Melendres # 1696 P Memo Re Notice Costs

Case 2:07-cv-02513-GMS Document 1696 Filed 06/01/16 Page 1 of 6
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Cecillia D. Wang (Pro Hac Vice)

cwang@aclu.org
Nida Vidutis*
nvidutis@aclu.org
ACLU Foundation
Immigrants Rights Project
39 Drumm Street
San Francisco, CA 94111
Telephone: (415) 343-0775
Facsimile: (415) 395-0950
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Daniel J. Pochoda
dpochoda@acluaz.org
Brenda Muoz Furnish
bmfurnish@acluaz.org
ACLU Foundation of Arizona
3707 N. 7th Street, Suite 235
Phoenix, AZ 85014
Telephone: (602) 650-1854
Facsimile: (602) 650-1376
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*Application for admission pro hac vice forthcoming
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Attorneys for Plaintiffs (Additional attorneys

for Plaintiffs listed on next page)
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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA
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Manuel de Jesus Ortega Melendres,

et al.,
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Plaintiffs,
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v.
Joseph M. Arpaio, et al.,
Defendants.
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CV-07-2513-PHX-GMS
PLAINTIFFS MEMORANDUM IN
SUPPORT OF A $200,000 NOTICE
BUDGET FOR CIVIL CONTEMPT
COMPENSATION SCHEME
PURSUANT TO THE COURTS
ORDER OF MAY 31, 2016
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Additional Attorneys for Plaintiffs:

Andre I. Segura (Pro Hac Vice)
asegura@aclu.org
ACLU Foundation
125 Broad Street, 17th Floor
New York, NY 10004
Telephone: (212) 549-2676
Facsimile: (212) 549-2654
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Anne Lai (Pro Hac Vice)

alai@law.uci.edu
401 E. Peltason, Suite 3500
Irvine, CA 92697
Telephone: (949) 824-9894
Facsimile: (949) 824-0066
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Stanley Young (Pro Hac Vice)

syoung@cov.com
Covington & Burling LLP
333 Twin Dolphin Drive, Suite 700
Redwood Shores, CA 94065
Telephone: (650) 632-4700
Facsimile: (650) 632-4800
Tammy Albarran (Pro Hac Vice)
talbarran@cov.com
Lauren E. Pedley (Pro Hac Vice)
lpedley@cov.com
Covington & Burling LLP
One Front Street
San Francisco, CA 94111
Telephone: (415) 591-7066
Facsimile: (415) 955-6566
Jorge M. Castillo (Pro Hac Vice)

jcastillo@maldef.org
Julia Gomez*
jgomez@maldef.org
Mexican American Legal Defense and

Educational Fund
634 South Spring Street, 11th Floor
Los Angeles, CA 90014
Telephone: (213) 629-2512
Facsimile: (213) 629-0266
James B. Chanin (Pro Hac Vice)
jbcofc@aol.com
Law Offices of James B. Chanin
3050 Shattuck Avenue
Berkeley, CA 94705
Telephone: (510) 848-4752
Facsimile: (510) 848-5819
*Application for admission pro hac vice

forthcoming
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THE BUDGET FOR BROWNGREERS NOTICE PLAN SHOULD BE $200,000

