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Bp settlement declaration_cameron_azari_bp_settlement_notice_administrator_4_17_2012_annotated
 

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    Bp settlement declaration_cameron_azari_bp_settlement_notice_administrator_4_17_2012_annotated Bp settlement declaration_cameron_azari_bp_settlement_notice_administrator_4_17_2012_annotated Document Transcript

    • Exhibit 1Case 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.orgThis is the Declaration of Cameron Azari, whoadministered the class action notice for the BP DeepwaterHorizon Oil Spill Settlement. It explains how BP settlementmembers would be given notice. The "Target Audience"for the BP Settlement notice was intended to be identicalto the BP Settlement Agreements class definition. Azarisplans for sending individual notice by mail are highlighted.
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN1IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF LOUISIANAIn Re: Oil Spill by the Oil Rig “DeepwaterHorizon” in the Gulf of Mexico, on April20, 2010***********MDL NO. 2179SECTION JHONORABLE CARL J.BARBIERMAGISTRATE JUDGESHUSHANBon Secour Fisheries, Inc., et al., individuallyand on behalf of themselves and all otherssimilarly situated,Plaintiffs,v.BP Exploration & Production Inc.;BP America Production Company;BP p.l.c.,Defendants.***************Civil Action No. 12-970SECTION: JHONORABLE CARL J. BARBIERMAGISTRATE JUDGE SHUSHANDECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTYDAMAGES SETTLEMENT NOTICES AND NOTICE PLANI, 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 havepersonal knowledge of the matters set forth herein, and I believe them to be true and correct.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 2 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN22. I am a nationally recognized expert in the field of legal notice and I have served as amedia 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 indesigning, developing, analyzing and implementing large-scale, un-biased, legal notificationplans. Hilsoft has been involved with some of the most complex and significant notices andnotice programs in recent history.4. With experience in more than 200 cases, notices prepared by Hilsoft Notificationshave appeared in 53 languages with distribution in almost every country and territory in theworld. Judges, including in published decisions, have recognized and approved numerous noticeplans developed by Hilsoft Notifications, which decisions have always withstood collateralreviews by other courts and appellate challenges.EXPERIENCE RELEVANT TO THIS CASE5. Hilsoft Notifications has served as notice expert and has been recognized andappointed 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 classmembers and publication in relevant local newspapers, 2011) No. 1:09-cv-6655 (N.D. Ill.); In reResidential Schools Class Action Litigation, Canada (notice program for the landmark settlementbetween the Canadian government and Aboriginal former students; Phase IV notice program iscurrently being implemented, 2011/2012); In re Department of Veterans Affairs (VA) Data TheftLitigation (notices appeared across the country in newspapers, consumer magazines andspecialty publications with a total circulation exceeding 76 million, 2009), MDL 1796 (D. D.C);Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 3 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN3and Vereen v. Lowe’s Home Centers (massive combined individual and media notice effortrelated to defective drywall, 2011) SU10-CV-2267B (Ga. Super. Ct.).6. We have been recognized by courts for our testimony as to which method ofnotification is appropriate for a given case, and have provided testimony on numerous occasionson whether a certain method of notice represents the best notice practicable under thecircumstances. For example:a) In Schulte v. Fifth Third Bank, No. 1:09-cv-6655 (N.D. Ill.), Judge RobertM. Dow, Jr. stated on July 29, 2011:The Court has reviewed the content of all of the various notices, as well asthe manner in which Notice was disseminated, and concludes that theNotice given to the Class fully complied with Federal Rule of CivilProcedure 23, as it was the best notice practicable, satisfied allconstitutional due process concerns, and provided the Court withjurisdiction 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 partiesthroughout this proceeding with respect to the certification of theSettlement Class, the proposed settlement, and all related procedures andhearings—including, without limitation, the notice to putative SettlementClass members and others more fully described in this Court’s order of30th day of March 2011 were reasonably calculated under all thecircumstances and have been sufficient, as to form, content, and manner ofdissemination, to apprise interested parties and members of the SettlementClass of the pendency of the action, the certification of the SettlementClass, the Settlement Agreement and its contents, Settlement Classmembers’ right to be represented by private counsel, at their own cost,and Settlement Class members’ right to appear in Court to have theirobjections heard, and to afford Settlement Class members an opportunityto exclude themselves from the Settlement Class. Such notices compliedwith all requirements of the federal and state constitutions, including thedue process clause, and applicable articles of the Louisiana Code of CivilProcedures, and constituted the best notice practicable under thecircumstances and constituted due and sufficient notice to all potentialCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 4 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN4members of the Settlement Class.c) In In re: Department of Veterans Affairs (VA) Data Theft Litigation, MDLNo. 1796 (D. D.C.), Judge James Robertson stated on September 23, 2009:The Notice Plan, as implemented, satisfied the requirements of dueprocess and was the best notice practicable under the circumstances. TheNotice Plan was reasonably calculated, under the circumstances, toapprise Class Members of the pendency of the action, the terms of theSettlement, and their right to appear, object to or exclude themselves fromthe 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 BreachLitigation, 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)’sreasonableness requirement… Hilsoft Notifications analyzed the noticeplan after its implementation and conservatively estimated that noticereached 81.4 percent of the class members. (Docket Entry No. 106, ¶ 32).Both the summary notice and the detailed notice provided the informationreasonably necessary for the presumptive class members to determinewhether to object to the proposed settlement. See Katrina Canal Breaches,628 F.3d at 197. Both the summary notice and the detailed notice “werewritten in easy-to-understand plain English.” In re Black FarmersDiscrimination Litig., — F. Supp. 2d —, 2011 WL 5117058, at *23(D.D.C. 2011); accord AGGREGATE LITIGATION § 3.04(c).15 Thenotice provided “satisf[ies] the broad reasonableness standards imposedby 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, (3rdJud. Cir. Ill.),Judge Barbara Crowder stated on March 23, 2009:The Court finds that the Notice Plan is the best notice practicable underthe circumstances and provides the Eligible Members of the SettlementClass sufficient information to make informed and meaningful decisionsregarding their options in this Litigation and the effect of the Settlementon their rights. The Notice Plan further satisfies the requirements of dueprocess and 735 ILCS 5/2-803. That Notice Plan is approved andaccepted. This Court further finds that the Notice of Settlement andClaim Form comply with 735 ILCS 5/2-803 and are appropriate as partof the Notice Plan and the Settlement, and thus they are herebyCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 5 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN5approved and adopted. This Court further finds that no other noticeother than that identified in the Notice Plan is reasonably necessary inthis Litigation.7. Numerous other court opinions and comments as to our testimony, and opinions onthe adequacy of our notice efforts, are included in Hilsoft Notifications’ curriculum vitaeattached as Exhibit 1.8. In forming my expert opinions, I and my staff draw from our in-depth class actioncase experience, as well as our educational and related work experiences. I am an active memberof the Oregon State Bar, receiving my Bachelor of Science from Willamette University and myJuris Doctor from Northwestern School of Law at Lewis and Clark College. I have served as theDirector of Legal Notice for Hilsoft Notifications since 2008 and have overseen the detailedplanning of virtually all of our court-approved notice programs since that time. Prior toassuming my current role with Hilsoft Notifications, I served in a similar role as Director of EpiqLegal Noticing (previously called Huntington Legal Advertising). Overall, I have twelve yearsexperience in the design and implementation of legal notification and claims administrationprograms, 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 determiningthe most effective mixture of media required to reach the greatest practicable number of Classmembers.9. This affidavit will describe the Economic and Property Damages Settlement NoticePlan (“E&PD Notice Plan” or “Notice Plan”) and notices (the “Notice” or “Notices”) designedby Hilsoft Notifications and proposed here for the Economic and Property Damages Settlement(“E&PD Settlement”) with BP Exploration & Production Inc. and BP America ProductionCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 6 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN6Company Inc. ("BP") in In re: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf ofMexico on April 20, 2010, MDL No. 2179 Litigation, including how the Notice Plan wasdeveloped and why it will be effective. The Notice Plan and its attachments are attached heretoas Exhibit 2 to this affidavit. We developed the Notice Plan and Notices based on our extensiveprior experience and research into the notice issues in this case. We have analyzed the mosteffective method of notice for this Class.NOTICE PLANNING METHODOLOGY10. Considerable efforts have been undertaken to compile names and addresses of allknown or likely Settlement Class Members. As described in the Notice Plan, the final mailinglist will include all records in the Gulf Coast Claims Facility database that do not relate solely toa medical claim, people and entities who filed a Short Form Joinder in MDL 2179 and knownVessels of Opportunity lists, among others. Additionally, public records were searched toidentify current postal addresses for property owners who are likely eligible to submit coastalreal property, wetlands real property and real property sales claims.11. Rule 23 directs that the best notice practicable under the circumstances mustinclude “individual notice to all members who can be identified through reasonable effort.”1Theproposed notice effort satisfies this direction. If a postal address is available or can beascertained for a likely Class Member, notice will be sent by first class mail. If there is an emailaddress available, notice will also be sent by electronic means. Address updating (both prior tomailing and on undeliverable pieces) and re-mailing protocols will meet or exceed those used inother class action settlements.1FRCP 23(c)(2)(B).Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 7 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN712. Separate from the compilation of the individual notice mailing lists, data sourcesand tools that are commonly employed by experts in this field were used to analyze the reach andfrequency2of the media portion of this Notice Program. These include GfK MediamarkResearch & Intelligence, LLC (“MRI”) data,3which provides statistically significant readershipand product usage data, and Audit Bureau Circulation (“ABC”)4statements, which certify howmany readers buy or obtain copies of publications. Broadcast media planning data was providedby Neilsen Media Research5and Arbitron Inc6. Online media planning data was provided bycomScore, Inc.7These tools, along with demographic breakdowns indicating how many peopleuse each media vehicle, as well as computer software that take the underlying data and factor outthe duplication among audiences of various media vehicles, allow us to determine the net2Reach is defined as the percentage of a class exposed to a notice, net of any duplication among people who mayhave 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 anotice.3GfK Mediamark Research & Intelligence, LLC (“MRI”) is a leading source of publication readership and productusage data for the communications industry. MRI offers comprehensive demographic, lifestyle, product usage andexposure to all forms of advertising media collected from a single sample. As the leading U.S. supplier ofmultimedia 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 andmarketing plans that are written for advertised brands in the U.S.4Established in 1914, ABC is a non-profit cooperative formed by media, advertisers, and advertising agencies toaudit the paid circulation statements of magazines and newspapers. ABC is the leading third party auditingorganization in the U.S. It is the industry’s leading, neutral source for documentation on the actual distribution ofnewspapers printed and bought by readers. Widely accepted throughout the industry, it certifies over 3,000publications, categorized by metro areas, region, and other geographical divisions. Its publication audits areconducted in accordance with rules established by its Board of Directors. These rules govern not only how auditsare conducted, but also how publishers report their circulation figures. ABC’s Board of Directors is comprised ofrepresentatives from the publishing and advertising communities.5Nielsen ratings are the audience measurement systems developed by the Nielsen Company, in an effort todetermine the audience size and composition of television programming in the United States. The Nielsen methodhas since become the primary source of audience measurement information in the television industry around theworld.6Arbitron Inc. is an international media and marketing research firm serving the media—radio, television, cable andout-of-home; the mobile industry as well as advertising agencies and advertisers around the world.7comScore, Inc.is a global leader in measuring the digital world and a preferred source of digital marketingintelligence. In an independent survey of 800 of the most influential publishers, advertising agencies and advertisersconducted by William Blair & Company in January 2009, comScore was rated the “most preferred online audiencemeasurement service” by 50% of respondents, a full 25 points ahead of its nearest competitor.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 8 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN8(unduplicated) reach of a particular media schedule. We combine the results of this analysis tohelp determine notice plan sufficiency and effectiveness.13. Tools and data trusted by the communications industry and courts. Virtually allof the nation’s largest advertising agency media departments utilize, scrutinize, and rely uponsuch independent, time-tested data and tools, including net reach and de-duplication analysismethodologies, 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 planningtools have become standard analytical tools for evaluations of notice programs, and have beenregularly accepted by courts.14. In fact, advertising and media planning firms around the world have long relied onaudience data and techniques: ABC data has been relied on since 1914; 90-100% of mediadirectors use reach and frequency planning;8all of the leading advertising and communicationstextbooks cite the need to use reach and frequency planning;9and a leading treatise says it mustbe used for reach and frequency planning: “In order to obtain this essential information, we mustuse the statistics known as reach and frequency.”10Ninety of the top one hundred media firmsuse MRI data, which has a 95% confidence interval, and at least 3,000 media firms in 25different countries use media planning software for reach and frequency planning.118See generally Peter B. Turk, Effective Frequency Report: Its Use And Evaluation By Major Agency MediaDepartment Executives, 28 J. ADVERTISING RES. 56 (1988); Peggy J. Kreshel et al., How Leading AdvertisingAgencies Perceive Effective Reach and Frequency, 14 J.ADVERTISING 32 (1985).9Textbook sources that have identified the need for reach and frequency for years include: JACK S. SISSORS & JIMSURMANEK, 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 MEDIA123-126 (1980); JACK Z. SISSORS & LINCOLN BUMBA, ADVERTISING MEDIA PLANNING 93-122 (4th ed. 1993); JIMSURMANEK, INTRODUCTION TO ADVERTISING MEDIA: RESEARCH, PLANNING, AND BUYING 106-187 (1993).10AMERICAN ADVERTISING AGENCY ASSOCIATION, GUIDE TO MEDIA RESEARCH 25 (1987), revised 1993.11For example, Telmar is the worlds leading supplier of media planning software and support services. Over 3,000users in 25 countries, including 95% of the worlds top agencies, use Telmar systems for media and marketingplanning tools including reach and frequency planning functions. Established in 1968, Telmar was the firstcompany to provide media planning systems on a syndicated basis.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 9 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN9ECONOMIC AND PROPERTY DAMAGES NOTICE PLAN SUMMARY15. The E&PD Settlement Agreement defines the “Class” as:A. Individuals. Unless otherwise specified, all Natural Persons residingin the United States who, at any time between April 20, 2010 and April16, 2012, lived in, worked in, were offered and accepted work in,owned or leased real or personal property located within, or owned orleased or worked on a vessel harbored or HOME PORTED in theStates of Louisiana, Mississippi, or Alabama, the counties of Chambers,Galveston, Jefferson and Orange in the State of Texas, or the countiesof 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 theState 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 theGulf of Mexico and all adjacent bays, estuaries, straits, and other tidalor brackish waters within the Gulf Coast Areas, as specifically shownand described in Exhibit 23 (“SPECIFIED GULF WATERS”), orworked on a vessel in Specified Gulf Waters after April 20, 2009. Withrespect to SEAFOOD CREW Claims, persons must have worked on avessel that landed SEAFOOD in the Gulf Coast Areas after April 20,2009.andB. Entities. All Entities doing business or operating in the Gulf CoastAreas 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 orSpecified Gulf Waters and (A) sold products in the Gulf CoastAreas or Specified Gulf Waters (1) directly to CONSUMERS orEND USERS of those products or (2) to another Entity that soldthose products directly to Consumers or End Users of thoseproducts, or (B) regularly purchased Seafood harvested fromSpecified Gulf Waters in order to produce goods for resale;b) are service businesses with one or more full-timeemployees (including owner-operators) who performed their full-time services while physically present in the Gulf Coast Areas orSpecified Gulf Waters at any time from April 20, 2010 to April 16,2012; orCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 10 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN10c) owned, operated, or leased a vessel that (1) was HomePorted in the Gulf Coast Areas at any time from April 20, 2010 toApril 16, 2012, or (2) landed Seafood in the Gulf Coast Areas atany time from April 20, 2009 to April 16, 2012; ord) owned or leased REAL PROPERTY in the Gulf CoastAreas at any time from April 20, 2010 to April 16, 2012;C. Individuals and Entities who meet the geographical descriptions ofSections A or B above are included in the Economic Class only if theirClaims meet the descriptions of one or more of the Damage Categoriesdescribed in the Settlement Agreement.16. To guide the selection of measured media in reaching unknown E&PD SettlementClass 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 unknownClass Members who do not currently reside in the Gulf Coast Areas, the Plan includes a broadnational 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 eachDesignated Marketing Area (“DMA”)12in which the largest population center within eachrespective DMA included a portion of the defined Gulf Coast Areas. Twenty-six (26) individualDMAs encompassing the Gulf Coast Areas have been used to establish the geographic scope forthe local portion of the media plan. They are as follows:Houston Mobile-Pensacola-Ft. Walton Ft. Meyers-NaplesBeaumont- Port Arthur Montgomery-Selma Panama CityNew Orleans Dothan Hattiesburg-LaurelLake Charles Miami-Ft. Lauderdale Alexandria, LALafayette, LA Tallahassee-Thomasville Monroe-El DoradoBaton Rouge Gainesville Shreveport12DMA or “Designated Marketing Area” is a term used by Nielsen Media Research to identify an exclusivegeographic area of counties or parishes in which the home market television stations hold a dominance of total hoursviewed. There are 210 DMAs in the U.S.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 11 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN11Biloxi-Gulfport Tampa-St. Petersburg-Sarasota Jackson, MSColumbus-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 ClassMembers, compiled from various lists provided by the settling parties and their experts. Framedby the 26 DMAs listed above, an extensive schedule of local newspaper, radio, television andInternet placements has been proposed to reach Class Members in the Gulf Coast Areas. Toreach Class Members across the United States, the schedule includes well-read consumermagazines, a national daily business newspaper, highly trafficked websites and Sunday localnewspapers (via newspaper supplements). Notice placements will also appear in non-measuredtrade, business and specialty publications, African-American, Vietnamese and Spanish languagepublications and Cajun radio programming. An informational release, television public serviceannouncements (“PSAs”), and case website will provide additional notice exposures.19. The combined measurable effort will reach at least 95% of adults aged 18+ in the26 identified DMAs covering the Gulf Coast Areas an average of 8.8 times each and anestimated 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 effortin the Gulf Coast Areas will surpass that of the vast majority of other court-approved noticeprograms, and has been designed to meet and exceed due process requirements. The reach andfrequency to all U.S. adults is also consistent with the most thorough and expansive class actionmedia notice efforts.21. Hilsoft was also retained to design and implement a Notice Plan for thecontemporaneously filed Medical Benefits Settlement with BP. The two Notice Plans areCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 12 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN12separate and distinct. For the purposes of this affidavit, the adequacy of the E&PD Notice Planand notices are discussed. A separate affidavit for the Medical Benefits Settlement has beensubmitted 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 Planhighlights that the Court is considering two separate settlements. Each Notice Plan includesunique individual mailing pieces, mailed separately in different colored envelopes. Printpublication notice consists of a single advertising unit with one Summary Publication Notice thataddresses the E&PD Settlement, and a separate Summary Publication Notice that addresses theMedical Benefits Settlement. Depending on the publication, the Summary Publication Noticeswill appear either side-by-side or stacked one above the other. Broadcast and Internet bannerefforts will provide the message that there is one settlement addressing economic and propertydamage claims, and a separate settlement addressing medical claims.ECONOMIC AND PROPERTY DAMAGES NOTICE PLAN23. We designed the Notice Program to reach the greatest practicable number of E&PDSettlement Class Members, ensuring that the Class will receive multiple opportunities to beexposed to the Notice, to see, review, understand, and be reminded about it, and to respondappropriately 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 PSAand 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 alertClass Members that the content may affect them.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 13 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN13Individual Mailed Notice24. For each unique name and address of a known or likely Economic and PropertyDamages Settlement Class Member, a Notice Packet will be mailed via first class mail in a flatenvelope. The Notice Packet will include a Cover Letter and Detailed Notice, and is expected toinclude a color map folio. Potential Class Members will be directed to the settlement websiteand 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 areincluded 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 likelySettlement 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 whorequested information about the GCCF process and provided contact information tothe GCCF 13;• BP Claims Facility list of claimants who filed claims under the Oil Pollution Act of1990, prior to the creation of the GCCF;• Vessels of Opportunity (“VoO”) lists and lists of VoO contractors whosubcontracted out to other vessels; and• Lists of ascertainable Coastal Real Property owners, Wetlands Real Propertyowners and Real Property Sales owners who are presumptively members theSettlement Class and do not have to demonstrate a loss in order to be eligible to filea claim.26. Prior to mailing, all addresses will be checked against the National Change ofAddress (“NCOA”) database maintained by the United States Postal Service (“USPS”).14If a13An Economic and Property Damage Settlement Notice packet will be mailed to all names and addresses in theGCCF database that do not unambiguously relate only to a medical claim. (Individuals who unambiguously relateonly to a medical claim will be mailed a Notice packet related to the separate Medical Benefits Settlement). For anyrecord in the GCCF database where there is any ambiguity as to the subject matter of that individual’s claim orrequest for further information, an Economic and Property Damage Notice Packet will be mailed.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 14 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN14record 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 willbe re-mailed to any new address available through postal service information, for example, to theaddress provided by the postal service on returned pieces for which the automatic forwardingorder has expired (but which is still during the period in which the postal service returns thepiece 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 willbe promptly re-mailed on an ongoing basis leading up to the Fairness Hearing. Additionally, theNotice Packet will be mailed to all persons who request one via the toll-free phone numbermaintained by the administrator.27. For some known or likely Settlement Class Members, only a name and emailaddress is available and no other means exist of determining a physical address. Theseindividuals will be sent notice via email. For known or likely Settlement Class Members forwhom a physical address and an email address are available, notice will be sent via email inaddition to postal mail. The Email Notice will include substantially the same content as the textof the Publication Notice that is specific to the E&PD Settlement, and will contain a link to thesettlement website where the Detailed Notice and other detailed settlement information can beaccessed. The Email Notice will be provided using an embedded HTML text format. Thisformat will provide text that is easy to read without graphics, tables, images and other elementsthat 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 will14The NCOA database contains records of all permanent change of address submissions received by the USPS forthe last four years. The USPS makes this data available to mailing firms and lists submitted to it are automaticallyupdated with any reported move based on a comparison with the person’s name and known address.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 15 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN15notify major ISPs about the scheduled notification effort to get these messages “white-listed” fordelivery to recipient mailboxes.28. Each Email Notice will be transmitted with a unique message identifier. If thereceiving email server cannot deliver the message, a “bounce code” should be returned to thesending server along with the unique message identifier. For any Email Notice for which abounce code is received indicating that the message was undeliverable, at least two additionalattempts will be made to deliver the Notice by email.29. The Notice Packet will also be sent to known attorneys who represent likely ClassMembers other than Class Counsel.Gulf Coast Areas Local Newspaper Notice30. The Notice Plan to the Gulf Coast Areas includes notice placements in daily andweekly newspapers covering each of the DMAs specified in paragraph 17 above. These 26DMAs ringing the Gulf Coast Areas will be covered by a total of 347 individual, localnewspapers.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 theClass 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 17additional newspapers. Including these insertions, the Publication Notice will run in a total of364 individual, local newspapers.32. The Publication Notice will appear four times as a full-page ad unit in eachnewspaper—twice on Sunday and twice on a weekday in daily newspapers and over fourCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 16 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN16successive weeks in weekly newspapers for a total of 1,456 insertions. The selected newspapershave a combined circulation of over 8 million. In most instances, the Notice will appear a fifthor sixth time in each local newspaper via the two planned insertions in the nationwide newspapersupplements (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 twolocal newspaper Sunday insertions. As placed, the Publication Notice ad unit will includeseparate Notices addressing both the E&PD Settlement, and the separate Medical BenefitsSettlement. Depending on the publication, the separate Notice text for each Settlement willappear 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&PDNotice Plan (attached hereto as Exhibit 2).Gulf Coast Areas Local Television Notice34. The E&PD Notice Plan provides for 30-second television spots that will appear onlocal broadcast and cable television in the same 26 DMAs as the daily and weekly newspaperplacements.35. We conservatively estimate that 2,730 30-second spots will run over a four-weekperiod. Television placements will substantially occur over the initial three weeks with thefourth week reserved for any remaining inventory. Approximately 300 Gross Rating Points(“GRPs”)15per market and over 67 million gross impressions will be generated. Ads are plannedto air on the top three local television stations per market and on the top six cable networks permarket. It is likely that additional spots will be negotiated at the time of the buy.15A “GRP” is a gross rating point. One rating point equals one percent of a target population. Gross rating pointsmay include the same person reached more than once, so ratings can and often do exceed 100.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 17 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN1736. 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 withdifferent viewing habits.37. On its own, the Television Notice is estimated to reach an average of 83% of adultsaged 18+ in the Gulf Coast Areas with an estimated average frequency of 3.6 times each. Adultswill be exposed to the television Notice more than 67 million times during the period in whichthe television schedule airs.38. The E&PD Notice Plan also includes a television PSA effort. The TelevisionNotice will be distributed to over 1,200 broadcast television stations throughout the United Stateswith a statement to station managers on why the announcement provides important legalinformation that may be relevant to their viewers.Gulf Coast Areas Local Radio39. The E&PD Notice Plan provides for 30-second radio units, which will appear overa two-week schedule on selected mainstream radio stations in the same 26 DMAs as the dailyand weekly newspaper placements and television ads.40. It is estimated that the mainstream local Radio Notice will generate approximately180 GRPs per market. We conservatively estimate that 8,712 total spots will be run, but it ispossible that additional spots will be negotiated at the time of the buy. On its own, themainstream Local Radio Notice is estimated to reach an average of 45% of adults aged 18+ inthe Gulf Coast Areas with an estimated average frequency of 4 times each.41. Targeting rural communities, the radio notice will also appear on “StateNets,” aradio network specializing in reaching rural areas. Typical StateNets features are news, regionalCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 18 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN18weather and other informational programs. We estimate that over 14,000 total spots will run onapproximately 200 radio stations in the 26 DMAs over a three-week period.42. Additionally, the Radio Notice will be placed on appropriate African-American andSpanish 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 highconcentrations of Spanish-speaking adults. The Spanish language Radio Notice will be recordedas a 60-second spot to accommodate the translation.43. A radio buy will also be executed, targeted toward the Cajun population in SouthernLouisiana. 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 Publications44. The Publication Notice will appear in publications covering ethnic and languagegroups identified as having a significant presence in the Gulf Coast Areas. The Notice willappear in 46 selected publications as a double-page spread or full-page ad unit three times inselected daily and weekly publications and one time in selected monthly publications coveringthe 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 selectedpublications have a combined estimated circulation of over 1.8 million.National Newspaper Inserts and Consumer Publications45. The E&PD Notice Plan includes highly visible notice placements in thirteen leadingweekly and monthly publications. Notices will appear twice in the national newspapersupplements Parade and USA Weekend and once in American Profile which appear in over2,190 Sunday newspapers nationwide with distribution in large cities and small towns. TheCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 19 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN19newspapers appear in a wide geographic area, covering both large markets (A and B counties16with Parade and USA Weekend) and small cities and towns (C and D counties17with AmericanProfile). Combined, Parade, USA Weekend and American Profile have an estimated circulationof more than 65 million.46. Notices will appear twice in People, and once in Better Homes and Gardens, AARPBulletin, National Geographic, Cosmopolitan, Sports Illustrated, Southern Living, People enEspanol, Ebony and Essence, for a total of 11 insertions.47. The selected publications include the top four in the country in terms of circulationand six of the top seven. The selected publications cover all demographic groups, specificallytargeting 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 totalcirculation of over 114 million. Adults will be exposed to the Notice through these publicationsalone more than 521 million times during the notice period. This includes the same reader morethan once, because readers of one publication read other publications as well. Detailedinformation on each of the publications selected is included in the E&PD Notice Plan attached asExhibit 2.16“County/parish size A” is defined as highly urbanized areas and belong to the 21 largest Metropolitan StatisticalAreas. The combined counties/parishes contain 40% of the United States households. “County/parish size B” isdefined as counties/parishes not defined as A counties/parishes that have more than 85,000 households. Thecombined 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 morethan 20,000 households or are in Consolidated Metropolitan Statistical Areas or Metropolitan Statistical Areas withmore than 20,000 households. “County/parish size D” is defined as all counties/parishes not classified as A, B or Ccounties/parishes. They are considered very rural.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 20 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN20Nationwide and Regional Business and Trade Publications49. The Publication Notice will appear once or twice as a double-page spread orequivalent size ad unit in 34 selected publications targeted to the industries and activities mostlikely 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 ofover 5 million.Internet Banner Notices50. The E&PD Notice Plan provides for Banner Notices measuring 728 x 90 pixels and300 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 includingthose related to health, fitness, and news and information).51. Where available, banners will also be placed on the websites of the selected tradeand specialty publications included in the print publication plan.52. Combined, approximately 72 million adult impressions will be generated by thesebanner notices over a one month period. Clicking on the banner will link the reader to the casenotice website where they can obtain information about the Settlement and link directly to theseparate claims administration websites for each Settlement.53. To complement print notices in the selected local newspapers, digital 728 x 90 pixeland 300 x 250 pixel banners will be placed on newspaper and local TV websites in the identifiedgeographies. Banner Notices will run across 31 days and deliver more than 42 millionimpressions across Louisiana, Mississippi, Alabama and portions of Texas and Florida. Eachbanner notice will include a clickable link to the case notice website.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 21 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN21Informational Release54. To build additional reach and extend exposures, a party-neutral informationalrelease will be issued to approximately 4,200 print and broadcast and 5,500 online press outletsthroughout the United States.55. An informational release serves a potentially valuable role, providing additionalnotice exposure beyond that which will be provided through paid media. There is no guaranteethat any news stories will result, but if they do, Class Members will have additional opportunitiesto learn that their rights are at stake in credible news media, adding to their understanding.Case Website56. A neutral, informational, notice website with an easy to remember domain namewill serve as the notice page for both Settlements (the E&PD Settlement as well as the MedicalBenefits Settlement) where potential Settlement Class Members can obtain additionalinformation and documents including the Detailed and Summary Notices, SettlementAgreements, Preliminary Approval Orders and any other information that the parties agree toprovide or that the Court may require. The case notice website will also include information onhow 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 noticedocuments, 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 claimsadministration websites tailored to each Settlement via prominent buttons on the notice websitehomepage (one reading “Economic and Property Damages Claims” and the other readingCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 22 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN22“Medical Claims”). Claim Forms and other information specific to each Settlement will beavailable at these claims administration sites. The case notice website will be color-coordinatedwith the claims administration websites and all pages that a visitor might see will have aconsistent look and functionality. To stress the separateness of the two Settlements, the claimsadministration sites will have different, but compatible, color schemes. The case notice websitewill reflect this by having the button links to each claims administration website in the specificcolor scheme of the website it is linking to. Both claims administration websites will include aprominent link to the other claims administration website for visitors interested in bothsettlements.59. The claims administrator claims filing website will include an interactive map ofthe Gulf Coast where visitors will be able to input their property or residency address or select ageographic location to assist them in determining if the address falls into one or more of thedefined Settlement “Zones.”60. All website content (including the Notices) will be available in English, Spanishand Vietnamese. Translated Notices may also be made available in Khmer, Lao andHaitian/Creole if requested.61. To facilitate locating the case notice website, sponsored search listings will beacquired on the three most highly-visited Internet search engines: Google, Yahoo! and Bing.When search engine visitors search on common keyword combinations such as “DeepwaterHorizon settlement,” “Gulf property settlement,” or “BP oil spill settlement,” the sponsoredsearch listing will display either at the top of the page prior to the search results or in the upperright hand column.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 23 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN23Toll-free Telephone Number and Postal Mailing Address62. A single toll-free number will be established for both Settlements. Callers will havethe option of selecting to listen in English, Spanish or Vietnamese. Initially, all callers will hearan introductory message that two separate settlements related to the Deepwater Horizon oil spill -one settlement addressing economic and property damages claims, and a separate settlementaddressing medical claims - have been reached. Callers will then have the option to continue toget information about one or the other settlement, request a Detailed Notice by mail and have theoption to choose to speak with a live operator.63. A postal mailing address and email address for each claims administrator will beprovided, allowing Class Members to request additional information or ask questions via thesechannels.PERFORMANCE OF E&PD NOTICE PROGRAMReach64. Using standard advertising media industry methodologies to calculate the overlapinherent in exposures to the measured publication, broadcast and Internet activity, we arrive at acombined measurable reach of at least 95% of adults in the Gulf Coast Areas18aged 18+ and anestimated 83% of all U.S. adults aged 18+. Reach will be enhanced further by the IndividualMailed Notice effort, notice placements in unmeasured trade, business and specialtypublications, African-American publications, Vietnamese and Spanish language publications,and the informational release, television PSAs and case website.18While there is some variation in reach of the individual Notice Plan components from DMA to DMA, theestimated reach of the entire Notice Plan is at least 95% in each of the 26 DMAs that cover the Gulf Coast Areas.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 24 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN2465. Many courts have accepted and understood that a 75 or 80 percent reach is morethan adequate. In 2010, the Federal Judicial Center issued a Judges’ Class Action Notice andClaims Process Checklist and Plain Language Guide. This Guide states that, “the lynchpin in anobjective determination of the adequacy of a proposed notice effort is whether all the noticeefforts 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 onapproved notice plans was 87%.”19Here we were able to exceed that and develop a notice planthat will perform at the highest level of reportable reach. These statistics reinforce the fact thatthe E&PD Notice Plan is broad in scope and is designed to reach the greatest practicable numberof Class Members.Average Frequency of Exposure66. The E&PD Notice Plan will provide Class Members with the best practicableopportunity to view and understand the Notice and their rights, including their rights to opt-outand object to the Settlement and their right to file a claim. A by-product of using media vehiclesnecessary to achieve a broad net reach is frequency of exposure to notice stemming frominherent audience overlap.67. As a result, adults in the Gulf Coast Areas reached will, on average, have 8.8exposure opportunities20to the proposed Notice Program and each U.S. adult aged 18+ reachedwill, on average, have 3.8 exposure opportunities to the proposed Notice Program. Thefrequency of exposure will be further enhanced by the Individual Mailed Notice effort, notice19Federal Judicial Center, Judges’ Class Action Notice and Claims Process Checklist and Plain Language Guide(2010), p. 3.20The estimated frequency of 8.8 times is a conservative average across all 26 DMAs covering the Gulf CoastAreas. Frequency by DMA is estimated to range from a low of 7.9 times to a high of 9.6 times or more.