UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
__________________________________________
)
CLAIRE BROU, et al.,				)
                                          )
                        Plaintiffs,		)	Case No.:  060838
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 FEMAs 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 FEMAs 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 FEMAs 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.accessboard.gov/ufas/ufashtml/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 classwide 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 159164 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) FEMAs 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 Members 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 Members 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 Members accessibility needs;
      (2) whether the Class Members need for temporary housing that is accessible can be accommodated by providing rental assistance;
      (3) whether the Class Members 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 Members 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 nonaccessible housing. 
      C.	Information to be provided by FEMA Intake Personnel to Class Members: FEMAs 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 Members accessibility needs.  The information described in this paragraph shall be given to the Class Member orally within five calendar days of the Class Members 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 Members accessibility needs, FEMAs Intake Personnel shall provide the Class Member with an estimated completion date which shall be:
(a)	within 30 days after the Class Member contacts FEMAs 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 FEMAs 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 Members need for temporary housing that is accessible can be accommodated by providing rental assistance, FEMAs 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 Members 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, FEMAs 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 Members accessibility needs, FEMAs 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, FEMAs 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.  FEMAs 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 FEMAs Intake Personnel depending upon whether a Unit that meets the Class Members 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, FEMAs Intake Personnel shall notify the Class Member of FEMAs determination, and advise the Class Member of any alternative temporary housing available that satisfies the Class Members 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 FEMAs Intake Personnel:  FEMAs 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) FEMAs 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 Members 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 FEMAs 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 Members 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 Courts 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 FEMAs 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 Plaintiffs 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 FEMAs 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 FEMAs contracting officer, the Ombudsperson shall be authorized to provide direction to FEMAs 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 Members 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) FEMAs 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 Members 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 30day 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.	Attorneys 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.	NonAdmission 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 Classs 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 Agreements terms have been met and, upon the filing of such report, the Courts 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) 2377380 
Facsimile:   (337) 2370486	
Email:  nhahn@advocacyla.org
Attorneys for Plaintiffs


_____________________________	
CARY LACHEEN
National Center for Law and Economic Justice
275 Seventh Avenue, Suite 1506
New York, NY 100016708
Telephone: (212) 6336967
Facsimile: (212) 6336371
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) 5144775
Facsimile:  (202) 6168470
Email: 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 dont 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 FEMAs 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 linethis 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: PSAs
(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 longterm 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 (rollin) 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 Cutout 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 (rollin) 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 Cutout 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 rollin shower
      o Wheelchair accessible, with rollin 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.:  060838
v.						)
                                          )	JUDGE DUVAL
FEDERAL EMERGENCY MANAGEMENT	)
AGENCY, et al.,					)	MAGISTRATE JUDGE
      )	KNOWLES
Defendants.		)
__________________________________________)
FINAL JUDGMENT APPROVING SETTLEMENT AGREEMENT
      Following this Courts 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.:  060838
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 counsels 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) 2377380 
Facsimile:   (337) 2370486	
Email:  nhahn@advocacyla.org

Attorney for Plaintiffs


_____________________________	
CARY LACHEEN
National Center for Law and Economic Justice
275 Seventh Avenue, Suite 1506
New York, NY 100016708
Tel: (212) 6336967
Fax: (212) 6336371
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) 5144775
Facsimile:  (202) 6168470
Email: Diane.Kelleher@usdoj.gov

Attorneys for Defendants

Dated:                                                           


	UNITED STATES DISTRICT COURT
	EASTERN DISTRICT OF LOUISIANA
__________________________________________
)
CLAIRE BROU, et al.,				)
                                          )
                        Plaintiffs,		)	Case No.:  060838
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:                                                          

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