After conferring with BrownGreer PLC (BrownGreer), and based upon their advice,
Plaintiffs propose that a budget of $200,000 is necessary to achieve adequate notice to
persons who were subject to detentions in violation of the December 23, 2011 preliminary
injunction and give them the best chance of participation in the court-ordered compensation
scheme. Without the widespread, effective notice plan afforded by a $200,000 budget, there
is substantial risk that the injured persons will not be aware of the availability of
compensation and will be prejudiced in their ability to obtain just compensation for harms
they suffered as a result of MCSOs contemptuous conduct. A more robust notice program
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is warranted in this case in part because Defendants have not undertaken independent efforts
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to locate individuals harmed by violations of the preliminary injunction, and because they
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failed to document all immigration detentions. Contempt Findings 159. Further, many
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years have passed since some of the detentions occurred and injured persons may not be
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aware that they should consider making a claim for the improper MCSO detention. A
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document created by BrownGreer outlining the specific breakdown of costs associated with
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the proposed notice plan is attached as Exhibit A. While the specifics of the plan outlined by
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BrownGreer are subject to the Parties input, it provides a helpful understanding of the type
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of widespread outreach that could be achieved with the proposed budget.
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As evidenced in Exhibit A, $200,000 provides for a more extensive radio campaign,
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which according to BrownGreers research has the highest reach among Latino audiences,
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thereby maximizing the chances of reaching individuals who were improperly detained by
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MCSO. Based upon that information, a significant portion of the budget would be spent on
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radio advertising on many different stations and in English and Spanish for at least thirty
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days. The smaller budget proposed by Defendants would result in fewer days of radio spots
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and would restrict notice of the plan to fewer stations. $200,000 is needed to secure
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advertising on radio stations with the largest Latino audiences and reach a larger number of
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individuals who were detained.
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The $200,000 budget would also allow BrownGreer to utilize strategic partnerships
with other organizations, including nongovernmental groups in Arizona and Mexico with
expertise working with hard-to-reach migrant communities (Public Relations). Local
nongovernmental organizations are well-positioned to reach directly potential victims of
Defendants contemptuous detentions and serve as effective sources of information regarding
the compensation plan. For that reason, they are vital to an effective outreach program, and
ought to be funded.
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Plaintiffs respectfully request that the Court issue an order that Maricopa County
provide $200,000 for a notice budget for the victim compensation mechanism as part of the
remedy for the civil contempt.
RESPECTFULLY SUBMITTED this 1st day of June, 2016.
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By: /s/ Lauren E. Pedley
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Cecillia D. Wang (Pro Hac Vice)

Andre I. Segura (Pro Hac Vice)
Nida Vidutis*
ACLU Foundation
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Daniel Pochoda
Brenda Muoz Furnish
ACLU Foundation of Arizona
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Anne Lai (Pro Hac Vice)
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Stanley Young (Pro Hac Vice)

Tammy Albarran (Pro Hac Vice)
Lauren E. Pedley (Pro Hac Vice)
Covington & Burling, LLP
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Jorge M. Castillo (Pro Hac Vice)

Julia Gomez*
Mexican American Legal Defense and
Educational Fund
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James B. Chanin (Pro Hac Vice)
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Attorneys for Plaintiffs
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*Applications for admission pro hac vice

forthcoming
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CERTIFICATE OF SERVICE
I hereby certify that on June 1, 2016, I electronically transmitted the attached
document to the Clerks office using the CM/ECF System for filing. Notice of this filing
will be sent by e-mail to all parties by operation of the Courts electronic filing system or by
mail as indicated on the Notice of Electronic Filing.
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Dated this 1st day of June, 2016.

/s/ Lauren E. Pedley
Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 1 of 15
EXHIBIT A
POTENTIAL SETTLEMENT
NOTICE PLAN
MELENDRES v. ARPAIO
2:07-cv-02513-PHX-GMS (D. Ariz.)
Developed on 8/18/2015.
Revised at party request on 6/1/16.
______________________________________________________________________________
2014 BrownGreer PLC
450896
TABLE OF CONTENTS
I.
General Introduction .............................................................................................................. 1
II.
Target Audience ..................................................................................................................... 1
III.
Available Potential Claimant Data......................................................................................... 3
IV. Individual Notice ................................................................................................................... 4

V.
Publication Notice.................................................................................................................. 5
VI. Summary of Notice Plan ...................................................................................................... 11

VII. Estimated Costs.................................................................................................................... 11
2015-16 BROWNGREER PLC | 250 ROCKETTS WAY | RICHMOND, VA 23231 | WWW.BROWNGREER.COM
I.
GENERAL INTRODUCTION
BrownGreer prepared this potential notice plan (the Plan) on August 18, 2015 for the
Melendres v. Arpaio matter, based on our initial conversations with Plaintiffs Counsel and on
our review of preliminary compensation procedure proposals prepared by the Parties and
provided to us on a confidential basis on August 7, 2015. Drawing upon our experience and the
positions of the Parties, we developed the Plan with an aim to provide an effective and efficient
notice framework in this non-Rule 23 context. On June 1, 2016, we updated Section V.B.5 of
this Plan (and the corresponding cost line item in Row 7 of the table in Section VII) to reflect an
increased public relations investment proposed by Plaintiffs in light of their interactions with
potential strategic partners presenting interest in assisting affected individuals to whom they have
direct access. The data and information included in this Plan is otherwise original to the August
18, 2015 initial version.
The Plan attempts to inform individuals and their passengers (the Potential Claimants) who
were stopped in violation of the December 2011 preliminary injunction order of the existence of
this proposed settlement, how it affects them, their rights and obligations under the eventual
Settlement Agreement, the actions they may take, the deadlines for acting, and the consequences
of acting or failing to act by the deadline. This document explains the means by which we
preliminarily proposed accomplishing this, how we arrived at those means, and how we would
implement the Plan.
II.
TARGET AUDIENCE
A. Target Audience Overview.