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 25 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN25placements in unmeasured trade, business and specialty publications, African-Americanpublications, Vietnamese and Spanish language publications, informational release, televisionPSAs, and case website.PLAIN LANGUAGE NOTICE DESIGN68. As fully explained in the E&PD Notice Plan, the Notices themselves are designedto be “noticed,” reviewed, and—by presenting the information in plain language— understoodby Class Members. The design of the Notices follows the principles embodied in the FederalJudicial Center’s illustrative “model” notices posted at www.fjc.gov. Many courts, and aspreviously cited, the FJC itself, have approved notices that we have written and designed in asimilar fashion. The Notices contain substantial, albeit easy-to-read, summaries of all of the keyinformation about Class Members’ rights and options. Consistent with our normal practice, allnotice documents will undergo a final edit prior to actual mailing and publication forgrammatical errors and accuracy. Along with our submission of the E&PD Notice Plan attachedas 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 potentialSettlement Class Members and to those who call to request one as well as madeavailable at the website.• The Email Notice that will be sent to known or likely Settlement Class Members forwhom 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 asa 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 whentranslated 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 theU.S.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 26 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN2669. All Notices were designed to increase noticeability and comprehension. Becausemailing 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 readershipand comprehension.70. The mailed Notice Packet will be inserted into a flat 9x12 envelope and will carry aprominent callout on the front of the envelope (“DEEPWATER HORIZON – Economic andProperty Damages Settlement”) and a more descriptive callout on the back of the envelope (“Ifyou had economic loss or property damage because of the Deepwater Horizon oil spill, youcould get money from a class action settlement.”). To reduce confusion for people that may bemembers of the E&PD Settlement Class and the Medical Benefits Settlement Class, the envelopewill coordinate with the color of the E&PD Settlement claims administration website and be distinctfrom the color of the envelope containing the Medical Settlement Notice Packet (which willcoordinate with the Medical Benefits claims administration website). The Publication Noticefeatures a prominent headline (“Deepwater Horizon Oil Spill – Economic and Property DamagesSettlement – Providing Money to Individuals and Businesses”) in bold text. These designelements alert recipients and readers that the Notice is an important document authorized by a courtand that the content may affect them, thereby supplying reasons to read the Notice.71. The Detailed Notice provides substantial information to Settlement Class Members. TheE&PD Detailed Notice begins with a summary page providing a concise overview of the importantinformation and a table highlighting key options available to E&PD Settlement Class Members. Atable of contents, categorized into logical sections, helps to organize the information, while aCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 27 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN27question and answer format makes it easy to find answers to common questions by breaking theinformation into simple headings.72. The Email Notice will include substantially the same content as the text of thePublication Notice that is specific to the E&PD Settlement, and will contain an embedded link to thenotice website where the Detailed Notice and other settlement information can be accessed. TheEmail Notice will be provided using an embedded HTML text format. This format will provide textthat is easy to read without graphics, tables, images and other elements that would increase thelikelihood 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 theE&PD Settlement. The Notices are either full-page units in the local newspapers or double-pagespreads in most print publications to promote readership.74. The Television and Radio Notices are designed to stand apart from regular consumerads. 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 andconcepts will be depicted on screen. The principles of communication dictate visual and verbalrepetition of key concepts presented. A convenient response-oriented approach is provided. In theTelevision Notice, the website and toll-free number will be spoken and shown on the screen longenough to allow Class Members to write them down or remember them. The Radio Notice willrepeat the toll-free number and website if time permits. Simple information allows sufficientunderstanding. Although concise, the purpose of the Notice is served by delivering the substance ofthe message (that there are two separate Settlements) and prompting a response to get moreinformation.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 28 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN28CONCLUSION75. In class action notice planning, execution, and analysis, we are guided by dueprocess considerations under the United States Constitution, by federal and local rules andstatutes, and further by case law pertaining to notice. This framework directs that the noticeprogram be designed to reach the greatest practicable number of potential Class Members and, ina settlement class action notice situation such as this, that the notice or notice program itself notlimit knowledge of the availability of benefits—nor the ability to exercise other options—toClass 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 obligationsthat 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 reasonablycalculated to do so:A. “But when notice is a person’s due, process which is a mere gesture is not dueprocess. The means employed must be such as one desirous of actually informing theabsentee might reasonably adopt to accomplish it,” Mullane v. Central HanoverTrust, 339 U.S. 306, 315 (1950).B. “[N]otice must be reasonably calculated, under all the circumstances, to appriseinterested parties of the pendency of the action and afford them an opportunity topresent their objections,” Eisen v. Carlisle & Jacquelin, 417 U.S. 156 (1974) citingMullane at 314.77. The Notice Program will provide the best notice practicable under thecircumstances of this case, conforms to all aspects of Federal Rule of Civil Procedure 23, andcomports with the guidance for effective notice articulated in the Manual for Complex Litigation4th.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 29 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • DECLARATION OF CAMERON R. AZARI, ESQ. ON ECONOMIC AND PROPERTY DAMAGESSETTLEMENT NOTICES AND NOTICE PLAN2978. As reported above, the E&PD Notice Plan will effectively reach at least 95% ofadults in the Gulf Coast Areas aged 18+ and no less than 83% of U.S. adults aged 18+. It willdeliver “noticeable” Notices to capture Class Members’ attention, and provide them withinformation necessary to understand their rights and options.79. The E&PD Notice Plan schedule will afford enough time to provide full and propernotice to Class Members before any opt-out and objection deadline.80. At the appropriate time, Hilsoft may also develop and implement subsequent noticeefforts as agreed to by the parties and/or directed by the Court, including a reminder notice effortin advance of the claim filing deadline. Any reminder notice effort will be guided by theperformance 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 verifyingits effective implementation.I declare under penalty of perjury that the foregoing is true and correct. Executed on April17, 2012.______________________________________Cameron R. Azari, Esq.© 2012 Hilsoft NotificatioCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 30 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • AFFIDAVIT OF CAMERON R. AZARI, ESQ., ON ECONOMIC AND PROPERTY DAMAGES SETTLEMENTNOTICES AND NOTICE PLANCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 31 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Exhibit 1 to Declaration of Cameron Azari: HilsoftNotifications Curriculum VitaeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 32 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Hilsoft NotificationsPhiladelphia Area Office1420 Locust Str 30FPhiladelphia, PA 19102(215) 721-2120(215) 721-6886 faxPortland Area Office10300 SW Allen BoulevardBeaverton, OR,97005(503) 350-5822(503) 350-5210 faxLeading expert firm for large-scale notice plan design, implementation, and analysis, for claimsprocesses, class actions and mass tort bankruptcies  Court-approved notice plans withstoodchallenge to U.S. Supreme Court  50+ favorable judicial comments–0 unfavorable  More than240 cases with notices appearing in 209 countries and 53 different languages  More than 20MDL cases  Equal work for defendants and plaintiffs  Case examples include (also seeHwww.hilsoft.comH): Largest discretionary class action notice campaign involving virtually every adult in theUnited States for the settlement of In re Trans Union Corp. Privacy Litigation. Largest U.S. and Canadian retail consumer security breach notice program designedand implemented in the settlement of In re TJX Companies, Inc., Customer DataSecurity Breach Litigation. Most complex national data theft class action settlement involving millions of classmembers in Lockwood v. Certegy Check Services, Inc. Most comprehensive notice ever in a securities class action for the $1.1 billion settlementof In re Royal Ahold Securities and ERISA Litigation. Largest and most complex class action in Canadian history. Designed/implementedgroundbreaking notice to disparate, remote aboriginal people in the multi-billion dollar Inre Residential Schools Litigation. Largest race-based pricing case with national settlement notice to 25 millionpolicyholders 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 billionsettlement 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 noticecampaign for the U.S. Dept. of Agriculture’s $10 billion tobacco growers’ transitionpayment 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.3d295, 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 reachmethodology challenge rejected by court. National publication notice in Avery v. State Farm, No. 97-L-114 (Cir. Ct. Ill.) withstoodchallenges to Illinois Supreme Court and U.S. Supreme Court, and re-affirmed in Averyv. State Farm, 321 Ill. App. 3d 269 (5thDist. 2001). Notice program untouched whenIllinois Supreme Court decertified Class.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 33 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 2KEY BIO’SCameron Azari, Esq., Director of Legal NoticingLegal Noticing Director Cameron Azari, Esq. has nine years experience in the design andimplementation of legal notification and claims administration programs. He is a nationally recognizedspecialist 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 noticeand advertising programs. High profile class actions he has been involved in include companies suchas 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 noticeand class action topics ranging from amendments to FRCP Rule 23 to email noticing, response ratesand optimizing settlement effectiveness. Cam is an active member of the Oregon State Bar. Hereceived his B.S. from Willamette University and his J.D. from Northwestern School of Law at Lewisand Clark College. Cam can be reached at caza@legalnotice.com.Lauran Schultz, Executive DirectorLauran Schultz is responsible for overall management of Hilsoft Notifications. He consultsextensively with clients on notice adequacy and innovative legal notice programs that are bothefficient and informed by the many court-approved programs developed by Hilsoft Notifications overclose 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 hasover a dozen years of consulting and management experience developing innovative marketingprograms for nationally and internationally recognized brands such as National City, HSBC andRegions Bank along with affiliates of the American Automobile Association and Better BusinessBureau. Prior to joining Epiq Systems in 2005, Lauran was a Senior Vice President of National CityBank in Cleveland, Ohio. Lauran’s education includes advanced study in political science at theUniversity of Wisconsin-Madison, Cornell University and the London School of Economics along witha Ford Foundation fellowship from the Social Science Research Council and American Council ofLearned Societies. Lauran can be reached at lschultz@hilsoft.com.ARTICLES AND PRESENTATIONSCameron Azari Speaker, “Class Action Litigation Trends: A Look into New Cases, Theories ofLiability & 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 7thAnnual Class Action Conference, San Francisco, CA, May, 2011.Cameron Azari Speaker, “Data Breaches Involving Consumer Financial Information: LitigationExposures 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 BestPractices.” CLE International’s 5thAnnual Class Action Conference: Prosecuting and DefendingComplex Litigation, San Francisco, CA, 2009.Lauran Schultz Speaker, “Efficiency and Adequacy Considerations in Class Action Media NoticePrograms.” 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 - ComplexSettlement Administration for the Class Action Litigator, Phoenix, AZ, 2007.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 34 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 3Cameron Azari Speaker, Noticing and Response Rates in Class Action Settlements” – Class ActionBar Gathering, Vancouver, British Columbia, 2007.Cameron Azari Speaker, “Structuring a Litigation Settlement.” CLE International’s 3rd AnnualConference on Class Actions, Los Angeles, CA, 2007.Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Skadden ArpsSlate Meagher & Flom, LLP, 2006.Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – BridgeportContinuing Legal Education, Class Action and the UCL, 2006.Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – Stoel Riveslitigation group, Portland/Seattle/Boise/Salt Lake City, 2005.Cameron Azari Speaker, “Notice and Response Rates in Class Action Settlements” – StroockStroock & 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 Gotshallitigation group, New York, 2003.JUDICIAL COMMENTSJudge 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 whichNotice was disseminated, and concludes that the Notice given to the Class fully complied withFederal Rule of Civil Procedure 23, as it was the best notice practicable, satisfied allconstitutional due process concerns, and provided the Court with jurisdiction over the absentClass 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 reasonablenessrequirement… Hilsoft Notifications analyzed the notice plan after its implementation andconservatively estimated that notice reached 81.4 percent of the class members. (Docket EntryNo. 106, ¶ 32). Both the summary notice and the detailed notice provided the informationreasonably necessary for the presumptive class members to determine whether to object to theproposed settlement. See Katrina Canal Breaches, 628 F.3d at 197. Both the summary noticeand the detailed notice “were written in easy-to-understand plain English.” In re Black FarmersDiscrimination Litig., — F. Supp. 2d —, 2011 WL 5117058, at *23 (D.D.C. 2011); accordAGGREGATE LITIGATION § 3.04(c).15 The notice provided “satisf[ies] the broadreasonableness standards imposed by due process” and Rule 23. Katrina Canal Breaches, 628F.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 andprovides the Eligible Members of the Settlement Class sufficient information to make informedand meaningful decisions regarding their options in this Litigation and the effect of the Settlementon their rights. The Notice Plan further satisfies the requirements of due process and 735 ILCS5/2-803. That Notice Plan is approved and accepted. This Court further finds that the Notice ofSettlement and Claim Form comply with 735 ILCS 5/2-803 and are appropriate as part of theNotice Plan and the Settlement, and thus they are hereby approved and adopted. This Courtfurther finds that no other notice other than that identified in the Notice Plan is reasonablynecessary in this Litigation.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 35 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 4Judge 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 thisproceeding with respect to the certification of the Settlement Class, the proposed settlement, andall related procedures and hearings—including, without limitation, the notice to putativeSettlement Class members and others more fully described in this Court’s order of 30thday ofMarch 2011 were reasonably calculated under all the circumstances and have been sufficient, asto form, content, and manner of dissemination, to apprise interested parties and members of theSettlement Class of the pendency of the action, the certification of the Settlement Class, theSettlement Agreement and its contents, Settlement Class members’ right to be represented byprivate counsel, at their own cost, and Settlement Class members’ right to appear in Court tohave their objections heard, and to afford Settlement Class members an opportunity to excludethemselves from the Settlement Class. Such notices complied with all requirements of thefederal and state constitutions, including the due process clause, and applicable articles of theLouisiana Code of Civil Procedures, and constituted the best notice practicable under thecircumstances and constituted due and sufficient notice to all potential members of theSettlement 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 wereadequate 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, theterms and conditions set forth in the Settlement Agreement, and these proceedings to all personsentitled to such notice, and said notice fully satisfied the requirements of Rule 23 of the FederalRules 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 identifiableClass members; 2) nationwide paid media notice through a combination of print publications,including newspapers, consumer magazines, newspaper supplements and the Internet; 3) aneutral, Court-approved, informational press release; 4) a neutral, Court-approved Internetwebsite; and 5) a toll-free telephone number. Similar mixed media plans have been approved byother district courts post class certification. The Court finds this plan is sufficient to meet thenotice 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 inthe Settlement Agreement provides for notice through a variety of means, including direct mail toeach class member, notice to the United States Attorney General and each State, a toll freenumber, and a website designed to provide information about the settlement and instructions onsubmitting claims. With a 99.9% effective rate, the Court finds that the notice program constitutedthe “best notice that is practicable under the circumstances,” Fed. R. Civ. P. 23(c)(2)(B), andclearly 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 bestnotice practicable under the circumstances. The Notice Plan was reasonably calculated, underthe circumstances, to apprise Class Members of the pendency of the action, the terms of theSettlement, 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 allperson entitled to receive notice.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 36 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 5Judge 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 publicationnotice, as specified in the Notice Plan (Exhibit 2 to the Affidavit of Lauran R. Schultz), providesthe 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 formatprovided for in its Preliminary Approval Order constitutes the best notice practicable under thecircumstances, 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 ofdue process under the Constitution of the United States, and any other applicablelaw…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 wereadequate 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, theterms and conditions set forth in the Settlement Agreement, and these proceedings to all Personsentitled to such notice, and said Notice fully satisfied the requirements of Fed. R. Civ. P. 23 anddue 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 wereadequate and reasonable and constituted the best notice practicable in the circumstances. Thenotice as given provided valid, due, and sufficient notice of the proposed settlement, the termsand conditions of the Settlement Agreement, and these proceedings to all persons entitled tosuch notice, and the notice satisfied the requirements of Rule 23, Federal Rules of CivilProcedure, 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 toreceive notice; and met all applicable requirements of the Federal Rules of Civil Procedure, theClass 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 thecircumstances and have been sufficient, as to form, content, and manner of dissemination…Suchnotices complied with all requirements of the federal and state constitutions, including the dueprocess clause, and applicable articles of the Louisiana Code of Civil Procedure, and constitutedthe best notice practicable under the circumstances and constituted due and sufficient notice toall 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 theIllinois Settlement Class were adequate and reasonable, and constituted the best noticepracticable under the circumstances. The notice, as given, provided valid, due, and sufficientCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 37 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 6notice of the proposed Settlement, the terms and conditions set forth in the SettlementAgreement, and these proceedings, to all Persons entitled to such notice, and said notice fullysatisfied 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 allreasonable, and has no reservations about the notice to those in this state and those in otherstates 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 thecase 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 anextensive notice campaign to Class members of approximately 10,707 persons, mailed noticereached 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 andthe manner in which it was disseminated…Notice was direct mailed to all Class members whosecurrent whereabouts could be identified by reasonable effort. Notice reached a large majority ofthe Class members. The Court finds that such notice constitutes the best notice practicable…Theforms 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 donewithin the time allowed and the manner best calculated to give notice and apprise all theinterested parties of the litigation. It was done through individual notice, first class mail, throughinternet website and the toll-free telephone call center…The Court does find that these methodswere the best possible methods to advise the class members of the pendency of the action andopportunity to present their objections and finds that these notices do comply with all theprovisions 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 (14thJud. 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’sbeen 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, andthe notice methodology…met all applicable requirements of the Federal Rules of Civil Procedure,the United States Constitution, (including the Due Process clause), the Private SecuritiesLitigation 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 werespecified and adopted by this Court, has been satisfied and that they meet the requirements ofdue process. They are fair, reasonable, and adequate. I think the method of notification certainlyCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 38 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 7meets the requirements of due process…So the Court finds that the notification that was used formaking the potential class members aware of this litigation and the method of filing their claims, ifthey chose to do so, all those are clear and concise and meet the plain language requirementsand 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, attachedhereto as Exhibits 1 and 2, respectively, and finds that the mailing and distribution of the Noticeand the publication of the Publication Notice in the manner and the form set forth in Paragraph 6of this Order…meet the requirements of Rule 23 of the Federal Rules of Civil Procedure, theSecurities Exchange Act of 1934, as emended by Section 21D(a)(7) of the Private SecuritiesLitigation Reform Act of 1995, 15 U.S.C. § 78u-4(a)(7), and due process, and is the best noticepracticable under the circumstances and shall constitute due and sufficient notice to all personsand 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 advisedmembers of the Settlement Class and each Settlement Subclass of all relevant and materialinformation concerning the proposed settlement of this action, their rights under Rule 23 of theFederal Rules of Civil Procedure, and related matters, and afforded the Settlement Class withadequate time and an opportunity to file objections to the Settlement or request exclusion fromthe Settlement Class. The court finds that the Notice Program constituted the best noticepracticable under the circumstances and fully satisfied the requirements of Rule 23 and dueprocess.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 findsand concludes that the Class Notice, as disseminated to members of the Settlement Class inaccordance with provisions of the Preliminary Approval Order, was the best notice practicableunder the circumstances to all members of the Settlement Class. Accordingly, the Class Noticeand Claim Form as disseminated are finally approved as fair, reasonable, and adequate noticeunder the circumstances. The Court finds and concludes that due and adequate notice of thependency of this Action, the Stipulation, and the Final Settlement Hearing has been provided tomembers of the Settlement Class, and the Court further finds and concludes that the noticecampaign described in the Preliminary Approval Order and completed by the parties compliedfully with the requirements of Arkansas Rule of Civil Procedure 23 and the requirements of dueprocess 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 affidavitoutlining 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 thoseclass members whose names and addresses are ascertainable, and that plaintiffs’ proposed formof publication notice, while complex, will prove both manageable and the best means practicableof 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 asfollows…The class members were given the best notice practicable under the circumstances, andthat such notice meets the requirements of the Due Process Clause of the U.S. Constitution, andall applicable statutes and rules of court.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 39 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 8Judge Ivan L.R. Lemelle, In re High Sulfur Content Gasoline Prods. Liability Litig, (November 8, 2006) MDLNo. 1632 (E.D. La.):This Court approved a carefully-worded Notice Plan, which was developed with the assistance ofa nationally-recognized notice expert, Hilsoft Notifications…The Notice Plan for this ClassSettlement 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 topersons displaced by the Hurricanes of 2005; and as this Court has already determined, theNotice 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 parallelcriminal proceedings in another district. The settlement obtained is among the largest cashsettlements ever in a securities class action case and represents an estimated 40% recovery ofpossible provable damages. The notice process appears to have been very successful not onlyin 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 publicationdeveloped by Plaintiff’s notice consultant, Hilsoft Notification[s]…who the Court recognized asexperts in the design of notice plans in class actions. The Notice by first-class mail andpublication was provided in an adequate and sufficient manner; constitutes the best noticepracticable under the circumstances; and satisfies all requirements of Rule 23(e) and dueprocess.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 findsand concludes that the Individual Notice and the Publication Notice, as disseminated to membersof the Settlement Class in accordance with provisions of the Preliminarily Approval Order, wasthe best notice practicable under the circumstances…and the requirements of due process underthe 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 themanner set forth here and in the Settlement Agreement meets the requirements of due processand 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 practicablenotice; and is reasonably calculated, under the circumstances, to apprise members of theSettlement Class of the pendency of the Lawsuit and of their right to object or to excludethemselves 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 inaccordance with the terms of the Third Amended Order constitutes the best notice practicableunder 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 proposedClass, the global nature of the Class, frankly, that again, at least on a preliminary basis, and I willCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 40 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 9be 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 dowhat I hope will be a very thorough and broad-ranging job of reaching as many of theshareholders, whether individual or institutional, as possibly can be done to participate in what Ialso 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 datedJanuary 9, 2006 provided Class Members with the best notice practicable under thecircumstances. The Notice provided due and adequate notice of these proceedings and thematters set forth herein, including the Settlement and Plan of Allocation, to all persons entitled tosuch notice, and the Notice fully satisfied the requirements of Rule 23 of the Federal Rules ofCivil 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 andthe manner in which it was disseminated. The Notice contained the essential elements necessaryto satisfy due process, including the Settlement Class definition, the identities of the Parties andof their counsel, a summary of the terms of the proposed settlement, Class Counsel’s intent toapply for fees, information regarding the manner in which objections could be submitted, andrequests for exclusions could be filed. The Notice properly informed Class members of theformula for the distribution of benefits under the settlement…Notice was direct mailed to all Classmembers whose current whereabouts could be identified by reasonable effort. Notice was alsoeffected by publication in many newspapers and magazines throughout the nation, reaching alarge majority of the Class members multiple times. The Court finds that such notice constitutesthe 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 andcompleted by HEC complied fully with the requirements of due process, the Federal Rules of CivilProcedure and all other applicable laws.Judge Wilford D. Carter, Thibodeaux v. Conoco Phillips Co., (May 26, 2005) No. 2003-481 F (14thJ.D. Ct.La.):Notice given to Class Members…were reasonably calculated under all the circumstances andhave been sufficient, both as to the form and content…Such notices complied with allrequirements of the federal and state constitutions, including the due process clause, andapplicable articles of the Louisiana Code of Civil Procedure, and constituted the best noticepracticable under the circumstances and constituted due process and sufficient notice to allpotential members of the Class as Defined.Judge Michael Canaday, Morrow v. Conoco Inc., (May 25, 2005) No. 2002-3860 G (14thJ.D. Ct. La.):The objections, if any, made to due process, constitutionality, procedures, and compliance withlaw, including, but not limited to, the adequacy of notice and the fairness of the proposedSettlement 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 Notificationsto design and oversee Notice to the End-Payor Class. Hilsoft Notifications has extensiveexperience in class action notice situations relating to prescription drugs and cases in whichunknown class members need to receive notice…After reviewing the individual mailed Notice, theCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 41 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 10publication Notices, the PSAs and the informational release, the Court concludes that thesubstance of the Notice provided to members of the End-Payor Class in this case was adequateto 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 ofthe class. That, to me, is admirable. And I’m also – at the time that this was initially entered, Iwas 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 summarynotice but even the long form of the notice were easily understandable, for somebody who couldread 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 indesigning, 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 modelnotices currently displayed on the Federal Judicial Center’s website as a template for others tofollow…To enhance consumer exposure, Hilsoft studied the demographics and readership ofpublications 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 greaterincidence of depression and heavy usage of the medication.Judge Richard G. Stearns, In re Lupron®Marketing and Sales Practice Litig., (November 24, 2004) MDL1430 (D. Mass.):After review of the proposed Notice Plan designed by Hilsoft Notifications…is hereby found to bethe best practicable notice under the circumstances and, when completed, shall constitute dueand sufficient notice of the Settlement and the Fairness Hearing to all persons and entitiesaffected by and/or entitled to participate in the Settlement, in full compliance with the noticerequirements 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) MDL1430 (D. Mass.):I actually find the [notice] plan as proposed to be comprehensive and extremely sophisticated andvery likely be as comprehensive as any plan of its kind could be in reaching those most directlyaffected.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 havingbeen offered to the members of the Class to participate in the Settlement Hearing, or object to thecertification of the Class and the Agreement, it is hereby determined that all members of theClass, except for Ms. Gwendolyn Thompson, who was the sole person opting out of theSettlement 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 existenceof the class action, of the issues in it, of the approaches taken by each side in it in such a way asto inform meaningfully those whose rights are affected and to thereby enable them to exercisetheir rights intelligently…The success rate in notifying the class is, I believe, at least in myexperience, I share Ms. Kauffman’s experience, it is as great as I have ever seen in practicing orserving in this job…So I don’t believe we could have had any more effective notice.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 42 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 11Judge 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 section6064, and provided the best practicable notice to all members of the Settlement Class under thecircumstances. The Court finds that the notice program provided class members with adequateinstructions and a variety of means to obtain information pertaining to their rights and obligationsunder the settlement so that a full opportunity has been afforded to class members and all otherpersons wishing to be heard…The Court has determined that the Notice given to potentialmembers of the Settlement Class fully and accurately informed potential Members of theSettlement 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 thebest 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 sufficientnotice under the circumstances. Pursuant to a limited scope of review, we need go no further indeciding the Cox courts findings that notice met due process are entitled to deference.1BJudge 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 Noticesubmitted with the Memorandum for Preliminary Approval and finds that the forms and manner ofnotice proposed by Plaintiffs and approved herein meet the requirements of due process andFed.R.Civ.P. 23(c) and (e), are the best notice practicable under the circumstances, constitutesufficient notice to all persons entitled to notice, and satisfy the Constitutional requirements ofnotice.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 havingbeen offered to the member of the Class to participate in the Settlement Hearing, or object to thecertification 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, asdescribed in the Motion, adequately protect the interests of the holders of Asbestos PI TrustClaims in a manner consistent with the principles of due process, and satisfy the applicablerequirements 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 Classmembers of the pendency of the litigation, the terms of the Phase 2 Settlement, and Classmembers’ rights and options…Not a single Class member—out of an estimated 30,000—objectedto the terms of the Phase 2 Settlement Agreement, notwithstanding a comprehensive nationalNotice campaign, via direct mail and publication Notice…The notice was reasonable and the bestnotice practicable under the circumstances, was due, adequate, and sufficient notice to all Classmembers, 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.):Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 43 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 12Notice of the settlement has been given in an adequate and sufficient manner. The noticeprovided by mailing the settlement notice to certain class members and publishing notice in themanner described in the settlement was the best practicable notice, complying in all respects withthe 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 ofclass members objecting or requesting exclusion from the settlement is a clear sign of strongsupport for the settlement…The notice provides, in language easily understandable to a layperson, the essential terms of the settlement, including the claims asserted…who would becovered by the settlement…[T]he notice campaign that defendant agreed to undertake wasextensive…I am satisfied, having reviewed the contents of the notice package, and the extensivesteps taken to disseminate notice of the settlement, that the class notice complies with therequirements of Rule 23 (c)(2) and 23(e). In summary, I have reviewed all of the objections, andnone persuade me to conclude that the proposed settlement is unfair, inadequate orunreasonable.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, whichcomports 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 lawrequirements…The content of the notice was more than adequate to enable class members tomake 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 andthe manner in which it was disseminated. The notice contained the essential elements necessaryto 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 bythe terms of the settlement meets due process requirements. The Notice Plan used a variety ofmethods to reach potential class members. For example, short form notices for print media wereplaced…throughout the United States and in major national consumer publications which includethe 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 SettlementAgreement are written in plain English and are readily understandable by Class Members. Insum, the Court finds that the proposed notice texts and methodology are reasonable, that theyconstitute 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), theRules 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):Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 44 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 13In order to maximize the efficiency of the notice, a professional concern, Hilsoft Notifications, wasretained. This Court concludes that the notice campaign was the best practicable, reasonablycalculated, under all the circumstances, to apprise interested parties of the settlement and affordthem an opportunity to present their objections…The notice campaign was highly successful andeffective, 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 withoutreliance on an unreasonably burdensome direct notification process…The form of the notice isreasonably calculated to apprise class members of their rights. The notice program is specificallydesigned 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 ofthe time periods that you were doing as to each publication and which media you were doing overwhat 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 beensubmitted on that subject and basically I’m satisfied. I think it’s amazing if you’re really getting 80percent coverage. That’s very reassuring. And the papers that you submitted responded to acouple 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 theirrequest that the Court approve the plan for dissemination of class action notice and proposedforms of notice, and amend the class definition. The Court finds that the forms of notice to Classmembers attached hereto as Exhibits A and B fairly and adequately inform the Class members oftheir rights concerning this litigation. The Court further finds that the methods for dissemination ofnotice are the fairest and best practicable under the circumstances, and comport with dueprocess requirements.LEGAL NOTICE CASESHilsoft Notifications has served as notice expert for planning, implementation and/or analysis in the followingpartial listing of cases:Andrews v. MCI (900 Number Litig.) S.D. Ga., CV 191-175Harper v. MCI (900 Number Litig.) S.D. Ga., CV 192-134In re Bausch & Lomb Contact Lens Litig. N.D. Ala., 94-C-1144-WWIn re Ford Motor Co. Vehicle Paint Litig. E.D. La., MDL 1063Castano v. Am. Tobacco E.D. La., CV 94-1044Cox v. Shell Oil (Polybutylene Pipe Litig.) Tenn. Ch., 18,844In re Amino Acid Lysine Antitrust Litig. N.D. Ill., MDL 1083Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 45 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 14In re Dow Corning Corp. (Breast Implant Bankruptcy) E.D. Mich., 95-20512-11-AJSKunhel v. CNA Ins. Companies N.J. Super. Ct., ATL-C-0184-94In re Factor Concentrate Blood Prods. Litig. (HemophiliacHIV)N.D. Ill., MDL 986In re Ford Ignition Switch Prods. Liability Litig. D. N.J., 96-CV-3125Jordan v. A.A. Friedman (Non-Filing Ins. Litig.) M.D. Ga., 95-52-COLKalhammer v. First USA (Credit Card Litig.) Cal. Cir. Ct., C96-45632010-CALNavarro-Rice v. First USA (Credit Card Litig.) Ore. Cir. Ct., 9709-06901Spitzfaden v. Dow Corning (Breast Implant Litig.) La. D. Ct., 92-2589Robinson v. Marine Midland (Finance Charge Litig.) N.D. Ill., 95 C 5635McCurdy v. Norwest Fin. Alabama Ala. Cir. Ct., CV-95-2601Johnson v. Norwest Fin. Alabama Ala. Cir. Ct., CV-93-PT-962-SIn re Residential Doors Antitrust Litig. E.D. Pa., MDL 1039Barnes v. Am. Tobacco Co. Inc. E.D. Pa., 96-5903Small v. Lorillard Tobacco Co. Inc. N.Y. Super. Ct., 110949/96Naef v. Masonite Corp (Hardboard Siding Litig.) Ala. Cir. Ct., CV-94-4033In re Synthroid Mktg. Litig. N.D. Ill., MDL 1182Chisolm v. Transouth Fin. 4thU.S. Cir. Ct., 97-1970Raysick v. Quaker State Slick 50 Inc. D. Tex., 96-12610Castillo v. Mike Tyson (Tyson v. Holyfield Bout) N.Y. Super. Ct., 114044/97Avery v. State Farm Auto. Ins. (Non-OEM Auto Parts Litig.) Ill. Cir. Ct., 97-L-114Walls v. The Am. Tobacco Co. Inc. N.D. Okla., 97-CV-218-HTempest v. Rainforest Café (Securities Litig.) D. Minn., 98-CV-608Stewart v. Avon Prods. (Securities Litig.) E.D. Pa., 98-CV-4135Goldenberg v. Marriott PLC Corp (Securities Litig.) D. Md., PJM 95-3461Delay v. Hurd Millwork (Building Products Litig.) Wash. Super. Ct., 97-2-07371-0Gutterman v. Am. Airlines (Frequent Flyer Litig.) Ill. Cir. Ct., 95CH982Hoeffner v. The Estate of Alan Kenneth Vieira (Un-scatteredCremated Remains Litig.)Cal. Super. Ct., 97-AS 02993In re Graphite Electrodes Antitrust Litig. E.D. Pa., MDL 1244In re Silicone Gel Breast Implant Prods. Liability Litig.,Altrichter v. INAMEDN.D. Ala., MDL 926St. John v. Am. Home Prods. Corp. (Fen/Phen Litig.) Wash. Super. Ct., 97-2-06368Crane v. Hackett Assocs. (Securities Litig.) E.D. Pa., 98-5504In re Holocaust Victims Assets Litig. (Swiss Banks Litig.) E.D. N.Y., CV-96-4849McCall v. John Hancock (Settlement Death Benefits) N.M. Cir. Ct., CV-2000-2818Williams v. Weyerhaeuser Co. (Hardboard Siding Litig.) Cal. Super. Ct., CV-995787Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 46 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 15Kapustin v. YBM Magnex Int’l Inc. (Securities Litig.) E.D. Pa., 98-CV-6599Leff v. YBM Magnex Int’l Inc. (Securities Litig.) E.D. Pa., 95-CV-89In re PRK/LASIK Consumer Litig. Cal. Super. Ct., CV-772894Hill v. Galaxy Cablevision N.D. Miss., 1:98CV51-D-DScott v. Am. Tobacco Co. Inc. La. D. Ct., 96-8461Jacobs v. Winthrop Fin. Assocs. (Securities Litig.) D. Mass., 99-CV-11363Int’l Comm’n on Holocaust Era Ins. Claims – WorldwideOutreach ProgramFormer Secretary of State LawrenceEagleburger CommissionBownes v. First USA Bank (Credit Card Litig.) Ala. Cir. Ct., CV-99-2479-PRWhetman v. IKON (ERISA Litig.) E.D. Pa., 00-87Mangone v. First USA Bank (Credit Card Litig.) Ill. Cir. Ct., 99AR672aIn re Babcock and Wilcox Co. (Asbestos Related Bankruptcy) E.D. La., 00-10992Barbanti v. W.R. Grace and Co. (Zonolite / Asbestos Litig.) Wash. Super. Ct., 00201756-6Brown v. Am. Tobacco Cal. Super. Ct., J.C.C.P. 4042, 711400Wilson v. Servier Canada Inc. (Canadian Fen/Phen Litig.) Ont. Super. Ct., 98-CV-158832In re Texaco Inc. (Bankruptcy)S.D. N.Y. 87 B 20142, 87 B 20143, 87 B20144.Olinde v. Texaco (Bankruptcy, Oil Lease Litig.) M.D. La., 96-390Gustafson v. Bridgestone/Firestone, Inc. (Recall Related Litig.) S.D. Ill., 00-612-DRHIn re Bridgestone/Firestone Tires Prods. Liability Litig. S.D. Ind., MDL 1373Gaynoe v. First Union Corp. (Credit Card Litig.) N.C. Super. Ct., 97-CVS-16536Carson v. Daimler Chrysler Corp. (Fuel O-Rings Litig.) W.D. Tenn., 99-2896 TU AProvidian Credit Card Cases Cal. Super. Ct., J.C.C.P. 4085Fields v. Great Spring Waters of Am., Inc. (Bottled Water Litig.) Cal. Super. Ct., 302774Sanders v. Great Spring Waters of Am., Inc. (Bottled WaterLitig.)Cal. Super. Ct., 303549Sims v. Allstate Ins. Co. (Diminished Auto Value Litig.) Ill. Cir. Ct., 99-L-393APeterson v. State Farm Mutual Auto. Ins. Co. (Diminished AutoValue Litig.)Ill. Cir. Ct., 99-L-394AMicrosoft I-V Cases (Antitrust Litig. Mirroring Justice Dept.) Cal. Super. Ct., J.C.C.P. 4106Westman v. Rogers Family Funeral Home, Inc. (RemainsHandling Litig.)Cal. Super. Ct., C-98-03165Rogers v. Clark Equipment Co. Ill. Cir. Ct., 97-L-20Garrett v. Hurley State Bank (Credit Card Litig.) Miss. Cir. Ct., 99-0337Ragoonanan v. Imperial Tobacco Ltd. (Firesafe CigaretteLitig.)Ont. Super. Ct., 00-CV-183165 CPDietschi v. Am. Home Prods. Corp. (PPA Litig.) W.D. Wash., C01-0306LDimitrios v. CVS, Inc. (PA Act 6 Litig.) Pa. C.P., 99-6209Jones v. Hewlett-Packard Co. (Inkjet Cartridge Litig.) Cal. Super. Ct., 302887In re Tobacco Cases II (California Tobacco Litig.) Cal. Super. Ct., J.C.C.P. 4042Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 47 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 16Scott v. Blockbuster, Inc (Extended Viewing Fees Litig.) 