Melendres # 1696 P Memo Re Notice Costs

8/16/2019 Melendres # 1696 P Memo Re Notice Costs

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Cecillia D. Wang ( Pro Hac Vice )[email protected]

Nida Vidutis*[email protected]

ACLU FoundationImmigrants’ Rights Project39 Drumm StreetSan Francisco, CA 94111Telephone: (415) 343-0775Facsimile: (415) 395-0950

Daniel J. [email protected] Muñoz Furnish

[email protected] Foundation of Arizona3707 N. 7th Street, Suite 235Phoenix, AZ 85014Telephone: (602) 650-1854Facsimile: (602) 650-1376

*Application for admission pro hac vice forthcoming

Attorneys for Plaintiffs (Additional attorneys for Plaintiffs listed on next page)

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF ARIZONA

Manuel de Jesus Ortega Melendres,et al. ,

Plaintiffs,

v.

Joseph M. Arpaio, et al. ,

Defendants.

)))))

))))))))

CV-07-2513-PHX-GMS

PLAINTIFFS’ MEMORANDUM INSUPPORT OF A $200,000 NOTICE

BUDGET FOR CIVIL CONTEMPTCOMPENSATION SCHEMEPURSUANT TO THE COURT’SORDER OF MAY 31, 2016

Case 2:07-cv-02513-GMS Document 1696 Filed 06/01/16 Page 1 of 6


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Additional Attorneys for Plaintiffs:

Andre I. Segura ( Pro Hac Vice )[email protected]

ACLU FoundationImmigrants’ Rights Project125 Broad Street, 17th Floor

New York, NY 10004Telephone: (212) 549-2676Facsimile: (212) 549-2654

Jorge M. Castillo ( Pro Hac Vice ) [email protected]

Julia Gomez* [email protected] Mexican American Legal Defense andEducational Fund634 South Spring Street, 11th FloorLos Angeles, CA 90014Telephone: (213) 629-2512Facsimile: (213) 629-0266

Anne Lai ( Pro Hac Vice ) [email protected] E. Peltason, Suite 3500Irvine, CA 92697Telephone: (949) 824-9894Facsimile: (949) 824-0066

James B. Chanin ( Pro Hac Vice ) [email protected] Offices of James B. Chanin3050 Shattuck AvenueBerkeley, CA 94705Telephone: (510) 848-4752Facsimile: (510) 848-5819

Stanley Young ( Pro Hac Vice )[email protected] & Burling LLP333 Twin Dolphin Drive, Suite 700Redwood Shores, CA 94065Telephone: (650) 632-4700Facsimile: (650) 632-4800

*Application for admission pro hac vice forthcoming

Tammy Albarran ( Pro Hac Vice )[email protected] E. Pedley ( Pro Hac Vice )[email protected] & Burling LLPOne Front Street

San Francisco, CA 94111Telephone: (415) 591-7066Facsimile: (415) 955-6566



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THE BUDGET FOR BROWNGREER’S NOTICE PLAN SHOULD BE $200,000

After conferring with BrownGreer PLC (“BrownGreer”), and based upon their advice,

Plaintiffs propose that a budget of $200,000 is necessary to achieve adequate notice to

persons who were subject to detentions in violation of the December 23, 2011 preliminary

injunction and give them the best chance of participation in the court-ordered compensation

scheme. Without the widespread, effective notice plan afforded by a $200,000 budget, there

is substantial risk that the injured persons will not be aware of the availability of

compensation and will be prejudiced in their ability to obtain just compensation for harms

they suffered as a result of MCSO’s contemptuous conduct. A more robust notice program

is warranted in this case in part because Defendants have not undertaken independent effortsto locate individuals harmed by violations of the preliminary injunction, and because they

failed to document all immigration detentions. Contempt Findings ¶ 159. Further, many

years have passed since some of the detentions occurred and injured persons may not be

aware that they should consider making a claim for the improper MCSO detention. A

document created by BrownGreer outlining the specific breakdown of costs associated with

the proposed notice plan is attached as Exhibit A. While the specifics of the plan outlined by

BrownGreer are subject to the Parties’ input, it provides a helpful understanding of the type

of widespread outreach that could be achieved with the proposed budget.