We understand that there may be approximately 200 to 500 known individuals, plus an
additional undetermined number of unknown individuals, who are affected by this litigation. The
population of Potential Claimants is mostly males aged 18 to 55 residing in Arizona, though it
may include women and minors who may reside in other southwestern states and possibly in
Mexico, Guatemala, or Honduras. We further understand that the individuals speak
predominantly, and in some cases exclusively, Spanish, generally have lower educational levels,
and for the most part consists of lower income earners. Additionally, we have tailored the Plan
to reach persons who may be apprehensive of persons in positions of authority.
B. The Methodology Used to Learn About These Potential Claimants.

To design an effective notice campaign, we must consider and analyze the attributes and the
media consumption habits of the target audience to select properly the media opportunities
offering the greatest reach in the most effective manner possible. This allows us to paint a
clearer picture of the target group and provide a better understanding of how to contact these
Potential Claimants.
This process begins with identifying the target audience through the use of syndicated research
data. The two most widely used options include Nielsens Scarborough USA+ study and GfK
MRIs Survey of the American Consumer.
Nielsens Scarborough USA+ is a leading provider of local and national market research,
shopping patterns, media behaviors, and lifestyle and demographic information of persons in the
United States. It uses a two-part survey conducted in the spring and the fall of each year with
over 210,000 consumers aged 18 and older, which provides a high level of reliability.
Scarborough serves multiple industries including print, radio, broadcast TV, cable TV, out of
home, agency, and sports marketing. Scarborough USA+ emphasizes the media consumption
habits of persons in the United States. Scarborough USA+ is accredited by the Media Rating
Council (MRC), which is an industry-funded organization that establishes standards and
guidelines for media industry measurement services to ensure valid and reliable research
methods.
GfK MRIs Survey of the American Consumer, also accredited by the MRC, conducts interviews
in the spring and the fall of each year with approximately 26,000 adult consumers in a two-phase
collection process. This survey provides a detailed view of media choices, demographics,
lifestyles, and attitudes of consumer usage of almost 6,000 products in 550 categories. The GfK
MRI survey focuses on consumer attitudes towards media.
While both sources offer reliable data, we chose to use syndicated data available from Nielsens
Scarborough USA+ to develop a profile of the demographics and media consumption habits of
Potential Claimants, because of Scarborough USA+s larger sample size and in-depth media
consumption surveying.
C. Potential Claimant Demographics.
1. Maricopa County is the largest county within the Phoenix market, which covers 9,224
square miles.
2. Maricopa County is the 4th most populous county in the United States.
3. In Maricopa County, the Hispanic population is over 1.1 Million. 60% of the states
Hispanic population resides in Maricopa County.
4. 31% of the population in the state of Arizona is Hispanic.
The makeup of the Hispanic population in Maricopa County is roughly 50/50 male/female
and 18+ population is 736,368, representing 52.4% of the whole.
49.90
%
Age Range
Gender
Male
50.06
%
2-11 12-17 18-34 35-64 65+

Age Range 13.5%18.2%17.6%18.9%15.9%
Female
III.
Hispanic market rank in the US: #9