136thTex. Jud. Dist., D 162-535Anesthesia Care Assocs. v. Blue Cross of Cal. Cal. Super. Ct., 986677Ting v. AT&T (Mandatory Arbitration Litig.) N.D. Cal., C-01-2969-BZIn re W.R. Grace & Co. (Asbestos Related Bankruptcy) Bankr. D. Del., 01-01139-JJFTalalai v. Cooper Tire & Rubber Co. (Tire Layer AdhesionLitig.)N.J. Super. Ct.,, MID-L-8839-00 MTKent v. Daimler Chrysler Corp. (Jeep Grand Cherokee Park-to-Reverse Litig.)N.D. Cal., C01-3293-JCSInt’l Org. of Migration – German Forced Labour CompensationProgrammeGeneva, SwitzerlandMadsen v. Prudential Federal Savings & Loan (Homeowner’sLoan Account Litig.)3rdJud. Dist. Ct. Utah, C79-8404Bryant v. Wyndham Int’l., Inc. (Energy Surcharge Litig.) Cal. Super. Ct., GIC 765441, GIC 777547In re USG Corp. (Asbestos Related Bankruptcy) Bankr. D. Del., 01-02094-RJNThompson v. Metropolitan Life Ins. Co. (Race Related SalesPractices Litig.)S.D. N.Y., 00-CIV-5071 HBErvin v. Movie Gallery Inc. (Extended Viewing Fees) Tenn. Ch., CV-13007Peters v. First Union Direct Bank (Credit Card Litig.) M.D. Fla., 8:01-CV-958-T-26 TBMNational Socialist Era Compensation Fund Republic of AustriaIn re Baycol Litig. D. Minn., MDL 1431Claims Conference–Jewish Slave Labour Outreach Program German Government InitiativeWells v. Chevy Chase Bank (Credit Card Litig.) Md. Cir. Ct., C-99-000202Walker v. Rite Aid of PA, Inc. (PA Act 6 Litig.) C.P. Pa., 99-6210Myers v. Rite Aid of PA, Inc. (PA Act 6 Litig.) C.P. Pa., 01-2771In re PA Diet Drugs Litig. C.P. Pa., 9709-3162Harp v. Qwest Communications (Mandatory Arbitration Litig.) Ore. Circ. Ct., 0110-10986Tuck v. Whirlpool Corp. & Sears, Roebuck & Co. (MicrowaveRecall Litig.)Ind. Cir. Ct., 49C01-0111-CP-002701Allison v. AT&T Corp. (Mandatory Arbitration Litig.) 1stJud. D.C. N.M., D-0101-CV-20020041Kline v. The Progressive Corp. Ill. Cir. Ct., 01-L-6Baker v. Jewel Food Stores, Inc. & Dominick’s Finer Foods,Inc. (Milk Price Fixing)Ill. Cir. Ct., 00-L-9664In re Columbia/HCA Healthcare Corp. (Billing Practices Litig.) M.D. Tenn., MDL 1227Foultz v. Erie Ins. Exchange (Auto Parts Litig.) C.P. Pa., 000203053Soders v. General Motors Corp. (Marketing InitiativeLitigation)C.P. Pa., CI-00-04255Nature Guard Cement Roofing Shingles Cases Cal. Super. Ct., J.C.C.P. 4215Curtis v. Hollywood Entm’t Corp. (Additional Rental Charges) Wash. Super. Ct., 01-2-36007-8 SEADefrates v. Hollywood Entm’t Corp. Ill. Cir. Ct., 02L707Pease v. Jasper Wyman & Son, Merrill Blueberry Farms Inc.,Allen’s Blueberry Freezer Inc. & Cherryfield Foods Inc.Me. Super. Ct., CV-00-015Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 48 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 17West v. G&H Seed Co. (Crawfish Farmers Litig.) 27thJud. D. Ct. La., 99-C-4984-ALinn v. Roto-Rooter Inc. (Miscellaneous Supplies Charge) C.P. Ohio, CV-467403McManus v. Fleetwood Enter., Inc. (RV Brake Litigation) D. Ct. Tex., SA-99-CA-464-FBBaiz v. Mountain View Cemetery (Burial Practices) Cal. Super. Ct., 809869-2Stetser v. TAP Pharm. Prods, Inc. & Abbott Laboratories(Lupron Price Litigation)N.C. Super. Ct., 01-CVS-5268Richison v. Am. Cemwood Corp. (Roofing DurabilitySettlement)Cal. Super. Ct., 005532Cotten v. Ferman Mgmt. Servs. Corp. 13thJud. Cir. Fla., 02-08115In re Pittsburgh Corning Corp. (Asbestos Related Bankruptcy) Bankr. W.D. Pa., 00-22876-JKFMostajo v. Coast Nat’l Ins. Co. Cal. Super. Ct., 00 CC 15165Friedman v. Microsoft Corp. (Antitrust Litigation) Ariz. Super. Ct., CV 2000-000722Multinational Outreach - East Germany Property Claims Claims ConferenceDavis v. Am. Home Prods. Corp. (Norplant ContraceptiveLitigation)D. La., 94-11684Walker v. Tap Pharmaceutical Prods., Inc. (Lupron PriceLitigation)N.J. Super. Ct., CV CPM-L-682-01Munsey v. Cox Communications (Late Fee Litigation) D. La., Sec. 9, 97 19571Gordon v. Microsoft Corp. (Antitrust Litigation) 4thJud. D. Ct. Minn., 00-5994Clark v. Tap Pharmaceutical Prods., Inc. 5thDist. App. Ct. Ill., 5-02-0316Fisher v. Virginia Electric & Power Co. E.D. Va., 3:02-CV-431Mantzouris v. Scarritt Motor Group, Inc. M.D. Fla., 8:03-CV-0015-T-30-MSSJohnson v. Ethicon, Inc. (Product Liability Litigation)W. Va. Cir. Ct., 01-C-1530, 1531, 1533, 01-C-2491 to 2500Schlink v. Edina Realty Title 4thJud. D. Ct. Minn., 02-018380Tawney v. Columbia Natural Res. (Oil & Gas Lease Litigation) W. Va. Cir. Ct., 03-C-10EWhite v. Washington Mutual, Inc. (Pre-Payment PenaltyLitigation)4thJud. D. Ct. Minn., CT 03-1282Acacia Media Techs. Corp. v. Cybernet Ventures Inc, (PatentInfringement Litigation)C.D. Cal., SACV03-1803 GLT (Anx)Bardessono v. Ford Motor Co. (15 Passenger Vans) Wash. Super. Ct., 32494Gardner v. Stimson Lumber Co. (Forestex Siding Litigation) Wash. Super. Ct., 00-2-17633-3SEAPoor v. Sprint Corp. (Fiber Optic Cable Litigation) Ill. Cir. Ct., 99-L-421Thibodeau v. Comcast Corp. E.D. Pa., 04-CV-1777Cazenave v. Sheriff Charles C. Foti (Strip Search Litigation) E.D. La., 00-CV-1246National Assoc. of Police Orgs., Inc. v. Second Chance BodyArmor, Inc. (Bullet Proof Vest Litigation)Mich. Cir. Ct., 04-8018-NPNichols v. SmithKline Beecham Corp. (Paxil) E.D. Pa., 00-6222Yacout v. Federal Pacific Electric Co. (Circuit Breaker) N.J. Super. Ct., MID-L-2904-97Lewis v. Bayer AG (Baycol) 1stJud. Dist. Ct. Pa., 002353In re Educ. Testing Serv. PLT 7-12 Test Scoring Litig. E.D. La., MDL-1643Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 49 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 18Stefanyshyn v. Consol. Indus. Corp. (Heat Exchanger) Ind. Super. Ct., 79 D 01-9712-CT-59Barnett v. Wal-Mart Stores, Inc. Wash. Super. Ct., 01-2-24553-8 SEAIn re Serzone Prods. Liability Litig. S.D. W. Va., MDL 1477Ford Explorer Cases Cal. Super. Ct., J.C.C.P. 4226 & 4270In re Solutia Inc. (Bankruptcy) S.D. N.Y., 03-17949-PCBIn re Lupron Marketing & Sales Practices Litig. D. Mass., MDL 1430Morris v. Liberty Mutual Fire Ins. Co. D. Okla., CJ-03-714Bowling, et al. v. Pfizer Inc. (Bjork-Shiley Convexo-ConcaveHeart Valve)S.D. Ohio, C-1-91-256Thibodeaux v. Conoco Philips Co. D. La., 2003-481Morrow v. Conoco Inc. D. La., 2002-3860Tobacco Farmer Transition Program U.S. Dept. of Agric.Perry v. Mastercard Int’l Inc. Ariz. Super. Ct., CV2003-007154Brown v. Credit Suisse First Boston Corp. C.D. La., 02-13738In re Unum Provident Corp. D. Tenn., 1:03-CV-1000In re Ephedra Prods. Liability Litig. D. N.Y., MDL-1598Chesnut v. Progressive Casualty Ins. Co. Ohio C.P., 460971Froeber v. Liberty Mutual Fire Ins. Co. Ore. Cir. Ct., 00C15234Luikart v. Wyeth Am. Home Prods. (Hormone Replacement) W. Va. Cir. Ct., 04-C-127Salkin v. MasterCard Int’l Inc. (Pennsylvania) Pa. C.P., 2648Rolnik v. AT&T Wireless Servs., Inc. N.J. Super. Ct., L-180-04Singleton v. Hornell Brewing Co. Inc. (Arizona Ice Tea) Cal. Super. Ct., BC 288 754Becherer v. Qwest Commc’ns Int’l, Inc. Ill. Cir. Ct., 02-L140Clearview Imaging v. Progressive Consumers Ins. Co. Fla. Cir. Ct., 03-4174Mehl v. Canadian Pacific Railway, Ltd D. N.D., A4-02-009Murray v. IndyMac Bank. F.S.B N.D. Ill., 04 C 7669Gray v. New Hampshire Indemnity Co., Inc. Ark. Cir. Ct., CV-2002-952-2-3George v. Ford Motor Co. M.D. Tenn., 3:04-0783Allen v. Monsanto Co. W. Va. Cir. Ct., 041465Carter v. Monsanto Co. W. Va. Cir. Ct., 00-C-300Carnegie v. Household Int’l, Inc. N. D. Ill., 98-C-2178Daniel v. AON Corp. Ill. Cir. Ct., 99 CH 11893In re Royal Ahold Securities and “ERISA” Litig. D. Md., MDL 1539In re Pharmaceutical Industry Average Wholesale Price Litig. D. Mass., MDL 1456Meckstroth v. Toyota Motor Sales, U.S.A., Inc. 24thJud. D. Ct. La., 583-318Walton v. Ford Motor Co. Cal. Super. Ct., SCVSS 126737Hill v. State Farm Mutual Auto Ins. Co. Cal. Super. Ct., BC 194491Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 50 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 19First State Orthopaedics et al. v. Concentra, Inc., et al. E.D. Pa. 2:05-CV-04951-ABSauro v. Murphy Oil USA, Inc. E.D. La., 05-4427In re High Sulfur Content Gasoline Prods. Liability Litig. E.D. La., MDL 1632Homeless Shelter Compensation Program City of New YorkRosenberg v. Academy Collection Service, Inc. E.D. Pa., 04-CV-5585Chapman v. Butler & Hosch, P.A. 2ndJud. Cir. Fla., 2000-2879In re Vivendi Universal, S.A. Securities Litig. S.D. N.Y., 02-CIV-5571 RJHDesportes v. American General Assurance Co. Ga. Super. Ct., SU-04-CV-3637In re: Propulsid Products Liability Litig. E.D. La., MDL 1355Baxter v. The Attorney General of Canada (Residential SchoolAttendees)Ont. Super. Ct., 00-CV-192059 CPAMcNall v. Mastercard Int’l, Inc. (Currency Conversion Fees) 13thTenn. Jud. Dist. Ct.Lee v. Allstate Ill. Cir. Ct., 03 LK 127Turner v. Murphy Oil USA, Inc. E.D. La., 2:05-CV-04206-EEF-JCWCarter v. North Central Life Ins. Co. Ga. Super. Ct., SU-2006-CV-3764-6Harper v. Equifax E.D. Pa., 2:04-CV-03584-TONBeasley v. Hartford Insurance Co. of the Midwest Ark. Cir. Ct., CV-2005-58-1Springer v. Biomedical Tissue Services, LTD (Human TissueLitig.)Ind. Cir. Ct., 1:06-CV-00332-SEB-VSSSpence v. Microsoft Corp. (Antitrust Litig.) Wis. Cir. Ct., 00-CV-003042Pennington v. The Coca Cola Co. (Diet Coke) Mo. Cir. Ct., 04-CV-208580Sunderman v. Regeneration Technologies, Inc. (Human TissueLitig.)S.D. Ohio, 1:06-CV-075-MHWSplater v. Thermal Ease Hydronic Systems, Inc. Wash. Super. Ct., 03-2-33553-3-SEAPeyroux v. The United States of America (New Orleans LeveeBreech)E.D. La., 06-2317Chambers v. DaimlerChrysler Corp. (Neon Head Gaskets) N.C. Super. Ct., 01:CVS-1555Ciabattari v. Toyota Motor Sales, U.S.A., Inc. (Sienna Run FlatTires)N.D. Cal., C-05-04289-BZIn re Bridgestone Securities Litig. M.D. Tenn., 3:01-CV-0017In re Mutual Funds Investment Litig. (Market Timing) D. Md., MDL 1586Accounting Outsourcing v. Verizon Wireless M.D. La., 03-CV-161Hensley v. Computer Sciences Corp. Ark. Cir. Ct., CV-2005-59-3Peek v. Microsoft Corporation Ark. Cir. Ct., CV-2006-2612Reynolds v. The Hartford Financial Services Group, Inc. D. Ore., CV-01-1529 BRSchwab v. Philip Morris USA, Inc. E.D. N.Y., CV-04-1945Zarebski v. Hartford Insurance Co. of the Midwest Ark. Cir. Ct., CV-2006-409-3In re Parmalat Securities Litig. S.D. N.Y., MDL 1653 (LAK)Beasley v. The Reliable Life Insurance Co. Ark. Cir. Ct., CV-2005-58-1Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 51 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 20Sweeten v. American Empire Insurance Company Ark. Cir. Ct., 2007-154-3Govt. Employees Hospital Assoc. v. Serono Int., S.A. D. Mass., 06-CA-10613-PBSGunderson v. Focus Healthcare Management, Inc. 14thJud. D. Ct. La., 2004-2417-DGunderson v. F.A. Richard & Associates, Inc., et al. 14thJud. D. Ct. La., 2004-2417-DPerez v. Manor Care of Carrollwood 13thJud. Cir. Fla., 06-00574-EPope v. Manor Care of Carrollwood 13thJud. Cir. Fla., 06-01451-BWest v. Carfax, Inc. Ohio C.P., 04-CV-1898 (ADL)Hunsucker v. American Standard Ins. Co. of Wisconsin Ark. Cir. Ct., CV-2007-155-3In re Conagra Peanut Butter Products Liability Litig. N.D. Ga., MDL 1845 (TWT)The People of the State of CA v. Universal Life Resources (CalDOI v. CIGNA)Cal. Super. Ct., GIC838913Burgess v. Farmers Insurance Co., Inc. D. Okla., CJ-2001-292Grays Harbor v. Carrier Corporation W.D. Wash., 05-05437-RBLPerrine v. E.I. Du Pont De Nemours & Co. W. Va. Cir. Ct., 04-C-296-2In re Alstom SA Securities Litig. S.D. N.Y., 03-CV-6595 VMBrookshire Bros. v. Chiquita (Antitrust) S.D. Fla., 05-CIV-21962Hoorman v. SmithKline Beecham Ill. Cir. Ct., 04-L-715Santos v. Government of Guam (Earned Income Tax Credit) D. Guam, 04-00049Johnson v. Progressive Ark. Cir. Ct., CV-2003-513Bond v. American Family Insurance Co. D. Ariz., CV06-01249-PXH-DGCIn re SCOR Holding (Switzerland) AG Litigation (Securities) S.D. N.Y., 04 Civ. 7897Shoukry v. Fisher-Price, Inc. (Toy Safety) S.D. N.Y., 07-CV-7182In re: Guidant Corp. Plantable Defibrillators Prod’s Liab. Litig. D. Minn., MDL 05-1708 (DWF/AJB)Clark v. Pfizer, Inc (Neurontin) C.P. Pa., 9709-3162Angel v. U.S. Tire Recovery (tire fire) W. Va. Cir. Ct., 06-C-855In re TJX Companies Retail Security Breach Litig. D. Mass., MDL 1838Webb v. Liberty Mutual Insurance Co. Ark. Cir. Ct., CV-2007-418-3Shaffer v. Continental Casualty Co. (long term care ins.) C.D. Cal., SACV06-2235-PSGPalace v. DaimlerChrysler (defective Neon head gaskets) Ill. Cir. Ct., 01-CH-13168Beringer v. Certegy Check Services, Inc. (stolen financial data) M.D. Fla., 8:07-cv-1657-T-23TGWLockwood v. Certegy Check Services, Inc. M.D. Fla., 8:07-cv-1434-T-23TGWSherrill v. Progressive Northwestern Ins. Co. 18thD. Ct. Mont., DV-03-220Gunderson v. F.A. Richard & Assocs., Inc. (AIG) 14thJud. D. Ct. La., 2004-2417-DJones v. Dominion Resources Services, Inc. S.D. W. Va., 2:06-cv-00671Gunderson v. F.A. Richard & Assocs., Inc. (Wal-Mart) 14thJud. D. Ct. La., 2004-2417-DIn re Trans Union Corp. Privacy Litig. N.D. Ill., MDL 1350Gudo v. The Administrator of the Tulane Ed. Fund La. D. Ct., 2007-C-1959Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 52 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 21Guidry v. American Public Life Insurance Co. 14thJud. D. Ct. La., 2008-3465McGee v. Continental Tire North America D. N.J., 2:06-CV-06234 (GEB)Sims v. Rosedale Cemetery Co. W. Va. Cir. Ct., 03-C-506Gunderson v. F.A. Richard & Assocs., Inc. (Amerisafe) 14thJud. D. Ct. La., 2004-002417In Re Katrina Canal Breaches Consolidated Litig. E.D. La., 05-4182In re Department of Veterans Affairs (VA) Data Theft Litigation D. D.C., MDL 1796Dolen v. ABN AMRO Bank N.V. (callable CD’s) Ill. Cir. Ct., 01-L-454 and 01-L-493Pavlov v. CNA (long term care insurance) N.D. Ohio, 5:07cv2580Steele v. Pergo( flooring products) D. Ore., 07-CV-01493-BROpelousas Trust Authority v. Summit Consulting 27thJud. D. Ct. La., 07-C-3737-BLittle v. Kia Motors America, Inc. (braking systems) N.J. Super. Ct., UNN-L-0800-01Boone v. City of Philadelphia (prisoner strip search) E.D. Pa., 05-CV-1851In Re Countrywide Customer Data Breach Litig. W. D. Ky., 3:08-md-01998-TBR, MDL 1998Miller v. Basic Research (weight-loss supplement) D. Utah, 2:07-cv-00871-TSGunderson v. F.A. Richard & Assocs., Inc. (Cambridge) 14thJud. D. Ct. La., 2004-002417Weiner v. Snapple Beverage Corporation S.D. N.Y., No. 07-CV-08742Holk v. Snapple Beverage Corporation D. N.J., No 3:07-CV-03018-MJC-JJHCoyle v. Hornell Brewing Co. (Arizona Iced Tea) D. N.J., No. 08-CV-2797-JBS-JSIn Re: Heartland Data Security Breach Litigation S.D. Tex., No. 4:09-MD-2046, MDL 2046Satterfield v. Simon & Schuster, Inc. (text messaging) N.D. Cal., No. 06-CV-2893 CWSchulte v. Fifth Third Bank (overdraft fees) N.D. Ill., No. 09-CV-06655Trombley v. National City Bank (overdraft fees) D. D.C., No. 1:10-CV-00232Vereen v. Lowe’s Home Centers (defective drywall) Ga. Super. Ct., SU10-CV-2267BMathena v. Webster Bank, N.A. (overdraft fees) D. Conn,.No. 3:10-cv-01448Delandro v. County of Allegheny (prisoner strip search) W.D. Pa., No. 2:06-cv-00927Gunderson v. F.A. Richard & Assocs., Inc. (First Health) 14thJud. D. Ct. La., 2004-002417Williams v. Hammerman & Gainer, Inc. (Hammerman) 27thJud. D. Ct. La., No. 11-C-3187-BWilliams v. Hammerman & Gainer, Inc. (Risk Management) 27thJud. D. Ct. La., No. 11-C-3187-BWilliams v. Hammerman & Gainer, Inc. (SIF Consultants) 27thJud. D. Ct. La., No. 11-C-3187-BGwiazdowski v. County of Chester (prisoner strip search) E.D. Pa., No. 2:08cv4463Williams v. S.I.F. Consultants (CorVel Corporation) 27thJud. D. Ct. La., No. 09-C-5244-CIn Re: Checking Account Overdraft Litigation (IBERIABANK) S.D. Fla., MDL No. 2036LaCour v. Whitney Bank (overdraft fees) M.D. Fla., 8:11cv1896Lawson. v. BancorpSouth (overdraft fees) W.D. Ark., 1:12cv1016In Re: Checking Account Overdraft Litigation(Bank of Oklahoma)S.D. Fla., MDL No. 2036Hilsoft-cv-115Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 53 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Exhibit 2 to Declaration of Cameron Azari:Economic & Property Damages Notice PlanCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 54 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • ©2012 Hilsoft NotificationsDeepwater Horizon Oil Spill LitigationEconomic and Property DamagesSettlement Notice PlanCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 55 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications 2Table of ContentsPage1. Introduction 42. Overview/Summary 63. Notice Schedule Flow Chart 124. Target Audience 135. Individual Notice 156. Media Selection 187. Plan Delivery Summary 208. Net Reach 219. Average Frequency of Exposure 2310. Geographic Coverage 2411. Nationwide Publication Plan 2512. Nationwide Publication Details 2613. Nationwide Publication Coverage 2914. Nationwide Publication Circulation 3015. Publication Secondary Reader Data 3116. Nationwide Publication Audience Data 3217. Nationwide Publication Gross Impressions 3318. Trade, Business and Specialty Publications 3419. Local Newspapers 36Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 56 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications320. African-American and Vietnamese and Spanish Language Publications 3821. Local Television 4022. TV Dayparts/Programming 4123. TV Rating Points (GRPs) 4224. TV Gross Impressions 4325. Local Radio Programming 4426. Internet Banner Notices 4527. Placing Notices to Be Highly Visible 4628. Informational Release 4729. TV Public Service Announcements 4830. Case Website 4931. Sponsored Search Listings 5032. Notice Design Strategy 5133. Draft Forms of Notice 53Attachment 1 - Drafts of NoticeAttachment 2 – Parade, USA Weekend and American Profile Newspaper ListAttachment 3 – Local NewspapersCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 57 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications41. IntroductionThe “Notice Plan” (or “Plan”) that follows details the dissemination effort that willbe undertaken to provide comprehensive notice to Class Members in connectionwith the proposed Economic and Property Damages Class Action Settlement in Inre: Oil Spill by the Oil Rig "Deepwater Horizon" in the Gulf of Mexico, on April20, 2010, MDL No. 2179. The Plan utilizes extensive and appropriate prior classaction notice experience.Two separate class action settlements within the MDL No. 2179 litigation—anEconomic and Property Damages Settlement and a Medical Benefits Settlement—have been proposed related to the Deepwater Horizon Incident. Each settlementcontemplates contemporaneous notice.To prevent confusion over the two class action settlements, the proposed Economicand Property Damages Notice Plan effort highlights that the Court is consideringtwo separate settlements. Print publication notice consists of a single advertisingunit that includes one summary notice that addresses the Economic and PropertyDamages Settlement, and a separate summary notice that addresses the MedicalBenefits Settlement. Broadcast and Internet banner efforts provide the messagethat there is one settlement addressing economic and property damages claims, anda separate settlement addressing medical claims. Finally, one individual notice forthe Economic and Property Damages Settlement will be mailed to all known, likelyClass Members of the Economic and Property Damages Settlement Class, and aseparate individual notice for the Medical Benefits Settlement will be mailed toknown individuals who are likely Class Members of the Medical Benefits Class.To further mitigate potential confusion, the Economic and Property DamagesSettlement and the Medical Benefits Settlement notices will include a commonwebsite address and toll-free number. The content of the website and toll-freenumbers will make clear to visitors/callers that two separate settlements have beenreached, and provide appropriate information about each respective settlement.1Hilsoft Notifications has designed and will implement this Notice Plan if and whenthe Economic and Property Damages Settlement receives Preliminary Approval bythe Court. At the appropriate time Hilsoft may also develop and implementsubsequent 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, theNotice content will be adjusted accordingly.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 58 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications5including a reminder notice effort in advance of the claim deadline.Hilsoft Notifications’ principals have been recognized as class action noticeexperts by judges, and have specific experience designing and implementing large-scale class action notice plans. Principals Cameron Azari, Esq., Director of LegalNoticing, and Lauran Schultz, Executive Director, have designed the Plan andNotices, and will oversee implementation to successful completion.With experience in more than 200 cases, notices prepared by Hilsoft Notificationshave appeared in 53 languages with distribution in almost every country, territoryand dependency in the world. Judges, including in published decisions, haverecognized and approved notice plans developed by Hilsoft Notifications, whichhave 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 theprinciples in the Federal Judicial Center’s (“FJC”) illustrative model notices thatwere written and designed to embody the satisfaction of the plain languagerequirements of Federal Rule of Civil Procedure 23(c)(2). To assist judges andattorneys, in federal as well as state courts, the FJC has posted the notices atwww.fjc.gov.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 59 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications62. Overview/Summary• Objective. To notify the greatest practicable number of Economic and PropertyDamages Settlement Class Members (hereinafter “Settlement Class Members”or “Class Members”) and provide them with opportunities to be exposed to theNotice, to see, review, understand, and be reminded about it, and to respondappropriately if they choose.• Imperatives. Key factors guide the dissemination methods needed to achieve areasonable and effective notice effort:1. The proposed Economic and Property Damages Settlement has specificgeographic boundaries. The majority of Class Members are locatedwithin a limited geographic area and the primary thrust of the Notice Planmust be focused there.2. Even with the defined geographic scope of the Settlement, some ClassMembers could be located throughout the U.S., including large cities andrural areas.3. Mailing addresses, compiled from various lists, are available for a portionof the Class.4. High quality notice methods are needed to convey the importance ofinformation affecting Settlement Class Members’ rights.• Target Audience. The E&PD Settlement Agreement defines the “Class” as:A. Individuals. Unless otherwise specified, all Natural Personsresiding in the United States who, at any time between April 20,2010 and April 16, 2012, lived in, worked in, were offered andaccepted work in, owned or leased real or personal propertylocated within, or owned or leased or worked on a vessel harboredor HOME PORTED in the States of Louisiana, Mississippi, orAlabama, the counties of Chambers, Galveston, Jefferson andOrange 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 inthe State of Florida, including all adjacent Gulf waters, bays,Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 60 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications7estuaries, straits, and other tidal or brackish waters within theStates of Louisiana, Mississippi, Alabama, or those describedcounties of Texas or Florida (the “GULF COAST AREAS”)(Exhibit 22), or the U.S. waters of the Gulf of Mexico and alladjacent bays, estuaries, straits, and other tidal or brackish waterswithin the Gulf Coast Areas, as specifically shown and describedin Exhibit 23 (“SPECIFIED GULF WATERS”), or worked on avessel in Specified Gulf Waters after April 20, 2009. With respectto SEAFOOD CREW Claims, persons must have worked on avessel that landed SEAFOOD in the Gulf Coast Areas after April20, 2009.andB. Entities. All Entities doing business or operating in the Gulf CoastAreas 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 CoastAreas or Specified Gulf Waters and (A) sold products in theGulf Coast Areas or Specified Gulf Waters (1) directly toCONSUMERS or END USERS of those products or (2) toanother Entity that sold those products directly to Consumers orEnd Users of those products, or (B) regularly purchasedSeafood harvested from Specified Gulf Waters in order toproduce goods for resale;b) are service businesses with one or more full-timeemployees (including owner-operators) who performed theirfull-time services while physically present in the Gulf CoastAreas or Specified Gulf Waters at any time from April 20, 2010to April 16, 2012; orc) owned, operated, or leased a vessel that (1) was HomePorted in the Gulf Coast Areas at any time from April 20, 2010to April 16, 2012, or (2) landed Seafood in the Gulf CoastAreas at any time from April 20, 2009 to April 16, 2012; ord) owned or leased REAL PROPERTY in the Gulf CoastAreas at any time from April 20, 2010 to April 16, 2012;Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 61 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications8C. Individuals and Entities who meet the geographical descriptions ofSections A or B above are included in the Economic Class only if theirClaims meet the descriptions of one or more of the damage categoriesdescribed in the Settlement Agreement.We further understand that the capitalized terms in the Class Definition have thefollowing 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 stockcompany, a trust, a joint venture or an unincorporated association of any kind ordescription.“Consumer” means a Natural Person or an Entity who or which buys anyproduct 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, heror 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 primarytarget audience of: all adults 18 years and older, currently living in the GulfCoast Areas. To further extend the reach of the Plan to unknown ClassMembers who do not currently reside in the Gulf Coast Areas, the Plan includesa broad national effort to reach adults 18 years and older across the UnitedStates.To verify the notice program’s effectiveness, GfK Mediamark Research &Intelligence, LCC (“MRI”)2 data was studied among all adults aged 18 yearsand older. This data formed the basis for the national program. Additionally,MRI, Nielsen Media Research and other data sources were studied for adultswho live in the Gulf Coast Areas.2 GfK Mediamark Research & Intelligence, LCC (“MRI”) is a leading source of publication readership and productusage data for the communications industry. MRI offers comprehensive demographic, lifestyle, product usage andexposure to all forms of advertising media collected from a single sample. As the leading U.S. supplier ofmultimedia 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 andmarketing plans that are written for advertised brands in the U.S.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 62 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications9• Strategies. Notice will be mailed to known or likely Class Members, compiledfrom various lists provided by the settling parties and their experts. Anextensive schedule of local newspaper, radio, television and Internet placementshas been developed to reach Class Members in the Gulf Coast Areas. To reachClass Members across the United States, the schedule includes well-readconsumer magazines, a national daily business newspaper, highly traffickedwebsites and Sunday local newspapers (via newspaper supplements). Althoughnot measurable, notice placements will also appear in trade, business andspecialty publications, African-American, Vietnamese and Spanish languagepublications, and Cajun radio programming. An informational release,television public service announcements (“PSAs”), and case website willprovide additional notice exposures.• Delivery. The combined measurable effort will reach at least 95% of adults inthe Gulf Coast Areas on average 8.8 times each and an estimated 83% of allU.S. adults an average of 3.8 times each. The “reach” or net reach of a noticeprogram is defined as the percentage of the target audience exposed to a noticenet of any duplication among people who may have been exposed more thanonce. Coverage will be further enhanced by media placements described abovefor which reach is not measured. The measurable reach and frequency that willbe 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 reachClass Members:1. Individual Notice. For each name and address of a known, likelyEconomic and Property Damages Settlement Class Member, a NoticePacket will be mailed via first class mail in a flat envelope. The NoticePacket will include a Cover Letter and Detailed Notice, and is expectedto include a color map folio.2. Consumer Publications. A Summary Notice will appear in twelveleading weekly and monthly consumer publications— two times each inPeople, Parade and USA Weekend, and once in American Profile, AARPBulletin, Better Homes and Gardens, National Geographic,Cosmopolitan, Sports Illustrated, Southern Living, People en Espanol,Ebony and Essence, for a total of 16 insertions.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 63 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications103. Trade, Business and Specialty Publications. One or two double-pagespread or full-page insertions in the Wall Street Journal and publicationstargeted to the industries and activities most likely directly affected bythe Deepwater Horizon Incident.4. Local Newspapers. Four full-page insertions will appear in 364 localnewspapers, covering virtually all of Louisiana, Alabama and Mississippiand 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) inpublications targeted to the relevant local communities.6. Local Television. Approximately 300 adult gross rating points (“GRPs”)4will air per market in the Gulf Coast Areas (matching the DMAs includedin the local newspaper effort) substantially over three weeks in a varietyof dayparts and programs on local and cable networks. Some spots mayrun in a fourth week as necessary.7. Local Radio Programming. Approximately 180 adult GRPs will air permarket in the Gulf Coast Areas (matching the DMAs included in the localtelevision effort) over three weeks on a variety of programming.Additional radio spots will run on “Statenets” targeting ruralcommunities the Gulf Coast Areas. Separate local radio efforts will betargeted to the African-American, Spanish-speaking and Cajunpopulations where appropriate.8. Internet Banner Notices. Banner Notices measuring 728 x 90 pixels and300 x 250 pixels will be placed during a one-month period on nationalweb properties such as 24/7 Real Media (a network that represents over900 websites), Yahoo!, MSN, AOL, Weather.com and on tradepublication websites. In addition, Banner Notices will be placed on localnewspaper 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 geographicarea 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 includesduplicate exposures to the same person.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 64 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications119. Informational Release. A party-neutral, Court-approved informationalrelease will be issued to approximately 4,200 print and broadcast and5,500 online press outlets throughout the United States.10. TV PSAs. A Court-approved television spot will be distributed to over1,200 television stations throughout the United States.11. Case Website. A neutral, informational website with an easy toremember domain name will be established where Class Members canobtain 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. TheNotices alert Class Members that the message may affect them. The summarypublication notice is a single advertising unit for both the Economic andProperty Damages and the Medical Benefits Settlement. The publication noticeincludes a summary of the Economic and Property Damages Settlement, and aseparate summary of the Medical Benefits Settlement. Broadcast and Internetefforts provide the message that there is one settlement addressing economicand property damages claims, and a separate settlement addressing medicalclaims. Consistent with our normal practice, all notice documents will undergoa final edit prior to actual mailing and publication for grammatical errors andaccuracy. Drafts of the forms of notice are included as Attachment 1.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 65 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications 123. Notice Schedule Flow ChartThe chart below shows a hypothetical schedule. The schedule would begin sometime after Court approval of theNotice Plan. Class members would be provided sufficient time to act upon their rights prior to the opt-out andobjection deadlines. The website will remain operational beyond the flowchart shown, until requested to beterminated.Notice Tactic Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10Issue Informational ReleaseIndividual Notice MailingIssue TV PSAsLocal NewspapersLocal Television*Local RadioInternet Banner NoticesNational Newspaper InsertsNational Consumer PublicationsTrade, Business, SpecialtyPublicationsNon-English LanguagePublicationsCase Website*Television placements will substantially occur over a 3-week period with the 4thweek reserved for “make-goods” and remaininginventory.Note: Print media blocks show when readers first receive publications (the on-sale date). Media selections are subject to change byaddition, deletion, or substitution at the time of placement. Appearance dates may vary within the notice period, based on availability atthe time of placementCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 66 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications 134. Target AudienceThe demographics of the class, including, but not limited to, those most likely to be ClassMembers.The proposed Economic and Property Damages Settlement has specific geographicboundaries. The majority of the Class will be located within a limited geographicarea in the Gulf Coast Areas (Louisiana, Mississippi and Alabama and portions ofTexas 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 identifykey demographic groups which can be used to guide local media selection.Additionally, because the Class definition encompasses people across manydifferent demographic audiences who could reside anywhere in the United States,the notice program includes a significant component designed to reach adults aged18+ across the country.According to MRI, demographic highlights of adults aged 18+ in the Gulf CoastAreas 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-timeUsing MRI data we can also pinpoint certain key demographics that make up agreater 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-American5 “County/parish size A” is defined as highly urbanized areas and belong to the 21 largest Metropolitan StatisticalAreas. The combined counties/parishes contain 40% of the United States households. “County/parish size B” isdefined as counties/parishes not defined as A counties/parishes that have more than 85,000 households. Thecombined counties/parishes contain 30% of United States households.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 67 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications14• 11.7% more likely to work in a natural resources or construction field• 28.1% more likely to have not graduated from high schoolCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 68 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications155. Individual NoticeReaches Class Members directly with notice.Postal Mailed NoticeFor each unique name and address of a known, likely Economic and PropertyDamages Settlement Class Member, a Notice Packet will be mailed via first classmail in a flat envelope. The Notice Packet will include a Cover Letter and DetailedNotice, and is expected to include a color map folio. Potential Class Members willbe directed to the settlement website and the toll-free number for detailedinformation on how to file a Claim, to access Claim Forms, and to seek assistanceas needed with filing a claim.The mailing list has been compiled from multiple lists of known, likely SettlementClass Members. The Notice Packet will also be sent to known attorneys, otherthan Class Counsel, who represent likely Class Members. This list will beassembled 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 andthose who requested information about the GCCF process and providedcontact information to the GCCF6;• BP Claims Facility list of claimants who filed claims under the Oil PollutionAct of 1990 prior to the creation of the GCCF;• Vessels of Opportunity (“VoO”) lists and lists of VoO contractors whosubcontracted out to other vessels; and• Lists of ascertainable Coastal Real Property owners, Wetlands RealProperty owners and Real Property Sales owners who are presumptivelymembers the Settlement Class and do not have to demonstrate a loss in orderto be eligible to file a claim.Prior to mailing, all addresses will be checked against the National Change ofAddress (“NCOA”) database maintained by the United States Postal Service(“USPS”).7 If a record is returned by NCOA as invalid, the administrator will6 An Economic and Property Damage Settlement Notice packet will be mailed to all names and addresses in theGCCF database that do not unambiguously relate only to a medical claim. (Individuals who unambiguously relateonly to a medical claim will be mailed a Medical Benefits Settlement Notice packet). For any record in the GCCFdatabase where there is any ambiguity as to the subject matter of that individual’s claim or request for furtherinformation, 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 forthe last four years. The USPS makes this data available to mailing firms and lists submitted to it are automaticallyCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 69 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications16update the address through third-party address search services and remail asappropriate. Notices returned as undeliverable will be remailed to any new addressavailable through postal service information, for example, to the address providedby the postal service on returned pieces for which the automatic forwarding orderhas expired, but which is still during the period in which the postal service returnsthe piece with the address indicated, or to better addresses that may be found afterreasonable, additional third-party source lookups. Upon successfully locatingbetter addresses, Notices will be promptly remailed on an ongoing basis.Additionally, the Notice Packet will be mailed to all persons who request one viathe toll-free phone number maintained by the Economic and Property Damagesclaims administrator.Email NoticeAn Email Notice will be sent to known, likely Settlement Class Members forwhom only a name and email address is known and no other means of determininga physical address are available. Additionally, an Email Notice will be sent toknown, likely Settlement Class Members for whom a physical address and anemail address are available (email notice sent in addition to postal mail). TheEmail Notice will include substantially the same content as the text of thePublication Notice that is specific to the E&PD Settlement, and will contain anembedded link to the notice website where the Detailed Notice and othersettlement information can be accessed.The Email Notice will be provided using an embedded HTML text format. Thisformat will provide text that is easy to read without graphics, tables, images andother elements that would increase the likelihood that the message is blocked byInternet Service Providers (ISP’s) and/or SPAM filters. Prior to transmitting theEmail Notice, the Claims Administrator will notify major ISPs about the schedulednotification effort in order to get these messages “white-listed” for delivery torecipient 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” shouldbe returned to the sending server along with the unique message identifier. For anyEmail Notice for which a bounce code is received indicating that the message wasundeliverable, at least two additional attempts will be made to deliver the Noticeby email.updated with any reported move based on a comparison with the person’s name and known address.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 70 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications17The proposed Cover Letter, Detailed Notice and Email Notice are part of the noticedocuments included in Attachment 1.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 71 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications186. Media SelectionThe media vehicles that will best reach Class Members in this particular notice program.In addition to the Individual Notice mailing to potential Class Members, acomprehensive national and regional multi-media effort in virtually every form ofmedia has been selected to effectively deliver a clear message to Economic andProperty Damages Settlement Class Members. Newspapers and print publicationsreach older audiences. Television and radio effectively reach less-affluentaudiences, and especially African-American and Spanish speaking audiences.Younger audiences will be targeted through the Internet effort. The businessaudience is targeted with business and trade publications. Non-English speakingaudiences will be targeted with print publications in identified languages and viaradio. We have reviewed the merits of all forms of media and, based on ouranalysis, 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 GulfCoast Areas and an estimated 83% of adults across the United States).• Multiple opportunities for Class Members to see the message throughoverlapping reach of the different notice methods.• “Noticeable” Publication Notices in leading consumer magazines, dailynewspapers and other publications that will allow readers to have a writtenrecord and the ability to refer back to the Notice, pass it on to others, and easilyrespond 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 editionsof newspapers with distribution in large cities and small towns.• High-quality Television Notices that will allow Settlement Class Members to bealerted to key information and to call or visit the website for additionalinformation.• 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 targetingindustries likely to have been affected by the Deepwater Horizon Incident.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 72 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications19• Publication Notice in appropriate foreign language publications covering majorethnic 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 targetedlocal coverage of the Gulf Coast Areas, ensuring that Settlement ClassMembers are not excluded based on where they choose to live.• The broadest, most-inclusive demographic coverage, ensuring that ClassMembers are effectively reached through notice placements in a variety ofcultural and trade publications as well as television and radio programs focusingon different target segments.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 73 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications207. Plan Delivery SummaryNational Consumer Publications 13Newspapers carrying Notices (via supplements): ≈2,191Gulf Coast Areas Local Newspapers 364Trade Publications 34Foreign Language and African-American Publications 46Total Print Insertions 5,421Local Television Adult GRPs per Market ≈300Total Radio Adult GRPs per Market ≈180Internet Banner Impressions ≈115 millionEstimated Net % Reached – National Plan 83.0%Avg. Frequency of Exposure – National 3.8 timesEstimated Net % Reached – Local Plan >95.0%Avg. Frequency of Exposure – Local 8.8 timesEstimated Net Audience - National 211,000,000Estimated Gross Impressions* - National 931,000,000Source: 2011 MRI Doublebase Study, ABC and publication circulation statements.*Total exposures to notice among all those exposed, including repeat exposures.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 74 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications218. Net ReachTotal different persons who open or read a publication containing a notice.We employ industry-standard computer software, which uses the latest readershipdata, to factor out the duplicate persons reached by the different and overlappingaudiences on a notice schedule to yield total net persons reached. The proposedmeasurable print and television, radio and online efforts are estimated to reach:Target% Reached, Netof DuplicationAdults in the Gulf Coast Areas aged18+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, noticeplacements in trade, business and specialty publications, African-American,Vietnamese and Spanish language publications, and the informational release, TVPSAs, and case website.The audience data used to determine these results are the same data used by mediaprofessionals to guide the billions of dollars of advertising we see today. Thestatistics and sources we cite are uniformly relied upon in our field: Audit Bureauof Circulations (“ABC”) data has been relied upon since 19148; 90-100% of mediadirectors use reach and frequency planning9; all of the leading advertising andcommunications textbooks cite the need to use reach and frequency planning10; and8 Established in 1914, ABC is a non-profit cooperative formed by media, advertisers, and advertising agencies toaudit the paid circulation statements of magazines and newspapers. ABC is the leading third-party auditingorganization in the U.S. It is the industry’s leading, neutral source for documentation on the actual distribution ofnewspapers printed and bought by readers. Widely accepted throughout the industry, it certifies over 3,000publications, categorized by metro areas, region, and other geographical divisions. Its publication audits areconducted in accordance with rules established by its Board of Directors. These rules govern not only how auditsare conducted, but also how publishers report their circulation figures. ABC’s Board of Directors is comprised ofrepresentatives from the publishing and advertising communities.9 See generally Peter B. Turk, Effective Frequency Report: Its Use And Evaluation By Major Agency MediaDepartment Executives, 28 J. ADVERTISING RES. 56 (1988); Peggy J. Kreshel et al., How Leading AdvertisingAgencies 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 & JIMSURMANEK, 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 MEDIA123-126 (1980); JACK Z. SISSORS & LINCOLN BUMBA, ADVERTISING MEDIA PLANNING 93-122 (4th ed. 1993); JIMSURMANEK, INTRODUCTION TO ADVERTISING MEDIA: RESEARCH, PLANNING, AND BUYING 106-187 (1993).Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 75 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications22a leading treatise says it must be used:11 “In order to obtain this essentialinformation, we must use the statistics known as reach and frequency.” Ninety ofthe top one hundred media firms use MRI data, which has a 95% confidenceinterval; and at least 3,000 media firms in 25 different countries use mediaplanning software for reach and frequency planning.12 Online media planning datais provided by comScore, Inc.1311 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 3,000users in 25 countries, including 95% of the world’s top agencies, use Telmar systems for media and marketingplanning tools, including reach and frequency planning functions. Established in 1968, Telmar was the firstcompany 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 marketingintelligence. In an independent survey of 800 of the most influential publishers, advertising agencies andadvertisers conducted by William Blair & Company in January 2009, comScore was rated the “most preferredonline audience measurement service” by 50% of respondents, a full 25 points ahead of its nearest competitor.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 76 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications239. Average Frequency of ExposureAverage number of times that each different person reached will have an opportunity to view avehicle containing a notice placement.This Notice Plan is intended to provide Class Members with the best practicableopportunity to view and understand the Notice and their rights, including their rightto file a claim, if desired. A by-product of the media vehicles necessary for a broadnet reach is multiple exposures to notice from overlapping audience coverage.This Notice Plan relies upon modern-style, audience-documented media coverageas reported herein, and provides a higher frequency of exposure than would a directmail notice program that sends one notice, one time, to a Class Member.14 Theaverage frequency of exposure resulting from the proposed Notice Program is asfollows:Target Average Frequency of ExposureAdults in the Gulf aged 18+ 8.8All U.S. adults aged 18+ 3.8Source: 2011 MRI Doublebase Study.The frequency of exposure will be further enhanced by the Individual MailedNotice effort, notice placements in trade, business and specialty publications,African-American , Vietnamese and Spanish language publications, informationalrelease, TV PSAs, and case website.14 The reach achievable through direct mail notice programs varies widely depending on the accuracy andcomprehensiveness of class member mailing lists.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 77 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications2410. Geographic CoverageEnsuring 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 ofLouisiana, Mississippi and Alabama and the enumerated counties in Texas andFlorida. 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 theU.S., as supported by the detailed ABC statements for each publication.• Parade, USA Weekend and American Profile are distributed within nearly 2,191newspapers nationwide, covering large markets as well as reaching deep intosmall towns. A listing of the newspapers that contain Parade, USA Weekendand American Profile is attached as Attachment 2.• The television and radio airings will result in the overall schedule beingavailable to Class Members in Louisiana, Mississippi, Alabama and portions ofTexas and Florida.• Notice placements in local newspapers targeting the Gulf Coast Areas withtargeted coverage to Settlement Class Members residing in the Economic andProperty Damages Settlement “Zones.” Additionally, the recommendedconsumer publications offer spill-over circulation into these areas.• Notice placements in trade, business and specialty publications extend reach totargeted industries throughout the U.S.• The Internet Banner Notices and case website allow access to the Noticeregardless of geography.• The informational release and television PSAs will broaden the geographiccoverage further.Accordingly, the Notice is designed to reach Class Members regardless of wherethey choose to live.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 78 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications2511. Nationwide Publication PlanThe national newspapers and consumer publications in which the notice will appear.The Notice Plan includes multiple notice placements in 13 leading weekly andmonthly publications. Notices will appear twice in the national newspapersupplements Parade and USA Weekend and once in American Profile. Combined,these publications appear in over 2,191 Sunday newspapers nationwide. Noticeswill appear twice in People, and once in Better Homes and Gardens, AARPBulletin, National Geographic, Cosmopolitan, Sports Illustrated, Southern Living,People en Espanol, Ebony and Essence, for a total of 16 insertions. The selectedpublications cover all demographic groups, specifically targeting men’s andwomen’s publications, magazines aimed at older demographic segments, Spanish-speaking readers, and publications specifically targeting the African-Americancommunity.Publication IssuanceOverall NoticeSizeEcon/PropertyNotice Content # of InsertionsPeople Weekly Dbl-Page Spread Full Page 2Parade Weekly Dbl-Page Spread Full Page 2USA Weekend Weekly Dbl-Page Spread Full Page 2American Profile Weekly Dbl-Page Spread Full Page 1Better Homes andGardensMonthly Dbl-Page Spread Full Page 1AARP Bulletin 10x/year Dbl-Page Spread Full Page 1National Geographic Monthly Dbl-Page Spread Full Page 1Cosmopolitan Monthly Dbl-Page Spread Full Page 1Sports Illustrated Monthly Dbl-Page Spread Full Page 1Southern Living Monthly Dbl-Page Spread Full Page 1People en Espanol 10x/year Dbl-Page Spread Full Page 1Ebony Monthly Dbl-Page Spread Full Page 1Essence Monthly Dbl-Page Spread Full Page 1TOTAL 16Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 79 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications2612. Nationwide Publication DetailsA summary of facts on the consumer publications in which the notice will appear.Publication FactsParade • Weekly national newspaper supplement coveringfamily, food, health, current events and entertainment.• Provides the single largest readership of any publication.• Provides a broad demographic readership andgeographic coverage.• Carried in approximately 522 papers throughout theU.S.• Planned notice size: Double-Page Spread• Planned insertions: 2xUSA Weekend • Weekly national newspaper supplement coveringfamily, food, health, current events and entertainment.• Readership ranks 2ndamong adults 18+• Provides a broad demographic readership andgeographic coverage.• Carried in approximately 686 papers throughout theU.S.• Planned notice size: Double-Page Spread• Planned insertions: 2xAmerican Profile • Weekly national newspaper supplement coveringfamily, food, health, current events and entertainment.• Provides a broad demographic readership andgeographic coverage.• Carried in approximately 1,350 papers throughout theU.S.• Planned notice size: Double-Page Spread• Planned insertions: 1xPeople • Weekly entertainment magazine featuring celebritynews, biographies, and gossip.• Readership ranks 3rdamong adults 18+• Provides a large number of pass along readers.• Planned notice size: Double-Page Spread• Planned insertions: 2xCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 80 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications27Better Homes andGardens• Monthly national magazine covering, lifestyle, homeand garden trends and remodeling, health and food.• Readership ranks 4thamong adults 18+• Planned notice size: Double-Page Spread• Planned insertions: 1xNationalGeographic• Monthly publications featuring photos, maps andarticles relating to animals, the environment, culturesand history around the world.• Readership ranks 6thamong adults 18+• Planned notice size: Double-Page Spread• Planned insertions: 1xAARP Bulletin • 10x/year publication targeting mature adults featuringthe latest news and information on health, socialsecurity, Medicare, politics and more.• Readership ranks 7thamong adults 18+• Planned notice size: Double-Page Spread• Planned insertions: 1xCosmopolitan • Monthly female targeted magazine featuring celebritynews, health, relationship and style advice.• Planned notice size: Double-Page Spread• Planned insertions: 1xSports Illustrated • Monthly sports magazine covering sports news, photos,scores, columns and expert analysis.• Planned notice size: Double-Page Spread• Planned insertions: 1xSouthern Living • Monthly magazine covering Southern culture, recipes,travel and events.• Planned notice size: Double-Page Spread• Planned insertions: 1xEbony • Monthly magazine covering African-American culture,arts, health, travel, politics and lifestyle.• Planned notice size: Double-Page Spread• Planned insertions: 1xEssence • Monthly magazine covering African-American culture,arts, health, travel, love and lifestyle.• Planned notice size: Double-Page Spread• Planned insertions: 1xCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 81 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications28People en Espanol • 10x/year entertainment magazine featuring celebritynews, biographies, and gossip in Spanish.• Planned notice size: Double-Page Spread• Planned insertions: 1xCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 82 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications2913. Nationwide Publication CoverageThe 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, aswell as publications that extend reach among various demographic segments.PublicationCoverageamong U.S.AdultsCoverageRankParade 30.37% 1USA Weekend 18.30% 2People 19.87% 3Better Homes and Gardens 17.37% 4National Geographic 13.95% 6AARP Bulletin 13.02% 7American Profile 11.40%* 9Sports Illustrated 9.17% 13Cosmopolitan 8.11% 17Southern Living 6.89% 19Ebony 4.60% 44Essence 3.51% 57People en Espanol 2.94% 81Source: 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 Doublebasesurvey. Reach percentage reported above is based on publisher’s estimates.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 83 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3014. Nationwide Publication CirculationTotal number of copies sold through all channels (subscription, newsstand)The selected publications include some of the largest circulating publications in thecountry. Combined, they provide a total circulation of over 114 million.Publication Total CirculationParade 33,000,000USA Weekend 22,600,000American Profile 10,000,000People 3,450,000Better Homes and Gardens 7,663,198Southern Living 2,800,000National Geographic 4,400,000AARP Bulletin 22,000,000Cosmopolitan 3,032,000Sports Illustrated 3,150,000Ebony 1,250,000Essence 1,050,000People en Espanol 540,000TOTAL 114,935,198Source: ABC audit and publisher’s statements.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 84 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3115. Publication Secondary Reader DataSecondary or ‘pass-along’ readers of a publication.Based on MRI readership data, we know that more readers than just those whopurchase or otherwise receive circulated issues actually open or read thepublication. Many secondary readers see the Notice away from home: forexample, 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 ofemployment; etc. Exposure in a different environment can increase attentivenessand response potential. It is also beneficial that readership tends to build over aperiod of time following the publication date. This is evidence that issues can bereferred to at any time, thereby providing readers with a longer, sustainedopportunity to be exposed to the Notice.The following calculations set forth the average number of readers-per-copy ofeach of the selected publications:Publication Readers Per CopyParade 2.10USA Weekend 1.85American Profile 2.60People 13.14Better Homes and Gardens 5.17Southern Living 5.62National Geographic 7.23AARP Bulletin 1.35Cosmopolitan 6.95Sports Illustrated 6.64Ebony 8.39Essence 6.90People en Espanol 12.42Source: 2011 MRI Doublebase Study audience numbers and ABC statements.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 85 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3216. Nationwide Publication Audience DataTotal different persons opening or reading a publication.The following outlines the total Adult audience (readership) for one insertion ineach 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” apublication.Publication Total Adult AudienceParade 69,278,000USA Weekend 41,747,000American Profile 26,000,000People 45,318,000Better Homes and Gardens 39,625,000Southern Living 15,722,000National Geographic 31,813,000AARP Bulletin 29,700,000Cosmopolitan 21,072,000Sports Illustrated 20,926,000Ebony 10,482,000Essence 7,245,000People en Espanol 6,708,000Source: 2011 MRI Doublebase Study.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 86 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3317. Nationwide Publication Gross ImpressionsTotal 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 than521 million times during the notice period. This includes the same reader morethan once, because readers of one publication read other publications as well. Thisduplication is factored out by the net reach analysis explained earlier.Publication Insertions Adult ImpressionsParade 2 138,556,000USA Weekend 2 83,494,000American Profile 1 26,000,000People 2 90,636,000Better Homes and Gardens 1 39,625,000Southern Living 1 15,722,000National Geographic 1 31,813,000AARP Bulletin 1 29,700,000Cosmopolitan 1 21,072,000Sports Illustrated 1 20,926,000Ebony 1 10,482,000Essence 1 7,245,000People en Espanol 1 6,708,000Total 521,979,000Source: 2011 MRI Doublebase Study.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 87 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3418. Trade, Business and Specialty PublicationsThe trade and business publications in which the notice will appear.The Notice will appear once or twice as appropriate in 34 publications targeted tothe industries and activities most likely to have been directly affected by theDeepwater Horizon Incident. The Selected publications, which include the nationaledition of the Wall Street Journal, have a combined circulation of over 5 million.The following provides circulation data for the selected Trade, Business andSpecialty publications:Publication Distribution Frequency# ofInsertions CirculationBass Master National 10x/year 1 521,397Conde Nast Traveler National Monthly 1 816,066Florida Sportsman National Monthly 2 76,194GAFF National bi-monthly 1 280,000Game and Fish National Monthly 1 415,000Gulfcoast Business Review SW Florida Weekly 2 14,000Gulfscapes Magazine Gulf Coast Quarterly 1 40,000Gulfshore Business Southwest Florida Monthly 2 31,942Marina Dock Age National 8x yearly 1 16,141Marine Log Global Monthly 2 31,619Maritime Executive Global bi-monthly 1 24,904National Fisherman National Monthly 2 30,076Offshore Global Monthly 2 44,546Recommend Magazine National Monthly 2 48,810Saltwater Sportsman National 10x/year 1 136,238Seafood Business National Monthly 2 14,000Sport Fishing National 9x/year 1 110,406Sunbelt Food Service Southern States Monthly 2 27,826Texas Monthly National Monthly 2 300,000Texas Saltwater Fishing Texas Monthly 2 40,000The Shelby Report of the Southeast SE Monthly 2 16,202The Shelby Report of the Southwest SW Monthly 2 15,934Travel Agent Magazine Global Bi-weekly 2 1,812Travel Weekly National Weekly 2 38,000Vacation Agent Magazine National Monthly 2 31,399Well Service National bi-monthly 1 10,000Louisiana Sportsman Louisiana Monthly 2 35,000Mississippi Sportsman Mississippi Monthly 2 9,500New Orleans Magazine New Orleans Monthly 2 34,241New Orleans CityBusiness New Orleans Weekly 2 20,150Louisiana Life Louisiana bi-monthly 1 40,000South Louisiana BusinessNews Louisiana Weekly 2 10,000Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 88 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications35Offbeat Louisiana Monthly 2 36,626Wall Street Journal National Daily 1 2,117,796Total 56 5,435,825Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 89 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3619. Local NewspapersThe newspapers in the Gulf Coast Areas in which the notice will appear.The Economic and Property Damages Notice Plan includes daily and weeklynewspapers covering each of the Designated Marketing Areas (“DMAs”) in whichthe largest population center within each respective DMA is part of the definedGulf Coast Areas. DMAs represent a geographic area defined by Nielsen MediaResearch Company as a group of counties/parishes that make up a particulartelevision 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, SantaRosa, Sarasota, Taylor, Wakulla, Walton, Washington in the State of Florida.These 26 individual DMAs have been used to establish the geographic scope forthe local portion of the media plan. They are as follows:• Houston• Beaumont-PortArthur• 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-ElDorado• Shreveport• Jackson, Ms• Columbus-Tupelo-WestPoint• Greenwood-Greenville• Meridian• Birmingham(Anniston andTuscaloosa)• Huntsville-Decatur (FL)For the Local Newspaper Notice, these 26 DMAs ringing the Gulf Coast Areas willbe covered by a total of 347 individual, local newspapers.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 90 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications37The Notice will run in an additional 17 newspapers in the Memphis (12), Atlanta(1) and Columbus (4) DMAs. These three DMAs lie predominately outside theClass geography, but do have small areas carved into the states of Mississippi(Memphis DMA) and Alabama (Atlanta and Columbus DMAs). It is these smallareas 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 onSunday and twice on a weekday in daily newspapers and over 4 successive weeksin weekly newspapers for a total of 1,456 insertions. The selected newspapershave a combined circulation of over 8 million. In most instances, the Notice willappear a fifth or sixth time in each local newspaper via the planned insertions inthe nationwide newspaper inserts (Parade, USA Weekend and American Profile).When this occurs, the Notice will appear on successive Sundays with the weekdayinsertion in-between the two Local Newspaper Sunday insertions.The list of selected local newspapers is included as Attachment 3.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 91 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications3820. African-American, Vietnamese andSpanish Language PublicationsIn order to target certain communities affected by the Deepwater Horizon Incidentin mediums culturally appropriate to them, the Notice will appear as a double pagespread or full-page ad unit 3 times in selected daily and weekly publications and 1time in selected monthly publications covering the African-American, Vietnameseand Spanish language populations in the Gulf Coast Areas. The Notice will betranslated into Vietnamese and Spanish where appropriate. The 46 selectedpublications have a combined circulation of over 1.8 million. The followingprovides circulation data for the African-American, Vietnamese and Spanishlanguage publications:Publication Distribution Language# ofInsertions CirculationAfrican American News &IssuesHouston English 3 250,000Alexandria News Weekly Alexandria English 3 5,000Baton Rouge Weekly Press Baton Rouge Spanish 3 7,500Birmingham Times Birmingham/Anniston/Tusc. Spanish 3 16,500Centro Tampa (formerlyCentro Mi Diario)Tampa/St. Petersburg Spanish 3 42,000Community Voice Ft. Myers/Naples Spanish 3 12,000Data News Weekly New Orleans Spanish 3 25,000Dep Weekly Magazine Houston Spanish 3 10,000Diario Las Americas Miami/Ft. Lauderdale Spanish 3 35,095El Nuevo Herald - SundayEditionMiami/Ft. Lauderdale English 3 84,972El Perico Beaumont/Port Arthur English 3 26,400El Sentinel (Ft.Lauderdale/Miami)Miami/Ft. Lauderdale Spanish 3 125,000El Sol De La Florida Miami/Ft. Lauderdale English 1 60,000El Tiempo New Orleans New Orleans English 1 20,000Florida Sentinel Bulletin Tampa/St. Petersburg English 3 23,000Forward Times Houston English 3 64,580Houston Defender Houston English 3 20,215Jackson Advocate Jackson, MS Spanish 3 8,000Jambalaya News New Orleans English 3 15,000La Gaceta Tampa/St. Petersburg English 3 18,000La Informacion Houston Bilingual 3 100,000La Noticia de Mississippi Jackson, MS Spanish 3 5,000La Subasta Houston (10 Houston Bilingual 3 163,875Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 92 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications39Zones)La Voz De Houston Houston English 3 100,000Latino News Birmingham/Anniston/Tusc. English 3 12,000Louisiana Weekly New Orleans English 3 6,500Miami Times Miami/Ft. Lauderdale Bilingual 3 25,000Mississippi Link Jackson, MS Bilingual 3 16,404Monroe Dispatch Monroe/El Dorado Spanish 3 12,000Monroe Free Press Monroe/El Dorado Spanish 3 15,000Montgomery-TuskegeeTimesMontgomery/Selma Spanish 3 5,000New Orleans Tribune New Orleans English 1 20,000Nuevos Ecos Ft. Myers/Naples English 3 20,000Paisano Birmingham/Anniston/Tusc. English 3 9,000Pensacola VoiceMobile/Pensacola/Ft. WaltonBeachSpanish 3 38,000Rio Grande Valley HispanicNewspaper NetworkHarlingen/Weslaco/Brownsville/McAllenEnglish 3 108,218Rumbo (Houston) Houston Bilingual 3 52,000Saigon Nho New Orleans Spanish 3 5,000Semana Houston Vietnamese 3 145,000Shreveport Sun Shreveport Spanish 3 4,900Siete Dias (7 Dias) Tampa/St. Petersburg English 3 22,000South Florida Times(formerly Broward Times)Miami/Ft. Lauderdale Spanish 3 26,000Thuong Mai Houston Vietnamese 3 42,000Viet Bao Weekly - HoustonEditionHouston Vietnamese 3 25,000Vietnam Moi News Houston Vietnamese 3 20,000Weekly Challenger Tampa/St. Petersburg English 3 10,000Total 132 1,876,159Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 93 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4021. Local TelevisionMainstream television is a high-reach medium providing exposure to affectedpeople regardless of where they reside (i.e. rural areas, urban areas, etc.).30-second units will appear on local broadcast and cable television as appropriatein the 26 DMAs identified in section 19. It is estimated that the local televisionNotice will generate approximately 300 “GRPs” per Market. GRP is a term usedin advertising to measure the size of an audience reached by a specific mediavehicle or schedule. It is the product of the percentage of the target audiencereached 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 targetaudience would have 250 GRPs (GRP = 5 × 50%).We conservatively estimate that 2,730 total spots will be run, but it is likely thatadditional spots will be negotiated at the time of the buy. On its own, the LocalTelevision Notice is estimated to reach over 80% of adults aged 18+ in the GulfCoast Areas with an estimated average frequency of 3.6 times each.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 94 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4122. TV Dayparts/ProgrammingThe 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 withdifferent viewing habits. Daypart mixes and programming selections may changeat the time the buy is authorized, based on negotiations and availabilities.Morning• Morning news programming provides an ideal environment fornotification messages.• Loyal audience builds frequency among those reached.• Programming considered includes Good Morning America, The TodayShow, CBS Early Show and Local News.Daytime• Extends reach among homemakers, retirees, or unemployed ClassMembers.• Loyal audience builds frequency among those reached.• Programming considered includes daytime dramas, game showsand/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, JudgeMathis, Judge Judy, Ellen DeGeneres Show, Jeopardy, Wheel ofFortune.Early News• Non-opinionated journalism provides an ideal environment fornotification programs.• Provides broad reach among Class Members.• Programming considered includes CBS Evening News, ABC WorldNews Tonight, NBC Nightly News with Brian Williams and LocalNews.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 MindsCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 95 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4223. TV Rating Points (GRPs)One rating point equals one percent of the targeted population. This may include the sameperson reached more than once, so ratings can and often do exceed 100.Approximately 2,730 30-second spots will substantially run over a three-weekperiod in Gulf Coast markets matching the DMAs covered in the Local Newspaperplan. Approximately 300 Gross Rating Points per market and over 67 milliongross impressions will be generated. Ads to air on the top 3 local stations permarket 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 onnegotiations and availabilities.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 96 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4324. TV Gross ImpressionsTotal 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 periodin which the television schedule airs.DaypartAdultGross ImpressionsMorning 6,792,300Daytime 6,792,300Early Fringe 6,792,300Early News 10,188,450Prime Access 10,188,450Primetime 13,584,600Late News 6,792,300Weekend 6,792,300TOTAL 67,923,000Daypart mixes may change at the time the buy is authorized, based on negotiationsand availabilities.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 97 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4425. Local Radio ProgrammingLocal radio is a high-frequency medium providing exposure to affected peopleregardless 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 inthe 26 DMAs identified in section 19. It is estimated that the local Radio Noticewill generate approximately 180 “GRPs” per Market. We conservatively estimatethat 8,712 total spots will be run, but it is possible that additional spots will benegotiated at the time of the buy. On its own, the Local Radio Notice is estimatedto reach just under 45% of adults aged 18+ in the Gulf Coast Areas with anestimated average frequency of 4 times each.To better reach rural communities, the radio notice will appear on “StateNets,” aradio network specializing in reaching C & D counties/parishes in 48 states.Typical StateNets features are news, regional weather and other informationalprograms. We estimate that over 14,000 total spots will run on approximately 200radio stations in the 26 DMAs over a three week period.Additionally, the Radio Notice will be placed on appropriate African-Americanand 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 inareas of the Gulf Coast with high concentrations of Spanish speaking adults. TheSpanish language Radio Notice will be recorded as a 60-second spot toaccommodate the translation.A radio buy will also be executed, targeted toward the Cajun population inSouthern Louisiana. Approximately 100 spots will run over a 2-week period onlocal stations, including: KLRZ-FM, KLEB-AM, and KANE-AM. The spot willbe voiced in a Cajun dialect.The Local Radio Notice to Hispanic, African-American and Cajun populations isnot calculated into the overall measured reach and frequency of the Notice Plan.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 98 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4526. Internet Banner NoticesNational and local banner notices that will appear on web properties.Digital 728x90 pixel and 300x250 pixel banners will be placed on the followingnational online networks:• Yahoo!,• MSN,• AOL,• Weather.com, and• 24/7 Real Media (representing over 900 websites including those related tohealth, fitness, and news and information).Where available, banners will also be placed on the websites of the selected tradeand specialty publications included in the print publication plan.Combined, approximately 72 million adult impressions will be generated by thesebanner notices over a one month period. Clicking on the banner will jump thesearcher to the case website where they can obtain information about thesettlement.To complement print notices in the selected local newspapers, digital 728x90 and300x250 banners will be placed through quadrantOne on newspaper and local TVwebsites in the identified geographies. Banner notices will run across 31 days anddeliver more than 42 million impressions across Texas, Louisiana, Mississippi,Alabama and Florida. Each banner notice will include a clickable link to thededicated case website.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 99 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4627. Placing Notices to be Highly VisibleInserting 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 inpositions that will generate “noticeability” among Class Members.In print, the Notice will run as a double page spread. Notice will be placed incertain sections of publications to help ensure that over the course of the mediaschedule, the greatest practicable number of Class Members will see the Notice. Inthe local newspapers, the Notice will appear as a full-page ad unit.Summary Publication Notice DesignThe Summary Publication Notice will be divided into two sections. One sectionwill provide notice of the Economic and Property Damages Settlement. The othersection will provide notice of the Medical Benefits Settlement. Each notice willfeature its own headline to alert potential Class Members that they may be affectedby one or more (or both) of the two proposed Settlements. Both Settlements willshare a common toll-free number and website address. These will be featuredprominently along the bottom of the Notice.In television, planned spots may be pre-empted15; however, “makegoods” will besought in acceptable programs. A post-buy analysis will assure that GRP levels areachieved. Efforts will be made to enhance the television reach and frequency bytaking 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 tocapitalize on the most efficient availabilities, or programs expected to be highlyrated.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.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 100 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4728. Informational ReleaseSeeking non-paid (and other) exposure of court-approved notice information mainly by wayof news articles.A party-neutral, Court-approved informational release will be issued toapproximately 4,200 print and broadcast and 5,500 online press outlets throughoutthe United States. A news release serves a potentially valuable role, providingadditional 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, ClassMembers will have additional opportunities to learn that their rights are at stake incredible news media, adding to their understanding. The release will include thetoll-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 asAttachment 1.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 101 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4829. TV Public Service AnnouncementsPaid distribution of the notice to select television stations.The 30-second television spot will be distributed as a TV PSA or “public serviceannouncement” to more than 1,200 broadcast television stations throughout theU.S. The packaging will include a letter explaining the important legal nature ofthe announcement to gain the attention of public service directors and encouragestations to air the information. The television spot will feature the case websiteaddress and toll-free number to increase Class Members’ opportunities to obtainmore information and/or respond to the Notice. A list of the broadcast televisionstations that will receive the TV PSA is available upon request.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 102 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications4930. Case WebsiteDelivery of notice via Internet and online services.A neutral, informational, notice website with an easy to remember domain namewill serve as the notice page for both Settlements where potential Settlement ClassMembers can obtain additional information and documents including the Detailedand Summary Notices, Settlement Agreements, Preliminary Approval Orders andany other information that the parties agree to provide or that the Court mayrequire. The case notice website will also include information on how potentialSettlement Class Members can opt-out of the Settlement if they choose.The case notice website address will be prominently displayed in all printed noticedocuments, and appear in all broadcast media including the informational releaseand 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 claimsadministration websites tailored to each Settlement via prominent buttons on thenotice website homepage (one reading “Economic and Property Damages Claims”and the other reading “Medical Claims”). Claim Forms and other informationspecific to each Settlement will be available at these claims administration sites.The case notice website will be color-coordinated with the claims administrationwebsites and all pages that a visitor might see will have a consistent look andfunctionality. In order to stress the separateness of the two Settlements, the claimsadministration sites will have different, but compatible, color schemes. The casenotice website will reflect this by having the button links to each claimsadministration website in the specific color scheme of the website it is linking to.Both claims administration websites will include a prominent link to the otherclaims administration website for visitors interested in both settlements.The claims administrator claims filing website will include an interactive map ofthe Gulf Coast where visitors will be able to input their property or residencyaddress or select a geographic location to assist them in determining if the addressfalls 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/Creoleif requested. A screen shot of the proposed notice website pages is part of thenotice documents included as Attachment 1.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 103 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications5031. Sponsored Search ListingsTo facilitate locating the case website, sponsored search listings will be acquiredon 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,” thesponsored search listing will display either at the top of the page prior to the searchresults or in the upper right hand column.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 104 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications5132. Notice Design StrategyThe Notices have been designed to motivate Settlement Class Members to viewand understand the message and carry a clear message outlining Settlement ClassMembers’ rights. The strategic approach to content and design is entirelyconsistent with the illustrative “model” notices developed by the Federal JudicialCenter (“FJC”).All print publication notices will be a single advertising unit that includes onesummary 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 onesettlement addressing economic and property damages claims, and a separatesettlement addressing medical claims.Summary Notice Design Elements:• Bold headline captures attention. The headlines immediately alert even casualreaders who may be potential Settlement Class Members that they should readthe 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 thelocal newspapers or double-page spreads in most print publications to promotereadership.• Notice design alerts readers to the legal significance, lending credibility. TheNotice design ensures that readers know that the communication carrieslegitimate, important information, not commercial advertising. The cleardelineation between the Economic and Property Damages Settlement Noticetext and the Medical Benefits Settlement Notice text highlights that the Court isconsidering two separate settlements and that the reader may have rights undereach Settlement or under both.• Plain language enhances comprehension. The Notice concisely and clearlystates the information in plain, easily understandable language so that ClassMembers can comprehend the Notice effectively.• Comprehensive content fulfills legal requirements. All critical informationabout Settlement Class Members’ rights is included. No key information isomitted.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 105 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications52• Toll-free number and website invite response. The Notice invites response byproviding simple, convenient mechanisms, such as the toll-free number andwebsite for Settlement Class Members to obtain additional information, ifdesired.• Translations allow participation across speakers of key languages. TheSummary Notice will be translated into Spanish and Vietnamese for placementin the appropriate Spanish and Vietnamese language newspapers. The DetailedNotice will include tag lines in Spanish and Vietnamese telling potential ClassMembers that the notices are available in each language on the website or bycalling the toll-free number.Television and Radio Notice Design Elements:• Designed to stand apart from ads. Because they are designed to look andsound different from commercials selling products, viewers and listenersunderstand its significance and take notice.• Key words and concepts are depicted on screen. The principles ofcommunication dictate visual and verbal repetition of key concepts presented.• Convenient response-oriented approach is provided. In the TV Notice, thewebsite and toll-free number are spoken and shown on the screen long enoughto allow Class Members to write them down or remember them. The RadioNotice will repeat the toll-free number and website if time permits.• Simple information allows sufficient understanding. Although concise, thepurpose of the Notice is served by delivering the substance of the message (thatthere are two separate Settlements) and prompting a response to get moreinformation.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 106 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • © 2012 Hilsoft Notifications5333. Draft Forms of NoticeAll notice documents have been drafted by Hilsoft in cooperation with the partiesand subject to the approval of the Court. These documents include:• The Cover Letter, Detailed Notice and Mailing Envelope that will be mailedto all known potential Settlement Class Members and to those who call torequest one as well as made available at the website.• The Email Notice that will be sent to known, likely Settlement Class Membersfor whom an email address is available.• The Publication Notice as it will appear in magazines and newspapersidentified in the Notice Plan.• The Television Notice Storyboard that will be produced as a 30-second unitand 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-secondwhen 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 outletsthroughout the U.S.Notice drafts are included as Attachment 1 and foreign language translations willbe provided with our final report.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 107 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • ––ƒ…Š‡– ͳǣ ‘”• ‘ˆ ‘–‹…‡ ˆ‘” …‘‘‹… Ƭ”‘’‡”–› ƒƒ‰‡• ‘–‹…‡ ŽƒCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 108 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1A: Cover Letter, Detailed Notice,Mailing EnvelopeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 109 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Cover LetterCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 110 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Notice Administrator for U.S. District CourtPost Office Box NNNNCity, ST ZipF-Name MI L-NameStreet Address 1Street Address 2City, ST ZipAn Economic & Property Damages Settlement has been reached related to the Deepwater Horizonincident. The Settlement will provide payments to qualifying individuals and businesses that file validclaims for economic and property damage. You are receiving this notice because you have beenidentified as a possible member of the Economic and Property Damage Settlement Class. Please reviewthe 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 forbenefits, opting-out of or objecting to the Settlement. A court hearing will be held on Month DD, 20YYto consider whether the Settlement is fair, reasonable and adequate. The hearing may be moved to adifferent date, time, or location without additional notice, so it is recommended that you periodicallycheck 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 thewebsite www.[ ].com or by calling 1-8XX-XXX-XXXX. If you have questions about how to file yourclaim, 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 amember of both settlement classes. To get more information about either settlement, visitwww.[ ].com or call 1-8XX-XXX-XXXX.Sincerely,Notice Administrator[Spanish Tag/Vietnamese Tag]Questions? Visit www.[ ].com or call 1-8XX-XXX-XXXX.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 111 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Detailed NoticeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 112 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COMSI DESEA RECIBIR ESTA NOTIFICACIÓN EN ESPAÑOL, LLÁMENOS O VISITE NUESTRA PÁGINA WEB.(ADD IN TRANSLATED TEXT FOR VIETNAMESE – FIRST PAGE ONLY)1UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANAIf you had economic loss or property damagebecause 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—havebeen reached with BP Exploration & Production Inc. and BP America Production Company (“BP”) overthe 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 youhave 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 websitewww.[ ].com has detailed descriptions and maps to help you determine whether a location may beincluded in one or more of these zones.• Payments will be made for most claims as they are received and approved, with the exception of certainSeafood Compensation claims.• If you are included in the E&PD Settlement (an “E&PD Class Member”), your legal rights are affectedwhether 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 exclusionfrom this Settlement (also called “Opting Out”) would allow youto bring a lawsuit against BP yourself about the legal claimsinvolved in this E&PD Settlement.OBJECT Write to the Court about why you do not like the E&PDSettlement.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 theE&PD Settlement will still apply to you.• These rights and options—and the deadlines to exercise them—are explained in this Notice.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 113 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM2Basic Information ...................................................................................................................................... Page 41. 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 610. 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 DamagesSettlement?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 DamagesSettlement?15. What happens if I am not included in the Economic & Property Damages Settlement?E&PD Settlement Claims Eligibility And Benefits Chart.................................................................... Page 11How To Request A Payment—Submitting A Claim Form.................................................................. Page 1516. 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 1723. 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 OilPollution 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 mindlater?WHAT THIS NOTICE CONTAINSCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 114 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM3Objecting To the Settlement ................................................................................................................... Page 1828. 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 1930. Do I have a lawyer in this case?31. How will the lawyers be paid?The Court’s Fairness Hearing................................................................................................................ Page 2032. When and where will the Court decide whether to approve this Economic & Property DamagesSettlement?33. Do I have to come to the Fairness Hearing?If You Do Nothing ................................................................................................................................... Page 2134. What happens if I do nothing?Getting More Information...................................................................................................................... Page 2135. How do I get more information?