UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA __________________________________________ ) CLAIRE BROU, et al., ) ) Plaintiffs, ) Case No.: 060838 v. ) ) JUDGE DUVAL FEDERAL EMERGENCY MANAGEMENT ) AGENCY, et al., ) MAGISTRATE JUDGE ) KNOWLES Defendants. ) __________________________________________) SETTLEMENT AGREEMENT This Settlement Agreement ("Settlement Agreement" or "Agreement") is entered into between Plaintiffs Claire Brou, Darlene Crosby (next friend of P.D., a minor), Willie Foster, Donna Graffagnino, Carla Hagler, Robert Thomas Harris, Eugene Johnson, Victoria Sumrall, Terry West, Anita Wilson, Martha Bryant, Cherie LeBlanc, Ronald Levron, Wanda Newbill, and Dora Villanueva, on behalf of themselves and a class of other similarly situated disabled persons who have been displaced by Hurricanes Katrina and Rita (“Plaintiffs”), and the defendants Federal Emergency Management Agency (“FEMA”), Department of Homeland Security (“DHS”), Michael Chertoff, Secretary, Department of Homeland Security, and David Paulison, Director, Federal Emergency Management Agency, (“Defendants”). Plaintiffs and Defendants are referred to herein as “the Parties.” On February 17, 2006, Plaintiffs filed this action in the United States District Court for the Eastern District of Louisiana (the "District Court"). Plaintiffs allege in their complaint that the Defendants have violated section 504 of the Rehabilitation Act (“Section 504"), 29 U.S.C. § 794(a), the Fair Housing Act (“FHA”), 42 U.S.C. § 3604, and the Stafford Act, 42 U.S.C. § 5170 et seq., by denying equal and meaningful access to the temporary housing assistance program for victims of Hurricane Katrina and Hurricane Rita who have disabilities. Defendants maintain that FEMA’s temporary housing assistance program has been and continues to be operated in compliance with all applicable laws, deny that they have violated any of the above statutes, and further deny that plaintiffs are entitled to any relief in this action. The Parties mutually desire to resolve all of the claims asserted by Plaintiffs in this action without the need for further litigation, and without any admission of liability by any party. Accordingly, the Parties hereby agree to compromise, settle and resolve all of the claims asserted by Plaintiffs in this action on the following terms and conditions: 1. Definitions: The following terms, when used in this Settlement Agreement, shall have the following meanings: Section 1.1 “Person with a disability” means a “qualified individual with a handicap” and a “qualified individual with a disability” as those terms are defined in Section 504, 29 U.S.C. §§ 705(20) and 794(a), and FEMA’s implementing regulations, 44 C.F.R. § 16.103; and has a “handicap” as that term is defined in the FHA, 42 U.S.C. § 3602(h). Section 1.2 “Applicant” means a person who has applied for assistance under the Stafford Act pursuant to 42 U.S.C. § 5174. Section 1.3 “Unit” means manufactured housing of any kind, and includes a travel trailer, mobile home, or Park model trailer. Section 1.4 “Currently in Stock” means in FEMA’s possession or subject to its control as of the date a call, which would result in the provision of the particular unit in question, is made to the special toll-free number referred to in paragraph 5. Section 1.5 “UFAS” means the Uniform Federal Accessibility Standards published at 49 Fed. Reg. 31528 (Aug. 7, 1984) and http://www.accessboard.gov/ufas/ufashtml/ufas.htm. Section 1.6 “Accessible Unit” means (A) a Unit that complies with all UFAS requirements except for those standards that have been amended, modified or waived by HUD; or (B) accessible mobile homes or Park Model trailers which do not satisfy all UFAS requirements but have been altered or modified to accommodate the accessibility needs of Class Members. Section 1.7 "Install" or "Provide" means either (i) to deliver an Accessible Unit, with any necessary modifications to ensure that it is, in fact, an Accessible Unit, to the Person With a Disability requesting the Unit or (ii) to make the modifications to a Unit that has already been delivered to, or is currently occupied by, a Person With a Disability, such that the Unit is an Accessible Unit. However, when a Unit is installed on a private or commercial site that is not operated by FEMA, the terms "Install" or "Provide" shall not include the provision of fully functioning utilities other than the completion of all steps that FEMA normally takes to facilitate the provision of such utilities. This section refers solely to FEMA's obligations under this Agreement and shall not waive, alter, or otherwise affect the scope of FEMA's obligations under 42 U.S.C. § 5174. 2. Persons Covered By Agreement: The class of persons covered by and eligible to obtain the benefits of this Agreement (hereinafter referred to as “Class Members”) is defined as all individuals who: A. As of August 29, 2005, resided in Louisiana or Mississippi in areas declared to be Federal Disaster Areas as a result of Hurricane Katrina; or as of September 24, 2005, resided in Louisiana in areas declared to be Federal Disaster Areas as a result of Hurricane Rita; and B. Were displaced from their pre-disaster primary residence or whose pre-disaster primary residences have been rendered uninhabitable as a result of damage caused by Hurricane Katrina or Hurricane Rita; and C. Are in receipt of, or who qualify or will qualify for, direct assistance pursuant to 42 U.S.C. § 5174(c)(1)(B); and D. Are Persons with Disabilities; and E. Have informed or will inform Defendants of their need for a Unit that accommodates their disabilities, but who have not received a Unit with the requested accessibility features. 3. Claims Covered By The Agreement: The claims compromised, settled and resolved by this Agreement, which are hereinafter referred to as the "Class Claims," include any individual or classwide disability discrimination claim, administrative charge, demand, grievance, complaint, right and cause of action of any kind, known or unknown, by a Class Member against FEMA or DHS for monetary, injunctive or equitable relief and/or for attorney's fees, arising from any events, acts, omissions, policies, practices, procedures, conditions or occurrences concerning or relating to FEMA's direct temporary housing assistance program that were raised in paragraphs 159164 of the Complaint filed in this action on February 17, 2006, or such claims that arise within 210 days after the beginning of the Notice Period described in paragraph 4 below. 4. Accessibility Notice: Over a thirty day period commencing 10 days after the Court enters an Order finally approving this Agreement and ending 40 days after the date of such Order (hereinafter the “Notice Period”), FEMA shall disseminate an informational notice in the form prescribed in Attachment A hereto regarding the provision of temporary housing that is accessible to Persons with Disabilities (“the Accessibility Notice”). The purpose of the Accessibility Notice is to emphasize that FEMA is committed to ensuring that individuals with disabilities have meaningful access to its temporary housing assistance programs, to ensure that the needs of victims of Hurricane Katrina and Hurricane Rita with disabilities for temporary housing that is accessible have been appropriately addressed, and to describe the procedures to be followed by Class Members who seek to have FEMA address any unmet accessibility needs. A. Dissemination of the Accessibility Notice: The Accessibility Notice shall be disseminated and publicized by FEMA during the Notice Period as follows: (1) FEMA’s National Processing Service Center in Hyattsville, Maryland shall send one copy of the Accessibility Notice by United States mail to the last known address of each Applicant who: (1) was displaced by Hurricane Katrina or Hurricane Rita, (2) has been determined by FEMA to be eligible for temporary housing assistance, and (3) either has requested but not yet received, or is currently housed in, a FEMA-provided mobile home or trailer. (2) At the inception of the Notice Period, FEMA shall issue a press release that incorporates the substance of the Accessibility Notice, and shall distribute it to the media listed in Attachment B. In addition, throughout the Notice Period, FEMA shall include information contained in the Accessibility Notice on its website, in combination with relevant contact information for those seeking further information. (3) At the inception of the Notice Period and 90 days thereafter, FEMA shall provide a public service announcement that summarizes information contained in the Accessibility Notice to the radio and television stations listed in Attachment B. (4) Copies of the Accessibility Notice shall be available for distribution at each FEMA Disaster Recovery Center in Louisiana and Mississippi. (5) FEMA shall also ensure that the Accessibility Notice is provided to case management workers retained pursuant to the agreement between FEMA and the United Methodist Committee on Relief. 5. Procedure To Be Followed By Class Members Who Seek To Have FEMA Address Unmet Accessibility Needs: On or before the date upon which the Notice Period commences, FEMA shall establish a special toll-free number for each of the Joint Field Offices (“JFO”) in Louisiana and Mississippi for the purpose of receiving calls made in response to the Accessibility Notice described above (“the special toll-free number”). The Louisiana and Mississippi JFO numbers shall be staffed initially with 30 persons and 10 persons, respectively, all of whom shall have some previous experience in conducting pre-placement interviews. The number of FEMA personnel staffing each special toll-free number may be increased or decreased by FEMA over time as warranted by the call volume received. The special toll-free number shall be staffed from 8:00 a.m. to 6:00 p.m. Monday through Saturday (except holidays) during the nine-month period following the commencement of the Notice Period. FEMA will inform individuals staffing its toll-free numbers, other than the special toll-free numbers, about the existence of the special toll-free numbers, and instruct such individuals to provide the special toll-free numbers to callers who may have accessibility needs. To receive the benefits of this Settlement Agreement, Class Members who seek to have FEMA address any unmet accessibility needs must contact FEMA at the special toll-free number no later than 180 days after the Notice Period ends, and request that FEMA address any unmet accessibility needs. 6. Responsibilities of FEMA Intake Personnel Receiving Responses to Accessibility Notice A. Information to be obtained by Intake Personnel: FEMA personnel answering the special toll-free number (hereinafter the “Intake Personnel”) shall obtain information sufficient to enable FEMA to determine whether each caller is a Class Member as defined in paragraph 2 of this Agreement, or is calling on behalf of a Class Member. For each caller who is a Class Member or who calls on behalf of a Class Member, the Intake Personnel shall use the screening questions in Attachment C to this Agreement to obtain information regarding the Class Member’s disabilities, accessibility needs, and current housing arrangements that is sufficient to enable FEMA to determine what further actions, if any, FEMA needs to take to address each Class Member’s accessibility needs. With assistance from plaintiffs’ counsel, FEMA shall develop or modify existing screening protocols and criteria designed to enable the Intake Personnel to identify the accessibility needs of callers and the type of Unit and modifications necessary to address their accessibility needs. FEMA will also train the Intake Personnel on the use of the screening protocols and criteria and any modifications. B. Initial determinations by Intake Personnel: Based upon the information provided by callers, FEMA shall determine: (1) whether the Class Member currently resides in temporary housing that already satisfies or can be altered or modified to satisfy the Class Member’s accessibility needs; (2) whether the Class Member’s need for temporary housing that is accessible can be accommodated by providing rental assistance; (3) whether the Class Member’s need for temporary housing that is accessible can be accommodated by Providing a Unit at a FEMA group site or commercial site that is available for immediate occupancy; (4) whether FEMA needs to Provide a Unit to address the Class Member’s accessibility needs and, if