76% of Phoenix Hispanics prefer to
speak Spanish; best reached using
Spanish language
Median Phoenix Latino household
income: $40,537
Persons per household: 3.6
AVAILABLE POTENTIAL CLAIMANT DATA
We understand that the Defendants can produce some name, date of birth, and address data on
approximately 200 to 500 individuals; however, as most Potential Claimants were never booked,
there may not be identifying information for the entire population of harmed individuals.
IV.
INDIVIDUAL NOTICE
We understand that this will not be a class action settlement and that, accordingly, Fed. R. Civ.
P. 23 will not be implicated expressly. Nevertheless, drawing upon Rule 23s directive that we
should issue individual notice to all members who can be identified through reasonable effort
and basic concepts of due process, the Plan will attempt direct, individual notice to all Potential
Claimants for whom any direct notice may be attempted using a combination of available contact
information again, recognizing that Defendants will have contact information for few, if any,
As it appears no email notice will be accomplishable, the direct notice necessarily must
contemplate mailing a notice letter or packet where possible. Such a notice would typically
include at least the following in clear and plain language:
(a) An introductory paragraph that summarizes the key facts of the settlement program
and proposed Settlement;
(b) An explanation of Claimant membership and Potential Claimants benefits under the
terms of the proposed Settlement;
(c) Instructions that indicate how Potential Claimants may receive benefits from the
Settlement;
(d) A clear and brief description of the underlying case and the claims and issues
involved;
(e) If applicable, a description of the Potential Claimants right to opt out of or object to
the Settlement and the procedures for doing so, and the right to appear before the
Court at a Fairness Hearing;
(f) Counsel information and a Potential Claimants right to hire his or her own attorney;
(g) Instructions that indicate how Potential Claimants may access a full, detailed notice
from the Claims Administrators website;
(h) The Claims Administrators mailing address, website, and toll-free number; and
(i) A notice identification number unique to every Potential Claimant.
We do not expect to receive many addresses, but for those that we do receive we will attempt to
verify and update all addresses in the data files from Defendants against the United States Postal
Services (USPS) National Change of Address (NCOA)1 database prior to mailing, to

confirm and update Potential Claimants mailing addresses based on change of address
information maintained by the USPS. We will then attempt to (1) certify the addresses through
Coding Accuracy Support System (CASS)2 software to ensure the accuracy of ZIP and ZIP + 4
codes and completeness of addresses; (2) verify the addresses through Delivery Point Validation
(DPV)3 data to confirm the accuracy of and deliverability to the addresses by checking the
addresses against valid deliverable addresses according to the USPS; and (3) process the
addresses against Locatable Address Conversion System (LACS)4 software to compare
addresses with USPS data and update them when there are rural route address changes or
emergency services address updates. If a Potential Claimants address is updated based NCOA,
CASS, DPV, or LACS, the updated address will be used for mailing the notice. If there are no
updates to a Potential Claimants address in NCOA, CASS, DPV, or LACS, the notice will be
sent to the most recent mailing address as reflected in Defendants records.
If a notice is returned by the USPS as undeliverable but with a forwarding address, we will
promptly re-mail the notice to the updated address provided by the USPS. Mail is forwarded by
the USPS for 12 months after a customer submits a Change of Address order and Change of
Address orders are maintained by the USPS for 18 months. An undeliverable notice should
therefore be returned to BrownGreer by the USPS with a forwarding address in the six-month
period after a Potential Claimants 12-month forwarding order expires. If the returned notice
does not identify any updated address from the USPS, we will submit the Potential Claimants
mailing information to the LexisNexis compendium of domestic addresses for updated address
information, if available. In addition, we will update addresses based on requests received from
V.
PUBLICATION NOTICE
A. Media Consumption.
With few addresses available to contact Potential Claimants directly, the primary focus of the
notice effort will be to reach persons through other media. Consumers have more choices than
ever today. Analyzing their usage and time spent with various media helps us identify the most
1
The NCOA database contains records of all permanent change of address submissions received by the USPS from
individuals and businesses. The Settlement Potential Claimant list is submitted against the database, and a Potential
Claimants address is automatically updated with the new address from USPS data based on a comparison with the
Potential Claimants name and last known address.
2
CASS is a certification process to standardize the address format and ensure the accuracy of ZIP and ZIP + 4
codes. The Potential Claimant list is submitted and the ZIP and ZIP + 4 codes are compared and updated based on
the ZIP and ZIP + 4 codes in the USPS data.
3
DPV confirms addresses against known addresses in the USPS system to verify accuracy and to confirm that mail
is deliverable to a particular address. The addresses are compared against valid addresses in the USPSs Address
Management System and DPV verifies the accuracy of addresses and reports the deficiencies or errors in incorrect
addresses.
4
LACS compares addresses against USPS data, and addresses are updated when there are emergency/E911 updates
or streets are renamed (for example, from Rural Route 2 Box 5 to 123 Main Street).
effective, efficient mediums to target. Radio has the highest reach among all media with the
target population:
91% 87%
80%
67%
60%
50% 49%
27%
7%
Listened to
Watched
Watched Any
Used
Visited
Read Any
Radio Past 7 Broadcast TV Non-Premium Cellphone to Facebook Past Newspaper
Days
Past Week
Cable Past Access Internet
Month
Past Week
Week
Visited
YouTube Past
Month
Visited
Pandora
Past Month
5%
Listened to Visited Spotify