As evidenced in Exhibit A, $200,000 provides for a more extensive radio campaign,

which according to BrownGreer’s research has the highest reach among Latino audiences,

thereby maximizing the chances of reaching individuals who were improperly detained by

MCSO. Based upon that information, a significant portion of the budget would be spent on

radio advertising on many different stations and in English and Spanish for at least thirty

days. The smaller budget proposed by Defendants would result in fewer days of radio spots

and would restrict notice of the plan to fewer stations. $200,000 is needed to secure

advertising on radio stations with the largest Latino audiences and reach a larger number of

individuals who were detained.



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The $200,000 budget would also allow BrownGreer to utilize strategic partnerships

with other organizations, including nongovernmental groups in Arizona and Mexico with

expertise working with hard-to-reach migrant communities (“Public Relations”). Local

nongovernmental organizations are well-positioned to reach directly potential victims of

Defendants’ contemptuous detentions and serve as effective sources of information regarding

the compensation plan. For that reason, they are vital to an effective outreach program, and

ought to be funded.

Plaintiffs respectfully request that the Court issue an order that Maricopa County

provide $200,000 for a notice budget for the victim compensation mechanism as part of the

remedy for the civil contempt.RESPECTFULLY SUBMITTED this 1st day of June, 2016.

By: /s/ Lauren E. Pedley

Cecillia D. Wang ( Pro Hac Vice )Andre I. Segura ( Pro Hac Vice )

Nida Vidutis*ACLU FoundationImmigrants’ Rights Project

Daniel PochodaBrenda Muñoz Furnish ACLU Foundation of Arizona

Anne Lai ( Pro Hac Vice )

Stanley Young ( Pro Hac Vice )Tammy Albarran ( Pro Hac Vice )Lauren E. Pedley ( Pro Hac Vice )

Covington & Burling, LLP

Jorge M. Castillo ( Pro Hac Vice )Julia Gomez*Mexican American Legal Defense andEducational Fund

James B. Chanin ( Pro Hac Vice )



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Attorneys for Plaintiffs

*Applications for admission pro hac viceforthcoming



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CERTIFICATE OF SERVICE

I hereby certify that on June 1, 2016, I electronically transmitted the attached

document to the Clerk’s office using the CM/ECF System for filing. Notice of this filing

will be sent by e-mail to all parties by operation of the Court’s electronic filing system or by

mail as indicated on the Notice of Electronic Filing.

Dated this 1st day of June, 2016.

/s/ Lauren E. Pedley



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EXHIBIT A

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 1 of 15


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© 2015-16 BROWNGREER PLC | 250 ROCKETTS WAY | RICHMOND, VA 23231 | WWW.BROWNGREER.COM

i

I. General Introduction .............................................................................................................. 1

II. Target Audience ..................................................................................................................... 1

III. Available Potential Claimant Data......................................................................................... 3

IV. Individual Notice ................................................................................................................... 4

V. Publication Notice .................................................................................................................. 5

VI. Summary of Notice Plan ...................................................................................................... 11

VII. Estimated Costs .................................................................................................................... 11

T ABLE OF C ONTENTS


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BrownGreer prepared this potential notice plan (the “Plan”) on August 18, 2015 for the Melendres v. Arpaio matter, based on our initial conversations with Plaintiffs’ Counsel and onour review of preliminary compensation procedure proposals prepared by the Parties and

provided to us on a confidential basis on August 7, 2015. Drawing upon our experience and the positions of the Parties, we developed the Plan with an aim to provide an effective and efficientnotice framework in this non-Rule 23 context. On June 1, 2016, we updated Section V.B.5 ofthis Plan (and the corresponding cost line item in Row 7 of the table in Section VII) to reflect anincreased public relations investment proposed by Plaintiffs in light of their interactions with

potential strategic partners presenting interest in assisting affected individuals to whom they havedirect access. The data and information included in this Plan is otherwise original to the August18, 2015 initial version.

The Plan attempts to inform individuals and their passengers (the “ Potential Claimants ”) whowere stopped in violation of the December 2011 preliminary injunction order of the existence ofthis proposed settlement, how it affects them, their rights and obligations under the eventualSettlement Agreement, the actions they may take, the deadlines for acting, and the consequencesof acting or failing to act by the deadline. This document explains the means by which we

preliminarily proposed accomplishing this, how we arrived at those means, and how we wouldimplement the Plan.

A. Target Audience Overview .

We understand that there may be approximately 200 to 500 known individuals, plus anadditional undetermined number of unknown individuals, who are affected by this litigation. The

population of Potential Claimants is mostly males aged 18 to 55 residing in Arizona, though itmay include women and minors who may reside in other southwestern states and possibly inMexico, Guatemala, or Honduras. We further understand that the individuals speak

predominantly, and in some cases exclusively, Spanish, generally have lower educational levels,and for the most part consists of lower income earners. Additionally, we have tailored the Planto reach persons who may be apprehensive of persons in positions of authority.