so, the model, type and size of the Unit required, any modifications that must be made to the Unit, and the proposed site or location where the Unit is to be Installed; and (5) whether the Class Member needs financial assistance to pay for a hotel or some other type of temporary housing until such time as an accessible mobile home or trailer can be provided by FEMA. Class members may not be required to accept or wait for housing that meets their accessibility needs, if they prefer nonaccessible housing. C. Information to be provided by FEMA Intake Personnel to Class Members: FEMA’s Intake Personnel shall advise each Class Member who calls the special toll-free number what further actions, if any, FEMA intends to take to address the Class Member’s accessibility needs. The information described in this paragraph shall be given to the Class Member orally within five calendar days of the Class Member’s call. (1) If FEMA determines that the temporary housing unit that is currently occupied by the Class Member can be altered or modified to satisfy the Class Member’s accessibility needs, FEMA’s Intake Personnel shall provide the Class Member with an estimated completion date which shall be: (a) within 30 days after the Class Member contacts FEMA’s Intake Personnel if the requested alterations or modifications are limited to the installation of an external ramp, external steps, or grab bars meeting UFAS standards; (b) up to 60 days after the Class Member contacts FEMA’s Intake Personnel for any other alterations or modifications, depending on the nature of the alteration or modification sought and the volume of requests received by FEMA. (2) If FEMA determines that the Class Member’s need for temporary housing that is accessible can be accommodated by providing rental assistance, FEMA’s Intake Personnel shall provide the Class Member with information regarding the procedures to be followed in obtaining such assistance. (3) If FEMA determines that the Class Member’s need for temporary housing that is accessible can be accommodated by Providing an existing mobile home or trailer at a FEMA group site or commercial site that is available for immediate occupancy, FEMA’s Intake Personnel shall provide information regarding the location of the group site or commercial site and the type of unit(s) available for immediate occupancy at such site. (4) If FEMA determines that a mobile home, Park Model trailer, or other travel trailer should be Provided to address the Class Member’s accessibility needs, FEMA’s Intake Personnel shall advise the Class Member of the model, type and size of the mobile home or trailer to be Provided, and the proposed site or location where the mobile home or trailer is to be Installed. If the proposed site is on privately owned property, FEMA’s Intake Personnel shall advise the Class Member that FEMA can install temporary housing on the site only if FEMA determines that the property is suitable for temporary housing. FEMA’s Intake Personnel shall provide the Class Member with an estimated installation date for any mobile home or trailer to be Installed which may range up to 90 days after the Class Member contacts FEMA’s Intake Personnel depending upon whether a Unit that meets the Class Member’s accessibility needs is Currently in Stock, whether a site suitability determination is necessary before the Unit can be Installed, and the volume of requests received by FEMA. If FEMA subsequently determines that the requested Unit cannot be Provided because the site is not suitable for temporary housing, FEMA’s Intake Personnel shall notify the Class Member of FEMA’s determination, and advise the Class Member of any alternative temporary housing available that satisfies the Class Member’s accessibility needs. (5) If FEMA determines that a Class Member needs financial assistance to pay for a hotel or some other type of temporary housing until such time as an accessible mobile home or trailer can be Provided, FEMA's Intake Personnel shall make arrangements to provide a hotel or some other type of temporary housing assistance for Class Members who are waiting for an Accessible Unit and who have no other place to stay while they are waiting. (6) If FEMA denies a request for direct housing assistance or for modification of a Unit in whole or in part, and if FEMA has not already notified the caller in writing of such denial, FEMA shall, within 15 days thereafter, notify the caller in writing of such denial, the reasons for the denial, and the Complaint Procedures available under paragraph 8 of this Agreement. D. Records to be maintained by FEMA’s Intake Personnel: FEMA’s Intake Personnel shall create a record reflecting: (1) the name, FEMA number, current and pre-disaster address, and current telephone number of each Applicant that contacts FEMA on the special toll-free number, (2) the date and subject matter of each such contact, and whether the contact was initiated by the caller or by FEMA (3) the type of disability, if any, identified by the Applicant, (4) a description of any accessibility needs identified by the Applicant, (5) FEMA’s determination concerning whether the Applicant is a Class Member; (6) a description of what further actions, if any, FEMA intends to take to address each Class Member’s accessibility needs; (7) the estimated completion date(s) for any such actions; and (8) any interim arrangements made for a hotel or other temporary housing that is accessible. The record created by FEMA’s Intake Personnel shall be updated to reflect any change in address or telephone number, the date, location, and type of Unit actually delivered, the date and type of any modifications completed, and the reasons for any significant unforeseen delays in processing the Class Member’s request. 7. Provision of Accessible Units: FEMA shall notify the specially designated contractor selected pursuant to paragraph 11 of this Agreement of the estimated completion date provided to each Class Member under paragraph 6 above, and shall require that the Contractor use its best efforts to provide an Accessible Unit and complete all necessary modifications on or before the completion date specified. A. Information to Plaintiffs’ Counsel: FEMA will provide Plaintiffs’ Counsel with six (6) bimonthly reports, beginning sixty (60) days after the date of the Court’s order approving the Settlement Agreement, and ending one year after approval, which shall contain the following information, separately for Louisiana and Mississippi: (1) cumulative number of callers to the Special 800 number who were determined to be Class Members or calling on behalf of Class Members; (2) cumulative number of households of callers FEMA determined to need interim hotel or rental assistance (assistance provided until an accessible unit becomes available) after their call, and cumulative number who received such assistance after their call; (3) cumulative number of households of callers determined to need an accessible unit, other than the unit they were occupying at the time of the call; (4) of the number above in paragraph 7.A.(3), the cumulative number of Accessible Units Provided to callers within 30, 60, 90, and over 90 days of the first call, respectively; (5) cumulative number of households of callers determined to need modifications to a unit currently occupied; (6) of the above in paragraph 7.A.(5), the cumulative number of households of callers Provided with modifications within 30, 60, 90, and over 90 days of the first call, respectively; (7) cumulative number of households of callers determined to need rental assistance rather than an accessible unit; (8) of the above in paragraph 7.A.(7), cumulative number of households of callers who received rental assistance after their call. B. Notification by FEMA of Inability to Meet Time Frames: If, for reasons beyond the control of FEMA, it appears to FEMA that the timeframes described above in paragraph 6.C. will not be met for a significant number of Applicants, FEMA will notify Plaintiffs' counsel in writing, with an explanation of the reason why such timeframes will not be met. The Parties will then confer within ten (10) days of the receipt of such notice and attempt to reach agreement. 8. Complaint Procedure: Callers to the special toll-free number will be instructed to call the special toll-free number back if they have complaints. If their complaint is that a Unit or modifications provided them are different than what they were supposed to receive, or that they were not Provided within the estimated time frame, the Intake Personnel shall attempt to resolve the complaint. If their complaint is that they disagree with FEMA’s actions or proposed actions under paragraphs 6 or 7 above, including a determination that they are not Class Members, they shall be informed that they may ask for a supervisor to review the determination and/or proposed action, and such a review will be provided. Personnel at the toll-free number shall attempt to resolve the complaint. If they have not resolved the complaint within ten days, personnel at the toll-free number shall refer the complaint to the Ombudsperson and provide the complainant with the address and telephone number of Plaintiff’s counsel. 9. Ombudsperson: FEMA shall appoint an Ombudsperson to serve as a liaison with Persons with Disabilities, and to resolve complaints referred to the Ombudsperon as set forth below. The Ombudsperson shall be responsible for monitoring and, as appropriate, recommending improvements to FEMA’s efforts to address the special needs of people with disabilities. Insofar as necessary to ensure that accessible mobile homes and/or trailers are provided to Class Members on a timely basis, and subject to the oversight of FEMA’s contracting officer, the Ombudsperson shall be authorized to provide direction to FEMA’s contracting officer technical representative for the contract entered into with the special designated contractor selected by FEMA pursuant to paragraph 11 of this Agreement. Referrals to the Ombudsperson: (A) shall be made by FEMA Intake Personnel who, after consultation with supervisory officials, determine that they are unable to resolve a Class Member’s complaint within ten days; or (B) may be made by attorneys or other representatives of advocacy/community groups that are providing assistance to Class Members. A. Information to Plaintiffs’ Counsel: Beginning sixty (60) days after the date of the Court's order approving this Settlement Agreement, and ending one year after approval, FEMA shall provide Plaintiffs' Counsel with six (6) bimonthly reports, separately for Louisiana and Mississippi, which shall contain, for each complaint referred to or received by the Ombudsperson, the information recorded by FEMA's Intake Personnel regarding the complainant, pursuant to 6.D. above, and the subject of the complaint, for example, whether it concerned: (1) FEMA’s determination that an individual caller is not a Class Member; (2) FEMA's provision of (or failure to provide) accessible temporary housing while the caller was waiting for an Accessible Unit; (3) a Unit that was not delivered, altered, or modified on or before the estimated completion date; (4) a Unit that was not Provided in the location desired by the caller; or (5) a disagreement with the type of modification or Unit FEMA determined would be Provided. In addition, FEMA shall identify the number of complaints in each of the above categories that: (a) have been resolved to the satisfaction of the complainant; (b) have been resolved by FEMA in a manner that has not been accepted by the complainant; or (c) remain unresolved at the end of the reporting period. Upon request, FEMA shall provide to Plaintiffs' counsel full details of any complaint received by the Ombudsman, including, in addition to the above information, the date the Ombudsman received the complaint, how the complaint was resolved, the date of such resolution, and how to contact the complainant. 