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 115 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM4BASIC INFORMATIONYou have a right to know about a proposed settlement of this class action lawsuit and about your optionsrelating to the proposed Settlement. This Notice explains the lawsuit, the E&PD Settlement, your legalrights, 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 moreinformation about the Medical Benefits Settlement, and to determine whether your rights are affected bythat settlement, or whether you are eligible for benefits under that settlement, visit www.[ ].com, orcall 1-8XX-XXX-XXXX.Judge Carl J. Barbier of the United States District Court for the Eastern District of Louisiana isoverseeing 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 thewebsite.Do not call the Court or any Judge’s office to ask questions about the E&PD Settlement. If you havequestions 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 “DeepwaterHorizon Incident” (see Question 3) in the Gulf of Mexico beginning on April 20, 2010. The Plaintiffsseek money and other relief for economic and property damage they allege was caused by the DeepwaterHorizon Incident. BP disputes and denies Plaintiffs’ claims in that lawsuit.“Deepwater Horizon Incident” refers to the events, actions, inactions, and omissions leading up to andincluding:• 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 oilrig 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 116 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM5In a class action, one or more people called “Class Representatives” sue on behalf of people who havesimilar claims. All of the people and businesses that have similar claims to the class representatives area “class,” or in this instance “Economic & Property Damages Settlement Class Members” (“E&PD ClassMembers”). 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 lengthnegotiations, the Plaintiffs and BP have agreed to settle this case to avoid the cost, delay, and risk of atrial. The Class Representatives and their lawyers think the proposed E&PD Settlement is best for allE&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 theparties, the new program operates according to specific, agreed-upon rules and under the supervision ofthe Court. If you had a claim rejected or denied by the GCCF, it will not affect your eligibility or rightto receive a payment under the E&PD Settlement. If you had a claim paid by the GCCF, and you did notsign a release (see Question 8), you may still be eligible to receive a payment under the E&PDSettlement.All pending and unresolved GCCF claims, including all documents related to those claims, have beentransferred to the new Settlement Program. The Settlement Program is processing these claims under therules of the E&PD Settlement. If additional information is needed to process your claim, you will becontacted. If you have a specific question about the status of a GCCF claim, you can call the SettlementProgram 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&PDSettlement. However, you may still be eligible to submit a VoO Charter Payment claim or a VesselPhysical Damage claim (see the E&PD Settlement Claims Eligibility and Benefits Chart below fordetails of VoO Charter Payments and Vessel Physical Damage claims.) You may also still be eligible toparticipate in the separate Medical Benefits Settlement. If your GCCF claim and the “Release andCovenant Not to Sue” related only to a bodily injury claim, you may still be able to participate in theE&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 ClaimsFacility (GCCF)?5. Why is there a settlement?4. Why is this a class action?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 117 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM6Yes. Even if you submitted a special short form (“Short Form Joinder”) as part of the lawsuit againstBP, you still must submit a Claim Form and provide all required documentation to request a paymentfrom the Settlement Program (see Question 17).WHO IS IN THE SETTLEMENTTo see if you will be affected by the E&PD Settlement or if you can get a payment from it, you first haveto determine if you are an E&PD Class Member.The E&PD Class includes individuals, businesses, and other entities. Please answer the series ofquestions below to see if you may be an E&PD Class Member. The first set of questions is forindividuals and the second set of questions is for businesses and other entities. The definitions belowwill help you when answering the questions.• “Gulf Coast Areas” include the States of Louisiana, Mississippi, and Alabama; the counties ofChambers, 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 CoastAreas” also includes all adjacent Gulf waters, bays, estuaries, straits, and other tidal or brackishwaters within the States of Louisiana, Mississippi, and Alabama, and those described counties ofTexas 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 orhaving operated for profit or not-for-profit, including a partnership, a corporation, a limited liabilitycompany, an association, a joint stock company, a trust, a joint venture, or an unincorporatedassociation of any kind or description.• “Consumer” means a Natural Person or an Entity that buys any product for individual use orconsumption and not for manufacture or resale.• “End User” means a Natural Person or Entity that buys any product for his, her, or its individual useor 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 118 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM7Questions for Individuals Yes NoDo you live in the U.S.? Continue tonext question.You are not anE&PD ClassMember.Did you live in, work in, were offered and accepted work in, own or leaseproperty in, or own, lease, or work on a vessel harbored or home-ported inthe Gulf Coast Areas or Specified Gulf Waters at any time between April20, 2010, and April 16, 2012?ORDid you work on a vessel in Specified Gulf Waters at any time betweenApril 20, 2010 and April 16, 2012 that landed Seafood in the Gulf CoastAreas after April 20, 2009?Continue tonext question.You are not anE&PD ClassMember.Do you have any economic loss arising out of the Deepwater HorizonIncident?ORWas your real or personal property damaged as a result of the DeepwaterHorizon Incident?Continue tonext question.You are not anE&PD ClassMember.Do your claims for economic loss or property damage meet the descriptions ofone 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 DamageYou may be anE&PD ClassMember.Continue toEligibility andBenefits Chartbeginning onpage 11 of thisNotice todeterminewhether youmay beeligible for apayment.You are not anE&PD ClassMember.Individuals may also be included in the Medical Benefits Settlement if they were Clean-Up Workers orwere residents in certain defined areas or “Zones.” More information on the Medical BenefitsSettlement is available on the website or by calling 1-8XX-XXX-XXXX.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 119 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM8Questions for Businesses and Other Entities Yes No(1) Did your business or Entity own, operate, or lease a physical facilityor vessel in the Gulf Coast Areas or Specified Gulf Waters betweenApril 20, 2010 and April 16, 2012, andSell 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 orEnd Users of those products?orRegularly purchase Seafood harvested from Specified GulfWaters 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-timeservices while physically present in the Gulf Coast Areas or SpecifiedGulf 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 atany time from April 20, 2009 to April 16, 2012?OR(4) Did your business or Entity own or lease real property in the GulfCoast Areas between April 20, 2010 and April 16, 2012?Continue to nextquestion.You are not anE&PD ClassMember.Do your business’s or Entity’s claims for economic loss or property damagemeet 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 DamageYou may be anE&PD ClassMember.Continue toEligibility andBenefits Chartbeginning on page11 of this Noticeto determinewhether you maybe eligible for apayment.You are not anE&PD ClassMember.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 120 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM9Yes. 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 Defendantsin MDL 2179;• The Court, including any sitting judges on the United States District Court for the EasternDistrict of Louisiana, their law clerks serving during the pendency of this lawsuit, and membersof 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 andCovenant Not To Sue” (although these Individuals and Entities may still make a VoO CharterPayment 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 Entitiesand/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 certaincategories of economic losses not related to these industries, such as Coastal Real Property Damage andWetlands Real Property Damage. See the Settlement Agreement or call 1-8XX-XXX-XXXX for moreinformation.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 Contractorindustries, as well as Entities selling or marketing BP-branded fuel (including jobbers andbranded 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 canbe found on the website or by calling 1-8XX-XXX-XXXX.11. Are there exceptions to being included in the Economic & Property DamagesClass?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 121 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM10There are separate eligibility rules for each of the claim categories in the E&PD Settlement. TheSettlement Claims Eligibility and Benefits Chart beginning on page 11 of this Notice illustrates who maybe eligible to receive a payment in each category. A number of these categories include geographiczones. 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 conditionsarising out of the Deepwater Horizon Incident, you may also be eligible to participate in the Medical BenefitsSettlement. More information about the Medical Benefits Settlement is available on the website or by calling1-8XX-XXX-XXXX.If you are not sure whether you are in the E&PD Class, or have any other questions about the E&PDSettlement, visit the settlement website at or call the toll-free number, 1-8XX-XXX-XXXX. You mayalso 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, youmay still be included in the Medical Benefits Settlement (see Question 13). Also, if you are not includedin the E&PD Settlement, you may file an Oil Pollution Act claim with BP directly. You can get moreinformation about filing an Oil Pollution Act claim directly with BP by visiting www.[ ].com orcalling 1-8XX-[OPANUMBER].15. What happens if I am not included in the Economic & Property DamagesSettlement?14. What if I’m still not sure whether I am included in the Economic & PropertyDamages Settlement?13. Does the Economic & Property Damages Settlement cover claims for medicalbenefits?12. How do I know if I am eligible to receive a payment from the Economic & PropertyDamages Settlement?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 122 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM11E&PD SETTLEMENT CLAIMS ELIGIBILITY AND BENEFITS CHARTClaim Category Eligibility Requirements Potential BenefitsSeafoodCompensationClaimClaims for economic loss related to Seafood can be made by Individuals andEntities that qualify as Commercial Fishermen, Seafood Boat Captains,Seafood Crew (including first mates, second mates, boatswains, anddeckhands), Oyster Leaseholders, and Seafood Vessel Owners. Claims maybe 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 SeafoodCompensation claim category, but all claims must be submitted on a singleSeafood Compensation Claim Form.The Seafood Compensation claim deadline is earlier than the claim deadlinefor all other claims in the E&PD Settlement. The deadline to submit aSeafood Compensation Claim Form is 30 days after entry and judgment of theCourt’s final approval of the E&PD Settlement. The exact date of the claimdeadline will be posted on the website.BP will pay at least $2.3 billion in total for economic lossrelated to Seafood under the Seafood Compensation Programunder a process approved by the Court-appointed Neutral,John W. Perry, Jr.The payment amount for Seafood Compensation claimsvaries by type of claim submitted.Any money previously received from BP or the GCCF forspill-related Seafood claims (excluding VoO claims) will bededucted from the Settlement payment.An RTP*multiplier may be applied to payments for all claimcategories other than IFQ holders and certain Seafood Crew.All Seafood Compensation claims will be paid as they arereceived and approved, except for some Seafood Crewclaims that will be determined after the SeafoodCompensation claim deadline and paid as soon as possibleby 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 riskof future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 123 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM12EconomicDamage ClaimClaims for economic damage can be made by Individuals and Entities incertain industries or geographic zones that lost profits or earnings as a result ofthe Deepwater Horizon Incident.Depending on their industry or geographic zone, some Individuals and Entitiesmay need to provide evidence that their economic losses were caused by theDeepwater Horizon Incident.For more details on eligible Economic Damage claims, please visit theSettlement website.In general, the payment amount for Economic Damageclaims is calculated by comparing actual post-spill earningsto the earnings that might have been expected in that post-spill period. There are also considerations for specializedcircumstances, such as start-up businesses, failed businesses,multi-facility businesses, new entrants to employment, andfestival vendors.An RTP*multiplier will be applied to the payments for sometypes of Economic Damage claims.Any money previously received from BP or the GCCF forthe same economic loss will be deducted from the Settlementpayment.Loss ofSubsistenceClaimClaims for loss of subsistence can be made by Individuals who fished orhunted in certain geographic regions to harvest, catch, barter, consume, ortrade Gulf of Mexico natural resources, including Seafood and Game, in atraditional or customary manner to sustain their basic or family dietary,economic security, shelter, tool or clothing needs, and who relied uponsubsistence resources that were diminished or restricted in the geographicregion used by the claimant due to the Deepwater Horizon Incident.Those who fish or hunt solely for pleasure or sport are not eligible to makeclaims for subsistence, regardless of whether or not they consume their catch.Payments will be based on the retail value of the Seafoodand Game lost between April 20, 2010 and December 31,2011.An RTP*multiplier will be applied to payments for Loss ofSubsistence claims, in part to account for the damage tosubsistence family and community customs and culture.VoO CharterPayment ClaimClaims for economic loss caused by participation in the VoO program(regardless of whether dispatched or asked to perform work) can be made bythose who:Registered to participate in the VoO program;Executed a VoO Master Vessel Charter Agreement; andCompleted the initial VoO training program.For claimants who were dispatched or asked to perform workin the VoO program, payment amounts will range from$41,600 to $88,400, depending on vessel length.For claimants who completed the initial VoO trainingprogram but were never dispatched or asked to perform workin 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 riskof future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 124 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM13Vessel PhysicalDamage ClaimIndividuals and Entities who were owners of an eligible vessel between April20, 2010 and December 31, 2011 may recover for physical damage resultingfrom the Deepwater Horizon Incident or certain response clean-up operations,including the cost of removal of equipment or rigging added to an eligiblevessel as part of response activities.Payment is not available to claimants who:• Signed a Receipt and Release Letter Agreement for damagereimbursement as part of the VoO program; or• Sustained damage to vessels while working for any oil spill responseorganization or an oil spill removal organization (other than the VoOprogram).Qualifying claimants will receive the lesser of the reasonableand necessary costs to repair or replace an eligible vessel.Coastal RealProperty DamageClaimIndividuals and Entities who owned or leased coastal real property or boatslips located in certain geographical areas at any time from April 20, 2010 toDecember 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 connectionwith the Deepwater Horizon Incident response cleanup operations can makeclaims for Physical Damage.Payment amounts range from 30% to 45% of the parcel’sstandardized 2010 applicable property tax amount,depending on its location and environmental sensitivity.An RTP*multiplier will be applied to payments for CoastalReal Property Damage claims.Payment for Response Operations Physical Damage is equalto 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 riskof future economic losses related to the Deepwater Horizon Incident. The E&PD Settlement specifies RTPs applicable to certain types of industries or claims.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 125 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM14Real PropertySales DamageClaimReal Property Sales Damage claims can be made by sellers of residentialproperty 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 April21, 2010, or (2) executed before April 21, 2010, but subject to a pricereduction due to the Deepwater Horizon Incident.Transfers of residential real property from borrowers to lenders as part of theforeclosure process are not included.Payment amounts will include 12.5% of the sale price of thequalifying residential property, less any prior compensationthat the claimant previously received from BP or the GCCFin connection with the same property.For shared properties, this amount will be divided based onthe claimant’s ownership interest.Wetlands RealProperty DamageClaimIndividuals and Entities who owned wetlands real property located in certaingeographic areas at any time between April 20, 2010 and April 16, 2012, canmake claims for Wetlands Real Property Damage.In addition, owners of real or personal property, on wetlands real propertylocated in certain geographic areas that was physically damaged by theDeepwater Horizon Incident response cleanup operations, can make claims forPhysical Damage.Payments will range between $4,500 and $25,000 per acre ofcertain shoreline or buffer areas based on whether thepresence of oil was observed by various official assessments.Payment for Physical Damage is equal to the cost to eitherrepair or replace the damaged property, whichever is lower.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 126 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM15HOW TO REQUEST A PAYMENT—SUBMITTING A CLAIM FORMThe amount of your payment will be based on the type of claim you have (see E&PD Settlement ClaimsEligibility and Benefits Chart beginning on page 11 of this Notice). Complete information on all of theE&PD Settlement benefits is available on the website.If you receive a payment for an Economic Damage or Seafood Compensation claim, you may also beeligible for payment of specified professional accounting services used to prepare your claim under areimbursement framework. Visit the website for information on the accounting services reimbursementprocess.If you have questions about how the value of your potential claim will be determined, you can call1-8XX-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 ofsupporting documentation required. A Claim Form package is available on the website, or can be sent toyou 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 thewebsite or call 1-8XX-XXX-XXXX for the location of the Claim Offices.The address for mailing your Claim Form(s) is:_____________ SettlementPO Box XXXCity, State XXXXX-XXXXYou may be eligible to file a claim under more than one category. You do not need to submit yourclaims under all categories at one time. However, once you receive your first payment under theSettlement Program, you must file any and all additional claims within six months from the date of thatfirst payment.All claims for Seafood Compensation must be made in a single Seafood Compensation Claim Form. Thedeadline to submit a Seafood Compensation Claim Form is 30 days after entry and judgment of theCourt’s final approval. This deadline is earlier than the claims deadline for all other claims in the E&PDSettlement. 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 “finalapproval” and any appeals are resolved). The exact date of the claim filing deadline will be posted on thewebsite. It is highly recommended that E&PD Class Members complete and submit their Claim Formpromptly. If you do not submit a Claim Form on time you will lose the opportunity to apply for apayment 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 127 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM16Yes. You will need to include certain supporting documents for your claim to be accepted. Please readthe Claim Form instructions carefully. If you have any questions about preparing the Claim Form, call1-8XX-XXX-XXXX.The E&PD Settlement provides a process to resolve disagreements about how much money you shouldget. You will get further details in the letter you receive with your payment. If your claim is denied, or ifyou are not satisfied with the amount of your payment, you may file an appeal. In cases of an awardabove $25,000, BP also has the right to appeal. The website will have an appeal form and furtherexplanation of the appeals process. Please note that there is no appeals process for some SeafoodCompensation claims.In general, valid claims will be paid as they are received and approved, except for certain SeafoodCompensation claims. Certain Seafood Crew claims for Seafood Compensation will be paid after theSeafood 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 theseafood 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 andHalliburton for the benefit of the E&PD Class. If successful, any proceeds from such claims will be usedfor 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 ReleasedParties (identified in Section 10 of the Settlement Agreement) regarding all of the claims resolved by theE&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 Agreementdescribes the released claims with specific descriptions in legal terminology, so read it carefully. Ifyou have any questions about the released claims and what they mean, you can talk to the law firmsrepresenting the E&PD Class, listed in Question 30 below, for free; or you can, at your own expense, talkto 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 128 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM17EXCLUDING YOURSELF FROM THE ECONOMIC & PROPERTY DAMAGES CLASSIf you do not want to participate in the E&PD Settlement and you want to keep all of your rights to sueBP and any of the Released Parties about the claims being resolved in the E&PD Settlement, then youmust take steps to get out of the E&PD Class. This is called asking to be excluded from, or sometimescalled “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 writtenrequest stating “I wish to be excluded from the Economic & Property Damages Class.” Your writtenrequest 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 SettlementExclusions DepartmentPO Box 222Hammond, LA 70404-0222You 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 areincluded 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 receiveany payment under the E&PD Settlement, and you cannot object to the proposed E&PD Settlement. Ifyou 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 129 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM18Yes. Individuals, businesses, and Entities that exclude themselves from the E&PD Settlement may file OilPollution Act claims directly with BP. You can get more information about filing an Oil Pollution Actclaim 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, yougive up the right to sue BP or any of the Released Parties for the claims that the E&PD Settlementresolves.Yes. You have the right to request to withdraw (“revoke”) your decision to Opt Out of the E&PDSettlement as long as you do it by Month Day, 20YY, as described more fully in Section 8 of the E&PDSettlement Agreement. In some cases you may be able to revoke your request to Opt Out of the E&PDSettlement after Month Day 20YY, but BP must agree to any request received after this date and there isno guarantee they will do so. Please visit the website or call 1-8XX-XXX-XXXX for details about howto revoke an Opt Out.OBJECTING TO THE SETTLEMENTOnly 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 letterexplaining your objection to the proposed Economic & Property Damages Settlement in In re: Oil Spillby the Oil Rig "Deepwater Horizon" in the Gulf of Mexico on April 20, 2010, MDL No. 2179. Yourobjection letter must include:1) A detailed statement of each objection being made, including the specific reasons for eachobjection, 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; and4) Any supporting papers, materials, or briefs that you want the Court to consider when reviewingthe objection.An E&PD Class Member may also object through an attorney hired at his, her, or its own expense. Theattorney will have to file a notice of appearance with the Court by Month Day, 2012, and serve a copy ofthe notice and the objection containing the information detailed above on E&PD Class Counsel and BP’sCounsel 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 DamagesSettlement?27. If I exclude myself from the Economic & Property Damages Settlement, can Ichange 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 stillmake an Oil Pollution Act claim with BP directly?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 130 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM19Do 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. Youcan object only if you stay in the E&PD Class. Excluding yourself, also called Opting Out, is telling theCourt that you do not want to be part of the E&PD Class. If you exclude yourself, you cannot object tothe E&PD Settlement and you will not be eligible to apply for a payment under the E&PD Settlement.THE LAWYERS REPRESENTING YOUThe Court has appointed [___________] as “Economic & Property Damages Class Counsel” to representthe E&PD Class Members. You will not be charged for these lawyers. If you want to be represented byyour own lawyer in this case, you may hire one at your own expense.ECONOMIC & PROPERTYDAMAGES CLASS COUNSELDEFENDANTS’ COUNSEL COURTJames Parkerson RoyAttn: Deepwater Horizon E&PDSettlementDomengeaux Wright Roy &Edwards556 Jefferson St., Suite 500P.O. Box 3668Lafayette, LA 70501Stephen J. HermanAttn: Deepwater Horizon E&PDSettlementHerman Herman Katz & CotlarLLP820 O’Keefe AvenueNew Orleans, LA 70113Richard C. Godfrey, P.C.Attn: Deepwater Horizon E&PDSettlementKirkland & Ellis LLP300 North LaSalle StreetChicago, IL 60654Clerk of CourtUnited States District Court forthe Eastern District of Louisiana500 Poydras StreetNew Orleans, LA 7013030. Do I have a lawyer in this case?29. What is the difference between objecting to, and asking to be excluded from, theEconomic & Property Damages Settlement?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 131 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM20E&PD Class Counsel will ask the Court to consider an award of fees, costs, and expenses, including aninterim payment of $75 million and additional awards equal to 6% of class claims and benefits paid, and amaximum of $600 million. Class Counsel fees, costs and expenses under the Economic and PropertyDamages Settlement Agreement and the Medical Settlement Agreement jointly cannot exceed $600million.Class members’ payments will not change if the Court approves the payment of Class Counselfees under either settlement, because BP will separately pay these amounts.THE COURT’S FAIRNESS HEARINGThe Court will hold a Fairness Hearing at ___ _.m. on Month Day, 2012, at the United States DistrictCourt for the Eastern District of Louisiana, Court Room No. ___, 500 Poydras Street, New Orleans, LA70130. 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 andexpenses 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 isrecommended 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 toattend the hearing at your own expense. If you send in a written objection, you do not have to come to theFairness Hearing to talk about it. As long as you mailed your written objection on time, the Court willconsider it.If you, or an attorney you have hired at your own expense, wish to speak at the Fairness Hearing, youmust by Month Day, 2012, file with the Court and send by first-class mail to E&PD Class Counsel andBP’s Counsel at the addresses listed in Question 28, a written notice of your intention to speak at theFairness 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 youhave 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 132 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • QUESTIONS? CALL 1-8XX-XXX-XXXX OR VISIT WWW.[ ].COM21IF YOU DO NOTHINGIf you are an E&PD Class Member and do nothing, you will not get a payment from this E&PDSettlement. And, unless you exclude yourself, you will not be able to start a lawsuit, continue with alawsuit, or be part of any other lawsuit against BP or the Released Parties about the claims being releasedby 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 forany other claims not resolved by the E&PD Settlement.GETTING MORE INFORMATIONThis Notice summarizes the proposed E&PD Settlement. More details are in the E&PD SettlementAgreement. You can get a copy of the E&PD Settlement Agreement on the website. You also may writewith questions to XXXXXXXXXXXXXXXX, PO Box XXXX, City, State XXXXX-XXXX or send ane-mail to info@[ ].com. You can get a Claim Form on the website, or have a Claim Form mailed toyou 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 youhave 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?Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 133 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Mailing EnvelopeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 134 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Notice Administrator for U.S. District CourtPost Office Box NNNNCity, ST NNNNN-NNNN123456789John Q. Doe1234 Main St.City, ST 00000PRESORTEDFIRST-CLASS MAILUS POSTAGEPAIDCITY, STPERMIT # 000DEEPWATER HORIZONEconomic andProperty DamagesSettlementIfyouhadeconomiclossorpropertydamagebecauseoftheDeepwaterHorizonoilspill,youcouldgetmoneyfromaclassactionsettlement.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 135 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1B: Email NoticeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 136 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • 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 PropertyDamages SettlementPara obtener una notificación en español, póngase en contacto con nosotros o visite nuestra sitio www.[ ].com[Vietnamese call out here.]Legal NoticeIf you had economic loss or property damage because of theDeepwater Horizon oil spill, you could get money from a classaction settlement.If you have economic loss or property damage because of the Deepwater Horizon oil spill, you could get moneyfrom 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 filea 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 DamagesSettlement 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 certaincounties in Texas and Florida, that were harmed by the oil spill. The website www.[ ].com (embeddedlink) has detailed descriptions and maps to help you determine whether a geographic location may be includedin the E&PD Settlement. Additionally, you can call [1-8XX-XXX-XXXX] or e-mail info@[ ].com tofind 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 CharterPayment, (6) Coastal Real Property Damage, (7) Wetlands Real Property Damage, and (8) Real Property SalesDamage. 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 SettlementYou need to submit a Claim Form to request a payment. You can get a copy of the various Claim Forms byvisiting the website or by calling 1-8XX-XXX-XXXX. Claims can be submitted online or by mail. If you havequestions 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 becomeseffective (i.e., after the Court grants “final approval” and any appeals are resolved), whichever is later. SeafoodCompensation claims must be submitted no later than 30 days after final approval of the settlement (regardless ofCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 137 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • E&PD Settlement E-mail Notice, Page 2 of 2appeals). Actual claim filing deadlines will be posted on the website as they become available. Valid claimswill be paid as they are approved, beginning on Month 00, 2012. It is highly recommended that E&PDSettlement Class Members complete and submit their claim forms promptly. Please read the Medical BenefitsSettlement notice because you may also be eligible for benefits from that settlement.Your Other OptionsIf you do not want to be legally bound by the E&PD Settlement, you must opt out (exclude yourself) by Month00, 2012 or you won’t be able to sue BP over certain economic and property damages claims. If you stay in theE&PD Settlement, you may object to it by Month 00, 2012. The Detailed Notice (hyperlink to DetailedNotice) 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. Youor your own lawyer may ask to appear and speak at the hearing at your own cost. The Court will also considerClass Counsel fees, costs, and expenses including an interim payment of $75 million and additional awardsequal to 6% of class claims and benefits paid, and a maximum of $600 million. Class Counsel fees, costs andexpenses under the Economic and Property Damages Settlement Agreement and the Medical BenefitsSettlement Agreement jointly cannot exceed $600 million. Class members’ payments will not change if theCourt approves the payment of Class Counsel fees under either settlement, because BP will separately pay theseamounts.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 LouisianaThis notice does not provide any information related to the separate Medical Benefits Settlement also reachedrelated to the Deepwater Horizon oil spill. For more information about the Medical Benefits Settlement, andto determine whether your rights are affected by that settlement, or whether you are eligible for a paymentunder that settlement, visit www.[ ].com (embedded link) or call 1-8XX-XXX-XXXX.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 138 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1C: Publication NoticeCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 139 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Legal notice Legal noticeIf you have economic loss or property damagebecause of the Deepwater Horizon oil spill, youcould get money from a class action settlementwith BP Exploration & Production Inc. and BPAmerica Production Company (“BP”). Go towww.[ ].com for more information, includinginformation 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, otherentities, and properties in the states of Louisiana,Alabama and Mississippi, and certain counties inTexas and Florida, that were harmed by the oilspill. The website www.[ ].com has detaileddescriptions and maps to help you determinewhether a geographic location may be included inthe E&PD Settlement. Additionally, you can call1-8XX-XXX-XXXX or e-mail info@[ ].comto find out if a geographic location is included.What does the Economic & PropertyDamages Settlement Provide?The E&PD Settlement makes payments forthe following types of claims: (1) SeafoodCompensation, (2) Economic Damage, (3) Lossof Subsistence, (4) Vessel Physical Damage, (5)Vessels of Opportunity Charter Payment, (6)Coastal Real Property Damage, (7) Wetlands RealProperty Damage, and (8) Real Property SalesDamage. There is no limit on the total dollaramount of the E&PD Settlement; all qualifiedclaims will be paid.How to Get Benefits from the Economic& Property Damages SettlementYou need to submit a Claim Form to requesta payment. You can get a copy of the variousClaim Forms by visiting the website or by calling1-8XX-XXX-XXXX. Claims can be submittedonline or by mail. If you have questions abouthow to file your claim, you should call the toll-freenumber for assistance.The deadline to submit most claims will be April22, 2014 or six months after the E&PD Settlementbecomes effective (i.e., after the Court grants“final approval” and any appeals are resolved),whichever is later. Seafood Compensation claimsmust be submitted no later than 30 days after finalapproval of the settlement (regardless of appeals).Actual claim filing deadlines will be posted on thewebsite as they become available. Valid claimswill be paid as they are approved, beginning onMonth 00, 2012. It is highly recommended thatE&PD Settlement Class Members complete andsubmit their claim forms promptly. Please readthe Medical Benefits Settlement notice becauseyou may also be eligible for benefits from thatsettlement.Your Other Options?If you do not want to be legally bound by theE&PD Settlement, you must opt out or excludeyourself by Month 00, 2012 or you won’t be able tosue BP over certain economic and property damageclaims. If you stay in the E&PD Settlement, youmay object to it by Month 00, 2012. The DetailedNotice explains how to exclude yourself or object.The Court will hold a hearing on Month 00,2012 to consider whether to approve the E&PDSettlement. You or your own lawyer may ask toappear and speak at the hearing at your own cost.The Court will also consider Class Counsel fees,costs, and expenses including an interim paymentof $75 million and additional awards equal to 6%of class claims and benefits paid, and a maximumof $600 million. Class Counsel fees, costs andexpenses under the Economic and PropertyDamages Settlement Agreement and the MedicalBenefits Settlement Agreement jointly cannotexceed $600 million. Class members’ paymentswill not change if the Court approves the paymentof Class Counsel fees under either settlement,because BP will separately pay these amounts.Economic and Property Damages SettlementProviding Money to Individuals and BusinessesDeepwater Horizon Oil Spill Settlementswww.[ ].com 1-8XX-XXX-XXXXMedical Benefits SettlementProviding Benefits to Clean-Up Workers and Certain Gulf Coast ResidentsDeepwater Horizon Oil Spill Settlementswww.[ ].com 1-8XX-XXX-XXXXMedical Benefits Settlement publication notice text.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 140 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1D: Television Notice StoryboardCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 141 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 30 Second Television Spot*Final images may vary depending on photo licensing details, but will be content equivalent.OFF-CAMERA NARRATOR: If you oryour businesswere harmed by the DeepwaterHorizon Oil Spill,you may be able to get payments andother benefits1. 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.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 142 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 30 Second Television Spot*Final images may vary depending on photo licensing details, but will be content equivalent.The other provides payments andbenefits for medical claims.To get detailed information and claimforms,go to www.[ ].com7. Medium Shot female doctor with patient. 8. People working in restaurant. 9. Man in front of fishing boat, other boats inbackground.or call 8XX-XXX- XXXX.10. Wide shot of man with clipboard next tofreighter11. Sunset with moorings in foreground.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 143 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1E: Television PSACase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 144 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Front Cover TextDeepwater Horizon Oil Spill Litigation - Class Action NoticeCourt-approved PSAs about two separate settlements related to the Deepwater Horizon Oil Spill - onesettlement addressing economic and property damage claims, and a separate settlement addressingmedical claims. People and businesses across the Gulf Coast region may be eligible for payments andother benefits from one or both of the two settlements.Please air these important announcements alerting those affected about their rights, including theirright to be excluded from the case, by Month DD, 20YY.Back Cover TextDeepwater Horizon Oil Spill Litigation - Class Action NoticeDear Public Service Director:Two separate settlements have been reached related to the Deepwater Horizon Oil Spill - onesettlement addressing economic and property damage claims, and a separate settlement addressingmedical claims. People and/or businesses across the Gulf Coast region may be eligible for payments andother benefits from one or both of the two settlements.This message is important because the people and/or businesses affected have various rights, includingthe right to file claims, request exclusion from or object to either or both settlements. The PSAs informpeople 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 fortaking the time to consider sharing these PSAs with your audience.Sincerely,Notice AdministratorInside Text30 second TV PSA:People and/or businesses across the Gulf Coast region may be eligible for payments and other benefitsfrom 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 othersettlement provides payments and other benefits for certain medical claims.To get claim forms and notices, go to www.[ ].com or call 8XX-XXX-XXXX.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 145 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1F: Radio Notice ScriptCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 146 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • :30 Radio ScriptIf you or your business were harmed by the DeepwaterHorizon Oil Spill, you may be able to get payments and otherbenefits from two separate legal settlements.One settlement provides payments for economic and propertydamage. The other provides payments and benefits formedical claims.To get detailed information and claim forms go towww.[ ].com or call 8XX-XXX-XXXX.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 147 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1G: Internet Banner NoticesCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 148 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Deepwater Horizon Court-Supervised Settlement ProgramIn re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179Notice Internet BannerLEGAL NOTICE FROM U.S. COURTIf 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.[ ].comDEEPWATER HORIZON SETTLEMENTSEconomic and Property Damages Settlement: Provides payments to people and businesses.Medical Benefits Settlement: Provides payments and other benefits.www.[ ].comLEGAL NOTICE FROM U.S. COURTIf you or your businesswere harmed by theDeepwater Horizon oil spill,you may be able to get benefitsfrom two separatelegal settlements.www.[ ].comDEEPWATER HORIZON SETTLEMENTSEconomic & Property DamagesSettlement:Provides paymentsto people and businesses.Medical Benefits Settlement:Provides payments andother benefits.www.[ ].comCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 149 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 1H: Notice Website (screencaptures)Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 150 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Deepwater Horizon Court-Supervised Settlement ProgramIn re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179Notice Website Portal-- 1 --Home PageNote: 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.Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 151 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Deepwater Horizon Court-Supervised Settlement ProgramIn re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179Notice Website Portal-- 2 --Key Dates PageCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 152 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Deepwater Horizon Court-Supervised Settlement ProgramIn re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179Notice Website Portal-- 3 --Economic and Property Damage Notice PageCase 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 ProgramIn re: Oil Spill by the Oil Rig "Deepwater Horizon" in Gulf of Mexico on April 20, 2010, MDL 2179Notice Website Portal-- 4 --Medical Benefits Notice PageCase 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 ReleaseCase 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 NotificationsCOURT ORDERED NOTICE PROGRAM ABOUT TWO DEEPWATER HORIZON OILSPILL SETTLEMENTS IS INITIATEDNew Orleans, LA, Month DD, 20YY / PR Newswire / -- A notification effort ordered by theUnited States District Court for the Eastern District of Louisiana is beginning today to notifypeople, businesses and other entities about two separate proposed settlements with BPExploration & Production Inc. and BP America Production Company (“BP”) related to theDeepwater Horizon oil spill. BP has estimated the cost of the proposed settlement to beapproximately $7.8 billion. The total amount BP will pay to settle valid claims is uncapped, andthe 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 haveseparate legal rights and options, including submitting claims for benefits, opting out orobjecting 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/leaseproperty in the states of Louisiana, Mississippi, and Alabama, along with specified Texas andFlorida 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 towetlands real property; and 8) real property sales damage related to sales of certain Gulf Coastresidences. In addition to compensation for actual damage, payments to eligible claimants mayinclude a multiplier related to unknown future damage.The Medical Benefits Settlement (or “Medical Settlement’) includes “Clean-Up Workers” andpeople who resided during specified periods in 2010 in coastal areas (Zone A) and wetlandsareas (Zone B). Medical Settlement benefits include (a) payments for Specified PhysicalConditions including reimbursement of hospital expenses, (b) a 21-year Periodic MedicalConsultation Program, and (c) a $105 million Gulf Region Health Outreach Program, availableto all Gulf residents, Class Members and non-Class Members alike, in order to strengthenhealthcare 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 geographiclocation may be included within one or more zones.Notices will be mailed to known potential Class Members and are scheduled to appear inthousands of media outlets over the next 60 days in English, Spanish and Vietnamese. Noticesare to appear in Gulf Coast daily newspapers, print publications, television and radio spots andon Internet websites. A parallel nationwide media effort includes well-read consumermagazines, trade publications and highly-trafficked Internet websites.The Court has appointed [______] as Proposed Settlement Class Counsel to represent each of theSettlement 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 Notifications2Class Members can submit a claim to either or both Settlements, or they can ask to be excludedfrom, or object to, either or both Settlements. The deadline to object to either or both settlementsis [_______]. 