v. Rite Aid of PA, Inc. (PA Act 6 Litig.) C.P. Pa., 01-2771
In re PA Diet Drugs Litig. C.P. Pa., 9709-3162
Harp v. Qwest Communications (Mandatory Arbitration Litig.) Ore. Circ. Ct., 0110-10986
Tuck v. Whirlpool Corp. & Sears, Roebuck & Co. (Microwave Recall Litig.)
Ind. Cir. Ct., 49C01-0111-CP-002701
Allison v. AT&T Corp. (Mandatory Arbitration Litig.) 1st Jud. D.C. N.M., D-0101-CV-20020041
Kline v. The Progressive Corp. Ill. Cir. Ct., 01-L-6
Baker v. Jewel Food Stores, Inc. & Dominick’s Finer Foods, Inc. (Milk Price Fixing)
Ill. Cir. Ct., 00-L-9664
In re Columbia/HCA Healthcare Corp. (Billing Practices Litig.) M.D. Tenn., MDL 1227
Foultz v. Erie Ins. Exchange (Auto Parts Litig.) C.P. Pa., 000203053
Soders v. General Motors Corp. (Marketing Initiative Litigation)
C.P. Pa., CI-00-04255
Nature Guard Cement Roofing Shingles Cases Cal. Super. Ct., J.C.C.P. 4215
Curtis v. Hollywood Entm’t Corp. (Additional Rental Charges) Wash. Super. Ct., 01-2-36007-8 SEA
Defrates v. Hollywood Entm’t Corp. Ill. Cir. Ct., 02L707
Pease v. Jasper Wyman & Son, Merrill Blueberry Farms Inc., Allen’s Blueberry Freezer Inc. & Cherryfield Foods Inc.
Me. Super. Ct., CV-00-015
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West v. G&H Seed Co. (Crawfish Farmers Litig.) 27th Jud. D. Ct. La., 99-C-4984-A
Linn v. Roto-Rooter Inc. (Miscellaneous Supplies Charge) C.P. Ohio, CV-467403
McManus v. Fleetwood Enter., Inc. (RV Brake Litigation) D. Ct. Tex., SA-99-CA-464-FB
Baiz v. Mountain View Cemetery (Burial Practices) Cal. Super. Ct., 809869-2
Stetser v. TAP Pharm. Prods, Inc. & Abbott Laboratories (Lupron Price Litigation)
N.C. Super. Ct., 01-CVS-5268
Richison v. Am. Cemwood Corp. (Roofing Durability Settlement)
Cal. Super. Ct., 005532
Cotten v. Ferman Mgmt. Servs. Corp. 13th Jud. Cir. Fla., 02-08115
In re Pittsburgh Corning Corp. (Asbestos Related Bankruptcy) Bankr. W.D. Pa., 00-22876-JKF
Mostajo v. Coast Nat’l Ins. Co. Cal. Super. Ct., 00 CC 15165
Friedman v. Microsoft Corp. (Antitrust Litigation) Ariz. Super. Ct., CV 2000-000722
Multinational Outreach - East Germany Property Claims Claims Conference
Davis v. Am. Home Prods. Corp. (Norplant Contraceptive Litigation)
D. La., 94-11684
Walker v. Tap Pharmaceutical Prods., Inc. (Lupron Price Litigation)
N.J. Super. Ct., CV CPM-L-682-01
Munsey v. Cox Communications (Late Fee Litigation) D. La., Sec. 9, 97 19571
Gordon v. Microsoft Corp. (Antitrust Litigation) 4th Jud. D. Ct. Minn., 00-5994
Clark v. Tap Pharmaceutical Prods., Inc. 5th Dist. App. Ct. Ill., 5-02-0316
Fisher v. Virginia Electric & Power Co. E.D. Va., 3:02-CV-431
Mantzouris v. Scarritt Motor Group, Inc. M.D. Fla., 8:03-CV-0015-T-30-MSS
Johnson v. Ethicon, Inc. (Product Liability Litigation) W. Va. Cir. Ct., 01-C-1530, 1531, 1533, 01-C-2491 to 2500
Schlink v. Edina Realty Title 4th Jud. D. Ct. Minn., 02-018380
Tawney v. Columbia Natural Res. (Oil & Gas Lease Litigation) W. Va. Cir. Ct., 03-C-10E
White v. Washington Mutual, Inc. (Pre-Payment Penalty Litigation)
4th Jud. D. Ct. Minn., CT 03-1282
Acacia Media Techs. Corp. v. Cybernet Ventures Inc, (Patent Infringement Litigation)
C.D. Cal., SACV03-1803 GLT (Anx)
Bardessono v. Ford Motor Co. (15 Passenger Vans) Wash. Super. Ct., 32494
Gardner v. Stimson Lumber Co. (Forestex Siding Litigation) Wash. Super. Ct., 00-2-17633-3SEA
Poor v. Sprint Corp. (Fiber Optic Cable Litigation) Ill. Cir. Ct., 99-L-421
Thibodeau v. Comcast Corp. E.D. Pa., 04-CV-1777
Cazenave v. Sheriff Charles C. Foti (Strip Search Litigation) E.D. La., 00-CV-1246
National Assoc. of Police Orgs., Inc. v. Second Chance Body Armor, Inc. (Bullet Proof Vest Litigation)
Mich. Cir. Ct., 04-8018-NP
Nichols v. SmithKline Beecham Corp. (Paxil) E.D. Pa., 00-6222
Yacout v. Federal Pacific Electric Co. (Circuit Breaker) N.J. Super. Ct., MID-L-2904-97
Lewis v. Bayer AG (Baycol) 1st Jud. Dist. Ct. Pa., 002353
In re Educ. Testing Serv. PLT 7-12 Test Scoring Litig. E.D. La., MDL-1643
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Stefanyshyn v. Consol. Indus. Corp. (Heat Exchanger) Ind. Super. Ct., 79 D 01-9712-CT-59
Barnett v. Wal-Mart Stores, Inc. Wash. Super. Ct., 01-2-24553-8 SEA
In re Serzone Prods. Liability Litig. S.D. W. Va., MDL 1477
Ford Explorer Cases Cal. Super. Ct., J.C.C.P. 4226 & 4270
In re Solutia Inc. (Bankruptcy) S.D. N.Y., 03-17949-PCB
In re Lupron Marketing & Sales Practices Litig. D. Mass., MDL 1430
Morris v. Liberty Mutual Fire Ins. Co. D. Okla., CJ-03-714
Bowling, et al. v. Pfizer Inc. (Bjork-Shiley Convexo-Concave Heart Valve)
S.D. Ohio, C-1-91-256
Thibodeaux v. Conoco Philips Co. D. La., 2003-481
Morrow v. Conoco Inc. D. La., 2002-3860
Tobacco Farmer Transition Program U.S. Dept. of Agric.
Perry v. Mastercard Int’l Inc. Ariz. Super. Ct., CV2003-007154
Brown v. Credit Suisse First Boston Corp. C.D. La., 02-13738
In re Unum Provident Corp. D. Tenn., 1:03-CV-1000
In re Ephedra Prods. Liability Litig. D. N.Y., MDL-1598
Chesnut v. Progressive Casualty Ins. Co. Ohio C.P., 460971
Froeber v. Liberty Mutual Fire Ins. Co. Ore. Cir. Ct., 00C15234
Luikart v. Wyeth Am. Home Prods. (Hormone Replacement) W. Va. Cir. Ct., 04-C-127
Salkin v. MasterCard Int’l Inc. (Pennsylvania) Pa. C.P., 2648
Rolnik v. AT&T Wireless Servs., Inc. N.J. Super. Ct., L-180-04
Singleton v. Hornell Brewing Co. Inc. (Arizona Ice Tea) Cal. Super. Ct., BC 288 754
Becherer v. Qwest Commc’ns Int’l, Inc. Ill. Cir. Ct., 02-L140
Clearview Imaging v. Progressive Consumers Ins. Co. Fla. Cir. Ct., 03-4174
Mehl v. Canadian Pacific Railway, Ltd D. N.D., A4-02-009
Murray v. IndyMac Bank. F.S.B N.D. Ill., 04 C 7669
Gray v. New Hampshire Indemnity Co., Inc. Ark. Cir. Ct., CV-2002-952-2-3
George v. Ford Motor Co. M.D. Tenn., 3:04-0783
Allen v. Monsanto Co. W. Va. Cir. Ct., 041465
Carter v. Monsanto Co. W. Va. Cir. Ct., 00-C-300
Carnegie v. Household Int’l, Inc. N. D. Ill., 98-C-2178
Daniel v. AON Corp. Ill. Cir. Ct., 99 CH 11893
In re Royal Ahold Securities and “ERISA” Litig. D. Md., MDL 1539
In re Pharmaceutical Industry Average Wholesale Price Litig. D. Mass., MDL 1456
Meckstroth v. Toyota Motor Sales, U.S.A., Inc. 24th Jud. D. Ct. La., 583-318
Walton v. Ford Motor Co. Cal. Super. Ct., SCVSS 126737
Hill v. State Farm Mutual Auto Ins. Co. Cal. Super. Ct., BC 194491
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First State Orthopaedics et al. v. Concentra, Inc., et al. E.D. Pa. 2:05-CV-04951-AB
Sauro v. Murphy Oil USA, Inc. E.D. La., 05-4427
In re High Sulfur Content Gasoline Prods. Liability Litig. E.D. La., MDL 1632
Homeless Shelter Compensation Program City of New York
Rosenberg v. Academy Collection Service, Inc. E.D. Pa., 04-CV-5585
Chapman v. Butler & Hosch, P.A. 2nd Jud. Cir. Fla., 2000-2879
In re Vivendi Universal, S.A. Securities Litig. S.D. N.Y., 02-CIV-5571 RJH
Desportes v. American General Assurance Co. Ga. Super. Ct., SU-04-CV-3637
In re: Propulsid Products Liability Litig. E.D. La., MDL 1355
Baxter v. The Attorney General of Canada (Residential School Attendees)
Ont. Super. Ct., 00-CV-192059 CPA
McNall v. Mastercard Int’l, Inc. (Currency Conversion Fees) 13th Tenn. Jud. Dist. Ct.
Lee v. Allstate Ill. Cir. Ct., 03 LK 127
Turner v. Murphy Oil USA, Inc. E.D. La., 2:05-CV-04206-EEF-JCW
Carter v. North Central Life Ins. Co. Ga. Super. Ct., SU-2006-CV-3764-6
Harper v. Equifax E.D. Pa., 2:04-CV-03584-TON
Beasley v. Hartford Insurance Co. of the Midwest Ark. Cir. Ct., CV-2005-58-1
Springer v. Biomedical Tissue Services, LTD (Human Tissue Litig.)
Ind. Cir. Ct., 1:06-CV-00332-SEB-VSS
Spence v. Microsoft Corp. (Antitrust Litig.) Wis. Cir. Ct., 00-CV-003042
Pennington v. The Coca Cola Co. (Diet Coke) Mo. Cir. Ct., 04-CV-208580
Sunderman v. Regeneration Technologies, Inc. (Human Tissue Litig.)
S.D. Ohio, 1:06-CV-075-MHW
Splater v. Thermal Ease Hydronic Systems, Inc. Wash. Super. Ct., 03-2-33553-3-SEA
Peyroux v. The United States of America (New Orleans Levee Breech)
E.D. La., 06-2317
Chambers v. DaimlerChrysler Corp. (Neon Head Gaskets) N.C. Super. Ct., 01:CVS-1555
Ciabattari v. Toyota Motor Sales, U.S.A., Inc. (Sienna Run Flat Tires)
N.D. Cal., C-05-04289-BZ
In re Bridgestone Securities Litig. M.D. Tenn., 3:01-CV-0017
In re Mutual Funds Investment Litig. (Market Timing) D. Md., MDL 1586
Accounting Outsourcing v. Verizon Wireless M.D. La., 03-CV-161
Hensley v. Computer Sciences Corp. Ark. Cir. Ct., CV-2005-59-3
Peek v. Microsoft Corporation Ark. Cir. Ct., CV-2006-2612
Reynolds v. The Hartford Financial Services Group, Inc. D. Ore., CV-01-1529 BR
Schwab v. Philip Morris USA, Inc. E.D. N.Y., CV-04-1945
Zarebski v. Hartford Insurance Co. of the Midwest Ark. Cir. Ct., CV-2006-409-3
In re Parmalat Securities Litig. S.D. N.Y., MDL 1653 (LAK)
Beasley v. The Reliable Life Insurance Co. Ark. Cir. Ct., CV-2005-58-1
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Sweeten v. American Empire Insurance Company Ark. Cir. Ct., 2007-154-3
Govt. Employees Hospital Assoc. v. Serono Int., S.A. D. Mass., 06-CA-10613-PBS
Gunderson v. Focus Healthcare Management, Inc. 14th Jud. D. Ct. La., 2004-2417-D
Gunderson v. F.A. Richard & Associates, Inc., et al. 14th Jud. D. Ct. La., 2004-2417-D
Perez v. Manor Care of Carrollwood 13th Jud. Cir. Fla., 06-00574-E
Pope v. Manor Care of Carrollwood 13th Jud. Cir. Fla., 06-01451-B
West v. Carfax, Inc. Ohio C.P., 04-CV-1898 (ADL)
Hunsucker v. American Standard Ins. Co. of Wisconsin Ark. Cir. Ct., CV-2007-155-3
In re Conagra Peanut Butter Products Liability Litig. N.D. Ga., MDL 1845 (TWT)
The People of the State of CA v. Universal Life Resources (Cal DOI v. CIGNA)
Cal. Super. Ct., GIC838913
Burgess v. Farmers Insurance Co., Inc. D. Okla., CJ-2001-292
Grays Harbor v. Carrier Corporation W.D. Wash., 05-05437-RBL
Perrine v. E.I. Du Pont De Nemours & Co. W. Va. Cir. Ct., 04-C-296-2
In re Alstom SA Securities Litig. S.D. N.Y., 03-CV-6595 VM
Brookshire Bros. v. Chiquita (Antitrust) S.D. Fla., 05-CIV-21962
Hoorman v. SmithKline Beecham Ill. Cir. Ct., 04-L-715
Santos v. Government of Guam (Earned Income Tax Credit) D. Guam, 04-00049
Johnson v. Progressive Ark. Cir. Ct., CV-2003-513
Bond v. American Family Insurance Co. D. Ariz., CV06-01249-PXH-DGC
In re SCOR Holding (Switzerland) AG Litigation (Securities) S.D. N.Y., 04 Civ. 7897
Shoukry v. Fisher-Price, Inc. (Toy Safety) S.D. N.Y., 07-CV-7182
In re: Guidant Corp. Plantable Defibrillators Prod’s Liab. Litig. D. Minn., MDL 05-1708 (DWF/AJB)
Clark v. Pfizer, Inc (Neurontin) C.P. Pa., 9709-3162
Angel v. U.S. Tire Recovery (tire fire) W. Va. Cir. Ct., 06-C-855
In re TJX Companies Retail Security Breach Litig. D. Mass., MDL 1838
Webb v. Liberty Mutual Insurance Co. Ark. Cir. Ct., CV-2007-418-3
Shaffer v. Continental Casualty Co. (long term care ins.) C.D. Cal., SACV06-2235-PSG
Palace v. DaimlerChrysler (defective Neon head gaskets) Ill. Cir. Ct., 01-CH-13168
Beringer v. Certegy Check Services, Inc. (stolen financial data) M.D. Fla., 8:07-cv-1657-T-23TGW
Lockwood v. Certegy Check Services, Inc. M.D. Fla., 8:07-cv-1434-T-23TGW
Sherrill v. Progressive Northwestern Ins. Co. 18th D. Ct. Mont., DV-03-220
Gunderson v. F.A. Richard & Assocs., Inc. (AIG) 14th Jud. D. Ct. La., 2004-2417-D
Jones v. Dominion Resources Services, Inc. S.D. W. Va., 2:06-cv-00671
Gunderson v. F.A. Richard & Assocs., Inc. (Wal-Mart) 14th Jud. D. Ct. La., 2004-2417-D
In re Trans Union Corp. Privacy Litig. N.D. Ill., MDL 1350
Gudo v. The Administrator of the Tulane Ed. Fund La. D. Ct., 2007-C-1959
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Guidry v. American Public Life Insurance Co. 14th Jud. D. Ct. La., 2008-3465
McGee v. Continental Tire North America D. N.J., 2:06-CV-06234 (GEB)
Sims v. Rosedale Cemetery Co. W. Va. Cir. Ct., 03-C-506
Gunderson v. F.A. Richard & Assocs., Inc. (Amerisafe) 14th Jud. D. Ct. La., 2004-002417
In Re Katrina Canal Breaches Consolidated Litig. E.D. La., 05-4182
In re Department of Veterans Affairs (VA) Data Theft Litigation D. D.C., MDL 1796
Dolen v. ABN AMRO Bank N.V. (callable CD’s) Ill. Cir. Ct., 01-L-454 and 01-L-493
Pavlov v. CNA (long term care insurance) N.D. Ohio, 5:07cv2580
Steele v. Pergo( flooring products) D. Ore., 07-CV-01493-BR
Opelousas Trust Authority v. Summit Consulting 27th Jud. D. Ct. La., 07-C-3737-B
Little v. Kia Motors America, Inc. (braking systems) N.J. Super. Ct., UNN-L-0800-01
Boone v. City of Philadelphia (prisoner strip search) E.D. Pa., 05-CV-1851
In Re Countrywide Customer Data Breach Litig. W. D. Ky., 3:08-md-01998-TBR, MDL 1998
Miller v. Basic Research (weight-loss supplement) D. Utah, 2:07-cv-00871-TS
Gunderson v. F.A. Richard & Assocs., Inc. (Cambridge) 14th Jud. D. Ct. La., 2004-002417
Weiner v. Snapple Beverage Corporation S.D. N.Y., No. 07-CV-08742
Holk v. Snapple Beverage Corporation D. N.J., No 3:07-CV-03018-MJC-JJH
Coyle v. Hornell Brewing Co. (Arizona Iced Tea) D. N.J., No. 08-CV-2797-JBS-JS
In Re: Heartland Data Security Breach Litigation S.D. Tex., No. 4:09-MD-2046, MDL 2046
Satterfield v. Simon & Schuster, Inc. (text messaging) N.D. Cal., No. 06-CV-2893 CW
Schulte v. Fifth Third Bank (overdraft fees) N.D. Ill., No. 09-CV-06655
Trombley v. National City Bank (overdraft fees) D. D.C., No. 1:10-CV-00232
Vereen v. Lowe’s Home Centers (defective drywall) Ga. Super. Ct., SU10-CV-2267B
Mathena v. Webster Bank, N.A. (overdraft fees) D. Conn,.No. 3:10-cv-01448
Delandro v. County of Allegheny (prisoner strip search) W.D. Pa., No. 2:06-cv-00927
Gunderson v. F.A. Richard & Assocs., Inc. (First Health) 14th Jud. D. Ct. La., 2004-002417
Williams v. Hammerman & Gainer, Inc. (Hammerman) 27th Jud. D. Ct. La., No. 11-C-3187-B
Williams v. Hammerman & Gainer, Inc. (Risk Management) 27th Jud. D. Ct. La., No. 11-C-3187-B
Williams v. Hammerman & Gainer, Inc. (SIF Consultants) 27th Jud. D. Ct. La., No. 11-C-3187-B
Gwiazdowski v. County of Chester (prisoner strip search) E.D. Pa., No. 2:08cv4463
Williams v. S.I.F. Consultants (CorVel Corporation) 27th Jud. D. Ct. La., No. 09-C-5244-C
In Re: Checking Account Overdraft Litigation (IBERIABANK) S.D. Fla., MDL No. 2036
LaCour v. Whitney Bank (overdraft fees) M.D. Fla., 8:11cv1896
Lawson. v. BancorpSouth (overdraft fees) W.D. Ark., 1:12cv1016
In Re: Checking Account Overdraft Litigation (Bank of Oklahoma)
S.D. Fla., MDL No. 2036
Hilsoft-cv-115
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Exhibit 2 to Declaration of Cameron Azari: Economic & Property Damages Notice Plan
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©2012 Hilsoft Notifications
Deepwater Horizon Oil Spill Litigation Economic and Property Damages
Settlement Notice Plan
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Table of Contents
Page 1. Introduction 4
2. Overview/Summary 6
3. Notice Schedule Flow Chart 12
4. Target Audience 13
5. Individual Notice 15
6. Media Selection 18
7. Plan Delivery Summary 20
8. Net Reach 21
9. Average Frequency of Exposure 23
10. Geographic Coverage 24
11. Nationwide Publication Plan 25
12. Nationwide Publication Details 26
13. Nationwide Publication Coverage 29
14. Nationwide Publication Circulation 30
15. Publication Secondary Reader Data 31
16. Nationwide Publication Audience Data 32
17. Nationwide Publication Gross Impressions 33
18. Trade, Business and Specialty Publications 34
19. Local Newspapers 36
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20. African-American and Vietnamese and Spanish Language Publications 38
21. Local Television 40
22. TV Dayparts/Programming 41
23. TV Rating Points (GRPs) 42
24. TV Gross Impressions 43
25. Local Radio Programming 44
26. Internet Banner Notices 45
27. Placing Notices to Be Highly Visible 46
28. Informational Release 47
29. TV Public Service Announcements 48
30. Case Website 49
31. Sponsored Search Listings 50
32. Notice Design Strategy 51
33. Draft Forms of Notice 53
Attachment 1 - Drafts of Notice
Attachment 2 – Parade, USA Weekend and American Profile Newspaper List
Attachment 3 – Local Newspapers
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1. Introduction The “Notice Plan” (or “Plan”) that follows details the dissemination effort that will be undertaken to provide comprehensive notice to Class Members in connection with the proposed Economic and Property Damages Class Action Settlement in In re: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf of Mexico, on April 20, 2010, MDL No. 2179. The Plan utilizes extensive and appropriate prior class action notice experience. Two separate class action settlements within the MDL No. 2179 litigation—an Economic and Property Damages Settlement and a Medical Benefits Settlement—have been proposed related to the Deepwater Horizon Incident. Each settlement contemplates contemporaneous notice. To prevent confusion over the two class action settlements, the proposed Economic and Property Damages Notice Plan effort highlights that the Court is considering two separate settlements. Print publication notice consists of a single advertising unit that includes one summary notice that addresses the Economic and Property Damages Settlement, and a separate summary notice that addresses the Medical Benefits Settlement. Broadcast and Internet banner efforts provide the message that there is one settlement addressing economic and property damages claims, and a separate settlement addressing medical claims. Finally, one individual notice for the Economic and Property Damages Settlement will be mailed to all known, likely Class Members of the Economic and Property Damages Settlement Class, and a separate individual notice for the Medical Benefits Settlement will be mailed to known individuals who are likely Class Members of the Medical Benefits Class. To further mitigate potential confusion, the Economic and Property Damages Settlement and the Medical Benefits Settlement notices will include a common website address and toll-free number. The content of the website and toll-free numbers will make clear to visitors/callers that two separate settlements have been reached, and provide appropriate information about each respective settlement.1 Hilsoft Notifications has designed and will implement this Notice Plan if and when the Economic and Property Damages Settlement receives Preliminary Approval by the Court. At the appropriate time Hilsoft may also develop and implement subsequent notice efforts as agreed to by the parties and/or directed by the Court, 1 If either settlement is not approved or the two Settlements are approved on substantially different schedules, the Notice content will be adjusted accordingly.
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including a reminder notice effort in advance of the claim deadline. Hilsoft Notifications’ principals have been recognized as class action notice experts by judges, and have specific experience designing and implementing large-scale class action notice plans. Principals Cameron Azari, Esq., Director of Legal Noticing, and Lauran Schultz, Executive Director, have designed the Plan and Notices, and will oversee implementation to successful completion. With experience in more than 200 cases, notices prepared by Hilsoft Notifications have appeared in 53 languages with distribution in almost every country, territory and dependency in the world. Judges, including in published decisions, have recognized and approved notice plans developed by Hilsoft Notifications, which have always withstood collateral reviews by other courts and appellate challenges, including to the U.S. Supreme Court. The proposed draft notice documents (the “Notice” or “Notices”) follow the principles in the Federal Judicial Center’s (“FJC”) illustrative model notices that were written and designed to embody the satisfaction of the plain language requirements of Federal Rule of Civil Procedure 23(c)(2). To assist judges and attorneys, in federal as well as state courts, the FJC has posted the notices at www.fjc.gov.
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2. Overview/Summary • Objective. To notify the greatest practicable number of Economic and Property
Damages Settlement Class Members (hereinafter “Settlement Class Members” or “Class Members”) and provide them with opportunities to be exposed to the Notice, to see, review, understand, and be reminded about it, and to respond appropriately if they choose.
• Imperatives. Key factors guide the dissemination methods needed to achieve a
reasonable and effective notice effort:
1. The proposed Economic and Property Damages Settlement has specific geographic boundaries. The majority of Class Members are located within a limited geographic area and the primary thrust of the Notice Plan must be focused there.
2. Even with the defined geographic scope of the Settlement, some Class Members could be located throughout the U.S., including large cities and rural areas.
3. Mailing addresses, compiled from various lists, are available for a portion of the Class.
4. High quality notice methods are needed to convey the importance of information affecting Settlement Class Members’ rights.
• Target Audience. The E&PD Settlement Agreement defines the “Class” as:
A. Individuals. Unless otherwise specified, all Natural Persons residing in the United States who, at any time between April 20, 2010 and April 16, 2012, lived in, worked in, were offered and accepted work in, owned or leased real or personal property located within, or owned or leased or worked on a vessel harbored or HOME PORTED in the States of Louisiana, Mississippi, or Alabama, the counties of Chambers, Galveston, Jefferson and Orange in the State of Texas, or the counties of Bay, Calhoun, Charlotte, Citrus, Collier, Dixie, Escambia, Franklin, Gadsden, Gulf, Hernando, Hillsborough, Holmes, Jackson, Jefferson, Lee, Leon, Levy, Liberty, Manatee, Monroe, Okaloosa, Pasco, Pinellas, Santa Rosa, Sarasota, Taylor, Wakulla, Walton and Washington in the State of Florida, including all adjacent Gulf waters, bays,
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estuaries, straits, and other tidal or brackish waters within the States of Louisiana, Mississippi, Alabama, or those described counties of Texas or Florida (the “GULF COAST AREAS”) (Exhibit 22), or the U.S. waters of the Gulf of Mexico and all adjacent bays, estuaries, straits, and other tidal or brackish waters within the Gulf Coast Areas, as specifically shown and described in Exhibit 23 (“SPECIFIED GULF WATERS”), or worked on a vessel in Specified Gulf Waters after April 20, 2009. With respect to SEAFOOD CREW Claims, persons must have worked on a vessel that landed SEAFOOD in the Gulf Coast Areas after April 20, 2009.
and
B. Entities. All Entities doing business or operating in the Gulf Coast
Areas or Specified Gulf Waters that:
a) at any time from April 20, 2010 to April 16, 2012, owned, operated, or leased a physical facility in the Gulf Coast Areas or Specified Gulf Waters and (A) sold products in the Gulf Coast Areas or Specified Gulf Waters (1) directly to CONSUMERS or END USERS of those products or (2) to another Entity that sold those products directly to Consumers or End Users of those products, or (B) regularly purchased Seafood harvested from Specified Gulf Waters in order to produce goods for resale;
b) are service businesses with one or more full-time
employees (including owner-operators) who performed their full-time services while physically present in the Gulf Coast Areas or Specified Gulf Waters at any time from April 20, 2010 to April 16, 2012; or
c) owned, operated, or leased a vessel that (1) was Home Ported in the Gulf Coast Areas at any time from April 20, 2010 to April 16, 2012, or (2) landed Seafood in the Gulf Coast Areas at any time from April 20, 2009 to April 16, 2012; or
d) owned or leased REAL PROPERTY in the Gulf Coast Areas at any time from April 20, 2010 to April 16, 2012;
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C. Individuals and Entities who meet the geographical descriptions of Sections A or B above are included in the Economic Class only if their Claims meet the descriptions of one or more of the damage categories described in the Settlement Agreement.
We further understand that the capitalized terms in the Class Definition have the following meanings: “Entity” an organization or entity, other than a Governmental Organization, operating or having operated for profit or not-for-profit, including a partnership, a corporation, a limited liability company, an association, a joint stock company, a trust, a joint venture or an unincorporated association of any kind or description. “Consumer” means a Natural Person or an Entity who or which buys any product for individual use or consumption and not for manufacture or resale. “End User” means a Natural Person or Entity that buys any product for his, her or its individual use or consumption and not for manufacture or resale. To guide the selection of measured media in reaching unknown Class Members, this Economic and Property Damages Settlement Notice Plan has a primary target audience of: all adults 18 years and older, currently living in the Gulf Coast Areas. To further extend the reach of the Plan to unknown Class Members who do not currently reside in the Gulf Coast Areas, the Plan includes a broad national effort to reach adults 18 years and older across the United States. To verify the notice program’s effectiveness, GfK Mediamark Research & Intelligence, LCC (“MRI”)2 data was studied among all adults aged 18 years and older. This data formed the basis for the national program. Additionally, MRI, Nielsen Media Research and other data sources were studied for adults who live in the Gulf Coast Areas.
2 GfK Mediamark Research & Intelligence, LCC (“MRI”) is a leading source of publication readership and product usage data for the communications industry. MRI offers comprehensive demographic, lifestyle, product usage and exposure to all forms of advertising media collected from a single sample. As the leading U.S. supplier of multimedia audience research, MRI provides information to magazines, televisions, radio, Internet, and other media, leading national advertisers, and over 450 advertising agencies—including 90 of the top 100 in the United States. MRI’s national syndicated data is widely used by companies as the basis for the majority of the media and marketing plans that are written for advertised brands in the U.S.
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• Strategies. Notice will be mailed to known or likely Class Members, compiled from various lists provided by the settling parties and their experts. An extensive schedule of local newspaper, radio, television and Internet placements has been developed to reach Class Members in the Gulf Coast Areas. To reach Class Members across the United States, the schedule includes well-read consumer magazines, a national daily business newspaper, highly trafficked websites and Sunday local newspapers (via newspaper supplements). Although not measurable, notice placements will also appear in trade, business and specialty publications, African-American, Vietnamese and Spanish language publications, and Cajun radio programming. An informational release, television public service announcements (“PSAs”), and case website will provide additional notice exposures.
• Delivery. The combined measurable effort will reach at least 95% of adults in
the Gulf Coast Areas on average 8.8 times each and an estimated 83% of all U.S. adults an average of 3.8 times each. The “reach” or net reach of a notice program is defined as the percentage of the target audience exposed to a notice net of any duplication among people who may have been exposed more than once. Coverage will be further enhanced by media placements described above for which reach is not measured. The measurable reach and frequency that will be achieved is consistent with other effective court-approved notice programs, and is designed to meet due process requirements.
• Notice Tactics. The following notice tactics have been selected to best reach
Class Members:
1. Individual Notice. For each name and address of a known, likely Economic and Property Damages Settlement Class Member, a Notice Packet will be mailed via first class mail in a flat envelope. The Notice Packet will include a Cover Letter and Detailed Notice, and is expected to include a color map folio.
2. Consumer Publications. A Summary Notice will appear in twelve leading weekly and monthly consumer publications— two times each in People, Parade and USA Weekend, and once in American Profile, AARP Bulletin, Better Homes and Gardens, National Geographic, Cosmopolitan, Sports Illustrated, Southern Living, People en Espanol, Ebony and Essence, for a total of 16 insertions.
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3. Trade, Business and Specialty Publications. One or two double-page spread or full-page insertions in the Wall Street Journal and publications targeted to the industries and activities most likely directly affected by the Deepwater Horizon Incident.
4. Local Newspapers. Four full-page insertions will appear in 364 local newspapers, covering virtually all of Louisiana, Alabama and Mississippi and DMAs3 in included counties of Texas and Florida.
5. African-American, Vietnamese and Spanish language Publications.
Three full-page or double-page insertions (where available) in publications targeted to the relevant local communities.
6. Local Television. Approximately 300 adult gross rating points (“GRPs”)4
will air per market in the Gulf Coast Areas (matching the DMAs included in the local newspaper effort) substantially over three weeks in a variety of dayparts and programs on local and cable networks. Some spots may run in a fourth week as necessary.
7. Local Radio Programming. Approximately 180 adult GRPs will air per
market in the Gulf Coast Areas (matching the DMAs included in the local television effort) over three weeks on a variety of programming. Additional radio spots will run on “Statenets” targeting rural communities the Gulf Coast Areas. Separate local radio efforts will be targeted to the African-American, Spanish-speaking and Cajun populations where appropriate.
8. Internet Banner Notices. Banner Notices measuring 728 x 90 pixels and
300 x 250 pixels will be placed during a one-month period on national web properties such as 24/7 Real Media (a network that represents over 900 websites), Yahoo!, MSN, AOL, Weather.com and on trade publication websites. In addition, Banner Notices will be placed on local newspaper and television web properties in the Gulf Coast Areas.
3 DMA or “Designated Market Area” is a term used by Nielsen Media Research to identify an exclusive geographic area of counties/parishes in which the home market television stations hold a dominance of total hours viewed. There are 210 DMAs in the U.S. 4 One rating point is equal to 1% of a given population. It is necessarily a gross measurement that includes duplicate exposures to the same person.
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9. Informational Release. A party-neutral, Court-approved informational release will be issued to approximately 4,200 print and broadcast and 5,500 online press outlets throughout the United States.
10. TV PSAs. A Court-approved television spot will be distributed to over
1,200 television stations throughout the United States.
11. Case Website. A neutral, informational website with an easy to remember domain name will be established where Class Members can obtain additional information about the case and notice documents, including the Detailed Notice.
• Message Content. The Notices have been designed to provide a clear, concise,
plain language statement of Class Members’ legal rights and options. The Notices alert Class Members that the message may affect them. The summary publication notice is a single advertising unit for both the Economic and Property Damages and the Medical Benefits Settlement. The publication notice includes a summary of the Economic and Property Damages Settlement, and a separate summary of the Medical Benefits Settlement. Broadcast and Internet efforts provide the message that there is one settlement addressing economic and property damages claims, and a separate settlement addressing medical claims. Consistent with our normal practice, all notice documents will undergo a final edit prior to actual mailing and publication for grammatical errors and accuracy. Drafts of the forms of notice are included as Attachment 1.
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3. Notice Schedule Flow Chart The chart below shows a hypothetical schedule. The schedule would begin sometime after Court approval of the Notice Plan. Class members would be provided sufficient time to act upon their rights prior to the opt-out and objection deadlines. The website will remain operational beyond the flowchart shown, until requested to be terminated.
Notice Tactic Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10 Issue Informational Release Individual Notice Mailing Issue TV PSAs Local Newspapers Local Television* Local Radio Internet Banner Notices National Newspaper Inserts National Consumer Publications
Trade, Business, Specialty Publications
Non-English Language Publications
Case Website *Television placements will substantially occur over a 3-week period with the 4th week reserved for “make-goods” and remaining inventory. Note: Print media blocks show when readers first receive publications (the on-sale date). Media selections are subject to change by addition, deletion, or substitution at the time of placement. Appearance dates may vary within the notice period, based on availability at the time of placement
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4. Target Audience The demographics of the class, including, but not limited to, those most likely to be Class
Members. The proposed Economic and Property Damages Settlement has specific geographic boundaries. The majority of the Class will be located within a limited geographic area in the Gulf Coast Areas (Louisiana, Mississippi and Alabama and portions of Texas and Florida) and the primary thrust of the Notice Plan must be focused there. Data on adults living in the Gulf Coast Areas was specifically analyzed to identify key demographic groups which can be used to guide local media selection. Additionally, because the Class definition encompasses people across many different demographic audiences who could reside anywhere in the United States, the notice program includes a significant component designed to reach adults aged 18+ across the country. According to MRI, demographic highlights of adults aged 18+ in the Gulf Coast Areas include the following:
• 87.4% are over the age of 25 • 72.0% are white • 16.4% are African-American • 70.1% own a home • 66.1% reside in county/parish size A or B5 • 19.4% own a home valued at less than $100,000 • 55.8% are married • 17.6% did not graduate from high school • 50.3% lived at their residence five or more years • 43.7% have a household income of $60,000 or more • 46.4% work full-time
Using MRI data we can also pinpoint certain key demographics that make up a greater percentage of adults in the Gulf Coast Areas, relative to the general U.S. adult population. For instance, adults in the Gulf Coast Areas are:
• 27.6% more likely to live in a rural county/parish • 51.2% more likely to own a home worth less than $100,000 • 41.4% more likely to be African-American
5 “County/parish size A” is defined as highly urbanized areas and belong to the 21 largest Metropolitan Statistical Areas. The combined counties/parishes contain 40% of the United States households. “County/parish size B” is defined as counties/parishes not defined as A counties/parishes that have more than 85,000 households. The combined counties/parishes contain 30% of United States households.
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• 11.7% more likely to work in a natural resources or construction field • 28.1% more likely to have not graduated from high school
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5. Individual Notice Reaches Class Members directly with notice.