10. UFAS Trailers: FEMA shall require that a minimum of 10% of all Units ordered on or after June 1, 2006 for use as temporary housing for victims of Hurricane Katrina or Hurricane Rita shall comply with the Uniform Federal Accessibility Standards (UFAS) subject to any amendment, modification or waiver of any UFAS standard which may be adopted or approved by the Department of Housing and Urban Development (HUD). At least 5% of all Units ordered on or after June 1, 2006 for use as temporary housing for victims of Hurricane Katrina or Hurricane Rita shall be UFAS-compliant Park Models with the remainder allocated as needed between UFAS-compliant mobile homes and travel trailers. If UFAS-compliant Units are not available or if there is any delay in the projected date for delivery of UFAS-compliant trailers, and with the prior written consent of plaintiffs’ counsel, FEMA may instead satisfy the requirements of this paragraph by ordering accessible mobile homes or Park Model trailers which do not satisfy all UFAS requirements but can be altered or modified to accommodate the accessibility needs of Class Members. 11. Contractor for Class Members: To ensure that Accessible Units are Provided on a timely basis to Class Members who respond to the Accessibility Notice, FEMA shall retain a separate designated contractor for the exclusive purpose of providing all materials, labor, equipment and support services such as required permitting and local inspections for installation of UFAS compliant manufactured homes and travel trailers. FEMA shall require that the contractor selected for this purpose have personnel and resources sufficient to enable the contractor to install UFAS-compliant mobile homes and trailers within the time periods specified in paragraph 6.C. above. FEMA shall award a contract conforming to the requirements of this paragraph no later than 30 days after the Court enters an order finally approving this Agreement. 12. Accessible Units at Group Sites: FEMA has undertaken a survey of all group sites or emergency group sites operated by FEMA in Louisiana and Mississippi but not including certain sites which are to be closed on or before September 30, 2006, or which are designated for the exclusive use of individuals none of whom are disabled (hereinafter the “Group Sites”). Based on the results of the survey, FEMA will make whatever improvements are necessary to ensure that: (A) the common areas of the Group Sites comply with UFAS requirements; (B) at least 5% of the Units located in each Group Site containing 20 or more units (with the exception of the Group Site at Groom Road, known as Renaissance Village) are Accessible Units; and (C) at least 5% of the aggregate total number of Units located on Group Sites are Accessible Units. FEMA shall not be required to involuntarily displace any person residing in a Group Site at the time this Agreement is executed to comply with these requirements. 13. Enforcement of Settlement Agreement: If any Class Member alleges that Defendants have failed to comply with any provision of this Agreement, counsel for the Class Member shall serve a written Notice upon Defendants’ Counsel which shall specify which paragraph(s) of this Agreement have allegedly been violated, shall describe all of the facts and circumstances supporting the Class Member’s claim that Defendants have violated this Agreement, and shall notify Defendants’ Counsel that the Class Member intends to seek an order from the District Court to enforce compliance with the Agreement. The Defendants shall have a period of thirty days after receipt of such Notice to take appropriate action to resolve any claims of noncompliance. If such claims are not resolved within that thirty day period or if, prior to the expiration of such 30-day period, counsel for Defendants advise Plaintiffs’ Counsel that no further action will be taken by Defendants, the Class Member may apply to the District Court for an order compelling compliance with this Agreement. If Defendants allege that Plaintiffs have failed to comply with any provision in this Agreement, the same procedures shall apply. It is understood and agreed by the Parties that the time frames specified in paragraphs 6.C.(1) and 6.C.(4) of this Agreement are estimates and not deadlines. Any alleged failure by Defendants to Install an Accessible Unit within the period prescribed in paragraph 6.C.(4) of this Agreement, or to alter or modify a temporary housing unit within the period prescribed in paragraph 6.C.(1), is not, by itself, a violation of this Agreement, and shall not, standing alone, provide a basis for any relief under this paragraph. Instead, any such claims shall be resolved in accordance with the procedures prescribed in paragraph 14 below. 14. Applications for Further Relief: If any Class Member alleges that FEMA has failed to Install an Accessible Unit within the period prescribed in paragraph 6.C.(4) of this Agreement, has failed to alter or modify a temporary housing unit within the period prescribed in paragraph 6.C.(1), has denied him or her an Accessible Unit or modifications to make a unit accessible, has denied his or her desired location of a trailer, or has failed to provide assistance for temporary accessible housing until an Accessible Unit can be provided, counsel for the Class Member shall serve a written notice upon Defendants' Counsel which shall notify Defendants' Counsel that the Class Member intends to seek further relief from the District Court and shall describe all of the facts and circumstances supporting the Class Member's claim. The Defendants shall have a period of thirty days after receipt of such Notice to take appropriate action to resolve the dispute, except in case of an emergency that poses a serious threat to the health or safety of a Class Member. If the dispute is not resolved within that thirty day period or if, prior to the expiration of such 30day period, counsel for Defendants advise Plaintiffs' Counsel that no further action will be taken by Defendants, or in the case of an emergency that poses a serious threat to his or her health or safety, the Class Member may apply for an order from the District Court compelling FEMA to provide an Accessible Unit to the Class Member, to alter or modify the Class Member's existing temporary housing unit to make it accessible, to Provide an Accessible Unit at a specific location, and/or to provide assistance for temporary accessible housing until an Accessible Unit can be provided. If the Court determines that FEMA has failed to Provide an Accessible Unit to the Class Member, to alter or modify the Class Member's existing temporary housing unit, to provide an Accessible Unit at a specific location, and/or to provide assistance for temporary accessible housing until an Accessible Unit can be provided, and further finds that such failure(s) violate Section 504 of the Rehabilitation Act, 29 U.S.C. § 794(a), the Fair Housing Act, 42 U.S.C. § 3604, or the Stafford Act, 42 U.S.C. § 5170 et seq., the Court may enter an appropriate order granting further relief to the Class Member. 15. Attorney’s Fees: Defendants agree to pay plaintiffs' counsel $310,000 for attorneys’ fees and expenses. Except as provided in the last sentence of this paragraph, payment of this amount shall represent full and final payment of any and all claims for attorneys' fees and costs related to this action. Plaintiffs explicitly waive any right to seek, and shall not be entitled to recover any additional attorneys’ fees or expenses for any time expended or to be expended by counsel monitoring compliance with this Agreement. Notwithstanding the foregoing, it is understood and agreed by the Parties that, in the event of a judicial determination that Defendants have failed to discharge any obligation under this Agreement, plaintiffs reserve the right to apply to the Court for an additional award of attorneys’ fees and expenses directly relating to plaintiffs’ application for such a judicial determination. 16. NonAdmission of Liability: This Agreement does not constitute an admission of the merits of any position taken by any party to this litigation, nor of any liability by Defendants for the violation of any law, statute, regulation, or policy. Defendants expressly deny any wrongdoing or liability. In addition, this Agreement may not be introduced or used or admitted in any other judicial, arbitral, administrative, investigative or other proceeding of any kind or nature whatsoever as evidence of discrimination, retaliation, or any violation of the Rehabilitation Act, the United States Constitution, the common law of any jurisdiction, or any other federal, state or local law, statute, ordinance, regulation, rule or executive order, or any obligation or duty at law or in equity. 17. Agreement Contingent on Court Approval: The commitments made by the Parties in this Agreement are contingent upon final approval of the Agreement by the District Court in accordance with the requirements of Rule 23(e)(1)(C) of the Federal Rules of Civil Procedure. In the event that final approval of the Settlement Agreement is not obtained or the Settlement Agreement is deemed null and void, nothing herein shall be deemed to waive any of the Class’s claims or the Defendants’ objections and defenses, and this Settlement Agreement shall not be admissible in any court regarding the propriety of class certification or regarding any other issue or subject of this case. 18. Settlement Hearing: Promptly after execution of this Agreement, but in no event later than ten days after this Agreement is signed by counsel for all Parties, the Parties will submit this Agreement (together with its Exhibits) to the Court and will apply for entry of an order (hereinafter the “Initial Order”) in which the Court: (A) Preliminarily approves the terms of the settlement embodied in this Agreement as being fair, reasonable and adequate to the Class; (B) Provisionally certifies the class for settlement purposes only; (C) Approves the form of a Notice to Class Members (“Class Notice”) informing them of the claims asserted in this action, a summary of the general terms and conditions of this Agreement, and of the date of the hearing set by the Court to determine whether the settlement is fair, reasonable and adequate; (D) Directs FEMA to disseminate the Class Notice to the Class Members by publication or such other means as the Court finds to be reasonable and in conformance with the requirements of Rule 23 of the Federal Rules of Civil Procedure, the Constitution of the United States, and any other applicable law; (E) Schedules a Settlement Hearing to be held by the Court to determine if the proposed settlement of the litigation as contained in this Agreement should be approved as fair, reasonable and adequate and whether the Judgment approving the settlement should be entered; (F) Provides that any objections to (i) the proposed settlement contained in this Agreement; or (ii) entry of the Judgment approving the settlement shall be heard only if, on or before a date specified in the Class Notice, persons making objections file and serve on all Parties notice of their intention to appear (which will set forth each objection and the basis therefore) and copies of any papers in support of their position as set forth in the Order Notice; and (G) Provides that the Settlement Hearing may, from time to time and without further notice to the Class, be continued or adjourned by order of the District Court. The Parties will request that, after notice is given, the Court hold the Settlement Hearing and finally approve the settlement of the litigation as set forth in this Agreement. 19. Release/Bar of Claims: In consideration of the commitments contained herein, and the benefits provided or to be provided hereunder, this Settlement Agreement shall fully resolve, extinguish, and finally and forever bar, and the Representative Plaintiffs and other Class Members hereby release all claims described in paragraph 3 above, except as expressly provided in paragraphs 13 and 14 above. Upon final approval by the District Court, this Settlement Agreement shall be fully binding on, and fully extinguish and release the claims of, all Class Members and the Representative Plaintiffs, and may be pled as a full and complete defense to any subsequent action or other proceeding involving any person or party that arises out of the claims released and discharged by this Settlement Agreement. 20. Dismissal of Claims/ Retention of Jurisdiction: Upon final approval by the District Court of this Agreement pursuant to Rule 23(e) of the Federal Rules of Civil Procedure, the Parties hereby stipulate and agree to entry of a Final Judgment in the form annexed hereto as Attachment D dismissing all of plaintiffs’ claims in this action with prejudice, except that the Court shall retain jurisdiction to enforce compliance with the terms and conditions of this Agreement in accordance with paragraph 13, and to hear and determine any applications for additional relief filed by any Class Member pursuant to paragraph 14 of this Agreement. 