I. G ENERAL I NTRODUCTION

II. T ARGET A UDIENCE



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B. The Methodology Used to Learn About These Potential Claimants .

To design an effective notice campaign, we must consider and analyze the attributes and the

media consumption habits of the target audience to select properly the media opportunitiesoffering the greatest reach in the most effective manner possible. This allows us to paint aclearer picture of the target group and provide a better understanding of how to contact thesePotential Claimants.

This process begins with identifying the target audience through the use of syndicated researchdata. The two most w idely used options include Nielsen’s Scarborough USA+ study and GfKMRI’s Survey of the American Consumer.

Nielsen’s Scarborough USA+ is a leading provider of local and national market research,shopping patterns, media behaviors, and lifestyle and demographic information of persons in theUnited States. It uses a two-part survey conducted in the spring and the fall of each year withover 210,000 consumers aged 18 and older, which provides a high level of reliability.Scarborough serves multiple industries including print, radio, broadcast TV, cable TV, out ofhome, agency, and sports marketing. Scarborough USA+ emphasizes the media consumptionhabits of persons in the United States. Scarborough USA+ is accredited by the Media RatingCouncil (“MRC”), w hich is an industry-funded organization that establishes standards andguidelines for media industry measurement services to ensure valid and reliable researchmethods.

GfK MRI’s Survey of the American Consumer , also accredited by the MRC, conducts interviewsin the spring and the fall of each year with approximately 26,000 adult consumers in a two-phasecollection process. This survey provides a detailed view of media choices, demographics,lifestyles, and attitudes of consumer usage of almost 6,000 products in 550 categories. The GfKMRI survey focuses on consumer attitudes towards media.

While both sources offer reliable data, we chose to use syndicated data available from Nielsen’sScarborough USA+ to develop a profile of the demographics and media consumption habits ofPotential Claimants, because of Scarborough USA+ ’s larger sample size and in -depth mediaconsumption surveying.

C. Potential Claimant Demographics .

1. Maricopa County is the largest county within the Phoenix market, which covers 9,224square miles.

2. Maricopa County is the 4th most populous county in the United States.3. In Maricopa County, the Hispanic population is over 1.1 Million. 60% of the state’s

Hispanic population resides in Maricopa County.4. 31% of the population in the state of Arizona is Hispanic.

The makeup of the Hispanic population in Maricopa County is roughly 50/50 male/femaleand 18+ population is 736,368, representing 52.4% of the whole.



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49.90

%

50.06%

Gender

Male Female2-11 12-17 18-34 35-64 65+

Age Range 13.5%18.2%17.6%18.9%15.9%

Age Range

We understand that the Defendants can produce some name, date of birth, and address data onapproximately 200 to 500 individuals; however, as most Potential Claimants were never booked,

there may not be identifying information for the entire population of harmed individuals.

III. A VAILABLE P OTENTIAL C LAIMANT D ATA

• Hispanic market rank in the US: #9 • 76% of Phoenix Hispanics prefer to

speak Spanish; best reached usingSpanish language

• Median Phoenix Latino householdincome: $40,537

•

Persons per household: 3.6



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We understand that this will not be a class action settlement and that, accordingly, Fed. R. Civ.P. 23 will not be implicated expressly. Nevertheless, drawing upon Rule 23’s directive that weshould issue “individual notice to all members who can be ident ified through reasonable effort ” and basic concepts of due process, the Plan will attempt direct, individual notice to all PotentialClaimants for whom any direct notice may be attempted using a combination of available contactinformation again, recognizing that Defendants will have contact information for few, if any,Potential Claimants.

As it appears no email notice will be accomplishable, the direct notice necessarily mustcontemplate mailing a notice letter or packet where possible. Such a notice would typicallyinclude at least the following in clear and plain language:

(a) An introductory paragraph that summarizes the key facts of the settlement programand proposed Settlement;

(b) An explanation of Claimant membership and Potential Claimants ’ benefits under theterms of the proposed Settlement;

(c) Instructions that indicate how Potential Claimants may receive benefits from theSettlement;

(d) A clear and brief description of the underlying case and the claims and issuesinvolved;

(e) If applicable, a description of the Potential Claimants ’ right to opt out of or object tothe Settlement and the procedures for doing so, and the right to appear before theCourt at a Fairness Hearing;

(f) Counsel information and a Potential Claimant ’s right to hire his or her own attorney;

(g) Instructions that indicate how Potential Claimants may access a full, detailed noticefrom the Claims Administrator’s website;

(h) The Claims Administrator’s mailing address, website, and toll-free number; and

(i) A notice identification number unique to every Potential Claimant.