Postal Mailed Notice For each unique name and address of a known, likely Economic and Property Damages Settlement Class Member, a Notice Packet will be mailed via first class mail in a flat envelope. The Notice Packet will include a Cover Letter and Detailed Notice, and is expected to include a color map folio. Potential Class Members will be directed to the settlement website and the toll-free number for detailed information on how to file a Claim, to access Claim Forms, and to seek assistance as needed with filing a claim. The mailing list has been compiled from multiple lists of known, likely Settlement Class Members. The Notice Packet will also be sent to known attorneys, other than Class Counsel, who represent likely Class Members. This list will be assembled from sources including the following:
• Short Form Joinders filed in MDL 2179; • The MDL 2179 Plaintiffs’ list; • Gulf Coast Claims Facility (“GCCF”) list of non-medical claimants and
those who requested information about the GCCF process and provided contact information to the GCCF6;
• BP Claims Facility list of claimants who filed claims under the Oil Pollution Act of 1990 prior to the creation of the GCCF;
• Vessels of Opportunity (“VoO”) lists and lists of VoO contractors who subcontracted out to other vessels; and
• Lists of ascertainable Coastal Real Property owners, Wetlands Real Property owners and Real Property Sales owners who are presumptively members the Settlement Class and do not have to demonstrate a loss in order to be eligible to file a claim.
Prior to mailing, all addresses will be checked against the National Change of Address (“NCOA”) database maintained by the United States Postal Service (“USPS”).7 If a record is returned by NCOA as invalid, the administrator will 6 An Economic and Property Damage Settlement Notice packet will be mailed to all names and addresses in the GCCF database that do not unambiguously relate only to a medical claim. (Individuals who unambiguously relate only to a medical claim will be mailed a Medical Benefits Settlement Notice packet). For any record in the GCCF database where there is any ambiguity as to the subject matter of that individual’s claim or request for further information, an Economic and Property Damage Notice Packet will be mailed. 7 The NCOA database contains records of all permanent changes of address submissions received by the USPS for the last four years. The USPS makes this data available to mailing firms and lists submitted to it are automatically
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update the address through third-party address search services and remail as appropriate. Notices returned as undeliverable will be remailed to any new address available through postal service information, for example, to the address provided by the postal service on returned pieces for which the automatic forwarding order has expired, but which is still during the period in which the postal service returns the piece with the address indicated, or to better addresses that may be found after reasonable, additional third-party source lookups. Upon successfully locating better addresses, Notices will be promptly remailed on an ongoing basis. Additionally, the Notice Packet will be mailed to all persons who request one via the toll-free phone number maintained by the Economic and Property Damages claims administrator. Email Notice An Email Notice will be sent to known, likely Settlement Class Members for whom only a name and email address is known and no other means of determining a physical address are available. Additionally, an Email Notice will be sent to known, likely Settlement Class Members for whom a physical address and an email address are available (email notice sent in addition to postal mail). The Email Notice will include substantially the same content as the text of the Publication Notice that is specific to the E&PD Settlement, and will contain an embedded link to the notice website where the Detailed Notice and other settlement information can be accessed. The Email Notice will be provided using an embedded HTML text format. This format will provide text that is easy to read without graphics, tables, images and other elements that would increase the likelihood that the message is blocked by Internet Service Providers (ISP’s) and/or SPAM filters. Prior to transmitting the Email Notice, the Claims Administrator will notify major ISPs about the scheduled notification effort in order to get these messages “white-listed” for delivery to recipient mailboxes. Each Summary Email Notice will be transmitted with a unique message identifier. If the receiving email server cannot deliver the message, a “bounce code” should be returned to the sending server along with the unique message identifier. For any Email Notice for which a bounce code is received indicating that the message was undeliverable, at least two additional attempts will be made to deliver the Notice by email.
updated with any reported move based on a comparison with the person’s name and known address.
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The proposed Cover Letter, Detailed Notice and Email Notice are part of the notice documents included in Attachment 1.
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6. Media Selection The media vehicles that will best reach Class Members in this particular notice program.
In addition to the Individual Notice mailing to potential Class Members, a comprehensive national and regional multi-media effort in virtually every form of media has been selected to effectively deliver a clear message to Economic and Property Damages Settlement Class Members. Newspapers and print publications reach older audiences. Television and radio effectively reach less-affluent audiences, and especially African-American and Spanish speaking audiences. Younger audiences will be targeted through the Internet effort. The business audience is targeted with business and trade publications. Non-English speaking audiences will be targeted with print publications in identified languages and via radio. We have reviewed the merits of all forms of media and, based on our analysis, our media selection allows: • A large majority of Class Members to be reached by the measurable paid print,
television, radio and online media alone (at least 95% of adults in the Gulf Coast Areas and an estimated 83% of adults across the United States).
• Multiple opportunities for Class Members to see the message through
overlapping reach of the different notice methods. • “Noticeable” Publication Notices in leading consumer magazines, daily
newspapers and other publications that will allow readers to have a written record and the ability to refer back to the Notice, pass it on to others, and easily respond via the website or toll-free number.
• Notice placements in approximately 2,191 newspapers nationwide via Parade,
USA Weekend and American Profile, which are inserted in the weekend editions of newspapers with distribution in large cities and small towns.
• High-quality Television Notices that will allow Settlement Class Members to be
alerted to key information and to call or visit the website for additional information.
• Radio Notices appearing on general interest radio stations and on African-
American, Spanish language and Cajun stations in the Gulf Coast Areas.
• Publication Notice in appropriate business and trade publications targeting industries likely to have been affected by the Deepwater Horizon Incident.
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• Publication Notice in appropriate foreign language publications covering major
ethnic groups identified as having a presence in the Gulf Coast Areas. • Extended reach via rotating Banner Notices on a variety of web properties. • The broadest, most inclusive national geographic coverage as well as targeted
local coverage of the Gulf Coast Areas, ensuring that Settlement Class Members are not excluded based on where they choose to live.
• The broadest, most-inclusive demographic coverage, ensuring that Class
Members are effectively reached through notice placements in a variety of cultural and trade publications as well as television and radio programs focusing on different target segments.
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7. Plan Delivery Summary
National Consumer Publications 13 Newspapers carrying Notices (via supplements): ≈2,191 Gulf Coast Areas Local Newspapers 364 Trade Publications 34 Foreign Language and African-American Publications 46 Total Print Insertions 5,421 Local Television Adult GRPs per Market ≈300 Total Radio Adult GRPs per Market ≈180 Internet Banner Impressions ≈115 million Estimated Net % Reached – National Plan 83.0%
Avg. Frequency of Exposure – National 3.8 times
Estimated Net % Reached – Local Plan >95.0%
Avg. Frequency of Exposure – Local 8.8 times
Estimated Net Audience - National 211,000,000
Estimated Gross Impressions* - National 931,000,000
Source: 2011 MRI Doublebase Study, ABC and publication circulation statements. *Total exposures to notice among all those exposed, including repeat exposures.
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8. Net Reach Total different persons who open or read a publication containing a notice.
We employ industry-standard computer software, which uses the latest readership data, to factor out the duplicate persons reached by the different and overlapping audiences on a notice schedule to yield total net persons reached. The proposed measurable print and television, radio and online efforts are estimated to reach:
Target
% Reached, Net of Duplication
Adults in the Gulf Coast Areas aged 18+ 95.0%
All U.S. adults aged 18+ 83.0% Source: 2011MRI Doublebase Study, Nielsen, Arbitron, comScore.
Reach will be further enhanced by the Individual Mailed Notice effort, notice placements in trade, business and specialty publications, African-American, Vietnamese and Spanish language publications, and the informational release, TV PSAs, and case website. The audience data used to determine these results are the same data used by media professionals to guide the billions of dollars of advertising we see today. The statistics and sources we cite are uniformly relied upon in our field: Audit Bureau of Circulations (“ABC”) data has been relied upon since 19148; 90-100% of media directors use reach and frequency planning9; all of the leading advertising and communications textbooks cite the need to use reach and frequency planning10; and
8 Established in 1914, ABC is a non-profit cooperative formed by media, advertisers, and advertising agencies to audit the paid circulation statements of magazines and newspapers. ABC is the leading third-party auditing organization in the U.S. It is the industry’s leading, neutral source for documentation on the actual distribution of newspapers printed and bought by readers. Widely accepted throughout the industry, it certifies over 3,000 publications, categorized by metro areas, region, and other geographical divisions. Its publication audits are conducted in accordance with rules established by its Board of Directors. These rules govern not only how audits are conducted, but also how publishers report their circulation figures. ABC’s Board of Directors is comprised of representatives from the publishing and advertising communities. 9 See generally Peter B. Turk, Effective Frequency Report: Its Use And Evaluation By Major Agency Media Department Executives, 28 J. ADVERTISING RES. 56 (1988); Peggy J. Kreshel et al., How Leading Advertising Agencies Perceive Effective Reach and Frequency, 14 J. ADVERTISING 32 (1985). 10 Textbook sources that have identified the need for reach and frequency for years include: JACK S. SISSORS & JIM SURMANEK, ADVERTISING MEDIA PLANNING, 57-72 (2d ed. 1982); KENT M. LANCASTER & HELEN E. KATZ, STRATEGIC MEDIA PLANNING 120-156 (1989); DONALD W. JUGENHEIMER & PETER B. TURK, ADVERTISING MEDIA 123-126 (1980); JACK Z. SISSORS & LINCOLN BUMBA, ADVERTISING MEDIA PLANNING 93-122 (4th ed. 1993); JIM SURMANEK, INTRODUCTION TO ADVERTISING MEDIA: RESEARCH, PLANNING, AND BUYING 106-187 (1993).
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a leading treatise says it must be used:11 “In order to obtain this essential information, we must use the statistics known as reach and frequency.” Ninety of the top one hundred media firms use MRI data, which has a 95% confidence interval; and at least 3,000 media firms in 25 different countries use media planning software for reach and frequency planning.12 Online media planning data is provided by comScore, Inc.13
11 AMERICAN ADVERTISING AGENCY ASSOCIATION, GUIDE TO MEDIA RESEARCH 25 (1987), revised 1993. 12 For example, Telmar is the world’s leading supplier of media planning software and support services. Over 3,000 users in 25 countries, including 95% of the world’s top agencies, use Telmar systems for media and marketing planning tools, including reach and frequency planning functions. Established in 1968, Telmar was the first company to provide media planning systems on a syndicated basis. 13 comScore, Inc.is a global leader in measuring the digital world and a preferred source of digital marketing intelligence. In an independent survey of 800 of the most influential publishers, advertising agencies and advertisers conducted by William Blair & Company in January 2009, comScore was rated the “most preferred online audience measurement service” by 50% of respondents, a full 25 points ahead of its nearest competitor.
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9. Average Frequency of Exposure Average number of times that each different person reached will have an opportunity to view a
vehicle containing a notice placement. This Notice Plan is intended to provide Class Members with the best practicable opportunity to view and understand the Notice and their rights, including their right to file a claim, if desired. A by-product of the media vehicles necessary for a broad net reach is multiple exposures to notice from overlapping audience coverage. This Notice Plan relies upon modern-style, audience-documented media coverage as reported herein, and provides a higher frequency of exposure than would a direct mail notice program that sends one notice, one time, to a Class Member.14 The average frequency of exposure resulting from the proposed Notice Program is as follows:
Target Average Frequency of Exposure
Adults in the Gulf aged 18+ 8.8 All U.S. adults aged 18+ 3.8
Source: 2011 MRI Doublebase Study.
The frequency of exposure will be further enhanced by the Individual Mailed Notice effort, notice placements in trade, business and specialty publications, African-American , Vietnamese and Spanish language publications, informational release, TV PSAs, and case website.
14 The reach achievable through direct mail notice programs varies widely depending on the accuracy and comprehensiveness of class member mailing lists.
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10. Geographic Coverage Ensuring that Class Members are not excluded simply because of where they live.
The notice effort covers the entire United States with specific focus on the states of Louisiana, Mississippi and Alabama and the enumerated counties in Texas and Florida. Selections of local media markets were informed by these boundaries, with local media coverage extending beyond the actual borders where appropriate. • The consumer publications have distribution and/or subscribers throughout the
U.S., as supported by the detailed ABC statements for each publication. • Parade, USA Weekend and American Profile are distributed within nearly 2,191
newspapers nationwide, covering large markets as well as reaching deep into small towns. A listing of the newspapers that contain Parade, USA Weekend and American Profile is attached as Attachment 2.
• The television and radio airings will result in the overall schedule being
available to Class Members in Louisiana, Mississippi, Alabama and portions of Texas and Florida.
• Notice placements in local newspapers targeting the Gulf Coast Areas with
targeted coverage to Settlement Class Members residing in the Economic and Property Damages Settlement “Zones.” Additionally, the recommended consumer publications offer spill-over circulation into these areas.
• Notice placements in trade, business and specialty publications extend reach to
targeted industries throughout the U.S. • The Internet Banner Notices and case website allow access to the Notice
regardless of geography. • The informational release and television PSAs will broaden the geographic
coverage further.
Accordingly, the Notice is designed to reach Class Members regardless of where they choose to live.
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11. Nationwide Publication Plan The national newspapers and consumer publications in which the notice will appear.
The Notice Plan includes multiple notice placements in 13 leading weekly and monthly publications. Notices will appear twice in the national newspaper supplements Parade and USA Weekend and once in American Profile. Combined, these publications appear in over 2,191 Sunday newspapers nationwide. Notices will appear twice in People, and once in Better Homes and Gardens, AARP Bulletin, National Geographic, Cosmopolitan, Sports Illustrated, Southern Living, People en Espanol, Ebony and Essence, for a total of 16 insertions. The selected publications cover all demographic groups, specifically targeting men’s and women’s publications, magazines aimed at older demographic segments, Spanish-speaking readers, and publications specifically targeting the African-American community.
Publication
Issuance
Overall Notice Size
Econ/Property Notice Content
# of Insertions
People Weekly Dbl-Page Spread Full Page 2 Parade Weekly Dbl-Page Spread Full Page 2 USA Weekend Weekly Dbl-Page Spread Full Page 2 American Profile Weekly Dbl-Page Spread Full Page 1 Better Homes and Gardens Monthly Dbl-Page Spread Full Page 1
AARP Bulletin 10x/year Dbl-Page Spread Full Page 1 National Geographic Monthly Dbl-Page Spread Full Page 1 Cosmopolitan Monthly Dbl-Page Spread Full Page 1 Sports Illustrated Monthly Dbl-Page Spread Full Page 1 Southern Living Monthly Dbl-Page Spread Full Page 1 People en Espanol 10x/year Dbl-Page Spread Full Page 1 Ebony Monthly Dbl-Page Spread Full Page 1 Essence Monthly Dbl-Page Spread Full Page 1 TOTAL 16
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12. Nationwide Publication Details A summary of facts on the consumer publications in which the notice will appear.
Publication Facts Parade • Weekly national newspaper supplement covering
family, food, health, current events and entertainment. • Provides the single largest readership of any publication.• Provides a broad demographic readership and
geographic coverage. • Carried in approximately 522 papers throughout the
U.S. • Planned notice size: Double-Page Spread • Planned insertions: 2x
USA Weekend • Weekly national newspaper supplement covering family, food, health, current events and entertainment.
• Readership ranks 2nd among adults 18+ • Provides a broad demographic readership and
geographic coverage. • Carried in approximately 686 papers throughout the
U.S. • Planned notice size: Double-Page Spread • Planned insertions: 2x
American Profile • Weekly national newspaper supplement covering family, food, health, current events and entertainment.
• Provides a broad demographic readership and geographic coverage.
• Carried in approximately 1,350 papers throughout the U.S.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
People • Weekly entertainment magazine featuring celebrity news, biographies, and gossip.
• Readership ranks 3rd among adults 18+ • Provides a large number of pass along readers. • Planned notice size: Double-Page Spread • Planned insertions: 2x
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Better Homes and Gardens
• Monthly national magazine covering, lifestyle, home and garden trends and remodeling, health and food.
• Readership ranks 4th among adults 18+ • Planned notice size: Double-Page Spread • Planned insertions: 1x
National Geographic
• Monthly publications featuring photos, maps and articles relating to animals, the environment, cultures and history around the world.
• Readership ranks 6th among adults 18+ • Planned notice size: Double-Page Spread • Planned insertions: 1x
AARP Bulletin • 10x/year publication targeting mature adults featuring the latest news and information on health, social security, Medicare, politics and more.
• Readership ranks 7th among adults 18+ • Planned notice size: Double-Page Spread • Planned insertions: 1x
Cosmopolitan • Monthly female targeted magazine featuring celebrity news, health, relationship and style advice.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
Sports Illustrated • Monthly sports magazine covering sports news, photos, scores, columns and expert analysis.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
Southern Living • Monthly magazine covering Southern culture, recipes, travel and events.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
Ebony • Monthly magazine covering African-American culture, arts, health, travel, politics and lifestyle.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
Essence • Monthly magazine covering African-American culture, arts, health, travel, love and lifestyle.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
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People en Espanol • 10x/year entertainment magazine featuring celebrity news, biographies, and gossip in Spanish.
• Planned notice size: Double-Page Spread • Planned insertions: 1x
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13. Nationwide Publication Coverage The size of the audience as a percent of the demographic base (reach).
The selected publications include the top four in the country and 6 of the top 7, as well as publications that extend reach among various demographic segments.
Publication
Coverage among U.S.
Adults Coverage
Rank
Parade 30.37% 1
USA Weekend 18.30% 2
People 19.87% 3
Better Homes and Gardens 17.37% 4
National Geographic 13.95% 6
AARP Bulletin 13.02% 7
American Profile 11.40%* 9
Sports Illustrated 9.17% 13
Cosmopolitan 8.11% 17
Southern Living 6.89% 19
Ebony 4.60% 44
Essence 3.51% 57
People en Espanol 2.94% 81 Source: 2011 MRI Doublebase Study. Read As: An insertion in Parade reaches 30.37% of adults 18+. * American Profile is not a measured publication in MRI’s most recent Doublebase survey. Reach percentage reported above is based on publisher’s estimates.
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14. Nationwide Publication Circulation Total number of copies sold through all channels (subscription, newsstand)
The selected publications include some of the largest circulating publications in the country. Combined, they provide a total circulation of over 114 million.
Publication Total Circulation
Parade 33,000,000
USA Weekend 22,600,000
American Profile 10,000,000
People 3,450,000
Better Homes and Gardens 7,663,198
Southern Living 2,800,000
National Geographic 4,400,000
AARP Bulletin 22,000,000
Cosmopolitan 3,032,000
Sports Illustrated 3,150,000
Ebony 1,250,000
Essence 1,050,000
People en Espanol 540,000
TOTAL 114,935,198 Source: ABC audit and publisher’s statements.
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15. Publication Secondary Reader Data Secondary or ‘pass-along’ readers of a publication.
Based on MRI readership data, we know that more readers than just those who purchase or otherwise receive circulated issues actually open or read the publication. Many secondary readers see the Notice away from home: for example, at a subscriber’s house; at a doctor’s office; in an airport; on an airplane; in the reception area of a company; passed around by co-workers at the place of employment; etc. Exposure in a different environment can increase attentiveness and response potential. It is also beneficial that readership tends to build over a period of time following the publication date. This is evidence that issues can be referred to at any time, thereby providing readers with a longer, sustained opportunity to be exposed to the Notice. The following calculations set forth the average number of readers-per-copy of each of the selected publications:
Publication
Readers Per Copy
Parade 2.10 USA Weekend 1.85 American Profile 2.60 People 13.14 Better Homes and Gardens 5.17 Southern Living 5.62 National Geographic 7.23 AARP Bulletin 1.35 Cosmopolitan 6.95 Sports Illustrated 6.64 Ebony 8.39 Essence 6.90 People en Espanol 12.42
Source: 2011 MRI Doublebase Study audience numbers and ABC statements.
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16. Nationwide Publication Audience Data Total different persons opening or reading a publication.
The following outlines the total Adult audience (readership) for one insertion in each of the selected publications. The total audience is based on actual MRI in-depth interview data that tell us how many persons “Opened or Read” a publication.
Publication
Total Adult Audience
Parade 69,278,000
USA Weekend 41,747,000
American Profile 26,000,000
People 45,318,000
Better Homes and Gardens 39,625,000
Southern Living 15,722,000
National Geographic 31,813,000
AARP Bulletin 29,700,000
Cosmopolitan 21,072,000
Sports Illustrated 20,926,000
Ebony 10,482,000
Essence 7,245,000
People en Espanol 6,708,000 Source: 2011 MRI Doublebase Study.
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17. Nationwide Publication Gross Impressions Total number of times any person opens or reads publications containing notice placements.
Adults will be exposed to the Notice through the publication effort alone more than 521 million times during the notice period. This includes the same reader more than once, because readers of one publication read other publications as well. This duplication is factored out by the net reach analysis explained earlier.
Publication
Insertions
Adult Impressions
Parade 2 138,556,000
USA Weekend 2 83,494,000
American Profile 1 26,000,000
People 2 90,636,000
Better Homes and Gardens 1 39,625,000
Southern Living 1 15,722,000
National Geographic 1 31,813,000
AARP Bulletin 1 29,700,000
Cosmopolitan 1 21,072,000
Sports Illustrated 1 20,926,000
Ebony 1 10,482,000
Essence 1 7,245,000
People en Espanol 1 6,708,000
Total 521,979,000 Source: 2011 MRI Doublebase Study.
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18. Trade, Business and Specialty Publications The trade and business publications in which the notice will appear.
The Notice will appear once or twice as appropriate in 34 publications targeted to the industries and activities most likely to have been directly affected by the Deepwater Horizon Incident. The Selected publications, which include the national edition of the Wall Street Journal, have a combined circulation of over 5 million. The following provides circulation data for the selected Trade, Business and Specialty publications:
Publication Distribution
Frequency # of
Insertions Circulation Bass Master National 10x/year 1 521,397 Conde Nast Traveler National Monthly 1 816,066 Florida Sportsman National Monthly 2 76,194 GAFF National bi-monthly 1 280,000 Game and Fish National Monthly 1 415,000 Gulfcoast Business Review SW Florida Weekly 2 14,000 Gulfscapes Magazine Gulf Coast Quarterly 1 40,000 Gulfshore Business Southwest Florida Monthly 2 31,942 Marina Dock Age National 8x yearly 1 16,141 Marine Log Global Monthly 2 31,619 Maritime Executive Global bi-monthly 1 24,904 National Fisherman National Monthly 2 30,076 Offshore Global Monthly 2 44,546 Recommend Magazine National Monthly 2 48,810 Saltwater Sportsman National 10x/year 1 136,238 Seafood Business National Monthly 2 14,000 Sport Fishing National 9x/year 1 110,406 Sunbelt Food Service Southern States Monthly 2 27,826 Texas Monthly National Monthly 2 300,000 Texas Saltwater Fishing Texas Monthly 2 40,000 The Shelby Report of the Southeast SE Monthly 2 16,202 The Shelby Report of the Southwest SW Monthly 2 15,934 Travel Agent Magazine Global Bi-weekly 2 1,812 Travel Weekly National Weekly 2 38,000 Vacation Agent Magazine National Monthly 2 31,399 Well Service National bi-monthly 1 10,000 Louisiana Sportsman Louisiana Monthly 2 35,000 Mississippi Sportsman Mississippi Monthly 2 9,500 New Orleans Magazine New Orleans Monthly 2 34,241 New Orleans CityBusiness New Orleans Weekly 2 20,150 Louisiana Life Louisiana bi-monthly 1 40,000 South Louisiana BusinessNews Louisiana Weekly 2 10,000
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Offbeat Louisiana Monthly 2 36,626 Wall Street Journal National Daily 1 2,117,796 Total 56 5,435,825
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19. Local Newspapers The newspapers in the Gulf Coast Areas in which the notice will appear.
The Economic and Property Damages Notice Plan includes daily and weekly newspapers covering each of the Designated Marketing Areas (“DMAs”) in which the largest population center within each respective DMA is part of the defined Gulf Coast Areas. DMAs represent a geographic area defined by Nielsen Media Research Company as a group of counties/parishes that make up a particular television market. The “Gulf Coast Areas” include the States of Louisiana, Mississippi, and Alabama; the counties of Chambers, Galveston, Jefferson and Orange in the State of Texas; and the counties of Bay, Calhoun, Charlotte, Citrus, Collier, Dixie, Escambia, Franklin, Gadsden, Gulf, Hernando, Hillsborough, Holmes, Jackson, Jefferson, Lee, Leon, Levy, Liberty, Manatee, Monroe, Okaloosa, Pasco, Pinellas, Santa Rosa, Sarasota, Taylor, Wakulla, Walton, Washington in the State of Florida. These 26 individual DMAs have been used to establish the geographic scope for the local portion of the media plan. They are as follows:
• Houston • Beaumont-Port
Arthur • New Orleans • Lake Charles • Lafayette, LA • Baton Rouge • Biloxi-Gulfport • Mobile-
Pensacola-Ft. Walton
• Montgomery-Selma
• Dothan
• Miami-Ft. Lauderdale
• Tallahassee-Thomasville
• Gainesville • Tampa-St.
Petersburg-Sarasota
• Ft. Myers-Naples
• Panama City • Hattiesburg-
Laurel • Alexandria, LA • Monroe-El
Dorado
• Shreveport • Jackson, Ms • Columbus-
Tupelo-West Point
• Greenwood-Greenville
• Meridian • Birmingham
(Anniston and Tuscaloosa)
• Huntsville-Decatur (FL)
For the Local Newspaper Notice, these 26 DMAs ringing the Gulf Coast Areas will be covered by a total of 347 individual, local newspapers.
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The Notice will run in an additional 17 newspapers in the Memphis (12), Atlanta (1) and Columbus (4) DMAs. These three DMAs lie predominately outside the Class geography, but do have small areas carved into the states of Mississippi (Memphis DMA) and Alabama (Atlanta and Columbus DMAs). It is these small areas that are covered by the 17 additional newspapers. Including these insertions, the Local Newspaper Notice will run in a total of 364 individual newspapers. The Notice will appear 4 times as a full-page ad unit in each newspaper—twice on Sunday and twice on a weekday in daily newspapers and over 4 successive weeks in weekly newspapers for a total of 1,456 insertions. The selected newspapers have a combined circulation of over 8 million. In most instances, the Notice will appear a fifth or sixth time in each local newspaper via the planned insertions in the nationwide newspaper inserts (Parade, USA Weekend and American Profile). When this occurs, the Notice will appear on successive Sundays with the weekday insertion in-between the two Local Newspaper Sunday insertions. The list of selected local newspapers is included as Attachment 3.
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20. African-American, Vietnamese and Spanish Language Publications
In order to target certain communities affected by the Deepwater Horizon Incident in mediums culturally appropriate to them, the Notice will appear as a double page spread or full-page ad unit 3 times in selected daily and weekly publications and 1 time in selected monthly publications covering the African-American, Vietnamese and Spanish language populations in the Gulf Coast Areas. The Notice will be translated into Vietnamese and Spanish where appropriate. The 46 selected publications have a combined circulation of over 1.8 million. The following provides circulation data for the African-American, Vietnamese and Spanish language publications:
Publication Distribution
Language # of
Insertions CirculationAfrican American News & Issues Houston English 3 250,000
Alexandria News Weekly Alexandria English 3 5,000 Baton Rouge Weekly Press Baton Rouge Spanish 3 7,500 Birmingham Times Birmingham/Anniston/Tusc. Spanish 3 16,500 Centro Tampa (formerly Centro Mi Diario) Tampa/St. Petersburg Spanish 3 42,000
Community Voice Ft. Myers/Naples Spanish 3 12,000 Data News Weekly New Orleans Spanish 3 25,000 Dep Weekly Magazine Houston Spanish 3 10,000 Diario Las Americas Miami/Ft. Lauderdale Spanish 3 35,095 El Nuevo Herald - Sunday Edition Miami/Ft. Lauderdale English 3 84,972
El Perico Beaumont/Port Arthur English 3 26,400 El Sentinel (Ft. Lauderdale/Miami) Miami/Ft. Lauderdale Spanish 3 125,000
El Sol De La Florida Miami/Ft. Lauderdale English 1 60,000 El Tiempo New Orleans New Orleans English 1 20,000 Florida Sentinel Bulletin Tampa/St. Petersburg English 3 23,000 Forward Times Houston English 3 64,580 Houston Defender Houston English 3 20,215 Jackson Advocate Jackson, MS Spanish 3 8,000 Jambalaya News New Orleans English 3 15,000 La Gaceta Tampa/St. Petersburg English 3 18,000 La Informacion Houston Bilingual 3 100,000 La Noticia de Mississippi Jackson, MS Spanish 3 5,000 La Subasta Houston (10 Houston Bilingual 3 163,875
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Zones) La Voz De Houston Houston English 3 100,000 Latino News Birmingham/Anniston/Tusc. English 3 12,000 Louisiana Weekly New Orleans English 3 6,500 Miami Times Miami/Ft. Lauderdale Bilingual 3 25,000 Mississippi Link Jackson, MS Bilingual 3 16,404 Monroe Dispatch Monroe/El Dorado Spanish 3 12,000 Monroe Free Press Monroe/El Dorado Spanish 3 15,000 Montgomery-Tuskegee Times Montgomery/Selma Spanish 3 5,000
New Orleans Tribune New Orleans English 1 20,000 Nuevos Ecos Ft. Myers/Naples English 3 20,000 Paisano Birmingham/Anniston/Tusc. English 3 9,000
Pensacola Voice Mobile/Pensacola/Ft. Walton
Beach Spanish 3 38,000
Rio Grande Valley Hispanic Newspaper Network
Harlingen/Weslaco/ Brownsville/McAllen English 3 108,218
Rumbo (Houston) Houston Bilingual 3 52,000 Saigon Nho New Orleans Spanish 3 5,000 Semana Houston Vietnamese 3 145,000 Shreveport Sun Shreveport Spanish 3 4,900 Siete Dias (7 Dias) Tampa/St. Petersburg English 3 22,000 South Florida Times (formerly Broward Times) Miami/Ft. Lauderdale Spanish 3 26,000
Thuong Mai Houston Vietnamese 3 42,000 Viet Bao Weekly - Houston Edition Houston Vietnamese 3 25,000
Vietnam Moi News Houston Vietnamese 3 20,000 Weekly Challenger Tampa/St. Petersburg English 3 10,000 Total 132 1,876,159
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21. Local Television Mainstream television is a high-reach medium providing exposure to affected people regardless of where they reside (i.e. rural areas, urban areas, etc.). 30-second units will appear on local broadcast and cable television as appropriate in the 26 DMAs identified in section 19. It is estimated that the local television Notice will generate approximately 300 “GRPs” per Market. GRP is a term used in advertising to measure the size of an audience reached by a specific media vehicle or schedule. It is the product of the percentage of the target audience reached by an advertisement, times the frequency they see it in a given campaign. For example, a TV advertisement that is aired 5 times reaching 50% of the target audience would have 250 GRPs (GRP = 5 × 50%). We conservatively estimate that 2,730 total spots will be run, but it is likely that additional spots will be negotiated at the time of the buy. On its own, the Local Television Notice is estimated to reach over 80% of adults aged 18+ in the Gulf Coast Areas with an estimated average frequency of 3.6 times each.
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22. TV Dayparts/Programming The periods of the day and programs on which the television notice will air.
Utilizing several dayparts increases the Notice Plan’s ability to reach persons with different viewing habits. Daypart mixes and programming selections may change at the time the buy is authorized, based on negotiations and availabilities.
Morning • Morning news programming provides an ideal environment for
notification messages. • Loyal audience builds frequency among those reached. • Programming considered includes Good Morning America, The Today
Show, CBS Early Show and Local News. Daytime
• Extends reach among homemakers, retirees, or unemployed Class Members.
• Loyal audience builds frequency among those reached. • Programming considered includes daytime dramas, game shows
and/or talk shows. Syndicated (Day/Prime Access/Early Fringe)
• Extends reach especially among those with varied viewing schedules. • Programming may include shows like The People’s Court, Judge
Mathis, Judge Judy, Ellen DeGeneres Show, Jeopardy, Wheel of Fortune.
Early News • Non-opinionated journalism provides an ideal environment for
notification programs. • Provides broad reach among Class Members. • Programming considered includes CBS Evening News, ABC World
News Tonight, NBC Nightly News with Brian Williams and Local News.
Prime/Syndicated Prime • Provides rapid audience awareness and accumulation. • Programming may include shows like CSI:NY, CSI: Miami, Law &
Order, 20/20, 60 Minutes, Dateline NBC and Criminal Minds
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23. TV Rating Points (GRPs) One rating point equals one percent of the targeted population. This may include the same
person reached more than once, so ratings can and often do exceed 100. Approximately 2,730 30-second spots will substantially run over a three-week period in Gulf Coast markets matching the DMAs covered in the Local Newspaper plan. Approximately 300 Gross Rating Points per market and over 67 million gross impressions will be generated. Ads to air on the top 3 local stations per market and on the top 6 cable networks per market. Cable networks include: CNN, Fox, Discovery (Deadliest Catch), USA, History and The Weather Channel. Daypart allocation may change at the time the buy is authorized, based on negotiations and availabilities.
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24. TV Gross Impressions Total number of times a television show containing a notice placement is seen.
Adults will be exposed to the Notice more than 67 million times during the period in which the television schedule airs.
Daypart
Adult Gross Impressions
Morning 6,792,300 Daytime 6,792,300 Early Fringe 6,792,300 Early News 10,188,450 Prime Access 10,188,450 Primetime 13,584,600 Late News 6,792,300 Weekend 6,792,300 TOTAL 67,923,000
Daypart mixes may change at the time the buy is authorized, based on negotiations and availabilities.
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25. Local Radio Programming
Local radio is a high-frequency medium providing exposure to affected people regardless of where they reside (i.e. rural areas, urban areas, etc.). 30-second units will appear over a two-week schedule on selected radio stations in the 26 DMAs identified in section 19. It is estimated that the local Radio Notice will generate approximately 180 “GRPs” per Market. We conservatively estimate that 8,712 total spots will be run, but it is possible that additional spots will be negotiated at the time of the buy. On its own, the Local Radio Notice is estimated to reach just under 45% of adults aged 18+ in the Gulf Coast Areas with an estimated average frequency of 4 times each. To better reach rural communities, the radio notice will appear on “StateNets,” a radio network specializing in reaching C & D counties/parishes in 48 states. Typical StateNets features are news, regional weather and other informational programs. We estimate that over 14,000 total spots will run on approximately 200 radio stations in the 26 DMAs over a three week period. Additionally, the Radio Notice will be placed on appropriate African-American and Spanish language stations. We estimate that 4,032 spots will run on African-American stations. A further 936 spots will run on Spanish language stations in areas of the Gulf Coast with high concentrations of Spanish speaking adults. The Spanish language Radio Notice will be recorded as a 60-second spot to accommodate the translation. A radio buy will also be executed, targeted toward the Cajun population in Southern Louisiana. Approximately 100 spots will run over a 2-week period on local stations, including: KLRZ-FM, KLEB-AM, and KANE-AM. The spot will be voiced in a Cajun dialect. The Local Radio Notice to Hispanic, African-American and Cajun populations is not calculated into the overall measured reach and frequency of the Notice Plan.
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26. Internet Banner Notices National and local banner notices that will appear on web properties.
Digital 728x90 pixel and 300x250 pixel banners will be placed on the following national online networks:
• Yahoo!, • MSN, • AOL, • Weather.com, and • 24/7 Real Media (representing over 900 websites including those related to
health, fitness, and news and information). Where available, banners will also be placed on the websites of the selected trade and specialty publications included in the print publication plan. Combined, approximately 72 million adult impressions will be generated by these banner notices over a one month period. Clicking on the banner will jump the searcher to the case website where they can obtain information about the settlement. To complement print notices in the selected local newspapers, digital 728x90 and 300x250 banners will be placed through quadrantOne on newspaper and local TV websites in the identified geographies. Banner notices will run across 31 days and deliver more than 42 million impressions across Texas, Louisiana, Mississippi, Alabama and Florida. Each banner notice will include a clickable link to the dedicated case website.
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27. Placing Notices to be Highly Visible Inserting notices in spots within the media that will help gain Class Members’ attention.
All placements are not equal. Extra care can and will be taken to place Notices in positions that will generate “noticeability” among Class Members. In print, the Notice will run as a double page spread. Notice will be placed in certain sections of publications to help ensure that over the course of the media schedule, the greatest practicable number of Class Members will see the Notice. In the local newspapers, the Notice will appear as a full-page ad unit. Summary Publication Notice Design The Summary Publication Notice will be divided into two sections. One section will provide notice of the Economic and Property Damages Settlement. The other section will provide notice of the Medical Benefits Settlement. Each notice will feature its own headline to alert potential Class Members that they may be affected by one or more (or both) of the two proposed Settlements. Both Settlements will share a common toll-free number and website address. These will be featured prominently along the bottom of the Notice. In television, planned spots may be pre-empted15; however, “makegoods” will be sought in acceptable programs. A post-buy analysis will assure that GRP levels are achieved. Efforts will be made to enhance the television reach and frequency by taking advantage of last minute market conditions at the time the buy is placed. This may include varying from the daypart mix or activity weeks in order to capitalize on the most efficient availabilities, or programs expected to be highly rated.
15 TV spot airtimes may change depending on other commercials a network has scheduled, but the network will “make good” on its contract by airing spots with comparable audience delivery.
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28. Informational Release Seeking non-paid (and other) exposure of court-approved notice information mainly by way
of news articles. A party-neutral, Court-approved informational release will be issued to approximately 4,200 print and broadcast and 5,500 online press outlets throughout the United States. A news release serves a potentially valuable role, providing additional notice exposure beyond that which will be provided through paid media. There is no guarantee that any news stories will result, but if they do, Class Members will have additional opportunities to learn that their rights are at stake in credible news media, adding to their understanding. The release will include the toll-free number and website address. A list of press outlets receiving the informational release is available upon request. The informational release itself is part of the notice documents included as Attachment 1.
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29. TV Public Service Announcements Paid distribution of the notice to select television stations.