21. Reports to the Court: The Parties shall file a joint status report with the District Court six (6) months after final approval of this Agreement advising the Court of their progress in implementing the terms of the Agreement. The Parties shall file a final report when all of the Agreement’s terms have been met and, upon the filing of such report, the Court’s jurisdiction to enforce this Agreement shall terminate. 22. Rule of Construction: The Parties through their counsel have negotiated the terms of this Agreement. Any rule of construction providing that ambiguities are to be resolved against the drafting party shall not be employed in the interpretation of this Agreement. This Agreement shall be construed as if drafted by both Parties. 23. Waiver of Provisions: No provisions hereof can be waived unless done so expressly and in writing. Express waiver of any one provision shall not be deemed a waiver of any other provision. 24. Entire Agreement: This Agreement contains the entire agreement between the Parties, and all previous understandings, agreements, and communications prior to the date hereof, whether express or implied, oral or written, relating to the subject matter of this Agreement, are fully and completely extinguished and superseded by this Agreement. This Agreement shall not be altered, amended, modified, or otherwise changed except by a writing duly signed by the Parties hereto. 25. Collateral Use of Agreement Prohibited: The Parties have entered into this Agreement as a compromise measure to terminate this action and resolve all issues of controversy between them. The terms of this Agreement, its substance, the negotiations leading up to the Agreement, and the information exchanged by the Parties in the course of those negotiations may not be offered, taken, construed or introduced as evidence for any purpose, either in this action or in any pending or subsequent proceeding of any nature, except that in any subsequent action involving the enforcement, construction, or application of this Agreement, a copy of the Agreement may be presented to verify its contents. 26. Headings: The headings in this Agreement are for the convenience of the Parties only and shall not limit, expand, modify, or aid in the interpretation or construction of this Agreement. 27. Notices under this Agreement: Copies of all notices required to be given to Plaintiffs' Counsel under this Agreement shall be sent by e-mail, to the following persons: Nell Hahn Advocacy Center Director of Litigation and Systems Advocacy E-mail: nhahn@advocacyla.org Melissa Losch Advocacy Center Managing Staff Attorney E-mail: mlosch@advocacyla.org Cary LaCheen National Center for Law and Economic Justice New York E-mail: lacheen@nclej.org Copies of all notices required to be given to Defendants' Counsel under this Agreement shall be sent by e-mail, to the following persons: Diane Kelleher Civil Division Department of Justice Diane.Kelleher@usdoj.gov Darren Wall Office of Chief Counsel Federal Emergency Management Agency Darren.Wall@dhs.gov 28. No Third-Party Rights: This Settlement Agreement is not intended to, and does not, create any third-party beneficiary rights or any other rights of any kind in any person, group, or entity other than the Parties. 29. Governing Law: The Parties agree that the validity, construction, and enforcement of this Settlement Agreement shall be governed by federal law. 30. Parties' Obligation to Defend Settlement Agreement: In the event this Settlement Agreement is challenged administratively or judicially, the Representative Plaintiffs, Class Counsel and the Defendants shall fully defend its lawfulness. 31. Privacy Act Information: Certain information to be provided to plaintiffs under paragraphs 6.D and 9 of this Agreement may be subject to the Privacy Act of 1974, 5 U.S.C. § 552a. In accordance with the requirements of the Privacy Act, the Parties will request that the Court enter a Privacy Act Protective Order in the form prescribed in Attachment E hereto. Each person designated by plaintiffs' counsel to receive information subject to the Privacy Act shall be required to execute an Acknowledgment as required by the Privacy Act Protective Order. 32. Binding Agreement: Undersigned counsel represent that they have the requisite authority to enter into this Settlement Agreement. Subject to final approval by the District Court and any applicable law, this Settlement Agreement shall be binding on the Parties and their successors, assigns, representatives, and trustees. 33. Execution: This Agreement may be executed in counterparts, each of which shall be deemed an original, and all of which together shall be deemed one and the same instrument. AGREED this ___ day of August, 2006. _____________________________ NELL HAHN Director of Litigation and Systems Advocacy Advocacy Center 600 Jefferson Street Suite 812 Lafayette LA 70501 Telephone: (337) 2377380 Facsimile: (337) 2370486 Email: nhahn@advocacyla.org Attorneys for Plaintiffs _____________________________ CARY LACHEEN National Center for Law and Economic Justice 275 Seventh Avenue, Suite 1506 New York, NY 100016708 Telephone: (212) 6336967 Facsimile: (212) 6336371 E-mail: lacheen@nclej.org Attorneys for Plaintiffs PETER KEISLER Assistant Attorney General JIM LETTEN United States Attorney GLENN K. SCHREIBER Assistant United States Attorney JOSEPH LOBUE Assistant Director Federal Programs Branch ____________________________ DIANE KELLEHER Trial Attorney Department of Justice Civil Division, Room 7318 Post Office Box 883 Washington, D.C. 20044 Telephone: (202) 5144775 Facsimile: (202) 6168470 Email: Diane.Kelleher@usdoj.gov Attorneys for Defendants ____________________________ DARREN WALL Trial Attorney Office of Chief Counsel Federal Emergency Management Agency 500 C St., SW Room 840 Washington D.C. Telephone: (202) 646-4611 Facsimile: (202) 646-4536 E-mail: Darren.Wall@dhs.gov Attorneys for Defendants List of Attachments Attachment A – Accessibility Notice Attachment B – Media Lists Attachment C – FEMA Screening Questions Attachment D – Proposed Final Judgment Attachment E – Privacy Act Protective Order ATTACHMENT A Attachment A – Accessibility Notice This notice is for people who have a disability or live with someone who has a disability. Usually a person with a disability is being treated by a doctor. To have a disability, you must have trouble: · walking · seeing · hearing · speaking · breathing · learning · working, or · doing another major activity. A disability does not include short-term problems like a broken leg. It also does not include a problem that is corrected, like someone who can see well with glasses. If you or someone you live with has a disability, you may be able to get an accessible trailer from FEMA. Depending on the type of disability, you may be able to get a trailer with– · A ramp · Enough turning space for a wheelchair · An accessible shower or tub · Grab bars in showers, tubs, and near toilets If you or someone you live with has a disability and needs an accessible trailer, call FEMA at 1-800-XXX-XXXX, from 8:00 a.m. to 6:00 p.m., Monday to Saturday. Tell FEMA what kind of disability you have and what you need to make a trailer accessible. After you call, FEMA will tell you if it will · Give you an accessible trailer · Make changes in the trailer you have · Help you find another place to live FEMA will also tell you how long it will take. It may take FEMA up to 90 days to deliver a trailer, or longer if you don’t have a suitable place to put it. If you already have a trailer, it may take up to 60 days to make the changes you need. If you do not get an accessible trailer within these times, or you do not agree with FEMA’s decision, please call 1-800-XXX-XXXX and FEMA will tell you how to obtain further assistance. To obtain an accessible trailer within the times in this notice, you must contact FEMA at 1-800-XXX-XXXX before [date]. ATTACHMENT B Attachment B – Louisiana Media Instructions: For the Louisiana media list (down to “Multiple Station Radio”), the first line is the name of the media outlet, the second a contact person, the third the town where the office is located. The fax or email number is the fourth line—this is the way that the press release or PSA should be distributed. The fifth line is a telephone number to call for more information, if necessary. LOUISIANA NEWSPAPERS Advocate Fred Kalmbach Managing Editor Baton Rouge, LA Fax (225) 388-0371; fkallmbach@theadvocate.com (225) 383-1111 American Press Brett Downer Editor-in-Chief Lake Charles, LA news@americanpress.com (337) 494-4080 Courier Keith Magill Editor Houma, LA Fax (985) 857-2244; marlene.callahan@houmatoday.com; ATTN Marlene 985) 857-2222 Daily Advertiser Chere Coen Editor Lafayette, LA Fax (337) 289-6443 ATTN Lisa Thibodeaux (337) 289-6300 Daily Iberian Steve Bandy Editor-in-Chief New Iberia, LA Fax (337) 367-9640; dailyiberian@bellsouth.net; ATTN Steven Landry (337) 365-6773 Daily Star Hammond, LA Fax (985) 543-0006 (985) 254-7827 Daily World Lisa Faust Editor Opelousas, LA Fax (337) 948-6572; Write “press release” as the subject (337) 942-4971 Natchitoches Times Carolyn Roy Editor Natchitoches, LA Fax (318) 352-7842; news@natchitochestimes.com 318) 352-3618 News-Star Ken Stickney Managing Editor Monroe, LA Fax (318) 362-0273 (318) 362-0289 Ruston Daily Leader Chuck Cannon Editor Ruston, LA leader@tcainternet.com 318) 255-4353 Slidell Sentry-News Sandy Cunningham Editor Slidell, LA Fax (985) 893-1527 ATTN Sandy Cunningham (985) 643-4918 Southwest Daily News Carla Vastos Editor Sulphur, LA Fax (337) 528-3044 (337) 527-7075 TheTownTalk Richard Sharkey Editor Alexandria, LA Fax (318) 487-6488 (318) 487-6397 Times Alan English Editor Shreveport, LA diyles@gannett.com (318) 459-3200 Times-Picayune Renee Peck Editor New Orleans, LA sfinch@timespicayune.com (504) 826-3300 Associated Press - Baton Rouge, LA Bureau Melinda Deslatte Reporter Baton Rouge, LA Wrong number 504) 343-1325 Associated Press - New Orleans, LA Bureau Charlotte Porter Bureau Chief New Orleans, LA Fax (504) 586-0531 (504) 523-3931 Gannett News Service - Baton Rouge Bureau John Hill Bureau Chief Baton Rouge, LA Fax (225) 346-8729 225) 342-7333 LOUISIANA TELEVISION KALB-TV Sharyn Bowen Program Director Alexandria, LA Fax: (318) 449-4594 (318) 4452456 KAQY-TV Doug Ginn Program Director Monroe, LA Fax: (318) 631-4195 (318) 6315677 KATC-TV John Korbel News Director Lafayette, LA Fax: (337) 232-5282 (337) 2353333 KLAX-TV Bob Kennon News Director Alexandria, LA Fax: (318) 473-9984 (318) 4730031 KLFY-TV Mike Barras General Manager Branch, LA Fax: (337) 981-6533 Attn: News (337) 9814823 KLPB-TV Lisa Stansbury Development Director Baton Rouge, LA Fax: (225) 767-4277 (225) 7675660 KLTL-TV Lisa Stansbury Development Director Baton Rouge, LA Fax: (225) 767-4277 (225) 7675660 KNOE-TV Ken Booth News Director Monroe, LA Fax: (318) 325-3405 (318) 3888888 KPLC-TV James Smith News Director Lake Charles, LA Fax: (337) 439-9905 (337) 4399071 KSLA-TV Gaylon Reasons News Director Shreveport, LA Fax: (318) 677-6705 (318) 2221212 KTAL-TV Jean Byrd Public Service Director Shreveport, LA Fax: (318) 629-7171 (318) 6296000 KTBS-TV Randy Bain Editor Shreveport, LA Email: pressreleases@ktbs.com (318) 8615800 WAFB-TV Robert Chandler News Assignment Editor Baton Rouge, LA Email: mcraig@wafb.com (225) 3839999 WBRZ-TV John Pastorek News Director Baton Rouge, LA Email: news@wbrz.com (225) 3872222 WDSU-TV Joseph Schiltz Promotion Director New Orleans, LA Fax: (504) 679-0733 (504) 6790600 WGNO-TV Catherine Koppel Editor New Orleans, LA Fax: (504) 619-6332 Attn: News Desk (504) 5253838 WLAE-TV John Pela Station Manager New Orleans, LA Fax: (504) 840-9838 (504) 8667411 WVLA-TV Joyce Harvey Program Director Baton Rouge, LA Fax: (225) 768-9200 (225) 7663233 WWL-TV Jimmie Phillips Station Manager New Orleans, LA Fax: (504) 529-6472 Attn: News Director Email: pressrelease@wwltv.com (504) 5294444 WYES-TV Beth Arroyo Utterbac Program Director New Orleans, LA Email: ahedgepeth@wyes.org (504) 4865511 LOUISIANA RADIO KCIL-FM Tanya West News Director Houma, LA Fax (985) 872-4403; ATTN Glen (985) 8511020 KDBH-FM George Sluppick News Director Natchitoches, LA Fax (318) 256-0950 (318) 2560555 KEDG-FM Tony Brown News Director Alexandria, LA (318) 4200106 KEZM-AM Bruce Merchant General Manager Sulphur, LA kezm1310am@structurex.net (337) 5273611 KJCB-AM Carol Thomas Program Director Lafayette, LA Fax (337) 235-9681; ATTN Carol Thomas (337) 2334262 KJIN-AM Tanya West News