Satellite Radio Past Month
Past Week
Reach and time spent with radio is strong across all age groups.
Hispanics
12+
Weekly
Reach:
93.0%
Weekly
Reach:
93.5%
Hispanics
18+
Weekly
Reach:
92.7%
Hispanics
18-34
Weekly
TSL:
13hrs:15min
Weekly
TSL:
14hrs:01min
Weekly
TSL:
12hrs:24min
Best
Daypart:
10a-3p
Best
Daypart:
10a -3p
Best
Daypart:
3-7p
Hispanics
25-54
Weekly
Reach:
94.6%
Hispanics
35-64
Weekly
Reach:
95.0%
Weekly
TSL:
14hrs:19min
Weekly
TSL:
15hrs:16min
Best
Dayparts:
10a-3p, 37p
Best
Daypart:
10a-3p
B. Preliminary Media Recommendation.

We recommend a combination of traditional and digital media to reach the primary target
audience in Phoenix, Arizona, including:
1. Hispanic Radio
2. Hispanic Newspaper
3. Digital: Paid Search

4. Digital: Banner Ad Display
5. Public Relations
1. Hispanic Radio.
Hispanic radio will offer the best opportunity to reach the largest cumulative persons within
our target audience. In addition, it is the primary broadcast medium that is most accessible to
this migrant target population.
We will work with stations that are primarily Spanish dominant, supported with a few topranking stations that are English dominant since this demographic is bilingual (80% of
Phoenix Hispanics are Spanish dominant or bilingual).
We will work with stations to develop a campaign that would include:
1.
2.
3.
4.
Spot schedule (:60)

Live reads from local on-air talent (adding strong level of trust)
Opportunities to have exposure at local events
Exposure on their website and social media networks
Our strategy will be to develop customized schedules across multiple top-ranking radio
stations among the Hispanic listeners. This will provide the highest reach against our target
audience, ensuring as many people as possible hear the message. The spot schedule alone
should deliver significant reach against the target audience in this community.
Station
Dial Position
Format
Rank
KLNZ-FM
103.5
Mexican Regional
KHOT-FM
105.9
Mexican Regional
KNAI-FM
88.3
Mexican Regional
3t
KVVA-FM
107.1
Spanish Adult Hits
3t
KESZ-FM
99.9
Adult Contemporary
5t
KUPD-FM
97.9
Rock
5t
KOMR-FM
106.3
Spanish Adult Hits
7t
KZZP-FM
104.7
CHR
7t
KKFR-FM
98.3
Rhythmic AC
9t
KZON-FM
101.5
Top 40
9t
2. Hispanic Newspapers.
To extend the reach of our target audience beyond radio, we feel that public notice ads
should be placed in the local Hispanic newspapers as well as an announcement in the primary
Arizona newspaper. The newspaper is easily accessible for our target audience.
Publication
Published
Circulation
Ad Size
LaVoz
Weekly on Fridays
75,000
Full Page
Prensa Hispana
Weekly on Thursdays
48,140
Full Page
The Catholic Sun
Monthly
117,000
Full Page
Arizona Republic
Main Daily Paper
503,080
1/8 Page
3. Digital: Paid Search.
We will develop and deploy targeted keywords across

Google, Yahoo and Bing search engines, the top three
search engines based on U.S. Explicit Core Search
Share.
It likely will be challenging to compete with the news
outlets in the search arena, therefore we recommend a
small paid search campaign for the primary settlement
keywords.
4. Digital: Banner Ad Display.