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&PDSettlement becomes effective (i.e., after the Court grants “final approval” and any appeals areresolved), whichever is later. E&PD Seafood Compensation claims must be submitted no laterthan 30 days after final approval of the Settlement (regardless of appeals). The deadline tosubmit 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 filingdeadlines 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 claimantsmay receive payments before the Court considers whether to grant final approval. MedicalSettlement benefits will not be issued until after the Court grants final approval and any appealsare resolved.A toll-free number, [1-8XX-XXX-XXXX], has been established in the case known as In re: OilSpill 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 andother documents may be obtained.# # #/CONTACT: Press Only: Class Counsel: [__________________________]BP: [ ]./URL: [www.[ ].com]/SOURCE: United States District Court for the Eastern District of LouisianaCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 157 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Attachment 2: American Profile, Parade, and USAWeekend Newspaper ListCase 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceAlabama Albertville The Sand Mountain Reporter 1 1 January 2012Alabama Alexander City Outlook 1 1 1 1 January 2012Alabama Alexander City The Dadeville Times 1 1 January 2012Alabama Andalusia The Andalusia Star-News 1 1 January 2012Alabama Anniston Star 1 1 January 2012Alabama Athens The News Courier 1 1 1 1 2 January 2012Alabama Atmore The Atmore Advance 1 1 January 2012Alabama Bay Minette The Baldwin Times 1 1 January 2012Alabama Birmingham News 1 1 January 2012Alabama Brewton The Brewton Standard 1 1 January 2012Alabama Clanton The Clanton Advertiser 1 1 January 2012Alabama Cullman Times 1 1 1 1 2 January 2012Alabama Daphne The Bulletin 1 1 January 2012Alabama Decatur The Decatur Daily 1 1 January 2012Alabama Demopolis The Demopolis Times 1 1 January 2012Alabama Dothan Eagle 1 1 January 2012Alabama Eufaula The Eufaula Tribune 1 1 January 2012Alabama Fairhope Fairhope Courier 1 1 January 2012Alabama Fayette Pickens County Herald 1 1 January 2012Alabama Fayette TheTimes-Record 1 1 January 2012Alabama Florence-Sheffield-Tuscumbia-Muscle Times Daily 1 1 January 2012Alabama Foley Elberta-Lillian Ledger 1 1 January 2012Alabama Foley The Foley Onlooker 1 1 January 2012Alabama Fort Payne The Times-Journal 1 1 January 2012Alabama Gadsden Times 1 1 January 2012Alabama Gardendale North Jefferson News 1 1 1 1 January 2012Alabama Greenville The Greenville Advocate 1 1 January 2012Alabama Gulf Shores The Islander 1 1 January 2012Alabama Hartselle The Hartselle Enquirer 1 1 January 2012Alabama Huntsville Times 1 1 January 2012Alabama Jasper Mountain Eagle 1 1 1 1 January 2012Alabama Leeds The Leeds News 1 1 January 2012Alabama Madison Madison County Record 1 1 January 2012Alabama Mobile Register 1 1 January 2012Alabama Montgomery Advertiser 1 1 January 2012Alabama Opelika/Auburn News 1 1 January 2012Alabama Ozark The Southern Star 1 1 January 2012Alabama Pell City St. Clair News-Aegis 1 1 January 2012Alabama Robertsdale The Independent 1 1 January 2012Alabama Russellville Franklin County Times 1 1 January 2012Alabama Scottsboro The Daily Sentinel 1 1 January 2012Alabama Selma Times Journal 1 1 January 2012Alabama Talladega Daily Home 1 1 January 2012Alabama Troy The Messenger 1 1 January 2012Alabama Tuscaloosa News 1 1 January 2012Alabama Wetumpka The Wetumpka Herald 1 1 January 2012Alaska Anchorage Daily News 1 1 January 2012Alaska Fairbanks News-Miner 1 1 January 2012Alaska Juneau Empire 1 1 January 2012Alaska Kenai Peninsula Clarion 1 1 January 2012Arizona Benzon San Pedro Valley News - Sun 1 1 January 2012Arizona Bullhead City Mohave Valley Daily News 1 1 1 1 January 2012Arizona Casa Grande Dispatch 1 1 1 1 January 2012Arizona Chino Valley Chino Valley Review 1 1 January 2012Arizona Cottonwood The Bugle 1 1 January 2012Arizona Cottonwood The Verde Independent 1 1 1 1 January 2012Arizona Douglas The Daily Dispatch 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 159 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceArizona Flagstaff Arizona Daily Sun 1 1 January 2012Arizona Gilbert Chandler Tribune 1 1 January 2012Arizona Globe Arizona Silver Belt 1 1 January 2012Arizona Green Valley Green Valley News & Sun 1 1 January 2012Arizona Green Valley The Sahuarita News and Sun 1 1 January 2012Arizona Holbrook Holbrook Tribune - News 1 1 January 2012Arizona Kingman Daily Miner 1 1 1 1 January 2012Arizona Lake Havasu City Todays News-Herald 1 1 1 1 January 2012Arizona Mesa The Tribune 1 1 January 2012Arizona Nogales Nogales Internationals 1 1 January 2012Arizona Parker Parker Pioneer 1 1 January 2012Arizona Phoenix Ahwatukee Foothills News 1 1 January 2012Arizona Phoenix La Voz 1 1 January 2012Arizona Phoenix Republic & Sunday Select 1 1 January 2012Arizona Prescott Daily Courier 1 1 1 1 January 2012Arizona Prescott Valley Prescott Valley Tribune 1 1 January 2012Arizona Safford Eastern Arizona Courier 1 1 1 1 January 2012Arizona Show Low White Mountain Independent 1 1 January 2012Arizona Sierra Vista Herald 1 1 1 1 January 2012Arizona Sun City Glendale/Peoria Today 1 1 January 2012Arizona Sun City News-Sun 1 1 1 1 January 2012Arizona Sun City Surprise Today 1 1 January 2012Arizona Tucson Star 1 1 1 1 January 2012Arizona Wickenburg Wickenburg Sun 1 1 January 2012Arizona Willcox Arizona Range News 1 1 January 2012Arizona Williams Williams-Grand Canyon News 1 1 January 2012Arizona Yuma Daily Sun 1 1 January 2012Arkansas Ashdown Little River News 1 1 January 2012Arkansas Atkins Atkins Chronicle 1 1 January 2012Arkansas Atkins The Dover Times 1 1 January 2012Arkansas Batesville Batesville Daily Guard 1 1 January 2012Arkansas Benton The Benton Courier 1 1 January 2012Arkansas Bentonville The Weekly Vista 1 1 January 2012Arkansas Berryville Carroll County News 1 1 January 2012Arkansas Blytheville Courier News 1 1 January 2012Arkansas Booneville Booneville Democrat 1 1 January 2012Arkansas Camden Camden News 1 1 January 2012Arkansas Charleston Charleston Express 1 1 January 2012Arkansas Cherokee Village The Villager Journal 1 1 January 2012Arkansas Conway Log Cabin Democrat 1 1 1 1 January 2012Arkansas Danville Yell County Record 1 1 January 2012Arkansas El Dorado News-Times 1 1 1 1 January 2012Arkansas Fayetteville Democrat-Gazette 1 1 1 1 January 2012Arkansas Fort Smith Times Record 1 1 January 2012Arkansas Greenwood Greenwood Democrat 1 1 January 2012Arkansas Harrison Times 1 1 1 1 January 2012Arkansas Heber Springs Cleburne County Sun-Times 1 1 January 2012Arkansas Helena Helena-West Helena Daily World 1 1 January 2012Arkansas Hope Hope Star 1 1 January 2012Arkansas Hope The Daily Siftings Herald 1 1 January 2012Arkansas Hot Springs Sentinel-Record 1 1 1 1 January 2012Arkansas Jonesboro Sun 1 1 January 2012Arkansas Little Rock Democrat-Gazette 1 1 January 2012Arkansas Lonoke Democrat 1 1 January 2012Arkansas Magnolia Banner-News 1 1 January 2012Arkansas Malvern Malvern Daily Record 1 1 January 2012Arkansas Manila Northeast Arkansas Town Crier 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 160 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceArkansas Melbourne The Melbourne Times 1 1 January 2012Arkansas Mountain Home Baxter Bulletin 1 1 January 2012Arkansas Mountain View Stone County Leader 1 1 January 2012Arkansas Nashville Nashville News 1 1 January 2012Arkansas Newport Newport Independent 1 1 January 2012Arkansas Osceola The Osceola Times 1 1 January 2012Arkansas Paragould Daily Press 1 1 January 2012Arkansas Paris Paris Express 1 1 January 2012Arkansas Piggott Piggott Times 1 1 January 2012Arkansas Pine Bluff Commercial 1 1 January 2012Arkansas Rector Clay County Democrat 1 1 January 2012Arkansas Russellville Courier 1 1 January 2012Arkansas Salem Alma Journal 1 1 January 2012Arkansas Salem The News 1 1 January 2012Arkansas Searcy Citizen 1 1 January 2012Arkansas Sherwood Voice 1 1 January 2012Arkansas Stuttgart Daily Leader 1 1 January 2012Arkansas Trumann Tri-City Tribune 1 1 January 2012Arkansas Trumann Trumann Democrat 1 1 January 2012Arkansas Van Buren County Democrat 1 1 January 2012Arkansas Van Buren Press Argus Courier 1 1 1 1 January 2012Arkansas West Memphis Evening Times 1 1 January 2012Arkansas White Hall The White Hall Journal 1 1 January 2012California Auburn Journal 1 1 January 2012California Avenal Avenal Progress 1 1 January 2012California Bakersfield Californian 1 1 January 2012California Benicia Herald 1 1 January 2012California Big Bear Lake Grizzly Weekender 1 1 January 2012California Blythe Palo Verde Valley Times(/Quartszite 1 1 January 2012California Burney Intermountain News 1 1 January 2012California Chester Chester Progressive 1 1 January 2012California Chico Enterprise-Record 1 1 1 1 January 2012California Coalinger Coalinger Record 1 1 January 2012California Davis Enterprise 1 1 January 2012California Dos Palas The Dos Palos Sun 1 1 January 2012California El Centro Imperial Valley Press 1 1 1 1 January 2012California Escalon Escalon Times 1 1 January 2012California Escondido-Oceanside-Vista-San Marcos North County Times 1 1 January 2012California Eureka Times-Standard 1 1 1 1 January 2012California Exeter The Exeter Sun dba The Foothills Sun 1 1 January 2012California Fairfield Republic 1 1 1 1 January 2012California Fort Bragg Fort Bragg Advocate News 1 1 January 2012California Fresno Bee 1 1 January 2012California Gilroy The Dispatch 1 1 January 2012California Glendale Glenside News-Press 1 1 January 2012California Grass Valley The Union 1 1 1 1 January 2012California Greenville Indian Valley Record 1 1 January 2012California Gridley The Gridley Herald 1 1 January 2012California Handford Central Valley Guide 1 1 January 2012California Handford Golden Eagle 1 1 January 2012California Handford Sentinel 1 1 1 1 January 2012California Handford Twin City Times 1 1 January 2012California Hollister Free Lance 1 1 January 2012California Holtville Calexico Chronicle 1 1 January 2012California Holtville Holtville Tribune 1 1 January 2012California Holtville Imperial Valley Weekly 1 1 January 2012California Idyllwild Idyllwild Town Crier 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 161 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceCalifornia Inyo Inyo Register 1 1 January 2012California Jackson Amador Ledger-Dispatch 1 1 January 2012California Kingsburg The Kingsburg Recorder 1 1 January 2012California La Canada Flintridge La Canada Valley Sun 1 1 January 2012California Laguna Beach Coastline Pilot 1 1 January 2012California Lakeport Record-Bee 1 1 1 1 January 2012California Lemoore Le Moore Advance 1 1 January 2012California Lodi News-Sentinel 1 1 January 2012California Long Beach Impacto USA 1 1 January 2012California Los Angeles Daily News 1 1 January 2012California Los Angeles Times 1 1 January 2012California Los Angeles County Breeze 1 1 January 2012California Los Angeles County Press Telegram 1 1 January 2012California Los Angeles County Star News-Valley Tribune-Daily 1 1 January 2012California Madera Tribune 1 1 January 2012California Manteca The Manteca Bulletin 1 1 January 2012California Marin County Independent Journal 1 1 January 2012California Marysville Appeal-Democrat 1 1 January 2012California Merced Sun-Star 1 1 January 2012California Modesto Bee 1 1 January 2012California Monterey Herald 1 1 1 1 January 2012California Monterey The Valley Adviser 1 1 January 2012California Morgan Hill Morgan Hill Times 1 1 January 2012California Mount Shasta Mount Shasta Herald 1 1 January 2012California Napa Register 1 1 1 1 2 January 2012California Needles Needles Desert Star 1 1 January 2012California Oakdale Oakdale Leader 1 1 January 2012California Oakland Tribune 1 1 January 2012California Ontario City News 1 1 January 2012California Ontario Inland Valley Daily Bulletin 1 1 January 2012California Palm Springs Cathedral Sun 1 1 January 2012California Palm Springs Desert Sun Newspapers 1 1 January 2012California Palm Springs Indio Sun 1 1 January 2012California Palmdale Antelope Valley Press 1 1 1 1 January 2012California Palo Alto/Menlo Park Daily News 1 1 January 2012California Paradise Paradise Post 1 1 January 2012California Pasadena Weekly Star 1 1 January 2012California Placerville Mountain Democrat 1 1 1 1 January 2012California Porterville Recorder 1 1 1 1 January 2012California Portola Portola Reporter 1 1 January 2012California Quincy Feather River Bulletin 1 1 January 2012California Red Bluff News 1 1 1 1 January 2012California Redding Record Searchlight 1 1 January 2012California Redlands Facts 1 1 January 2012California Ridgecrest The Daily Independent 1 1 1 1 January 2012California Riverbank The Riverbank News 1 1 January 2012California Riverside La Prensa 1 1 January 2012California Riverside Press Enterprise 1 1 January 2012California Sacramento Bee 1 1 January 2012California Salinas Californian 1 1 January 2012California San Bernardino Sun 1 1 January 2012California San Diego La Jolla Village News 1 1 January 2012California San Diego Union-Tribune 1 1 January 2012California San Francisco Chronicle 1 1 January 2012California San Francisco Examiner 1 1 January 2012California San Gabriel Valley Highlander 1 1 January 2012California San Jose Mercury News 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 162 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceCalifornia San Jose Yes! Your essential Shopper 1 1 January 2012California San Luis Obispo Tribune 1 1 January 2012California San Mateo/Lompoc Times 1 1 January 2012California Santa Ana Orange CO Register 1 1 January 2012California Santa Barbara News-Press 1 1 1 1 January 2012California Santa Clarita The Signal 1 1 January 2012California Santa Cruz Sentinel 1 1 January 2012California Santa Maria/Lompoc Times-Record 1 1 1 1 January 2012California Santa Rosa Press Democrat 1 1 January 2012California Selma The Selma Enterprise 1 1 January 2012California Shasta Lake Shasta Lake Bulletin 1 1 January 2012California Sonora The Union Democrat 1 1 January 2012California South Lake Tahoe Tahoe Daily Tribune 1 1 January 2012California Stockton Record 1 1 January 2012California Susanville Lassen County Times 1 1 January 2012California Susanville Westwood Pinepress 1 1 January 2012California Taft Daily Midway Driller 1 1 January 2012California Tahoe City North Lake Tahoe Bonanza 1 1 January 2012California Tehachapi Tehachapi News 1 1 January 2012California Truckee Sierra Sun 1 1 January 2012California Tulare/Visalia Advance Register-Times-Delta 1 1 January 2012California Turlock Turlock Journal 1 1 January 2012California Twenty-nine Palms The Desert Trail 1 1 January 2012California Ukiah Journal 1 1 1 1 January 2012California Vacaville Reporter 1 1 1 1 January 2012California Vallejo Times-Herald 1 1 1 1 January 2012California Valley Springs The Valley Springs News 1 1 January 2012California Ventura County Star 1 1 January 2012California Victorville/Barstow Press-Desert Dispatch 1 1 1 1 2 January 2012California Watsonville Register-Pajaronian 1 1 January 2012California Willits The Willits News 1 1 January 2012California Woodland Democrat 1 1 1 1 January 2012California Yreka Siskiyou Daily News 1 1 1 1 January 2012California Yucca Valley Hi-Desert Star 1 1 1 1 January 2012California Yucca Valley Observation Post 1 1 January 2012Colorado Akron Akron News-Reporter 1 1 January 2012Colorado Aspen Times 1 1 January 2012Colorado Boulder Sunday Camera 1 1 January 2012Colorado Brush Brush News-Tribune 1 1 January 2012Colorado Burlington The Burlington Record 1 1 January 2012Colorado Canon City Daily Record 1 1 1 1 January 2012Colorado Colorado Springs Gazette 1 1 January 2012Colorado Craig Craig Daily Press 1 1 January 2012Colorado Denver Post-Rocky Mountain News 1 1 1 1 January 2012Colorado Durango/Cortez Herald-Journal 1 1 January 2012Colorado Estes Park Estes Park Trail-Gazette 1 1 January 2012Colorado Fort Collins Coloradoan 1 1 January 2012Colorado Fort Morgan Fort Morgan Times 1 1 January 2012Colorado Frisco Summit Daily News 1 1 January 2012Colorado Glenwood Springs Post Independent 1 1 January 2012Colorado Granby Sky Hi News 1 1 January 2012Colorado Grand Junction Daily Sentinel 1 1 January 2012Colorado Grand Junction Free Press 1 1 January 2012Colorado Greeley Tribune 1 1 January 2012Colorado Julesburg Julesburg Advocate 1 1 January 2012Colorado Lafayette Lafayette News 1 1 January 2012Colorado Longmont Times-Call 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 163 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceColorado Louisville Louisville Times 1 1 January 2012Colorado Loveland Reporter-Herald 1 1 1 1 January 2012Colorado Montrose Press 1 1 January 2012Colorado Pueblo Sunday Chieftain 1 1 January 2012Colorado Steamboat Springs Steamboat Pilot 1 1 January 2012Colorado Steamboat Springs Steamboat Today 1 1 1 1 January 2012Colorado Sterling Journal Advocate 1 1 January 2012Colorado Trinidad The Chronicle News 1 1 January 2012Colorado Vail Daily 1 1 January 2012Colorado Windsor Now 1 1 January 2012Connecticut Bridgeport Connecticut Post 1 1 January 2012Connecticut Danbury News-Times 1 1 January 2012Connecticut Greenwich Time 1 1 January 2012Connecticut Hartford Courant 1 1 January 2012Connecticut Manchester Journal Inquirer 1 1 1 1 January 2012Connecticut Meriden Record-Journal Publishing Co. 1 1 1 1 January 2012Connecticut Middletown Press 1 1 January 2012Connecticut New Britain Herald Press 1 1 January 2012Connecticut New Haven Register 1 1 January 2012Connecticut New London Day 1 1 January 2012Connecticut Norwalk Hour 1 1 1 1 January 2012Connecticut Norwich Bulletin 1 1 January 2012Connecticut Stamford Advocate 1 1 January 2012Connecticut Torrington Register Citizen 1 1 January 2012Connecticut Waterbury Republican-American 1 1 January 2012Connecticut Willimantic Chronicle 1 1 1 1 January 2012Deleware Dover Delaware State News 1 1 January 2012Deleware Newark Newark Post 1 1 January 2012Deleware Newark Route 40 Flier 1 1 January 2012Deleware Wilmington News Journal 1 1 January 2012District of Columbia Washington Examiner 1 1 January 2012District of Columbia Washington Times 1 1 January 2012District of Columbia Washington Washington Post 1 1 January 2012Florida Bartow The Polk County Democrat 1 1 January 2012Florida Bradenton Herald 1 1 January 2012Florida Brooksville Hernando Today 1 1 1 1 January 2012Florida Cape Coral Daily Breeze 1 1 January 2012Florida Charlotte Harbor/Port Charlotte Sun 1 1 1 1 January 2012Florida Chiefland Chiefland Citizen 1 1 January 2012Florida Coral Springs Forum 1 1 January 2012Florida Crawfordville The Wakulla News 1 1 January 2012Florida Crescent City Courier Journal 1 1 January 2012Florida Cross City Dixie County Advocate 1 1 January 2012Florida Crystal River Citrus County Chronicle 1 1 January 2012Florida Daytona Beach News-Journal 1 1 January 2012Florida Deerfield Forum 1 1 January 2012Florida Deland DeLand - Deltona Beacon 1 1 January 2012Florida Dunnellon Riverland News 1 1 January 2012Florida Eastpoint Franklin Chronicle 1 1 January 2012Florida Fernandina Beach Fernandina Beach News-Leader 1 1 January 2012Florida Fort Meade The Fort Meade Leader 1 1 January 2012Florida Ft. Lauderdale East Side Forum 1 1 January 2012Florida Ft. Lauderdale El Sentinel 1 1 January 2012Florida Ft. Lauderdale/South Florida Sun-Sentinel 1 1 January 2012Florida Ft. Myers News-Press 1 1 January 2012Florida Ft. Walton Beach Northwest Florida News 1 1 January 2012Florida Gainesville Sun 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 164 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceFlorida Jackson County Floridian 1 1 January 2012Florida Jacksonville The Beaches Leader 1 1 January 2012Florida Jacksonville The Florida Times-Union 1 1 1 1 January 2012Florida Kissimmee Osceola News-Gazette 1 1 1 1 January 2012Florida Lake City Reporter 1 1 1 1 January 2012Florida Lake Placid Lake Placid Journal 1 1 January 2012Florida Lake Wales Frostproof News 1 1 January 2012Florida Lake Wales Lake Wales News 1 1 January 2012Florida Lakeland Ledger 1 1 January 2012Florida Leesburg Commercial 1 1 January 2012Florida Live Oak Suwannee Democrat 1 1 1 1 2 January 2012Florida Madison The Madison Enterprise-Recorder 1 1 January 2012Florida Margate The Forum 1 1 January 2012Florida Marianna Jackson County Floridan 1 1 January 2012Florida Melbourne Florida Today & Sunday Select 1 1 January 2012Florida Miami El Nuevo Herald 1 1 January 2012Florida Miami Miami Herald 1 1 January 2012Florida Naples Daily News 1 1 January 2012Florida Ocala Star-Banner 1 1 January 2012Florida Orlando El Sentinel 1 1 January 2012Florida Orlando Sentinel 1 1 January 2012Florida Orlando Whats The Deal 1 1 January 2012Florida Panama City News Herald/Freedom Florida 1 1 January 2012Florida Pensacola News Journal 1 1 January 2012Florida Pompano Beach Forum 1 1 January 2012Florida Quincy Gadsden County Times 1 1 January 2012Florida Sarasota Herald-Tribune 1 1 January 2012Florida Sebring Highlands Today 1 1 1 1 January 2012Florida St. Augustine Record 1 1 1 1 January 2012Florida St. Petersburg Times 1 1 January 2012Florida Stuart Treasure Coast News/Press-Tribune 1 1 January 2012Florida Tallahassee Democrat 1 1 January 2012Florida Tampa Centro Mi Diario 1 1 January 2012Florida Tampa Tribune & Times 1 1 January 2012Florida Tampa/Newport Richey Suncoast Newspapers 1 1 January 2012Florida The Villages Daily Sun 1 1 1 1 2 January 2012Florida Venice Hardee Sun 1 1 January 2012Florida Venice Venice Gondolier Sun 1 1 January 2012Florida Wauchula The Herald Advocate 1 1 January 2012Florida West Palm Beach Post 1 1 January 2012Florida Winter Haven News Chief 1 1 1 1 January 2012Florida Winter Park The Voice (Oviedo) 1 1 January 2012Georgia Albany Herald 1 1 January 2012Georgia Americus Times-Recorder 1 1 January 2012Georgia Athens Banner-Herald 1 1 1 1 January 2012Georgia Atlanta Journal & Constitution 1 1 January 2012Georgia Augusta Chronicle 1 1 1 1 January 2012Georgia Augusta North Augusta Today 1 1 January 2012Georgia Bainbridge The Post Searchlight 1 1 January 2012Georgia Blakely Early County News 1 1 January 2012Georgia Brunswick The Brunswick News 1 1 January 2012Georgia Cairo The Cairo Messenger 1 1 January 2012Georgia Canton Cherokee Tribune 1 1 January 2012Georgia Carrollton Times-Georgian 1 1 January 2012Georgia Cartersville The Daily Tribune News 1 1 1 1 January 2012Georgia Clayton The Clayton Tribune 1 1 January 2012Georgia Columbus Ledger-Enquirer 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 165 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceGeorgia Cordele Dispatch 1 1 January 2012Georgia Covington The Covington News 1 1 January 2012Georgia Cumming Forysth County News 1 1 1 1 January 2012Georgia Cummings South Forsyth News 1 1 January 2012Georgia Dalton Citizen 1 1 January 2012Georgia Dawsonville Dawson Community News 1 1 January 2012Georgia Douglas County Sentinel 1 1 January 2012Georgia Dublin Courier Herald 1 1 January 2012Georgia Eatonton The Eatonton Messenger 1 1 January 2012Georgia Fayetteville Fayette Daily News 1 1 January 2012Georgia Fayetteville Today in Peachtree City 1 1 January 2012Georgia Forsyth The Monroe County Reporter 1 1 January 2012Georgia Gainesville Times 1 1 January 2012Georgia Gray The Jones County News 1 1 January 2012Georgia Griffin News 1 1 January 2012Georgia Hawkinsville Hawkinsville Dispatch & News 1 1 January 2012Georgia Hinesville Coastal Courier 1 1 January 2012Georgia Jesup The Press-Sentinel 1 1 January 2012Georgia Jonesboro/McDonough News-Daily Herald 1 1 January 2012Georgia LaGrange LaGrange Daily News 1 1 1 1 January 2012Georgia Lawrenceville/Conyers/Rockdale Daily Post-Citizen 1 1 January 2012Georgia Louisville The News & Farmer 1 1 January 2012Georgia Macon Telegraph 1 1 January 2012Georgia Marietta Daily Journal-Cherokee Tribune- 1 1 January 2012Georgia Milledgeville The Baldwin Bulletin 1 1 January 2012Georgia Milledgeville Union-Recorder 1 1 January 2012Georgia Monroe The Walton Tribune 1 1 January 2012Georgia Montezuma The Citizen and Georgian 1 1 January 2012Georgia Moultrie Observer 1 1 January 2012Georgia Newnan Times-Herald 1 1 January 2012Georgia Perry Houston Journal 1 1 January 2012Georgia Reidsville The Tattnall Journal 1 1 January 2012Georgia Richmond Hill Bryan County News 1 1 January 2012Georgia Rome News Tribune 1 1 January 2012Georgia Savannah Morning News 1 1 1 1 January 2012Georgia Statesboro Herald 1 1 January 2012Georgia Sylvania The Sylvania Telephone 1 1 January 2012Georgia Thomaston The Thomaston Times 1 1 January 2012Georgia Thomasville Times-Enterprise 1 1 January 2012Georgia Thomson McDuffie Mirror 1 1 January 2012Georgia Tifton Gazette 1 1 January 2012Georgia Valdosta Times 1 1 January 2012Georgia Winder The Barrow County News 1 1 January 2012Hawaii Hilo Tribune-Herald 1 1 January 2012Hawaii Honolulu Advertiser 1 1 January 2012Hawaii Kailua/Kona West Hawaii Today 1 1 January 2012Hawaii Lihue Garden Island 1 1 January 2012Hawaii Wailuku Maui News 1 1 January 2012Idaho Aberdeen The Aberdeen Times 1 1 January 2012Idaho American Falls Power County Press 1 1 January 2012Idaho Blackfoot The Morning News 1 1 January 2012Idaho Boise Idaho Statesman 1 1 January 2012Idaho Coeur DAlene Press 1 1 1 1 January 2012Idaho Grangeville Idaho County Free Press 1 1 January 2012Idaho Idaho Falls Post-Register 1 1 January 2012Idaho Kellogg Shoshone News-Press 1 1 January 2012Idaho Lewiston-Clarkson Morning Tribune 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 166 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceIdaho Moscow The Moscow-Pullman Daily News 1 1 1 1 January 2012Idaho Mt. Home Mountain Home News 1 1 January 2012Idaho Nampa-Caldwell Idaho Press-Tribune 1 1 January 2012Idaho Payette Independent Enterprise 1 1 January 2012Idaho Pocatello Idaho State Journal 1 1 January 2012Idaho Preston The Preston Citizen 1 1 January 2012Idaho Priest River Priest River Times 1 1 January 2012Idaho Rexburg Standard Journal 1 1 1 1 January 2012Idaho Sandpoint Bonner County Daily Bee 1 1 January 2012Idaho Sandpoint Bonners Ferry Herald 1 1 January 2012Idaho Twin Falls Times-News 1 1 January 2012Illinois Aledo The Times Record 1 1 January 2012Illinois Alton/East Alton/Wood River Telegraph 1 1 1 1 January 2012Illinois Arlington Heights Reflejos 1 1 January 2012Illinois Aurora Beacon News 1 1 January 2012Illinois Belleville News-Democrat 1 1 January 2012Illinois Benton Evening News 1 1 1 1 January 2012Illinois Bloomington-Normal Pantagraph 1 1 January 2012Illinois Canton The Daily Ledger 1 1 1 1 January 2012Illinois Carbondale The Southern Illinoisan 1 1 1 1 January 2012Illinois Carlinville Macoupin County Enquirer Democrat 1 1 January 2012Illinois Centralia Morning Sentinel 1 1 January 2012Illinois Champaign-Urbana News-Gazette 1 1 January 2012Illinois Chester Randolph County Herald-Tribune 1 1 January 2012Illinois Chicago La Raza 1 1 January 2012Illinois Chicago News Crusader 1 1 January 2012Illinois Chicago Redeye 1 1 January 2012Illinois Chicago Sun-Times 1 1 January 2012Illinois Chicago Tribune 1 1 January 2012Illinois Christopher The Progress 1 1 January 2012Illinois Crystal Lake Lake County Journals 1 1 January 2012Illinois Crystal Lake Northwest Herald 1 1 1 1 January 2012Illinois Danville Commercial-News 1 1 January 2012Illinois De Kalb Daily Chronicle 1 1 January 2012Illinois Decatur Herald & Review 1 1 January 2012Illinois Dekalb The Daily Chronicle 1 1 January 2012Illinois Downers Grove Press Publications 1 1 January 2012Illinois Du Quoin Evening Call 1 1 1 1 January 2012Illinois Effingham Daily News 1 1 1 1 2 January 2012Illinois Eldorado Journal 1 1 January 2012Illinois Elgin Courier News 1 1 January 2012Illinois Elmhurst Press Publications 1 1 January 2012Illinois Fairbury The Blade 1 1 January 2012Illinois Flora The Clay County Advocate-Press 1 1 January 2012Illinois Freeport Journal-Standard 1 1 1 1 January 2012Illinois Galesburg Register-Mail 1 1 January 2012Illinois Galesburg The Paper 1 1 January 2012Illinois Geneseo Geneseo Republic. 1 1 January 2012Illinois Geneva Kane County Chronicle 1 1 January 2012Illinois Harrisburg Register 1 1 1 1 January 2012Illinois Herrin The Spokesman 1 1 January 2012Illinois Hillsboro The Journal News 1 1 January 2012Illinois Jacksonville Journal-Courier 1 1 1 1 January 2012Illinois Joliet Herald-News 1 1 January 2012Illinois Kankakee The Daily Journal 1 1 1 1 January 2012Illinois Kewanee Star-Courier 1 1 1 1 January 2012Illinois La Salle La Salle News Tribune 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 167 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceIllinois Lemont Reporter-Courier 1 1 January 2012Illinois Lena Northwestern Illinois Farmers 1 1 January 2012Illinois Lincoln The Courier 1 1 January 2012Illinois Loves Park Rock Valley Publishing 1 1 January 2012Illinois Machesney Park Elmhurst Independent 1 1 January 2012Illinois Macomb Journal 1 1 1 1 January 2012Illinois Marion Republican 1 1 1 1 January 2012Illinois Metamora Metamora Herald 1 1 January 2012Illinois Metropolis Metropolis Planet 1 1 January 2012Illinois Moline The Dispatch/Rock Island Argus 1 1 January 2012Illinois Monmouth Review Atlas 1 1 1 1 January 2012Illinois Morris Daily Herald 1 1 1 1 January 2012Illinois Mount Carmel Daily Republican-Register 1 1 January 2012Illinois Mount Vernon Register-News 1 1 1 1 January 2012Illinois Murphysboro Murphysboro American 1 1 January 2012Illinois Naperville Sun 1 1 January 2012Illinois Newton Newton Press-Mentor 1 1 January 2012Illinois Oak Brook Suburban Life 1 1 January 2012Illinois Olney Olney Daily Mail 1 1 1 1 January 2012Illinois Oquawka Oquawka Current 1 1 January 2012Illinois Ottawa The Times 1 1 1 1 January 2012Illinois Palos Heights The Regional News 1 1 January 2012Illinois Paris Paris - Beacon News 1 1 January 2012Illinois Pekin Daily Times 1 1 1 1 January 2012Illinois Peoria Chillicothe Times-Bulletin 1 1 January 2012Illinois Peoria East Peoria Times-Courier 1 1 January 2012Illinois Peoria Journal Star 1 1 January 2012Illinois Peoria Morton Times-News 1 1 January 2012Illinois Peoria Peoria Times-Observer 1 1 January 2012Illinois Peoria Washington Times-Reporter 1 1 January 2012Illinois Plainfield The Enterprise 1 1 January 2012Illinois Pontiac Leader 1 1 1 1 January 2012Illinois Quincy Herald-Whig 1 1 January 2012Illinois Rock Island/Moline/East Moline Argus-Dispatch 1 1 January 2012Illinois Rockford Register Star 1 1 1 1 January 2012Illinois Rushville The Rushville Times 1 1 January 2012Illinois Salem Salem Times Commoner 1 1 January 2012Illinois Shawneetown The Gallatin Democrat 1 1 January 2012Illinois Shelbyville Daily Union 1 1 1 1 January 2012Illinois Springfield State Journal-Register 1 1 January 2012Illinois St. Charles Chronicle 1 1 January 2012Illinois Sterling/Rock Falls Sauk Valley 1 1 1 1 January 2012Illinois Suburban Chicago Herald 1 1 January 2012Illinois Suburban Chicago Southtown 1 1 January 2012Illinois Taylorville Breeze Courier 1 1 January 2012Illinois Vandalia Leader-Union 1 1 January 2012Illinois Waukegan/Lake County News Sun 1 1 January 2012Illinois West Frankfort American 1 1 1 1 January 2012Illinois Zion Zion Benton News/Bargaineer 1 1 January 2012Indiana Anderson Herald Bulletin 1 1 January 2012Indiana Angola Herald-Republican 1 1 January 2012Indiana Auburn Evening Star 1 1 January 2012Indiana Batesville The Herald Tribune 1 1 1 1 January 2012Indiana Bedford The Bedford Times Mail 1 1 January 2012Indiana Bloomington The Herald Times 1 1 January 2012Indiana Bloomington-Bedfored-Martinsville Hoosier Times 1 1 January 2012Indiana Bluffton News-Banner 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 168 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceIndiana Boonville Boonville Standard 1 1 January 2012Indiana Brazil Brazil Times 1 1 January 2012Indiana Bremen The Bremen Enquirer 1 1 January 2012Indiana Columbia City The Post & Mail 1 1 January 2012Indiana Columbus Republic 1 1 January 2012Indiana Connersville News Examiner 1 1 January 2012Indiana Crawfordsville Journal Review 1 1 January 2012Indiana Culver The Culver Citizen 1 1 January 2012Indiana Decatur Decatur Daily Democrat 1 1 January 2012Indiana Elkhart Truth 1 1 January 2012Indiana Evansville Courier & Press 1 1 January 2012Indiana Fort Wayne Journal Gazette 1 1 January 2012Indiana Frankfort Times 1 1 January 2012Indiana Franklin Journal 1 1 January 2012Indiana French Lick Springs Valley Herald 1 1 January 2012Indiana Ft. Wayne News-Sentinel 1 1 January 2012Indiana Goshen News 1 1 January 2012Indiana Greencastle Banner - Graphic 1 1 January 2012Indiana Greenfield The Daily Reporter 1 1 January 2012Indiana Greensburg Greensburg Daily News 1 1 1 1 January 2012Indiana Hope The Hope Star-Journal 1 1 January 2012Indiana Huntington Herald-Press 1 1 January 2012Indiana Indianapolis Star & Sunday Select 1 1 January 2012Indiana Jasper Herald 1 1 January 2012Indiana Kendallville News-Sun 1 1 1 1 January 2012Indiana Knox The Leader 1 1 January 2012Indiana Kokomo Tribune 1 1 January 2012Indiana La Porte Herald Argus 1 1 January 2012Indiana Lafayette/West Lafayette Journal and Courier 1 1 January 2012Indiana LaPorte The LaPorte Herald Argus 1 1 January 2012Indiana Lawrenceburg Journal Press 1 1 January 2012Indiana Lebanon The Reporter 1 1 1 1 2 January 2012Indiana Linton The Daily World 1 1 January 2012Indiana Logansport Pharos-Tribune 1 1 January 2012Indiana Madison The Madison Courier 1 1 January 2012Indiana Marion Chronicle Tribune 1 1 January 2012Indiana Martinsville The Reporter-Times 1 1 January 2012Indiana Merriville Post-Tribune 1 1 January 2012Indiana Michigan City News-Dispatch 1 1 January 2012Indiana Mooresville The Mooresville/The Decatur 1 1 January 2012Indiana Mooresville/Decatur Reporter-Times 1 1 January 2012Indiana Muncie Star-Press 1 1 January 2012Indiana Munster Times of Northwest Indiana 1 1 January 2012Indiana Nappanee Nappanee Advance News 1 1 January 2012Indiana New Albany/Jeffersonville Evening News/Tribune 1 1 January 2012Indiana New Castle Courier-Times 1 1 January 2012Indiana North Vernon North Vernon Plain Dealer 1 1 January 2012Indiana Paoli Paoli Republican 1 1 January 2012Indiana Peru Tribune 1 1 January 2012Indiana Plymouth Bourbon News-Mirror 1 1 January 2012Indiana Plymouth Pilot News 1 1 January 2012Indiana Portland The Commercial Review 1 1 January 2012Indiana Princton Princeton Daily Clarion 1 1 January 2012Indiana Richmond Palladium-Item 1 1 January 2012Indiana Rochester The Rochester Sentinel 1 1 January 2012Indiana Rushville The Republican 1 1 1 2 January 2012Indiana Seymour Tribune 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 169 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceIndiana Shelbyville News 1 1 January 2012Indiana Shoals The Shoals News 1 1 January 2012Indiana South Bend-Mishawaka Tribune 1 1 January 2012Indiana Terre Haute Tribune-Star 1 1 January 2012Indiana Versailles The Versailles Republican 1 1 January 2012Indiana Vincennes Sun-Commercial 1 1 January 2012Indiana Wabash Plain Dealer 1 1 January 2012Indiana Warsaw Times-Union 1 1 January 2012Indiana Washington The Washington Times-Herald 1 1 January 2012Indiana Winchester The News-Gazette 1 1 January 2012Iowa Algona The Algona Upper Des Moines 1 1 January 2012Iowa Allison Butler County Tribune Journal 1 1 January 2012Iowa Ames Tribune 1 1 January 2012Iowa Armstrong Rock Valley Bee 1 1 January 2012Iowa Atlantic Atlantic News - Telegraph 1 1 January 2012Iowa Audubon Audubon County Advocate Journal 1 1 January 2012Iowa Bedford The Bedford Times-Press 1 1 January 2012Iowa Boone Boone News-Republican 1 1 January 2012Iowa Britt The Britt News Tribune 1 1 January 2012Iowa Burlington Hawk Eye 1 1 1 1 January 2012Iowa Carroll Daily Times Herald 1 1 January 2012Iowa Cascade Cascade Pioneer 1 1 January 2012Iowa Cedar Rapids-Marion Gazette 1 1 January 2012Iowa Centerville Daily Iowegian 1 1 1 1 January 2012Iowa Cherokee Chronicle Times 1 1 January 2012Iowa Clarinda Clarinda Herald-Journal 1 1 January 2012Iowa Clarksville Clarksville Star 1 1 January 2012Iowa Clinton Clinton Herald 1 1 1 1 January 2012Iowa Corwith CWL Times 1 1 January 2012Iowa Council Bluffs Nonpareil 1 1 1 1 January 2012Iowa Creston Creston News Advertiser 1 1 January 2012Iowa Davenport-Bettendorf Quad-City Times 1 1 January 2012Iowa Denison Denison Review 1 1 January 2012Iowa Des Moines Register & Sunday Select 1 1 January 2012Iowa Dows Dows Advocate 1 1 January 2012Iowa Dubuque Telegraph Herald 1 1 1 1 January 2012Iowa Dyersville Dyersville Commerical 1 1 January 2012Iowa Eagle Grove Eagle Grove Eagle 1 1 January 2012Iowa Fairfield The Fairfield Daily Ledger 1 1 January 2012Iowa Forest City Forest City Summit 1 1 January 2012Iowa Fort Dodge Messenger 1 1 January 2012Iowa Fort Madison Fort Madison Daily Democrat 1 1 January 2012Iowa Freemont Village Vine 1 1 January 2012Iowa Ft. Madison Daily Democrat 1 1 January 2012Iowa Garner Garner Leader & Signal 1 1 January 2012Iowa Grundy Grove The Grundy Register 1 1 January 2012Iowa Hamburg Hamburg Reporter 1 1 January 2012Iowa Hampton Calhoun County Advocate 1 1 January 2012Iowa Hampton Hampton Chonicle 1 1 January 2012Iowa Hampton Pioneer Enterprise 1 1 January 2012Iowa Harlan Harlan News-Advertiser 1 1 January 2012Iowa Hawarden The Independent/Examiner 1 1 January 2012Iowa Hull Sioux County Index-Reporter 1 1 January 2012Iowa Ida Grove Ida County Courier 1 1 January 2012Iowa Inwood West Lyon Herald 1 1 January 2012Iowa Iowa City Press-Citizen 1 1 January 2012Iowa Kalona The Kalona News 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 170 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceIowa Kalona The Lone Tree Reporter 1 1 January 2012Iowa Kanawha Kanawha Reporter 1 1 January 2012Iowa Keokuk Daily Gate City 1 1 1 1 January 2012Iowa Keota Keota Eagle 1 1 January 2012Iowa Knoxville Journal Express 1 1 1 1 2 January 2012Iowa Knoxville The Chronicle 1 1 January 2012Iowa Lake City Lake City Graphic 1 1 January 2012Iowa LeMars LeMars Daily Sentinel 1 1 January 2012Iowa Logan Logan Herald-Observer 1 1 January 2012Iowa Marshalltown Times-Republican 1 1 January 2012Iowa Mason City Sunday Globe 1 1 1 1 January 2012Iowa Mount Pleasant Mt. Pleasant News 1 1 January 2012Iowa Muscatine Journal 1 1 January 2012Iowa New Sharon New Sharon Sun 1 1 January 2012Iowa Newton Newton Daily News 1 1 January 2012Iowa Osage Mitchell County Press News 1 1 January 2012Iowa Osceola Osceola Sentinel-Tribune 1 1 January 2012Iowa Oskaloosa Oskaloosa Herald 1 1 1 1 January 2012Iowa Ottumwa The Ottumwa Courier 1 1 1 1 January 2012Iowa Rock Rapids Lyon County Reporter 1 1 January 2012Iowa Sheffield Sheffield Press 1 1 January 2012Iowa Shenandoah Valley News Today 1 1 January 2012Iowa Sigourney Sigourney News Review 1 1 January 2012Iowa Sioux City Journal 1 1 1 1 January 2012Iowa Spencer The Daily Reporter 1 1 January 2012Iowa Spirit Lake Dickinson County News 1 1 January 2012Iowa Storm Lake Pilot Tribune 1 1 January 2012Iowa Story City The Story City Herald 1 1 January 2012Iowa Tipton The Tipton Conservative and 1 1 January 2012Iowa Washington The Washington Evening Journal 1 1 January 2012Iowa Waterloo-Cedar Falls-Evansdale Courier 1 1 January 2012Iowa West Branch West Branch Times 1 1 January 2012Iowa West Liberty The West Liberty Index 1 1 January 2012Iowa What Cheer What Cheer Paper 1 1 January 2012Iowa Woodbine The Woodbine Twiner 1 1 January 2012Kansas Abilene Abilene Reflector-Chronicle 1 1 1 1 January 2012Kansas Arkansas City Traveler 1 1 January 2012Kansas Atchison Atchison Daily Globe 1 1 January 2012Kansas Augusta Augusta Daily Gazette 1 1 January 2012Kansas Baxter Springs Baxter Springs News 1 1 January 2012Kansas Chanute The Chanute Tribune 1 1 1 1 January 2012Kansas Coffeyville The Coffeyville Journal 1 1 January 2012Kansas Columbus The Columbus Advocate 1 1 January 2012Kansas Dodge City Globe 1 1 January 2012Kansas El Dorado The El Dorado Times 1 1 January 2012Kansas Ellsworth Ellsworth County 1 1 January 2012Kansas Emporia Gazette 1 1 January 2012Kansas Eureka The Eureka Herald 1 1 January 2012Kansas Garden City Telegram 1 1 January 2012Kansas Garnett The Anderson County Review 1 1 January 2012Kansas Goodland The Goodland Daily News 1 1 January 2012Kansas Great Bend The Great Bend Tribune 1 1 January 2012Kansas Hays News 1 1 1 1 January 2012Kansas Herington The Herington Times 1 1 January 2012Kansas Hiawatha Hiawatha World 1 1 January 2012Kansas Holton The Holton Recorder 1 1 January 2012Kansas Hutchinson The Hutchinson News 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 171 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceKansas Junction City The Daily Union 1 1 January 2012Kansas Lawrence Journal-World 1 1 1 1 January 2012Kansas Leavenworth Times 1 1 January 2012Kansas Liberal Southwest Daily Times 1 1 January 2012Kansas Louisburg Louisburg Herald 1 1 January 2012Kansas Manhattan Mercury 1 1 January 2012Kansas McPherson McPherson Sentinel 1 1 January 2012Kansas Newton Kansan 1 1 January 2012Kansas Norton The Norton Telegram 1 1 January 2012Kansas Oberlin Bird City Times 1 1 January 2012Kansas Oberlin Colby Free Press 1 1 January 2012Kansas Oberlin The Oberlin Herald 1 1 January 2012Kansas Oberlin The St. Francis Herald 1 1 January 2012Kansas Osawatomie Osawatomie Graphic 1 1 January 2012Kansas Oskaloosa The Oskaloosa Independent 1 1 January 2012Kansas Ottawa The Ottawa Herald 1 1 1 1 January 2012Kansas Overland Park Blue Valley Sun 1 1 January 2012Kansas Overland Park Johnson County Sun 1 1 January 2012Kansas Overland Park Overland Park Sun 1 1 January 2012Kansas Overland Park Wednesday Sun 1 1 January 2012Kansas Paola The Miami County Republic 1 1 January 2012Kansas Parsons Parsons Sun 1 1 1 1 January 2012Kansas Pittsburg Sun 1 1 1 1 January 2012Kansas Pratt The Pratt Tribune 1 1 January 2012Kansas Salina Journal 1 1 1 1 January 2012Kansas Shawnee The Shawnee Dispatch 1 1 January 2012Kansas Stockton Stockton Sentinel 1 1 January 2012Kansas Topeka Capital-Journal 1 1 1 1 January 2012Kansas Valley Falls The Vindicator 1 1 January 2012Kansas Wellington Wellington Daily News 1 1 January 2012Kansas Wichita Eagle 1 1 January 2012Kansas Winfield Courier 1 1 January 2012Kentucky Ashland Sunday Independent 1 1 January 2012Kentucky Bardstown Kentucky Standard 1 1 1 1 January 2012Kentucky Benton The Tribune Courier 1 1 January 2012Kentucky Bowling Green Daily News 1 1 1 1 January 2012Kentucky Brownsville Edmonson News 1 1 January 2012Kentucky Cadiz The Cadiz Record 1 1 January 2012Kentucky Corbin Times-Tribune 1 1 1 1 January 2012Kentucky Danville The Advocate Messenger 1 1 1 1 January 2012Kentucky Eddyville Lyon County Herald-Ledger 1 1 January 2012Kentucky Elizabethtown News-Enterprise 1 1 January 2012Kentucky Falmouth The Falmouth Outlook 1 1 January 2012Kentucky Flemingsburg Flemingsburg Gazette 1 1 January 2012Kentucky Frankfort The State Journal 1 1 1 1 January 2012Kentucky Fulton The Fulton Leader 1 1 January 2012Kentucky Georgetown Georgetown News Graphic 1 1 January 2012Kentucky Glasgow Daily Times 1 1 January 2012Kentucky Greenup Greenup County News-Times 1 1 January 2012Kentucky Harlan Enterprise 1 1 January 2012Kentucky Henderson Gleaner 1 1 January 2012Kentucky Hopkinsville Kentucky New Era 1 1 1 1 January 2012Kentucky Leitchfield Grayson Co. News - Gazette 1 1 January 2012Kentucky Lexington Herald-Leader 1 1 January 2012Kentucky Liberty Casey County News 1 1 January 2012Kentucky London The Sentinel-Echo 1 1 1 1 2 January 2012Kentucky Louisville Courier-Journal & Sunday Select 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 172 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceKentucky Madisonville Messenger 1 1 January 2012Kentucky Maysville Ledger Independent 1 1 January 2012Kentucky Middlesboro The Daily News 1 1 1 1 January 2012Kentucky Monticello The Wayne County Outlook 1 1 January 2012Kentucky New Castle Henry County Local 1 1 January 2012Kentucky Nicholasville The Jessamine Journal 1 1 January 2012Kentucky Oak Grove The Eagle Post 1 1 January 2012Kentucky Owensboro Messenger-Inquirer 1 1 January 2012Kentucky Paducah Sun 1 1 January 2012Kentucky Pikeville Appalachian News Express 1 1 January 2012Kentucky Prestonsburg The Floyd County Times 1 1 January 2012Kentucky Princeton The Times - Leader 1 1 January 2012Kentucky Richmond Register 1 1 January 2012Kentucky Russellville News Democrat 1 1 1 1 January 2012Kentucky Salyersville The Salyersville Independent 1 1 January 2012Kentucky Shepherdsville The Pioneer News 1 1 January 2012Kentucky Somerset Commonwealth Journal 1 1 January 2012Kentucky Taylorsville Taylorsville Spencer Magnet 1 1 January 2012Kentucky Whitley City The McCreary County Record 1 1 January 2012Kentucky Winchester Sun 1 1 1 1 January 2012Louisianna Bastrop Bastrop Daily Enterprise 1 1 January 2012Lousianna Abbeville Meridonial-News-Gazette 1 1 January 