The 30-second television spot will be distributed as a TV PSA or “public service announcement” to more than 1,200 broadcast television stations throughout the U.S. The packaging will include a letter explaining the important legal nature of the announcement to gain the attention of public service directors and encourage stations to air the information. The television spot will feature the case website address and toll-free number to increase Class Members’ opportunities to obtain more information and/or respond to the Notice. A list of the broadcast television stations that will receive the TV PSA is available upon request.
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30. Case Website Delivery of notice via Internet and online services.
A neutral, informational, notice website with an easy to remember domain name will serve as the notice page for both Settlements where potential Settlement Class Members can obtain additional information and documents including the Detailed and Summary Notices, Settlement Agreements, Preliminary Approval Orders and any other information that the parties agree to provide or that the Court may require. The case notice website will also include information on how potential Settlement Class Members can opt-out of the Settlement if they choose. The case notice website address will be prominently displayed in all printed notice documents, and appear in all broadcast media including the informational release and TV PSAs. The Banner Notices will link directly to the website. Visitors to the case notice website will be able to easily link to separate claims administration websites tailored to each Settlement via prominent buttons on the notice website homepage (one reading “Economic and Property Damages Claims” and the other reading “Medical Claims”). Claim Forms and other information specific to each Settlement will be available at these claims administration sites. The case notice website will be color-coordinated with the claims administration websites and all pages that a visitor might see will have a consistent look and functionality. In order to stress the separateness of the two Settlements, the claims administration sites will have different, but compatible, color schemes. The case notice website will reflect this by having the button links to each claims administration website in the specific color scheme of the website it is linking to. Both claims administration websites will include a prominent link to the other claims administration website for visitors interested in both settlements. The claims administrator claims filing website will include an interactive map of the Gulf Coast where visitors will be able to input their property or residency address or select a geographic location to assist them in determining if the address falls into one or more of the defined Settlement “Zones.” All website content (including the Notices) will be available in English, Spanish and Vietnamese. Translated Notices may also be made available in Khmer, Lao and Haitian/Creole if requested. A screen shot of the proposed notice website pages is part of the notice documents included as Attachment 1.
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31. Sponsored Search Listings To facilitate locating the case website, sponsored search listings will be acquired on the three most highly-visited Internet search engines: Google, Yahoo! and Bing. When search engine visitors search on common keyword combinations such as “Deepwater Horizon,” “Gulf property settlement,” or “BP Settlement,” the sponsored search listing will display either at the top of the page prior to the search results or in the upper right hand column.
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32. Notice Design Strategy
The Notices have been designed to motivate Settlement Class Members to view and understand the message and carry a clear message outlining Settlement Class Members’ rights. The strategic approach to content and design is entirely consistent with the illustrative “model” notices developed by the Federal Judicial Center (“FJC”). All print publication notices will be a single advertising unit that includes one summary notice that addresses the Economic and Property Damages Settlement, and a separate summary notice that addresses the Medical Benefits Settlement. Broadcast and Internet efforts will also provide the message that there is one settlement addressing economic and property damages claims, and a separate settlement addressing medical claims.
Summary Notice Design Elements: • Bold headline captures attention. The headlines immediately alert even casual
readers who may be potential Settlement Class Members that they should read the Notices and why they are important. It speaks directly to the Class Member.
• Notice size promotes attention. The Notices are either full-page units in the
local newspapers or double-page spreads in most print publications to promote readership.
• Notice design alerts readers to the legal significance, lending credibility. The
Notice design ensures that readers know that the communication carries legitimate, important information, not commercial advertising. The clear delineation between the Economic and Property Damages Settlement Notice text and the Medical Benefits Settlement Notice text highlights that the Court is considering two separate settlements and that the reader may have rights under each Settlement or under both.
• Plain language enhances comprehension. The Notice concisely and clearly
states the information in plain, easily understandable language so that Class Members can comprehend the Notice effectively.
• Comprehensive content fulfills legal requirements. All critical information
about Settlement Class Members’ rights is included. No key information is omitted.
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• Toll-free number and website invite response. The Notice invites response by
providing simple, convenient mechanisms, such as the toll-free number and website for Settlement Class Members to obtain additional information, if desired.
• Translations allow participation across speakers of key languages. The
Summary Notice will be translated into Spanish and Vietnamese for placement in the appropriate Spanish and Vietnamese language newspapers. The Detailed Notice will include tag lines in Spanish and Vietnamese telling potential Class Members that the notices are available in each language on the website or by calling the toll-free number.
Television and Radio Notice Design Elements: • Designed to stand apart from ads. Because they are designed to look and
sound different from commercials selling products, viewers and listeners understand its significance and take notice.
• Key words and concepts are depicted on screen. The principles of
communication dictate visual and verbal repetition of key concepts presented. • Convenient response-oriented approach is provided. In the TV Notice, the
website and toll-free number are spoken and shown on the screen long enough to allow Class Members to write them down or remember them. The Radio Notice will repeat the toll-free number and website if time permits.
• Simple information allows sufficient understanding. Although concise, the
purpose of the Notice is served by delivering the substance of the message (that there are two separate Settlements) and prompting a response to get more information.
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33. Draft Forms of Notice All notice documents have been drafted by Hilsoft in cooperation with the parties and subject to the approval of the Court. These documents include: • The Cover Letter, Detailed Notice and Mailing Envelope that will be mailed
to all known potential Settlement Class Members and to those who call to request one as well as made available at the website.
• The Email Notice that will be sent to known, likely Settlement Class Members
for whom an email address is available.
• The Publication Notice as it will appear in magazines and newspapers identified in the Notice Plan.
• The Television Notice Storyboard that will be produced as a 30-second unit and aired as a paid local spot and nationally via the TV PSA effort.
• The Television PSA script and cover text.
• The Radio Notice Script that will be produced as a 30-second spot (60-second
when translated into Spanish) and aired as a paid local spot.
• The Internet Banner Notices that will be posted on a variety of web properties.
• Pages from the Notice Website as they will be posted on the Internet.
• The neutral Informational Release that will be issued to news outlets throughout the U.S.
Notice drafts are included as Attachment 1 and foreign language translations will be provided with our final report.
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Attachment 1A: Cover Letter, Detailed Notice, Mailing Envelope
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Cover Letter
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Notice Administrator for U.S. District Court Post Office Box NNNN City, ST Zip
F-Name MI L-Name Street Address 1 Street Address 2 City, ST Zip
An Economic & Property Damages Settlement has been reached related to the Deepwater Horizon incident. The Settlement will provide payments to qualifying individuals and businesses that file valid claims for economic and property damage. You are receiving this notice because you have been identified as a possible member of the Economic and Property Damage Settlement Class. Please review the enclosed notice about the Economic & Property Damages Settlement carefully.
If you are included in this Settlement, you have rights and options such as submitting a claim for benefits, opting-out of or objecting to the Settlement. A court hearing will be held on Month DD, 20YY to consider whether the Settlement is fair, reasonable and adequate. The hearing may be moved to a different date, time, or location without additional notice, so it is recommended that you periodically check www.[ ].com for updated information.
You need to submit a claim to request a payment. You can get a copy of the Claim Form by visiting the website www.[ ].com or by calling 1-8XX-XXX-XXXX. If you have questions about how to file your claim, you should call 1-8XX-XXX-XXXX for assistance.
Another settlement related to medical benefits claims has also been reached. It is possible to be a member of both settlement classes. To get more information about either settlement, visit www.[ ].com or call 1-8XX-XXX-XXXX.
Sincerely,
Notice Administrator
[Spanish Tag/Vietnamese Tag]
Questions? Visit www.[ ].com or call 1-8XX-XXX-XXXX.
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Detailed Notice
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QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM SI DESEA RECIBIR ESTA NOTIFICACIÓN EN ESPAÑOL, LLÁMENOS O VISITE NUESTRA PÁGINA WEB.
(ADD IN TRANSLATED TEXT FOR VIETNAMESE – FIRST PAGE ONLY) 1
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA
If you had economic loss or property damage because of the Deepwater Horizon oil spill,
you could get money from a class action settlement. A federal court directed this Notice. This is not a solicitation from a lawyer.
• Two settlements—one for economic and property damage claims and another for medical claims—have been reached with BP Exploration & Production Inc. and BP America Production Company (“BP”) over the Deepwater Horizon oil spill.
• This Notice explains the Economic & Property Damages Settlement (“E&PD Settlement”).
• If you are included in the Economic & Property Damages Settlement, you may receive money if you have been damaged by the Deepwater Horizon oil spill in one or more of the following categories:
■ Seafood Compensation ■ Vessels of Opportunity Charter Payment ■ Economic Damage ■ Coastal Real Property Damage ■ Loss of Subsistence ■ Wetlands Real Property Damage ■ Vessel Physical Damage ■ Real Property Sales Damage
• There are geographic areas or “Zones” associated with several of these categories. The website www.[ ].com has detailed descriptions and maps to help you determine whether a location may be included in one or more of these zones.
• Payments will be made for most claims as they are received and approved, with the exception of certain Seafood Compensation claims.
• If you are included in the E&PD Settlement (an “E&PD Class Member”), your legal rights are affected whether you act or not. Read this Notice carefully.
E&PD CLASS MEMBERS’ LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
SUBMIT A CLAIM FORM The only way to request a payment under the E&PD Settlement.
EXCLUDE YOURSELF (OPT OUT) Get no benefits from the E&PD Settlement. Requesting exclusion from this Settlement (also called “Opting Out”) would allow you to bring a lawsuit against BP yourself about the legal claims involved in this E&PD Settlement.
OBJECT Write to the Court about why you do not like the E&PD Settlement.
GO TO A FAIRNESS HEARING Ask to speak in Court about the fairness of the E&PD Settlement.
DO NOTHING Get no individual financial benefits from the E&PD Settlement. However, if you are an E&PD Class Member, the terms of the E&PD Settlement will still apply to you.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
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Basic Information ...................................................................................................................................... Page 4 1. Why is this Notice being provided? 2. What is this lawsuit about? 3. What is the Deepwater Horizon Incident? 4. Why is this a class action? 5. Why is there a settlement? 6. Is the Economic & Property Damages Settlement part of the Gulf Coast Claims Facility (GCCF)? 7. What happened to pending or unresolved GCCF claims? 8. What if I received a GCCF final payment and signed a release? 9. If I submitted a Short Form Joinder in the lawsuit, do I still need to file a claim? Who Is In The Settlement ......................................................................................................................... Page 6 10. Who is in the Economic & Property Damages Class? 11. Are there exceptions to being included in the Economic & Property Damages Class? 12. How do I know if I am eligible to receive a payment from the Economic & Property Damages
Settlement? 13. Does the Economic & Property Damages Settlement cover claims for medical benefits? 14. What if I’m still not sure whether I am included in the Economic & Property Damages
Settlement? 15. What happens if I am not included in the Economic & Property Damages Settlement? E&PD Settlement Claims Eligibility And Benefits Chart .................................................................... Page 11 How To Request A Payment—Submitting A Claim Form .................................................................. Page 15 16. How much will an eligible Economic & Property Damages Class Member receive? 17. How do I submit a Claim Form to request payment? 18. Do I need to submit supporting documentation? 19. What if my claim is denied or I am not satisfied with my payment? 20. When will I get my payment? 21. What other benefits does the Economic & Property Damages Settlement provide? 22. What am I giving up to get a payment? Excluding Yourself From the Economic & Property Damages Class ................................................ Page 17 23. If I do not want to participate in the Economic & Property Damages Settlement, what must I do? 24. If I exclude myself, can I get anything from this Settlement? 25. If I exclude myself from the Economic & Property Damages Settlement, can I still make an Oil
Pollution Act claim with BP directly? 26. If I do not exclude myself, can I sue BP later? 27. If I exclude myself from the Economic & Property Damages Settlement, can I change my mind
later?
WHAT THIS NOTICE CONTAINS
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Objecting To the Settlement ................................................................................................................... Page 18 28. How do I tell the Court if I do not like the Economic & Property Damages Settlement? 29. What is the difference between objecting to, and asking to be excluded from, the Economic &
Property Damages Settlement? The Lawyers Representing You ............................................................................................................. Page 19 30. Do I have a lawyer in this case? 31. How will the lawyers be paid? The Court’s Fairness Hearing ................................................................................................................ Page 20 32. When and where will the Court decide whether to approve this Economic & Property Damages
Settlement? 33. Do I have to come to the Fairness Hearing? If You Do Nothing ................................................................................................................................... Page 21 34. What happens if I do nothing? Getting More Information ...................................................................................................................... Page 21 35. How do I get more information?
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BASIC INFORMATION
You have a right to know about a proposed settlement of this class action lawsuit and about your options relating to the proposed Settlement. This Notice explains the lawsuit, the E&PD Settlement, your legal rights, what benefits are available, who may be eligible for those benefits, and how to get them.
This Notice does not provide any information related to the Medical Benefits Settlement. For more information about the Medical Benefits Settlement, and to determine whether your rights are affected by that settlement, or whether you are eligible for benefits under that settlement, visit www.[ ].com, or call 1-8XX-XXX-XXXX.
Judge Carl J. Barbier of the United States District Court for the Eastern District of Louisiana is overseeing this class action. The case is known as In re: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf of Mexico on April 20, 2010, MDL No. 2179. The people who started the lawsuit are called “Plaintiffs,” and BP is among the companies being sued.
Capitalized terms are defined terms in the E&PD Settlement Agreement, which is available on the website.
Do not call the Court or any Judge’s office to ask questions about the E&PD Settlement. If you have questions or if you want more information, please visit www.[ ].com or call 1-8XX-XXX-XXXX.
The lawsuit asserts certain economic loss and property damage claims arising out of the “Deepwater Horizon Incident” (see Question 3) in the Gulf of Mexico beginning on April 20, 2010. The Plaintiffs seek money and other relief for economic and property damage they allege was caused by the Deepwater Horizon Incident. BP disputes and denies Plaintiffs’ claims in that lawsuit.
“Deepwater Horizon Incident” refers to the events, actions, inactions, and omissions leading up to and including:
• The blowout of the MC252 Well (also known as the “Macondo well”) on April 20, 2010; • The explosions and fire on board the Deepwater Horizon oil rig; • The sinking of the Deepwater Horizon oil rig on April 22, 2010; • The release of oil and other substances from the MC252 Well and/or the Deepwater Horizon oil
rig and its appurtenances (equipment); • The efforts to contain the MC252 Well; • All “Response Activities” including the “Vessels of Opportunity” (“VoO”) program; • The operation of the “Gulf Coast Claims Facility” (“GCCF”); and • BP’s public statements relating to all of the above.
3. What is the Deepwater Horizon Incident?
2. What is this lawsuit about?
1. Why is this Notice being provided?
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In a class action, one or more people called “Class Representatives” sue on behalf of people who have similar claims. All of the people and businesses that have similar claims to the class representatives are a “class,” or in this instance “Economic & Property Damages Settlement Class Members” (“E&PD Class Members”). One court resolves the issues for all class members.
The Court has not decided the case in favor of Plaintiffs or BP. Instead, after extensive, arm’s length negotiations, the Plaintiffs and BP have agreed to settle this case to avoid the cost, delay, and risk of a trial. The Class Representatives and their lawyers think the proposed E&PD Settlement is best for all E&PD Class Members.
No. The GCCF has been closed. The new Deepwater Horizon Court-Supervised Settlement Program (“Settlement Program”) has been established under the E&PD Settlement. By the agreement of the parties, the new program operates according to specific, agreed-upon rules and under the supervision of the Court. If you had a claim rejected or denied by the GCCF, it will not affect your eligibility or right to receive a payment under the E&PD Settlement. If you had a claim paid by the GCCF, and you did not sign a release (see Question 8), you may still be eligible to receive a payment under the E&PD Settlement.
All pending and unresolved GCCF claims, including all documents related to those claims, have been transferred to the new Settlement Program. The Settlement Program is processing these claims under the rules of the E&PD Settlement. If additional information is needed to process your claim, you will be contacted. If you have a specific question about the status of a GCCF claim, you can call the Settlement Program at 1-8XX-XXX-XXXX for assistance.
If you made a claim to the GCCF, received payment for that claim, and signed a document called, “Release and Covenant Not to Sue,” you are not eligible to receive money from most parts of the E&PD Settlement. However, you may still be eligible to submit a VoO Charter Payment claim or a Vessel Physical Damage claim (see the E&PD Settlement Claims Eligibility and Benefits Chart below for details of VoO Charter Payments and Vessel Physical Damage claims.) You may also still be eligible to participate in the separate Medical Benefits Settlement. If your GCCF claim and the “Release and Covenant Not to Sue” related only to a bodily injury claim, you may still be able to participate in the E&PD Settlement.
8. What if I received a GCCF final payment and signed a release?
7. What happened to pending or unresolved GCCF claims?
6. Is the Economic & Property Damages Settlement part of the Gulf Coast Claims Facility (GCCF)?
5. Why is there a settlement?
4. Why is this a class action?
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Yes. Even if you submitted a special short form (“Short Form Joinder”) as part of the lawsuit against BP, you still must submit a Claim Form and provide all required documentation to request a payment from the Settlement Program (see Question 17).
WHO IS IN THE SETTLEMENT
To see if you will be affected by the E&PD Settlement or if you can get a payment from it, you first have to determine if you are an E&PD Class Member.
The E&PD Class includes individuals, businesses, and other entities. Please answer the series of questions below to see if you may be an E&PD Class Member. The first set of questions is for individuals and the second set of questions is for businesses and other entities. The definitions below will help you when answering the questions.
• “Gulf Coast Areas” include the States of Louisiana, Mississippi, and Alabama; the counties of Chambers, Galveston, Jefferson, and Orange in the State of Texas; and the counties of Bay, Calhoun, Charlotte, Citrus, Collier, Dixie, Escambia, Franklin, Gadsden, Gulf, Hernando, Hillsborough, Holmes, Jackson, Jefferson, Lee, Leon, Levy, Liberty, Manatee, Monroe, Okaloosa, Pasco, Pinellas, Santa Rosa, Sarasota, Taylor, Wakulla, Walton, and Washington in the State of Florida. “Gulf Coast Areas” also includes all adjacent Gulf waters, bays, estuaries, straits, and other tidal or brackish waters within the States of Louisiana, Mississippi, and Alabama, and those described counties of Texas or Florida.
• “Specified Gulf Waters” means the U.S. waters of the Gulf of Mexico and all adjacent bays, estuaries, straits, and other tidal or brackish waters within the Gulf Coast Areas.
• “Entity” means an organization or entity, other than a Governmental Organization, operating or having operated for profit or not-for-profit, including a partnership, a corporation, a limited liability company, an association, a joint stock company, a trust, a joint venture, or an unincorporated association of any kind or description.
• “Consumer” means a Natural Person or an Entity that buys any product for individual use or consumption and not for manufacture or resale.
• “End User” means a Natural Person or Entity that buys any product for his, her, or its individual use or consumption and not for manufacture or resale.
10. Who is in the Economic & Property Damages Class?
9. If I submitted a Short Form Joinder in the lawsuit, do I still need to file a claim?
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Questions for Individuals Yes No
Do you live in the U.S.?
Continue to next question.
You are not an E&PD Class Member.
Did you live in, work in, were offered and accepted work in, own or lease property in, or own, lease, or work on a vessel harbored or home-ported in the Gulf Coast Areas or Specified Gulf Waters at any time between April 20, 2010, and April 16, 2012?
OR
Did you work on a vessel in Specified Gulf Waters at any time between April 20, 2010 and April 16, 2012 that landed Seafood in the Gulf Coast Areas after April 20, 2009?
Continue to next question.
You are not an E&PD Class Member.
Do you have any economic loss arising out of the Deepwater Horizon Incident? OR Was your real or personal property damaged as a result of the Deepwater Horizon Incident?
Continue to next question.
You are not an E&PD Class Member.
Do your claims for economic loss or property damage meet the descriptions of one or more of these categories:
(1) Seafood Compensation
(2) Economic Damage
(3) Loss of Subsistence
(4) Vessels of Opportunity (“VoO”) Charter Payment
(5) Vessel Physical Damage
(6) Coastal Real Property Damage
(7) Wetlands Real Property Damage
(8) Real Property Sales Damage
You may be an E&PD Class Member. Continue to Eligibility and Benefits Chart beginning on page 11 of this Notice to determine whether you may be eligible for a payment.
You are not an E&PD Class Member.
Individuals may also be included in the Medical Benefits Settlement if they were Clean-Up Workers or were residents in certain defined areas or “Zones.” More information on the Medical Benefits Settlement is available on the website or by calling 1-8XX-XXX-XXXX.
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Questions for Businesses and Other Entities Yes No
(1) Did your business or Entity own, operate, or lease a physical facility or vessel in the Gulf Coast Areas or Specified Gulf Waters between April 20, 2010 and April 16, 2012, and
Sell products in the Gulf Coast Areas or Specified Gulf Waters: (a) directly to Consumers or End Users of those products; or (b) to another Entity that sold those products to Consumers or End Users of those products?
or
Regularly purchase Seafood harvested from Specified Gulf Waters in order to produce goods for resale?
OR
(2) Was your business or Entity a service business with one or more full-time employees (including owner-operators) who performed full-time services while physically present in the Gulf Coast Areas or Specified Gulf Waters between April 20, 2010 and April 16, 2012?
OR
(3) Did your business or Entity own, operate, or lease a vessel that (a) was home ported in the Gulf Coast Areas at any time from April 20, 2010 to April 16, 2012, or (b) landed Seafood in the Gulf Coast Areas at any time from April 20, 2009 to April 16, 2012?
OR
(4) Did your business or Entity own or lease real property in the Gulf Coast Areas between April 20, 2010 and April 16, 2012?
Continue to next question.
You are not an E&PD Class Member.
Do your business’s or Entity’s claims for economic loss or property damage meet the descriptions one or more of these categories:
(1) Seafood Compensation
(2) Economic Damage
(3) Vessels of Opportunity (“VoO”) Charter Payment
(4) Vessel Physical Damage
(5) Coastal Real Property Damage
(6) Wetlands Real Property Damage
(7) Real Property Sales Damage
You may be an E&PD Class Member. Continue to Eligibility and Benefits Chart beginning on page 11 of this Notice to determine whether you may be eligible for a payment.
You are not an E&PD Class Member.
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Yes. The following individuals and entities are excluded from the E&PD Class:
• Anyone who excludes themselves from (“Opts Out” of) the E&PD Class; • Defendants in MDL 2179 and certain current and former employees of BP and other Defendants
in MDL 2179; • The Court, including any sitting judges on the United States District Court for the Eastern
District of Louisiana, their law clerks serving during the pendency of this lawsuit, and members of any such judge’s or current law clerk’s immediate family;
• Governmental Organizations; and • Individuals and Entities that received a payment from the GCCF and signed a “Release and
Covenant Not To Sue” (although these Individuals and Entities may still make a VoO Charter Payment claim or a Vessel Physical Damage claim). See Questions 6-8.
In addition, the following types of Entities and their employees are excluded, to the extent these Entities and/or their employees claim economic losses based on their employment by such Entity:
• Certain Financial Institutions; • Certain Funds, Trusts, and Other Financial Vehicles; • Certain Gaming Entities; • Certain Insurance Entities; • Certain Oil & Gas Industry Entities; • Certain Defense Contractors; • Certain Real Estate Developers; and • Any Entity selling or marketing BP-branded fuel, including jobbers and branded dealers.
Individuals and Entities in these above-listed industries may be eligible for payments under certain categories of economic losses not related to these industries, such as Coastal Real Property Damage and Wetlands Real Property Damage. See the Settlement Agreement or call 1-8XX-XXX-XXXX for more information.
The following claims are also not included in the E&PD Settlement: • Bodily Injury Claims; • BP Shareholder Claims; • Moratoria Loss Claims; • Claims relating to menhaden (or “pogy”) fishing, processing, selling, catching, or harvesting; • Claims for Economic Damage by Entities or Individuals based on employment in the Banking,
Gaming, Financial, Insurance, Oil & Gas, Real Estate Development, and Defense Contractor industries, as well as Entities selling or marketing BP-branded fuel (including jobbers and branded dealers); and
• Claims for punitive damages against Halliburton and Transocean. See Question 21. You may still pursue these claims even if you remain in the E&PD Class. The full description of the Entities, individuals, and claims that are excluded from the E&PD Class can be found on the website or by calling 1-8XX-XXX-XXXX.
11. Are there exceptions to being included in the Economic & Property Damages Class?
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There are separate eligibility rules for each of the claim categories in the E&PD Settlement. The Settlement Claims Eligibility and Benefits Chart beginning on page 11 of this Notice illustrates who may be eligible to receive a payment in each category. A number of these categories include geographic zones. Visit the website to review detailed zone maps.
No. The E&PD Settlement does not include claims for medical benefits. If you suffer from medical conditions arising out of the Deepwater Horizon Incident, you may also be eligible to participate in the Medical Benefits Settlement. More information about the Medical Benefits Settlement is available on the website or by calling 1-8XX-XXX-XXXX.
If you are not sure whether you are in the E&PD Class, or have any other questions about the E&PD Settlement, visit the settlement website at or call the toll-free number, 1-8XX-XXX-XXXX. You may also write with questions to XXXXXXXXXXXXXXXXXX, PO Box XXXX, City, State XXXXX-XXXX or send an e-mail to info@[ ].com.
If you are not an E&PD Class Member, you are not included in the E&PD Settlement. However, you may still be included in the Medical Benefits Settlement (see Question 13). Also, if you are not included in the E&PD Settlement, you may file an Oil Pollution Act claim with BP directly. You can get more information about filing an Oil Pollution Act claim directly with BP by visiting www.[ ].com or calling 1-8XX-[OPANUMBER].
15. What happens if I am not included in the Economic & Property Damages Settlement?
14. What if I’m still not sure whether I am included in the Economic & Property Damages Settlement?
13. Does the Economic & Property Damages Settlement cover claims for medical benefits?
12. How do I know if I am eligible to receive a payment from the Economic & Property Damages Settlement?
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E&PD SETTLEMENT CLAIMS ELIGIBILITY AND BENEFITS CHART
Claim Category Eligibility Requirements Potential Benefits
Seafood Compensation Claim
Claims for economic loss related to Seafood can be made by Individuals and Entities that qualify as Commercial Fishermen, Seafood Boat Captains, Seafood Crew (including first mates, second mates, boatswains, and deckhands), Oyster Leaseholders, and Seafood Vessel Owners. Claims may be submitted in the following categories:
• Shrimp; • Oyster (including leaseholder interest and lost income claims); • Finfish (including IFQ holders); • Blue Crab and Other Fish; and • Seafood Crew (excluding Boat Captains)
Claimants may seek compensation under more than one Seafood Compensation claim category, but all claims must be submitted on a single Seafood Compensation Claim Form.
The Seafood Compensation claim deadline is earlier than the claim deadline for all other claims in the E&PD Settlement. The deadline to submit a Seafood Compensation Claim Form is 30 days after entry and judgment of the Court’s final approval of the E&PD Settlement. The exact date of the claim deadline will be posted on the website.
BP will pay at least $2.3 billion in total for economic loss related to Seafood under the Seafood Compensation Program under a process approved by the Court-appointed Neutral, John W. Perry, Jr.
The payment amount for Seafood Compensation claims varies by type of claim submitted.
Any money previously received from BP or the GCCF for spill-related Seafood claims (excluding VoO claims) will be deducted from the Settlement payment.
An RTP* multiplier may be applied to payments for all claim categories other than IFQ holders and certain Seafood Crew.
All Seafood Compensation claims will be paid as they are received and approved, except for some Seafood Crew claims that will be determined after the Seafood Compensation claim deadline and paid as soon as possible by the Claims Administrator.
* The “Risk Transfer Premium” (“RTP”) increases the payment amount for certain E&PD Class Members whose losses could be recurring, to account for the risk of future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.
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Economic Damage Claim
Claims for economic damage can be made by Individuals and Entities in certain industries or geographic zones that lost profits or earnings as a result of the Deepwater Horizon Incident.
Depending on their industry or geographic zone, some Individuals and Entities may need to provide evidence that their economic losses were caused by the Deepwater Horizon Incident.
For more details on eligible Economic Damage claims, please visit the Settlement website.
In general, the payment amount for Economic Damage claims is calculated by comparing actual post-spill earnings to the earnings that might have been expected in that post-spill period. There are also considerations for specialized circumstances, such as start-up businesses, failed businesses, multi-facility businesses, new entrants to employment, and festival vendors.
An RTP* multiplier will be applied to the payments for some types of Economic Damage claims.
Any money previously received from BP or the GCCF for the same economic loss will be deducted from the Settlement payment.
Loss of Subsistence Claim
Claims for loss of subsistence can be made by Individuals who fished or hunted in certain geographic regions to harvest, catch, barter, consume, or trade Gulf of Mexico natural resources, including Seafood and Game, in a traditional or customary manner to sustain their basic or family dietary, economic security, shelter, tool or clothing needs, and who relied upon subsistence resources that were diminished or restricted in the geographic region used by the claimant due to the Deepwater Horizon Incident.
Those who fish or hunt solely for pleasure or sport are not eligible to make claims for subsistence, regardless of whether or not they consume their catch.
Payments will be based on the retail value of the Seafood and Game lost between April 20, 2010 and December 31, 2011.
An RTP* multiplier will be applied to payments for Loss of Subsistence claims, in part to account for the damage to subsistence family and community customs and culture.
VoO Charter Payment Claim
Claims for economic loss caused by participation in the VoO program (regardless of whether dispatched or asked to perform work) can be made by those who:
Registered to participate in the VoO program;
Executed a VoO Master Vessel Charter Agreement; and
Completed the initial VoO training program.
For claimants who were dispatched or asked to perform work in the VoO program, payment amounts will range from $41,600 to $88,400, depending on vessel length.
For claimants who completed the initial VoO training program but were never dispatched or asked to perform work in the VoO program, payment amounts will range from $4,800 to $10,200, depending on vessel length.
* The “Risk Transfer Premium” (“RTP”) increases the payment amount for certain E&PD Class Members whose losses could be recurring, to account for the risk of future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.
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Vessel Physical Damage Claim
Individuals and Entities who were owners of an eligible vessel between April 20, 2010 and December 31, 2011 may recover for physical damage resulting from the Deepwater Horizon Incident or certain response clean-up operations, including the cost of removal of equipment or rigging added to an eligible vessel as part of response activities.
Payment is not available to claimants who:
• Signed a Receipt and Release Letter Agreement for damage reimbursement as part of the VoO program; or
• Sustained damage to vessels while working for any oil spill response organization or an oil spill removal organization (other than the VoO program).
Qualifying claimants will receive the lesser of the reasonable and necessary costs to repair or replace an eligible vessel.
Coastal Real Property Damage Claim
Individuals and Entities who owned or leased coastal real property or boat slips located in certain geographical areas at any time from April 20, 2010 to December 31, 2010, can make claims for damage to that property.
In addition, for coastal real property located in certain geographic areas, owners of real or personal property that was physically damaged in connection with the Deepwater Horizon Incident response cleanup operations can make claims for Physical Damage.
Payment amounts range from 30% to 45% of the parcel’s standardized 2010 applicable property tax amount, depending on its location and environmental sensitivity.
An RTP* multiplier will be applied to payments for Coastal Real Property Damage claims.
Payment for Response Operations Physical Damage is equal to the cost to either repair or replace the damaged property, whichever is lower.
* The “Risk Transfer Premium” (“RTP”) increases the payment amount for certain E&PD Class Members whose losses could be recurring, to account for the risk of future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.
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Real Property Sales Damage Claim
Real Property Sales Damage claims can be made by sellers of residential property located in certain geographic areas if:
• The seller owned the property on April 20, 2010; and
• The sale of the property closed between April 21, 2010 and December 31, 2010. The sales contract must have been: (1) executed on or after April 21, 2010, or (2) executed before April 21, 2010, but subject to a price reduction due to the Deepwater Horizon Incident.
Transfers of residential real property from borrowers to lenders as part of the foreclosure process are not included.
Payment amounts will include 12.5% of the sale price of the qualifying residential property, less any prior compensation that the claimant previously received from BP or the GCCF in connection with the same property.
For shared properties, this amount will be divided based on the claimant’s ownership interest.
Wetlands Real Property Damage Claim
Individuals and Entities who owned wetlands real property located in certain geographic areas at any time between April 20, 2010 and April 16, 2012, can make claims for Wetlands Real Property Damage.
In addition, owners of real or personal property, on wetlands real property located in certain geographic areas that was physically damaged by the Deepwater Horizon Incident response cleanup operations, can make claims for Physical Damage.
Payments will range between $4,500 and $25,000 per acre of certain shoreline or buffer areas based on whether the presence of oil was observed by various official assessments.
Payment for Physical Damage is equal to the cost to either repair or replace the damaged property, whichever is lower.
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HOW TO REQUEST A PAYMENT—SUBMITTING A CLAIM FORM
The amount of your payment will be based on the type of claim you have (see E&PD Settlement Claims Eligibility and Benefits Chart beginning on page 11 of this Notice). Complete information on all of the E&PD Settlement benefits is available on the website.
If you receive a payment for an Economic Damage or Seafood Compensation claim, you may also be eligible for payment of specified professional accounting services used to prepare your claim under a reimbursement framework. Visit the website for information on the accounting services reimbursement process.
If you have questions about how the value of your potential claim will be determined, you can call 1-8XX-XXX-XXXX for assistance.
If you are an E&PD Class Member, you must complete and submit a Claim Form to request a payment. Each claim category has its own specific Claim Form with detailed instructions, including the types of supporting documentation required. A Claim Form package is available on the website, or can be sent to you by mail by calling 1-8XX-XXX-XXXX.
To submit a Claim Form, you must mail it to the address below or file your Claim online on the website. If you have questions about how to file your claim, you should call 1-8XX-XXX-XXXX for assistance. Claim Offices will also be open across the Gulf Coast to help Class Members file claims. Please visit the website or call 1-8XX-XXX-XXXX for the location of the Claim Offices.
The address for mailing your Claim Form(s) is:
_____________ Settlement PO Box XXX City, State XXXXX-XXXX
You may be eligible to file a claim under more than one category. You do not need to submit your claims under all categories at one time. However, once you receive your first payment under the Settlement Program, you must file any and all additional claims within six months from the date of that first payment.
All claims for Seafood Compensation must be made in a single Seafood Compensation Claim Form. The deadline to submit a Seafood Compensation Claim Form is 30 days after entry and judgment of the Court’s final approval. This deadline is earlier than the claims deadline for all other claims in the E&PD Settlement. The exact date of the claim filing deadline will be posted on the website.
The deadline for filing a Claim Form for all claims other than Seafood Compensation claims is April 22, 2014, or six months after the E&PD Settlement becomes effective (i.e. after the Court grants “final approval” and any appeals are resolved). The exact date of the claim filing deadline will be posted on the website. It is highly recommended that E&PD Class Members complete and submit their Claim Form promptly. If you do not submit a Claim Form on time you will lose the opportunity to apply for a payment from the E&PD Settlement.
17. How do I submit a Claim Form to request payment?
16. How much will an eligible Economic & Property Damages Class Member receive?
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Yes. You will need to include certain supporting documents for your claim to be accepted. Please read the Claim Form instructions carefully. If you have any questions about preparing the Claim Form, call 1-8XX-XXX-XXXX.
The E&PD Settlement provides a process to resolve disagreements about how much money you should get. You will get further details in the letter you receive with your payment. If your claim is denied, or if you are not satisfied with the amount of your payment, you may file an appeal. In cases of an award above $25,000, BP also has the right to appeal. The website will have an appeal form and further explanation of the appeals process. Please note that there is no appeals process for some Seafood Compensation claims.
In general, valid claims will be paid as they are received and approved, except for certain Seafood Compensation claims. Certain Seafood Crew claims for Seafood Compensation will be paid after the Seafood Compensation claim deadline, after all such Seafood Crew claims have been processed.
The E&PD Settlement includes the creation of a new $57 million fund to promote tourism and the seafood industry in Gulf Coast areas affected by the Deepwater Horizon Incident.
In addition, BP is giving to the E&PD Class the right to pursue certain claims against Transocean and Halliburton for the benefit of the E&PD Class. If successful, any proceeds from such claims will be used for the benefit of the class in a manner to be approved by the Court.
If you accept a payment in the E&PD Settlement, you will give up your right to sue BP or the Released Parties (identified in Section 10 of the Settlement Agreement) regarding all of the claims resolved by the E&PD Settlement, as described more fully in Section 10 of the E&PD Settlement Agreement.
However, you will NOT give up your right to sue BP or any of the Released Parties for any other claims (i.e. any claims that were not resolved by the E&PD Settlement).
The full text of the Settlement Agreement is available on the website. The Settlement Agreement describes the released claims with specific descriptions in legal terminology, so read it carefully. If you have any questions about the released claims and what they mean, you can talk to the law firms representing the E&PD Class, listed in Question 30 below, for free; or you can, at your own expense, talk to your own lawyer.
22. What am I giving up to get a payment?
21. What other benefits does the E&PD Settlement provide?
20. When will I get my payment?
19. What if my claim is denied or I am not satisfied with my payment?
18. Do I need to submit supporting documentation?
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EXCLUDING YOURSELF FROM THE ECONOMIC & PROPERTY DAMAGES CLASS
If you do not want to participate in the E&PD Settlement and you want to keep all of your rights to sue BP and any of the Released Parties about the claims being resolved in the E&PD Settlement, then you must take steps to get out of the E&PD Class. This is called asking to be excluded from, or sometimes called “Opting Out” of, the class.
To exclude yourself or your Entity from (or Opt Out of) the E&PD Class, you must mail in a written request stating “I wish to be excluded from the Economic & Property Damages Class.” Your written request must also include your printed name, address and phone number, and must be signed by you. You must mail your written request postmarked by Month Day, 2012, to: Deepwater Horizon Court-Supervised Settlement Exclusions Department PO Box 222 Hammond, LA 70404-0222 You cannot ask to be excluded from the E&PD Settlement on the phone, by email, or on the website.