We do not expect to receive many addresses, but for those that we do receive we will attempt toverify and update all addresses in the data files from Defendants against the United States Postal

IV. I NDIVIDUAL N OTICE



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Service’s (“USPS”) National Change of Address (“NCOA”) 1 database prior to mailing, toconfirm and update Potential Claimants ’ mailing addresses based on change of addressinformation maintained by the USPS. We will then attempt to (1) certify the addresses through

Coding Accuracy Support System (“CASS”)2

software to ensure the accuracy of ZIP and ZIP + 4codes and completeness of addresses; (2) verify the addresses through Delivery Point Validation(“DPV”) 3 data to confirm the accuracy of and deliverability to the addresses by checking theaddresses against valid deliverable addresses according to the USPS; and (3) process theaddresses against Locatable Address Conversion System (“LACS”) 4 software to compareaddresses with USPS data and update them when there are rural route address changes oremergency services address updates. If a Potential Claimant ’s address is updated based NCOA,CASS, DPV, or LACS, the updated address will be used for mailing the notice. If there are noupdates to a Potential Claimant ’s address in NCOA, CASS, DPV, or LACS, the notice will besent to the most recent mailing address as reflected in Defendants ’ records.

If a notice is returned by the USPS as undeliverable but with a forwarding address, we will promptly re-mail the notice to the updated address provided by the USPS. Mail is forwarded bythe USPS for 12 months after a customer submits a Change of Address order and Change ofAddress orders are maintained by the USPS for 18 months. An undeliverable notice shouldtherefore be returned to BrownGreer by the USPS with a forwarding address in the six-month

period after a Potential Claimant ’s 12 -month forwarding order expires. If the returned noticedoes not identify any updated address from the USPS, we will submit the Potential Claimant ’smailing information to the LexisNexis compendium of domestic addresses for updated addressinformation, if available. In addition, we will update addresses based on requests received fromPotential Claimants.

A. Media Consumption .

With few addresses available to contact Potential Claimants directly, the primary focus of thenotice effort will be to reach persons through other media. Consumers have more choices thanever today. Analyzing their usage and time spent with various media helps us identify the most

1 The NCOA database contains records of all permanent change of address submissions received by the USPS fromindividuals and businesses. The Settlement Potential Claimant list is submitted against the database, and a PotentialClaimant ’s address is automatically updated with the new address from USPS data based on a comparison with the

Potential Claimant ’s name and last known address. 2 CASS is a certification process to standardize the address format and ensure the accuracy of ZIP and ZIP + 4codes. The Potential Claimant list is submitted and the ZIP and ZIP + 4 codes are compared and updated based onthe ZIP and ZIP + 4 codes in the USPS data. 3 DPV confirms addresses against known addresses in the USPS system to verify accuracy and to confirm that mailis deliverable to a particular address. The addresses are compared against valid addresses in the USPS’s AddressManagement System and DPV verifies the accuracy of addresses and reports the deficiencies or errors in incorrectaddresses.4 LACS compares addresses against USPS data, and addresses are updated when there are emergency/E911 updatesor streets are renamed (for example, from Rural Route 2 Box 5 to 123 Main Street).

V. P UBLICATION N OTICE



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effective, efficient mediums to target. Radio has the highest reach among all media with thetarget population:

Reach and time spent with radio is strong across all age groups.

B. Preliminary Media Recommendation .

We recommend a combination of traditional and digital media to reach the primary targetaudience in Phoenix, Arizona, including:

1. Hispanic Radio2. Hispanic Newspaper

91% 87% 80%67%

60%50% 49%

27%

7% 5%

Listened toRadio Past 7

Days

WatchedBroadcast TV

Past Week

Watched AnyNon-Premium

Cable PastWeek

UsedCellphone to

Access Internet

VisitedFacebook Past

Month

Read AnyNewspaper Past Week

VisitedYouTube Past

Month

VisitedPandora

Past Month

Listened toSatellite Radio

Past Week

Visited SpotifyPast Month

WeeklyReach:93.0%

WeeklyTSL:

13hrs:15min

BestDaypart:10a-3p

Hispanics12+

WeeklyReach:93.5%

WeeklyTSL:

14hrs:01min

BestDaypart:10a -3p

Hispanics18+

WeeklyReach:92.7%

WeeklyTSL:

12hrs:24min

BestDaypart:

3-7p

Hispanics 18-34

WeeklyReach:94.6%

WeeklyTSL:

14hrs:19min

BestDayparts:10a-3p, 3-

7p

Hispanics25-54 Weekly

Reach:95.0%

WeeklyTSL:

15hrs:16min

BestDaypart:10a-3p

Hispanics35-64



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3. Digital: Paid Search4. Digital: Banner Ad Display5. Public Relations

1. Hispanic Radio .

Hispanic radio will offer the best opportunity to reach the largest cumulative persons withinour target audience. In addition, it is the primary broadcast medium that is most accessible tothis migrant target population.

We will work with stations that are primarily Spanish dominant, supported with a few top-ranking stations that are English dominant since this demographic is bilingual (80% ofPhoenix Hispanics are Spanish dominant or bilingual).

We will work with stations to develop a campaign that would include:

1. Spot schedule (:60)2. Live reads from local on-air talent (adding strong level of trust)3. Opportunities to have exposure at local events4. Exposure on their website and social media networks

Our strategy will be to develop customized schedules across multiple top-ranking radiostations among the Hispanic listeners. This will provide the highest reach against our targetaudience, ensuring as many people as possible hear the message. The spot schedule aloneshould deliver significant reach against the target audience in this community.

Station Dial Position Format Rank

KLNZ-FM 103.5 Mexican Regional 1

KHOT-FM 105.9 Mexican Regional 2

KNAI-FM 88.3 Mexican Regional 3t

KVVA-FM 107.1 Spanish Adult Hits 3t

KESZ-FM 99.9 Adult Contemporary 5t

KUPD-FM 97.9 Rock 5t

KOMR-FM 106.3 Spanish Adult Hits 7t

KZZP-FM 104.7 CHR 7t

KKFR-FM 98.3 Rhythmic AC 9t

KZON-FM 101.5 Top 40 9t



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2. Hispanic Newspapers .

To extend the reach of our target audience beyond radio, we feel that public notice ads

should be placed in the local Hispanic newspapers as well as an announcement in the primaryArizona newspaper. The newspaper is easily accessible for our target audience.

Publication Published Circulation Ad Size

LaVoz Weekly on Fridays 75,000 Full Page

Prensa Hispana Weekly on Thursdays 48,140 Full Page

The Catholic Sun Monthly 117,000 Full Page

Arizona Republic Main Daily Paper 503,080 1/8 Page

3. Digital: Paid Search .

We will develop and deploy targeted keywords acrossGoogle, Yahoo and Bing search engines, the top threesearch engines based on U.S. Explicit Core SearchShare.

It likely will be challenging to compete with the newsoutlets in the search arena, therefore we recommend asmall paid search campaign for the primary settlementkeywords.



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4. Digital: Banner Ad Display .

Behavioral targeting increases the effectiveness of a campaign by using an individual’s web - browsing behavior, such as pages they have visited or searches they have made, to select thewebsites on which the ads appear. This allows us to reach the broader portion of our targetaudience based on language, geography, and age range.

Facebook ads will allow us to target the audience more narrowly, based on language,geography, age range, income levels and interests.

As our target audience is highly mobile, it will be critical to select mobile-friendly websitesin anticipation of Potential Claimants accessing the internet on non-desktops, such assmartphones. Therefore, we will deploy the following standard ad sizes: (1) 320x50(Mobile), (2) 728x90, (3) 300x250, (4) 160x600, and (5) 300x600.

5. Public Relations .

The proposed public relations efforts focus on communications objectives, tactical measures,media outreach and other assets beneficial to disseminating the notification message. ThePlan will utilize public relations outreach and leverage media relations and digitalcommunications to drive conversation and reach a vast population among local and regionaltarget audiences, with a focus on the below outreach categories:

(a) Maricopa County(1) General Public(2) Community Centers(3) Religious Centers (focus on Catholic groups)

(b) Arizona Hispanic Chamber of Commerce(c) Legal Aid of Arizona(d) Advocacy Groups (National Council of La Raza (NCLR))

Behaviorally targeted banner display ads will appear on strategicallyselected websites as our target audience surfs the web. We can target

both demographically and geographically and display ads in Spanishand/or English.

We preliminarily recommend one to two million impressions deliveredover a 30-day campaign.