Director Houma, LA Fax (985) 872-4403; ATTN Glen (985) 8511020 KJLO-FM John Reynolds news director Monroe, LA Fax (318) 388-0569 (318) 388-2323 KKGB-FM Craig Morrison News Director Lake Charles, LA Fax (337) 436-7278; ATTN Larry Leblanc (337) 4393300 KLSA-FM, KDAQ-FM Adam Giblin Program Director Shreveport, LA; Alexandria, LA, Lufkin, TX Fax (318) 797-5265 (318) 7975150 KNOC-AM John Brewer Operations Director Natchitoches, LA Fax (318) 352-9598 (318) 3544000 KNOE-AM KNOE-FM News Director Monroe, LA Fax (318) 325-9466 (318) 3888888 KPEL-AM Lafayette, LA Fax (337) 234-7360 (337) 2336000 KPEL-FM David Steel Public Affairs Director Lafayette, LA Fax (337) 233-2989 (337) 2322242 KQID-FM Rick Stevens News Director Alexandria, LA Fax (318) 473-1960 (318) 4451234 KQXL-FM Mya Vernon Promotion Director Baton Rouge, LA Fax (225) 928-1606 (225) 9261106 KRJO-AM C.H. Murray Station Manager Monroe, LA Fax (318) 388-0569 (318) 388-2323 KRRQ-FM Tony Burks Program Director Lafayette, LA Fax (337) 233-3779 (337) 2321311 KRRV-FM Kathy Carsons News Director Alexandria, LA Fax (318) 442-2747 (318) 4437454 KRVS-FM Lafayette/Lake Charles, LA Dave Spizale, General Manager Fax : (337) 482-6101 or EMAIL dspizale@krvs.org 1-800-892-6827 KRVV-FM News Director Monroe, LA Fax (318) 388-0569 (318) 3221914 KSMB-FM Bill Producer Lafayette, LA Fax (337) 233-3779 (337) 2321311 KTDY-FM Mike Grimsley General Manager Lafayette, LA Fax (337) 234-7360 (337) 2322242 KYKZ-FM Larry Beck News Director Lake Charles, LA Fax(337) 436-7278 (337) 4393300 KZMZ-FM Kathy Carsons News Director Alexandria, LA Fax (318) 442-2747 ATTN Cindy (318) 4437454 KZWA-FM Charles Washam News Director Lake Charles, LA Fax (337) 433-8097 (337) 4919955 WBOK-AM Annette Pete Program Director New Orleans, LA contact info not available WDGL-FM Ted Kelly Program Director Baton Rouge, LA Fax (225) 499-9800 (225) 3889898 WGSO-AM Charles Travis News Director Metairie, LA Fax (504) 830-7200 (504) 8323555 WIBR-AM Randy Chase Program Director Baton Rouge, LA Fax (225) 928-1606 Attn: Leah (225) 9261106 WJBO-AM Shauna Sanford News Director Baton Rouge, LA Fax (225) 231-1873 Attn: PSA’s (225) 2311860 WLMG-FM Steve Suter On-Air Anchor New Orleans, LA Fax (504) 593-2099 (504) 5936376 WRBH-FM New Orleans, LA Fax (504) 899-1165 Attn: Jakie (504) 8991144 WRKF-FM Karen Anderson News Director Baton Rouge, LA Fax (225) 926-3105 (225) 9263050 WSLA-AM Paul Mayoral Promotion Director Slidell, LA Fax (985) 649-9822 (985) 6431560 WSMB-AM Craig Jacobes General Manager New Orleans, LA Fax (504) 593-2099 (504) 5936376 WTIX-FM Bob DelGiorno Sports Director Metairie, LA Fax (504) 454-9002 (504) 4549000 WWL-AM Craig Jacobes General Manager New Orleans, LA Email: WWLNewsroom@yahoo.com (504) 5932100 WWNO-FM David Srebnik Program Director New Orleans, LA Email: kanklam@uno.edu Attn: Karen Anklam (504) 2807000 WWOZ-FM David Freedman General Manager New Orleans, LA Email: events@wwoz.org (504) 5681238 WYLD-FM Monica Pierre News Director New Orleans, LA Fax: (504) 679-7343 (504) 6797300 WYNK-AM Dick Lewis General Manager Baton Rouge, LA Fax: (225) 231-1873 (225) 2311860 WYNK-FM Shauna Sanford News Director Baton Rouge, LA Fax: (225) 231-1873 (225) 2311860 MULTIPLE STATION RADIO Instructions: Capstar, Citicasters, and Clear Channel are all one group= Total 22 stations in Louisiana. To distribute to these stations in Louisiana, Fax: (225) 231-1879 Attn: Lori Hardeson, and state “Please send to all stations in Louisiana” Capstar (10) Licensee: CAPSTAR TX LIMITED PARTNERSHIP Address: 2625 S MEMORIAL DR, SUITE A Address 2: City: TULSA State: OK Zip Code: 74129 - 2623 Phone Number: (918) 664-4581 Citicasters (4) Licensee: CITICASTERS LICENSES, L.P. Address: 2625 S MEMORIAL DR, SUITE A Address 2: City: TULSA State: OK Zip Code: 74129 - 2623 Phone Number: (918) 664-4581 Clear Channel ( 8) Licensee: CLEAR CHANNEL BROADCASTING LICENSES, INC. Address: 2625 S MEMORIAL DR, SUITE A Address 2: City: TULSA State: OK Zip Code: 74129 - 2623 Phone Number: (918) 664-4581 For remaining multiple station broadcasters, please send to fax numbers or email addresses highlighted below, with instructions to distribute in appropriate markets: Citadel (14) Citadel Licensee: CITADEL BROADCASTING COMPANY Address: 7201 W LAKE MEAD BLVD STE 400 Address 2: City: LAS VEGAS State: NV Zip Code: 89128 - 8366 Phone Number: (702) 804-5200 Baton Rouge (225) 926-1106 Fax: (225) 928-1606 Attn: Press Release Cumulus (11) Licensee: CUMULUS LICENSING LLC Address: 3535 PIEDMONT ROAD Address 2: BUILDING 14, 14TH FLOOR City: ATLANTA State: GA Zip Code: 30305 - Phone Number: (404) 949-0700 Lake Charles Market Phone: (337) 439-3300 Fax: (337) 436-7287 NOTE: PSA –Send to all stations Shreveport Market Phone : (318) 549-8500 Fax: (318) 549-8505 –Send to all stations La. Educational Television Authority (10) Licensee: LOUISIANA EDUCATIONAL TELEVISION AUTHORITY Address: 7733 PERKINS RD Address 2: City: BATON ROUGE State: LA Zip Code: 70810 - Phone: (225) 767-5660 Fax: (225) 763-8710 Send to all stations Guarantee Broadcasting (8) Licensee: GUARANTY BROADCASTING COMPANY OF BATON ROUGE, LLC Address: 929 GOVERNMENT ST STE B Address 2: City: BATON ROUGE State: LA Zip Code: 70802 - 6034 Phone Number: (225) 383-0355 Fax: (225)499-9800 Attention Scotty Drake Please send to all stations Regent Broadcasting (7) REGENT BROADCASTING OF LAFAYETTE, INC. Address: 2000 FIFTH THIRD CENTER Address 2: 511 WALNUT STREET City: CINCINNATI State: OH Zip Code: 45202 - Phone Number: (859) 292-0030 La. Market Phone: (337) 233-6000 (Paul Sonnier) Fax: (337) 234-7360 Attn: Carrie Note: Please send to all stations Holladay (7) Licensee: HOLLADAY BROADCASTING OF LOUISIANA, LLC Address: 1109 HUDSON LANE Address 2: City: MONROE State: LA Zip Code: 71211 - Phone Number: (318) 322-1914 Fax: (318) 388-0569 Note: Send to all stations Apex (6) Licensee: APEX BROADCASTING, INC. Address: 2294 CLEMENTS FERRY ROAD Address 2: City: CHARLESTON State: SC Zip Code: 29492 - Phone Number: (843) 972-1100 La. Phone: (337) 433-1641 Fax: (337) 433-2999 Attn: PSA Please send to all radio stations Entercom (6) Licensee: ENTERCOM NEW ORLEANS LICENSE, LLC Address: 401 CITY AVENUE Address 2: SUITE 809 City: BALA CYNWYD State: PA Zip Code: 19004 - Entercom New Orleans 504-593-NEWS(6397) Fax: 593-2099 Email: WWLNewsroom@yahoo.com Access one (5) ACCESS.1 LOUISIANA HOLDING COMPANY LLC Address: 1155 CONNECTICUT AVENUE NW Address 2: SIXTH FLOOR City: WASHINGTON State: DC Zip Code: 20036 - Phone Number: (202) 861-0870 La. (318) 445-0800 Fax: (318) 445-1445 Opus (5) Licensee: OPUS BROADCASTING ALEXANDRIA LLC Address: 950 THIRD AVENUE Address 2: 19TH FLOOR City: NEW YORK State: NY Zip Code: 10022 - Phone Number: (212) 634-3376 La. Phone: (318) 487- 1035 Fax: (318) 487-1045 Attn: Steve Coco Communications Capital (5) Licensee: COMMUNICATIONS CAPITAL COMPANY II OF LOUISIANA, LLC Address: 1111 MICHIGAN AVENUE Address 2: SUITE 301 City: EAST LANSING State: MI Zip Code: 48823 - 1096 Phone Number: (517) 351-3222 KRUS phone: (318) 255-2530 Fax: (318) 255-5084 Attn: James Cooper Pittman (5) Licensee: PITTMAN BROADCASTING SERVICES, LLC Address: 307 S. JEFFERSON AVENUE Address 2: City: COVINGTON State: LA Zip Code: 70433 - 3135 Phone Number: (337) 312-9792 Mandeville : 985-624-9452 Fax: 985) 624-9559 note: Please send to all stations Noe (4) Licensee: NOE CORP., LLC Address: 1400 OLIVER ROAD Address 2: City: MONROE State: LA Zip Code: 71201 - Phone: (318) 388-8888 Fax: (318) 325-9466 Attn: PSA Radio for the Blind and Handicapped (1) Licensee: RADIO FOR THE BLIND & HANDICAPPED, INC. Address: 3606 MAGAZINE STREET Address 2: City: NEW ORLEANS State: LA Zip Code: 70115 - Phone: 899-1144 Fax: 899-1165 Attn: Jackie Attachment B – Non-Louisiana Media Major Radio Markets National Entercom ENTERCOM MEMPHIS 5904 Ridgeway Center Parkway Memphis, TN 38120 Phone: (901)767-0104 Cumulus Market : Beaumont (6) Address: 755 S. 11th Street Suite # 102 P. O. Box 870 Beaumont TX,77704 Tel.: 409-833-9421 Fax: 409-833-9296 Market : Houston (2) Address: 2700 Post Oak Blvd Suite 2300 Houston Texas,77056 Tel.: 713-300-3500 Fax: 713-300-3585 Market : Lake Charles (6) (also listed in Louisiana Media list) Address: 425 Broad Street Lake Charles LA,70601 Tel.: 337-439-3300 Fax: 337-433-7701 Market : Shreveport (5) (also listed in Louisiana Media list) Address: 270 Plaza Loop Louisiana Boardwalk Bossier City LA,71111 Tel.: (318) 549-8500 Fax: (318) 549-8505 Market : Nashville Address: 10 Music Circle East Nashville TN,37203 Tel.: 615-321-1067 Fax: 615-321-5808 Market : Mobile (6) Address: 2800 Dauphin Street Suite 104 Mobile AL,36606 Tel.: 251-652-2000 Fax: 251-652-2001 Market : Huntsville (4) Address: 1717 Highway 72 East Athens AL,35611 Tel.: (256) 830-8300 Fax: (256) 232-6842 Market : Columbus/Starkville Ms. (7) Address: 601 2nd Avenue North Court Square Towers Columbus MS,39701 Tel.: 662-327-1183 Fax: 662-328-1122 Clear Channel Alabama (25) Louisiana (11) (Note: send to Laurie Hardeson as per Louisiana media list) Mississippi (4) Texas (34) Tennessee (22) Clear Channel Communications 200 E. Basse San Antonio, TX 78209 Phone: 210-822-2828 Fax: 210-822-2299 Citadel Alabama (11) Louisiana (16) (Note: these are also covered in the Louisiana media list) Tennesee (10) 7201 W. Lake Mead Blvd. Suite 400 Las Vegas, NV 89128 Phone: (702) 804-5200 Fax us: (702) 804-5936 Mississippi Urban Radio (3) 608 Yellowjacket Drive Starkville, MS 39759 Phone:662.338.5424 Fax: 662.338.5436 American Family Association (189) Licensee: AMERICAN FAMILY ASSOCIATION (189) Address: PO BOX 2440 Address 2: City: TUPELO State: MS Zip Code: 38803 - 2440 Phone Number: (662) 844-8888 Mississippi Authority for Educational Television (14) 3825 Ridgewood Road Jackson MS 39211 601-432-6565 Fax: (601) 432-6927 attn: PSA Cumulus (8) Market : Columbus/Starkville Ms. (7) Address: 601 2nd Avenue North Court Square Towers Columbus MS,39701 Tel.: 662-327-1183 Fax: 662-328-1122 Monterey (6) Licensee: MONTEREY LICENSES, LLC Address: 2511 GARDEN ROAD, BUILDING A Address 2: SUITE 104 City: MONTEREY State: CA Zip Code: 93940 - Phone Number: (831) 655-6350 Gulfport (228) 388-2001 Texas Capstar 600 CONGRESS AVENUE AUSTIN, TX 78701 Phone: (512) 340-7800 Fax: (512) 380-8501 Mississippi Newspapers 1. The Sun Herald The Sun Herald P.O. Box 4567 Biloxi, MS 39535 228-896-2420 www.thesunherald.com Newsroom: 228-896-2390 Email: mynews@sunherald.com 2. Hattiesburg American PO BOX 1374 Hattiesburg, MS 39401 601-450-4445 601-582-4321 www.hattiesbergnews.info Submit press release on line: www.hattiesburgamerican.com/apps/pbcs.dll/section?Category=CUSTOMERSERVICE03 3. The Clarion-Ledger The Clarion-Ledger 201 S. Congress St. Jackson, MS 39201 601-961-7000 In-state Watts number: 800-222-8015 www.clarionledger.com/ Metro News Editor: Grace Simmons, 601-961-7250 News/Copy Desk Editor: Jenny Humphryes 601-961-7238 4. Mississippi Press Mississippi Press 1225 Jackson Ave Pascagoula, MS 39567 228-762-3805, 228-762-1111 Fax: 228-934-1454 or 228-934-1474 www.gulflive.com/mississippipress msnews@themississippipress.com Coastlines Editor: Susan Ruddiman, 228-934-1419 msfeatures@themississippipress.com Managing Editor: Paul South, 228-934-1423 psouth@themississippipress.com mseditor@themississippipress.com 5. Meridian Star P.O. Box 1591 Meridian, MS 39302 601-693-1551 Toll Free: 800-232-2525 www.meridianstar.com General Manager: John Bohl - Ext. 3211 News Fax: 601-485-1275 News Desk: Kassie Rowell - Ext. 3274 6. Desoto Appeal 230 Goodman Rd E Southaven, MS 38671 901-333-2020 www.commercialappeal.com/mca/desoto 7. Madison County Herald 670 Highway 51 Ridgeland, MS 39157 601-853-2899 www.mcherald.com Managing Editor: J. Ben Kelly, 601-853-8783 jbkelly@mcherald.com 8. Neshoba Democrat P.O. Box 30 Philadelphia, MS 39350 601-656-4000 www.neshobademocrat.com Managing Editor: Debbie Meyers 9. Starkville Daily News P.O. Box 1068 Starkville, MS 39759 662-323-1642 www.starkvilledailynews.com Editor: sdneditor@starkvilledailynews.com Managing Editor: Brian Hawkins 10. Northeast Mississippi Journal P.O. Box 909 Tupelo, MS 38802 662-842-2611 www.mediatico.com www.djournal.com Television stations 1. WLOX P.O. Box 4596 Biloxi, MS 39535 www.wlox.com wlox@wlox.com Newsroom: news@wlox.com; (fax) 228-896-2596 Public Service Announcements: e-mail Todd Durbin in the WLOX-TV Marketing Department at branding@wlox.com Post on community calendar: www.wlox.com/Global/link.asp?L=81603&nav=6uyeEngN 2. WAPT www.wapt.com 3. WTOK-TV 815 23rd Ave Meridian, MS 39301 601-693-1441 fax: 601-483-3266 www.wtok.com wtok@wtok.com