If you choose to Opt Out of the Economic Class, you must Opt Out for all claims you have that are included in the E&PD Settlement. You do not have to Opt Out of the E&PD Settlement in order to preserve or pursue:
• Bodily Injury Claims; • BP Shareholder Claims; • Moratoria Loss Claims; • Claims arising from the fishing, processing, selling, catching, or harvesting of menhaden or
“pogy” fish; • Certain Oil & Gas Industry Claims; • Certain Gaming Industry Claims; • Certain Banking, Financial and/or Insurance Industry Claims; • Economic Damage claims based on employment in the following industries:
o Banking, Financial and/or Insurance; o Oil & Gas; o Gaming;
• Claims for punitive damages against Halliburton and Transocean.
No. If you exclude yourself from the E&PD Settlement, you will not be able to make a claim to receive any payment under the E&PD Settlement, and you cannot object to the proposed E&PD Settlement. If you exclude yourself, however, you may sue or be part of a different lawsuit against BP in the future. You will not be bound by anything that happens in this lawsuit.
24. If I exclude myself, can I get anything from this Settlement?
23. If I do not want to participate in the Economic & Property Damages Settlement, what must I do?
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Yes. Individuals, businesses, and Entities that exclude themselves from the E&PD Settlement may file Oil Pollution Act claims directly with BP. You can get more information about filing an Oil Pollution Act claim directly with BP by visiting www.[ ].com or calling 1-8XX-[OPANUMBER].
No. If you are an Economic & Property Damages Class Member and you do not exclude yourself, you give up the right to sue BP or any of the Released Parties for the claims that the E&PD Settlement resolves.
Yes. You have the right to request to withdraw (“revoke”) your decision to Opt Out of the E&PD Settlement as long as you do it by Month Day, 20YY, as described more fully in Section 8 of the E&PD Settlement Agreement. In some cases you may be able to revoke your request to Opt Out of the E&PD Settlement after Month Day 20YY, but BP must agree to any request received after this date and there is no guarantee they will do so. Please visit the website or call 1-8XX-XXX-XXXX for details about how to revoke an Opt Out.
OBJECTING TO THE SETTLEMENT
Only an E&PD Class Member can object to the E&PD Settlement. If you are an E&PD Class Member, you can object to the E&PD Settlement if you do not like all or some part of it. To object, send a letter explaining your objection to the proposed Economic & Property Damages Settlement in In re: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf of Mexico on April 20, 2010, MDL No. 2179. Your objection letter must include:
1) A detailed statement of each objection being made, including the specific reasons for each objection, and any evidence or legal authority to support each objection;
2) Your name, address, and telephone number; 3) Written evidence establishing that you are an E&PD Class Member, such as proof of residency,
proof of ownership of property, and/or proof of business incorporation and operation; and 4) Any supporting papers, materials, or briefs that you want the Court to consider when reviewing
the objection.
An E&PD Class Member may also object through an attorney hired at his, her, or its own expense. The attorney will have to file a notice of appearance with the Court by Month Day, 2012, and serve a copy of the notice and the objection containing the information detailed above on E&PD Class Counsel and BP’s Counsel by Month Day, 2012.
Objections must be sent by first class mail to the following addresses postmarked by Month Day, 2012. Objections submitted after this date will not be considered.
28. How do I tell the Court if I do not like the Economic & Property Damages Settlement?
27. If I exclude myself from the Economic & Property Damages Settlement, can I change my mind later?
26. If I do not exclude myself, can I sue BP later?
25. If I exclude myself from the Economic & Property Damages Settlement, can I still make an Oil Pollution Act claim with BP directly?
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Do not call the Court or any Judge’s office to object to the E&PD Settlement. If you have questions, please visit www.[ ].com or call 1-8XX-XXX-XXXX.
Objecting is simply telling the Court that you do not like something about the E&PD Settlement. You can object only if you stay in the E&PD Class. Excluding yourself, also called Opting Out, is telling the Court that you do not want to be part of the E&PD Class. If you exclude yourself, you cannot object to the E&PD Settlement and you will not be eligible to apply for a payment under the E&PD Settlement.
THE LAWYERS REPRESENTING YOU
The Court has appointed [___________] as “Economic & Property Damages Class Counsel” to represent the E&PD Class Members. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your own expense.
ECONOMIC & PROPERTY DAMAGES CLASS COUNSEL DEFENDANTS’ COUNSEL COURT
James Parkerson Roy Attn: Deepwater Horizon E&PD Settlement Domengeaux Wright Roy & Edwards 556 Jefferson St., Suite 500 P.O. Box 3668 Lafayette, LA 70501
Stephen J. Herman Attn: Deepwater Horizon E&PD Settlement Herman Herman Katz & Cotlar LLP 820 O’Keefe Avenue New Orleans, LA 70113
Richard C. Godfrey, P.C. Attn: Deepwater Horizon E&PD Settlement Kirkland & Ellis LLP 300 North LaSalle Street Chicago, IL 60654
Clerk of Court United States District Court for the Eastern District of Louisiana 500 Poydras Street New Orleans, LA 70130
30. Do I have a lawyer in this case?
29. What is the difference between objecting to, and asking to be excluded from, the Economic & Property Damages Settlement?
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E&PD Class Counsel will ask the Court to consider an award of fees, costs, and expenses, including an interim payment of $75 million and additional awards equal to 6% of class claims and benefits paid, and a maximum of $600 million. Class Counsel fees, costs and expenses under the Economic and Property Damages Settlement Agreement and the Medical Settlement Agreement jointly cannot exceed $600 million.
Class members’ payments will not change if the Court approves the payment of Class Counsel fees under either settlement, because BP will separately pay these amounts.
THE COURT’S FAIRNESS HEARING
The Court will hold a Fairness Hearing at ___ _.m. on Month Day, 2012, at the United States District Court for the Eastern District of Louisiana, Court Room No. ___, 500 Poydras Street, New Orleans, LA 70130. At the Fairness Hearing, the Court will consider whether the proposed E&PD Settlement is fair, reasonable, and adequate. The Court will also consider Class Counsel’s request for fees, costs and expenses described in Question 31.
If there are objections to the E&PD Settlement, the Court will consider them. After the Fairness Hearing, the Court will decide whether to approve the E&PD Settlement and how much to award to Economic & Property Damages Class Counsel as fees, costs and expenses.
The Fairness Hearing may be moved to a different date, time, or location without additional notice, so it is recommended that you periodically check the website for updated information.
No. E&PD Class Counsel will answer any questions the Court may have. However, you are welcome to attend the hearing at your own expense. If you send in a written objection, you do not have to come to the Fairness Hearing to talk about it. As long as you mailed your written objection on time, the Court will consider it.
If you, or an attorney you have hired at your own expense, wish to speak at the Fairness Hearing, you must by Month Day, 2012, file with the Court and send by first-class mail to E&PD Class Counsel and BP’s Counsel at the addresses listed in Question 28, a written notice of your intention to speak at the Fairness Hearing. Be sure to include your name, address, telephone number, and your signature. Do not call the Court or any Judge’s office to get more information about the E&PD Settlement. If you have questions, please visit the website or call 1-8XX-XXX-XXXX.
33. Do I have to come to the Fairness Hearing?
32. When and where will the Court decide whether to approve this Economic & Property Damages Settlement?
31. How will the lawyers be paid?
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IF YOU DO NOTHING
If you are an E&PD Class Member and do nothing, you will not get a payment from this E&PD Settlement. And, unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against BP or the Released Parties about the claims being released by the E&PD Settlement.
However, even if you take no action, you will keep your right to sue BP or any of the Released Parties for any other claims not resolved by the E&PD Settlement.
GETTING MORE INFORMATION
This Notice summarizes the proposed E&PD Settlement. More details are in the E&PD Settlement Agreement. You can get a copy of the E&PD Settlement Agreement on the website. You also may write with questions to XXXXXXXXXXXXXXXX, PO Box XXXX, City, State XXXXX-XXXX or send an e-mail to info@[ ].com. You can get a Claim Form on the website, or have a Claim Form mailed to you by calling 1-8XX-XXX-XXXX.
Do not call the Court or any Judge’s office to get more information about the E&PD Settlement. If you have questions, please visit the website or call 1-8XX-XXX-XXXX.
34. How do I get more information?
34. What happens if I do nothing?
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Mailing Envelope
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Notice Administrator for U.S. District Court Post Office Box NNNN City, ST NNNNN-NNNN
123456789
John Q. Doe1234 Main St.City, ST 00000
PRESORTEDFIRST-CLASS MAIL
US POSTAGEPAID
CITY, STPERMIT # 000
DEEPWATER HORIZON
Economic and Property Damages
Settlement
If you had economic loss
or property damage
because of the Deepw
ater H
orizon oil spill, you could get m
oney from a class
action settlement.
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Attachment 1B: Email Notice
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To: [email address] From: administrator@[ ].com [Notice Administrator for U.S. District Court] Reply To: info@[ ].com [Deepwater Horizon Settlement] Subject: Court-Directed Legal Notice about Deepwater Horizon Economic and Property Damages Settlement
Para obtener una notificación en español, póngase en contacto con nosotros o visite nuestra sitio www.[ ].com [Vietnamese call out here.]
Legal Notice
If you had economic loss or property damage because of the Deepwater Horizon oil spill, you could get money from a class action settlement. If you have economic loss or property damage because of the Deepwater Horizon oil spill, you could get money from a class action settlement with BP Exploration & Production Inc. and BP America Production Company (“BP”). Go to www.[ ].com (embedded link) for more information, including information on how to file a claim. Who is Included in the Economic & Property Damages Settlement? You have received this notice because you have been identified as a potential Economic and Property Damages Settlement Class Member. The Economic and Property Damages (“E&PD”) Settlement Class includes people, businesses, other entities, and properties in the states of Louisiana, Alabama and Mississippi, and certain counties in Texas and Florida, that were harmed by the oil spill. The website www.[ ].com (embedded link) has detailed descriptions and maps to help you determine whether a geographic location may be included in the E&PD Settlement. Additionally, you can call [1-8XX-XXX-XXXX] or e-mail info@[ ].com to find out if a geographic location is included. What does the Economic & Property Damages Settlement Provide? The E&PD Settlement makes payments for the following types of claims: (1) Seafood Compensation, (2) Economic Damage, (3) Loss of Subsistence, (4) Vessel Physical Damage, (5) Vessels of Opportunity Charter Payment, (6) Coastal Real Property Damage, (7) Wetlands Real Property Damage, and (8) Real Property Sales Damage. There is no limit on the total dollar amount of the E&PD Settlement; all qualified claims will be paid. How to Get Benefits from the Economic & Property Damages Settlement You need to submit a Claim Form to request a payment. You can get a copy of the various Claim Forms by visiting the website or by calling 1-8XX-XXX-XXXX. Claims can be submitted online or by mail. If you have questions about how to file your claim, you should call the toll-free number for assistance. The deadline to submit most claims will be April 22, 2014 or six months after the E&PD Settlement becomes effective (i.e., after the Court grants “final approval” and any appeals are resolved), whichever is later. Seafood Compensation claims must be submitted no later than 30 days after final approval of the settlement (regardless of
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E&PD Settlement E-mail Notice, Page 2 of 2
appeals). Actual claim filing deadlines will be posted on the website as they become available. Valid claims will be paid as they are approved, beginning on Month 00, 2012. It is highly recommended that E&PD Settlement Class Members complete and submit their claim forms promptly. Please read the Medical Benefits Settlement notice because you may also be eligible for benefits from that settlement. Your Other Options If you do not want to be legally bound by the E&PD Settlement, you must opt out (exclude yourself) by Month 00, 2012 or you won’t be able to sue BP over certain economic and property damages claims. If you stay in the E&PD Settlement, you may object to it by Month 00, 2012. The Detailed Notice (hyperlink to Detailed Notice) explains how to exclude yourself or object. The Court will hold a hearing on Month 00, 2012 to consider whether to approve the E&PD Settlement. You or your own lawyer may ask to appear and speak at the hearing at your own cost. The Court will also consider Class Counsel fees, costs, and expenses including an interim payment of $75 million and additional awards equal to 6% of class claims and benefits paid, and a maximum of $600 million. Class Counsel fees, costs and expenses under the Economic and Property Damages Settlement Agreement and the Medical Benefits Settlement Agreement jointly cannot exceed $600 million. Class members’ payments will not change if the Court approves the payment of Class Counsel fees under either settlement, because BP will separately pay these amounts. For more information and a Claim Form, visit www.[ ].com (embedded link) or call toll-free: 1-8XX-XXX-XXXX. SOURCE: United States District Court for the Eastern District of Louisiana
This notice does not provide any information related to the separate Medical Benefits Settlement also reached related to the Deepwater Horizon oil spill. For more information about the Medical Benefits Settlement, and to determine whether your rights are affected by that settlement, or whether you are eligible for a payment under that settlement, visit www.[ ].com (embedded link) or call 1-8XX-XXX-XXXX.
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Attachment 1C: Publication Notice
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LegaL notice LegaL notice
If you have economic loss or property damage because of the Deepwater Horizon oil spill, you could get money from a class action settlement with BP Exploration & Production Inc. and BP America Production Company (“BP”). Go to www.[ ].com for more information, including information on how to file a claim.
Who is included in the economic & ProPerty damages settlement?
The Economic and Property Damage (“E&PD”) Settlement Class includes people, businesses, other entities, and properties in the states of Louisiana, Alabama and Mississippi, and certain counties in Texas and Florida, that were harmed by the oil spill. The website www.[ ].com has detailed descriptions and maps to help you determine whether a geographic location may be included in the E&PD Settlement. Additionally, you can call 1-8XX-XXX-XXXX or e-mail info@[ ].com to find out if a geographic location is included.
What does the economic & ProPerty damages settlement Provide?
The E&PD Settlement makes payments for the following types of claims: (1) Seafood Compensation, (2) Economic Damage, (3) Loss of Subsistence, (4) Vessel Physical Damage, (5) Vessels of Opportunity Charter Payment, (6) Coastal Real Property Damage, (7) Wetlands Real Property Damage, and (8) Real Property Sales Damage. There is no limit on the total dollar amount of the E&PD Settlement; all qualified claims will be paid.
hoW to get Benefits from the economic & ProPerty damages settlement
You need to submit a Claim Form to request a payment. You can get a copy of the various Claim Forms by visiting the website or by calling 1-8XX-XXX-XXXX. Claims can be submitted online or by mail. If you have questions about how to file your claim, you should call the toll-free
number for assistance.
The deadline to submit most claims will be April 22, 2014 or six months after the E&PD Settlement becomes effective (i.e., after the Court grants “final approval” and any appeals are resolved), whichever is later. Seafood Compensation claims must be submitted no later than 30 days after final approval of the settlement (regardless of appeals). Actual claim filing deadlines will be posted on the website as they become available. Valid claims will be paid as they are approved, beginning on Month 00, 2012. It is highly recommended that E&PD Settlement Class Members complete and submit their claim forms promptly. Please read the Medical Benefits Settlement notice because you may also be eligible for benefits from that settlement.
your other oPtions?
If you do not want to be legally bound by the E&PD Settlement, you must opt out or exclude yourself by Month 00, 2012 or you won’t be able to sue BP over certain economic and property damage claims. If you stay in the E&PD Settlement, you may object to it by Month 00, 2012. The Detailed Notice explains how to exclude yourself or object.
The Court will hold a hearing on Month 00, 2012 to consider whether to approve the E&PD Settlement. You or your own lawyer may ask to appear and speak at the hearing at your own cost. The Court will also consider Class Counsel fees, costs, and expenses including an interim payment of $75 million and additional awards equal to 6% of class claims and benefits paid, and a maximum of $600 million. Class Counsel fees, costs and expenses under the Economic and Property Damages Settlement Agreement and the Medical Benefits Settlement Agreement jointly cannot exceed $600 million. Class members’ payments will not change if the Court approves the payment of Class Counsel fees under either settlement, because BP will separately pay these amounts.
Economic and Property Damages SettlementProviding Money to Individuals and Businesses
Deepwater Horizon Oil Spill Settlements
www.[ ].com 1-8XX-XXX-XXXX
Medical Benefits SettlementProviding Benefits to Clean-Up Workers and Certain Gulf Coast Residents
Deepwater Horizon Oil Spill Settlements
www.[ ].com 1-8XX-XXX-XXXX
Medical Benefits Settlement publication notice text.
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Attachment 1D: Television Notice Storyboard
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DeepwaterHorizonCourt‐SupervisedSettlementProgramInre:OilSpillbytheOilRig"DeepwaterHorizon"inGulfofMexicoonApril20,2010,MDL217930SecondTelevisionSpot
*Final images may vary depending on photo licensing details, but will be content equivalent.
OFF-CAMERA NARRATOR: If you or your business
were harmed by the Deepwater Horizon Oil Spill,
you may be able to get payments and other benefits
1. Wide shot of beach and clouds. 2. Men in marshy area. 3. Small beach house.
from two separate legal settlements. One settlement provides payments for economic and property damage.
4. Fisherman in front of boat. 5. Man at desk in marina. 6. Hotel housekeeper making bed.
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DeepwaterHorizonCourt‐SupervisedSettlementProgramInre:OilSpillbytheOilRig"DeepwaterHorizon"inGulfofMexicoonApril20,2010,MDL217930SecondTelevisionSpot
*Final images may vary depending on photo licensing details, but will be content equivalent.
The other provides payments and benefits for medical claims.
To get detailed information and claim forms,
go to www.[ ].com
7. Medium Shot female doctor with patient. 8. People working in restaurant. 9. Man in front of fishing boat, other boats in background.
or call 8XX-XXX-
XXXX.
10. Wide shot of man with clipboard next to freighter
11. Sunset with moorings in foreground.
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Attachment 1E: Television PSA
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Front Cover Text Deepwater Horizon Oil Spill Litigation - Class Action Notice Court-approved PSAs about two separate settlements related to the Deepwater Horizon Oil Spill - one settlement addressing economic and property damage claims, and a separate settlement addressing medical claims. People and businesses across the Gulf Coast region may be eligible for payments and other benefits from one or both of the two settlements. Please air these important announcements alerting those affected about their rights, including their right to be excluded from the case, by Month DD, 20YY. Back Cover Text Deepwater Horizon Oil Spill Litigation - Class Action Notice Dear Public Service Director: Two separate settlements have been reached related to the Deepwater Horizon Oil Spill - one settlement addressing economic and property damage claims, and a separate settlement addressing medical claims. People and/or businesses across the Gulf Coast region may be eligible for payments and other benefits from one or both of the two settlements. This message is important because the people and/or businesses affected have various rights, including the right to file claims, request exclusion from or object to either or both settlements. The PSAs inform people and businesses of their legal rights and how to obtain additional information. Please air these spots as soon as possible, and continue to do so until Month DD, 20YY. Thank you for taking the time to consider sharing these PSAs with your audience. Sincerely, Notice Administrator Inside Text 30 second TV PSA: People and/or businesses across the Gulf Coast region may be eligible for payments and other benefits from two separate class action settlements related to the Deepwater Horizon Oil Spill. One settlement provides payments for some types of economic and property damage claims. The other settlement provides payments and other benefits for certain medical claims. To get claim forms and notices, go to www.[ ].com or call 8XX-XXX-XXXX.
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Attachment 1F: Radio Notice Script
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:30 Radio Script If you or your business were harmed by the Deepwater Horizon Oil Spill, you may be able to get payments and other benefits from two separate legal settlements. One settlement provides payments for economic and property damage. The other provides payments and benefits for medical claims. To get detailed information and claim forms go to www.[ ].com or call 8XX-XXX-XXXX.
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Attachment 1G: Internet Banner Notices
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Deepwater Horizon Court-Supervised Settlement Program In re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179
Notice Internet Banner
LEGAL NOTICE FROM U.S. COURT
If you or your business were harmed by the Deepwater Horizon oil spill, you may be able to get benefits from two separate legal settlements.
www.[ ].com
DEEPWATER HORIZON SETTLEMENTS
� Economic and Property Damages Settlement: Provides payments to people and businesses.
� Medical Benefits Settlement: Provides payments and other benefits.
www.[ ].com
LEGAL NOTICE FROM U.S. COURT
If you or your business
were harmed by the
Deepwater Horizon oil spill,
you may be able to get benefits
from two separate
legal settlements.
www.[ ].com
DEEPWATER HORIZON SETTLEMENTS
� Economic & Property Damages Settlement: Provides payments to people and businesses. � Medical Benefits Settlement: Provides payments and other benefits.
www.[ ].com
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Attachment 1H: Notice Website (screen captures)
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Deepwater Horizon Court-Supervised Settlement Program In re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179
Notice Website Portal
-- 1 --
Home Page
Note: Claim Administrator buttons appear at the bottom of all pages.
Formatting Note: Content will be updated to conform to final notice document submitted to Court.
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Deepwater Horizon Court-Supervised Settlement Program In re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179
Notice Website Portal
-- 2 --
Key Dates Page
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Deepwater Horizon Court-Supervised Settlement Program In re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179
Notice Website Portal
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Economic and Property Damage Notice Page
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 153 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Deepwater Horizon Court-Supervised Settlement Program In re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179
Notice Website Portal
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Medical Benefits Notice Page
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 154 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Attachment 1I: Informational Release
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 155 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
© 2012 Hilsoft Notifications
COURT ORDERED NOTICE PROGRAM ABOUT TWO DEEPWATER HORIZON OIL SPILL SETTLEMENTS IS INITIATED New Orleans, LA, Month DD, 20YY / PR Newswire / -- A notification effort ordered by the United States District Court for the Eastern District of Louisiana is beginning today to notify people, businesses and other entities about two separate proposed settlements with BP Exploration & Production Inc. and BP America Production Company (“BP”) related to the Deepwater Horizon oil spill. BP has estimated the cost of the proposed settlement to be approximately $7.8 billion. The total amount BP will pay to settle valid claims is uncapped, and the ultimate cost will depend on the actual outcomes of the court-supervised claims processes. People may be affected by one or both settlements. In each settlement, Class Members have separate legal rights and options, including submitting claims for benefits, opting out or objecting to each settlement. The Economic and Property Damages Settlement (or “E&PD Settlement”) includes people, businesses and other entities who live, work, conduct business operations and/or own/lease property in the states of Louisiana, Mississippi, and Alabama, along with specified Texas and Florida counties. The E&PD Settlement generally covers the following types of claims: 1) seafood compensation; 2) economic loss; 3) loss of subsistence use; 4) vessel physical damage; 5) Vessels of Opportunity charter payment; 6) damage to coastal real property; 7) damage to wetlands real property; and 8) real property sales damage related to sales of certain Gulf Coast residences. In addition to compensation for actual damage, payments to eligible claimants may include a multiplier related to unknown future damage. The Medical Benefits Settlement (or “Medical Settlement’) includes “Clean-Up Workers” and people who resided during specified periods in 2010 in coastal areas (Zone A) and wetlands areas (Zone B). Medical Settlement benefits include (a) payments for Specified Physical Conditions including reimbursement of hospital expenses, (b) a 21-year Periodic Medical Consultation Program, and (c) a $105 million Gulf Region Health Outreach Program, available to all Gulf residents, Class Members and non-Class Members alike, in order to strengthen healthcare capacity and increase health literacy throughout the region. Detailed information on the two settlements can be found at the settlement website, www.[ ].com. The website has detailed maps that allow users to see if a geographic location may be included within one or more zones. Notices will be mailed to known potential Class Members and are scheduled to appear in thousands of media outlets over the next 60 days in English, Spanish and Vietnamese. Notices are to appear in Gulf Coast daily newspapers, print publications, television and radio spots and on Internet websites. A parallel nationwide media effort includes well-read consumer magazines, trade publications and highly-trafficked Internet websites. The Court has appointed [______] as Proposed Settlement Class Counsel to represent each of the Settlement Classes.
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 156 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
© 2012 Hilsoft Notifications
2
Class Members can submit a claim to either or both Settlements, or they can ask to be excluded from, or object to, either or both Settlements. The deadline to object to either or both settlements is [_______]. The deadline to request exclusion from either or both settlements is [_______]. The deadline to submit most E&PD claims will be April 22, 2014 or six months after the E&PD Settlement becomes effective (i.e., after the Court grants “final approval” and any appeals are resolved), whichever is later. E&PD Seafood Compensation claims must be submitted no later than 30 days after final approval of the Settlement (regardless of appeals). The deadline to submit Medical Benefits claims is one year after the Medical Settlement becomes effective (i.e., after the Court grants “final approval” and any appeals are resolved). Exact claim filing deadlines will be posted on the website as they become available. Eligible E&PD Settlement claims will be paid on a rolling basis and E&PD Settlement claimants may receive payments before the Court considers whether to grant final approval. Medical Settlement benefits will not be issued until after the Court grants final approval and any appeals are resolved. A toll-free number, [1-8XX-XXX-XXXX], has been established in the case known as In re: Oil Spill by the Oil Rig “Deepwater Horizon” in the Gulf of Mexico on April 20, 2010, MDL No. 2179, along with a website, [www.[ ].com], where notices, each Settlement Agreement and other documents may be obtained. # # #
/CONTACT: Press Only: Class Counsel: [__________________________] BP: [ ]. /URL: [www.[ ].com] /SOURCE: United States District Court for the Eastern District of Louisiana
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Attachment 2: American Profile, Parade, and USA Weekend Newspaper List
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 158 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Alabama Albertville The Sand Mountain Reporter 1 1 January 2012
Alabama Alexander City Outlook 1 1 1 1 January 2012
Alabama Alexander City The Dadeville Times 1 1 January 2012
Alabama Andalusia The Andalusia Star-News 1 1 January 2012
Alabama Anniston Star 1 1 January 2012
Alabama Athens The News Courier 1 1 1 1 2 January 2012
Alabama Atmore The Atmore Advance 1 1 January 2012
Alabama Bay Minette The Baldwin Times 1 1 January 2012
Alabama Birmingham News 1 1 January 2012
Alabama Brewton The Brewton Standard 1 1 January 2012
Alabama Clanton The Clanton Advertiser 1 1 January 2012
Alabama Cullman Times 1 1 1 1 2 January 2012
Alabama Daphne The Bulletin 1 1 January 2012
Alabama Decatur The Decatur Daily 1 1 January 2012
Alabama Demopolis The Demopolis Times 1 1 January 2012
Alabama Dothan Eagle 1 1 January 2012
Alabama Eufaula The Eufaula Tribune 1 1 January 2012
Alabama Fairhope Fairhope Courier 1 1 January 2012
Alabama Fayette Pickens County Herald 1 1 January 2012
Alabama Fayette TheTimes-Record 1 1 January 2012
Alabama Florence-Sheffield-Tuscumbia-Muscle Times Daily 1 1 January 2012
Alabama Foley Elberta-Lillian Ledger 1 1 January 2012
Alabama Foley The Foley Onlooker 1 1 January 2012
Alabama Fort Payne The Times-Journal 1 1 January 2012
Alabama Gadsden Times 1 1 January 2012
Alabama Gardendale North Jefferson News 1 1 1 1 January 2012
Alabama Greenville The Greenville Advocate 1 1 January 2012
Alabama Gulf Shores The Islander 1 1 January 2012
Alabama Hartselle The Hartselle Enquirer 1 1 January 2012
Alabama Huntsville Times 1 1 January 2012
Alabama Jasper Mountain Eagle 1 1 1 1 January 2012
Alabama Leeds The Leeds News 1 1 January 2012
Alabama Madison Madison County Record 1 1 January 2012
Alabama Mobile Register 1 1 January 2012
Alabama Montgomery Advertiser 1 1 January 2012
Alabama Opelika/Auburn News 1 1 January 2012
Alabama Ozark The Southern Star 1 1 January 2012
Alabama Pell City St. Clair News-Aegis 1 1 January 2012
Alabama Robertsdale The Independent 1 1 January 2012
Alabama Russellville Franklin County Times 1 1 January 2012
Alabama Scottsboro The Daily Sentinel 1 1 January 2012
Alabama Selma Times Journal 1 1 January 2012
Alabama Talladega Daily Home 1 1 January 2012
Alabama Troy The Messenger 1 1 January 2012
Alabama Tuscaloosa News 1 1 January 2012
Alabama Wetumpka The Wetumpka Herald 1 1 January 2012
Alaska Anchorage Daily News 1 1 January 2012
Alaska Fairbanks News-Miner 1 1 January 2012
Alaska Juneau Empire 1 1 January 2012
Alaska Kenai Peninsula Clarion 1 1 January 2012
Arizona Benzon San Pedro Valley News - Sun 1 1 January 2012
