Exhibit B

Pollard Order

Case: 19-30088 Doc# 2642-2 Filed: 06/19/19 Entered: 06/19/19 14:39:00 Page 1

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IN THE UNITED STATES DISTRICT COURT FOR THE 

WESTERN DISTRICT OF MISSOURI 

WESTERN DIVISION 

IAN POLLARD, on behalf of himself ) 

and all others similarly situated, ) 

) 

Plaintiffs, ) 

) 

v. ) Case No. 4:13-CV-00086-ODS 

) 

REMINGTON ARMS COMPANY, LLC, et al. ) 

) 

Defendants. ) 

ORDER 

In April 2015, the Court granted preliminary approval of the settlement of this 

class action. Doc. #88. Prior to a scheduled hearing for final approval of the 

settlement, the Court issued an Order deferring consideration of the parties’ joint motion 

for settlement approval and cancelling the hearing. Doc. #127. The Court directed the 

parties to develop a new notice plan that would result in a more significant response 

rate. Id. The Court also asked the parties to address issues raised by objectors. Id.

On June 10, 2016, the parties filed their Joint Supplement Brief Pursuant to the 

Court’s Order of December 8, 2015 (“Joint Supplemental Brief”). Doc. #138. On 

August 2, 2016, the Court held a hearing where the parties presented evidence and 

arguments. Doc. #136. The Court has carefully reviewed and considered the notice 

proposal set forth in the Joint Supplemental Brief, the Parties’ Fourth Amended 

Settlement Agreement (“Agreement”) (Doc. #138), and the evidence and arguments 

presented during the hearing held earlier this month. The Court finds as follows: 

1. Except as otherwise noted herein, the Court incorporates by reference, as

if fully stated herein, its findings and determinations set forth in its Amended Order 

Preliminarily Approving Class Action Settlement (Doc. #88). 

2. The definitions set forth in the Agreement are incorporated by reference

into this Order. 

3. The parties have executed the Agreement in order to settle and resolve

this Action, subject to Court approval. 

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4. The Parties have developed an additional notice proposal (“Plan”) that will

remind Settlement Class Members of the Settlement and complement the original notice 

plan previously approved by the Court. 

5. The Plan consists of four components: (1) social media campaign, (2)

national radio campaign, (3) e-mail and direct mail notification, and (4) poster 

notification. The Plan is detailed in the Joint Supplemental Brief and was discussed at 

the hearing earlier this month. 

6. The Court expressly reserves its decision with regard to the adequacy and

reasonableness of the Plan. 

7. The Court hereby adopts and orders the parties to implement the Plan as

follows: 

a. First, using its proprietary hunter-sportsman consumer models and

data analytics, Signal Interactive Media, LLC developed and tested a Facebook 

advertising campaign that targeted consumers could click and be redirected to 

the Settlement Website to file a claim. The social media campaign is intended to 

reach 3.4 million potential class members. Signal Interactive Media shall 

administer the social media campaign pursuant to the Joint Supplemental Brief 

(Doc. #127-1) for four consecutive weeks, commencing within four weeks of the 

date of this Order. 

b. Second, the Parties developed a targeted, national radio media

campaign that will generate more than 61 million targeted impressions. The 

proposed radio campaign consists of running a 60-second notice for four 

consecutive weeks during peak morning and evening drive times on the country’s 

top syndicated networks and programs, which consists of more than 2,000 

stations across the country. In addition to the terrestrial radio notice, the 

proposed radio campaign consists of custom digital streaming through iHeart 

radio, the largest national radio group with the largest streaming radio stations 

nationwide. The online digital streaming includes a companion banner for class 

members to click that will redirect them to the Settlement Website. The script 

(Doc. #127-1, ¶ 58) is approved, and Signal Interactive Media shall administer 

the radio media campaign pursuant to the Joint Supplemental Brief (Doc. #127-1) 

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for four consecutive weeks, commencing within four weeks of the date of this 

Order. 

c. Third, Remington will send an e-mail notification of the Settlement 

to approximately one million individuals whose e-mail addresses have been 

culled from its internal databases. The e-mail shall contain a link to the Claim 

Form found on the Settlement Website. Additionally, Remington will send 

postcard notifications to approximately 93,000 individuals for whom it has a 

mailing address but no e-mail address. The content of these messages is 

approved in the format submitted at Doc. #138-6. 

d. Fourth, Remington will create and disseminate information posters 

for display at more than 11,000 retail locations. The posters will be disseminated 

in the same manner in which Remington disseminates recall notices. The retail 

locations will be instructed that, although the poster is not a recall notice, it 

should be printed in color and displayed in the same manner as a recall notice. 

The poster is approved in the format submitted at Doc. #138-6. 