News and community calendar: news@wtok.com 4. WJTV 1820 TV Road Jackson, MS 39204-4148 601-372-6311 fax: 601-372-8798 News story suggestion: rrussell@wjtv.com,news@wjtv.com Community calendar: eventcalendar.mgnetwork.com/index.cfm?fuseaction=home.open&siteid=jtv 5. WXXV-TV www.fox25.com 6. WDAM-TV P.O. Box 16269, Hattiesburg, MS 39404. www.wdam.com News tips and story ideas: news7@wdam.com 7. WLBT-TV 715 South Jefferson Street Jackson, Mississippi 39201 601-948-3333 (main switchboard) www.wlbt.com Newsroom: 601-960-4426, (fax) 601-355-7830; news@wlbt.com 8. WMPN-TV 3825 Ridgewood Road Jackson MS 39211 601-432-6565 ; 1-800-922-9698 www.etv.state.ms.us phyllis.allen@mpbonline.org Radio Stations 1. WMJY (FM) 286 Debuys Rd. Biloxi, MS 39531 228-388-2323 fax: 228-388-2362 www.magic937.com reggiebates@clearchannel.com 2. WBSL 1190 Casino Magic Drive Bay Saint Louis, MS 39520 228-467-1190 fax: 228-467-5295 3. WTNI (AM) 1909 E. Pass Rd. Suite D-11 Gulfport, MS 39507 228-388-2001 fax: 228-996-9114 www.1640wtni.com 4. WFOR(FM) One Commerce Drive, #106 Hattiesburg, MS 39402 601-544-1400 fax: 601-582-5481 5. WUSW (FM) One Commerce Drive, Hattiesburg, MS 601-544-1037 fax: 601-582-5481 6. WORV(AM) 1204 Graveline Street Hattiesburg, MS 601-544-1941 fax: 601-544-1947 7. WJWG (FM) 1204 Graveline Street Hattiesburg, MS 601-544-1941 fax: 601-544-1947 8. WHLH (FM) 1375 Beasley Rd. Jackson, MS 39206 601-982-1062 fax: 601-362-1905 www.hallelujah955.com 9. WJDX (AM) Box 31999 Jackson, MS 39286 601-982-1062 fax: 601-362-1905 www.wjdx.com 10. WMSI (FM) 1375 Beasley Road Jackson, MS 39206 601-982-1062 fax: 601-362-1905 www.miss103.com Contact: Kenny Windham 11. WKXI (AM) Box 9446 Jackson, MS 39286 6001-957-1300 fax: 601-956-0516 12. WOAD(AM) 731 S. Pear Orchard Street, Suite 27 Jackson, MS 39157 601-957-1300 fax: 601-956-0516 www.woad.com 13. WJMI (FM) 731 S. Pear Orchard Street Jackson, MS 39157 601-957-1300 fax: 601-956-0516 14. WWJK (FM) 222 Beasley Rd. Jackson, MS 39206 www.arrow94.com mail94@arrow94.com 15. WZRX (AM) Box 9734 Jackson, MS 601-981-9080 fax: 601-981-9093 16. WUSJ 265 High Point Drive Jackson, MS 601-956-0102 fax: 601-978-3890 www.us963.com 17. WALT(AM) Box 5797 Meridian, MS 39302 601-693-2661 fax: 601-483-0826 18. WJDQ (FM) 4307 Hwy. 39 N. Meridian, MS 39301 601-693-2381 fax: 601-485-2972 19. WMER (AM) 1106 18th Ave Meridian, MS 39301 601-693-9637 fax: 601-693-9637 20. WMMZ (FM) 3436 Hwy. 45 N. Meridian, MS 39301 601-693-2661 fax: 601-483-0826 wmmz@wokk.com 21. WMOX (AM) Box 5184 Meridian, MS 39302 601-693-1891 fax: 601-483-1010 wmox@wmox.net www.wmox.net 22. WNBM (AM) 266 23rd Street Meridian, MS 39301 601-483-3401 fax: 483-3411 www.wnbn.onlineyp.net 23. WKNN (FM) 286 Debuys Biloxi, MS 39531 228-388-2323 fax: 228-388-2362 www.k99fm.com 24. WXRG (FM) 109 E. Pass Rd. Suite D-11 Gulfport, MS 39507 228-388-2001 fax: 228-896-9736 wxrg@wxrgfm.com www.wxrgfm.com 25. WPMP (AM) 5115 Telephone Rd. Pascagoula, MS 39567 228-762-5683 fax: 228-762-1222 wzzjam1580@aol.com 26. WAVN (FM) 1336 Brookhaven Dr. Southaven, MS 38671 662-393-8056 662-393-8066 27. WELO (AM) Box 410 2214 S. Gloster Ave Tupleo, MS 38801 662-842-7658 fax: 662-842-0197 28. WZLQ (FM) Box 410 2214 S. Gloster Ave Tupleo, MS 38801 662-842-7658 fax: 662-842-0197 29. WKMQ (AM) Box 3300 Tupelo, MS 38803 662-842-1067 fax: 601-842-0725 rickstevens@clearchannel.com 30. WMAH (FM) & WMPN (FM) & WMAV (FM) 3825 Ridgewood Rd. Jackson, MS 39211 601-432-6565 fax: 601-432-6806 www.mpbonline.org 31. WAII (FM) & WPAS (FM) & WAFR (FM) & WAJS (FM) & WAQB (FM) American Family Radio P.O. Box 3206 Tupelo, MS 38803 662-844-8888 fax: 662-842-6791 www.afr.net 32. WMPR(FM) Box 9782 Jackson, MS 39286 601-948-5835 fax: 601-948-6162 www.wmpr901.com wmpr@wmpr901.com Alabama Newspapers 1. Mobile Press Register P.O. Box 2488 Mobile, AL 36652-2488 251.219.5454 - 800.239.1659 www.mobileregister.com Managing Editor: Dewey English, 251-219-5612 newsroom@press-register.com 2. Montgomery Advertiser www.montgomeryadvertiser.com Send press releases to: www.montgomeryadvertiser.com/customerservice/pressrelease.htm Managing Editor: Mel Gray, 334-261-1516 Metro Editor: Jack Mitchell, 334-240-9268 3. The Birmingham News 2200 4th Avenue North P.O. Box 2553 Birmingham, AL 35203 Birmingham, AL 35202 205-325-2222 www.bhamnews.com Metro Editor: Wayne Hester, 205-325-2478, FAX: (205) 325-2283 whester@bhamnews.com State Editor: Glenn Stephens, 205-325-2482, FAX: (205) 325-2283 gstephens@bhamnews.com 4. Dothan Eagle P.O. Box 1968 227 N. Oates St Dothan, AL 36302 Dothan, AL 36301 334-792-3141 www.dothaneagle.com 5. Huntsville Times 2317 South Memorial Parkway Huntsville, AL 35801 256-532-4000 800-239-5271 fax: 256-532-4213 www.htimes.com Metro Editor: Curtis Coghlan, ccoghlan@htimes.com News Editor: Joe Duncan, jduncan@htimes.com City Editor: Shelly Haskins, shaskins@htimes.com General Newsroom: htimes@htimes.com Television stations 1. Alabama Public Television 2112 11th Ave South, Suite 400 Birmingham, AL 35205 205-328-8756 800-239-5233 fax: 205-251-2192 www.aptv.org News Hotline: 334-264-9900, 800-239-5239 2. WABM-TV Birmingham, AL www.wabm68.com Submit to community calendar: www.wabm68.com/community/event_submit.shtml 3. WIAT-TV 2075 Golden Crest Drive Birmingham, AL 35209 205-322-4200 www.wiat.com Newsroom Fax: 205-320-2722 News tips: vporter@wiat.com News press Release: newsrelease@wiat.com 4. WVTM-TV 1732 Valley View Drive Birmingham, AL 35209 205-558-7300 www.nbc13.com/index.html News tip (check “news tip”): www.nbc13.com/contactus/index.html 5. WTTO-TV Birmingham, AL www.wtto21.com Submit to community calendar: www.wtto21.com/community/event_submit.shtml 6. WJTC-TV 661 Azalea Road Mobile, AL 36609 251-602-1544; 877-765-1544 fax: 251-602-1547 www.myupn44.com/Default.aspx News Hotline: 251-602-1558 7. WKRG-TV 555 Broadcast Dr. Mobile, Alabama 36606 251- 479-5555 fax: 251-473-8130 www.wkrg.com News Room fax: 251-662-3071 Assignment desk: assignmentdesk@wkrg.com tv5@wkrg.com 8. WPMI-TV 661 Azalea Road Mobile, Alabama 36609 251-602-1500 fax: 251-602-1547 www.wpmi.com News Tip Hotline: 251-602-1558; fax: 251-602-1550 News Department: nbc15@wpmi.com Public Service Announcements: mobileTV-publicservice@clearchannel.com Calendar Submissions: mornings@wpmi.com 9. WAKA-TV 3020 East Boulevard Montgomery, Alabama 36116 334-271-8888; 800-467-0424 fax: 334-272-6444 www.waka.com Montgomery Newsroom: 334-270-9252; 800-467-0401; fax: 334-244-7859 West Alabama Newsroom: 334-872-2125; fax: 334-872-3787 South Alabama Newsroom: 334-427-1884 10. WSFA-TV Montgomery, AL 334-288-1212 www.wsfa.com Newsroom: 334:284-5276; fax: 334-613-8303 News@wsfa.com Radio Stations 1. WBPT (FM) 301 Beacon Pkwy Suite 200 Birmingham, AL 35209 205-916-1100 fax: 205-916-1152 www.biminghampoint.com 2. WDJC (FM) 2727 19th Place South Birmingham, AL 35209 205-879-3324 fax: 205-802-4555 www.93.7wdjc.com 3. WMJJ (FM) 530 Beacon Pkwy West Suite 600 Birmingham, AL 35209 205-439-9600 fax: 205-439-8390 www.magic96fm.com 4. WUHT (FM) 244 Goodwin Crest Drive Suite 300 Birmingham, AL 35209 205-942-4646 fax: 205-942-3175 www.hot1077radio.com 5. WXJC (AM) 244 Goodwin Crest Drive Suite 126 Birmingham, AL 35209 205-942-9033 fax: 205-942-1087 wydeinfo@crawfordbroadcasting.com www.crawfordbroadcasting.com 6. WAPI (AM) 244 Goodwin Crest Drive Suite 126 Birmingham, AL 35209 205-942-1004 fax: 205-942-1906 www.wapi1070.com 7. WYSF (FM) 244 Goodwin Crest Drive Suite 126 Birmingham, AL 35209 205-942-1004 fax: 205-942-1906 www.wapi1070.com 9. WGIB (FM) 1137 10th Place S. Birmingham, AL 35205 205-323-1516 fax: 205-323-2747 nmills@gleniris.net www.glenirisbaptist.org 10. WABB (AM & FM) 1551 Springhill Ave Mobile, AL 36604 251-432-5572 fax: 251-438-4044 b.dittman@wabb.com www.wabb.com 11. WGOK (AM) 2800 Dauphin St Suite 104 Mobile, AL 36606 251-652-2000 fax: 251-652-2001 www.cumulus.com 12. WKSJ (FM) 555 Broadcast Drive 3rd Fl. Mobile, AL 36606 251-450-0100 fax: 251-497-3418 www.95ksj.com 13. WMOB (AM) Box 63 Mobile, AL 36601 251-432-1360 fax: 251-432-1396 14. WRKH (FM) 555 Broadcast Dr. 3rd Fl. Mobile, AL 36606 www.961therocket.com 15. WHIL (FM) Box 8509 Mobile, AL 36689-0509 251-380-4655 fax: 251-460-2189 whil@whil.org www.whil.org 16. WACV (AM) Box 210723 4101-A Wall St. Montgomery, AL 36121 334-244-1170 fax: 334-279-9563 www.wacv1170.com 17. WHHY(FM) One Commerce St. Suite 300 Montgomery, AL 36104 334-240-9274 fax: 224-279-9219 www.y102montgomery.com 18. WLWI (AM & FM) One Commerce St. Suite 300 Montgomery, AL 36104 334-240-9274 fax: 224-279-9219 www.culumus.com 19. WLBF (FM) Box 210789 Montgomery, AL 36121-0789 334-271-8900 fax: 334-260-8962 mail@faithradio.org www.faithradio.org Texas Newspapers 1. Beaumont Enterprise www.beaumontenterprise.com Submit community news: home.southeasttexaslive.com/Forms/community Local news: localnews@beaumontenterprise.com Managing editor: bpearson@hearstnp.com 2. Houston Chronicle 801 Texas Ave. Houston, TX 77002 713-362-7171 www.chron.com News tips: news@chron.com 3. San Antonio Express News PO Box 2171 San Antonio, Texas 78297-2171 210-225-7411 210-250-3000 fax : 210-351-7372. www.express-news.com Email press releases to: citydesk@express-news.net 4. Austin American Statesman P.O. Box 670 Austin, Texas 78767 www.statesman.com Managing Editor: Fred Zipp, 512-912-2983 State Editor: Gary Susswein, 512-445-3851, FAX: 512- 445-1707 Public/Legal Notices: 512-445-3832 5. Dallas Morning News 508 Young St. Dallas, TX 75202 214-977-8222 www.dallasnews.com Television stations 1. KVUE-TV Austin, TX www.kvue.com Add event to community calendar: www.kvue.com/entertainment/events/addEvent.htm 2. KTBC-TV Austin, TX www.ktbc.com 3. KXAN-TV P.O. Box 490 Austin, TX 78767 512-476-3636 fax: 512- 476-1520 www.kxan.com News Hotline: 512-476-2863, fax:512-469-0630; news36@kxan.com 4. KLRU-TV P.O. Box 7158 Austin, Texas 78713-7158 512-471-4811 fax: 512-475-9090 info@klru.org support.klru.org/site/PageServer?pagename=homepage 5. KNVA-TV P.O. Box 490 Austin, TX 78767 512- 476-3636 fax: 512-476-1520 www.knva.com News Hotline: 512- 476-2863 News: news36@kxan.com 6. KFDM-TV P.O. Box 7128 Beaumont, TX 77726-7128 409-892-6622 fax: 409-892-6665 www.kfdm.com News stories: news@kfdm.com Post on the community calendar: comcal@kfdm.com 7. WFAA-TV 606 Young St. Dallas, TX, 75202 214-748-9631 www.wfaa.com News Tips: news8@wfaa.com Community calendar: www.wfaa.com/localnews/communitycalendar 8. KERA-TV 3000 Harry Hines Boulevard Dallas, Texas 75201 214-871-1390 Metro 972-263-3151 fax 214-754-0635 www.kera.org News leads: 214-871-1390 9. WKTRK-TV 3310 Bissonnet, Houston TX 77005 713-666-0713 www.abclocal.go.com/ktrk News Tips: 713-669-1313 10. KPRC-TV Houston, TX www.click2houston.com/index.html 11. KHOU-TV 1945 Allen Parkway Houston, Texas 77019 713-526-1111 www.khou.com News tips: 713-521-4398; fax: 713-520-7763; assignments@khou.com Community calendar: fax: 713-284-8783 http://poseidon.belointeractive.com/cgi-bin/calendar/index.pl?Calendar=khou_events Public service announcements: KHOU, 1945 Allen Parkway, Houston, Texas 77019 12. KABB-TV 4335 N.W. Loop 410 San Antonio, Texas 78229-5168 210-366-1129 fax: 210-377-4758 www.kabb.com kabbtv@kabb.com news@kabb.com News Desk: 210-442-NEWS; fax: 210-442-6333 13. KUHT-TV 4343 Elgin Houston, TX 77204-0008 713-748-8888 fax: 713-743-8867 www.houstonpbs.org/site/PageServer 14. KLRN-TV 501 Broadway San Antonio, Texas 78215-1820 210-270-9000 800-627-8193 fax: 210-270-9078 www.klrn.org 15. KNVA-TV P.O. Box 490 Austin, TX 78767 512- 476-3636 fax: 512-476-1520 www.knva.com News Hotline: 512- 476-2863 News: news36@kxan.com Radio Stations 1. KLBJ (AM & FM) 8309 N. 1-35 Austin, TX 78753 512-832-4000 fax: 512-832-4081 www.590klbj.com 2. KPEZ (FM) & KVET (FM) 3601 South Congress, #F Austin, TX 78704-7213 512-684-7300 fax: 5120684-7441 www.z1023.com www.kvet.com 3. KAZI (FM) 8906 Wall St. Suite 203 Austin, TX 78754 512-836-9544 fax: 512-836-9563 kazifm@msn.com www.kazifm.com 4. KMFA (FM) 300 N. Lamar Suite 100 Austin, TX 78705 512-476-5632 fax: 512-474-7463 info@kfma.oeg www.kfma.org 5. KLVI (AM) 2855 Interstate 10 east Beaumont, TX 77702 409-896-5555 fax: 409-896-5599 www.klvi.com 6. KQXY(FM) 755 S. 11th St. Suite102 Beaumont, TX 77701 409-833-9421 fax: 409-833-9296 psanders@qt.rr.com www.kqxy.com 7. KRCM (AM) Box 22257 Beaumont, TX 77720-2257 409-835-1340 fax: 409-835-5686 manager@newsradiofox.com www.newsradiofox.com 8. KYKR (FM) 2885 Interstate 10 East Beaumont, TX 77702 409-896-5555 fax: 409-896-5599 www.kykr.com 9. KZZB (AM) 2531 Calder Ave Beaumont, TX 77702 409-833-0990 fax: 409-833-0995 www.kzzbradio.com 10. KBFK (FM) 13331 Preston Rd. Suite 1180 Dallas, TX 75240 972-331-5400 fax: 972-331-5560 www.979tlpbeat.com 11. KFXR (AM) 720 N. Saint Paul St. Dallas, TX 75201 214-855-0002 fax: 214-855-0002 12. KJKK (FM) 7901 Carpenter Fwy. Dallas, TX 75247 214- 630-3011 13. KCBI (FM) Box 619000 Dallas, TX 75261-9000 817-792-3800 fax: 817-277-9929 kcbi@kcbi.org www.kcbi.org 14. KERA (FM) 3000 Harry Hines Blvd. Dallas, TX 75201 214-871-1390 fax: 214-740-9369 kerafm@kera.org www.kera.org 15. KVTT (FM) 11061 Shady Tr. Dallas, TX 75229 214-351-6655 fax: 469-522-0992 kvtt@kvtt.org www.kvtt.org 16. KFJZ (AM) 7700 Carpenter Fwy. Dallas, TX 75247 817-923-3424 fax: 817-923-3451 sarita@radioluz.com 17. KLNO (FM) 7700 Carpenter Fwy. Dallas, TX 75247 214-525-0400 fax: 214-525-0473 (Spanish format - should press release be in Spanish?) 