Arizona Bullhead City Mohave Valley Daily News 1 1 1 1 January 2012
Arizona Casa Grande Dispatch 1 1 1 1 January 2012
Arizona Chino Valley Chino Valley Review 1 1 January 2012
Arizona Cottonwood The Bugle 1 1 January 2012
Arizona Cottonwood The Verde Independent 1 1 1 1 January 2012
Arizona Douglas The Daily Dispatch 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Arizona Flagstaff Arizona Daily Sun 1 1 January 2012
Arizona Gilbert Chandler Tribune 1 1 January 2012
Arizona Globe Arizona Silver Belt 1 1 January 2012
Arizona Green Valley Green Valley News & Sun 1 1 January 2012
Arizona Green Valley The Sahuarita News and Sun 1 1 January 2012
Arizona Holbrook Holbrook Tribune - News 1 1 January 2012
Arizona Kingman Daily Miner 1 1 1 1 January 2012
Arizona Lake Havasu City Today's News-Herald 1 1 1 1 January 2012
Arizona Mesa The Tribune 1 1 January 2012
Arizona Nogales Nogales Internationals 1 1 January 2012
Arizona Parker Parker Pioneer 1 1 January 2012
Arizona Phoenix Ahwatukee Foothills News 1 1 January 2012
Arizona Phoenix La Voz 1 1 January 2012
Arizona Phoenix Republic & Sunday Select 1 1 January 2012
Arizona Prescott Daily Courier 1 1 1 1 January 2012
Arizona Prescott Valley Prescott Valley Tribune 1 1 January 2012
Arizona Safford Eastern Arizona Courier 1 1 1 1 January 2012
Arizona Show Low White Mountain Independent 1 1 January 2012
Arizona Sierra Vista Herald 1 1 1 1 January 2012
Arizona Sun City Glendale/Peoria Today 1 1 January 2012
Arizona Sun City News-Sun 1 1 1 1 January 2012
Arizona Sun City Surprise Today 1 1 January 2012
Arizona Tucson Star 1 1 1 1 January 2012
Arizona Wickenburg Wickenburg Sun 1 1 January 2012
Arizona Willcox Arizona Range News 1 1 January 2012
Arizona Williams Williams-Grand Canyon News 1 1 January 2012
Arizona Yuma Daily Sun 1 1 January 2012
Arkansas Ashdown Little River News 1 1 January 2012
Arkansas Atkins Atkins Chronicle 1 1 January 2012
Arkansas Atkins The Dover Times 1 1 January 2012
Arkansas Batesville Batesville Daily Guard 1 1 January 2012
Arkansas Benton The Benton Courier 1 1 January 2012
Arkansas Bentonville The Weekly Vista 1 1 January 2012
Arkansas Berryville Carroll County News 1 1 January 2012
Arkansas Blytheville Courier News 1 1 January 2012
Arkansas Booneville Booneville Democrat 1 1 January 2012
Arkansas Camden Camden News 1 1 January 2012
Arkansas Charleston Charleston Express 1 1 January 2012
Arkansas Cherokee Village The Villager Journal 1 1 January 2012
Arkansas Conway Log Cabin Democrat 1 1 1 1 January 2012
Arkansas Danville Yell County Record 1 1 January 2012
Arkansas El Dorado News-Times 1 1 1 1 January 2012
Arkansas Fayetteville Democrat-Gazette 1 1 1 1 January 2012
Arkansas Fort Smith Times Record 1 1 January 2012
Arkansas Greenwood Greenwood Democrat 1 1 January 2012
Arkansas Harrison Times 1 1 1 1 January 2012
Arkansas Heber Springs Cleburne County Sun-Times 1 1 January 2012
Arkansas Helena Helena-West Helena Daily World 1 1 January 2012
Arkansas Hope Hope Star 1 1 January 2012
Arkansas Hope The Daily Siftings Herald 1 1 January 2012
Arkansas Hot Springs Sentinel-Record 1 1 1 1 January 2012
Arkansas Jonesboro Sun 1 1 January 2012
Arkansas Little Rock Democrat-Gazette 1 1 January 2012
Arkansas Lonoke Democrat 1 1 January 2012
Arkansas Magnolia Banner-News 1 1 January 2012
Arkansas Malvern Malvern Daily Record 1 1 January 2012
Arkansas Manila Northeast Arkansas Town Crier 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Arkansas Melbourne The Melbourne Times 1 1 January 2012
Arkansas Mountain Home Baxter Bulletin 1 1 January 2012
Arkansas Mountain View Stone County Leader 1 1 January 2012
Arkansas Nashville Nashville News 1 1 January 2012
Arkansas Newport Newport Independent 1 1 January 2012
Arkansas Osceola The Osceola Times 1 1 January 2012
Arkansas Paragould Daily Press 1 1 January 2012
Arkansas Paris Paris Express 1 1 January 2012
Arkansas Piggott Piggott Times 1 1 January 2012
Arkansas Pine Bluff Commercial 1 1 January 2012
Arkansas Rector Clay County Democrat 1 1 January 2012
Arkansas Russellville Courier 1 1 January 2012
Arkansas Salem Alma Journal 1 1 January 2012
Arkansas Salem The News 1 1 January 2012
Arkansas Searcy Citizen 1 1 January 2012
Arkansas Sherwood Voice 1 1 January 2012
Arkansas Stuttgart Daily Leader 1 1 January 2012
Arkansas Trumann Tri-City Tribune 1 1 January 2012
Arkansas Trumann Trumann Democrat 1 1 January 2012
Arkansas Van Buren County Democrat 1 1 January 2012
Arkansas Van Buren Press Argus Courier 1 1 1 1 January 2012
Arkansas West Memphis Evening Times 1 1 January 2012
Arkansas White Hall The White Hall Journal 1 1 January 2012
California Auburn Journal 1 1 January 2012
California Avenal Avenal Progress 1 1 January 2012
California Bakersfield Californian 1 1 January 2012
California Benicia Herald 1 1 January 2012
California Big Bear Lake Grizzly Weekender 1 1 January 2012
California Blythe Palo Verde Valley Times(/Quartszite 1 1 January 2012
California Burney Intermountain News 1 1 January 2012
California Chester Chester Progressive 1 1 January 2012
California Chico Enterprise-Record 1 1 1 1 January 2012
California Coalinger Coalinger Record 1 1 January 2012
California Davis Enterprise 1 1 January 2012
California Dos Palas The Dos Palos Sun 1 1 January 2012
California El Centro Imperial Valley Press 1 1 1 1 January 2012
California Escalon Escalon Times 1 1 January 2012
California Escondido-Oceanside-Vista-San Marcos North County Times 1 1 January 2012
California Eureka Times-Standard 1 1 1 1 January 2012
California Exeter The Exeter Sun dba The Foothill's Sun 1 1 January 2012
California Fairfield Republic 1 1 1 1 January 2012
California Fort Bragg Fort Bragg Advocate News 1 1 January 2012
California Fresno Bee 1 1 January 2012
California Gilroy The Dispatch 1 1 January 2012
California Glendale Glenside News-Press 1 1 January 2012
California Grass Valley The Union 1 1 1 1 January 2012
California Greenville Indian Valley Record 1 1 January 2012
California Gridley The Gridley Herald 1 1 January 2012
California Handford Central Valley Guide 1 1 January 2012
California Handford Golden Eagle 1 1 January 2012
California Handford Sentinel 1 1 1 1 January 2012
California Handford Twin City Times 1 1 January 2012
California Hollister Free Lance 1 1 January 2012
California Holtville Calexico Chronicle 1 1 January 2012
California Holtville Holtville Tribune 1 1 January 2012
California Holtville Imperial Valley Weekly 1 1 January 2012
California Idyllwild Idyllwild Town Crier 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
California Inyo Inyo Register 1 1 January 2012
California Jackson Amador Ledger-Dispatch 1 1 January 2012
California Kingsburg The Kingsburg Recorder 1 1 January 2012
California La Canada Flintridge La Canada Valley Sun 1 1 January 2012
California Laguna Beach Coastline Pilot 1 1 January 2012
California Lakeport Record-Bee 1 1 1 1 January 2012
California Lemoore Le Moore Advance 1 1 January 2012
California Lodi News-Sentinel 1 1 January 2012
California Long Beach Impacto USA 1 1 January 2012
California Los Angeles Daily News 1 1 January 2012
California Los Angeles Times 1 1 January 2012
California Los Angeles County Breeze 1 1 January 2012
California Los Angeles County Press Telegram 1 1 January 2012
California Los Angeles County Star News-Valley Tribune-Daily 1 1 January 2012
California Madera Tribune 1 1 January 2012
California Manteca The Manteca Bulletin 1 1 January 2012
California Marin County Independent Journal 1 1 January 2012
California Marysville Appeal-Democrat 1 1 January 2012
California Merced Sun-Star 1 1 January 2012
California Modesto Bee 1 1 January 2012
California Monterey Herald 1 1 1 1 January 2012
California Monterey The Valley Adviser 1 1 January 2012
California Morgan Hill Morgan Hill Times 1 1 January 2012
California Mount Shasta Mount Shasta Herald 1 1 January 2012
California Napa Register 1 1 1 1 2 January 2012
California Needles Needles Desert Star 1 1 January 2012
California Oakdale Oakdale Leader 1 1 January 2012
California Oakland Tribune 1 1 January 2012
California Ontario City News 1 1 January 2012
California Ontario Inland Valley Daily Bulletin 1 1 January 2012
California Palm Springs Cathedral Sun 1 1 January 2012
California Palm Springs Desert Sun Newspapers 1 1 January 2012
California Palm Springs Indio Sun 1 1 January 2012
California Palmdale Antelope Valley Press 1 1 1 1 January 2012
California Palo Alto/Menlo Park Daily News 1 1 January 2012
California Paradise Paradise Post 1 1 January 2012
California Pasadena Weekly Star 1 1 January 2012
California Placerville Mountain Democrat 1 1 1 1 January 2012
California Porterville Recorder 1 1 1 1 January 2012
California Portola Portola Reporter 1 1 January 2012
California Quincy Feather River Bulletin 1 1 January 2012
California Red Bluff News 1 1 1 1 January 2012
California Redding Record Searchlight 1 1 January 2012
California Redlands Facts 1 1 January 2012
California Ridgecrest The Daily Independent 1 1 1 1 January 2012
California Riverbank The Riverbank News 1 1 January 2012
California Riverside La Prensa 1 1 January 2012
California Riverside Press Enterprise 1 1 January 2012
California Sacramento Bee 1 1 January 2012
California Salinas Californian 1 1 January 2012
California San Bernardino Sun 1 1 January 2012
California San Diego La Jolla Village News 1 1 January 2012
California San Diego Union-Tribune 1 1 January 2012
California San Francisco Chronicle 1 1 January 2012
California San Francisco Examiner 1 1 January 2012
California San Gabriel Valley Highlander 1 1 January 2012
California San Jose Mercury News 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
California San Jose Yes! Your essential Shopper 1 1 January 2012
California San Luis Obispo Tribune 1 1 January 2012
California San Mateo/Lompoc Times 1 1 January 2012
California Santa Ana Orange CO Register 1 1 January 2012
California Santa Barbara News-Press 1 1 1 1 January 2012
California Santa Clarita The Signal 1 1 January 2012
California Santa Cruz Sentinel 1 1 January 2012
California Santa Maria/Lompoc Times-Record 1 1 1 1 January 2012
California Santa Rosa Press Democrat 1 1 January 2012
California Selma The Selma Enterprise 1 1 January 2012
California Shasta Lake Shasta Lake Bulletin 1 1 January 2012
California Sonora The Union Democrat 1 1 January 2012
California South Lake Tahoe Tahoe Daily Tribune 1 1 January 2012
California Stockton Record 1 1 January 2012
California Susanville Lassen County Times 1 1 January 2012
California Susanville Westwood Pinepress 1 1 January 2012
California Taft Daily Midway Driller 1 1 January 2012
California Tahoe City North Lake Tahoe Bonanza 1 1 January 2012
California Tehachapi Tehachapi News 1 1 January 2012
California Truckee Sierra Sun 1 1 January 2012
California Tulare/Visalia Advance Register-Times-Delta 1 1 January 2012
California Turlock Turlock Journal 1 1 January 2012
California Twenty-nine Palms The Desert Trail 1 1 January 2012
California Ukiah Journal 1 1 1 1 January 2012
California Vacaville Reporter 1 1 1 1 January 2012
California Vallejo Times-Herald 1 1 1 1 January 2012
California Valley Springs The Valley Springs News 1 1 January 2012
California Ventura County Star 1 1 January 2012
California Victorville/Barstow Press-Desert Dispatch 1 1 1 1 2 January 2012
California Watsonville Register-Pajaronian 1 1 January 2012
California Willits The Willits News 1 1 January 2012
California Woodland Democrat 1 1 1 1 January 2012
California Yreka Siskiyou Daily News 1 1 1 1 January 2012
California Yucca Valley Hi-Desert Star 1 1 1 1 January 2012
California Yucca Valley Observation Post 1 1 January 2012
Colorado Akron Akron News-Reporter 1 1 January 2012
Colorado Aspen Times 1 1 January 2012
Colorado Boulder Sunday Camera 1 1 January 2012
Colorado Brush Brush News-Tribune 1 1 January 2012
Colorado Burlington The Burlington Record 1 1 January 2012
Colorado Canon City Daily Record 1 1 1 1 January 2012
Colorado Colorado Springs Gazette 1 1 January 2012
Colorado Craig Craig Daily Press 1 1 January 2012
Colorado Denver Post-Rocky Mountain News 1 1 1 1 January 2012
Colorado Durango/Cortez Herald-Journal 1 1 January 2012
Colorado Estes Park Estes Park Trail-Gazette 1 1 January 2012
Colorado Fort Collins Coloradoan 1 1 January 2012
Colorado Fort Morgan Fort Morgan Times 1 1 January 2012
Colorado Frisco Summit Daily News 1 1 January 2012
Colorado Glenwood Springs Post Independent 1 1 January 2012
Colorado Granby Sky Hi News 1 1 January 2012
Colorado Grand Junction Daily Sentinel 1 1 January 2012
Colorado Grand Junction Free Press 1 1 January 2012
Colorado Greeley Tribune 1 1 January 2012
Colorado Julesburg Julesburg Advocate 1 1 January 2012
Colorado Lafayette Lafayette News 1 1 January 2012
Colorado Longmont Times-Call 1 1 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Colorado Louisville Louisville Times 1 1 January 2012
Colorado Loveland Reporter-Herald 1 1 1 1 January 2012
Colorado Montrose Press 1 1 January 2012
Colorado Pueblo Sunday Chieftain 1 1 January 2012
Colorado Steamboat Springs Steamboat Pilot 1 1 January 2012
Colorado Steamboat Springs Steamboat Today 1 1 1 1 January 2012
Colorado Sterling Journal Advocate 1 1 January 2012
Colorado Trinidad The Chronicle News 1 1 January 2012
Colorado Vail Daily 1 1 January 2012
Colorado Windsor Now 1 1 January 2012
Connecticut Bridgeport Connecticut Post 1 1 January 2012
Connecticut Danbury News-Times 1 1 January 2012
Connecticut Greenwich Time 1 1 January 2012
Connecticut Hartford Courant 1 1 January 2012
Connecticut Manchester Journal Inquirer 1 1 1 1 January 2012
Connecticut Meriden Record-Journal Publishing Co. 1 1 1 1 January 2012
Connecticut Middletown Press 1 1 January 2012
Connecticut New Britain Herald Press 1 1 January 2012
Connecticut New Haven Register 1 1 January 2012
Connecticut New London Day 1 1 January 2012
Connecticut Norwalk Hour 1 1 1 1 January 2012
Connecticut Norwich Bulletin 1 1 January 2012
Connecticut Stamford Advocate 1 1 January 2012
Connecticut Torrington Register Citizen 1 1 January 2012
Connecticut Waterbury Republican-American 1 1 January 2012
Connecticut Willimantic Chronicle 1 1 1 1 January 2012
Deleware Dover Delaware State News 1 1 January 2012
Deleware Newark Newark Post 1 1 January 2012
Deleware Newark Route 40 Flier 1 1 January 2012
Deleware Wilmington News Journal 1 1 January 2012
District of Columbia Washington Examiner 1 1 January 2012
District of Columbia Washington Times 1 1 January 2012
District of Columbia Washington Washington Post 1 1 January 2012
Florida Bartow The Polk County Democrat 1 1 January 2012
Florida Bradenton Herald 1 1 January 2012
Florida Brooksville Hernando Today 1 1 1 1 January 2012
Florida Cape Coral Daily Breeze 1 1 January 2012
Florida Charlotte Harbor/Port Charlotte Sun 1 1 1 1 January 2012
Florida Chiefland Chiefland Citizen 1 1 January 2012
Florida Coral Springs Forum 1 1 January 2012
Florida Crawfordville The Wakulla News 1 1 January 2012
Florida Crescent City Courier Journal 1 1 January 2012
Florida Cross City Dixie County Advocate 1 1 January 2012
Florida Crystal River Citrus County Chronicle 1 1 January 2012
Florida Daytona Beach News-Journal 1 1 January 2012
Florida Deerfield Forum 1 1 January 2012
Florida Deland DeLand - Deltona Beacon 1 1 January 2012
Florida Dunnellon Riverland News 1 1 January 2012
Florida Eastpoint Franklin Chronicle 1 1 January 2012
Florida Fernandina Beach Fernandina Beach News-Leader 1 1 January 2012
Florida Fort Meade The Fort Meade Leader 1 1 January 2012
Florida Ft. Lauderdale East Side Forum 1 1 January 2012
Florida Ft. Lauderdale El Sentinel 1 1 January 2012
Florida Ft. Lauderdale/South Florida Sun-Sentinel 1 1 January 2012
Florida Ft. Myers News-Press 1 1 January 2012
Florida Ft. Walton Beach Northwest Florida News 1 1 January 2012
Florida Gainesville Sun 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Florida Jackson County Floridian 1 1 January 2012
Florida Jacksonville The Beaches Leader 1 1 January 2012
Florida Jacksonville The Florida Times-Union 1 1 1 1 January 2012
Florida Kissimmee Osceola News-Gazette 1 1 1 1 January 2012
Florida Lake City Reporter 1 1 1 1 January 2012
Florida Lake Placid Lake Placid Journal 1 1 January 2012
Florida Lake Wales Frostproof News 1 1 January 2012
Florida Lake Wales Lake Wales News 1 1 January 2012
Florida Lakeland Ledger 1 1 January 2012
Florida Leesburg Commercial 1 1 January 2012
Florida Live Oak Suwannee Democrat 1 1 1 1 2 January 2012
Florida Madison The Madison Enterprise-Recorder 1 1 January 2012
Florida Margate The Forum 1 1 January 2012
Florida Marianna Jackson County Floridan 1 1 January 2012
Florida Melbourne Florida Today & Sunday Select 1 1 January 2012
Florida Miami El Nuevo Herald 1 1 January 2012
Florida Miami Miami Herald 1 1 January 2012
Florida Naples Daily News 1 1 January 2012
Florida Ocala Star-Banner 1 1 January 2012
Florida Orlando El Sentinel 1 1 January 2012
Florida Orlando Sentinel 1 1 January 2012
Florida Orlando What's The Deal 1 1 January 2012
Florida Panama City News Herald/Freedom Florida 1 1 January 2012
Florida Pensacola News Journal 1 1 January 2012
Florida Pompano Beach Forum 1 1 January 2012
Florida Quincy Gadsden County Times 1 1 January 2012
Florida Sarasota Herald-Tribune 1 1 January 2012
Florida Sebring Highlands Today 1 1 1 1 January 2012
Florida St. Augustine Record 1 1 1 1 January 2012
Florida St. Petersburg Times 1 1 January 2012
Florida Stuart Treasure Coast News/Press-Tribune 1 1 January 2012
Florida Tallahassee Democrat 1 1 January 2012
Florida Tampa Centro Mi Diario 1 1 January 2012
Florida Tampa Tribune & Times 1 1 January 2012
Florida Tampa/Newport Richey Suncoast Newspapers 1 1 January 2012
Florida The Villages Daily Sun 1 1 1 1 2 January 2012
Florida Venice Hardee Sun 1 1 January 2012
Florida Venice Venice Gondolier Sun 1 1 January 2012
Florida Wauchula The Herald Advocate 1 1 January 2012
Florida West Palm Beach Post 1 1 January 2012
Florida Winter Haven News Chief 1 1 1 1 January 2012
Florida Winter Park The Voice (Oviedo) 1 1 January 2012
Georgia Albany Herald 1 1 January 2012
Georgia Americus Times-Recorder 1 1 January 2012
Georgia Athens Banner-Herald 1 1 1 1 January 2012
Georgia Atlanta Journal & Constitution 1 1 January 2012
Georgia Augusta Chronicle 1 1 1 1 January 2012
Georgia Augusta North Augusta Today 1 1 January 2012
Georgia Bainbridge The Post Searchlight 1 1 January 2012
Georgia Blakely Early County News 1 1 January 2012
Georgia Brunswick The Brunswick News 1 1 January 2012
Georgia Cairo The Cairo Messenger 1 1 January 2012
Georgia Canton Cherokee Tribune 1 1 January 2012
Georgia Carrollton Times-Georgian 1 1 January 2012
Georgia Cartersville The Daily Tribune News 1 1 1 1 January 2012
Georgia Clayton The Clayton Tribune 1 1 January 2012
Georgia Columbus Ledger-Enquirer 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Georgia Cordele Dispatch 1 1 January 2012
Georgia Covington The Covington News 1 1 January 2012
Georgia Cumming Forysth County News 1 1 1 1 January 2012
Georgia Cummings South Forsyth News 1 1 January 2012
Georgia Dalton Citizen 1 1 January 2012
Georgia Dawsonville Dawson Community News 1 1 January 2012
Georgia Douglas County Sentinel 1 1 January 2012
Georgia Dublin Courier Herald 1 1 January 2012
Georgia Eatonton The Eatonton Messenger 1 1 January 2012
Georgia Fayetteville Fayette Daily News 1 1 January 2012
Georgia Fayetteville Today in Peachtree City 1 1 January 2012
Georgia Forsyth The Monroe County Reporter 1 1 January 2012
Georgia Gainesville Times 1 1 January 2012
Georgia Gray The Jones County News 1 1 January 2012
Georgia Griffin News 1 1 January 2012
Georgia Hawkinsville Hawkinsville Dispatch & News 1 1 January 2012
Georgia Hinesville Coastal Courier 1 1 January 2012
Georgia Jesup The Press-Sentinel 1 1 January 2012
Georgia Jonesboro/McDonough News-Daily Herald 1 1 January 2012
Georgia LaGrange LaGrange Daily News 1 1 1 1 January 2012
Georgia Lawrenceville/Conyers/Rockdale Daily Post-Citizen 1 1 January 2012
Georgia Louisville The News & Farmer 1 1 January 2012
Georgia Macon Telegraph 1 1 January 2012
Georgia Marietta Daily Journal-Cherokee Tribune- 1 1 January 2012
Georgia Milledgeville The Baldwin Bulletin 1 1 January 2012
Georgia Milledgeville Union-Recorder 1 1 January 2012
Georgia Monroe The Walton Tribune 1 1 January 2012
Georgia Montezuma The Citizen and Georgian 1 1 January 2012
Georgia Moultrie Observer 1 1 January 2012
Georgia Newnan Times-Herald 1 1 January 2012
Georgia Perry Houston Journal 1 1 January 2012
Georgia Reidsville The Tattnall Journal 1 1 January 2012
Georgia Richmond Hill Bryan County News 1 1 January 2012
Georgia Rome News Tribune 1 1 January 2012
Georgia Savannah Morning News 1 1 1 1 January 2012
Georgia Statesboro Herald 1 1 January 2012
Georgia Sylvania The Sylvania Telephone 1 1 January 2012
Georgia Thomaston The Thomaston Times 1 1 January 2012
Georgia Thomasville Times-Enterprise 1 1 January 2012
Georgia Thomson McDuffie Mirror 1 1 January 2012
Georgia Tifton Gazette 1 1 January 2012
Georgia Valdosta Times 1 1 January 2012
Georgia Winder The Barrow County News 1 1 January 2012
Hawaii Hilo Tribune-Herald 1 1 January 2012
Hawaii Honolulu Advertiser 1 1 January 2012
Hawaii Kailua/Kona West Hawaii Today 1 1 January 2012
Hawaii Lihue Garden Island 1 1 January 2012
Hawaii Wailuku Maui News 1 1 January 2012
Idaho Aberdeen The Aberdeen Times 1 1 January 2012
Idaho American Falls Power County Press 1 1 January 2012
Idaho Blackfoot The Morning News 1 1 January 2012
Idaho Boise Idaho Statesman 1 1 January 2012
Idaho Coeur D'Alene Press 1 1 1 1 January 2012
Idaho Grangeville Idaho County Free Press 1 1 January 2012
Idaho Idaho Falls Post-Register 1 1 January 2012
Idaho Kellogg Shoshone News-Press 1 1 January 2012
Idaho Lewiston-Clarkson Morning Tribune 1 1 January 2012
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Idaho Moscow The Moscow-Pullman Daily News 1 1 1 1 January 2012
Idaho Mt. Home Mountain Home News 1 1 January 2012
Idaho Nampa-Caldwell Idaho Press-Tribune 1 1 January 2012
Idaho Payette Independent Enterprise 1 1 January 2012
Idaho Pocatello Idaho State Journal 1 1 January 2012
Idaho Preston The Preston Citizen 1 1 January 2012
Idaho Priest River Priest River Times 1 1 January 2012
Idaho Rexburg Standard Journal 1 1 1 1 January 2012
Idaho Sandpoint Bonner County Daily Bee 1 1 January 2012
Idaho Sandpoint Bonners Ferry Herald 1 1 January 2012
Idaho Twin Falls Times-News 1 1 January 2012
Illinois Aledo The Times Record 1 1 January 2012
Illinois Alton/East Alton/Wood River Telegraph 1 1 1 1 January 2012
Illinois Arlington Heights Reflejos 1 1 January 2012
Illinois Aurora Beacon News 1 1 January 2012
Illinois Belleville News-Democrat 1 1 January 2012
Illinois Benton Evening News 1 1 1 1 January 2012
Illinois Bloomington-Normal Pantagraph 1 1 January 2012
Illinois Canton The Daily Ledger 1 1 1 1 January 2012
Illinois Carbondale The Southern Illinoisan 1 1 1 1 January 2012
Illinois Carlinville Macoupin County Enquirer Democrat 1 1 January 2012
Illinois Centralia Morning Sentinel 1 1 January 2012
Illinois Champaign-Urbana News-Gazette 1 1 January 2012
Illinois Chester Randolph County Herald-Tribune 1 1 January 2012
Illinois Chicago La Raza 1 1 January 2012
Illinois Chicago News Crusader 1 1 January 2012
Illinois Chicago Redeye 1 1 January 2012
Illinois Chicago Sun-Times 1 1 January 2012
Illinois Chicago Tribune 1 1 January 2012
Illinois Christopher The Progress 1 1 January 2012
Illinois Crystal Lake Lake County Journals 1 1 January 2012
Illinois Crystal Lake Northwest Herald 1 1 1 1 January 2012
Illinois Danville Commercial-News 1 1 January 2012
Illinois De Kalb Daily Chronicle 1 1 January 2012
Illinois Decatur Herald & Review 1 1 January 2012
Illinois Dekalb The Daily Chronicle 1 1 January 2012
Illinois Downers Grove Press Publications 1 1 January 2012
Illinois Du Quoin Evening Call 1 1 1 1 January 2012
Illinois Effingham Daily News 1 1 1 1 2 January 2012
Illinois Eldorado Journal 1 1 January 2012
Illinois Elgin Courier News 1 1 January 2012
Illinois Elmhurst Press Publications 1 1 January 2012
Illinois Fairbury The Blade 1 1 January 2012
Illinois Flora The Clay County Advocate-Press 1 1 January 2012
Illinois Freeport Journal-Standard 1 1 1 1 January 2012
Illinois Galesburg Register-Mail 1 1 January 2012
Illinois Galesburg The Paper 1 1 January 2012
Illinois Geneseo Geneseo Republic. 1 1 January 2012
Illinois Geneva Kane County Chronicle 1 1 January 2012
Illinois Harrisburg Register 1 1 1 1 January 2012
Illinois Herrin The Spokesman 1 1 January 2012
Illinois Hillsboro The Journal News 1 1 January 2012
Illinois Jacksonville Journal-Courier 1 1 1 1 January 2012
Illinois Joliet Herald-News 1 1 January 2012
Illinois Kankakee The Daily Journal 1 1 1 1 January 2012
Illinois Kewanee Star-Courier 1 1 1 1 January 2012
Illinois La Salle La Salle News Tribune 1 1 1 1 January 2012
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Illinois Lemont Reporter-Courier 1 1 January 2012
Illinois Lena Northwestern Illinois Farmers 1 1 January 2012
Illinois Lincoln The Courier 1 1 January 2012
Illinois Loves Park Rock Valley Publishing 1 1 January 2012
Illinois Machesney Park Elmhurst Independent 1 1 January 2012
Illinois Macomb Journal 1 1 1 1 January 2012
Illinois Marion Republican 1 1 1 1 January 2012
Illinois Metamora Metamora Herald 1 1 January 2012
Illinois Metropolis Metropolis Planet 1 1 January 2012
Illinois Moline The Dispatch/Rock Island Argus 1 1 January 2012
Illinois Monmouth Review Atlas 1 1 1 1 January 2012
Illinois Morris Daily Herald 1 1 1 1 January 2012
Illinois Mount Carmel Daily Republican-Register 1 1 January 2012
Illinois Mount Vernon Register-News 1 1 1 1 January 2012
Illinois Murphysboro Murphysboro American 1 1 January 2012
Illinois Naperville Sun 1 1 January 2012
Illinois Newton Newton Press-Mentor 1 1 January 2012
Illinois Oak Brook Suburban Life 1 1 January 2012
Illinois Olney Olney Daily Mail 1 1 1 1 January 2012
Illinois Oquawka Oquawka Current 1 1 January 2012
Illinois Ottawa The Times 1 1 1 1 January 2012
Illinois Palos Heights The Regional News 1 1 January 2012
Illinois Paris Paris - Beacon News 1 1 January 2012
Illinois Pekin Daily Times 1 1 1 1 January 2012
Illinois Peoria Chillicothe Times-Bulletin 1 1 January 2012
Illinois Peoria East Peoria Times-Courier 1 1 January 2012
Illinois Peoria Journal Star 1 1 January 2012
Illinois Peoria Morton Times-News 1 1 January 2012
Illinois Peoria Peoria Times-Observer 1 1 January 2012
Illinois Peoria Washington Times-Reporter 1 1 January 2012
Illinois Plainfield The Enterprise 1 1 January 2012
Illinois Pontiac Leader 1 1 1 1 January 2012
Illinois Quincy Herald-Whig 1 1 January 2012
Illinois Rock Island/Moline/East Moline Argus-Dispatch 1 1 January 2012
Illinois Rockford Register Star 1 1 1 1 January 2012
Illinois Rushville The Rushville Times 1 1 January 2012
Illinois Salem Salem Times Commoner 1 1 January 2012
Illinois Shawneetown The Gallatin Democrat 1 1 January 2012
Illinois Shelbyville Daily Union 1 1 1 1 January 2012
Illinois Springfield State Journal-Register 1 1 January 2012
Illinois St. Charles Chronicle 1 1 January 2012
Illinois Sterling/Rock Falls Sauk Valley 1 1 1 1 January 2012
Illinois Suburban Chicago Herald 1 1 January 2012
Illinois Suburban Chicago Southtown 1 1 January 2012
Illinois Taylorville Breeze Courier 1 1 January 2012
Illinois Vandalia Leader-Union 1 1 January 2012
Illinois Waukegan/Lake County News Sun 1 1 January 2012
Illinois West Frankfort American 1 1 1 1 January 2012
Illinois Zion Zion Benton News/Bargaineer 1 1 January 2012
Indiana Anderson Herald Bulletin 1 1 January 2012
Indiana Angola Herald-Republican 1 1 January 2012
Indiana Auburn Evening Star 1 1 January 2012
Indiana Batesville The Herald Tribune 1 1 1 1 January 2012
Indiana Bedford The Bedford Times Mail 1 1 January 2012
Indiana Bloomington The Herald Times 1 1 January 2012
Indiana Bloomington-Bedfored-Martinsville Hoosier Times 1 1 January 2012
Indiana Bluffton News-Banner 1 1 January 2012
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Indiana Boonville Boonville Standard 1 1 January 2012
Indiana Brazil Brazil Times 1 1 January 2012
Indiana Bremen The Bremen Enquirer 1 1 January 2012
Indiana Columbia City The Post & Mail 1 1 January 2012
Indiana Columbus Republic 1 1 January 2012
Indiana Connersville News Examiner 1 1 January 2012
Indiana Crawfordsville Journal Review 1 1 January 2012
Indiana Culver The Culver Citizen 1 1 January 2012
Indiana Decatur Decatur Daily Democrat 1 1 January 2012
Indiana Elkhart Truth 1 1 January 2012
Indiana Evansville Courier & Press 1 1 January 2012
Indiana Fort Wayne Journal Gazette 1 1 January 2012
Indiana Frankfort Times 1 1 January 2012
Indiana Franklin Journal 1 1 January 2012
Indiana French Lick Springs Valley Herald 1 1 January 2012
Indiana Ft. Wayne News-Sentinel 1 1 January 2012
Indiana Goshen News 1 1 January 2012
Indiana Greencastle Banner - Graphic 1 1 January 2012
Indiana Greenfield The Daily Reporter 1 1 January 2012
Indiana Greensburg Greensburg Daily News 1 1 1 1 January 2012
Indiana Hope The Hope Star-Journal 1 1 January 2012
Indiana Huntington Herald-Press 1 1 January 2012
Indiana Indianapolis Star & Sunday Select 1 1 January 2012
Indiana Jasper Herald 1 1 January 2012
Indiana Kendallville News-Sun 1 1 1 1 January 2012
Indiana Knox The Leader 1 1 January 2012
Indiana Kokomo Tribune 1 1 January 2012
Indiana La Porte Herald Argus 1 1 January 2012
Indiana Lafayette/West Lafayette Journal and Courier 1 1 January 2012
Indiana LaPorte The LaPorte Herald Argus 1 1 January 2012
Indiana Lawrenceburg Journal Press 1 1 January 2012
Indiana Lebanon The Reporter 1 1 1 1 2 January 2012
Indiana Linton The Daily World 1 1 January 2012
Indiana Logansport Pharos-Tribune 1 1 January 2012
Indiana Madison The Madison Courier 1 1 January 2012
Indiana Marion Chronicle Tribune 1 1 January 2012
Indiana Martinsville The Reporter-Times 1 1 January 2012
Indiana Merriville Post-Tribune 1 1 January 2012
Indiana Michigan City News-Dispatch 1 1 January 2012
Indiana Mooresville The Mooresville/The Decatur 1 1 January 2012
Indiana Mooresville/Decatur Reporter-Times 1 1 January 2012
Indiana Muncie Star-Press 1 1 January 2012
Indiana Munster Times of Northwest Indiana 1 1 January 2012
Indiana Nappanee Nappanee Advance News 1 1 January 2012
Indiana New Albany/Jeffersonville Evening News/Tribune 1 1 January 2012
Indiana New Castle Courier-Times 1 1 January 2012
Indiana North Vernon North Vernon Plain Dealer 1 1 January 2012
Indiana Paoli Paoli Republican 1 1 January 2012
Indiana Peru Tribune 1 1 January 2012
Indiana Plymouth Bourbon News-Mirror 1 1 January 2012
Indiana Plymouth Pilot News 1 1 January 2012
Indiana Portland The Commercial Review 1 1 January 2012
Indiana Princton Princeton Daily Clarion 1 1 January 2012
Indiana Richmond Palladium-Item 1 1 January 2012
Indiana Rochester The Rochester Sentinel 1 1 January 2012
Indiana Rushville The Republican 1 1 1 2 January 2012
Indiana Seymour Tribune 1 1 1 1 January 2012
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Indiana Shelbyville News 1 1 January 2012
Indiana Shoals The Shoals News 1 1 January 2012
Indiana South Bend-Mishawaka Tribune 1 1 January 2012
Indiana Terre Haute Tribune-Star 1 1 January 2012
Indiana Versailles The Versailles Republican 1 1 January 2012
Indiana Vincennes Sun-Commercial 1 1 January 2012
Indiana Wabash Plain Dealer 1 1 January 2012
Indiana Warsaw Times-Union 1 1 January 2012
Indiana Washington The Washington Times-Herald 1 1 January 2012
Indiana Winchester The News-Gazette 1 1 January 2012
Iowa Algona The Algona Upper Des Moines 1 1 January 2012
Iowa Allison Butler County Tribune Journal 1 1 January 2012
Iowa Ames Tribune 1 1 January 2012
Iowa Armstrong Rock Valley Bee 1 1 January 2012
Iowa Atlantic Atlantic News - Telegraph 1 1 January 2012
Iowa Audubon Audubon County Advocate Journal 1 1 January 2012
Iowa Bedford The Bedford Times-Press 1 1 January 2012
Iowa Boone Boone News-Republican 1 1 January 2012
Iowa Britt The Britt News Tribune 1 1 January 2012
Iowa Burlington Hawk Eye 1 1 1 1 January 2012
Iowa Carroll Daily Times Herald 1 1 January 2012
Iowa Cascade Cascade Pioneer 1 1 January 2012
Iowa Cedar Rapids-Marion Gazette 1 1 January 2012
Iowa Centerville Daily Iowegian 1 1 1 1 January 2012
Iowa Cherokee Chronicle Times 1 1 January 2012
Iowa Clarinda Clarinda Herald-Journal 1 1 January 2012
Iowa Clarksville Clarksville Star 1 1 January 2012
Iowa Clinton Clinton Herald 1 1 1 1 January 2012
Iowa Corwith CWL Times 1 1 January 2012
Iowa Council Bluffs Nonpareil 1 1 1 1 January 2012
Iowa Creston Creston News Advertiser 1 1 January 2012
Iowa Davenport-Bettendorf Quad-City Times 1 1 January 2012
Iowa Denison Denison Review 1 1 January 2012
Iowa Des Moines Register & Sunday Select 1 1 January 2012
Iowa Dows Dows Advocate 1 1 January 2012
Iowa Dubuque Telegraph Herald 1 1 1 1 January 2012
Iowa Dyersville Dyersville Commerical 1 1 January 2012
Iowa Eagle Grove Eagle Grove Eagle 1 1 January 2012
Iowa Fairfield The Fairfield Daily Ledger 1 1 January 2012
Iowa Forest City Forest City Summit 1 1 January 2012
Iowa Fort Dodge Messenger 1 1 January 2012
Iowa Fort Madison Fort Madison Daily Democrat 1 1 January 2012
Iowa Freemont Village Vine 1 1 January 2012
Iowa Ft. Madison Daily Democrat 1 1 January 2012
Iowa Garner Garner Leader & Signal 1 1 January 2012
Iowa Grundy Grove The Grundy Register 1 1 January 2012
Iowa Hamburg Hamburg Reporter 1 1 January 2012
Iowa Hampton Calhoun County Advocate 1 1 January 2012
Iowa Hampton Hampton Chonicle 1 1 January 2012
Iowa Hampton Pioneer Enterprise 1 1 January 2012
Iowa Harlan Harlan News-Advertiser 1 1 January 2012
Iowa Hawarden The Independent/Examiner 1 1 January 2012
Iowa Hull Sioux County Index-Reporter 1 1 January 2012
Iowa Ida Grove Ida County Courier 1 1 January 2012
Iowa Inwood West Lyon Herald 1 1 January 2012