2012Lousianna Alexandria Town Talk 1 1 January 2012Lousianna Baton Rouge Sunday Advocate 1 1 January 2012Lousianna Belle Chasse The Plaquemines Watchman 1 1 January 2012Lousianna Bogalusa Daily News 1 1 1 1 January 2012Lousianna Bossier City Bossier Press-Tribune 1 1 January 2012Lousianna Covington St. Tammany News 1 1 1 1 January 2012Lousianna Crowley Post Signal 1 1 January 2012Lousianna DeRidder Beauregard Daily News 1 1 January 2012Lousianna Gonzales Ascension Citizen 1 1 January 2012Lousianna Hammond Star 1 1 January 2012Lousianna Houma Courier 1 1 January 2012Lousianna Jena The Jena - Times 1 1 January 2012Lousianna La Place LObserveteur 1 1 1 1 January 2012Lousianna Lafayette Advertiser 1 1 January 2012Lousianna Lake Charles American Press 1 1 January 2012Lousianna Leesville Leesville News Leader 1 1 January 2012Lousianna Minden Minden Press-Herald 1 1 January 2012Lousianna Monroe News-Star 1 1 January 2012Lousianna New Iberia Sunday Iberian 1 1 January 2012Lousianna New Orleans Times-Picayune 1 1 January 2012Lousianna Opelousas World 1 1 January 2012Lousianna Ruston Daily Leader 1 1 January 2012Lousianna Shreveport Times 1 1 January 2012Lousianna Sulphur Southwest Daily News 1 1 January 2012Lousianna Thibodaux Comet 1 1 January 2012Maine Augusta-Waterville Kennebec Journal-Morning Sentinel 1 1 January 2012Maine Bangor News 1 1 1 1 January 2012Maine Biddeford Journal-Tribune 1 1 January 2012Maine Lewiston/Auburn Sun-Journal 1 1 1 1 January 2012Maine Portland Maine Sunday Telegram 1 1 January 2012Maine Portland Portland Press Herald 1 1 January 2012Maryland Annapolis Capital 1 1 January 2012Maryland Annapolis Maryland Gazette 1 1 1 1 January 2012Maryland Baltimore Baltimore Weeklies 1 1 January 2012Maryland Baltimore Sunday Sun 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 173 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMaryland Baltimore Times 1 1 January 2012Maryland Centreville The Record-Observer 1 1 January 2012Maryland Chestertown Kent County News 1 1 January 2012Maryland Cumberland Times-News 1 1 January 2012Maryland Denton The Times Record 1 1 January 2012Maryland Easton Sunday Star 1 1 1 1 January 2012Maryland Elkton Cecil Whig 1 1 January 2012Maryland Frederick News-Post 1 1 1 1 January 2012Maryland Hagerstown Herald-Mail 1 1 January 2012Maryland Salisbury Times 1 1 January 2012Maryland Stevensville The Bay Times 1 1 January 2012Maryland Westminster Carrol County Times 1 1 1 1 January 2012Massachusetts Attleboro Sun Chronicle 1 1 1 1 January 2012Massachusetts Beverly News 1 1 January 2012Massachusetts Boston Herald 1 1 January 2012Massachusetts Boston Sunday Globe 1 1 January 2012Massachusetts Brockton Enterprise 1 1 January 2012Massachusetts Fall River Herald News 1 1 January 2012Massachusetts Fitchburg Sentinel & Enterprise 1 1 January 2012Massachusetts Framingham/Milford Metrowest News 1 1 January 2012Massachusetts Gloucester Daily Times 1 1 January 2012Massachusetts Greenfield Recorder 1 1 1 1 January 2012Massachusetts Hyannis/Cape Cod Cape Cod Times 1 1 January 2012Massachusetts Lowell Sun 1 1 January 2012Massachusetts New Bedford Sunday Standard-Times 1 1 January 2012Massachusetts Newburyport Daily News 1 1 January 2012Massachusetts North Adams Transcript 1 1 1 1 January 2012Massachusetts North Andover Eagle-Tribune 1 1 January 2012Massachusetts North Reading North Reading Transcript 1 1 January 2012Massachusetts North Reading The Lynnfield Villager 1 1 January 2012Massachusetts Northampton Hampshire Gazette 1 1 January 2012Massachusetts Pittsfield/Berkshire Eagle 1 1 January 2012Massachusetts Quincy Patriot Ledger 1 1 January 2012Massachusetts Springfield Sunday Republican 1 1 January 2012Massachusetts Taunton Gazette 1 1 January 2012Massachusetts Worcester Maine Sunday Telegram 1 1 January 2012Michigan Adrian Telegram 1 1 January 2012Michigan Alpena News 1 1 January 2012Michigan Ann Arbor News 1 1 January 2012Michigan Bad Axe Huron Daily Tribune 1 1 January 2012Michigan Battle Creek Enquirer 1 1 January 2012Michigan Bay City Times 1 1 January 2012Michigan Benton Harbor/St. Joseph Herald-Palladium 1 1 January 2012Michigan Big Rapids Big Rapids Pioneer 1 1 January 2012Michigan Big Rapids/Manistee Pioneer-News Advocate 1 1 January 2012Michigan Cadillac News 1 1 1 1 January 2012Michigan Caro Tuscola County Advertiser 1 1 January 2012Michigan Cheboygan Daily Tribune 1 1 1 1 January 2012Michigan Coldwater The Daily Reporter 1 1 1 1 January 2012Michigan Dearborn Press & Guide 1 1 January 2012Michigan Detroit News and Free Press & Sunday Select 1 1 January 2012Michigan Escanaba Press 1 1 January 2012Michigan Flint Journal 1 1 January 2012Michigan Grand Haven Tribune 1 1 January 2012Michigan Grand Rapids Press 1 1 January 2012Michigan Greenville News 1 1 January 2012Michigan Hart Oceanas Herald Journal 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 174 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMichigan Hillsdale News 1 1 1 1 January 2012Michigan Holland Sentinel 1 1 1 1 January 2012Michigan Houghton Mining Gazette 1 1 January 2012Michigan Howell Livingston County Daily Press & 1 1 1 1 January 2012Michigan Ionia Sentinel-Standard 1 1 January 2012Michigan Iron Mountain/Kingsford News 1 1 January 2012Michigan Ironwood (The Ironwood) Daily Globe 1 1 January 2012Michigan Jackson Citizen Patriot 1 1 January 2012Michigan Kalamazoo Gazette 1 1 January 2012Michigan Lansing Lansing Community Newspapers 1 1 January 2012Michigan Lansing State Journal 1 1 January 2012Michigan Lapeer The County Press 1 1 1 1 January 2012Michigan Livonia Canton Observer 1 1 January 2012Michigan Livonia Eccentric 1 1 January 2012Michigan Livonia Garden City Observer 1 1 January 2012Michigan Livonia Livonia Observer 1 1 1 1 January 2012Michigan Livonia Plymouth Observer 1 1 January 2012Michigan Livonia Rochester Eccentric 1 1 January 2012Michigan Livonia Westland Observer 1 1 January 2012Michigan Ludington Ludington Daily News 1 1 January 2012Michigan Manistee Manistee News Advocate 1 1 January 2012Michigan Marquette Mining Journal 1 1 January 2012Michigan Midland News 1 1 January 2012Michigan Milford Milford Times 1 1 January 2012Michigan Monroe Sunday News 1 1 January 2012Michigan Mount Clemens Macomb Daily 1 1 January 2012Michigan Mount Pleasant Morning Sun 1 1 January 2012Michigan Munising The Munising News 1 1 January 2012Michigan Muskegon Sunday Chronicle 1 1 January 2012Michigan New Baltimore The Weekend Voice 1 1 January 2012Michigan Northville Northville Record 1 1 January 2012Michigan Northville Novi News 1 1 January 2012Michigan Owosso Argus-Press 1 1 January 2012Michigan Petsokey Petoskey News-Review 1 1 January 2012Michigan Pontiac Oakland Press 1 1 January 2012Michigan Port Huron Times-Herald 1 1 January 2012Michigan Rogers City Onaway Outlook 1 1 January 2012Michigan Rogers City Presque Isle County Advance 1 1 January 2012Michigan Royal Oak Daily Tribune 1 1 January 2012Michigan Saginaw News 1 1 January 2012Michigan Sault Ste. Marie The Evening News 1 1 January 2012Michigan Shelby Advisor & Source Newspapers 1 1 January 2012Michigan South Lyon South Lyon Herald 1 1 January 2012Michigan Southgate News-Herald 1 1 January 2012Michigan Sturgis Sturgis Journal 1 1 1 1 January 2012Michigan Tecumseh The Tecumseh Herald 1 1 January 2012Michigan Three Rivers Three Rivers Commerical News 1 1 January 2012Michigan Traverse City Record-Eagle 1 1 January 2012Michigan Whitehall White Lake Beacon 1 1 January 2012Michigan Ypsilanti Ypsilanti Courier 1 1 January 2012Michigan Zeeland The Zeeland Record 1 1 January 2012Minnesota Aitkin Aitkin Independent Age 1 1 January 2012Minnesota Albert Lea Tribune 1 1 January 2012Minnesota Austin Daily Herald 1 1 January 2012Minnesota Bagley Farmers Independent 1 1 January 2012Minnesota Baudette The Baudette Region 1 1 January 2012Minnesota Bemidji Pioneer 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 175 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMinnesota Brainerd Dispatch 1 1 1 1 January 2012Minnesota Canby Canby News 1 1 January 2012Minnesota Clarissa Independent News Herald 1 1 January 2012Minnesota Cloquet The Pine Journal 1 1 January 2012Minnesota Cloquet The Pine Knot 1 1 January 2012Minnesota Cottonwood Tri-County News 1 1 January 2012Minnesota Crookston Crookston Daily Times 1 1 January 2012Minnesota Duluth News-Tribune 1 1 January 2012Minnesota Elbow Lake Grant County Herald 1 1 January 2012Minnesota Fairmont Sentinel 1 1 January 2012Minnesota Faribault Faribault Daily News 1 1 1 1 January 2012Minnesota Fergus Falls Journal 1 1 January 2012Minnesota Grand Rapids Herald Review 1 1 1 1 January 2012Minnesota Granite Falls Granite Falls Advocate-Tribune 1 1 January 2012Minnesota Hibbing The Daily Tribune 1 1 January 2012Minnesota Isle Mille Lacs Messenger 1 1 January 2012Minnesota Mankato Free Press 1 1 January 2012Minnesota Marshall Independent 1 1 January 2012Minnesota Minnesota Sun Papers 1 1 January 2012Minnesota Montevideo Montevideo American News 1 1 January 2012Minnesota Montgomery Montgomery Messenger 1 1 January 2012Minnesota New Prague The New Prague Times 1 1 January 2012Minnesota New Ulm Journal 1 1 January 2012Minnesota Northfield Northfield News 1 1 January 2012Minnesota Owatonna Peoples Press 1 1 1 1 January 2012Minnesota Paynesville The Paynesville Press 1 1 January 2012Minnesota Red Wing Republican Eagle 1 1 January 2012Minnesota Redwood Falls The Redwood Falls Gazette 1 1 January 2012Minnesota Rochester Post-Bulletin 1 1 1 1 January 2012Minnesota Sleepy Eye Sleepy Eye Herald - Dispatch 1 1 January 2012Minnesota St. Cloud Times 1 1 January 2012Minnesota St. James St. James Plaindealer 1 1 January 2012Minnesota St. Paul Pioneer Press 1 1 January 2012Minnesota St. Peter St. Peter Herald 1 1 January 2012Minnesota Staples Staples World 1 1 January 2012Minnesota Stillwater Gazette 1 1 January 2012Minnesota Thief River Falls Thief River Falls Times 1 1 January 2012Minnesota Virginia Mesabi News 1 1 1 1 2 January 2012Minnesota Waseca Waseca County News 1 1 January 2012Minnesota Westbrook Westbrook Sentinel/Tribune 1 1 January 2012Minnesota Willmar West Central Tribune 1 1 January 2012Minnesota Winona News 1 1 1 1 January 2012Minnesota Worthington Daily Globe 1 1 January 2012Mississippi Aberdeen The Monroe County Journal 1 1 January 2012Mississippi Batesville Panola Partnership 1 1 January 2012Mississippi Batesville The Panolian 1 1 January 2012Mississippi Biloxi-Gulfport Sun Herald 1 1 January 2012Mississippi Brandon Rankin County News 1 1 January 2012Mississippi Brookhaven Daily Leader 1 1 January 2012Mississippi Calhoun City The Monitor-Herald 1 1 January 2012Mississippi Clarksdale Press Register 1 1 1 1 January 2012Mississippi Cleveland Bolivar Commerical 1 1 1 1 January 2012Mississippi Columbus Commercial Dispatch 1 1 January 2012Mississippi Corinth Corinthian 1 1 January 2012Mississippi Crystal Springs The Meteor 1 1 January 2012Mississippi Fulton The Itawamba County Times 1 1 January 2012Mississippi Greenville Delta Democrat-Times 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 176 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMississippi Greenwood Commonwealth 1 1 January 2012Mississippi Grenada The Daily Star 1 1 January 2012Mississippi Hattiesburg American 1 1 January 2012Mississippi Hazelhurst Copiah County Courier 1 1 January 2012Mississippi Holly Springs The South Reporter 1 1 January 2012Mississippi Houston The Chickasaw Journal 1 1 January 2012Mississippi Jackson Clarion-Ledger 1 1 January 2012Mississippi Kosciusko The Star-Herald 1 1 January 2012Mississippi Laurel Laurel Leader-Call 1 1 1 1 January 2012Mississippi McComb Enterprise-Journal 1 1 January 2012Mississippi Meadville Wilk-Amite Record 1 1 January 2012Mississippi Meridan The Meridian Star 1 1 1 1 January 2012Mississippi Monticello Lawrence County Press 1 1 January 2012Mississippi Morton Spirit of Morton 1 1 January 2012Mississippi Natchez Democrat 1 1 January 2012Mississippi New Albany New Albany Gazette 1 1 January 2012Mississippi Oxford The Oxford Eagle 1 1 January 2012Mississippi Philadelphia Kemper County Messener 1 1 January 2012Mississippi Philadelphia The Neshoba Democrat 1 1 January 2012Mississippi Picayune Item 1 1 January 2012Mississippi Pontotoc The Pontotoc Progress 1 1 January 2012Mississippi Senatobia The Democrat 1 1 January 2012Mississippi Starkville Starkville Daily News 1 1 January 2012Mississippi Tupelo Northeast Mississippi Journal 1 1 January 2012Mississippi Tylertown The Tylertown Times 1 1 January 2012Mississippi Vicksburg Post 1 1 1 1 January 2012Mississippi West Point Daily Times Leader 1 1 January 2012Missouri Aurora Aurora Advertiser 1 1 January 2012Missouri Bloomfield The North Stoddard Countian 1 1 January 2012Missouri Bolivar Bolivar Herald -Free Press 1 1 January 2012Missouri Boonville Boonville Daily News 1 1 January 2012Missouri Branson The Ozarks Sentinel 1 1 January 2012Missouri Buffalo Buffalo Reflex 1 1 January 2012Missouri Camdenton Lake Sun Leader 1 1 January 2012Missouri Cape Girardeau Southeast Missourian 1 1 January 2012Missouri Carthage The Carthage Press 1 1 January 2012Missouri Caruthersville Democrat-Argus 1 1 January 2012Missouri Columbia Missourian 1 1 January 2012Missouri Columbia Tribune 1 1 January 2012Missouri Concordia The Concordian 1 1 January 2012Missouri Cuba The Cuba Free Press 1 1 January 2012Missouri Dexter Daily Statesman 1 1 January 2012Missouri Dexter Daily Statesman 1 1 January 2012Missouri Edina The Edina Sentinel 1 1 January 2012Missouri Fulton The Fulton Sun 1 1 1 1 January 2012Missouri Gladstone Liberty Tribune 1 1 January 2012Missouri Gladstone Sun Gazette 1 1 January 2012Missouri Gladstone Sun Tribune 1 1 January 2012Missouri Hannibal Courier-Post 1 1 1 1 January 2012Missouri Hermitage The Index 1 1 January 2012Missouri Independence The Examiner 1 1 January 2012Missouri Independence/Blue Springs Examiner 1 1 January 2012Missouri Jefferson City Sunday News Tribune 1 1 January 2012Missouri Joplin Globe 1 1 January 2012Missouri Kahoka The Media 1 1 January 2012Missouri Kansas City Star 1 1 January 2012Missouri Kennett Daily Dunklin Democrat 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 177 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMissouri Kirksville Kirksville Daily Express 1 1 1 1 January 2012Missouri Lebanon The Lebanon Daily Record 1 1 January 2012Missouri Malden Delta News Citizen 1 1 January 2012Missouri Marble Hill The Banner Press 1 1 January 2012Missouri Marshfield The Marshfield Mall 1 1 January 2012Missouri Maryville Maryville Daily Forum 1 1 1 1 January 2012Missouri Mexico Mexico Ledger 1 1 1 1 January 2012Missouri Moberly Evening Democrat 1 1 January 2012Missouri Moberly Moberly Monitor - Index and Evening 1 1 1 1 January 2012Missouri Monett The Monett Times 1 1 January 2012Missouri Neosho Neosho Daily News 1 1 January 2012Missouri Nevada Sunday Journal 1 1 January 2012Missouri New Madrid The Weekly Record 1 1 January 2012Missouri Ozark Christian County Headliner 1 1 January 2012Missouri Palmyra Palmyra Spectator 1 1 January 2012Missouri Park Hills Daily Journal 1 1 January 2012Missouri Perrysville Perry County Repubic-Monitor 1 1 January 2012Missouri Poplar Bluff Daily American Republic 1 1 January 2012Missouri Portageville Missourian-News 1 1 January 2012Missouri Republic Republic Monitor 1 1 January 2012Missouri Rogersville South County Mail 1 1 January 2012Missouri Rolla Rolla Daily News 1 1 1 1 January 2012Missouri Sedalia Democrat 1 1 1 1 January 2012Missouri Sikeston Standard Democrat 1 1 January 2012Missouri Springfield News-Leader 1 1 January 2012Missouri St. Joseph News-Press 1 1 1 1 January 2012Missouri St. Louis Post-Dispatch 1 1 January 2012Missouri St. Louis Suburban Newspapers of Greater 1 1 January 2012Missouri Steele The Steele Enterprise 1 1 January 2012Missouri Stockton Cedar County Republican 1 1 January 2012Missouri Thayer South Missourian-News 1 1 January 2012Missouri Warrensburg The Daily Star-Journal 1 1 January 2012Missouri Warrenton Warren County Record 1 1 January 2012Missouri Washington Washington Missourian 1 1 January 2012Missouri West Plains West Plains Daily Quill 1 1 January 2012Montana Big Timber The Big Timber Pioneer 1 1 January 2012Montana Billings Gazette 1 1 1 1 January 2012Montana Bozeman Chronicle 1 1 January 2012Montana Butte-Anaconda Montana Standard 1 1 January 2012Montana Chinook The Journal News-Opinion 1 1 January 2012Montana Columbus Stillwater County News 1 1 January 2012Montana Dillon Dillon Tribune Examiner 1 1 January 2012Montana Fairfield Fairfield Sun Times 1 1 January 2012Montana Forsyth The Independent Press 1 1 January 2012Montana Glendive Ranger Review 1 1 January 2012Montana Great Falls Tribune 1 1 January 2012Montana Hardin Big Horn County New 1 1 January 2012Montana Havre Havre Daily News 1 1 January 2012Montana Helena Independent Record 1 1 1 1 January 2012Montana Kalispell Daily Inter Lake 1 1 1 1 January 2012Montana Lewistown Lewistown News-Argus 1 1 January 2012Montana Libby The Western News 1 1 January 2012Montana Livingston The Livingston Enterprise 1 1 January 2012Montana Miles City Miles City Star 1 1 January 2012Montana Missoula Missoulian 1 1 January 2012Montana Polson Lake County Leader 1 1 January 2012Montana Red Lodge Carbon County News 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 178 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceMontana Sidney Sidney Herald 1 1 January 2012Montana Townsend The Townsend Star 1 1 January 2012Nebraska Alliance Alliance Times-Herald 1 1 January 2012Nebraska Ashland Ashland Gazette 1 1 January 2012Nebraska Boulder City Review -Journal 1 1 January 2012Nebraska Breatrice Breatrice Daily Sun 1 1 1 1 January 2012Nebraska Broken Bow Custer County Chief 1 1 January 2012Nebraska Chadron The Chadron Record 1 1 January 2012Nebraska Columbus Columbus Telegram 1 1 1 1 January 2012Nebraska David City Banner Press 1 1 January 2012Nebraska Fremont Fremont Tribune 1 1 1 1 January 2012Nebraska Gordon Gordon Journal 1 1 January 2012Nebraska Gothenburg Gothenburg Times 1 1 January 2012Nebraska Grand Island Independent 1 1 1 1 January 2012Nebraska Hasting Hastings Tribune 1 1 1 1 January 2012Nebraska Hebron Journal - Register 1 1 January 2012Nebraska Kearney Hub 1 1 1 1 January 2012Nebraska Lexington Lexington Clipper-Herald 1 1 January 2012Nebraska Lincoln Journal-Star 1 1 January 2012Nebraska McCook McCook Daily Gazette 1 1 January 2012Nebraska Minden The Minden Courier 1 1 January 2012Nebraska Nebraska City Nebraska City News-Press 1 1 January 2012Nebraska Norfolk Norfolk Daily News 1 1 January 2012Nebraska North Platte Telegraph 1 1 1 1 January 2012Nebraska Omaha World-Herald 1 1 January 2012Nebraska Ord The Ord Quiz 1 1 January 2012Nebraska Papillion PapillionTimes 1 1 January 2012Nebraska Papillion Ralston Recorder 1 1 January 2012Nebraska Ponca Nebraska Journal Leader 1 1 January 2012Nebraska Schuyler The Schuyler Sun 1 1 January 2012Nebraska Scottsbluff Star Herald 1 1 1 1 January 2012Nebraska Sidney Sun - Telegraph 1 1 January 2012Nebraska Sutton Clay County News 1 1 January 2012Nebraska Syracuse Syracuse Journal-Democrat 1 1 January 2012Nebraska Wahoo Wahoo Newspaper 1 1 January 2012Nebraska Waverly Waverly News 1 1 January 2012Nebraska York News-Times 1 1 January 2012Nevada Battle Mountain The Battle Mountain Bugle 1 1 January 2012Nevada Carson City Appeal 1 1 1 1 January 2012Nevada Elko Elko Daily Free Press 1 1 January 2012Nevada Ely Ely Times 1 1 January 2012Nevada Fallon Lahontan Valley News and Eagle 1 1 1 1 January 2012Nevada Gardnerville The Record Courier 1 1 January 2012Nevada Las Vegas El Tiempo 1 1 January 2012Nevada Las Vegas Review -Journal 1 1 1 1 January 2012Nevada Mesquite Desert Valley Times 1 1 January 2012Nevada Pahrump Pahrump Valley Times 1 1 January 2012Nevada Reno Gazette-Journal & Sunday Select 1 1 January 2012Nevada Sparks Tribune Sunday 1 1 January 2012Nevada Tonopah Tonopah Times-Bonanza/Goldfield 1 1 January 2012Nevada Winnemucca The Humboldt Sun 1 1 January 2012New Hampshire Claremont Eagle Times 1 1 January 2012New Hampshire Concord Monitor 1 1 January 2012New Hampshire Dover/Laconia Citizen-Fosters Sunday Citizen 1 1 January 2012New Hampshire Hudson The Telegraph 1 1 January 2012New Hampshire Keene Sentinel 1 1 January 2012New Hampshire Lebanon/Hanover Valley News 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 179 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceNew Hampshire Manchester New Hampshire News 1 1 January 2012New Hampshire Nashua Telegraph 1 1 January 2012New Hampshire Portsmouth Herald 1 1 January 2012New Hampshire Tonopah Times-Bonanza 1 1 January 2012New Jersey Atlantic City Press 1 1 January 2012New Jersey Bergen County Record 1 1 January 2012New Jersey Bridgewater Courier-News 1 1 January 2012New Jersey Camden/Cherry Hill Courier-Post 1 1 January 2012New Jersey Cherry Hill My Community Trend 1 1 January 2012New Jersey East Brunswick Home News Tribune 1 1 January 2012New Jersey Flemington Hunterdon Observer 1 1 January 2012New Jersey Hackensack Suburban Trends 1 1 January 2012New Jersey Jersey City The Jersey Journal 1 1 January 2012New Jersey Morristown/Parsippany Record 1 1 January 2012New Jersey Neptune Asbury Park Press 1 1 January 2012New Jersey Newark Star-Ledger 1 1 January 2012New Jersey Newton New Jersey Herald 1 1 1 1 January 2012New Jersey Salem Todays Sunbeam 1 1 January 2012New Jersey Trenton Times 1 1 January 2012New Jersey Trenton Trentonian 1 1 January 2012New Jersey Vineland Journal 1 1 January 2012New Jersey Willingboro Burlington County Times 1 1 January 2012New Jersey Woodbury Times 1 1 January 2012New Mexico Alamagordo Times 1 1 January 2012New Mexico Albuquerque Journal 1 1 1 1 2 January 2012New Mexico Belen Valencia County News-Bulletin 1 1 1 1 January 2012New Mexico Carlsbad Current-Argus 1 1 January 2012New Mexico Clovis News Journal 1 1 1 1 January 2012New Mexico Farmington Times 1 1 January 2012New Mexico Gallup Independent 1 1 1 1 January 2012New Mexico Hobbs News Sun 1 1 1 1 January 2012New Mexico Las Alamos Los Alamos Monitor 1 1 January 2012New Mexico Las Cruces Sun-News 1 1 January 2012New Mexico Las Vegas Las Vegas Optic 1 1 January 2012New Mexico Los Alamos Los Alamos Monitor 1 1 January 2012New Mexico Lovington The Lovington Daily Leader 1 1 January 2012New Mexico Portales News-Tribune 1 1 1 1 January 2012New Mexico Roswell Record 1 1 1 1 January 2012New Mexico Santa Fe New Mexican 1 1 January 2012New Mexico Socorro El Defensor Chieftain 1 1 1 1 January 2012New Mexico Tucumcari Quay County Sun 1 1 January 2012New York Adirondack Enterprise 1 1 January 2012New York Albany Times Union 1 1 January 2012New York Auburn Citizen 1 1 January 2012New York Batavia Daily News 1 1 1 1 January 2012New York Binghamton Press & Sun-Bulletin 1 1 January 2012New York Buffalo News 1 1 January 2012New York Callicoon Sullivan County Democrat 1 1 January 2012New York Canandaigua Messenger 1 1 January 2012New York Catskill Daily Mail 1 1 1 1 January 2012New York Corning Leader 1 1 January 2012New York Dansville Genesee Country Express 1 1 January 2012New York Dunkirk/Fredonia Observer 1 1 January 2012New York Elmira Star-Gazette 1 1 January 2012New York Geneseo Livingston County News 1 1 January 2012New York Geneva Finger Lakes Times 1 1 January 2012New York Glens Falls Post-Star 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 180 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceNew York Gloversville Leader-Herald 1 1 January 2012New York Herkimer The Evening Telegram 1 1 January 2012New York Hornell Tribune 1 1 January 2012New York Hudson Register-Star 1 1 1 1 January 2012New York Ithaca Journal 1 1 January 2012New York Jamestown Post-Journal 1 1 January 2012New York Kingston Freeman 1 1 January 2012New York Little Falls The Evening Times 1 1 January 2012New York Long Island Newsday 1 1 January 2012New York Melville This Week 1 1 January 2012New York Middletown Times Herald-Record 1 1 January 2012New York New York Post 1 1 January 2012New York New York City Daily News 1 1 January 2012New York Niagara Falls Sunday Niagara 1 1 January 2012New York Ogdensburg Journal-Advance News 1 1 January 2012New York Olean Times Herald 1 1 January 2012New York Oneida Dispatch 1 1 January 2012New York Oneonta Cooperstown Crier 1 1 January 2012New York Oneonta Daily Star 1 1 1 1 January 2012New York Oswego Palladium-Times 1 1 1 1 January 2012New York Oswego Pennysaver 1 1 January 2012New York Penn Yan The Chronicle-Express 1 1 January 2012New York Plattsburgh Press-Republican 1 1 1 1 January 2012New York Poughkeepsie Journal 1 1 January 2012New York Rochester Democrat and Chronicle 1 1 January 2012New York Saratoga Springs Saratogian 1 1 January 2012New York Schenectady Gazette 1 1 January 2012New York Staten Island Advance 1 1 January 2012New York Syracuse Post-Standard 1 1 January 2012New York Troy Record 1 1 January 2012New York Utica Observer-Dispatch 1 1 January 2012New York Wappingers Falls Southern Dutchess News 1 1 January 2012New York Watertown Times 1 1 1 1 January 2012New York White Plains Journal News Group 1 1 January 2012North Carolina Ahoskie Roanoke-Chowan News Herald 1 1 January 2012North Carolina Albemarle The Stanley News & Press 1 1 1 1 January 2012North Carolina Asheboro Courier-Tribune 1 1 January 2012North Carolina Asheboro The Randolph Guide 1 1 January 2012North Carolina Asheville Citizen-Times 1 1 January 2012North Carolina Bladen The Bladen Journal 1 1 January 2012North Carolina Boone The Watauga Democrat 1 1 1 1 January 2012North Carolina Boone Watauga Mountain Times 1 1 January 2012North Carolina Burgaw The Pender Chronicle 1 1 January 2012North Carolina Burlington Times-News 1 1 1 1 2 January 2012North Carolina Chapel Hill The Chapel Hill News 1 1 January 2012North Carolina Charlotte Carolina Weekly 1 1 January 2012North Carolina Charlotte Observer 1 1 January 2012North Carolina Clemmons The Clemmons Courier 1 1 January 2012North Carolina Clinton The Sampson Independent 1 1 January 2012North Carolina Concord/Kannapolis Independent Tribune 1 1 January 2012North Carolina Dunn The Daily Record 1 1 January 2012North Carolina Durham Herald-Sun 1 1 January 2012North Carolina Durham News 1 1 January 2012North Carolina Eden News 1 1 January 2012North Carolina Elizabeth City Advance 1 1 January 2012North Carolina Elkin The Tribune 1 1 January 2012North Carolina Fayetteville Observer 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 181 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceNorth Carolina Forest City Courier 1 1 January 2012North Carolina Franklin The Franklin Press 1 1 January 2012North Carolina Fremont Wayne-Wilson News Leader 1 1 January 2012North Carolina Fuquay Varina Holly Springs Sun 1 1 January 2012North Carolina Garner Cleveland Post 1 1 January 2012North Carolina Gastonia Gaston Gazette 1 1 1 1 2 January 2012North Carolina Goldsboro News-Argus 1 1 January 2012North Carolina Greensboro News & Record 1 1 January 2012North Carolina Greenville Reflector 1 1 January 2012North Carolina Hayesville Clay County Progress 1 1 January 2012North Carolina Henderson Dispatch 1 1 January 2012North Carolina Hendersonville Times-News 1 1 January 2012North Carolina Hickory Record 1 1 January 2012North Carolina High Point Enterprise 1 1 January 2012North Carolina Highlands The Highlander 1 1 January 2012North Carolina Jacksonville News 1 1 1 1 January 2012North Carolina Kannapolis Independent Tribune 1 1 January 2012North Carolina Kinston Free Press 1 1 1 1 January 2012North Carolina LaGrange Weekly Gazette 1 1 January 2012North Carolina Laurinburg The Laurinburg Exchange 1 1 1 1 January 2012North Carolina Lenoir News-Topic 1 1 January 2012North Carolina Lexington Dispatch 1 1 January 2012North Carolina Lumberton Robesonian 1 1 January 2012North Carolina Marion The McDowell News 1 1 1 1 January 2012North Carolina Marshville The Home News 1 1 January 2012North Carolina Mocksville Davie County Enterprise-Record 1 1 January 2012North Carolina Monroe Enquirer-Journal 1 1 January 2012North Carolina Monroe Waxhaw Exchange 1 1 January 2012North Carolina Morganton News-Herald 1 1 1 1 January 2012North Carolina Mount Airy Stokes News 1 1 1 1 January 2012North Carolina Mount Olive Mount Olive Tribune 1 1 January 2012North Carolina Mt. Airy Mt. Airy News 1 1 January 2012North Carolina Murphy Cherokee Scout 1 1 January 2012North Carolina Nashville The Nashville Graphic 1 1 January 2012North Carolina New Bern Sun-Journal 1 1 1 1 2 January 2012North Carolina Newton The Observer-News-Enterprise 1 1 January 2012North Carolina North Wilkesboro The Record 1 1 January 2012North Carolina Princeton Princeton News-Leader 1 1 January 2012North Carolina Raleigh News & Observer 1 1 January 2012North Carolina Reidsville Review 1 1 January 2012North Carolina Roanoke Rapids Herald 1 1 January 2012North Carolina Robbinsville Graham Star 1 1 January 2012North Carolina Rockingham Richmond County Daily Journal 1 1 1 1 January 2012North Carolina Rocky Mount Telegram 1 1 January 2012North Carolina Roxboro The Courier-Times 1 1 January 2012North Carolina Salisbury/Spencer/East Spencer Salisbury Post 1 1 January 2012North Carolina Sanford Herald 1 1 January 2012North Carolina Shelby Star 1 1 1 1 January 2012North Carolina Southern Pines The Pilot 1 1 1 1 1 January 2012North Carolina Spring Hope Spring Hope Enterprise 1 1 January 2012North Carolina Statesville Record & Landmark 1 1 1 1 January 2012North Carolina Tarboro The Daily Southerner 1 1 1 1 January 2012North Carolina Taylorsville The Taylorsville Times 1 1 January 2012North Carolina Washington News 1 1 January 2012North Carolina Whiteville The News Reporter 1 1 January 2012North Carolina Wilmington Star-News 1 1 January 2012North Carolina Wilson Times 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 182 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceNorth Carolina Winston-Salem Journal 1 1 January 2012North Dakota Beulah Beulah Beacon 1 1 January 2012North Dakota Bismarck Tribune 1 1 1 1 January 2012North Dakota Devils Lake Devils Lake Journal 1 1 January 2012North Dakota Dickinson Press 1 1 January 2012North Dakota Fargo, ND-Moorhead, MN Forum 1 1 January 2012North Dakota Garrison Center Republican 1 1 January 2012North Dakota Garrison McClean Couty Independent 1 1 January 2012North Dakota Garrison McClusky Gazette 1 1 January 2012North Dakota Garrison The Leader-News 1 1 January 2012North Dakota Garrison Underwood News 1 1 January 2012North Dakota Grand Forks Herald 1 1 January 2012North Dakota Hankinson Richland County News - Monitor 1 1 January 2012North Dakota Hazen Hazen Star 1 1 January 2012North Dakota Jamestown The Jamestown Sun 1 1 January 2012North Dakota Minot News 1 1 January 2012North Dakota New Town New Town News 1 1 January 2012North Dakota Parshall Mountrail County Record 1 1 January 2012North Dakota Stanley Mountrail County Promoter 1 1 January 2012North Dakota Turtle Lake McLean County Journal 1 1 January 2012North Dakota Valley City Valley City Times-Record 1 1 January 2012North Dakota Velva Velva Voice 1 1 January 2012North Dakota Wahpeton The Daily News 1 1 January 2012Ohio Ada Ada Herald 1 1 January 2012Ohio Akron Beacon Journal 1 1 January 2012Ohio Akron Cuyahoga Falls News Press 1 1 January 2012Ohio Akron The Subarbanite 1 1 January 2012Ohio Alliance Review 1 1 January 2012Ohio Ashland Ashland County Times 1 1 1 1 January 2012Ohio Ashtabula Star Beacon 1 1 1 1 January 2012Ohio Athens Messenger 1 1 1 1 2 January 2012Ohio Athens Vinton County Courier 1 1 January 2012Ohio Batavia Clermont Sun 1 1 January 2012Ohio Bellevue Gazette Publishing Company 1 1 January 2012Ohio Bowling Green Sentinel-Tribune 1 1 January 2012Ohio Bryan Times 1 1 1 1 January 2012Ohio Cambridge Jeffersonian 1 1 January 2012Ohio Canton Repository 1 1 January 2012Ohio Carey Mohawk Leader 1 1 January 2012Ohio Carey The Progressor Times 1 1 January 2012Ohio Cincinnati Enquirer 1 1 January 2012Ohio Circleville Herald 1 1 1 1 2 January 2012Ohio Cleveland Plain Dealer 1 1 January 2012Ohio Columbus Dispatch 1 1 January 2012Ohio Columbus Suburban News Publications 1 1 January 2012Ohio Dayton Daily News 1 1 January 2012Ohio Defiance Crescent-News 1 1 1 1 January 2012Ohio Delaware Brown Publishing Co. - Marysville 1 1 January 2012Ohio Delphos The Daily Herald 1 1 January 2012Ohio East Liverpool Review 1 1 January 2012Ohio Eaton The Register-Herald 1 1 January 2012Ohio Elyria Chronicle-Telegram 1 1 1 1 January 2012Ohio Fairborn Daily Herald 1 1 January 2012Ohio Findlay Courier 1 1 January 2012Ohio Fostoria Review-Times 1 1 January 2012Ohio Galion The Galion Inquirer 1 1 January 2012Ohio Gallipolis/Point Pleasant Register (WV) 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 183 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceOhio Gallipolis/Point Pleasant Times-Sentinel (OH) 1 1 January 2012Ohio Georgetown Georgetown News Democrat 1 1 January 2012Ohio Greenville Advocate 1 1 1 1 January 2012Ohio Hamilton Journal-News 1 1 January 2012Ohio Hillsboro Times-Gazette 1 1 1 1 January 2012Ohio Ironton Tribune 1 1 January 2012Ohio Jackson Jackson County Times-Journal 1 1 1 1 January 2012Ohio Kent/Ravenna Record-Courier 1 1 January 2012Ohio Kenton The Kenton Times 1 1 January 2012Ohio Lewis Center This Week Community Newspapers 1 1 January 2012Ohio Lima News 1 1 January 2012Ohio Lisbon Morning Journal 1 1 January 2012Ohio Logan News 1 1 1 1 January 2012Ohio London Brown Publishing Co. - London 1 1 January 2012Ohio Lorain Journal 1 1 January 2012Ohio Mansfield News Journal 1 1 January 2012Ohio Marietta Times 1 1 January 2012Ohio Marion Star 1 1 January 2012Ohio Martins Ferry/Belmont County Times Leader 1 1 January 2012Ohio Marysville Marysville Journal -Tribune 1 1 January 2012Ohio Marysville Richwood Gazette 1 1 January 2012Ohio Massillion The Independent 1 1 January 2012Ohio Medina Gazette 1 1 1 1 January 2012Ohio Miami Valley Sunday News 1 1 January 2012Ohio Middletown Journal 1 1 January 2012Ohio Millersburg The Holmes County Hub 1 1 January 2012Ohio Minster The Community Post 1 1 January 2012Ohio Mount Gilead The Mount Gilead Weeklies 1 1 January 2012Ohio Napoleon Northwest Signal 1 1 1 1 January 2012Ohio New Lexington Perry County Tribune 1 1 January 2012Ohio New Philadelphia-Dover Times Reporter 1 1 January 2012Ohio Newark Advocate 1 1 January 2012Ohio Norwalk Reflector 1 1 1 1 January 2012Ohio Ottawa Putnam County Sentinel 1 1 January 2012Ohio Piqua Call 1 1 1 1 January 2012Ohio Pomeroy Daily Sentinel 1 1 January 2012Ohio Portsmouth Times 1 1 January 2012Ohio Salem News 1 1 January 2012Ohio Sandusky Register 1 1 1 1 January 2012Ohio Sidney News 1 1 1 1 January 2012Ohio Springfield News-Sun 1 1 January 2012Ohio St. Marys Evening Leader 1 1 January 2012Ohio Steubenville/Weirton Herald-Star 1 1 January 2012Ohio Stow Sentry 1 1 January 2012Ohio Tallmadge Express 1 1 January 2012Ohio Tiffin Advertiser-Tribune 1 1 January 2012Ohio Toledo Blade 1 1 January 2012Ohio Troy Troy Daily News 1 1 January 2012Ohio Upper Sandusky The Daily Chief-Union (Upper 1 1 January 2012Ohio Urbana Citizen 1 1 1 1 January 2012Ohio Van Wert Times-Bulletin 1 1 1 1 January 2012Ohio Wapakoneta Wapakoneta Daily News 1 1 January 2012Ohio Warren Tribune Chronicle 1 1 January 2012Ohio Washington Court House Record-Herald 1 1 1 1 January 2012Ohio Wauseon Fulton County Expositor 1 1 January 2012Ohio Waverly The News Watchman 1 1 1 1 2 January 2012Ohio West Union Peoples Defender 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 184 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceOhio Wheelersburg The Scioto Voice 1 1 January 2012Ohio Willoughby Lake County News-Herald 1 1 January 2012Ohio Wilmington News-Journal 1 1 1 1 January 2012Ohio Wooster Record 1 1 1 1 January 2012Ohio Xenia Beavercreek News Current 1 1 January 2012Ohio Xenia Fairborn Daily Herald 1 1 January 2012Ohio Xenia The Xenia Daily Gazette 1 1 January 2012Ohio Xenia/Beavercreek Daily Gazette-News Currant 1 1 January 2012Ohio Youngstown Vindicator 1 1 January 2012Oklahoma Ada Evening News 1 1 January 2012Oklahoma Altus Times 1 1 1 1 January 2012Oklahoma Ardmore The Sunday Ardmorite 1 1 1 1 January 2012Oklahoma Bartlesville Examiner-Enterprise 1 1 1 1 January 2012Oklahoma Blackwell Blackwell Journal Tribune 1 1 January 2012Oklahoma Checotah McIntosh County Democrat 1 1 January 2012Oklahoma Chickasha Star 1 1 1 1 January 2012Oklahoma Claremore Daily Progress 1 1 1 1 2 January 2012Oklahoma Cleveland Cleveland American 1 1 January 2012Oklahoma Duncan The Duncan Banner 1 1 1 1 January 2012Oklahoma Durant Democrat 1 1 1 1 January 2012Oklahoma Edmond The Edmond Sun 1 1 1 1 January 2012Oklahoma Enid News & Eagle 1 1 January 2012Oklahoma Eufaula Indian Journal 1 1 January 2012Oklahoma Fairland The American 1 1 January 2012Oklahoma Fort Gibson Fort Gibson Times 1 1 January 2012Oklahoma Frederick Frederick Leader 1 1 January 2012Oklahoma Grove The Grove Sun 1 1 January 2012Oklahoma Guthrie Guthrie News Leader 1 1 January 2012Oklahoma Guymon Guymon Daily Herald 1 1 January 2012Oklahoma Idabel McCurtain Daily Gazette 1 1 January 2012Oklahoma Jay Delaware County Journal 1 1 January 2012Oklahoma Lawton Sunday Constitution 1 1 January 2012Oklahoma Mangum The Mangum Star News 1 1 January 2012Oklahoma McAlester News-Capitol 1 1 1 1 January 2012Oklahoma Miami Miami News-Record 1 1 January 2012Oklahoma Muskogee Phoenix & Times Democrat 1 1 1 1 January 2012Oklahoma Mustang Mustang Times 1 1 January 2012Oklahoma Norman Transcript 1 1 January 2012Oklahoma Nowata The Nowata Star 1 1 January 2012Oklahoma Oklahoma City Oklahoman 1 1 January 2012Oklahoma Okmulgee Okmulgee County 1 1 January 2012Oklahoma Pauls Valley Daily Democrat 1 1 1 1 January 2012Oklahoma Perkins The Perkins Journal 1 1 January 2012Oklahoma Poteau Poteau Daily News 1 1 January 2012Oklahoma Pryor The Daily Times 1 1 1 1 2 January 2012Oklahoma Sapulpa Sapulpa Daily Herald 1 1 January 2012Oklahoma Shawnee News-Star 1 1 1 1 January 2012Oklahoma Stillwater News-Press 1 1 January 2012Oklahoma Stilwell Stilwell Democrat Journal 1 1 January 2012Oklahoma Tahlequah Tahlequah Daily Press 1 1 1 1 2 January 2012Oklahoma Tulsa World 1 1 1 1 January 2012Oklahoma Vinita Vinita Daily Journal 1 1 January 2012Oklahoma Westville Westville Reporter 1 1 January 2012Oklahoma Woodward News 1 1 1 1 2 January 2012Oregon Albany/Corvallis Democrat-Herald-Gazette-Times 1 1 1 1 January 2012Oregon Baker City Baker City Herald 1 1 January 2012Oregon Bend Bulletin 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 185 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceOregon Brookings Curry Coastal Pilot 1 1 January 2012Oregon Burns Burns Times-Herald 1 1 January 2012Oregon Coos Bay-North Bend World 1 1 January 2012Oregon Enterprise Wallowa County Chieftain 1 1 January 2012Oregon Eugene Register-Guard 1 1 January 2012Oregon Grants Pass Courier 1 1 January 2012Oregon Hermiston The Hermiston Herald 1 1 January 2012Oregon Hood River Hood River News 1 1 January 2012Oregon John Day Blue Mountain Eagle 1 1 January 2012Oregon Keizer Keizertimes 1 1 January 2012Oregon Klamath Falls Herald and News 1 1 1 1 January 2012Oregon La Grande The Observer 1 1 January 2012Oregon Madras The Madras Pioneer 1 1 January 2012Oregon Medford Ashland Daily Tidings 1 1 January 2012Oregon Medford Mail Tribune 1 1 1 1 January 2012Oregon Myrtle Creek The Douglas County Mail 1 1 January 2012Oregon Newberg The Graphic 1 1 January 2012Oregon Ontario Argus Observer 1 1 January 2012Oregon Pendleton East Oregonian 1 1 1 1 January 2012Oregon Portland Oregonian 1 1 January 2012Oregon Prineville Central Oregonian 1 1 January 2012Oregon Roseburg News-Review of Douglas County 1 1 1 1 January 2012Oregon Salem Statesman-Journal 1 1 January 2012Oregon The Dalles The Dalles Daily Chronicle 1 1 January 2012Oregon Woodburn Woodburn Independent/Canby 1 1 January 2012Pennsylvania Allentown Call 1 1 January 2012Pennsylvania Allentown East Penn Press 1 1 January 2012Pennsylvania Allentown Northwestern Press 1 1 January 2012Pennsylvania Allentown Parkland Press 1 1 January 2012Pennsylvania Allentown Whitehall-Coplay Press 1 1 January 2012Pennsylvania Altoona Mirror 1 1 January 2012Pennsylvania Beaver County Times 1 1 January 2012Pennsylvania Bedford Bedford Gazette 1 1 January 2012Pennsylvania Bloomsburg Press-Enterprise 1 1 1 1 January 2012Pennsylvania Bradford Era 1 1 January 2012Pennsylvania Butler Eagle 1 1 January 2012Pennsylvania Canton The Canton Independent Sentinel 1 1 January 2012Pennsylvania Carlisle Sentinel 1 1 1 1 January 2012Pennsylvania Chambersburg Public Opinion 1 1 January 2012Pennsylvania Clearfield Progress 1 1 January 2012Pennsylvania Corry Corry Evening Journal 1 1 January 2012Pennsylvania Danville News 1 1 January 2012Pennsylvania Doylestown Intelligencer 1 1 January 2012Pennsylvania Dubois Tri County Sunday 1 1 January 2012Pennsylvania Easton Express-Times 1 1 January 2012Pennsylvania Erie Times-News 1 1 January 2012Pennsylvania Gettysburg Times 1 1 January 2012Pennsylvania Greencastle The Echo-Pilot 1 1 January 2012Pennsylvania Greensburg Tribune-Review 1 1 January 2012Pennsylvania Greenville The Record-Argus 1 1 January 2012Pennsylvania Hanover Sun 1 1 January 2012Pennsylvania Harrisburg Patriot-News 1 1 January 2012Pennsylvania Hazleton Hazleton Standard-Speaker 1 1 January 2012Pennsylvania Hellertown The Valley Voice 1 1 January 2012Pennsylvania Honesdale The Wayne Independent 1 1 January 2012Pennsylvania Huntingdon The Daily News 1 1 January 2012Pennsylvania Indiana Gazette 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 186 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourcePennsylvania Johnstown Tribune-Democrat 1 1 January 2012Pennsylvania Kane The Kane Republican 1 1 January 2012Pennsylvania Lancaster News 1 1 January 2012Pennsylvania Latrobe The Latrobe Bulletin 1 1 January 2012Pennsylvania Lebanon News 1 1 January 2012Pennsylvania Lehighton Salisbury Press 1 1 January 2012Pennsylvania Lehighton Times News 1 1 1 1 January 2012Pennsylvania Levittown/Bristol Bucks Courier Times 1 1 January 2012Pennsylvania Lewistown Sentinel 1 1 January 2012Pennsylvania Lock Haven Express 1 1 January 2012Pennsylvania McKeesport/Duquesne/Clairton News 1 1 January 2012Pennsylvania Meadville Tribune 1 1 January 2012Pennsylvania Milton Lewisburg Daily Journal 1 1 January 2012Pennsylvania Milton The Standard Journal 1 1 January 2012Pennsylvania Montrose (The Susquehanna County) 1 1 January 2012Pennsylvania New Castle News 1 1 January 2012Pennsylvania New Kensington-Tarentum-Vandegrift Valley News Dispatch 1 1 January 2012Pennsylvania Newville Valley Times-Star 1 1 January 2012Pennsylvania Norristown/Lansdale Times Herald 1 1 January 2012Pennsylvania Oil City Derrick Publishing Co. 1 1 1 1 January 2012Pennsylvania Philadelphia Daily News 1 1 January 2012Pennsylvania Philadelphia Inquirer 1 1 January 2012Pennsylvania Phoenixville Phoenix 1 1 January 2012Pennsylvania Pittsburgh Post-Gazette 1 1 January 2012Pennsylvania Pittsburgh Trib Total Media 1 1 January 2012Pennsylvania Pottstown Mercury 1 1 January 2012Pennsylvania Pottsville Republican & Herald 1 1 January 2012Pennsylvania Primos Delaware County Times 1 1 January 2012Pennsylvania Punxsutawney The Spirit 1 1 January 2012Pennsylvania Reading Eagle 1 1 January 2012Pennsylvania Ridway The Ridgway Record 1 1 January 2012Pennsylvania Sayre Morning Times 1 1 1 1 January 2012Pennsylvania Scranton Times-Tribune 1 1 1 1 January 2012Pennsylvania Shamokin The News-Item 1 1 January 2012Pennsylvania Sharon-Farrell-Sharpsville-Hermitage Herald 1 1 January 2012Pennsylvania Shippensburg The News-Chronicle 1 1 January 2012Pennsylvania Smoakin/Pottsville Republican & Herald/News Item 1 1 January 2012Pennsylvania Somerset Daily American 1 1 January 2012Pennsylvania St. Marys The Daily Press 1 1 January 2012Pennsylvania State College Center Daily Times 1 1 January 2012Pennsylvania Stroudsburg-East Stroudsburg Pocono Record 1 1 1 1 January 2012Pennsylvania Sunbury Daily Item 1 1 1 1 January 2012Pennsylvania Towanda Sunday Review 1 1 January 2012Pennsylvania Towanda The Daily Review 1 1 January 2012Pennsylvania Tunkhannock The New Age-Examiner 1 1 January 2012Pennsylvania Tyrone The Daily Herald 1 1 January 2012Pennsylvania Uniontown Herald-Standard 1 1 January 2012Pennsylvania Warren Times-Observer 1 1 January 2012Pennsylvania Washington Observer-Reporter 1 1 1 1 January 2012Pennsylvania Waynesboro The Record Herald 1 1 January 2012Pennsylvania West Chester Local News 1 1 January 2012Pennsylvania White Haven The Journal-Herald 1 1 January 2012Pennsylvania Wilkes-Barre Sunday Voice 1 1 January 2012Pennsylvania Wilkes-Barre The Citizens Voice 1 1 January 2012Pennsylvania Wilkes-Barre Times Leader 1 1 January 2012Pennsylvania Williamsport Sun-Gazette 1 1 January 2012Pennsylvania Wyalusing Rocket-Courier 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 187 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourcePennsylvania York Sunday News 1 1 January 2012Rhode Island Kent County Times 1 1 January 2012Rhode Island Newport The Daily News 1 1 January 2012Rhode Island Pawtucket/Central Falls Times 1 1 January 2012Rhode Island Providence Sunday Journal 1 1 January 2012Rhode Island Warwick Cranston Herald 1 1 January 2012Rhode Island Warwick Warwick Beacon 1 1 January 2012Rhode Island Westerly Sun 1 1 1 1 January 2012Rhode Island Woonsocket Call 1 1 January 2012South Carolina Aiken Standard 1 1 January 2012South Carolina Anderson Independent-Mail 1 1 January 2012South Carolina Barnwell The People-Sentinel 1 1 January 2012South Carolina Bennettsville Marlboro Herald - Advocate 1 1 January 2012South Carolina Bluffton Today 1 1 1 1 January 2012South Carolina Charleston Post and Courier 1 1 January 2012South Carolina Columbia The State 1 1 January 2012South Carolina Edgefield The Citizen News 1 1 January 2012South Carolina Florence Morning News 1 1 January 2012South Carolina Georgetown Times 1 1 January 2012South Carolina Goose Creek Gazette 1 1 January 2012South Carolina Greenville News & Sunday Select 1 1 1 1 January 2012South Carolina Greenwood Index-Journal 1 1 January 2012South Carolina Hampton Hampton County Guardian 1 1 January 2012South Carolina Hartsville The Messenger 1 1 January 2012South Carolina Hilton Head Island Island Packet 1 1 January 2012South Carolina Lancaster The Lancaster News 1 1 