18. KPLX (FM) 3500 Maple at Turtle Creek Suite 1600 Dallas, TX 75219 214-526-2400 Toll free: 888-462-1995 fax: 214-520-4343 www.995thewolf.com 19. WBAP (FM) 2221 E. Lamar Suite 300 Arlington, TX 76006 817-695-1820 fax: 817-695-0014 wbap.com 20. KPFT (FM) 418 Lovett Blvd. Houston, TX 77006 713-526-4000 fax: 713-526-5750 www.kpft.org 21. KTRU (FM) 6100 S. Main Houston, TX 77005 713-348-4098 fax: 713-348-4093 ktru@ktru.org www.noise.ktru.org 22. KTSU (FM) 3100 Cleburne St. Houston, TX 77004 713-313-7591 fax: 313-7479 23. KUHF (FM) 4343 Elgin 3rd Floor Houston, TX 77204-0887 713-743-0887 fax: 713-743-0868 kuhf@kuhf.org www.kuhf.org 24. KFNC (FM) 2700 Post Oak Road Blvd. Suite 2300 Houston, TX 77056 713-300-3585 fax: 713-300-3500 25. KHIB (FM) Houston Christian Broadcasters Inc. 2424 South Blvd. Houston, TX 77098-5196 713-520-5200 www.khcb.org 26. KQQK (FM) 3000 Bering Drive Houston, TX 77057 731-315-3400 fax: 731-315-3506 juliocesar@xoradio.com www.xoradio.com (Partial Spanish format - should press release be in Spanish?) 27. KCOR (FM) 1777 N.E. Loop 410 Suite 400 San Antonio, TX 78217 214-821-6548 fax: 214-804-7820 (Partial Spanish format - should press release be in Spanish?) 28. KCYY (FM) 8122 Datapoint Dr., Suite 500 San Antonio, TX 78229 210-615-5400 fax: 214-615-5300 www.y100fm.com 29. WOAI (FM) 6222 N.W. IH-10 San Antonio, TX 78201 210-736-9700 fax: 210-735-8811 www.woai.com 30. KSTX (FM) & KPAC 8401 Datapoint Dr. Suite 800 San Antonio, TX 78229 210-614-8977 210-614-8983 www.tpr.org 31. KSYM (FM) 1300 San Pedro Ave San Antonio, TX 78212-4299 210-733-2787 fax: 210-733-2801 ksym@accd.edu www.ksym.org 32. KYFS (FM) 9330 Corporate Dr. Suite 808 San Antonio, TX 78154 210-651-9093 fax: 210-651-9093 kyfs@bbnradio.org www.bbnradio.org Tennessee Newspapers 1. Memphis Commercial Appeal 495 Union Ave. Memphis, TN, 38103 901-529-2345 800-444-6397 www.commercialappeal.com Features Editor: Peggy McKenzie, 901-529-2341 Metro Editor: Louis Graham, 901-529-2333 2. Jackson Sun P.O. 1059 Jackson, TN 38302 www.jacksonsun.com Jackson-Madison County News: Amy , McDaniel, 731-425-9617 amcdaniel@jacksonsun.com Region News: Donna Miller, 731-425-9617 dmiller@jacksonsun.com Managing Editor: Africa Price, 731-425-9708 aprice@jacksonsun.com 3. Nashville Tennessean 1100 Broadway Nashville, TN 37203 www.tennessean.com Local news: 615-259-8095 General news and business: 615-259-8093 Managing Editor: David Green, 615-726-5989, dgreen@tennessean.com News announcements: newstips@tennessean.com 4. Chattanooga Times 400 East 11th St. Chattanooga, TN 37403 www.timesfreepress.com News Managing Editor: Larry Henry, 423-757-6597 City Editor: Alison Gerber: 423-757-6408 Television stations 1. WTVC-TV P.O. Box 60028 (mailing address) Chattanooga, TN 37406 423-756-5500 www.newschannel9.com News tips: 423-757-7320 News department fax: 423-757-7401 Events calendar: Mscott@NewsChannel9.com 2. WDEF-TV 3300 Broad Street Chattanooga, TN 37408 423-785-1200 fax: 423-785-1273 www.wdef.com News tips: news@wdef.com Add event to community calendar: http://eventcalendar.mgnetwork.com/index.cfm?fuseaction=home.open&siteid=DEF 3. WRCB-TV Chattanooga, TN www.wrcbtv.com News stories: news@wrcbtv.com 4. WTCI-TV Chattanooga, TN www.wtci-tv45.com 5. WLFI-TV 6024 Shallowford Road, Suite 100 Chattanooga, TN 37421 423-893-9553 fax: 423-893-9853 Community calendar: wfli.promotions@wflitv.com 6. WBBJ-TV Jackson, TN www.wbbjtv.com Community Calendar: 346 Muse Street, Jackson, TN 38301, fax:731-423-8016 7. WPTY-TV Memphis. TN www.abc24.com 8. WREG-TV 803 Channel 3 Drive Memphis, Tennessee 38103 901-543-2333 www.wreg.com News tips: 901-543-2111 News tips and press releases: ethel.sengstacke@wreg.com; lisa.dandridge@wreg.com; mark.woodall@wreg.com; corie.mitchell@wreg.com; dennis.turner@wreg.com; leslie.isbell@wreg.com; tom.moo@wreg.com 9. WMC-TV Memphis, TN www.wmcstations.com 10. WLMT-TV 2701 Union Extd. Memphis, TN 38112 901-323-2430 www.myeyewitnessnews.com News Hotline: 901-321-7668; newsdesk@myeyewitnessnews.com 11. WKNO-TV Memphis, TN www.wkno.org wknopi@wkno.org 12. WKRN-TV 441 Murfreesboro Road Nashville, TN 37210 615-259-2200; 615-369-7222 www.wkrn.com News: 615-369-7236; news@wkrn.com Community events calendar: communityevents@wkrn.com 13. WTVF-TV 474 James Robertson Parkway Nashville, TN 37219 www.newschannel5.com News Tips: 615-254-6397; fax: 615-244-9883 14. WZTV Nashville, TN 615-(615) 369-1717369-1717 Submit story ideas: news@fox17.com To post an event on the community calendar: community@fox17.com www.wztv.com 15. WSMV-TV 5700 Knob Road Nashville, TN 37209 www.wsmv.com/index.html News tips: 615-353-2231; news@wsmv.com 16. WUXP-TV Nashville, TN www.wuxp.com To post a community event: notes@upn30.com Radio Stations 1. WDEF (AM) Box 11008 Chattanooga, TN 37401 423-321-6200 fax: 423-321-6264 2. WDOD (FM) Box 11008 Chattanooga, TN 37401 423-321-6200 fax: 423-321-6264 3. WDYN (FM) 1815 Union Ave Chattanooga, TN 37404 423-493-4382 fax: 423-493-4526 wdyn@wdyn.com www.wdyn.com 4. WDXI (AM) & WMXX (FM) Box 3865 Jackson, TN 38303-3845 731-427-9611 fax: 731-427-1321 5. WJAK (AM) 111 W. Main St. Jackson, TN 38303-38301 731-427-9616 fax: 731-427-9302 bthomas@stn1077.com 6. WNWS (FM) 202 W. Lafayette St. Jackson, TN 38301 731-423-8316 fax: 731-423-8304 newstalk@wnws.com www.wnws.com 7. WTJS (AM) & WTNV (FM) 122 Radio Rd. Jackson, TN 38301 731-427-3316 fax: 731-427-4576 8. WQOX (FM) Telecommunications Center 2485 Union Avenue Memphis, TN 38112 901-320-3460 fax: 901-454-7673 www.wqoxmes/admin/avery/mes.com 9. WBBP (AM) 369 GE Patterson Ave. Memphis, TN 38126 901-278-7878 fax: 901-332-1707 www.bbless.com 10. WGKX (FM) 965 Ridge Lake Blvd Memphis, TN 38119 901-682-1106 fax: 901-767-9531 www.kix106.com 11. WEGR(FM) 2650 Thousand Oaks Blvd. Memphis, TN 38118 901-259-1300 fax: 901-259-6449 www.rock103.com Rock103@aol.com 12. WWTQ (AM) 5904 Ridgeway Ctr. Pkwy. Memphis, TN 38120 901-767-0104 fax: 901-767-0582 13. WAMB (AM & FM) 1617 Lebanon Pike Suite 100 Nashville, TN 37210 615-889-1960 fax: 615-902-9108 wamb@bellsouth.net (Note: partial Spanish format - should press release be in Spanish?) 14. WKDF (FM) Box 101604 Nashville, TN 37224 615-244-9533 fax: 615-259-1271 www.1-3WKDF.com 15. WLAC (AM) 55 Music Sq. West Nashville, TN 37203 615-664-2400 fax: 615-664-2457 www.1510wlac.com 16. WNQM (AM) 1300 WWCR Ave Nashville, TN 37218 615-255-1300 fax: 615-255-1311 www.wwcr.com (Partial Spanish format - should press release be in Spanish?) 17. WSIX (FM) 55 Music Square West Nashville, TN 37203 615-664-2400 fax: 615-664-2457 18. WPLN (FM) 630 Mainstream Dr. Nashville, TN 37228-1204 615-760-2903 fax: 615-760-2904 talkback@wpln.org www.wpln.org Georgia Newspapers 1. Atlanta Journal-Constitution 72 Marietta St NW Ste 4 Atlanta, GA 30303-2899 404-577-5772 www.ajc.com Editor: Julia Wallace, 404-526-7679, jdwallace@ajc.com 2. Marietta Daily Journal 580 Fairground St SE Marietta, GA 30060-2797 770-795-3000 www.mdjonline.com Nat'l News Desk: Ken Denney, 404-422-9533 Managing Editor: Billy Mitchell 3. www.paulding.com (free on-line newsboard) 4. www.cobbtalks.com (free on-line newsboard) ATTACHMENT C FEMA Screening Questions IF: Applicant calls the 800 number in response to the flyer: THEN: Preamble (to be read to applicants): I would like to ask you some questions to find out what you need from FEMA. You have stated that you or a household member has a disability such as longterm physical or health problems, mental health issues, or learning problems that make it hard to do certain things. You do not have to answer these questions, but if you don't answer them, we may not know how to help you or properly determine what you need. FEMA will keep the information you give us confidential. 1. Who in your household has a disability? _________________________________ 2. Name and age of person in the household who has the disability: ____________________________________________________________________ 3. Relationship to you: ___________________________________________________ 4. What type of disability is it? _________________________________________ 5. Describe the disability: ________________________________________________ 6. Does the person use any type of mobility aid (such as a wheelchair, cane, or walker)? ____________________________________________________________ 7. What kind? If a wheelchair, is it a manual wheelchair, a power chair, or a scooter? _______________________________________________________________ 8. Is the mobility aid used at all times or only part of the time? Explain: _______________________________________________________________ 9. What do you or the household member need? Check all that apply: o Ramp with handrails to entrance of trailer or hotel ______ o Sturdy steps with handrails on steps at entrance to trailer or hotel ______ o Doorways wide enough for a wheelchair ______ o Raised toilet seat ______ o Grab bars around toilet ______ o Accessible (rollin) shower ______ o Bathtub with low sides ______ o Grab bars in tub or shower ______ o Bath bench or shower chair (specify) ____________________________ o Hand held shower controls ______ o Cutout area under bathroom sink so chair can pull under _______ o Rooms big enough for wheelchair and wheelchair turn space _______ o Switches and controls reachable from wheelchair ______ o Accessible kitchen appliances (leg space under sink, lower stoves, counters, cabinets etc.) ______ o Visual alarms and notification devices Explain: ________________________ o More room for equipment (e.g., hospital bed) Explain: ________________________________________________________ o All electric trailer ______ o Other _______ Explain in detail: _____________________________________________________ __________________________________________________________________ Are there other things you or a household member need in a trailer or hotel room because of a disability? Explain: _______________________________________________________ How many people in your household will be living in the trailer or hotel? Adult _______ Children ________ How many bedrooms do you need in a trailer? ________ Do you own property with functioning utilities (electric, water, sewer) where a trailer could be placed? ________ If so, do you want a trailer on that property? ________ If no, would you be willing to live in a commercial or group park? ________ For internal FEMA use only Applicant needs a trailer with the following accessibility features: o Ramp with handrails to entrance of trailer ________ o Sturdy steps with handrails on steps at entrance to trailer ________ o Doorways wide enough for a wheelchair ________ o Raised toilet seat ________ o Grab bars around toilet ________ o Accessible (rollin) shower ________ o Bathtub with low sides ________ o Grab bars in tub or shower ________ o Bath bench or shower chair (specify) ________ o Hand held shower controls ________ o Cutout area under lavatory so chair can pull under ________ o Rooms big enough for wheelchair and wheelchair turn space ________ o Switches and controls reachable from wheelchair ________ o Accessible kitchen appliances (leg space under sink, lower stoves, counters, cabinets etc.) ________ o Visual alarms and notification devices: ________ o More room for equipment (e.g., hospital bed) Explain: _____________________________________________________________ o All electric trailer ________ o Other __________________ Explain in detail _____________________________________________________ ____________________________________________________________________ Applicant needs a trailer park with the following accessibility features: o Paved surface from parking area to ramp or stairs to trailer ________ o Level paved landing at