Iowa Iowa City Press-Citizen 1 1 January 2012
Iowa Kalona The Kalona News 1 1 January 2012
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Iowa Kalona The Lone Tree Reporter 1 1 January 2012
Iowa Kanawha Kanawha Reporter 1 1 January 2012
Iowa Keokuk Daily Gate City 1 1 1 1 January 2012
Iowa Keota Keota Eagle 1 1 January 2012
Iowa Knoxville Journal Express 1 1 1 1 2 January 2012
Iowa Knoxville The Chronicle 1 1 January 2012
Iowa Lake City Lake City Graphic 1 1 January 2012
Iowa LeMars LeMars Daily Sentinel 1 1 January 2012
Iowa Logan Logan Herald-Observer 1 1 January 2012
Iowa Marshalltown Times-Republican 1 1 January 2012
Iowa Mason City Sunday Globe 1 1 1 1 January 2012
Iowa Mount Pleasant Mt. Pleasant News 1 1 January 2012
Iowa Muscatine Journal 1 1 January 2012
Iowa New Sharon New Sharon Sun 1 1 January 2012
Iowa Newton Newton Daily News 1 1 January 2012
Iowa Osage Mitchell County Press News 1 1 January 2012
Iowa Osceola Osceola Sentinel-Tribune 1 1 January 2012
Iowa Oskaloosa Oskaloosa Herald 1 1 1 1 January 2012
Iowa Ottumwa The Ottumwa Courier 1 1 1 1 January 2012
Iowa Rock Rapids Lyon County Reporter 1 1 January 2012
Iowa Sheffield Sheffield Press 1 1 January 2012
Iowa Shenandoah Valley News Today 1 1 January 2012
Iowa Sigourney Sigourney News Review 1 1 January 2012
Iowa Sioux City Journal 1 1 1 1 January 2012
Iowa Spencer The Daily Reporter 1 1 January 2012
Iowa Spirit Lake Dickinson County News 1 1 January 2012
Iowa Storm Lake Pilot Tribune 1 1 January 2012
Iowa Story City The Story City Herald 1 1 January 2012
Iowa Tipton The Tipton Conservative and 1 1 January 2012
Iowa Washington The Washington Evening Journal 1 1 January 2012
Iowa Waterloo-Cedar Falls-Evansdale Courier 1 1 January 2012
Iowa West Branch West Branch Times 1 1 January 2012
Iowa West Liberty The West Liberty Index 1 1 January 2012
Iowa What Cheer What Cheer Paper 1 1 January 2012
Iowa Woodbine The Woodbine Twiner 1 1 January 2012
Kansas Abilene Abilene Reflector-Chronicle 1 1 1 1 January 2012
Kansas Arkansas City Traveler 1 1 January 2012
Kansas Atchison Atchison Daily Globe 1 1 January 2012
Kansas Augusta Augusta Daily Gazette 1 1 January 2012
Kansas Baxter Springs Baxter Springs News 1 1 January 2012
Kansas Chanute The Chanute Tribune 1 1 1 1 January 2012
Kansas Coffeyville The Coffeyville Journal 1 1 January 2012
Kansas Columbus The Columbus Advocate 1 1 January 2012
Kansas Dodge City Globe 1 1 January 2012
Kansas El Dorado The El Dorado Times 1 1 January 2012
Kansas Ellsworth Ellsworth County 1 1 January 2012
Kansas Emporia Gazette 1 1 January 2012
Kansas Eureka The Eureka Herald 1 1 January 2012
Kansas Garden City Telegram 1 1 January 2012
Kansas Garnett The Anderson County Review 1 1 January 2012
Kansas Goodland The Goodland Daily News 1 1 January 2012
Kansas Great Bend The Great Bend Tribune 1 1 January 2012
Kansas Hays News 1 1 1 1 January 2012
Kansas Herington The Herington Times 1 1 January 2012
Kansas Hiawatha Hiawatha World 1 1 January 2012
Kansas Holton The Holton Recorder 1 1 January 2012
Kansas Hutchinson The Hutchinson News 1 1 1 1 January 2012
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Kansas Junction City The Daily Union 1 1 January 2012
Kansas Lawrence Journal-World 1 1 1 1 January 2012
Kansas Leavenworth Times 1 1 January 2012
Kansas Liberal Southwest Daily Times 1 1 January 2012
Kansas Louisburg Louisburg Herald 1 1 January 2012
Kansas Manhattan Mercury 1 1 January 2012
Kansas McPherson McPherson Sentinel 1 1 January 2012
Kansas Newton Kansan 1 1 January 2012
Kansas Norton The Norton Telegram 1 1 January 2012
Kansas Oberlin Bird City Times 1 1 January 2012
Kansas Oberlin Colby Free Press 1 1 January 2012
Kansas Oberlin The Oberlin Herald 1 1 January 2012
Kansas Oberlin The St. Francis Herald 1 1 January 2012
Kansas Osawatomie Osawatomie Graphic 1 1 January 2012
Kansas Oskaloosa The Oskaloosa Independent 1 1 January 2012
Kansas Ottawa The Ottawa Herald 1 1 1 1 January 2012
Kansas Overland Park Blue Valley Sun 1 1 January 2012
Kansas Overland Park Johnson County Sun 1 1 January 2012
Kansas Overland Park Overland Park Sun 1 1 January 2012
Kansas Overland Park Wednesday Sun 1 1 January 2012
Kansas Paola The Miami County Republic 1 1 January 2012
Kansas Parsons Parsons Sun 1 1 1 1 January 2012
Kansas Pittsburg Sun 1 1 1 1 January 2012
Kansas Pratt The Pratt Tribune 1 1 January 2012
Kansas Salina Journal 1 1 1 1 January 2012
Kansas Shawnee The Shawnee Dispatch 1 1 January 2012
Kansas Stockton Stockton Sentinel 1 1 January 2012
Kansas Topeka Capital-Journal 1 1 1 1 January 2012
Kansas Valley Falls The Vindicator 1 1 January 2012
Kansas Wellington Wellington Daily News 1 1 January 2012
Kansas Wichita Eagle 1 1 January 2012
Kansas Winfield Courier 1 1 January 2012
Kentucky Ashland Sunday Independent 1 1 January 2012
Kentucky Bardstown Kentucky Standard 1 1 1 1 January 2012
Kentucky Benton The Tribune Courier 1 1 January 2012
Kentucky Bowling Green Daily News 1 1 1 1 January 2012
Kentucky Brownsville Edmonson News 1 1 January 2012
Kentucky Cadiz The Cadiz Record 1 1 January 2012
Kentucky Corbin Times-Tribune 1 1 1 1 January 2012
Kentucky Danville The Advocate Messenger 1 1 1 1 January 2012
Kentucky Eddyville Lyon County Herald-Ledger 1 1 January 2012
Kentucky Elizabethtown News-Enterprise 1 1 January 2012
Kentucky Falmouth The Falmouth Outlook 1 1 January 2012
Kentucky Flemingsburg Flemingsburg Gazette 1 1 January 2012
Kentucky Frankfort The State Journal 1 1 1 1 January 2012
Kentucky Fulton The Fulton Leader 1 1 January 2012
Kentucky Georgetown Georgetown News Graphic 1 1 January 2012
Kentucky Glasgow Daily Times 1 1 January 2012
Kentucky Greenup Greenup County News-Times 1 1 January 2012
Kentucky Harlan Enterprise 1 1 January 2012
Kentucky Henderson Gleaner 1 1 January 2012
Kentucky Hopkinsville Kentucky New Era 1 1 1 1 January 2012
Kentucky Leitchfield Grayson Co. News - Gazette 1 1 January 2012
Kentucky Lexington Herald-Leader 1 1 January 2012
Kentucky Liberty Casey County News 1 1 January 2012
Kentucky London The Sentinel-Echo 1 1 1 1 2 January 2012
Kentucky Louisville Courier-Journal & Sunday Select 1 1 January 2012
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Kentucky Madisonville Messenger 1 1 January 2012
Kentucky Maysville Ledger Independent 1 1 January 2012
Kentucky Middlesboro The Daily News 1 1 1 1 January 2012
Kentucky Monticello The Wayne County Outlook 1 1 January 2012
Kentucky New Castle Henry County Local 1 1 January 2012
Kentucky Nicholasville The Jessamine Journal 1 1 January 2012
Kentucky Oak Grove The Eagle Post 1 1 January 2012
Kentucky Owensboro Messenger-Inquirer 1 1 January 2012
Kentucky Paducah Sun 1 1 January 2012
Kentucky Pikeville Appalachian News Express 1 1 January 2012
Kentucky Prestonsburg The Floyd County Times 1 1 January 2012
Kentucky Princeton The Times - Leader 1 1 January 2012
Kentucky Richmond Register 1 1 January 2012
Kentucky Russellville News Democrat 1 1 1 1 January 2012
Kentucky Salyersville The Salyersville Independent 1 1 January 2012
Kentucky Shepherdsville The Pioneer News 1 1 January 2012
Kentucky Somerset Commonwealth Journal 1 1 January 2012
Kentucky Taylorsville Taylorsville Spencer Magnet 1 1 January 2012
Kentucky Whitley City The McCreary County Record 1 1 January 2012
Kentucky Winchester Sun 1 1 1 1 January 2012
Louisianna Bastrop Bastrop Daily Enterprise 1 1 January 2012
Lousianna Abbeville Meridonial-News-Gazette 1 1 January 2012
Lousianna Alexandria Town Talk 1 1 January 2012
Lousianna Baton Rouge Sunday Advocate 1 1 January 2012
Lousianna Belle Chasse The Plaquemines Watchman 1 1 January 2012
Lousianna Bogalusa Daily News 1 1 1 1 January 2012
Lousianna Bossier City Bossier Press-Tribune 1 1 January 2012
Lousianna Covington St. Tammany News 1 1 1 1 January 2012
Lousianna Crowley Post Signal 1 1 January 2012
Lousianna DeRidder Beauregard Daily News 1 1 January 2012
Lousianna Gonzales Ascension Citizen 1 1 January 2012
Lousianna Hammond Star 1 1 January 2012
Lousianna Houma Courier 1 1 January 2012
Lousianna Jena The Jena - Times 1 1 January 2012
Lousianna La Place L'Observeteur 1 1 1 1 January 2012
Lousianna Lafayette Advertiser 1 1 January 2012
Lousianna Lake Charles American Press 1 1 January 2012
Lousianna Leesville Leesville News Leader 1 1 January 2012
Lousianna Minden Minden Press-Herald 1 1 January 2012
Lousianna Monroe News-Star 1 1 January 2012
Lousianna New Iberia Sunday Iberian 1 1 January 2012
Lousianna New Orleans Times-Picayune 1 1 January 2012
Lousianna Opelousas World 1 1 January 2012
Lousianna Ruston Daily Leader 1 1 January 2012
Lousianna Shreveport Times 1 1 January 2012
Lousianna Sulphur Southwest Daily News 1 1 January 2012
Lousianna Thibodaux Comet 1 1 January 2012
Maine Augusta-Waterville Kennebec Journal-Morning Sentinel 1 1 January 2012
Maine Bangor News 1 1 1 1 January 2012
Maine Biddeford Journal-Tribune 1 1 January 2012
Maine Lewiston/Auburn Sun-Journal 1 1 1 1 January 2012
Maine Portland Maine Sunday Telegram 1 1 January 2012
Maine Portland Portland Press Herald 1 1 January 2012
Maryland Annapolis Capital 1 1 January 2012
Maryland Annapolis Maryland Gazette 1 1 1 1 January 2012
Maryland Baltimore Baltimore Weeklies 1 1 January 2012
Maryland Baltimore Sunday Sun 1 1 January 2012
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Maryland Baltimore Times 1 1 January 2012
Maryland Centreville The Record-Observer 1 1 January 2012
Maryland Chestertown Kent County News 1 1 January 2012
Maryland Cumberland Times-News 1 1 January 2012
Maryland Denton The Times Record 1 1 January 2012
Maryland Easton Sunday Star 1 1 1 1 January 2012
Maryland Elkton Cecil Whig 1 1 January 2012
Maryland Frederick News-Post 1 1 1 1 January 2012
Maryland Hagerstown Herald-Mail 1 1 January 2012
Maryland Salisbury Times 1 1 January 2012
Maryland Stevensville The Bay Times 1 1 January 2012
Maryland Westminster Carrol County Times 1 1 1 1 January 2012
Massachusetts Attleboro Sun Chronicle 1 1 1 1 January 2012
Massachusetts Beverly News 1 1 January 2012
Massachusetts Boston Herald 1 1 January 2012
Massachusetts Boston Sunday Globe 1 1 January 2012
Massachusetts Brockton Enterprise 1 1 January 2012
Massachusetts Fall River Herald News 1 1 January 2012
Massachusetts Fitchburg Sentinel & Enterprise 1 1 January 2012
Massachusetts Framingham/Milford Metrowest News 1 1 January 2012
Massachusetts Gloucester Daily Times 1 1 January 2012
Massachusetts Greenfield Recorder 1 1 1 1 January 2012
Massachusetts Hyannis/Cape Cod Cape Cod Times 1 1 January 2012
Massachusetts Lowell Sun 1 1 January 2012
Massachusetts New Bedford Sunday Standard-Times 1 1 January 2012
Massachusetts Newburyport Daily News 1 1 January 2012
Massachusetts North Adams Transcript 1 1 1 1 January 2012
Massachusetts North Andover Eagle-Tribune 1 1 January 2012
Massachusetts North Reading North Reading Transcript 1 1 January 2012
Massachusetts North Reading The Lynnfield Villager 1 1 January 2012
Massachusetts Northampton Hampshire Gazette 1 1 January 2012
Massachusetts Pittsfield/Berkshire Eagle 1 1 January 2012
Massachusetts Quincy Patriot Ledger 1 1 January 2012
Massachusetts Springfield Sunday Republican 1 1 January 2012
Massachusetts Taunton Gazette 1 1 January 2012
Massachusetts Worcester Maine Sunday Telegram 1 1 January 2012
Michigan Adrian Telegram 1 1 January 2012
Michigan Alpena News 1 1 January 2012
Michigan Ann Arbor News 1 1 January 2012
Michigan Bad Axe Huron Daily Tribune 1 1 January 2012
Michigan Battle Creek Enquirer 1 1 January 2012
Michigan Bay City Times 1 1 January 2012
Michigan Benton Harbor/St. Joseph Herald-Palladium 1 1 January 2012
Michigan Big Rapids Big Rapids Pioneer 1 1 January 2012
Michigan Big Rapids/Manistee Pioneer-News Advocate 1 1 January 2012
Michigan Cadillac News 1 1 1 1 January 2012
Michigan Caro Tuscola County Advertiser 1 1 January 2012
Michigan Cheboygan Daily Tribune 1 1 1 1 January 2012
Michigan Coldwater The Daily Reporter 1 1 1 1 January 2012
Michigan Dearborn Press & Guide 1 1 January 2012
Michigan Detroit News and Free Press & Sunday Select 1 1 January 2012
Michigan Escanaba Press 1 1 January 2012
Michigan Flint Journal 1 1 January 2012
Michigan Grand Haven Tribune 1 1 January 2012
Michigan Grand Rapids Press 1 1 January 2012
Michigan Greenville News 1 1 January 2012
Michigan Hart Oceana's Herald Journal 1 1 January 2012
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Michigan Hillsdale News 1 1 1 1 January 2012
Michigan Holland Sentinel 1 1 1 1 January 2012
Michigan Houghton Mining Gazette 1 1 January 2012
Michigan Howell Livingston County Daily Press & 1 1 1 1 January 2012
Michigan Ionia Sentinel-Standard 1 1 January 2012
Michigan Iron Mountain/Kingsford News 1 1 January 2012
Michigan Ironwood (The Ironwood) Daily Globe 1 1 January 2012
Michigan Jackson Citizen Patriot 1 1 January 2012
Michigan Kalamazoo Gazette 1 1 January 2012
Michigan Lansing Lansing Community Newspapers 1 1 January 2012
Michigan Lansing State Journal 1 1 January 2012
Michigan Lapeer The County Press 1 1 1 1 January 2012
Michigan Livonia Canton Observer 1 1 January 2012
Michigan Livonia Eccentric 1 1 January 2012
Michigan Livonia Garden City Observer 1 1 January 2012
Michigan Livonia Livonia Observer 1 1 1 1 January 2012
Michigan Livonia Plymouth Observer 1 1 January 2012
Michigan Livonia Rochester Eccentric 1 1 January 2012
Michigan Livonia Westland Observer 1 1 January 2012
Michigan Ludington Ludington Daily News 1 1 January 2012
Michigan Manistee Manistee News Advocate 1 1 January 2012
Michigan Marquette Mining Journal 1 1 January 2012
Michigan Midland News 1 1 January 2012
Michigan Milford Milford Times 1 1 January 2012
Michigan Monroe Sunday News 1 1 January 2012
Michigan Mount Clemens Macomb Daily 1 1 January 2012
Michigan Mount Pleasant Morning Sun 1 1 January 2012
Michigan Munising The Munising News 1 1 January 2012
Michigan Muskegon Sunday Chronicle 1 1 January 2012
Michigan New Baltimore The Weekend Voice 1 1 January 2012
Michigan Northville Northville Record 1 1 January 2012
Michigan Northville Novi News 1 1 January 2012
Michigan Owosso Argus-Press 1 1 January 2012
Michigan Petsokey Petoskey News-Review 1 1 January 2012
Michigan Pontiac Oakland Press 1 1 January 2012
Michigan Port Huron Times-Herald 1 1 January 2012
Michigan Rogers City Onaway Outlook 1 1 January 2012
Michigan Rogers City Presque Isle County Advance 1 1 January 2012
Michigan Royal Oak Daily Tribune 1 1 January 2012
Michigan Saginaw News 1 1 January 2012
Michigan Sault Ste. Marie The Evening News 1 1 January 2012
Michigan Shelby Advisor & Source Newspapers 1 1 January 2012
Michigan South Lyon South Lyon Herald 1 1 January 2012
Michigan Southgate News-Herald 1 1 January 2012
Michigan Sturgis Sturgis Journal 1 1 1 1 January 2012
Michigan Tecumseh The Tecumseh Herald 1 1 January 2012
Michigan Three Rivers Three Rivers Commerical News 1 1 January 2012
Michigan Traverse City Record-Eagle 1 1 January 2012
Michigan Whitehall White Lake Beacon 1 1 January 2012
Michigan Ypsilanti Ypsilanti Courier 1 1 January 2012
Michigan Zeeland The Zeeland Record 1 1 January 2012
Minnesota Aitkin Aitkin Independent Age 1 1 January 2012
Minnesota Albert Lea Tribune 1 1 January 2012
Minnesota Austin Daily Herald 1 1 January 2012
Minnesota Bagley Farmers Independent 1 1 January 2012
Minnesota Baudette The Baudette Region 1 1 January 2012
Minnesota Bemidji Pioneer 1 1 January 2012
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Minnesota Brainerd Dispatch 1 1 1 1 January 2012
Minnesota Canby Canby News 1 1 January 2012
Minnesota Clarissa Independent News Herald 1 1 January 2012
Minnesota Cloquet The Pine Journal 1 1 January 2012
Minnesota Cloquet The Pine Knot 1 1 January 2012
Minnesota Cottonwood Tri-County News 1 1 January 2012
Minnesota Crookston Crookston Daily Times 1 1 January 2012
Minnesota Duluth News-Tribune 1 1 January 2012
Minnesota Elbow Lake Grant County Herald 1 1 January 2012
Minnesota Fairmont Sentinel 1 1 January 2012
Minnesota Faribault Faribault Daily News 1 1 1 1 January 2012
Minnesota Fergus Falls Journal 1 1 January 2012
Minnesota Grand Rapids Herald Review 1 1 1 1 January 2012
Minnesota Granite Falls Granite Falls Advocate-Tribune 1 1 January 2012
Minnesota Hibbing The Daily Tribune 1 1 January 2012
Minnesota Isle Mille Lacs Messenger 1 1 January 2012
Minnesota Mankato Free Press 1 1 January 2012
Minnesota Marshall Independent 1 1 January 2012
Minnesota Minnesota Sun Papers 1 1 January 2012
Minnesota Montevideo Montevideo American News 1 1 January 2012
Minnesota Montgomery Montgomery Messenger 1 1 January 2012
Minnesota New Prague The New Prague Times 1 1 January 2012
Minnesota New Ulm Journal 1 1 January 2012
Minnesota Northfield Northfield News 1 1 January 2012
Minnesota Owatonna People's Press 1 1 1 1 January 2012
Minnesota Paynesville The Paynesville Press 1 1 January 2012
Minnesota Red Wing Republican Eagle 1 1 January 2012
Minnesota Redwood Falls The Redwood Falls Gazette 1 1 January 2012
Minnesota Rochester Post-Bulletin 1 1 1 1 January 2012
Minnesota Sleepy Eye Sleepy Eye Herald - Dispatch 1 1 January 2012
Minnesota St. Cloud Times 1 1 January 2012
Minnesota St. James St. James Plaindealer 1 1 January 2012
Minnesota St. Paul Pioneer Press 1 1 January 2012
Minnesota St. Peter St. Peter Herald 1 1 January 2012
Minnesota Staples Staples World 1 1 January 2012
Minnesota Stillwater Gazette 1 1 January 2012
Minnesota Thief River Falls Thief River Falls Times 1 1 January 2012
Minnesota Virginia Mesabi News 1 1 1 1 2 January 2012
Minnesota Waseca Waseca County News 1 1 January 2012
Minnesota Westbrook Westbrook Sentinel/Tribune 1 1 January 2012
Minnesota Willmar West Central Tribune 1 1 January 2012
Minnesota Winona News 1 1 1 1 January 2012
Minnesota Worthington Daily Globe 1 1 January 2012
Mississippi Aberdeen The Monroe County Journal 1 1 January 2012
Mississippi Batesville Panola Partnership 1 1 January 2012
Mississippi Batesville The Panolian 1 1 January 2012
Mississippi Biloxi-Gulfport Sun Herald 1 1 January 2012
Mississippi Brandon Rankin County News 1 1 January 2012
Mississippi Brookhaven Daily Leader 1 1 January 2012
Mississippi Calhoun City The Monitor-Herald 1 1 January 2012
Mississippi Clarksdale Press Register 1 1 1 1 January 2012
Mississippi Cleveland Bolivar Commerical 1 1 1 1 January 2012
Mississippi Columbus Commercial Dispatch 1 1 January 2012
Mississippi Corinth Corinthian 1 1 January 2012
Mississippi Crystal Springs The Meteor 1 1 January 2012
Mississippi Fulton The Itawamba County Times 1 1 January 2012
Mississippi Greenville Delta Democrat-Times 1 1 January 2012
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Mississippi Greenwood Commonwealth 1 1 January 2012
Mississippi Grenada The Daily Star 1 1 January 2012
Mississippi Hattiesburg American 1 1 January 2012
Mississippi Hazelhurst Copiah County Courier 1 1 January 2012
Mississippi Holly Springs The South Reporter 1 1 January 2012
Mississippi Houston The Chickasaw Journal 1 1 January 2012
Mississippi Jackson Clarion-Ledger 1 1 January 2012
Mississippi Kosciusko The Star-Herald 1 1 January 2012
Mississippi Laurel Laurel Leader-Call 1 1 1 1 January 2012
Mississippi McComb Enterprise-Journal 1 1 January 2012
Mississippi Meadville Wilk-Amite Record 1 1 January 2012
Mississippi Meridan The Meridian Star 1 1 1 1 January 2012
Mississippi Monticello Lawrence County Press 1 1 January 2012
Mississippi Morton Spirit of Morton 1 1 January 2012
Mississippi Natchez Democrat 1 1 January 2012
Mississippi New Albany New Albany Gazette 1 1 January 2012
Mississippi Oxford The Oxford Eagle 1 1 January 2012
Mississippi Philadelphia Kemper County Messener 1 1 January 2012
Mississippi Philadelphia The Neshoba Democrat 1 1 January 2012
Mississippi Picayune Item 1 1 January 2012
Mississippi Pontotoc The Pontotoc Progress 1 1 January 2012
Mississippi Senatobia The Democrat 1 1 January 2012
Mississippi Starkville Starkville Daily News 1 1 January 2012
Mississippi Tupelo Northeast Mississippi Journal 1 1 January 2012
Mississippi Tylertown The Tylertown Times 1 1 January 2012
Mississippi Vicksburg Post 1 1 1 1 January 2012
Mississippi West Point Daily Times Leader 1 1 January 2012
Missouri Aurora Aurora Advertiser 1 1 January 2012
Missouri Bloomfield The North Stoddard Countian 1 1 January 2012
Missouri Bolivar Bolivar Herald -Free Press 1 1 January 2012
Missouri Boonville Boonville Daily News 1 1 January 2012
Missouri Branson The Ozarks Sentinel 1 1 January 2012
Missouri Buffalo Buffalo Reflex 1 1 January 2012
Missouri Camdenton Lake Sun Leader 1 1 January 2012
Missouri Cape Girardeau Southeast Missourian 1 1 January 2012
Missouri Carthage The Carthage Press 1 1 January 2012
Missouri Caruthersville Democrat-Argus 1 1 January 2012
Missouri Columbia Missourian 1 1 January 2012
Missouri Columbia Tribune 1 1 January 2012
Missouri Concordia The Concordian 1 1 January 2012
Missouri Cuba The Cuba Free Press 1 1 January 2012
Missouri Dexter Daily Statesman 1 1 January 2012
Missouri Dexter Daily Statesman 1 1 January 2012
Missouri Edina The Edina Sentinel 1 1 January 2012
Missouri Fulton The Fulton Sun 1 1 1 1 January 2012
Missouri Gladstone Liberty Tribune 1 1 January 2012
Missouri Gladstone Sun Gazette 1 1 January 2012
Missouri Gladstone Sun Tribune 1 1 January 2012
Missouri Hannibal Courier-Post 1 1 1 1 January 2012
Missouri Hermitage The Index 1 1 January 2012
Missouri Independence The Examiner 1 1 January 2012
Missouri Independence/Blue Springs Examiner 1 1 January 2012
Missouri Jefferson City Sunday News Tribune 1 1 January 2012
Missouri Joplin Globe 1 1 January 2012
Missouri Kahoka The Media 1 1 January 2012
Missouri Kansas City Star 1 1 January 2012
Missouri Kennett Daily Dunklin Democrat 1 1 1 1 January 2012
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Missouri Kirksville Kirksville Daily Express 1 1 1 1 January 2012
Missouri Lebanon The Lebanon Daily Record 1 1 January 2012
Missouri Malden Delta News Citizen 1 1 January 2012
Missouri Marble Hill The Banner Press 1 1 January 2012
Missouri Marshfield The Marshfield Mall 1 1 January 2012
Missouri Maryville Maryville Daily Forum 1 1 1 1 January 2012
Missouri Mexico Mexico Ledger 1 1 1 1 January 2012
Missouri Moberly Evening Democrat 1 1 January 2012
Missouri Moberly Moberly Monitor - Index and Evening 1 1 1 1 January 2012
Missouri Monett The Monett Times 1 1 January 2012
Missouri Neosho Neosho Daily News 1 1 January 2012
Missouri Nevada Sunday Journal 1 1 January 2012
Missouri New Madrid The Weekly Record 1 1 January 2012
Missouri Ozark Christian County Headliner 1 1 January 2012
Missouri Palmyra Palmyra Spectator 1 1 January 2012
Missouri Park Hills Daily Journal 1 1 January 2012
Missouri Perrysville Perry County Repubic-Monitor 1 1 January 2012
Missouri Poplar Bluff Daily American Republic 1 1 January 2012
Missouri Portageville Missourian-News 1 1 January 2012
Missouri Republic Republic Monitor 1 1 January 2012
Missouri Rogersville South County Mail 1 1 January 2012
Missouri Rolla Rolla Daily News 1 1 1 1 January 2012
Missouri Sedalia Democrat 1 1 1 1 January 2012
Missouri Sikeston Standard Democrat 1 1 January 2012
Missouri Springfield News-Leader 1 1 January 2012
Missouri St. Joseph News-Press 1 1 1 1 January 2012
Missouri St. Louis Post-Dispatch 1 1 January 2012
Missouri St. Louis Suburban Newspapers of Greater 1 1 January 2012
Missouri Steele The Steele Enterprise 1 1 January 2012
Missouri Stockton Cedar County Republican 1 1 January 2012
Missouri Thayer South Missourian-News 1 1 January 2012
Missouri Warrensburg The Daily Star-Journal 1 1 January 2012
Missouri Warrenton Warren County Record 1 1 January 2012
Missouri Washington Washington Missourian 1 1 January 2012
Missouri West Plains West Plains Daily Quill 1 1 January 2012
Montana Big Timber The Big Timber Pioneer 1 1 January 2012
Montana Billings Gazette 1 1 1 1 January 2012
Montana Bozeman Chronicle 1 1 January 2012
Montana Butte-Anaconda Montana Standard 1 1 January 2012
Montana Chinook The Journal News-Opinion 1 1 January 2012
Montana Columbus Stillwater County News 1 1 January 2012
Montana Dillon Dillon Tribune Examiner 1 1 January 2012
Montana Fairfield Fairfield Sun Times 1 1 January 2012
Montana Forsyth The Independent Press 1 1 January 2012
Montana Glendive Ranger Review 1 1 January 2012
Montana Great Falls Tribune 1 1 January 2012
Montana Hardin Big Horn County New 1 1 January 2012
Montana Havre Havre Daily News 1 1 January 2012
Montana Helena Independent Record 1 1 1 1 January 2012
Montana Kalispell Daily Inter Lake 1 1 1 1 January 2012
Montana Lewistown Lewistown News-Argus 1 1 January 2012
Montana Libby The Western News 1 1 January 2012
Montana Livingston The Livingston Enterprise 1 1 January 2012
Montana Miles City Miles City Star 1 1 January 2012
Montana Missoula Missoulian 1 1 January 2012
Montana Polson Lake County Leader 1 1 January 2012
Montana Red Lodge Carbon County News 1 1 January 2012
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Montana Sidney Sidney Herald 1 1 January 2012
Montana Townsend The Townsend Star 1 1 January 2012
Nebraska Alliance Alliance Times-Herald 1 1 January 2012
Nebraska Ashland Ashland Gazette 1 1 January 2012
Nebraska Boulder City Review -Journal 1 1 January 2012
Nebraska Breatrice Breatrice Daily Sun 1 1 1 1 January 2012
Nebraska Broken Bow Custer County Chief 1 1 January 2012
Nebraska Chadron The Chadron Record 1 1 January 2012
Nebraska Columbus Columbus Telegram 1 1 1 1 January 2012
Nebraska David City Banner Press 1 1 January 2012
Nebraska Fremont Fremont Tribune 1 1 1 1 January 2012
Nebraska Gordon Gordon Journal 1 1 January 2012
Nebraska Gothenburg Gothenburg Times 1 1 January 2012
Nebraska Grand Island Independent 1 1 1 1 January 2012
Nebraska Hasting Hastings Tribune 1 1 1 1 January 2012
Nebraska Hebron Journal - Register 1 1 January 2012
Nebraska Kearney Hub 1 1 1 1 January 2012
Nebraska Lexington Lexington Clipper-Herald 1 1 January 2012
Nebraska Lincoln Journal-Star 1 1 January 2012
Nebraska McCook McCook Daily Gazette 1 1 January 2012
Nebraska Minden The Minden Courier 1 1 January 2012
Nebraska Nebraska City Nebraska City News-Press 1 1 January 2012
Nebraska Norfolk Norfolk Daily News 1 1 January 2012
Nebraska North Platte Telegraph 1 1 1 1 January 2012
Nebraska Omaha World-Herald 1 1 January 2012
Nebraska Ord The Ord Quiz 1 1 January 2012
Nebraska Papillion PapillionTimes 1 1 January 2012
Nebraska Papillion Ralston Recorder 1 1 January 2012
Nebraska Ponca Nebraska Journal Leader 1 1 January 2012
Nebraska Schuyler The Schuyler Sun 1 1 January 2012
Nebraska Scottsbluff Star Herald 1 1 1 1 January 2012
Nebraska Sidney Sun - Telegraph 1 1 January 2012
Nebraska Sutton Clay County News 1 1 January 2012
Nebraska Syracuse Syracuse Journal-Democrat 1 1 January 2012
Nebraska Wahoo Wahoo Newspaper 1 1 January 2012
Nebraska Waverly Waverly News 1 1 January 2012
Nebraska York News-Times 1 1 January 2012
Nevada Battle Mountain The Battle Mountain Bugle 1 1 January 2012
Nevada Carson City Appeal 1 1 1 1 January 2012
Nevada Elko Elko Daily Free Press 1 1 January 2012
Nevada Ely Ely Times 1 1 January 2012
Nevada Fallon Lahontan Valley News and Eagle 1 1 1 1 January 2012
Nevada Gardnerville The Record Courier 1 1 January 2012
Nevada Las Vegas El Tiempo 1 1 January 2012
Nevada Las Vegas Review -Journal 1 1 1 1 January 2012
Nevada Mesquite Desert Valley Times 1 1 January 2012
Nevada Pahrump Pahrump Valley Times 1 1 January 2012
Nevada Reno Gazette-Journal & Sunday Select 1 1 January 2012
Nevada Sparks Tribune Sunday 1 1 January 2012
Nevada Tonopah Tonopah Times-Bonanza/Goldfield 1 1 January 2012
Nevada Winnemucca The Humboldt Sun 1 1 January 2012
New Hampshire Claremont Eagle Times 1 1 January 2012
New Hampshire Concord Monitor 1 1 January 2012
New Hampshire Dover/Laconia Citizen-Foster's Sunday Citizen 1 1 January 2012
New Hampshire Hudson The Telegraph 1 1 January 2012
New Hampshire Keene Sentinel 1 1 January 2012
New Hampshire Lebanon/Hanover Valley News 1 1 January 2012
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New Hampshire Manchester New Hampshire News 1 1 January 2012
New Hampshire Nashua Telegraph 1 1 January 2012
New Hampshire Portsmouth Herald 1 1 January 2012
New Hampshire Tonopah Times-Bonanza 1 1 January 2012
New Jersey Atlantic City Press 1 1 January 2012
New Jersey Bergen County Record 1 1 January 2012
New Jersey Bridgewater Courier-News 1 1 January 2012
New Jersey Camden/Cherry Hill Courier-Post 1 1 January 2012
New Jersey Cherry Hill My Community Trend 1 1 January 2012
New Jersey East Brunswick Home News Tribune 1 1 January 2012
New Jersey Flemington Hunterdon Observer 1 1 January 2012
New Jersey Hackensack Suburban Trends 1 1 January 2012
New Jersey Jersey City The Jersey Journal 1 1 January 2012
New Jersey Morristown/Parsippany Record 1 1 January 2012
New Jersey Neptune Asbury Park Press 1 1 January 2012
New Jersey Newark Star-Ledger 1 1 January 2012
New Jersey Newton New Jersey Herald 1 1 1 1 January 2012
New Jersey Salem Today's Sunbeam 1 1 January 2012
New Jersey Trenton Times 1 1 January 2012
New Jersey Trenton Trentonian 1 1 January 2012
New Jersey Vineland Journal 1 1 January 2012
New Jersey Willingboro Burlington County Times 1 1 January 2012
New Jersey Woodbury Times 1 1 January 2012
New Mexico Alamagordo Times 1 1 January 2012
New Mexico Albuquerque Journal 1 1 1 1 2 January 2012
New Mexico Belen Valencia County News-Bulletin 1 1 1 1 January 2012
New Mexico Carlsbad Current-Argus 1 1 January 2012
New Mexico Clovis News Journal 1 1 1 1 January 2012
New Mexico Farmington Times 1 1 January 2012
New Mexico Gallup Independent 1 1 1 1 January 2012
New Mexico Hobbs News Sun 1 1 1 1 January 2012
New Mexico Las Alamos Los Alamos Monitor 1 1 January 2012
New Mexico Las Cruces Sun-News 1 1 January 2012
New Mexico Las Vegas Las Vegas Optic 1 1 January 2012
New Mexico Los Alamos Los Alamos Monitor 1 1 January 2012
New Mexico Lovington The Lovington Daily Leader 1 1 January 2012
New Mexico Portales News-Tribune 1 1 1 1 January 2012
New Mexico Roswell Record 1 1 1 1 January 2012
New Mexico Santa Fe New Mexican 1 1 January 2012
New Mexico Socorro El Defensor Chieftain 1 1 1 1 January 2012
New Mexico Tucumcari Quay County Sun 1 1 January 2012
New York Adirondack Enterprise 1 1 January 2012
New York Albany Times Union 1 1 January 2012
New York Auburn Citizen 1 1 January 2012
New York Batavia Daily News 1 1 1 1 January 2012
New York Binghamton Press & Sun-Bulletin 1 1 January 2012
New York Buffalo News 1 1 January 2012
New York Callicoon Sullivan County Democrat 1 1 January 2012
New York Canandaigua Messenger 1 1 January 2012
New York Catskill Daily Mail 1 1 1 1 January 2012
New York Corning Leader 1 1 January 2012
New York Dansville Genesee Country Express 1 1 January 2012
New York Dunkirk/Fredonia Observer 1 1 January 2012
New York Elmira Star-Gazette 1 1 January 2012
New York Geneseo Livingston County News 1 1 January 2012
New York Geneva Finger Lakes Times 1 1 January 2012
New York Glens Falls Post-Star 1 1 January 2012
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New York Gloversville Leader-Herald 1 1 January 2012
New York Herkimer The Evening Telegram 1 1 January 2012
New York Hornell Tribune 1 1 January 2012
New York Hudson Register-Star 1 1 1 1 January 2012
New York Ithaca Journal 1 1 January 2012
New York Jamestown Post-Journal 1 1 January 2012
New York Kingston Freeman 1 1 January 2012
New York Little Falls The Evening Times 1 1 January 2012
New York Long Island Newsday 1 1 January 2012
New York Melville This Week 1 1 January 2012
New York Middletown Times Herald-Record 1 1 January 2012
New York New York Post 1 1 January 2012
New York New York City Daily News 1 1 January 2012
New York Niagara Falls Sunday Niagara 1 1 January 2012
New York Ogdensburg Journal-Advance News 1 1 January 2012
New York Olean Times Herald 1 1 January 2012
New York Oneida Dispatch 1 1 January 2012
New York Oneonta Cooperstown Crier 1 1 January 2012
New York Oneonta Daily Star 1 1 1 1 January 2012
New York Oswego Palladium-Times 1 1 1 1 January 2012
New York Oswego Pennysaver 1 1 January 2012
New York Penn Yan The Chronicle-Express 1 1 January 2012
New York Plattsburgh Press-Republican 1 1 1 1 January 2012
New York Poughkeepsie Journal 1 1 January 2012
New York Rochester Democrat and Chronicle 1 1 January 2012
New York Saratoga Springs Saratogian 1 1 January 2012
New York Schenectady Gazette 1 1 January 2012
New York Staten Island Advance 1 1 January 2012
New York Syracuse Post-Standard 1 1 January 2012
New York Troy Record 1 1 January 2012
New York Utica Observer-Dispatch 1 1 January 2012
New York Wappingers Falls Southern Dutchess News 1 1 January 2012
New York Watertown Times 1 1 1 1 January 2012
New York White Plains Journal News Group 1 1 January 2012
North Carolina Ahoskie Roanoke-Chowan News Herald 1 1 January 2012
North Carolina Albemarle The Stanley News & Press 1 1 1 1 January 2012
North Carolina Asheboro Courier-Tribune 1 1 January 2012
North Carolina Asheboro The Randolph Guide 1 1 January 2012
North Carolina Asheville Citizen-Times 1 1 January 2012
North Carolina Bladen The Bladen Journal 1 1 January 2012
North Carolina Boone The Watauga Democrat 1 1 1 1 January 2012
North Carolina Boone Watauga Mountain Times 1 1 January 2012
North Carolina Burgaw The Pender Chronicle 1 1 January 2012
North Carolina Burlington Times-News 1 1 1 1 2 January 2012
North Carolina Chapel Hill The Chapel Hill News 1 1 January 2012
North Carolina Charlotte Carolina Weekly 1 1 January 2012
North Carolina Charlotte Observer 1 1 January 2012
North Carolina Clemmons The Clemmons Courier 1 1 January 2012
North Carolina Clinton The Sampson Independent 1 1 January 2012
North Carolina Concord/Kannapolis Independent Tribune 1 1 January 2012
North Carolina Dunn The Daily Record 1 1 January 2012
North Carolina Durham Herald-Sun 1 1 January 2012
North Carolina Durham News 1 1 January 2012
North Carolina Eden News 1 1 January 2012