Behaviorally targeted banner display ads will appear on strategically
selected websites as our target audience surfs the web. We can target
both demographically and geographically and display ads in Spanish
and/or English.
We preliminarily recommend one to two million impressions delivered
over a 30-day campaign.
We will use a mix of behavioral targeting through Googles DoubleClick
advertising network exchange, direct placement on news websites
catering to the Latino community, and Facebook ads targeting the
Hispanic population.
Behavioral targeting increases the effectiveness of a campaign by using an individuals webbrowsing behavior, such as pages they have visited or searches they have made, to select the
websites on which the ads appear. This allows us to reach the broader portion of our target
audience based on language, geography, and age range.
Facebook ads will allow us to target the audience more narrowly, based on language,
geography, age range, income levels and interests.
As our target audience is highly mobile, it will be critical to select mobile-friendly websites
in anticipation of Potential Claimants accessing the internet on non-desktops, such as
smartphones. Therefore, we will deploy the following standard ad sizes: (1) 320x50
(Mobile), (2) 728x90, (3) 300x250, (4) 160x600, and (5) 300x600.
5. Public Relations.
The proposed public relations efforts focus on communications objectives, tactical measures,
media outreach and other assets beneficial to disseminating the notification message. The
Plan will utilize public relations outreach and leverage media relations and digital
communications to drive conversation and reach a vast population among local and regional
target audiences, with a focus on the below outreach categories:
(a) Maricopa County
(1) General Public
(2) Community Centers
(3) Religious Centers (focus on Catholic groups)
(b) Arizona Hispanic Chamber of Commerce
(c) Legal Aid of Arizona
(d) Advocacy Groups (National Council of La Raza (NCLR))
(e) Recreational and Professional Sports Leagues

(1) Soccer
(2) Baseball
(f) Media
(1) Local Media (print, online, radio); focus on local and community news, Hispanic
focus, legal matters, current affairs and investigative news, advocacy awareness
(2) Regional Media (surrounding states)
(g) Party-Selected Strategic Partners (other groups in affected areas reporting access to
Potential Claimants)
The Plan contemplates distributing a print, online, or audio news release as necessary to
media and general interest groups across Maricopa County and the Phoenix direct markets, as
well as regional markets beyond Arizona, budget permitting. General media for the
Maricopa County market include, but are not limited to:
1. Arizona Daily Sun
2. Arizona Informant
3. Arizona Oddities
4. Arizona Republic Online
5. Associated Press Phoenix Bureau
6. Coolidge Examiner
7. Daily News-Sun
8. El Mirage News
9. Fountain Hills Times
10. Prensa Hispana
11. The Catholic Sun
12. La Voz Arizona
13. Horizonte
14. Latino Perspectives
15. Peoria Times
16. Phoenix New Times
17. Pueblo Publishers
18. San Manuel Miner

19. Southeast Valley Ledger
20. The Arizona Republic
21. The Daily Courier
22. West Valley View
23. KFYI-AM
24. KNAU-FM
25. Horizonte-KAE-TV
26. iHeartMedia, Inc.
27. Hubbard Radio
28. CBS Radios
29. Univision
30. Entravision Communications
31. Bonneville International Corporation
32. Cesar Chavez Foundation
33. Family Life Broadcasters, Inc.
The tentative Public Relations Timeline would be:

(a) 30 Days:
(1) Direct bulk of Plan outreach efforts to local/regionally targeted media and
community lists
(2) Follow-ups, continued research and outreach development
(3) Coordinate interview opportunities
(4) Monitor PR media coverage
(b) 60 90 Days:
(1) Continued follow-up and support of Plan
(2) Monitor PR media coverage
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C. Regional Target Audience Beyond Phoenix.