bottom of ramp ________ o Accessible path of travel (e.g., paved surfaces) to laundry rooms, public telephones, public transit stops, other trailers, etc. ________ o Front loading washing machines ________ o Accessible paths of travel in and out of the trailer park and within park o Other issues (explain) _________________________________________________ Was applicant provided with another trailer on an interim basis? ________ Applicant was provided with a trailer on ________ The model and size of the trailer provided was ________ The following modifications were made to the trailer on ________ An accessible trailer was not provided to the applicant within ________ days of the request for the following reason: ________________________________ Applicant should be provided with the following trailer model(s), which provide the above accessibility features: [Caseworkers need a complete list of specific (available) trailer models, including numbers of bedrooms] Applicant needs a hotel room with the following accessibility features: o Wheelchair accessible, without rollin shower o Wheelchair accessible, with rollin shower o Visual alarms, notification devices and TDD phones (for Deaf persons) o Other (explain): ATTACHMENT D UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA __________________________________________ ) CLAIRE BROU, et al., ) ) Plaintiffs, ) Case No.: 060838 v. ) ) JUDGE DUVAL FEDERAL EMERGENCY MANAGEMENT ) AGENCY, et al., ) MAGISTRATE JUDGE ) KNOWLES Defendants. ) __________________________________________) FINAL JUDGMENT APPROVING SETTLEMENT AGREEMENT Following this Court’s order preliminarily approving the proposed Settlement Agreement and certifying this action as a class action for settlement purposes, the parties disseminated a Notice of Proposed Settlement and Fairness Hearing to the plaintiff class. After consideration of the written submissions of the parties, the proposed Settlement Agreement between the parties, all objections to the Settlement Agreement, all filings in support of the Settlement Agreement, and the presentations at the hearing held by the Court to consider the fairness of the Settlement Agreement, the Court hereby Orders, Adjudges, and Decrees that: 1. The Settlement Agreement between plaintiffs and defendants, which is attached hereto, is finally approved as fair, reasonable, and adequate. 2. Except as provided in paragraph 3 of this Order, Plaintiffs’ Claims in this action are hereby dismissed with prejudice. 3. The Court shall retain jurisdiction to enforce compliance with the terms and conditions of the Settlement Agreement, as specified in paragraph 13 of such Agreement, and to hear and determine claims for additional relief filed upon behalf of individual Class Members pursuant to paragraph 14 of the Agreement. The Court's jurisdiction under this paragraph shall terminate at such time as the Parties file a final report as specified in paragraph 21 of the Agreement. Dated: , 2006 HONORABLE STANWOOD R. DUVAL, JR. United States District Judge ATTACHMENT E UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA __________________________________________ ) CLAIRE BROU, et al., ) ) Plaintiffs, ) Case No.: 060838 v. ) ) JUDGE DUVAL FEDERAL EMERGENCY MANAGEMENT ) AGENCY, et al., ) MAGISTRATE JUDGE ) KNOWLES Defendants. ) __________________________________________) PRIVACY ACT PROTECTIVE ORDER Upon the joint motion of the Parties in the above-captioned matter, and pursuant to the provisions of Section 3(b)(11) of the Privacy Act of 1974, 5 U.S.C. § 552a(b)(11), IT IS HEREBY ORDERED that Defendants are authorized to release the records described in paragraphs 6.D. and 9.A. of the Settlement Agreement between the Parties to the attorneys designated by the Court as Class Counsel, without obtaining the prior written consent of the individuals to whom such records or information pertain. Such disclosure is subject to the following conditions: 1. For purposes of this Order, the term "record" shall have the same meaning as set forth in the Privacy Act, 5 U.S.C. § 552a(a)(4). This Order applies to documents or information contained in records that are subject to the Privacy Act only and does not create greater or lesser rights or obligations than those contained in the Privacy Act. Document summaries, statistical compilations, or other summary records which do not contain information by which to identify specific individuals (whether by name, social security number, symbol or other form of personal identification), and which are not thereby subject to the Privacy Act, are not covered by this Order. 2. Records that identify specific individuals shall be marked "PRODUCED SUBJECT TO PROTECTIVE ORDER" or "SUBJECT TO PROTECTIVE ORDER" or contain a similar marking, and may be used only for purposes of this litigation. For any records, such as computer data, whose medium makes such stamping impracticable, the diskette case and/or accompanying cover letter shall be marked "PRODUCED SUBJECT TO PROTECTIVE ORDER" or "SUBJECT TO PROTECTIVE ORDER" or contain a similar marking. Answers to interrogatories, if any, that contain protected information derived from records subject to the Privacy Act also shall be marked "PRODUCED SUBJECT TO PROTECTIVE ORDER" or "SUBJECT TO PROTECTIVE ORDER" or contain a similar marking, and may be used only for purposes of this litigation. Except as provided herein, no person having access to records designated as subject to this Order or the information therein shall make public disclosure of those records or that information without further Order of the Court. 3. Class Counsel may disclose records subject to the requirements of this Order only to the Court, the attorneys of record for the Parties, persons regularly in the employ of such attorneys who have a need for the information in the performance of their duties, experts or other retained consultants, the individual(s) to whom the record pertains, and fact witnesses for the Parties who have a need for the information for the purposes of this litigation. Such disclosure shall in all cases be made only for the purposes of the pending litigation. 4. Any person listed in paragraph 3 (except the Court and Defendants’ employees and Defendants’ counsel) who has a need to review records subject to this Order must sign the Acknowledgment of Privacy Act Protective Order attached hereto before the records may be disclosed to that person by Class Counsel. 5. Should Class Counsel wish to disclose records or information which are subject to this Order to any additional persons except those indicated in paragraph 3, Class Counsel will first seek the Defendants’ consent. If Defendants do not consent to disclosure, then Plaintiffs or their counsel may, on motion, seek modification of this Order from the Court. 6. All individuals to whom records which are subject to this Order are disclosed by Class Counsel shall return any and all records and copies thereof in their possession to Class Counsel before termination of this litigation, or when they are no longer a party to or assigned or retained to work on this case, whichever comes earlier. 7. Records designated as subject to this Order and all copies thereof must be returned to the Federal Emergency Management Agency and/or its counsel or destroyed within 30 days after the termination of this litigation, including any appeals. Any document created by Class Counsel which contains or reflects information protected by the Privacy Act must be destroyed when this litigation is concluded. Notwithstanding the preceding two sentences, Class Counsel may, upon certification to Defendants that the records are being maintained pursuant to this Protective Order, defer the return and/or destruction of any such documents for a period not to exceed six years after the termination of this litigation, including any appeals. In the event that such certification is provided, Class Counsel must, at Defendants’ counsel’s request, inform Defendants of steps being taken to ensure compliance with this order. Should Class Counsel elect to destroy rather than return the documents, Class Counsel shall within 45 days thereafter certify to Defendants’ counsel that the documents have been destroyed. 8. Nothing in this Protective Order affects the right of counsel to discuss with their clients any relevant information contained in records subject to this Protective Order. 9. Those portions of any filings with the Court which contain information protected by the Privacy Act shall be made under seal. 10. This Order does not constitute a ruling on the question of whether any particular record is properly discoverable or admissible, and does not constitute a ruling on any potential objection to the discoverability of any record, other than objections based on the Privacy Act. IT IS SO ORDERED. DATED: , 2006 UNITED STATES DISTRICT JUDGE AGREED: _____________________________ NELL HAHN Director of Litigation and Systems Advocacy Advocacy Center 600 Jefferson Street Suite 812 Lafayette LA 70501 Telephone: (337) 2377380 Facsimile: (337) 2370486 Email: nhahn@advocacyla.org Attorney for Plaintiffs _____________________________ CARY LACHEEN National Center for Law and Economic Justice 275 Seventh Avenue, Suite 1506 New York, NY 100016708 Tel: (212) 6336967 Fax: (212) 6336371 E-mail: lacheen@nclej.org Attorneys for Plaintiffs Dated: PETER KEISLER Assistant Attorney General JIM LETTEN United States Attorney GLENN K. SCHREIBER Assistant United States Attorney JOSEPH LOBUE Assistant Director Federal Programs Branch ____________________________ DIANE KELLEHER Trial Attorney Department of Justice Civil Division, Room 7318 Post Office Box 883 Washington, D.C. 20044 Telephone: (202) 5144775 Facsimile: (202) 6168470 Email: Diane.Kelleher@usdoj.gov Attorneys for Defendants Dated: UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA __________________________________________ ) CLAIRE BROU, et al., ) ) Plaintiffs, ) Case No.: 060838 v. ) ) JUDGE DUVAL FEDERAL EMERGENCY MANAGEMENT ) AGENCY, et al., ) MAGISTRATE JUDGE ) KNOWLES Defendants. ) __________________________________________) ACKNOWLEDGMENT OF PRIVACY ACT PROTECTIVE ORDER I, , hereby acknowledge that I have read and understand the Privacy Act Protective Order entered in this action. I hereby agree to be bound by the terms of the Order and to comply with each of its requirements, including the following: 1. I agree that I will use records and information protected by the Order only for purposes of this case, including any appeals, and not for any other purpose of any kind. 2. I agree that records and information and all copies thereof protected by the Order, will be returned to Class Counsel prior to the termination of this litigation, or when I am no longer assigned or retained to work on this case, whichever comes earlier so that the records and information may be returned to the Defendants or destroyed within 30 days after the termination of this litigation. 3. I agree that any documents containing Privacy Act information will be destroyed when this litigation is concluded, and that Class Counsel will so certify to the Defendants. 4. I agree that I will disclose records and information protected by the Order only to the Court, the attorneys of record for the Parties, persons regularly in the employ of such attorneys, and any experts or consultants hired for this case by the Parties or their attorneys, the individual(s) to whom the record pertains, and fact witnesses who (except the Court, Defendants’ employees and Defendants’ counsel) have signed an acknowledgment like this one and have a need for such information to perform duties specifically related to the conduct of this litigation. 5. Should I wish to disclose the records which are subject to the Order to any additional persons except those indicated in the Order and herein, I will first seek the Defendants’ consent. If the Defendants do not consent to the disclosure, then I may, on motion, seek modification of the Order from the Court. 6. I agree that those portions of any filings with the Court which contain Privacy Act materials shall be filed under seal. 7. I hereby confirm that my duties under this Acknowledgment shall survive the termination of this case and are binding upon me for all time. 8. I hereby consent to the personal jurisdiction of the United States District Court for the Eastern District of Louisiana in the above-captioned case for the purpose of enforcing the aforementioned Order. [signature] [print name] DATED: ?28? ?54? ?5? ?2? ?6? ?3?