North Carolina Elizabeth City Advance 1 1 January 2012
North Carolina Elkin The Tribune 1 1 January 2012
North Carolina Fayetteville Observer 1 1 January 2012
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North Carolina Forest City Courier 1 1 January 2012
North Carolina Franklin The Franklin Press 1 1 January 2012
North Carolina Fremont Wayne-Wilson News Leader 1 1 January 2012
North Carolina Fuquay Varina Holly Springs Sun 1 1 January 2012
North Carolina Garner Cleveland Post 1 1 January 2012
North Carolina Gastonia Gaston Gazette 1 1 1 1 2 January 2012
North Carolina Goldsboro News-Argus 1 1 January 2012
North Carolina Greensboro News & Record 1 1 January 2012
North Carolina Greenville Reflector 1 1 January 2012
North Carolina Hayesville Clay County Progress 1 1 January 2012
North Carolina Henderson Dispatch 1 1 January 2012
North Carolina Hendersonville Times-News 1 1 January 2012
North Carolina Hickory Record 1 1 January 2012
North Carolina High Point Enterprise 1 1 January 2012
North Carolina Highlands The Highlander 1 1 January 2012
North Carolina Jacksonville News 1 1 1 1 January 2012
North Carolina Kannapolis Independent Tribune 1 1 January 2012
North Carolina Kinston Free Press 1 1 1 1 January 2012
North Carolina LaGrange Weekly Gazette 1 1 January 2012
North Carolina Laurinburg The Laurinburg Exchange 1 1 1 1 January 2012
North Carolina Lenoir News-Topic 1 1 January 2012
North Carolina Lexington Dispatch 1 1 January 2012
North Carolina Lumberton Robesonian 1 1 January 2012
North Carolina Marion The McDowell News 1 1 1 1 January 2012
North Carolina Marshville The Home News 1 1 January 2012
North Carolina Mocksville Davie County Enterprise-Record 1 1 January 2012
North Carolina Monroe Enquirer-Journal 1 1 January 2012
North Carolina Monroe Waxhaw Exchange 1 1 January 2012
North Carolina Morganton News-Herald 1 1 1 1 January 2012
North Carolina Mount Airy Stokes News 1 1 1 1 January 2012
North Carolina Mount Olive Mount Olive Tribune 1 1 January 2012
North Carolina Mt. Airy Mt. Airy News 1 1 January 2012
North Carolina Murphy Cherokee Scout 1 1 January 2012
North Carolina Nashville The Nashville Graphic 1 1 January 2012
North Carolina New Bern Sun-Journal 1 1 1 1 2 January 2012
North Carolina Newton The Observer-News-Enterprise 1 1 January 2012
North Carolina North Wilkesboro The Record 1 1 January 2012
North Carolina Princeton Princeton News-Leader 1 1 January 2012
North Carolina Raleigh News & Observer 1 1 January 2012
North Carolina Reidsville Review 1 1 January 2012
North Carolina Roanoke Rapids Herald 1 1 January 2012
North Carolina Robbinsville Graham Star 1 1 January 2012
North Carolina Rockingham Richmond County Daily Journal 1 1 1 1 January 2012
North Carolina Rocky Mount Telegram 1 1 January 2012
North Carolina Roxboro The Courier-Times 1 1 January 2012
North Carolina Salisbury/Spencer/East Spencer Salisbury Post 1 1 January 2012
North Carolina Sanford Herald 1 1 January 2012
North Carolina Shelby Star 1 1 1 1 January 2012
North Carolina Southern Pines The Pilot 1 1 1 1 1 January 2012
North Carolina Spring Hope Spring Hope Enterprise 1 1 January 2012
North Carolina Statesville Record & Landmark 1 1 1 1 January 2012
North Carolina Tarboro The Daily Southerner 1 1 1 1 January 2012
North Carolina Taylorsville The Taylorsville Times 1 1 January 2012
North Carolina Washington News 1 1 January 2012
North Carolina Whiteville The News Reporter 1 1 January 2012
North Carolina Wilmington Star-News 1 1 January 2012
North Carolina Wilson Times 1 1 1 1 January 2012
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North Carolina Winston-Salem Journal 1 1 January 2012
North Dakota Beulah Beulah Beacon 1 1 January 2012
North Dakota Bismarck Tribune 1 1 1 1 January 2012
North Dakota Devils Lake Devils Lake Journal 1 1 January 2012
North Dakota Dickinson Press 1 1 January 2012
North Dakota Fargo, ND-Moorhead, MN Forum 1 1 January 2012
North Dakota Garrison Center Republican 1 1 January 2012
North Dakota Garrison McClean Couty Independent 1 1 January 2012
North Dakota Garrison McClusky Gazette 1 1 January 2012
North Dakota Garrison The Leader-News 1 1 January 2012
North Dakota Garrison Underwood News 1 1 January 2012
North Dakota Grand Forks Herald 1 1 January 2012
North Dakota Hankinson Richland County News - Monitor 1 1 January 2012
North Dakota Hazen Hazen Star 1 1 January 2012
North Dakota Jamestown The Jamestown Sun 1 1 January 2012
North Dakota Minot News 1 1 January 2012
North Dakota New Town New Town News 1 1 January 2012
North Dakota Parshall Mountrail County Record 1 1 January 2012
North Dakota Stanley Mountrail County Promoter 1 1 January 2012
North Dakota Turtle Lake McLean County Journal 1 1 January 2012
North Dakota Valley City Valley City Times-Record 1 1 January 2012
North Dakota Velva Velva Voice 1 1 January 2012
North Dakota Wahpeton The Daily News 1 1 January 2012
Ohio Ada Ada Herald 1 1 January 2012
Ohio Akron Beacon Journal 1 1 January 2012
Ohio Akron Cuyahoga Falls News Press 1 1 January 2012
Ohio Akron The Subarbanite 1 1 January 2012
Ohio Alliance Review 1 1 January 2012
Ohio Ashland Ashland County Times 1 1 1 1 January 2012
Ohio Ashtabula Star Beacon 1 1 1 1 January 2012
Ohio Athens Messenger 1 1 1 1 2 January 2012
Ohio Athens Vinton County Courier 1 1 January 2012
Ohio Batavia Clermont Sun 1 1 January 2012
Ohio Bellevue Gazette Publishing Company 1 1 January 2012
Ohio Bowling Green Sentinel-Tribune 1 1 January 2012
Ohio Bryan Times 1 1 1 1 January 2012
Ohio Cambridge Jeffersonian 1 1 January 2012
Ohio Canton Repository 1 1 January 2012
Ohio Carey Mohawk Leader 1 1 January 2012
Ohio Carey The Progressor Times 1 1 January 2012
Ohio Cincinnati Enquirer 1 1 January 2012
Ohio Circleville Herald 1 1 1 1 2 January 2012
Ohio Cleveland Plain Dealer 1 1 January 2012
Ohio Columbus Dispatch 1 1 January 2012
Ohio Columbus Suburban News Publications 1 1 January 2012
Ohio Dayton Daily News 1 1 January 2012
Ohio Defiance Crescent-News 1 1 1 1 January 2012
Ohio Delaware Brown Publishing Co. - Marysville 1 1 January 2012
Ohio Delphos The Daily Herald 1 1 January 2012
Ohio East Liverpool Review 1 1 January 2012
Ohio Eaton The Register-Herald 1 1 January 2012
Ohio Elyria Chronicle-Telegram 1 1 1 1 January 2012
Ohio Fairborn Daily Herald 1 1 January 2012
Ohio Findlay Courier 1 1 January 2012
Ohio Fostoria Review-Times 1 1 January 2012
Ohio Galion The Galion Inquirer 1 1 January 2012
Ohio Gallipolis/Point Pleasant Register (WV) 1 1 January 2012
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Ohio Gallipolis/Point Pleasant Times-Sentinel (OH) 1 1 January 2012
Ohio Georgetown Georgetown News Democrat 1 1 January 2012
Ohio Greenville Advocate 1 1 1 1 January 2012
Ohio Hamilton Journal-News 1 1 January 2012
Ohio Hillsboro Times-Gazette 1 1 1 1 January 2012
Ohio Ironton Tribune 1 1 January 2012
Ohio Jackson Jackson County Times-Journal 1 1 1 1 January 2012
Ohio Kent/Ravenna Record-Courier 1 1 January 2012
Ohio Kenton The Kenton Times 1 1 January 2012
Ohio Lewis Center This Week Community Newspapers 1 1 January 2012
Ohio Lima News 1 1 January 2012
Ohio Lisbon Morning Journal 1 1 January 2012
Ohio Logan News 1 1 1 1 January 2012
Ohio London Brown Publishing Co. - London 1 1 January 2012
Ohio Lorain Journal 1 1 January 2012
Ohio Mansfield News Journal 1 1 January 2012
Ohio Marietta Times 1 1 January 2012
Ohio Marion Star 1 1 January 2012
Ohio Martins Ferry/Belmont County Times Leader 1 1 January 2012
Ohio Marysville Marysville Journal -Tribune 1 1 January 2012
Ohio Marysville Richwood Gazette 1 1 January 2012
Ohio Massillion The Independent 1 1 January 2012
Ohio Medina Gazette 1 1 1 1 January 2012
Ohio Miami Valley Sunday News 1 1 January 2012
Ohio Middletown Journal 1 1 January 2012
Ohio Millersburg The Holmes County Hub 1 1 January 2012
Ohio Minster The Community Post 1 1 January 2012
Ohio Mount Gilead The Mount Gilead Weeklies 1 1 January 2012
Ohio Napoleon Northwest Signal 1 1 1 1 January 2012
Ohio New Lexington Perry County Tribune 1 1 January 2012
Ohio New Philadelphia-Dover Times Reporter 1 1 January 2012
Ohio Newark Advocate 1 1 January 2012
Ohio Norwalk Reflector 1 1 1 1 January 2012
Ohio Ottawa Putnam County Sentinel 1 1 January 2012
Ohio Piqua Call 1 1 1 1 January 2012
Ohio Pomeroy Daily Sentinel 1 1 January 2012
Ohio Portsmouth Times 1 1 January 2012
Ohio Salem News 1 1 January 2012
Ohio Sandusky Register 1 1 1 1 January 2012
Ohio Sidney News 1 1 1 1 January 2012
Ohio Springfield News-Sun 1 1 January 2012
Ohio St. Marys Evening Leader 1 1 January 2012
Ohio Steubenville/Weirton Herald-Star 1 1 January 2012
Ohio Stow Sentry 1 1 January 2012
Ohio Tallmadge Express 1 1 January 2012
Ohio Tiffin Advertiser-Tribune 1 1 January 2012
Ohio Toledo Blade 1 1 January 2012
Ohio Troy Troy Daily News 1 1 January 2012
Ohio Upper Sandusky The Daily Chief-Union (Upper 1 1 January 2012
Ohio Urbana Citizen 1 1 1 1 January 2012
Ohio Van Wert Times-Bulletin 1 1 1 1 January 2012
Ohio Wapakoneta Wapakoneta Daily News 1 1 January 2012
Ohio Warren Tribune Chronicle 1 1 January 2012
Ohio Washington Court House Record-Herald 1 1 1 1 January 2012
Ohio Wauseon Fulton County Expositor 1 1 January 2012
Ohio Waverly The News Watchman 1 1 1 1 2 January 2012
Ohio West Union People's Defender 1 1 January 2012
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Ohio Wheelersburg The Scioto Voice 1 1 January 2012
Ohio Willoughby Lake County News-Herald 1 1 January 2012
Ohio Wilmington News-Journal 1 1 1 1 January 2012
Ohio Wooster Record 1 1 1 1 January 2012
Ohio Xenia Beavercreek News Current 1 1 January 2012
Ohio Xenia Fairborn Daily Herald 1 1 January 2012
Ohio Xenia The Xenia Daily Gazette 1 1 January 2012
Ohio Xenia/Beavercreek Daily Gazette-News Currant 1 1 January 2012
Ohio Youngstown Vindicator 1 1 January 2012
Oklahoma Ada Evening News 1 1 January 2012
Oklahoma Altus Times 1 1 1 1 January 2012
Oklahoma Ardmore The Sunday Ardmorite 1 1 1 1 January 2012
Oklahoma Bartlesville Examiner-Enterprise 1 1 1 1 January 2012
Oklahoma Blackwell Blackwell Journal Tribune 1 1 January 2012
Oklahoma Checotah McIntosh County Democrat 1 1 January 2012
Oklahoma Chickasha Star 1 1 1 1 January 2012
Oklahoma Claremore Daily Progress 1 1 1 1 2 January 2012
Oklahoma Cleveland Cleveland American 1 1 January 2012
Oklahoma Duncan The Duncan Banner 1 1 1 1 January 2012
Oklahoma Durant Democrat 1 1 1 1 January 2012
Oklahoma Edmond The Edmond Sun 1 1 1 1 January 2012
Oklahoma Enid News & Eagle 1 1 January 2012
Oklahoma Eufaula Indian Journal 1 1 January 2012
Oklahoma Fairland The American 1 1 January 2012
Oklahoma Fort Gibson Fort Gibson Times 1 1 January 2012
Oklahoma Frederick Frederick Leader 1 1 January 2012
Oklahoma Grove The Grove Sun 1 1 January 2012
Oklahoma Guthrie Guthrie News Leader 1 1 January 2012
Oklahoma Guymon Guymon Daily Herald 1 1 January 2012
Oklahoma Idabel McCurtain Daily Gazette 1 1 January 2012
Oklahoma Jay Delaware County Journal 1 1 January 2012
Oklahoma Lawton Sunday Constitution 1 1 January 2012
Oklahoma Mangum The Mangum Star News 1 1 January 2012
Oklahoma McAlester News-Capitol 1 1 1 1 January 2012
Oklahoma Miami Miami News-Record 1 1 January 2012
Oklahoma Muskogee Phoenix & Times Democrat 1 1 1 1 January 2012
Oklahoma Mustang Mustang Times 1 1 January 2012
Oklahoma Norman Transcript 1 1 January 2012
Oklahoma Nowata The Nowata Star 1 1 January 2012
Oklahoma Oklahoma City Oklahoman 1 1 January 2012
Oklahoma Okmulgee Okmulgee County 1 1 January 2012
Oklahoma Pauls Valley Daily Democrat 1 1 1 1 January 2012
Oklahoma Perkins The Perkins Journal 1 1 January 2012
Oklahoma Poteau Poteau Daily News 1 1 January 2012
Oklahoma Pryor The Daily Times 1 1 1 1 2 January 2012
Oklahoma Sapulpa Sapulpa Daily Herald 1 1 January 2012
Oklahoma Shawnee News-Star 1 1 1 1 January 2012
Oklahoma Stillwater News-Press 1 1 January 2012
Oklahoma Stilwell Stilwell Democrat Journal 1 1 January 2012
Oklahoma Tahlequah Tahlequah Daily Press 1 1 1 1 2 January 2012
Oklahoma Tulsa World 1 1 1 1 January 2012
Oklahoma Vinita Vinita Daily Journal 1 1 January 2012
Oklahoma Westville Westville Reporter 1 1 January 2012
Oklahoma Woodward News 1 1 1 1 2 January 2012
Oregon Albany/Corvallis Democrat-Herald-Gazette-Times 1 1 1 1 January 2012
Oregon Baker City Baker City Herald 1 1 January 2012
Oregon Bend Bulletin 1 1 January 2012
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Oregon Brookings Curry Coastal Pilot 1 1 January 2012
Oregon Burns Burns Times-Herald 1 1 January 2012
Oregon Coos Bay-North Bend World 1 1 January 2012
Oregon Enterprise Wallowa County Chieftain 1 1 January 2012
Oregon Eugene Register-Guard 1 1 January 2012
Oregon Grants Pass Courier 1 1 January 2012
Oregon Hermiston The Hermiston Herald 1 1 January 2012
Oregon Hood River Hood River News 1 1 January 2012
Oregon John Day Blue Mountain Eagle 1 1 January 2012
Oregon Keizer Keizertimes 1 1 January 2012
Oregon Klamath Falls Herald and News 1 1 1 1 January 2012
Oregon La Grande The Observer 1 1 January 2012
Oregon Madras The Madras Pioneer 1 1 January 2012
Oregon Medford Ashland Daily Tidings 1 1 January 2012
Oregon Medford Mail Tribune 1 1 1 1 January 2012
Oregon Myrtle Creek The Douglas County Mail 1 1 January 2012
Oregon Newberg The Graphic 1 1 January 2012
Oregon Ontario Argus Observer 1 1 January 2012
Oregon Pendleton East Oregonian 1 1 1 1 January 2012
Oregon Portland Oregonian 1 1 January 2012
Oregon Prineville Central Oregonian 1 1 January 2012
Oregon Roseburg News-Review of Douglas County 1 1 1 1 January 2012
Oregon Salem Statesman-Journal 1 1 January 2012
Oregon The Dalles The Dalles Daily Chronicle 1 1 January 2012
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Pennsylvania Allentown Call 1 1 January 2012
Pennsylvania Allentown East Penn Press 1 1 January 2012
Pennsylvania Allentown Northwestern Press 1 1 January 2012
Pennsylvania Allentown Parkland Press 1 1 January 2012
Pennsylvania Allentown Whitehall-Coplay Press 1 1 January 2012
Pennsylvania Altoona Mirror 1 1 January 2012
Pennsylvania Beaver County Times 1 1 January 2012
Pennsylvania Bedford Bedford Gazette 1 1 January 2012
Pennsylvania Bloomsburg Press-Enterprise 1 1 1 1 January 2012
Pennsylvania Bradford Era 1 1 January 2012
Pennsylvania Butler Eagle 1 1 January 2012
Pennsylvania Canton The Canton Independent Sentinel 1 1 January 2012
Pennsylvania Carlisle Sentinel 1 1 1 1 January 2012
Pennsylvania Chambersburg Public Opinion 1 1 January 2012
Pennsylvania Clearfield Progress 1 1 January 2012
Pennsylvania Corry Corry Evening Journal 1 1 January 2012
Pennsylvania Danville News 1 1 January 2012
Pennsylvania Doylestown Intelligencer 1 1 January 2012
Pennsylvania Dubois Tri County Sunday 1 1 January 2012
Pennsylvania Easton Express-Times 1 1 January 2012
Pennsylvania Erie Times-News 1 1 January 2012
Pennsylvania Gettysburg Times 1 1 January 2012
Pennsylvania Greencastle The Echo-Pilot 1 1 January 2012
Pennsylvania Greensburg Tribune-Review 1 1 January 2012
Pennsylvania Greenville The Record-Argus 1 1 January 2012
Pennsylvania Hanover Sun 1 1 January 2012
Pennsylvania Harrisburg Patriot-News 1 1 January 2012
Pennsylvania Hazleton Hazleton Standard-Speaker 1 1 January 2012
Pennsylvania Hellertown The Valley Voice 1 1 January 2012
Pennsylvania Honesdale The Wayne Independent 1 1 January 2012
Pennsylvania Huntingdon The Daily News 1 1 January 2012
Pennsylvania Indiana Gazette 1 1 January 2012
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Pennsylvania Johnstown Tribune-Democrat 1 1 January 2012
Pennsylvania Kane The Kane Republican 1 1 January 2012
Pennsylvania Lancaster News 1 1 January 2012
Pennsylvania Latrobe The Latrobe Bulletin 1 1 January 2012
Pennsylvania Lebanon News 1 1 January 2012
Pennsylvania Lehighton Salisbury Press 1 1 January 2012
Pennsylvania Lehighton Times News 1 1 1 1 January 2012
Pennsylvania Levittown/Bristol Bucks Courier Times 1 1 January 2012
Pennsylvania Lewistown Sentinel 1 1 January 2012
Pennsylvania Lock Haven Express 1 1 January 2012
Pennsylvania McKeesport/Duquesne/Clairton News 1 1 January 2012
Pennsylvania Meadville Tribune 1 1 January 2012
Pennsylvania Milton Lewisburg Daily Journal 1 1 January 2012
Pennsylvania Milton The Standard Journal 1 1 January 2012
Pennsylvania Montrose (The Susquehanna County) 1 1 January 2012
Pennsylvania New Castle News 1 1 January 2012
Pennsylvania New Kensington-Tarentum-Vandegrift Valley News Dispatch 1 1 January 2012
Pennsylvania Newville Valley Times-Star 1 1 January 2012
Pennsylvania Norristown/Lansdale Times Herald 1 1 January 2012
Pennsylvania Oil City Derrick Publishing Co. 1 1 1 1 January 2012
Pennsylvania Philadelphia Daily News 1 1 January 2012
Pennsylvania Philadelphia Inquirer 1 1 January 2012
Pennsylvania Phoenixville Phoenix 1 1 January 2012
Pennsylvania Pittsburgh Post-Gazette 1 1 January 2012
Pennsylvania Pittsburgh Trib Total Media 1 1 January 2012
Pennsylvania Pottstown Mercury 1 1 January 2012
Pennsylvania Pottsville Republican & Herald 1 1 January 2012
Pennsylvania Primos Delaware County Times 1 1 January 2012
Pennsylvania Punxsutawney The Spirit 1 1 January 2012
Pennsylvania Reading Eagle 1 1 January 2012
Pennsylvania Ridway The Ridgway Record 1 1 January 2012
Pennsylvania Sayre Morning Times 1 1 1 1 January 2012
Pennsylvania Scranton Times-Tribune 1 1 1 1 January 2012
Pennsylvania Shamokin The News-Item 1 1 January 2012
Pennsylvania Sharon-Farrell-Sharpsville-Hermitage Herald 1 1 January 2012
Pennsylvania Shippensburg The News-Chronicle 1 1 January 2012
Pennsylvania Smoakin/Pottsville Republican & Herald/News Item 1 1 January 2012
Pennsylvania Somerset Daily American 1 1 January 2012
Pennsylvania St. Marys The Daily Press 1 1 January 2012
Pennsylvania State College Center Daily Times 1 1 January 2012
Pennsylvania Stroudsburg-East Stroudsburg Pocono Record 1 1 1 1 January 2012
Pennsylvania Sunbury Daily Item 1 1 1 1 January 2012
Pennsylvania Towanda Sunday Review 1 1 January 2012
Pennsylvania Towanda The Daily Review 1 1 January 2012
Pennsylvania Tunkhannock The New Age-Examiner 1 1 January 2012
Pennsylvania Tyrone The Daily Herald 1 1 January 2012
Pennsylvania Uniontown Herald-Standard 1 1 January 2012
Pennsylvania Warren Times-Observer 1 1 January 2012
Pennsylvania Washington Observer-Reporter 1 1 1 1 January 2012
Pennsylvania Waynesboro The Record Herald 1 1 January 2012
Pennsylvania West Chester Local News 1 1 January 2012
Pennsylvania White Haven The Journal-Herald 1 1 January 2012
Pennsylvania Wilkes-Barre Sunday Voice 1 1 January 2012
Pennsylvania Wilkes-Barre The Citizens' Voice 1 1 January 2012
Pennsylvania Wilkes-Barre Times Leader 1 1 January 2012
Pennsylvania Williamsport Sun-Gazette 1 1 January 2012
Pennsylvania Wyalusing Rocket-Courier 1 1 January 2012
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Pennsylvania York Sunday News 1 1 January 2012
Rhode Island Kent County Times 1 1 January 2012
Rhode Island Newport The Daily News 1 1 January 2012
Rhode Island Pawtucket/Central Falls Times 1 1 January 2012
Rhode Island Providence Sunday Journal 1 1 January 2012
Rhode Island Warwick Cranston Herald 1 1 January 2012
Rhode Island Warwick Warwick Beacon 1 1 January 2012
Rhode Island Westerly Sun 1 1 1 1 January 2012
Rhode Island Woonsocket Call 1 1 January 2012
South Carolina Aiken Standard 1 1 January 2012
South Carolina Anderson Independent-Mail 1 1 January 2012
South Carolina Barnwell The People-Sentinel 1 1 January 2012
South Carolina Bennettsville Marlboro Herald - Advocate 1 1 January 2012
South Carolina Bluffton Today 1 1 1 1 January 2012
South Carolina Charleston Post and Courier 1 1 January 2012
South Carolina Columbia The State 1 1 January 2012
South Carolina Edgefield The Citizen News 1 1 January 2012
South Carolina Florence Morning News 1 1 January 2012
South Carolina Georgetown Times 1 1 January 2012
South Carolina Goose Creek Gazette 1 1 January 2012
South Carolina Greenville News & Sunday Select 1 1 1 1 January 2012
South Carolina Greenwood Index-Journal 1 1 January 2012
South Carolina Hampton Hampton County Guardian 1 1 January 2012
South Carolina Hartsville The Messenger 1 1 January 2012
South Carolina Hilton Head Island Island Packet 1 1 January 2012
South Carolina Lancaster The Lancaster News 1 1 1 1 January 2012
South Carolina Myrtle Beach Sun News 1 1 January 2012
South Carolina Newberry The Newberry Observer 1 1 1 1 January 2012
South Carolina Orangeburg Times and Democrat 1 1 1 1 January 2012
South Carolina Pickens The Pickens Sentinel 1 1 January 2012
South Carolina Ridgeland Jasper County Sun Times 1 1 January 2012
South Carolina Rock Hill The Herald 1 1 January 2012
South Carolina Seneca The Daily Journal 1 1 January 2012
South Carolina Seneca The Daily Messenger 1 1 January 2012
South Carolina Spartanburg Herald-Journal 1 1 January 2012
South Carolina Summerville The Journal Scene 1 1 January 2012
South Carolina Sumter Clarendon Sun 1 1 January 2012
South Carolina Sumter Item 1 1 January 2012
South Carolina Union The Union Daily Times 1 1 1 1 January 2012
South Carolina Winnsboro The Herald Independent 1 1 1 1 January 2012
South Dakota Aberdeen American News 1 1 1 1 January 2012
South Dakota Armour Armour Chronicle 1 1 January 2012
South Dakota Belle Fourche Butte County Post 1 1 1 1 January 2012
South Dakota Brookins Brookings Register 1 1 January 2012
South Dakota Chamberlain Central Dakota Times 1 1 January 2012
South Dakota Corsica Corisca Globe 1 1 January 2012
South Dakota Corsica The Delmont Record 1 1 January 2012
South Dakota De Smet The De Smet News 1 1 January 2012
South Dakota Deadwood The Lawrence County Journal 1 1 January 2012
South Dakota Elk Point Leader-Courier 1 1 January 2012
South Dakota Hot Sprints Hot Springs Star 1 1 January 2012
South Dakota Huron Plainsman 1 1 January 2012
South Dakota Lake Preston Lake Preston Times 1 1 January 2012
South Dakota Mitchell Daily Republic 1 1 January 2012
South Dakota Newell Butte County Valley Irrigator 1 1 January 2012
South Dakota Parker The New Era 1 1 January 2012
South Dakota Rapid City Journal 1 1 January 2012
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South Dakota Sioux Falls Argus Leader 1 1 January 2012
South Dakota Spearfish Black Hills Pioneer 1 1 January 2012
South Dakota Sturgis Meade County Times Tribune 1 1 January 2012
South Dakota Watertown Public Opinion 1 1 January 2012
South Dakota White Lake Aurora County Standard 1 1 January 2012
South Dakota White Lake The Stickney Argus 1 1 January 2012
South Dakota Yankton Press & Dakotan 1 1 1 1 January 2012
Tennessee Athens Post-Athenian 1 1 January 2012
Tennessee Bolivar Bolivar Bulletin-Times 1 1 January 2012
Tennessee Brownsville Brownsville States-Graphic 1 1 January 2012
Tennessee Camden Carroll County News-Leader 1 1 January 2012
Tennessee Camden The Camden Chronicle 1 1 January 2012
Tennessee Chattanooga Times-Free Press 1 1 January 2012
Tennessee Clarksville Leaf-Chronicle 1 1 January 2012
Tennessee Cleveland Banner 1 1 1 1 January 2012
Tennessee Collierville The Collierville Herald 1 1 January 2012
Tennessee Columbia Herald 1 1 January 2012
Tennessee Cookeville Herald-Citizen 1 1 January 2012
Tennessee Covington The Leader 1 1 January 2012
Tennessee Crossville Chronicle 1 1 1 1 2 January 2012
Tennessee Dayton The Herald - News 1 1 January 2012
Tennessee Dyer The Tri-City Reporter 1 1 January 2012
Tennessee Dyersburg State Gazette 1 1 1 1 January 2012
Tennessee Elizabethton Elizabethton Star 1 1 1 1 January 2012
Tennessee Erwin The Erwin Record 1 1 January 2012
Tennessee Fayetteville Elk Valley Times 1 1 January 2012
Tennessee Fayetteville Observer & News 1 1 January 2012
Tennessee Franklin The Williamson Herald 1 1 January 2012
Tennessee Gallatin News-Examiner 1 1 January 2012
Tennessee Greeneville The Greeneville Sun 1 1 1 1 January 2012
Tennessee Henderson Chester County Independent 1 1 January 2012
Tennessee Hendersonville Star News 1 1 January 2012
Tennessee Humboldt Humboldt Chronicle 1 1 January 2012
Tennessee Jackson Sun 1 1 January 2012
Tennessee Jamestown Fentress Courier 1 1 January 2012
Tennessee Jefferson City The Standard Banner 1 1 January 2012
Tennessee Johnson City Press 1 1 January 2012
Tennessee Jonesborough Herald & Tribune 1 1 January 2012
Tennessee Kingsport Times-News 1 1 January 2012
Tennessee Knoxville News-Sentinel 1 1 January 2012
Tennessee Lafayette Macon County Times 1 1 January 2012
Tennessee Lebanon Democrat 1 1 January 2012
Tennessee Lebanon The Wilson Post 1 1 January 2012
Tennessee Lenoir City The News-Herald 1 1 January 2012
Tennessee Maryville The Daily Times 1 1 1 1 January 2012
Tennessee McMinnville Southern Standard 1 1 January 2012
Tennessee Memphis Commercial Appeal 1 1 January 2012
Tennessee Morristown Citizen Tribune 1 1 January 2012
Tennessee Mt. Juliet The Mt. Juliet News 1 1 January 2012
Tennessee Mufreesboro Post 1 1 January 2012
Tennessee Murfreesboro News Journal 1 1 January 2012
Tennessee Nashville Tennessean 1 1 January 2012
Tennessee Newport Plain Talk 1 1 January 2012
Tennessee Oak Ridge Oak Ridger 1 1 1 1 January 2012
Tennessee Oneida Independent Herald 1 1 January 2012
Tennessee Parsons The News Leader 1 1 January 2012
Tennessee Pulaski The Pulaski Citizen 1 1 January 2012
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Tennessee Selmer Independent Appeal 1 1 January 2012
Tennessee Sevierville Mountain Press 1 1 January 2012
Tennessee Shelbyville Shelbyville Times Gazette 1 1 1 1 January 2012
Tennessee Smithville Smithville Review 1 1 January 2012
Tennessee Sweetwater The Advocate & Democrat 1 1 January 2012
Tennessee Tazewell Claiborne Progress 1 1 January 2012
Tennessee Tullahoma The Sunday News 1 1 1 1 January 2012
Tennessee Waynesboro The Wayne County News 1 1 January 2012
Texas Abilene Reporter-News 1 1 January 2012
Texas Alice Alice Echo News-Journal 1 1 January 2012
Texas Allen American 1 1 January 2012
Texas Alvin Alvin Sun 1 1 January 2012
Texas Amarillo Globe-News 1 1 January 2012
Texas Andrews Andrews County News 1 1 January 2012
Texas Athens Daily Review 1 1 1 1 January 2012
Texas Atlanta The Atlanta Citizens Journal 1 1 January 2012
Texas Austin American-Statesman 1 1 January 2012
Texas Austin Lake Travis View 1 1 January 2012
Texas Austin Westlake Picayune 1 1 January 2012
Texas Bastrop Bastrop Advertiser 1 1 January 2012
Texas Bay City The Bay City Tribune 1 1 January 2012
Texas Baytown The Sun 1 1 1 1 January 2012
Texas Beaumont Enterprise 1 1 January 2012
Texas Big Sandy Big Sandy & Hawkins Journal and Tri- 1 1 January 2012
Texas Big Spring Big Spring Herald 1 1 January 2012
Texas Borger Borger News-Herald 1 1 January 2012
Texas Bowie The Bowie News 1 1 January 2012
Texas Breckenridge Breckenridge American 1 1 January 2012
Texas Brenham The Banner - Press 1 1 January 2012
Texas Brownfield Brownfield News 1 1 January 2012
Texas Brownsville Herald 1 1 January 2012
Texas Brownwood Bulletin 1 1 1 1 January 2012
Texas Bryan Bryan-College Station Eagle 1 1 1 1 January 2012
Texas Buffalo The Buffalo Press 1 1 January 2012
Texas Burelson Alvarado Star 1 1 January 2012
Texas Burelson Burleson Star 1 1 January 2012
Texas Burelson Crowley Star 1 1 January 2012
Texas Burelson Everman Star 1 1 January 2012
Texas Burelson Joshua Star 1 1 January 2012
Texas Burelson Kenne Star 1 1 January 2012
Texas Canyon The Canyon News 1 1 January 2012
Texas Carthage Panola Watchman 1 1 January 2012
Texas Center Light and Champion 1 1 January 2012
Texas Childress The Childress Index 1 1 January 2012
Texas Clarksville Clarksville Times 1 1 January 2012
Texas Cleburne Times-Review 1 1 1 1 January 2012
Texas Clute Brazosport Facts 1 1 January 2012
Texas Comfort The Comfort News 1 1 January 2012
Texas Corpus Christi Caller-Times 1 1 January 2012
Texas Corrigan Corrigan Times 1 1 January 2012
Texas Corsicana Sun 1 1 January 2012
Texas Crockett Houston County Courier 1 1 January 2012
Texas Daingerfield The Bee 1 1 January 2012
Texas Dallas Al Dia 1 1 January 2012
Texas Dallas Briefing 1 1 January 2012
Texas Dallas Morning News 1 1 January 2012
Texas Dallas Quick 1 1 January 2012
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Texas Decatur Wise County Messenger 1 1 January 2012
Texas Del Rio News Herald 1 1 January 2012
Texas Denton Record Chronicle 1 1 1 1 January 2012
Texas Edinburg Edinburg Review 1 1 January 2012
Texas El Campo El Campo Leader - News 1 1 January 2012
Texas El Paso El Diario 1 1 January 2012
Texas El Paso Times 1 1 January 2012
Texas Eldorado The Eldorado Success 1 1 January 2012
Texas Emory Rains County Leader 1 1 January 2012
Texas Floresville Wilson County News 1 1 January 2012
Texas Flower Mound Leader 1 1 January 2012
Texas Fredericksburg Fredericksburg Standard-Radio Post 1 1 January 2012
Texas Freer The Freer Press 1 1 January 2012
Texas Frisco Enterprise 1 1 January 2012
Texas Ft. Worth Star-Telegram 1 1 January 2012
Texas Gainesville Daily Register 1 1 1 1 January 2012
Texas Galveston Galveston County Daily News 1 1 1 1 January 2012
Texas Gatesville Star-Forum 1 1 January 2012
Texas Gatesville The Gatesville Messenger 1 1 January 2012
Texas Gilmer The Gilmer Mirror 1 1 January 2012
Texas Gladewater Gladewater Mirror 1 1 January 2012
Texas Glen Rose Glen Rose Reporter 1 1 January 2012
Texas Graford Lake Country Sun 1 1 January 2012
Texas Graham The Graham Leader 1 1 January 2012
Texas Granbury Hood County News 1 1 January 2012
Texas Greenville Herald-Banner 1 1 1 1 January 2012
Texas Groveton Groveton News 1 1 January 2012
Texas Harlingen Valley Morning Star 1 1 January 2012
Texas Hearne Calvert Tribune 1 1 January 2012
Texas Hearne Franlkin Advocate 1 1 January 2012
Texas Hearne Hearne Democrat 1 1 January 2012
Texas Hemphill Sabine County Reporter 1 1 January 2012
Texas Henderson Henderson Daily News 1 1 January 2012
Texas Hereford Hereford Brand 1 1 January 2012
Texas Houston Chronicle 1 1 January 2012
Texas Houston Chronicle Plus 1 1 January 2012
Texas Houston Community Papers 1 1 January 2012
Texas Houston East Texas Community Newspapers 1 1 January 2012
Texas Huntsville Item 1 1 1 1 January 2012
Texas Ingram West Kerr Current 1 1 January 2012
Texas Iowa Park Iowa Park Leader 1 1 January 2012
Texas Irving Rambler 1 1 January 2012
Texas Jacksboro Jack County Herald 1 1 January 2012
Texas Jacksonville Daily Progress 1 1 1 1 January 2012
Texas Jonestown Cedar Park Citizen 1 1 January 2012
Texas Jonestown Leander Ledger 1 1 January 2012
Texas Junction The Junction Eagle 1 1 January 2012
Texas Karnes The Countywide 1 1 January 2012
Texas Katy The Katy Times 1 1 January 2012
Texas Kaufman Kaufman Herald 1 1 January 2012
Texas Kerrville Daily Times 1 1 1 1 January 2012
Texas Kilgore Kilgore News Herald 1 1 January 2012
Texas Killeen Herald 1 1 1 1 January 2012
Texas Kingsville Kingsville Record 1 1 January 2012
Texas Lamesa Lamesa Press-Reporter 1 1 January 2012
Texas LaPorte Bayshore Sun 1 1 January 2012
Texas Laredo Morning Times 1 1 1 1 January 2012
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Texas Levelland Levelland And Hockley County News- 1 1 January 2012
Texas Lewisville Leader 1 1 January 2012
Texas Lindale The Lindale News & Times 1 1 January 2012
Texas Linden Cass County Sun 1 1 January 2012
Texas Little Elm Journal 1 1 January 2012
Texas Littlefield The Lamb County Leader News 1 1 January 2012
Texas Livingston Polk County Enterprise 1 1 January 2012
Texas Longview News-Journal 1 1 1 1 January 2012
Texas Lubbock Avalanche-Journal 1 1 January 2012
Texas Lufkin Daily News 1 1 1 1 January 2012
Texas Lytle Leader News 1 1 January 2012
Texas Mabank The Monitor/Leader 1 1 January 2012
Texas Marble Falls The Highlander 1 1 January 2012
Texas Marshall News Messenger 1 1 1 1 January 2012
Texas McAllen Monitor 1 1 1 1 January 2012
Texas McAllen Original Winter Texan 1 1 January 2012
Texas McKinney Courier-Gazette 1 1 January 2012
Texas Menard Menard News & Messenger 1 1 January 2012
Texas Merdian Bosque County News 1 1 January 2012
Texas Mesquite News 1 1 January 2012
Texas Mexia The Mexia Daily News 1 1 January 2012
Texas Midland Reporter-Telegram 1 1 1 1 January 2012
Texas Mineola Mineola Monitor 1 1 January 2012
Texas Mineral Wells Mineral Wells Index 1 1 1 1 January 2012
Texas Mount Vernon Mount Vernon Optic-Herald 1 1 January 2012
Texas Mt. Pleasant Mount Pleasant Daily Tribune 1 1 January 2012
Texas Muleshoe Muleshoe Journal 1 1 January 2012
Texas New Boston Bowie County Citizens Tribune 1 1 January 2012
Texas New Boston DeKalb News 1 1 January 2012
Texas New Braunfels Herald-Zeitung 1 1 1 1 January 2012
Texas Nochgodoches The Daily Sentinel 1 1 1 1 January 2012
Texas Odessa American 1 1 January 2012
Texas Olney The Olney Enterprise 1 1 January 2012
Texas Orange Leader 1 1 1 1 January 2012
Texas Overton The Overton Press 1 1 January 2012
Texas Palestine Herald - Press 1 1 1 1 January 2012
Texas Paris News 1 1 January 2012
Texas Plainview Plainview Daily Herald 1 1 1 1 January 2012
Texas Plano Star Community Newspapers 1 1 January 2012
Texas Plano Star Courier 1 1 January 2012
Texas Plugerville Pflugerville Pflag 1 1 January 2012
Texas Port Arthur News 1 1 1 1 January 2012
Texas Port Lavaca The Port Lavaca Wave 1 1 January 2012
Texas Post The Post Dispatch 1 1 January 2012
Texas Quitman Wood County Democrat 1 1 January 2012
Texas Raymondville Raymondville Chronicle 1 1 January 2012
Texas Raymondville Willacy County News 1 1 January 2012
Texas Robstown Nueces Co. Record Star 1 1 January 2012
Texas Rockport Rockport Pilot 1 1 January 2012
Texas Rockwall Rockwall County News 1 1 January 2012
Texas Rosenburg The Fort Bend Herald 1 1 January 2012
Texas Round Rock Round Rock Leader 1 1 January 2012
Texas Rowlett Lakeshore Times 1 1 January 2012
Texas San Angelo Standard-Times 1 1 January 2012
Texas San Antonio Express-News 1 1 January 2012
Texas San Diego Duval County Picture 1 1 January 2012
Texas San Marcos Daily Record 1 1 January 2012