A regional public notice campaign will extend beyond the local Phoenix area. It will reach cities
with large Hispanic populations that are likely to have connections to or have travelled through
the Maricopa County area, with these preliminary suggestions of focus:
1.
2.
3.
4.
Arizona: Tucson
New Mexico: Albuquerque, Santa Fe, Las Cruces
California: San Diego, Los Angeles
Nevada: Las Vegas
Traditional media in these markets would run between $500,000 and $1 million, so we
recommend utilizing digital paid search and display advertising, as well public relations efforts,
to minimize costs but still enjoy productive reach.
D. International Target Audience.
To reach the target population in international markets, we recommend utilizing paid search and
display advertising to ensure the highest number of impressions at the highest efficiency.
Accordingly, we preliminarily recommend one million to two million impressions directed
specifically to the following markets: (1) Mexico, (2) Honduras, and (3) Guatemala.
VI.
SUMMARY OF NOTICE PLAN
The potential Plan thus includes: (1) direct, individual notice by first-class mail where possible,
with procedures for verifying addresses and resending undeliverable notices; (2) radio spots; (3)
newspaper placements; (4) online paid search words; (5) online website banner and social media
displays; and (6) public relations efforts. The Plan will focus on Maricopa County and the
greater Phoenix area with regional targeting beyond to surrounding states and international
targeting to three select countries.
VII.
ESTIMATED COSTS
We will prepare an estimate of direct notice costs once the quality, quantity, and type of Potential
Claimant data becomes known. While the actual costs will be determined by the notice elements
chosen by the Parties and media costs applicable at that time, we can estimate the possible costs
of otherwise implementing the Plan described above as follows:
1.
2.
3.
4.
Estimated Costs for Notice Plan (Exclusive of Direct Notice Campaign)

Item
Estimated Cost
Radio Campaign (30 days)
$120,000
Newspaper (1 ad per paper)
$16,665
Digital: Paid Search (30 days)
$3,500
Digital: Banner Ad Display (30 days)
$17,500
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Estimated Costs for Notice Plan (Exclusive of Direct Notice Campaign)

Item
Estimated Cost
$10,000
5. Digital: Facebook Ad Display (30 days)
$20,000
6. Digital: International Markets
$21,600
7. Public Relations
Variable
8. Translation
Variable
9. Interview Opportunities & Travel
$3,000
10. Flyer Creation and Printing
11. TOTAL
$ 212,265+
12

Melendres # 1696 P Memo Re Notice Costs

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

Cecillia D. Wang (Pro Hac Vice)

*Application for admission pro hac vice forthcoming

Attorneys for Plaintiffs (Additional attorneys

IN THE UNITED STATES DISTRICT COURT

Manuel de Jesus Ortega Melendres,

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

Additional Attorneys for Plaintiffs:

Anne Lai (Pro Hac Vice)

Stanley Young (Pro Hac Vice)

Jorge M. Castillo (Pro Hac Vice)

Mexican American Legal Defense and

*Application for admission pro hac vice

Case 2:07-cv-02513-GMS Document 1696 Filed 06/01/16 Page 3 of 6

THE BUDGET FOR BROWNGREERS NOTICE PLAN SHOULD BE $200,000

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

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

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

individuals who were detained.

Case 2:07-cv-02513-GMS Document 1696 Filed 06/01/16 Page 4 of 6

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

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

Defendants contemptuous detentions and serve as effective sources of information regarding

By: /s/ Lauren E. Pedley

Cecillia D. Wang (Pro Hac Vice)

Anne Lai (Pro Hac Vice)

Stanley Young (Pro Hac Vice)

Jorge M. Castillo (Pro Hac Vice)

James B. Chanin (Pro Hac Vice)

Case 2:07-cv-02513-GMS Document 1696 Filed 06/01/16 Page 5 of 6

Attorneys for Plaintiffs

*Applications for admission pro hac vice

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

mail as indicated on the Notice of Electronic Filing.

Dated this 1st day of June, 2016.

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

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 3 of 15

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

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

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

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

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

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 4 of 15

A. Target Audience Overview.

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 5 of 15

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 6 of 15

2-11 12-17 18-34 35-64 65+

Hispanic market rank in the US: #9

AVAILABLE POTENTIAL CLAIMANT DATA

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 7 of 15

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 8 of 15

Services (USPS) National Change of Address (NCOA)1 database prior to mailing, to

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 9 of 15

Listened to Visited Spotify

B. Preliminary Media Recommendation.

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

Case 2:07-cv-02513-GMS Document 1696-1 Filed 06/01/16 Page 10 of 15