1 1 January 2012South Carolina Myrtle Beach Sun News 1 1 January 2012South Carolina Newberry The Newberry Observer 1 1 1 1 January 2012South Carolina Orangeburg Times and Democrat 1 1 1 1 January 2012South Carolina Pickens The Pickens Sentinel 1 1 January 2012South Carolina Ridgeland Jasper County Sun Times 1 1 January 2012South Carolina Rock Hill The Herald 1 1 January 2012South Carolina Seneca The Daily Journal 1 1 January 2012South Carolina Seneca The Daily Messenger 1 1 January 2012South Carolina Spartanburg Herald-Journal 1 1 January 2012South Carolina Summerville The Journal Scene 1 1 January 2012South Carolina Sumter Clarendon Sun 1 1 January 2012South Carolina Sumter Item 1 1 January 2012South Carolina Union The Union Daily Times 1 1 1 1 January 2012South Carolina Winnsboro The Herald Independent 1 1 1 1 January 2012South Dakota Aberdeen American News 1 1 1 1 January 2012South Dakota Armour Armour Chronicle 1 1 January 2012South Dakota Belle Fourche Butte County Post 1 1 1 1 January 2012South Dakota Brookins Brookings Register 1 1 January 2012South Dakota Chamberlain Central Dakota Times 1 1 January 2012South Dakota Corsica Corisca Globe 1 1 January 2012South Dakota Corsica The Delmont Record 1 1 January 2012South Dakota De Smet The De Smet News 1 1 January 2012South Dakota Deadwood The Lawrence County Journal 1 1 January 2012South Dakota Elk Point Leader-Courier 1 1 January 2012South Dakota Hot Sprints Hot Springs Star 1 1 January 2012South Dakota Huron Plainsman 1 1 January 2012South Dakota Lake Preston Lake Preston Times 1 1 January 2012South Dakota Mitchell Daily Republic 1 1 January 2012South Dakota Newell Butte County Valley Irrigator 1 1 January 2012South Dakota Parker The New Era 1 1 January 2012South Dakota Rapid City Journal 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 188 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceSouth Dakota Sioux Falls Argus Leader 1 1 January 2012South Dakota Spearfish Black Hills Pioneer 1 1 January 2012South Dakota Sturgis Meade County Times Tribune 1 1 January 2012South Dakota Watertown Public Opinion 1 1 January 2012South Dakota White Lake Aurora County Standard 1 1 January 2012South Dakota White Lake The Stickney Argus 1 1 January 2012South Dakota Yankton Press & Dakotan 1 1 1 1 January 2012Tennessee Athens Post-Athenian 1 1 January 2012Tennessee Bolivar Bolivar Bulletin-Times 1 1 January 2012Tennessee Brownsville Brownsville States-Graphic 1 1 January 2012Tennessee Camden Carroll County News-Leader 1 1 January 2012Tennessee Camden The Camden Chronicle 1 1 January 2012Tennessee Chattanooga Times-Free Press 1 1 January 2012Tennessee Clarksville Leaf-Chronicle 1 1 January 2012Tennessee Cleveland Banner 1 1 1 1 January 2012Tennessee Collierville The Collierville Herald 1 1 January 2012Tennessee Columbia Herald 1 1 January 2012Tennessee Cookeville Herald-Citizen 1 1 January 2012Tennessee Covington The Leader 1 1 January 2012Tennessee Crossville Chronicle 1 1 1 1 2 January 2012Tennessee Dayton The Herald - News 1 1 January 2012Tennessee Dyer The Tri-City Reporter 1 1 January 2012Tennessee Dyersburg State Gazette 1 1 1 1 January 2012Tennessee Elizabethton Elizabethton Star 1 1 1 1 January 2012Tennessee Erwin The Erwin Record 1 1 January 2012Tennessee Fayetteville Elk Valley Times 1 1 January 2012Tennessee Fayetteville Observer & News 1 1 January 2012Tennessee Franklin The Williamson Herald 1 1 January 2012Tennessee Gallatin News-Examiner 1 1 January 2012Tennessee Greeneville The Greeneville Sun 1 1 1 1 January 2012Tennessee Henderson Chester County Independent 1 1 January 2012Tennessee Hendersonville Star News 1 1 January 2012Tennessee Humboldt Humboldt Chronicle 1 1 January 2012Tennessee Jackson Sun 1 1 January 2012Tennessee Jamestown Fentress Courier 1 1 January 2012Tennessee Jefferson City The Standard Banner 1 1 January 2012Tennessee Johnson City Press 1 1 January 2012Tennessee Jonesborough Herald & Tribune 1 1 January 2012Tennessee Kingsport Times-News 1 1 January 2012Tennessee Knoxville News-Sentinel 1 1 January 2012Tennessee Lafayette Macon County Times 1 1 January 2012Tennessee Lebanon Democrat 1 1 January 2012Tennessee Lebanon The Wilson Post 1 1 January 2012Tennessee Lenoir City The News-Herald 1 1 January 2012Tennessee Maryville The Daily Times 1 1 1 1 January 2012Tennessee McMinnville Southern Standard 1 1 January 2012Tennessee Memphis Commercial Appeal 1 1 January 2012Tennessee Morristown Citizen Tribune 1 1 January 2012Tennessee Mt. Juliet The Mt. Juliet News 1 1 January 2012Tennessee Mufreesboro Post 1 1 January 2012Tennessee Murfreesboro News Journal 1 1 January 2012Tennessee Nashville Tennessean 1 1 January 2012Tennessee Newport Plain Talk 1 1 January 2012Tennessee Oak Ridge Oak Ridger 1 1 1 1 January 2012Tennessee Oneida Independent Herald 1 1 January 2012Tennessee Parsons The News Leader 1 1 January 2012Tennessee Pulaski The Pulaski Citizen 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 189 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceTennessee Selmer Independent Appeal 1 1 January 2012Tennessee Sevierville Mountain Press 1 1 January 2012Tennessee Shelbyville Shelbyville Times Gazette 1 1 1 1 January 2012Tennessee Smithville Smithville Review 1 1 January 2012Tennessee Sweetwater The Advocate & Democrat 1 1 January 2012Tennessee Tazewell Claiborne Progress 1 1 January 2012Tennessee Tullahoma The Sunday News 1 1 1 1 January 2012Tennessee Waynesboro The Wayne County News 1 1 January 2012Texas Abilene Reporter-News 1 1 January 2012Texas Alice Alice Echo News-Journal 1 1 January 2012Texas Allen American 1 1 January 2012Texas Alvin Alvin Sun 1 1 January 2012Texas Amarillo Globe-News 1 1 January 2012Texas Andrews Andrews County News 1 1 January 2012Texas Athens Daily Review 1 1 1 1 January 2012Texas Atlanta The Atlanta Citizens Journal 1 1 January 2012Texas Austin American-Statesman 1 1 January 2012Texas Austin Lake Travis View 1 1 January 2012Texas Austin Westlake Picayune 1 1 January 2012Texas Bastrop Bastrop Advertiser 1 1 January 2012Texas Bay City The Bay City Tribune 1 1 January 2012Texas Baytown The Sun 1 1 1 1 January 2012Texas Beaumont Enterprise 1 1 January 2012Texas Big Sandy Big Sandy & Hawkins Journal and Tri- 1 1 January 2012Texas Big Spring Big Spring Herald 1 1 January 2012Texas Borger Borger News-Herald 1 1 January 2012Texas Bowie The Bowie News 1 1 January 2012Texas Breckenridge Breckenridge American 1 1 January 2012Texas Brenham The Banner - Press 1 1 January 2012Texas Brownfield Brownfield News 1 1 January 2012Texas Brownsville Herald 1 1 January 2012Texas Brownwood Bulletin 1 1 1 1 January 2012Texas Bryan Bryan-College Station Eagle 1 1 1 1 January 2012Texas Buffalo The Buffalo Press 1 1 January 2012Texas Burelson Alvarado Star 1 1 January 2012Texas Burelson Burleson Star 1 1 January 2012Texas Burelson Crowley Star 1 1 January 2012Texas Burelson Everman Star 1 1 January 2012Texas Burelson Joshua Star 1 1 January 2012Texas Burelson Kenne Star 1 1 January 2012Texas Canyon The Canyon News 1 1 January 2012Texas Carthage Panola Watchman 1 1 January 2012Texas Center Light and Champion 1 1 January 2012Texas Childress The Childress Index 1 1 January 2012Texas Clarksville Clarksville Times 1 1 January 2012Texas Cleburne Times-Review 1 1 1 1 January 2012Texas Clute Brazosport Facts 1 1 January 2012Texas Comfort The Comfort News 1 1 January 2012Texas Corpus Christi Caller-Times 1 1 January 2012Texas Corrigan Corrigan Times 1 1 January 2012Texas Corsicana Sun 1 1 January 2012Texas Crockett Houston County Courier 1 1 January 2012Texas Daingerfield The Bee 1 1 January 2012Texas Dallas Al Dia 1 1 January 2012Texas Dallas Briefing 1 1 January 2012Texas Dallas Morning News 1 1 January 2012Texas Dallas Quick 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 190 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceTexas Decatur Wise County Messenger 1 1 January 2012Texas Del Rio News Herald 1 1 January 2012Texas Denton Record Chronicle 1 1 1 1 January 2012Texas Edinburg Edinburg Review 1 1 January 2012Texas El Campo El Campo Leader - News 1 1 January 2012Texas El Paso El Diario 1 1 January 2012Texas El Paso Times 1 1 January 2012Texas Eldorado The Eldorado Success 1 1 January 2012Texas Emory Rains County Leader 1 1 January 2012Texas Floresville Wilson County News 1 1 January 2012Texas Flower Mound Leader 1 1 January 2012Texas Fredericksburg Fredericksburg Standard-Radio Post 1 1 January 2012Texas Freer The Freer Press 1 1 January 2012Texas Frisco Enterprise 1 1 January 2012Texas Ft. Worth Star-Telegram 1 1 January 2012Texas Gainesville Daily Register 1 1 1 1 January 2012Texas Galveston Galveston County Daily News 1 1 1 1 January 2012Texas Gatesville Star-Forum 1 1 January 2012Texas Gatesville The Gatesville Messenger 1 1 January 2012Texas Gilmer The Gilmer Mirror 1 1 January 2012Texas Gladewater Gladewater Mirror 1 1 January 2012Texas Glen Rose Glen Rose Reporter 1 1 January 2012Texas Graford Lake Country Sun 1 1 January 2012Texas Graham The Graham Leader 1 1 January 2012Texas Granbury Hood County News 1 1 January 2012Texas Greenville Herald-Banner 1 1 1 1 January 2012Texas Groveton Groveton News 1 1 January 2012Texas Harlingen Valley Morning Star 1 1 January 2012Texas Hearne Calvert Tribune 1 1 January 2012Texas Hearne Franlkin Advocate 1 1 January 2012Texas Hearne Hearne Democrat 1 1 January 2012Texas Hemphill Sabine County Reporter 1 1 January 2012Texas Henderson Henderson Daily News 1 1 January 2012Texas Hereford Hereford Brand 1 1 January 2012Texas Houston Chronicle 1 1 January 2012Texas Houston Chronicle Plus 1 1 January 2012Texas Houston Community Papers 1 1 January 2012Texas Houston East Texas Community Newspapers 1 1 January 2012Texas Huntsville Item 1 1 1 1 January 2012Texas Ingram West Kerr Current 1 1 January 2012Texas Iowa Park Iowa Park Leader 1 1 January 2012Texas Irving Rambler 1 1 January 2012Texas Jacksboro Jack County Herald 1 1 January 2012Texas Jacksonville Daily Progress 1 1 1 1 January 2012Texas Jonestown Cedar Park Citizen 1 1 January 2012Texas Jonestown Leander Ledger 1 1 January 2012Texas Junction The Junction Eagle 1 1 January 2012Texas Karnes The Countywide 1 1 January 2012Texas Katy The Katy Times 1 1 January 2012Texas Kaufman Kaufman Herald 1 1 January 2012Texas Kerrville Daily Times 1 1 1 1 January 2012Texas Kilgore Kilgore News Herald 1 1 January 2012Texas Killeen Herald 1 1 1 1 January 2012Texas Kingsville Kingsville Record 1 1 January 2012Texas Lamesa Lamesa Press-Reporter 1 1 January 2012Texas LaPorte Bayshore Sun 1 1 January 2012Texas Laredo Morning Times 1 1 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 191 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceTexas Levelland Levelland And Hockley County News- 1 1 January 2012Texas Lewisville Leader 1 1 January 2012Texas Lindale The Lindale News & Times 1 1 January 2012Texas Linden Cass County Sun 1 1 January 2012Texas Little Elm Journal 1 1 January 2012Texas Littlefield The Lamb County Leader News 1 1 January 2012Texas Livingston Polk County Enterprise 1 1 January 2012Texas Longview News-Journal 1 1 1 1 January 2012Texas Lubbock Avalanche-Journal 1 1 January 2012Texas Lufkin Daily News 1 1 1 1 January 2012Texas Lytle Leader News 1 1 January 2012Texas Mabank The Monitor/Leader 1 1 January 2012Texas Marble Falls The Highlander 1 1 January 2012Texas Marshall News Messenger 1 1 1 1 January 2012Texas McAllen Monitor 1 1 1 1 January 2012Texas McAllen Original Winter Texan 1 1 January 2012Texas McKinney Courier-Gazette 1 1 January 2012Texas Menard Menard News & Messenger 1 1 January 2012Texas Merdian Bosque County News 1 1 January 2012Texas Mesquite News 1 1 January 2012Texas Mexia The Mexia Daily News 1 1 January 2012Texas Midland Reporter-Telegram 1 1 1 1 January 2012Texas Mineola Mineola Monitor 1 1 January 2012Texas Mineral Wells Mineral Wells Index 1 1 1 1 January 2012Texas Mount Vernon Mount Vernon Optic-Herald 1 1 January 2012Texas Mt. Pleasant Mount Pleasant Daily Tribune 1 1 January 2012Texas Muleshoe Muleshoe Journal 1 1 January 2012Texas New Boston Bowie County Citizens Tribune 1 1 January 2012Texas New Boston DeKalb News 1 1 January 2012Texas New Braunfels Herald-Zeitung 1 1 1 1 January 2012Texas Nochgodoches The Daily Sentinel 1 1 1 1 January 2012Texas Odessa American 1 1 January 2012Texas Olney The Olney Enterprise 1 1 January 2012Texas Orange Leader 1 1 1 1 January 2012Texas Overton The Overton Press 1 1 January 2012Texas Palestine Herald - Press 1 1 1 1 January 2012Texas Paris News 1 1 January 2012Texas Plainview Plainview Daily Herald 1 1 1 1 January 2012Texas Plano Star Community Newspapers 1 1 January 2012Texas Plano Star Courier 1 1 January 2012Texas Plugerville Pflugerville Pflag 1 1 January 2012Texas Port Arthur News 1 1 1 1 January 2012Texas Port Lavaca The Port Lavaca Wave 1 1 January 2012Texas Post The Post Dispatch 1 1 January 2012Texas Quitman Wood County Democrat 1 1 January 2012Texas Raymondville Raymondville Chronicle 1 1 January 2012Texas Raymondville Willacy County News 1 1 January 2012Texas Robstown Nueces Co. Record Star 1 1 January 2012Texas Rockport Rockport Pilot 1 1 January 2012Texas Rockwall Rockwall County News 1 1 January 2012Texas Rosenburg The Fort Bend Herald 1 1 January 2012Texas Round Rock Round Rock Leader 1 1 January 2012Texas Rowlett Lakeshore Times 1 1 January 2012Texas San Angelo Standard-Times 1 1 January 2012Texas San Antonio Express-News 1 1 January 2012Texas San Diego Duval County Picture 1 1 January 2012Texas San Marcos Daily Record 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 192 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceTexas San Marcos San Marcos Daily Record 1 1 January 2012Texas Seagoville The Suburbia News 1 1 January 2012Texas Seguin Seguin Gazette-Enterprise 1 1 1 1 January 2012Texas Seminole Seminole Sentinel 1 1 January 2012Texas Shepherd San Jacinto News-Times 1 1 January 2012Texas Sherman/Denison Herald Democrat 1 1 January 2012Texas Smithvilel Smithville Times 1 1 January 2012Texas Snyder The Snyder Daily News 1 1 January 2012Texas Stephenville Stephenville Empire-Tribune 1 1 January 2012Texas Sweetwater Sweetwater Reporter 1 1 January 2012Texas Teague The Teague Chronicle 1 1 January 2012Texas Temple Daily Telegram 1 1 January 2012Texas Terrell Terrell Tribune 1 1 January 2012Texas Texarkana Gazette 1 1 1 1 January 2012Texas Trinity Trinity Standard 1 1 January 2012Texas Tyler Courier Times-Telegraph 1 1 January 2012Texas Uvalde The Uvalde Leader-News 1 1 January 2012Texas Van Alstyne Leader 1 1 January 2012Texas Vernon The Vernon Daily Record 1 1 January 2012Texas Victoria Advocate 1 1 January 2012Texas Vidor The Vidorian 1 1 January 2012Texas Waco Tribune-Herald 1 1 January 2012Texas Waco Waco Tribune - Herald 1 1 January 2012Texas Waxahachie Waxahachie Daily Light 1 1 January 2012Texas Weatherford The Democrat 1 1 1 1 January 2012Texas Wellington Wellington Leader 1 1 January 2012Texas Weslaco Mid Valley Town Crier 1 1 1 1 January 2012Texas Wharton Wharton Journal - Spectator 1 1 January 2012Texas Wichita Falls Times Record News 1 1 January 2012Texas Wills Point Van Zandt News 1 1 January 2012Texas Woodville Tyler County Booster 1 1 January 2012Texas Zapata Zapata County News 1 1 January 2012Utah Bountiful Davis County Clipper 1 1 January 2012Utah Heber City Wasatch Wave 1 1 January 2012Utah Logan Herald Journal 1 1 January 2012Utah Moab The Times Indpendent 1 1 January 2012Utah Ogden Standard-Examiner 1 1 1 1 January 2012Utah Price Sun-Advocate 1 1 January 2012Utah Provo Herald 1 1 January 2012Utah Richfield Richfield Reaper 1 1 January 2012Utah Salt Lake City Tribune-Desert Morning News 1 1 January 2012Utah St. George Spectrum 1 1 January 2012Utah Tooele Tooele Transcript Bulletin 1 1 January 2012Vermont Bennington Bennington Banner 1 1 1 1 January 2012Vermont Bradford Journal Opinion 1 1 January 2012Vermont Brattleboro Brattleboro Reformer 1 1 1 1 January 2012Vermont Burlington Free Press 1 1 January 2012Vermont Newport The Newport Daily Express 1 1 January 2012Vermont Rutland Herald and Times Argus 1 1 January 2012Vermont St. Albans St. Albans Messenger 1 1 January 2012Vermont St. Johnsbury The Caledonian-Record 1 1 January 2012Vermont West Dover Deerfield Valley News 1 1 January 2012Virginia Ashland Herald Progress 1 1 January 2012Virginia Bedford Bedford Bulletin 1 1 January 2012Virginia Big Stone Gap The Post 1 1 January 2012Virginia Bristol Herald-Courier 1 1 January 2012Virginia Charlottesville Progress 1 1 January 2012Case 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceVirginia Culpeper Star-Exponent 1 1 January 2012Virginia Danville Register & Bee 1 1 January 2012Virginia Farmville The Farmville Herald 1 1 January 2012Virginia Floyd The Floyd Press 1 1 January 2012Virginia Fredericksburg Free Lance-Star 1 1 January 2012Virginia Front Royal The Warren Sentinel 1 1 January 2012Virginia Galax The Gazette 1 1 January 2012Virginia Goochland The Goochland Gazette 1 1 January 2012Virginia Harrisonburg News Record 1 1 January 2012Virginia Harrisonburg Page News and Courier 1 1 January 2012Virginia Harrisonburg Shenandoah Valley-Herald 1 1 January 2012Virginia Harrisonburg Valley Banner 1 1 January 2012Virginia Hillsville The Carroll News 1 1 January 2012Virginia Hopewell The Hopewell News 1 1 January 2012Virginia Lexington The News - Gazette 1 1 January 2012Virginia Louisa The Central Virginian 1 1 January 2012Virginia Lynchburg News & Advance 1 1 January 2012Virginia Marion Smyth County News & Messenger 1 1 January 2012Virginia Martinsville Bulletin 1 1 January 2012Virginia Newport News-Hampton-Williamsburg Daily Press 1 1 January 2012Virginia Norfolk-Portsmouth-Virginia Beach- Virginian Pilot 1 1 January 2012Virginia Norton Dickenson Star/Cumberland Times 1 1 January 2012Virginia Norton The Coalfield Progress 1 1 January 2012Virginia Petersburg Progress-Index 1 1 1 1 January 2012Virginia Richlands Richlands News-Press 1 1 January 2012Virginia Richmond Times-Dispatch 1 1 January 2012Virginia Roanoke Times 1 1 January 2012Virginia South Boston The Gazette-Virginian 1 1 January 2012Virginia Staunton News Leader 1 1 January 2012Virginia Strasburg Northern Virginia Daily 1 1 1 1 January 2012Virginia Suffolk Suffolk News-Herald 1 1 January 2012Virginia Tazewell Clinch Valley News 1 1 January 2012Virginia Waynesboro News Virginian 1 1 January 2012Virginia Winchester Star 1 1 January 2012Virginia Woodbridge-Manassas Potomac News & Journal Messenger 1 1 January 2012Virginia Wytheville The Bland Messenger 1 1 January 2012Virginia Wytheville Wytheville Enterprise 1 1 January 2012Washington Aberdeen Daily World 1 1 January 2012Washington Auburn Reporter 1 1 January 2012Washington Bainbridge Island Review 1 1 January 2012Washington Bellevue Reporter 1 1 January 2012Washington Bellingham The Bellingham 1 1 January 2012Washington Bremerton Kitsap Sun 1 1 1 1 January 2012Washington Camas Camas-Washougal Post-Record 1 1 January 2012Washington Central Kitsap Reporter 1 1 January 2012Washington Centralia/Chehalis Chronicle 1 1 January 2012Washington Cle Elum Northern Kittitas County Tribune 1 1 January 2012Washington Colville Statesman-Examiner 1 1 January 2012Washington Deer Park Tribune 1 1 January 2012Washington Ellensburg Record 1 1 January 2012Washington Ellensburg Record 1 1 January 2012Washington Everett Sound Publishing Group 1 1 January 2012Washington Grandview Grandview Herald 1 1 January 2012Washington Issaquah/Sammamish Reporter 1 1 January 2012Washington Kent Reporter 1 1 January 2012Washington Longview Daily News 1 1 January 2012Washington Montesano Vidette 1 1 January 2012Case 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceWashington Moses Lake Columbia Basin Herald 1 1 January 2012Washington Mount Vernon Skagit Valley Herald 1 1 January 2012Washington Olympia Olympian 1 1 January 2012Washington Omak The (Omak-Okanogan County) 1 1 January 2012Washington Othello Othello Independent 1 1 January 2012Washington Pasco-Kennewick-Richland Tri-City Herald 1 1 January 2012Washington Port Angeles Peninsula Daily News 1 1 January 2012Washington Port Orchard Independent Tribune 1 1 January 2012Washington Prosser Record Bulletin 1 1 January 2012Washington Quincy The Quincy Valley Post-Register 1 1 January 2012Washington Redmond Reporter 1 1 January 2012Washington Renton Reporter 1 1 January 2012Washington Seattle Times/Post-Intelligencer 1 1 January 2012Washington Sequim Sequim Gazette 1 1 January 2012Washington South Whidbey Record 1 1 January 2012Washington Spokane The Spokesman-Review 1 1 1 1 January 2012Washington Sunnyside Daily Sun News 1 1 January 2012Washington Tacoma News Tribune 1 1 January 2012Washington Vancouver Columbian 1 1 January 2012Washington Walla Walla Union-Bulletin 1 1 January 2012Washington Wenatchee World 1 1 January 2012Washington Whidbey News Times 1 1 January 2012Washington Yakima Herald-Republic 1 1 January 2012Washington Yakima Herald-Republic 1 1 1 1 January 2012West Virginia Beckley Register-Herald 1 1 January 2012West Virginia Bluefield Telegraph 1 1 January 2012West Virginia Charleston Gazette-Mail 1 1 1 1 January 2012West Virginia Clarksburg Exponent Telegram 1 1 January 2012West Virginia Elkins Inter-Mountain 1 1 January 2012West Virginia Fairmont Times-West Virginian 1 1 January 2012West Virginia Gilbert Gilbert Times 1 1 January 2012West Virginia Hamlin Lincoln Journal 1 1 January 2012West Virginia Hamlin The Weekly News Sentinel 1 1 January 2012West Virginia Harrisville Ritchie Gazette 1 1 January 2012West Virginia Huntington Herald-Dispatch 1 1 January 2012West Virginia Keyser Mineral Daily News Tribune 1 1 January 2012West Virginia Lewisburg Mountain Messenger 1 1 January 2012West Virginia Logan Logan Banner 1 1 January 2012West Virginia Martinsburg Sunday Journal 1 1 January 2012West Virginia Montgomery Montgomery Herald 1 1 January 2012West Virginia Morgantown Dominion Post 1 1 January 2012West Virginia Oak Hill The Fayette Tribune 1 1 January 2012West Virginia Parkersburg News 1 1 January 2012West Virginia Petersburg Grant County Press 1 1 January 2012West Virginia Pineville Independent Herald 1 1 January 2012West Virginia Princeton Princeton Times 1 1 1 1 January 2012West Virginia Ravenswood The Star Herald 1 1 January 2012West Virginia Romney Hampshire Review 1 1 January 2012West Virginia Sutton Braxton Democrat-Central 1 1 January 2012West Virginia Wayne Wayne County News 1 1 January 2012West Virginia Wheeling Sunday News-Register 1 1 January 2012West Virginia Williamson Daily News 1 1 January 2012Wisconisn Amery Amery Free Press 1 1 January 2012Wisconisn Ashland The Daily Press 1 1 January 2012Wisconisn Baldwin The Baldwin Bulletin 1 1 January 2012Wisconisn Baraboo Baraboo News Republic 1 1 1 1 January 2012Wisconisn Barron Barron News - Shield 1 1 January 2012Case 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 195 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceWisconisn Beaver Dam Daily Citizen 1 1 1 1 January 2012Wisconisn Black River Falls Jackson County Chronicle 1 1 January 2012Wisconisn Burlington Burlington Standard Press 1 1 January 2012Wisconisn Cedarburg Ozaukee County News Graphic 1 1 January 2012Wisconisn Chetek The Chetek Alert 1 1 January 2012Wisconisn Clintonville Clintonville Tribune Gazette 1 1 January 2012Wisconisn Cumberland Cumberland Advocate 1 1 January 2012Wisconisn Delavan The Delavan Enterprise 1 1 January 2012Wisconisn Eagle River Vilas County News - Review 1 1 January 2012Wisconisn East Troy The East Troy News 1 1 January 2012Wisconisn Elkhorn The Elkhorn Independent 1 1 January 2012Wisconisn Fort Atkinson Daily Jefferson County Union 1 1 January 2012Wisconisn Hammond Central St. Croix News 1 1 January 2012Wisconisn Hayward Sawyer County Record 1 1 January 2012Wisconisn Iola Manawa Advocate 1 1 January 2012Wisconisn Iola The Iola Herald 1 1 January 2012Wisconisn Lake Geneva Lake Geneva Times 1 1 January 2012Wisconisn Lancaster Grant County Herald Independent 1 1 January 2012Wisconisn Marinette Eagle Herald 1 1 January 2012Wisconisn Mauston Juneau County Star-Times 1 1 January 2012Wisconisn Merrill Foto News 1 1 January 2012Wisconisn Monroe The Monroe Times 1 1 January 2012Wisconisn Osceola Osceola Sun 1 1 January 2012Wisconisn Platteville The Platteville Journal 1 1 January 2012Wisconisn Portage Daily Register 1 1 1 1 January 2012Wisconisn Racine The Journal Times 1 1 January 2012Wisconisn Reedsburg Reedsburg Times Press 1 1 January 2012Wisconisn Rhinelander Star Journal 1 1 January 2012Wisconisn Sauk City The Sauk Prairie Eagle 1 1 January 2012Wisconisn Shawano Shawano Leader 1 1 January 2012Wisconisn Spooner Spooner Advocate 1 1 January 2012Wisconisn Twin Lakes Westosha Report 1 1 January 2012Wisconisn Union Grove Westine Report 1 1 January 2012Wisconisn Walworth The Times, Walworth 1 1 January 2012Wisconisn Washburn The County Journal 1 1 January 2012Wisconisn Waterford Waterford Post 1 1 January 2012Wisconisn Watertown Times Publishing Company 1 1 January 2012Wisconisn Waukesha Waukesha Freeman 1 1 January 2012Wisconisn Waupaca Waupaca County Post 1 1 January 2012Wisconisn Wautoma The Waushara Argus 1 1 January 2012Wisconisn West Bend West Bend Daily News 1 1 January 2012Wisconisn Weyauwega The Chronicle 1 1 January 2012Wisconisn Whitewater Whitewater Register 1 1 January 2012Wisconisn Wisconsin Dells Wisconsin Dells Events 1 1 January 2012Wisconsin Appleton Post-Crescent 1 1 January 2012Wisconsin Beloit My Stateline Shopper 1 1 January 2012Wisconsin Beloit News 1 1 January 2012Wisconsin Chippewa Falls Chippewa Valley Newspapers 1 1 January 2012Wisconsin Eau Claire Leader-Telegram 1 1 January 2012Wisconsin Fond Du Lac Reporter 1 1 January 2012Wisconsin Green Bay Press-Gazette 1 1 January 2012Wisconsin Janesville Gazette 1 1 January 2012Wisconsin Kenosha News 1 1 January 2012Wisconsin La Crosse Tribune 1 1 January 2012Wisconsin Madison State Journal 1 1 January 2012Wisconsin Manitowoc/Two Rivers Herald Times Reporter 1 1 January 2012Wisconsin Marinette Eagle Herald 1 1 January 2012Case 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 LitigationEconomic and Property DamageState City Newspaper American Profile Parade USA Weekend Frequency Duplication SourceWisconsin Marshfield New Herald 1 1 January 2012Wisconsin Milwaukee Journal Sentinel 1 1 January 2012Wisconsin Oshkosh Northwestern 1 1 January 2012Wisconsin Racine Journal Times 1 1 January 2012Wisconsin Rhinelander Daily News 1 1 January 2012Wisconsin Sheboygan Press 1 1 January 2012Wisconsin Superior Telegram 1 1 January 2012Wisconsin Watertown Times 1 1 January 2012Wisconsin Wausau-Stevens Point Herald-Central WI Sunday 1 1 January 2012Wyoming Afton Star Valley Independent 1 1 January 2012Wyoming Casper Star-Tribune 1 1 1 1 January 2012Wyoming Cheyenne Wyoming Tribune-Eagle 1 1 January 2012Wyoming Cody The Cody Enterprise 1 1 January 2012Wyoming Douglas Douglas Budget 1 1 January 2012Wyoming Gillette The News-Record 1 1 January 2012Wyoming Landers The Journal 1 1 January 2012Wyoming Laramie Boomerang 1 1 January 2012Wyoming Powell The Powell Tribune 1 1 January 2012Wyoming Rawlins Rawlins Daily Times 1 1 January 2012Wyoming Riverton The Ranger 1 1 January 2012Wyoming Rock Sprints Daily Rocket-Miner 1 1 January 2012Wyoming Sheridan Sheridan Press 1 1 January 2012Wyoming Sundance The Sundance Times 1 1 January 2012Wyoming Torrington The Torrington Telegram 1 1 January 2012Wyoming Worland Northern Wyoming Daily News 1 1 January 2012TOTAL 1350 522 686 2191 367American Profile Circ. Parade Circ. USA Weekend Circ.1/1/12 1/1/12 1/1/1210,000,000 32,400,000 22,654,682Case 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 ListCase 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 LitigationEconomic and Property Damage SettlementLocal Newspaper ListTexasPublication Distribution Language Insertions Ad SizeAlvin Advertiser And Sun-Advertiser Combo Alvin, TX English 8 Full PageBay City Tribune Bay City, TX English 4 Full PageBeaumont Enterprise Beaumont, TX English 4 Full PageClute Facts Clute, TX English 4 Full PageGalveston County Daily News Galveston, TX English 4 Full PageHometown Press- Houston Winnie, TX English 4 Full PageHouston Chronicle Houston, TX English 4 Full PageJackson County Herald-Tribune Edna, TX English 4 Full PagePearland Reporter News Pearland, TX English 4 Full PagePort Arthur News Port Arthur, TX English 4 Full PageTexas City Post Texas City, TX English 4 Full PageJasper Newsboy Jasper, TX English 4 Full PageNewton County News Newton, TX English 4 Full PageOrange Leader Orange, TX English 4 Full PageBaytown Sun Baytown, TX English 4 Full PageBellville Times Bellville, TX English 4 Full PageBrenham Banner-Press Brenham, TX English 4 Full PageEl Campo Leader-News El Campo, TX English 4 Full PageFort Bend Herald Rosenberg, TX English 4 Full PageFort Bend/Southwest Star Stafford, TX English 4 Full PageHouston Community Newspapers Group Combo Houston, TX English 120 Full PageHouston County Courier Crockett, TX English 4 Full PageHuntsville Item Huntsville, TX English 4 Full PageKaty Times Katy, TX English 4 Full PagePolk County Enterprise Livingston, TX English 4 Full PageTrinity Standard Livingston, TX English 4 Full PageTotal 224LouisianaPublication Distribution Language Insertions Ad SizeAlexandria News Weekly Alexandria, LA English 4 Full PageAlexandria Town Talk Alexandria, LA English 4 Full PageBunkie Record Marksville, LA English 4 Full PageOakdale Journal Oakdale, LA English 4 Full PageCase 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 PageFranklin Banner-Tribune Franklin, LA English 4 Full PageGonzales Weekly Citizen Gonzales, LA English 4 Full PageLivingston Parish News Denham Springs, LA English 4 Full PageMorgan City Daily Review Morgan City, LA English 4 Full PageNapoleonville Assumption Pioneer Napoleonville, LA English 4 Full PagePierre Part Bayou Journal Pierre Part, LA English 4 Full PageBaton Rouge Advocate Baton Rouge, LA English 4 Full PagePort Allen West Side Journal Port Allen, LA English 4 Full PagePostsouth News Plaquemine, LA English 4 Full PageZachary Plainsman-News Zachary, LA English 4 Full PageAbbeville Meridional Abbeville, LA English 4 Full PageGueydan Journal Gueydan, LA English 4 Full PageKaplan Herald Kaplan, LA English 4 Full PageNew Iberia Daily Iberian New Iberia, LA English 4 Full PageSt. Martinville Teche News Saint Martinville, LA English 4 Full PageBasile Weekly Basile, LA English 4 Full PageCrowley Post-Signal Crowley, LA English 4 Full PageEunice News Eunice, LA English 4 Full PageJennings Daily News Jennings, LA English 4 Full PageKinder Courier News Kinder, LA English 4 Full PageLafayette Daily Advertiser Lafayette, LA English 4 Full PageOpelousas Daily World Opelousas, LA English 4 Full PageRayne Acadian-Tribune Rayne, LA English 4 Full PageRayne Independent Rayne, LA English 4 Full PageVille Platte Gazette Ville Platte, LA English 4 Full PageCameron Parish Pilot Dequincy, LA English 4 Full PageDequincy News Dequincy, LA English 4 Full PageLake Charles American Press Lake Charles, LA English 4 Full PageSulphur Southwest Daily News Sulphur, LA English 4 Full PageVinton News Sulphur, LA English 4 Full PageBeauregard Daily News Deridder, LA English 4 Full PageMoss Bluff News Sulphur, LA English 4 Full PageBastrop Daily Enterprise Bastrop, LA English 4 Full PageCatahoula News Booster Jonesville, LA English 4 Full PageConcordia Sentinel Ferriday, LA English 4 Full PageFranklin Sun Winnsboro, LA English 4 Full PageMonroe News-Star Monroe, LA English 4 Full PageRuston Daily Leader Ruston, LA English 4 Full PageWinn Parish Enterprise Winnfield, LA English 4 Full PageHammond Daily Star Hammond, LA English 4 Full PageHouma Daily Courier/Daily Comet Combo Houma, LA English 8 Full PageLObservateur La Place, LA English 4 Full PageNew Orleans Times-Picayune New Orleans, LA English 4 Full PagePlaquemines Gazette Belle Chasse, LA English 4 Full PageSt. Bernard Voice Arabi, LA English 4 Full PageSt. Charles Herald-Guide Boutte, LA English 4 Full PageSt. Tammany Farmer Covington, LA English 4 Full PageSt. Tammany News Slidell, LA English 4 Full PageCase 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 PageBogalusa Daily News Bogalusa, LA English 4 Full PageFranklinton Era-Leader Franklinton, LA English 4 Full PagePicayune Item Picayune, MS English 4 Full PagePoplarville Democrat Poplarville, MS English 4 Full PageSt. Bernard News Metairie, LA English 4 Full PageSt. Francisville Democrat Saint Francisville, LA English 4 Full PageAtlanta Citizens Journal Atlanta, TX English 4 Full PageBarksdale Warrior Shreveport, LA English 4 Double Page SpreadBowie County Citizens Tribune And DeKalbNews ComboNew Boston, TX English 8 Full PageCenter Light & Champion Center, TX English 4 Full PageDaingerfield Bee Daingerfield, TX English 4 Full PageLeesville Daily Leader De Ridder, LA English 4 Full PageMarshall News Messenger Marshall, TX English 4 Full PageMinden Press-Herald Minden, LA English 4 Full PageMt. Pleasant Daily Tribune Mount Pleasant, TX English 4 Full PageNatchitoches Times Natchitoches, LA English 4 Full PageShreveport Times Shreveport, LA English 4 Double Page SpreadTexarkana Gazette Texarkana, TX English 4 Full PageTotal 296MississippiPublication Distribution Language Insertions Ad SizeBiloxi D ‘Iberville Press Biloxi, MS English 4 Full PageBiloxi-Gulfport Sun Herald Biloxi-gulfport, MS English 4 Full PageMississippi Press Pascagoula, MS English 4 Full PageOcean Springs Record Ocean Springs, MS English 4 Full PageSea Coast Echo Bay Saint Louis, MS English 4 Full PageGreene County Herald Leakesville, MS English 4 Full PageColumbian-Progress Columbia, MS English 4 Full PageHattiesburg Lamar Times Hattiesburg, MS English 4 Double Page SpreadPetal News Hattiesburg, MS English 4 Double Page SpreadStone County Enterprise Wiggins, MS English 4 Full PageTimes Of Stone County Wiggins, MS English 4 Full PageBrookhaven Daily Leader Brookhaven, MS English 4 Full PageCarthaginian Carthage, MS English 4 Full PageDeer Creek Pilot Rolling Fork, MS English 4 Full PageJackson Clarion Ledger/HattiesburgAmerican ComboJackson, MS English 8 Full PageJasper County News Bay Springs, MS English 4 Full PageKosciusko Star-Herald Kosciusko, MS English 4 Full PageLawrence County Press Monticello, MS English 4 Full PageMcComb Enterprise-Journal Mccomb, MS English 4 Full PageNatchez Democrat Natchez, MS English 4 Full PageRankin County News Brandon, MS English 4 Full PageTylertown Times Tylertown, MS English 4 Full PageCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 201 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Vicksburg Evening Post Vicksburg, MS English 4 Full PageWayne County News Waynesboro, MS English 4 Full PageYazoo Herald Yazoo City, MS English 4 Double Page SpreadGeorge County Times Lucedale, MS English 4 Full PageBooneville Banner-Independent Booneville, MS English 4 Full PageChickasaw Journal Houston, MS English 4 Full PageColumbus Commercial Dispatch Columbus, MS English 4 Full PageColumbus Packet Columbus, MS English 4 Double Page SpreadLamar Democrat & The Sulligent News Vernon, AL English 4 Full PageLouisville Winston County Journal Louisville, MS English 4 Double Page SpreadMacon Beacon Macon, MS English 4 Full PageN.E. Mississippi Daily Journal Tupelo, MS English 4 Full PageNew Albany Gazette New Albany, MS English 4 Full PagePontotoc Progress Pontotoc, MS English 4 Full PagePrentiss Headlight Prentiss, MS English 4 Full PageStarkville Daily News Starkville, MS English 4 Full PageWebster Progress-Times Louisville, MS English 4 Double Page SpreadWest Point Daily Times Leader West Point, MS English 4 Full PageCleveland Bolivar Commercial Cleveland, MS English 4 Full PageEnterprise-Tocsin Indianola, MS English 4 Double Page SpreadGreenville Delta Democrat-Times Greenville, MS English 4 Double Page SpreadGreenwood Commonwealth Greenwood, MS English 4 Full PageGrenada Star Grenada, MS English 4 Full PageChoctaw Sun-Advocate Gilbertown, AL English 4 Full PageMeridian Star Meridian, MS English 4 Full PageNeshoba Democrat Philadelphia, MS English 4 Full PageNewton County Appeal Union, MS English 4 Full PageSumter County Record-Journal Livingston, AL English 4 Full PageBatesville Panolian Batesville, MS English 4 Full PageClarksdale Press Register Clarksdale, MS English 4 Double Page SpreadCorinth Daily Corinthian Corinth, MS English 4 Full PageDeSoto Appeal Southaven, MS English 4 Full PageDesoto Times-Tribune Hernando, MS English 4 Double Page SpreadOxford Eagle Oxford, MS English 4 Full PageQuitman County Democrat Marks, MS English 4 Full PageSenatobia Democrat Senatobia, MS English 4 Full PageSouth Reporter Holly Springs, MS English 4 Full PageSouthern Advocate Ashland, MS English 4 Full PageSouthern Sentinel Ripley, MS English 4 Full PageTunica Times Tunica, MS English 4 Full PageTotal 252AlabamaPublication Distribution Language Insertions Ad SizeBaldwin Register Daphne, AL English 4 Full PageGulf Coast Newspapers Combo Robertsdale, AL English 24 Full PageMobile Press-Register Mobile, AL English 4 Full PageCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 202 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Washington County News - Alabama Citronelle, AL English 4 Full PageFlomaton Tri-City Ledger Flomaton, AL English 4 Full PageJackson South Alabamian Jackson, AL English 4 Full PageMonroe Journal Monroeville, AL English 4 Full PageDothan Eagle Dothan, AL English 4 Full PageEnterprise Ledger Enterprise, AL English 4 Full PageGeneva County Reaper Geneva, AL English 4 Full PageAnniston Star Anniston, AL English 4 Full PageBessemer Western Star Bessemer, AL English 4 Full PageBirmingham News Birmingham, AL English 4 Full PageBlount Countian Oneonta, AL English 4 Full PageClanton Advertiser Clanton, AL English 4 Full PageCullman Times Cullman, AL English 4 Full PageFayette Times-Record Fayette, AL English 4 Full PageGadsden Times Gadsden, AL English 4 Full PageGuntersville Advertiser-Gleam Guntersville, AL English 4 Full PageHaleyville Northwest Alabamian Haleyville, AL English 4 Full PageHamilton Journal Record Hamilton, AL English 4 Full PageJasper Daily Mountain Eagle Jasper, AL English 4 Full PageNorth Jefferson News Gardendale, AL English 4 Full PageShelby County Reporter Columbiana, AL English 4 Full PageSt. Clair News-Aegis Pell City, AL English 4 Full PageSylacauga Daily Home Sylacauga, AL English 4 Full PageTuscaloosa News Tuscaloosa, AL English 4 Full PageAthens News Courier Athens, AL English 4 Full PageDecatur Daily Decatur, AL English 4 Full PageFlorence Times Daily Florence, AL English 4 Full PageFort Payne Times-Journal Fort Payne, AL English 4 Full PageFranklin County Times Russellville, AL English 4 Full PageHuntsville Times Huntsville, AL English 4 Full PageSand Mountain Reporter Albertville, AL English 4 Full PageScottsboro Daily Sentinel Scottsboro, AL English 4 Full PageAlexander City Outlook Alexander City, AL English 4 Full PageAndalusia Star-News Andalusia, AL English 4 Full PageDemopolis Times Demopolis, AL English 4 Full PageFlorala News Florala, AL English 4 Full PageGreenville Advocate Greenville, AL English 4 Full PageMontgomery Advertiser Montgomery, AL English 4 Full PageMontgomery Independent / MiddlebrookIndependent ComboMontgomery, AL English 8 Double Page SpreadOpp News Opp, AL English 4 Full PageSelma Times-Journal Selma, AL English 4 Full PageTallassee Tribune Wetumpka, AL English 4 Full PageTroy Messenger Troy, AL English 4 Full PageWetumpka Eclectic Observer Wetumpka, AL English 4 Full PageWetumpka Herald Wetumpka, AL English 4 Full PageCitizen Of East Alabama Phenix City, AL English 4 Full PageEufaula Tribune Eufaula, AL English 4 Full PageRandolph Leader Roanoke, AL English 4 Full PageCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 203 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Valley Times-News -Lanett Lanett, AL English 4 Full PageCleburne News Heflin, Al English 4 Full PageTotal 236FloridaPublication Distribution Language Insertions Ad SizeJackson County Floridan Marianna, FL English 4 Full PageArcadian Arcadia, FL English 4 Double Page SpreadBeach Observer Fort Meyers, FL English 4 Double Page SpreadBoca Beacon Boca Grande, FL English 4 Double Page SpreadBokeelia Pine Island Eagle Bokeelia, FL English 4 Double Page SpreadBonita Banner Naples, FL English 4 Full PageCape Coral Daily Breeze Cape Coral, FL English 4 Full PageCharlotte Sun Port Charlotte, FL English 4 Full PageCollier Citizen Naples, FL English 4 Full PageFort Myers News-Press Fort Myers, FL English 4 Full PageLehigh Acres Citizen Lehigh Acres, FL English 4 Double Page SpreadLehigh News Star Lehigh Acres, FL English 4 Full PageMarco Eagle Marco Island, FL English 4 Full PageMarco Island Sun Times Marco Island, FL English 4 Full PageNaples Daily News Naples, FL English 4 Full PageNorth Fort Myers Neighbor Cape Coral, FL English 4 Double Page SpreadSanibel/Captiva Islander Sanibel, FL English 4 Double Page SpreadAlachua County Today Alachua, FL English 4 Full PageChiefland Citizen/Tri-CountyBulletin/Cedar Key Beacon/WillistonPioneer Sun NewsChiefland, FL English 16 Double Page SpreadDixie County Advocate Cross City, FL English 4 Full PageGainesville Guardian Gainesville, FL English 4 Full PageGainesville Record Gainesville, FL English 4 Double Page SpreadGainesville Sun Gainesville, FL English 4 Full PageGilchrist County Journal Trenton, FL English 4 Full PageNorth Florida Herald High Springs, FL English 4 Full PageBoca Raton Forum Pompano Beach, FL English 4 Double Page SpreadBoynton Forum Pompano Beach, FL English 4 Double Page SpreadCoral Springs/Parkland Forum Pompano Beach, FL English 4 Double Page SpreadDelray Forum Pompano Beach, FL English 4 Double Page SpreadFlorida Keys Keynoter Tavernier, FL English 4 Full PageFort Lauderdale Sun-Sentinel Fort Lauderdale, FL English 4 Full PageForum Publishing Group-Boca RatonComboPompano Beach, FL English 16 Double Page SpreadKey Biscayne Islander News Key Biscayne, FL English 4 Double Page SpreadKey West Citizen Key West, FL English 4 Full PageLake Worth Forum Pompano Beach, FL English 4 Full PageCase 2:10-md-02179-CJB-SS Document 6266-2 Filed 04/18/12 Page 204 of 206Uploaded by law firms which sponsor the website http://www.BP-Settlement-Help.org
    • Margate/Coconut Creek Forum Pompano Beach, FL English 4 Double Page SpreadMiami Herald Miami, FL English 4 Full PagePalm Beach Gardens Jupiter Palm Beach Gardens, FL English 4 Double Page SpreadPlantation Forum Deerfield Beach, FL English 4 Double Page SpreadPompano Beach Sentry Pompano Beach, FL English 4 Full PagePompano Forum Pompano Beach, FL English 4 Double Page SpreadSouth Dade News Leader Homestead, FL English 4 Full PageSunrise Forum Pompano Beach, FL English 4 Double Page SpreadTamarac/N. Lauderdale Forum Pompano Beach, FL English 4 Double Page SpreadTavernier Reporter Tavernier, FL English 4 Full PageWellington Forum Pompano Beach, FL English 4 Double Page SpreadCrestview News Bulletin Crestview, FL English 4 Full PageDestin Log Destin, FL English 4 Full PageGulf Breeze News Gulf Breeze, FL English 4 Full PageNavarre Press Navarre, FL English 4 Full PageNorthwest Florida Daily News Fort Walton Beach, FL English 4 Full PagePensacola News Journal Pensacola, FL English 4 Full PageSanta Rosa Press Gazette Milton, FL English 4 Full PageApalachicola and Carrebelle Times/PortSt. Joe Star ComboApalachicola, FL English 8 Full PageBlountstown County Record Blountstown, FL English 4 Full PageBristol Calhoun-Liberty Journal Bristol, FL English 4 Double Page SpreadGraceville News Graceville, FL English 4 Full PageHerald Breeze De Funiak Springs, FL English 4 Full PageHolmes County Times-Advertiser Bonifay, FL English 4 Full PagePanama City News Herald Panama City, FL English 4 Full PageWalton Sun Santa Rosa Beach, FL English 4 Full PageWashington County News - Florida Chipley, FL English 4 Full PageChattahoochee Twin City News Chattahoochee, FL English 4 Full PageGadsden County Times Quincy, FL English 4 Full PageHavana Herald Havana, FL English 4 Full PageJasper News Jasper, FL English 4 Full PageLake City News Advertiser Lake City, FL English 4 Double Page SpreadMadison County Carrier Madison, FL English 4 Full PageMadison Enterprise Recorder Madison, FL English 4 Full PageMayo Free Press Live Oak, FL English 4 Full PageMonticello News Monticello, FL English 4 Full PageSuwannee Democrat Live Oak, FL English 4 Full PageTaco Times Perry, FL English 4 Full PageTallahassee Democrat Tallahassee, FL English 4 Full PageWakulla News Crawfordville, FL English 4 Full PageBradenton Herald Bradenton, FL English 4 Full PageBrandon News & Tribune Brandon, FL English 4 Double Page SpreadCarrollwood News & Tribune Tampa, FL English 4 Double Page SpreadCitrus County Chronicle Crystal River, FL English 4 Full PageFort Meade Leader Fort Meade, FL English 4 Full PageHernando Today Brooksville, FL English 4 Full PageHighlands Today Sebring, FL English 4 Full PageLake Wales News Lake Wales, FL English 4 Full PageCase 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 PageLongboat Observer Longboat Key, FL English 4 Double Page SpreadNew Port Richey Sunbelt NewspapersComboNew Port Richey, FL English 8 Double Page SpreadNew Port Richey Suncoast News New Port Richey, FL English 4 Double Page SpreadNortheast News & Tribune Tampa, FL English 4 Double Page SpreadNorthwest News & Tribune Hillsborough, FL English 4 Double Page SpreadPelican Press Sarasota, FL English 4 Double Page SpreadPlant City Courier & Tribune Plant City, FL English 4 Double Page SpreadPolk County Democrat-Leader Bartow, FL English 4 Full PageSarasota Herald-Tribune Sarasota, FL English 4 Full PageSarasota Observer Sarasota, FL English 4 Double Page SpreadSebring News-Sun Sebring, FL English 4 Full PageSouth & Central Tampa News & Tribune Tampa, FL English 4 Double Page SpreadSouth Shore News & Tribune Tampa, FL English 4 Double Page SpreadSt. Petersburg Times/Tampa Bay Times Saint Petersburg, FL English 4 Full PageSuncoast News-Pasco New Port Richey, FL English 4 Double Page SpreadTampa Tribune Tampa, FL English 4 Full PageVenice Gondolier Sun Venice, FL English 4 Full PageWauchula Herald-Advocate Wauchula, FL English 4 Full PageWinter Haven News Chief Winter Haven, FL English 4 Full PageZephyrhills News Zephyrhills, FL English 4 Full PageTotal 448Case 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