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Texas San Marcos San Marcos Daily Record 1 1 January 2012
Texas Seagoville The Suburbia News 1 1 January 2012
Texas Seguin Seguin Gazette-Enterprise 1 1 1 1 January 2012
Texas Seminole Seminole Sentinel 1 1 January 2012
Texas Shepherd San Jacinto News-Times 1 1 January 2012
Texas Sherman/Denison Herald Democrat 1 1 January 2012
Texas Smithvilel Smithville Times 1 1 January 2012
Texas Snyder The Snyder Daily News 1 1 January 2012
Texas Stephenville Stephenville Empire-Tribune 1 1 January 2012
Texas Sweetwater Sweetwater Reporter 1 1 January 2012
Texas Teague The Teague Chronicle 1 1 January 2012
Texas Temple Daily Telegram 1 1 January 2012
Texas Terrell Terrell Tribune 1 1 January 2012
Texas Texarkana Gazette 1 1 1 1 January 2012
Texas Trinity Trinity Standard 1 1 January 2012
Texas Tyler Courier Times-Telegraph 1 1 January 2012
Texas Uvalde The Uvalde Leader-News 1 1 January 2012
Texas Van Alstyne Leader 1 1 January 2012
Texas Vernon The Vernon Daily Record 1 1 January 2012
Texas Victoria Advocate 1 1 January 2012
Texas Vidor The Vidorian 1 1 January 2012
Texas Waco Tribune-Herald 1 1 January 2012
Texas Waco Waco Tribune - Herald 1 1 January 2012
Texas Waxahachie Waxahachie Daily Light 1 1 January 2012
Texas Weatherford The Democrat 1 1 1 1 January 2012
Texas Wellington Wellington Leader 1 1 January 2012
Texas Weslaco Mid Valley Town Crier 1 1 1 1 January 2012
Texas Wharton Wharton Journal - Spectator 1 1 January 2012
Texas Wichita Falls Times Record News 1 1 January 2012
Texas Wills Point Van Zandt News 1 1 January 2012
Texas Woodville Tyler County Booster 1 1 January 2012
Texas Zapata Zapata County News 1 1 January 2012
Utah Bountiful Davis County Clipper 1 1 January 2012
Utah Heber City Wasatch Wave 1 1 January 2012
Utah Logan Herald Journal 1 1 January 2012
Utah Moab The Times Indpendent 1 1 January 2012
Utah Ogden Standard-Examiner 1 1 1 1 January 2012
Utah Price Sun-Advocate 1 1 January 2012
Utah Provo Herald 1 1 January 2012
Utah Richfield Richfield Reaper 1 1 January 2012
Utah Salt Lake City Tribune-Desert Morning News 1 1 January 2012
Utah St. George Spectrum 1 1 January 2012
Utah Tooele Tooele Transcript Bulletin 1 1 January 2012
Vermont Bennington Bennington Banner 1 1 1 1 January 2012
Vermont Bradford Journal Opinion 1 1 January 2012
Vermont Brattleboro Brattleboro Reformer 1 1 1 1 January 2012
Vermont Burlington Free Press 1 1 January 2012
Vermont Newport The Newport Daily Express 1 1 January 2012
Vermont Rutland Herald and Times Argus 1 1 January 2012
Vermont St. Albans St. Albans Messenger 1 1 January 2012
Vermont St. Johnsbury The Caledonian-Record 1 1 January 2012
Vermont West Dover Deerfield Valley News 1 1 January 2012
Virginia Ashland Herald Progress 1 1 January 2012
Virginia Bedford Bedford Bulletin 1 1 January 2012
Virginia Big Stone Gap The Post 1 1 January 2012
Virginia Bristol Herald-Courier 1 1 January 2012
Virginia Charlottesville Progress 1 1 January 2012
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 193 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Virginia Culpeper Star-Exponent 1 1 January 2012
Virginia Danville Register & Bee 1 1 January 2012
Virginia Farmville The Farmville Herald 1 1 January 2012
Virginia Floyd The Floyd Press 1 1 January 2012
Virginia Fredericksburg Free Lance-Star 1 1 January 2012
Virginia Front Royal The Warren Sentinel 1 1 January 2012
Virginia Galax The Gazette 1 1 January 2012
Virginia Goochland The Goochland Gazette 1 1 January 2012
Virginia Harrisonburg News Record 1 1 January 2012
Virginia Harrisonburg Page News and Courier 1 1 January 2012
Virginia Harrisonburg Shenandoah Valley-Herald 1 1 January 2012
Virginia Harrisonburg Valley Banner 1 1 January 2012
Virginia Hillsville The Carroll News 1 1 January 2012
Virginia Hopewell The Hopewell News 1 1 January 2012
Virginia Lexington The News - Gazette 1 1 January 2012
Virginia Louisa The Central Virginian 1 1 January 2012
Virginia Lynchburg News & Advance 1 1 January 2012
Virginia Marion Smyth County News & Messenger 1 1 January 2012
Virginia Martinsville Bulletin 1 1 January 2012
Virginia Newport News-Hampton-Williamsburg Daily Press 1 1 January 2012
Virginia Norfolk-Portsmouth-Virginia Beach- Virginian Pilot 1 1 January 2012
Virginia Norton Dickenson Star/Cumberland Times 1 1 January 2012
Virginia Norton The Coalfield Progress 1 1 January 2012
Virginia Petersburg Progress-Index 1 1 1 1 January 2012
Virginia Richlands Richlands News-Press 1 1 January 2012
Virginia Richmond Times-Dispatch 1 1 January 2012
Virginia Roanoke Times 1 1 January 2012
Virginia South Boston The Gazette-Virginian 1 1 January 2012
Virginia Staunton News Leader 1 1 January 2012
Virginia Strasburg Northern Virginia Daily 1 1 1 1 January 2012
Virginia Suffolk Suffolk News-Herald 1 1 January 2012
Virginia Tazewell Clinch Valley News 1 1 January 2012
Virginia Waynesboro News Virginian 1 1 January 2012
Virginia Winchester Star 1 1 January 2012
Virginia Woodbridge-Manassas Potomac News & Journal Messenger 1 1 January 2012
Virginia Wytheville The Bland Messenger 1 1 January 2012
Virginia Wytheville Wytheville Enterprise 1 1 January 2012
Washington Aberdeen Daily World 1 1 January 2012
Washington Auburn Reporter 1 1 January 2012
Washington Bainbridge Island Review 1 1 January 2012
Washington Bellevue Reporter 1 1 January 2012
Washington Bellingham The Bellingham 1 1 January 2012
Washington Bremerton Kitsap Sun 1 1 1 1 January 2012
Washington Camas Camas-Washougal Post-Record 1 1 January 2012
Washington Central Kitsap Reporter 1 1 January 2012
Washington Centralia/Chehalis Chronicle 1 1 January 2012
Washington Cle Elum Northern Kittitas County Tribune 1 1 January 2012
Washington Colville Statesman-Examiner 1 1 January 2012
Washington Deer Park Tribune 1 1 January 2012
Washington Ellensburg Record 1 1 January 2012
Washington Ellensburg Record 1 1 January 2012
Washington Everett Sound Publishing Group 1 1 January 2012
Washington Grandview Grandview Herald 1 1 January 2012
Washington Issaquah/Sammamish Reporter 1 1 January 2012
Washington Kent Reporter 1 1 January 2012
Washington Longview Daily News 1 1 January 2012
Washington Montesano Vidette 1 1 January 2012
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 194 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Washington Moses Lake Columbia Basin Herald 1 1 January 2012
Washington Mount Vernon Skagit Valley Herald 1 1 January 2012
Washington Olympia Olympian 1 1 January 2012
Washington Omak The (Omak-Okanogan County) 1 1 January 2012
Washington Othello Othello Independent 1 1 January 2012
Washington Pasco-Kennewick-Richland Tri-City Herald 1 1 January 2012
Washington Port Angeles Peninsula Daily News 1 1 January 2012
Washington Port Orchard Independent Tribune 1 1 January 2012
Washington Prosser Record Bulletin 1 1 January 2012
Washington Quincy The Quincy Valley Post-Register 1 1 January 2012
Washington Redmond Reporter 1 1 January 2012
Washington Renton Reporter 1 1 January 2012
Washington Seattle Times/Post-Intelligencer 1 1 January 2012
Washington Sequim Sequim Gazette 1 1 January 2012
Washington South Whidbey Record 1 1 January 2012
Washington Spokane The Spokesman-Review 1 1 1 1 January 2012
Washington Sunnyside Daily Sun News 1 1 January 2012
Washington Tacoma News Tribune 1 1 January 2012
Washington Vancouver Columbian 1 1 January 2012
Washington Walla Walla Union-Bulletin 1 1 January 2012
Washington Wenatchee World 1 1 January 2012
Washington Whidbey News Times 1 1 January 2012
Washington Yakima Herald-Republic 1 1 January 2012
Washington Yakima Herald-Republic 1 1 1 1 January 2012
West Virginia Beckley Register-Herald 1 1 January 2012
West Virginia Bluefield Telegraph 1 1 January 2012
West Virginia Charleston Gazette-Mail 1 1 1 1 January 2012
West Virginia Clarksburg Exponent Telegram 1 1 January 2012
West Virginia Elkins Inter-Mountain 1 1 January 2012
West Virginia Fairmont Times-West Virginian 1 1 January 2012
West Virginia Gilbert Gilbert Times 1 1 January 2012
West Virginia Hamlin Lincoln Journal 1 1 January 2012
West Virginia Hamlin The Weekly News Sentinel 1 1 January 2012
West Virginia Harrisville Ritchie Gazette 1 1 January 2012
West Virginia Huntington Herald-Dispatch 1 1 January 2012
West Virginia Keyser Mineral Daily News Tribune 1 1 January 2012
West Virginia Lewisburg Mountain Messenger 1 1 January 2012
West Virginia Logan Logan Banner 1 1 January 2012
West Virginia Martinsburg Sunday Journal 1 1 January 2012
West Virginia Montgomery Montgomery Herald 1 1 January 2012
West Virginia Morgantown Dominion Post 1 1 January 2012
West Virginia Oak Hill The Fayette Tribune 1 1 January 2012
West Virginia Parkersburg News 1 1 January 2012
West Virginia Petersburg Grant County Press 1 1 January 2012
West Virginia Pineville Independent Herald 1 1 January 2012
West Virginia Princeton Princeton Times 1 1 1 1 January 2012
West Virginia Ravenswood The Star Herald 1 1 January 2012
West Virginia Romney Hampshire Review 1 1 January 2012
West Virginia Sutton Braxton Democrat-Central 1 1 January 2012
West Virginia Wayne Wayne County News 1 1 January 2012
West Virginia Wheeling Sunday News-Register 1 1 January 2012
West Virginia Williamson Daily News 1 1 January 2012
Wisconisn Amery Amery Free Press 1 1 January 2012
Wisconisn Ashland The Daily Press 1 1 January 2012
Wisconisn Baldwin The Baldwin Bulletin 1 1 January 2012
Wisconisn Baraboo Baraboo News Republic 1 1 1 1 January 2012
Wisconisn Barron Barron News - Shield 1 1 January 2012
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American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Wisconisn Beaver Dam Daily Citizen 1 1 1 1 January 2012
Wisconisn Black River Falls Jackson County Chronicle 1 1 January 2012
Wisconisn Burlington Burlington Standard Press 1 1 January 2012
Wisconisn Cedarburg Ozaukee County News Graphic 1 1 January 2012
Wisconisn Chetek The Chetek Alert 1 1 January 2012
Wisconisn Clintonville Clintonville Tribune Gazette 1 1 January 2012
Wisconisn Cumberland Cumberland Advocate 1 1 January 2012
Wisconisn Delavan The Delavan Enterprise 1 1 January 2012
Wisconisn Eagle River Vilas County News - Review 1 1 January 2012
Wisconisn East Troy The East Troy News 1 1 January 2012
Wisconisn Elkhorn The Elkhorn Independent 1 1 January 2012
Wisconisn Fort Atkinson Daily Jefferson County Union 1 1 January 2012
Wisconisn Hammond Central St. Croix News 1 1 January 2012
Wisconisn Hayward Sawyer County Record 1 1 January 2012
Wisconisn Iola Manawa Advocate 1 1 January 2012
Wisconisn Iola The Iola Herald 1 1 January 2012
Wisconisn Lake Geneva Lake Geneva Times 1 1 January 2012
Wisconisn Lancaster Grant County Herald Independent 1 1 January 2012
Wisconisn Marinette Eagle Herald 1 1 January 2012
Wisconisn Mauston Juneau County Star-Times 1 1 January 2012
Wisconisn Merrill Foto News 1 1 January 2012
Wisconisn Monroe The Monroe Times 1 1 January 2012
Wisconisn Osceola Osceola Sun 1 1 January 2012
Wisconisn Platteville The Platteville Journal 1 1 January 2012
Wisconisn Portage Daily Register 1 1 1 1 January 2012
Wisconisn Racine The Journal Times 1 1 January 2012
Wisconisn Reedsburg Reedsburg Times Press 1 1 January 2012
Wisconisn Rhinelander Star Journal 1 1 January 2012
Wisconisn Sauk City The Sauk Prairie Eagle 1 1 January 2012
Wisconisn Shawano Shawano Leader 1 1 January 2012
Wisconisn Spooner Spooner Advocate 1 1 January 2012
Wisconisn Twin Lakes Westosha Report 1 1 January 2012
Wisconisn Union Grove Westine Report 1 1 January 2012
Wisconisn Walworth The Times, Walworth 1 1 January 2012
Wisconisn Washburn The County Journal 1 1 January 2012
Wisconisn Waterford Waterford Post 1 1 January 2012
Wisconisn Watertown Times Publishing Company 1 1 January 2012
Wisconisn Waukesha Waukesha Freeman 1 1 January 2012
Wisconisn Waupaca Waupaca County Post 1 1 January 2012
Wisconisn Wautoma The Waushara Argus 1 1 January 2012
Wisconisn West Bend West Bend Daily News 1 1 January 2012
Wisconisn Weyauwega The Chronicle 1 1 January 2012
Wisconisn Whitewater Whitewater Register 1 1 January 2012
Wisconisn Wisconsin Dells Wisconsin Dells Events 1 1 January 2012
Wisconsin Appleton Post-Crescent 1 1 January 2012
Wisconsin Beloit My Stateline Shopper 1 1 January 2012
Wisconsin Beloit News 1 1 January 2012
Wisconsin Chippewa Falls Chippewa Valley Newspapers 1 1 January 2012
Wisconsin Eau Claire Leader-Telegram 1 1 January 2012
Wisconsin Fond Du Lac Reporter 1 1 January 2012
Wisconsin Green Bay Press-Gazette 1 1 January 2012
Wisconsin Janesville Gazette 1 1 January 2012
Wisconsin Kenosha News 1 1 January 2012
Wisconsin La Crosse Tribune 1 1 January 2012
Wisconsin Madison State Journal 1 1 January 2012
Wisconsin Manitowoc/Two Rivers Herald Times Reporter 1 1 January 2012
Wisconsin Marinette Eagle Herald 1 1 January 2012
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 196 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
American Profile, Parade and USA Weekend Newspaper ListDeepwater Horizon Oil Spill Litigation
Economic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication Source
Wisconsin Marshfield New Herald 1 1 January 2012
Wisconsin Milwaukee Journal Sentinel 1 1 January 2012
Wisconsin Oshkosh Northwestern 1 1 January 2012
Wisconsin Racine Journal Times 1 1 January 2012
Wisconsin Rhinelander Daily News 1 1 January 2012
Wisconsin Sheboygan Press 1 1 January 2012
Wisconsin Superior Telegram 1 1 January 2012
Wisconsin Watertown Times 1 1 January 2012
Wisconsin Wausau-Stevens Point Herald-Central WI Sunday 1 1 January 2012
Wyoming Afton Star Valley Independent 1 1 January 2012
Wyoming Casper Star-Tribune 1 1 1 1 January 2012
Wyoming Cheyenne Wyoming Tribune-Eagle 1 1 January 2012
Wyoming Cody The Cody Enterprise 1 1 January 2012
Wyoming Douglas Douglas Budget 1 1 January 2012
Wyoming Gillette The News-Record 1 1 January 2012
Wyoming Landers The Journal 1 1 January 2012
Wyoming Laramie Boomerang 1 1 January 2012
Wyoming Powell The Powell Tribune 1 1 January 2012
Wyoming Rawlins Rawlins Daily Times 1 1 January 2012
Wyoming Riverton The Ranger 1 1 January 2012
Wyoming Rock Sprints Daily Rocket-Miner 1 1 January 2012
Wyoming Sheridan Sheridan Press 1 1 January 2012
Wyoming Sundance The Sundance Times 1 1 January 2012
Wyoming Torrington The Torrington Telegram 1 1 January 2012
Wyoming Worland Northern Wyoming Daily News 1 1 January 2012
TOTAL 1350 522 686 2191 367
American Profile Circ. Parade Circ. USA Weekend Circ.
1/1/12 1/1/12 1/1/12
10,000,000 32,400,000 22,654,682
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 197 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Attachment 3: Local Newspaper List
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 198 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Deepwater Horizon Oil Spill Litigation
Economic and Property Damage Settlement
Local Newspaper List
Texas
Publication Distribution Language Insertions Ad Size
Alvin Advertiser And Sun-Advertiser Combo Alvin, TX English 8 Full Page
Bay City Tribune Bay City, TX English 4 Full Page
Beaumont Enterprise Beaumont, TX English 4 Full Page
Clute Facts Clute, TX English 4 Full Page
Galveston County Daily News Galveston, TX English 4 Full Page
Hometown Press- Houston Winnie, TX English 4 Full Page
Houston Chronicle Houston, TX English 4 Full Page
Jackson County Herald-Tribune Edna, TX English 4 Full Page
Pearland Reporter News Pearland, TX English 4 Full Page
Port Arthur News Port Arthur, TX English 4 Full Page
Texas City Post Texas City, TX English 4 Full Page
Jasper Newsboy Jasper, TX English 4 Full Page
Newton County News Newton, TX English 4 Full Page
Orange Leader Orange, TX English 4 Full Page
Baytown Sun Baytown, TX English 4 Full Page
Bellville Times Bellville, TX English 4 Full Page
Brenham Banner-Press Brenham, TX English 4 Full Page
El Campo Leader-News El Campo, TX English 4 Full Page
Fort Bend Herald Rosenberg, TX English 4 Full Page
Fort Bend/Southwest Star Stafford, TX English 4 Full Page
Houston Community Newspapers Group Combo Houston, TX English 120 Full Page
Houston County Courier Crockett, TX English 4 Full Page
Huntsville Item Huntsville, TX English 4 Full Page
Katy Times Katy, TX English 4 Full Page
Polk County Enterprise Livingston, TX English 4 Full Page
Trinity Standard Livingston, TX English 4 Full Page
Total 224
Louisiana
Publication Distribution Language Insertions Ad Size
Alexandria News Weekly Alexandria, LA English 4 Full Page
Alexandria Town Talk Alexandria, LA English 4 Full Page
Bunkie Record Marksville, LA English 4 Full Page
Oakdale Journal Oakdale, LA English 4 Full Page
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 199 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Donaldsonville Chief Donaldsonville, LA English 4 Full Page
Franklin Banner-Tribune Franklin, LA English 4 Full Page
Gonzales Weekly Citizen Gonzales, LA English 4 Full Page
Livingston Parish News Denham Springs, LA English 4 Full Page
Morgan City Daily Review Morgan City, LA English 4 Full Page
Napoleonville Assumption Pioneer Napoleonville, LA English 4 Full Page
Pierre Part Bayou Journal Pierre Part, LA English 4 Full Page
Baton Rouge Advocate Baton Rouge, LA English 4 Full Page
Port Allen West Side Journal Port Allen, LA English 4 Full Page
Postsouth News Plaquemine, LA English 4 Full Page
Zachary Plainsman-News Zachary, LA English 4 Full Page
Abbeville Meridional Abbeville, LA English 4 Full Page
Gueydan Journal Gueydan, LA English 4 Full Page
Kaplan Herald Kaplan, LA English 4 Full Page
New Iberia Daily Iberian New Iberia, LA English 4 Full Page
St. Martinville Teche News Saint Martinville, LA English 4 Full Page
Basile Weekly Basile, LA English 4 Full Page
Crowley Post-Signal Crowley, LA English 4 Full Page
Eunice News Eunice, LA English 4 Full Page
Jennings Daily News Jennings, LA English 4 Full Page
Kinder Courier News Kinder, LA English 4 Full Page
Lafayette Daily Advertiser Lafayette, LA English 4 Full Page
Opelousas Daily World Opelousas, LA English 4 Full Page
Rayne Acadian-Tribune Rayne, LA English 4 Full Page
Rayne Independent Rayne, LA English 4 Full Page
Ville Platte Gazette Ville Platte, LA English 4 Full Page
Cameron Parish Pilot Dequincy, LA English 4 Full Page
Dequincy News Dequincy, LA English 4 Full Page
Lake Charles American Press Lake Charles, LA English 4 Full Page
Sulphur Southwest Daily News Sulphur, LA English 4 Full Page
Vinton News Sulphur, LA English 4 Full Page
Beauregard Daily News Deridder, LA English 4 Full Page
Moss Bluff News Sulphur, LA English 4 Full Page
Bastrop Daily Enterprise Bastrop, LA English 4 Full Page
Catahoula News Booster Jonesville, LA English 4 Full Page
Concordia Sentinel Ferriday, LA English 4 Full Page
Franklin Sun Winnsboro, LA English 4 Full Page
Monroe News-Star Monroe, LA English 4 Full Page
Ruston Daily Leader Ruston, LA English 4 Full Page
Winn Parish Enterprise Winnfield, LA English 4 Full Page
Hammond Daily Star Hammond, LA English 4 Full Page
Houma Daily Courier/Daily Comet Combo Houma, LA English 8 Full Page
L'Observateur La Place, LA English 4 Full Page
New Orleans Times-Picayune New Orleans, LA English 4 Full Page
Plaquemines Gazette Belle Chasse, LA English 4 Full Page
St. Bernard Voice Arabi, LA English 4 Full Page
St. Charles Herald-Guide Boutte, LA English 4 Full Page
St. Tammany Farmer Covington, LA English 4 Full Page
St. Tammany News Slidell, LA English 4 Full Page
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 200 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Vacherie Enterprise Vacherie, LA English 4 Full Page
Bogalusa Daily News Bogalusa, LA English 4 Full Page
Franklinton Era-Leader Franklinton, LA English 4 Full Page
Picayune Item Picayune, MS English 4 Full Page
Poplarville Democrat Poplarville, MS English 4 Full Page
St. Bernard News Metairie, LA English 4 Full Page
St. Francisville Democrat Saint Francisville, LA English 4 Full Page
Atlanta Citizens Journal Atlanta, TX English 4 Full Page
Barksdale Warrior Shreveport, LA English 4 Double Page Spread
Bowie County Citizens Tribune And DeKalb News Combo
New Boston, TX English 8 Full Page
Center Light & Champion Center, TX English 4 Full Page
Daingerfield Bee Daingerfield, TX English 4 Full Page
Leesville Daily Leader De Ridder, LA English 4 Full Page
Marshall News Messenger Marshall, TX English 4 Full Page
Minden Press-Herald Minden, LA English 4 Full Page
Mt. Pleasant Daily Tribune Mount Pleasant, TX English 4 Full Page
Natchitoches Times Natchitoches, LA English 4 Full Page
Shreveport Times Shreveport, LA English 4 Double Page Spread
Texarkana Gazette Texarkana, TX English 4 Full Page
Total 296
Mississippi
Publication Distribution Language Insertions Ad Size
Biloxi D ‘Iberville Press Biloxi, MS English 4 Full Page
Biloxi-Gulfport Sun Herald Biloxi-gulfport, MS English 4 Full Page
Mississippi Press Pascagoula, MS English 4 Full Page
Ocean Springs Record Ocean Springs, MS English 4 Full Page
Sea Coast Echo Bay Saint Louis, MS English 4 Full Page
Greene County Herald Leakesville, MS English 4 Full Page
Columbian-Progress Columbia, MS English 4 Full Page
Hattiesburg Lamar Times Hattiesburg, MS English 4 Double Page Spread
Petal News Hattiesburg, MS English 4 Double Page Spread
Stone County Enterprise Wiggins, MS English 4 Full Page
Times Of Stone County Wiggins, MS English 4 Full Page
Brookhaven Daily Leader Brookhaven, MS English 4 Full Page
Carthaginian Carthage, MS English 4 Full Page
Deer Creek Pilot Rolling Fork, MS English 4 Full Page
Jackson Clarion Ledger/Hattiesburg American Combo
Jackson, MS English 8 Full Page
Jasper County News Bay Springs, MS English 4 Full Page
Kosciusko Star-Herald Kosciusko, MS English 4 Full Page
Lawrence County Press Monticello, MS English 4 Full Page
McComb Enterprise-Journal Mccomb, MS English 4 Full Page
Natchez Democrat Natchez, MS English 4 Full Page
Rankin County News Brandon, MS English 4 Full Page
Tylertown Times Tylertown, MS English 4 Full Page
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Vicksburg Evening Post Vicksburg, MS English 4 Full Page
Wayne County News Waynesboro, MS English 4 Full Page
Yazoo Herald Yazoo City, MS English 4 Double Page Spread
George County Times Lucedale, MS English 4 Full Page
Booneville Banner-Independent Booneville, MS English 4 Full Page
Chickasaw Journal Houston, MS English 4 Full Page
Columbus Commercial Dispatch Columbus, MS English 4 Full Page
Columbus Packet Columbus, MS English 4 Double Page Spread
Lamar Democrat & The Sulligent News Vernon, AL English 4 Full Page
Louisville Winston County Journal Louisville, MS English 4 Double Page Spread
Macon Beacon Macon, MS English 4 Full Page
N.E. Mississippi Daily Journal Tupelo, MS English 4 Full Page
New Albany Gazette New Albany, MS English 4 Full Page
Pontotoc Progress Pontotoc, MS English 4 Full Page
Prentiss Headlight Prentiss, MS English 4 Full Page
Starkville Daily News Starkville, MS English 4 Full Page
Webster Progress-Times Louisville, MS English 4 Double Page Spread
West Point Daily Times Leader West Point, MS English 4 Full Page
Cleveland Bolivar Commercial Cleveland, MS English 4 Full Page
Enterprise-Tocsin Indianola, MS English 4 Double Page Spread
Greenville Delta Democrat-Times Greenville, MS English 4 Double Page Spread
Greenwood Commonwealth Greenwood, MS English 4 Full Page
Grenada Star Grenada, MS English 4 Full Page
Choctaw Sun-Advocate Gilbertown, AL English 4 Full Page
Meridian Star Meridian, MS English 4 Full Page
Neshoba Democrat Philadelphia, MS English 4 Full Page
Newton County Appeal Union, MS English 4 Full Page
Sumter County Record-Journal Livingston, AL English 4 Full Page
Batesville Panolian Batesville, MS English 4 Full Page
Clarksdale Press Register Clarksdale, MS English 4 Double Page Spread
Corinth Daily Corinthian Corinth, MS English 4 Full Page
DeSoto Appeal Southaven, MS English 4 Full Page
Desoto Times-Tribune Hernando, MS English 4 Double Page Spread
Oxford Eagle Oxford, MS English 4 Full Page
Quitman County Democrat Marks, MS English 4 Full Page
Senatobia Democrat Senatobia, MS English 4 Full Page
South Reporter Holly Springs, MS English 4 Full Page
Southern Advocate Ashland, MS English 4 Full Page
Southern Sentinel Ripley, MS English 4 Full Page
Tunica Times Tunica, MS English 4 Full Page
Total 252
Alabama
Publication Distribution Language Insertions Ad Size
Baldwin Register Daphne, AL English 4 Full Page
Gulf Coast Newspapers Combo Robertsdale, AL English 24 Full Page
Mobile Press-Register Mobile, AL English 4 Full Page
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Washington County News - Alabama Citronelle, AL English 4 Full Page
Flomaton Tri-City Ledger Flomaton, AL English 4 Full Page
Jackson South Alabamian Jackson, AL English 4 Full Page
Monroe Journal Monroeville, AL English 4 Full Page
Dothan Eagle Dothan, AL English 4 Full Page
Enterprise Ledger Enterprise, AL English 4 Full Page
Geneva County Reaper Geneva, AL English 4 Full Page
Anniston Star Anniston, AL English 4 Full Page
Bessemer Western Star Bessemer, AL English 4 Full Page
Birmingham News Birmingham, AL English 4 Full Page
Blount Countian Oneonta, AL English 4 Full Page
Clanton Advertiser Clanton, AL English 4 Full Page
Cullman Times Cullman, AL English 4 Full Page
Fayette Times-Record Fayette, AL English 4 Full Page
Gadsden Times Gadsden, AL English 4 Full Page
Guntersville Advertiser-Gleam Guntersville, AL English 4 Full Page
Haleyville Northwest Alabamian Haleyville, AL English 4 Full Page
Hamilton Journal Record Hamilton, AL English 4 Full Page
Jasper Daily Mountain Eagle Jasper, AL English 4 Full Page
North Jefferson News Gardendale, AL English 4 Full Page
Shelby County Reporter Columbiana, AL English 4 Full Page
St. Clair News-Aegis Pell City, AL English 4 Full Page
Sylacauga Daily Home Sylacauga, AL English 4 Full Page
Tuscaloosa News Tuscaloosa, AL English 4 Full Page
Athens News Courier Athens, AL English 4 Full Page
Decatur Daily Decatur, AL English 4 Full Page
Florence Times Daily Florence, AL English 4 Full Page
Fort Payne Times-Journal Fort Payne, AL English 4 Full Page
Franklin County Times Russellville, AL English 4 Full Page
Huntsville Times Huntsville, AL English 4 Full Page
Sand Mountain Reporter Albertville, AL English 4 Full Page
Scottsboro Daily Sentinel Scottsboro, AL English 4 Full Page
Alexander City Outlook Alexander City, AL English 4 Full Page
Andalusia Star-News Andalusia, AL English 4 Full Page
Demopolis Times Demopolis, AL English 4 Full Page
Florala News Florala, AL English 4 Full Page
Greenville Advocate Greenville, AL English 4 Full Page
Montgomery Advertiser Montgomery, AL English 4 Full Page
Montgomery Independent / Middlebrook Independent Combo
Montgomery, AL English 8 Double Page Spread
Opp News Opp, AL English 4 Full Page
Selma Times-Journal Selma, AL English 4 Full Page
Tallassee Tribune Wetumpka, AL English 4 Full Page
Troy Messenger Troy, AL English 4 Full Page
Wetumpka Eclectic Observer Wetumpka, AL English 4 Full Page
Wetumpka Herald Wetumpka, AL English 4 Full Page
Citizen Of East Alabama Phenix City, AL English 4 Full Page
Eufaula Tribune Eufaula, AL English 4 Full Page
Randolph Leader Roanoke, AL English 4 Full Page
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Valley Times-News -Lanett Lanett, AL English 4 Full Page
Cleburne News Heflin, Al English 4 Full Page
Total 236
Florida
Publication Distribution Language Insertions Ad Size
Jackson County Floridan Marianna, FL English 4 Full Page
Arcadian Arcadia, FL English 4 Double Page Spread
Beach Observer Fort Meyers, FL English 4 Double Page Spread
Boca Beacon Boca Grande, FL English 4 Double Page Spread
Bokeelia Pine Island Eagle Bokeelia, FL English 4 Double Page Spread
Bonita Banner Naples, FL English 4 Full Page
Cape Coral Daily Breeze Cape Coral, FL English 4 Full Page
Charlotte Sun Port Charlotte, FL English 4 Full Page
Collier Citizen Naples, FL English 4 Full Page
Fort Myers News-Press Fort Myers, FL English 4 Full Page
Lehigh Acres Citizen Lehigh Acres, FL English 4 Double Page Spread
Lehigh News Star Lehigh Acres, FL English 4 Full Page
Marco Eagle Marco Island, FL English 4 Full Page
Marco Island Sun Times Marco Island, FL English 4 Full Page
Naples Daily News Naples, FL English 4 Full Page
North Fort Myers Neighbor Cape Coral, FL English 4 Double Page Spread
Sanibel/Captiva Islander Sanibel, FL English 4 Double Page Spread
Alachua County Today Alachua, FL English 4 Full Page
Chiefland Citizen/Tri-County Bulletin/Cedar Key Beacon/Williston Pioneer Sun News
Chiefland, FL English 16 Double Page Spread
Dixie County Advocate Cross City, FL English 4 Full Page
Gainesville Guardian Gainesville, FL English 4 Full Page
Gainesville Record Gainesville, FL English 4 Double Page Spread
Gainesville Sun Gainesville, FL English 4 Full Page
Gilchrist County Journal Trenton, FL English 4 Full Page
North Florida Herald High Springs, FL English 4 Full Page
Boca Raton Forum Pompano Beach, FL English 4 Double Page Spread
Boynton Forum Pompano Beach, FL English 4 Double Page Spread
Coral Springs/Parkland Forum Pompano Beach, FL English 4 Double Page Spread
Delray Forum Pompano Beach, FL English 4 Double Page Spread
Florida Keys Keynoter Tavernier, FL English 4 Full Page
Fort Lauderdale Sun-Sentinel Fort Lauderdale, FL English 4 Full Page
Forum Publishing Group-Boca Raton Combo
Pompano Beach, FL English 16 Double Page Spread
Key Biscayne Islander News Key Biscayne, FL English 4 Double Page Spread
Key West Citizen Key West, FL English 4 Full Page
Lake Worth Forum Pompano Beach, FL English 4 Full Page
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Margate/Coconut Creek Forum Pompano Beach, FL English 4 Double Page Spread
Miami Herald Miami, FL English 4 Full Page
Palm Beach Gardens Jupiter Palm Beach Gardens, FL English 4 Double Page Spread
Plantation Forum Deerfield Beach, FL English 4 Double Page Spread
Pompano Beach Sentry Pompano Beach, FL English 4 Full Page
Pompano Forum Pompano Beach, FL English 4 Double Page Spread
South Dade News Leader Homestead, FL English 4 Full Page
Sunrise Forum Pompano Beach, FL English 4 Double Page Spread
Tamarac/N. Lauderdale Forum Pompano Beach, FL English 4 Double Page Spread
Tavernier Reporter Tavernier, FL English 4 Full Page
Wellington Forum Pompano Beach, FL English 4 Double Page Spread
Crestview News Bulletin Crestview, FL English 4 Full Page
Destin Log Destin, FL English 4 Full Page
Gulf Breeze News Gulf Breeze, FL English 4 Full Page
Navarre Press Navarre, FL English 4 Full Page
Northwest Florida Daily News Fort Walton Beach, FL English 4 Full Page
Pensacola News Journal Pensacola, FL English 4 Full Page
Santa Rosa Press Gazette Milton, FL English 4 Full Page
Apalachicola and Carrebelle Times/Port St. Joe Star Combo
Apalachicola, FL English 8 Full Page
Blountstown County Record Blountstown, FL English 4 Full Page
Bristol Calhoun-Liberty Journal Bristol, FL English 4 Double Page Spread
Graceville News Graceville, FL English 4 Full Page
Herald Breeze De Funiak Springs, FL English 4 Full Page
Holmes County Times-Advertiser Bonifay, FL English 4 Full Page
Panama City News Herald Panama City, FL English 4 Full Page
Walton Sun Santa Rosa Beach, FL English 4 Full Page
Washington County News - Florida Chipley, FL English 4 Full Page
Chattahoochee Twin City News Chattahoochee, FL English 4 Full Page
Gadsden County Times Quincy, FL English 4 Full Page
Havana Herald Havana, FL English 4 Full Page
Jasper News Jasper, FL English 4 Full Page
Lake City News Advertiser Lake City, FL English 4 Double Page Spread
Madison County Carrier Madison, FL English 4 Full Page
Madison Enterprise Recorder Madison, FL English 4 Full Page
Mayo Free Press Live Oak, FL English 4 Full Page
Monticello News Monticello, FL English 4 Full Page
Suwannee Democrat Live Oak, FL English 4 Full Page
Taco Times Perry, FL English 4 Full Page
Tallahassee Democrat Tallahassee, FL English 4 Full Page
Wakulla News Crawfordville, FL English 4 Full Page
Bradenton Herald Bradenton, FL English 4 Full Page
Brandon News & Tribune Brandon, FL English 4 Double Page Spread
Carrollwood News & Tribune Tampa, FL English 4 Double Page Spread
Citrus County Chronicle Crystal River, FL English 4 Full Page
Fort Meade Leader Fort Meade, FL English 4 Full Page
Hernando Today Brooksville, FL English 4 Full Page
Highlands Today Sebring, FL English 4 Full Page
Lake Wales News Lake Wales, FL English 4 Full Page
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 205 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
Lakeland Ledger Lakeland, FL English 4 Full Page
Longboat Observer Longboat Key, FL English 4 Double Page Spread
New Port Richey Sunbelt Newspapers Combo
New Port Richey, FL English 8 Double Page Spread
New Port Richey Suncoast News New Port Richey, FL English 4 Double Page Spread
Northeast News & Tribune Tampa, FL English 4 Double Page Spread
Northwest News & Tribune Hillsborough, FL English 4 Double Page Spread
Pelican Press Sarasota, FL English 4 Double Page Spread
Plant City Courier & Tribune Plant City, FL English 4 Double Page Spread
Polk County Democrat-Leader Bartow, FL English 4 Full Page
Sarasota Herald-Tribune Sarasota, FL English 4 Full Page
Sarasota Observer Sarasota, FL English 4 Double Page Spread
Sebring News-Sun Sebring, FL English 4 Full Page
South & Central Tampa News & Tribune Tampa, FL English 4 Double Page Spread
South Shore News & Tribune Tampa, FL English 4 Double Page Spread
St. Petersburg Times/Tampa Bay Times Saint Petersburg, FL English 4 Full Page
Suncoast News-Pasco New Port Richey, FL English 4 Double Page Spread
Tampa Tribune Tampa, FL English 4 Full Page
Venice Gondolier Sun Venice, FL English 4 Full Page
Wauchula Herald-Advocate Wauchula, FL English 4 Full Page
Winter Haven News Chief Winter Haven, FL English 4 Full Page
Zephyrhills News Zephyrhills, FL English 4 Full Page
Total 448
Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 206 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org