We will use a mix of behavioral targeting through Google’s DoubleClickadvertising network exchange, direct placement on news websitescatering to the Latino community, and Facebook ads targeting theHispanic population.



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(e) Recreational and Professional Sports Leagues(1) Soccer(2) Baseball

(f) Media(1) Local Media (print, online, radio); focus on local and community news, Hispanicfocus, legal matters, current affairs and investigative news, advocacy awareness

(2) Regional Media (surrounding states)(g) Party-Selected Strategic Partners (other groups in affected areas reporting access to

Potential Claimants)

The Plan contemplates distributing a print, online, or audio news release as necessary tomedia and general interest groups across Maricopa County and the Phoenix direct markets, aswell as regional markets beyond Arizona, budget permitting. General media for theMaricopa County market include, but are not limited to:

1. Arizona Daily Sun2. Arizona Informant3. Arizona Oddities4. Arizona Republic Online5. Associated Press – Phoenix Bureau6. Coolidge Examiner7. Daily News-Sun8. El Mirage News9. Fountain Hills Times10. Prensa Hispana11. The Catholic Sun12. La Voz Arizona13. Horizonte14. Latino Perspectives15. Peoria Times16. Phoenix New Times17. Pueblo Publishers

18. San Manuel Miner19. Southeast Valley Ledger20. The Arizona Republic21. The Daily Courier22. West Valley View23. KFYI-AM24. KNAU-FM25. Horizonte-KAE-TV26. iHeartMedia, Inc.27. Hubbard Radio28. CBS Radios29. Univision30. Entravision Communications31. Bonneville International Corporation32. Cesar Chavez Foundation33. Family Life Broadcasters, Inc.

The tentative Public Relations Timeline would be:

(a) 30 Days:(1) Direct bulk of Plan outreach efforts to local/regionally targeted media and

community lists(2) Follow-ups, continued research and outreach development(3) Coordinate interview opportunities(4) Monitor PR media coverage

(b) 60 – 90 Days:(1) Continued follow-up and support of Plan(2) Monitor PR media coverage



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C. Regional Target Audience Beyond Phoenix .

A regional public notice campaign will extend beyond the local Phoenix area. It will reach cities

with large Hispanic populations that are likely to have connections to or have travelled throughthe Maricopa County area, with these preliminary suggestions of focus:

1. Arizona: Tucson2. New Mexico: Albuquerque, Santa Fe, Las Cruces3. California: San Diego, Los Angeles4. Nevada: Las Vegas

Traditional media in these markets would run between $500,000 and $1 million, so werecommend utilizing digital paid search and display advertising, as well public relations efforts,to minimize costs but still enjoy productive reach.

D. International Target Audience .

To reach the target population in international markets, we recommend utilizing paid search anddisplay advertising to ensure the highest number of impressions at the highest efficiency.Accordingly, we preliminarily recommend one million to two million impressions directedspecifically to the following markets: (1) Mexico, (2) Honduras, and (3) Guatemala.

The potential Plan thus includes: (1) direct, individual notice by first-class mail where possible,with procedures for verifying addresses and resending undeliverable notices; (2) radio spots; (3)newspaper placements; (4) online paid search words; (5) online website banner and social mediadisplays; and (6) public relations efforts. The Plan will focus on Maricopa County and thegreater Phoenix area with regional targeting beyond to surrounding states and internationaltargeting to three select countries.

We will prepare an estimate of direct notice costs once the quality, quantity, and type of PotentialClaimant data becomes known. While the actual costs will be determined by the notice elementschosen by the Parties and media costs applicable at that time, we can estimate the possible costsof otherwise implementing the Plan described above as follows:

Estimated Costs for Notice Plan (Exclusive of Direct Notice Campaign)Item Estimated Cost

1. Radio Campaign (30 days) $120,0002. Newspaper (1 ad per paper) $16,6653. Digital: Paid Search (30 days) $3,5004. Digital: Banner Ad Display (30 days) $17,500

VI. S UMMARY OF N OTICE P LAN

VII. E STIMATED C OSTS



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Estimated Costs for Notice Plan (Exclusive of Direct Notice Campaign)Item Estimated Cost

5. Digital: Facebook Ad Display (30 days) $10,000

6. Digital: International Markets $20,0007. Public Relations $21,6008. Translation Variable9. Interview Opportunities & Travel Variable

10. Flyer Creation and Printing $3,00011. TOTAL $ 212,265+


Melendres # 1696 P Memo Re Notice Costs

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Transcript of Melendres # 1696 P Memo Re Notice Costs