8. In addition to the foregoing, at the time of the hearing, the Court inquired 

about and the Parties have agreed to implement the following changes or additions: 

a. The language, including checking of the box, on the notice forms 

requiring the claimant to indicate that the claimant has read and acknowledged 

the warning shall be removed. The new claim forms are approved in the format 

submitted at Doc. #138-1. 

b. The claim forms found on the Settlement website shall be placed in 

the following order: (1) Models 700 and Seven; (2) Models 700 and Seven 

(containing an X-Mark Pro Trigger manufactured from May 1, 2006 to April 9, 

2014 Not Previously Remedied); (3) Sportsman 78 and Model 673 Firearms; (4) 

Models 710, 715, and 770; (5) Models 721, 722, and 725; and (6) Models 600, 

660, and XP-100. 

c. Remington shall resend an additional direct mailing in the form 

submitted at Doc. #138-6 to the Settlement Class Members who previously 

received direct mail. Because the model number and appropriate claim form for 

these individuals is known (all will need the Model 700 and Seven form 

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containing the rebate section), Remington will also include a copy of the claim 

form with the reminder notice. 

9. Any member of the settlement clauses desiring exclusion shall mail a 

Request for Exclusion to the Class Action Settlement Administrator, Angeion Group. To 

be valid, the Request for Exclusion must be in writing, must state the person wants to 

be excluded, and must be received on or before November 18, 2016. The Class Action 

Settlement Administrator shall promptly forward copies of Requests for Exclusion to 

Class Counsel and Defendants’ Counsel. 

10. A list reflecting all Requests for Exclusion shall be filed with the Court by 

the Class Action Settlement Administrator no later than 28 days before the Final 

Approval Hearing. Any member of the settlement classes who does not properly and 

timely request exclusion shall be included in the Settlement and bound by any judgment 

entered in this action with respect to the settlement classes. 

11. The Class Action Settlement Administrator shall file with the Court the 

details outlining the scope, method, and results of the Plan no later than 28 days before 

the Final Approval Hearing. 

12. The parties shall file any motion for final settlement approval on or before 

January 17, 2017. Plaintiffs shall file any motion seeking approval of attorneys’ fees 

and representative plaintiff awards on or before January 17, 2017. 

13. The Court will hold a Final Approval Hearing on February 14, 2017, at 

1:00 p.m., in Courtroom 8C of the Charles Evans Whittaker Courthouse in Kansas City, 

Missouri. At the Final Approval Hearing, the Court will consider: (a) the fairness, 

reasonableness, and adequacy of the settlement; (b) the entry of any final order or 

judgment in this lawsuit with respect to the settlement classes; (c) the application for 

representative plaintiff awards; (d) the application for attorneys’ fees; and (e) other 

related matters. The Final Approval Hearing may be postponed, adjourned, or 

continued by Order of the Court without further notice to the settlement classes. 

14. To be considered at the Final Approval Hearing, any settlement class 

member desiring to file an objection or other comment on the settlement shall be 

required to file such objections and comments and all supporting pleadings on or before 

November 18, 2016, via certified or first class mail to the Court and the Class Action 

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Settlement Administrator. The objection must bear the signature of the settlement class 

member (even if represented by counsel), the settlement class member’s current 

address and telephone number, the firearm model and serial number, and state the 

exact nature of the objection, including any legal support the settlement class member 

wishes to introduce in support of the objection, regardless of whether the settlement 

class member intends to appear at the Final Approval Hearing. If the settlement class 

member is represented by counsel, the objection shall also be signed by his or her 

attorney and state whether the attorney representing the objector will appear at the 

Final Approval Hearing. 

15. Unless otherwise ordered by the Court, no objection to or other comment 

concerning the Settlement shall be heard unless timely filed in accordance with these 

guidelines. 

16. Any settlement class member who does not make his or her objection in 

the manner provided in this Order shall be deemed to have waived any such objection 

and shall forever be barred from making any objection to the Settlement, including, 

without limitation, the propriety of class certification, adequacy of notice, or the fairness, 

adequacy, or reasonableness of the Settlement. 

17. Any attorney hired by a settlement class member for the purpose of 

appearing and/or making an objection shall file an entry of appearance no later than five 

days after the objection has been filed, with service on Class Counsel and Defendants’ 

Counsel per the Federal Rules of Civil Procedure. 

18. Any settlement class member may appear at the Final Approval Hearing in 

person, or by counsel if an appearance is filed and served as provided in the Notice 

Plan, and such person will be heard to the extent allowed by the Court. No settlement 

class member shall be permitted to be heard unless he or she complies with the 

provisions stated herein. 

IT IS SO ORDERED. 

/s/ Ortrie D. Smith 

ORTRIE D. SMITH, SENIOR JUDGE 

DATE: August 23, 2016 UNITED STATES DISTRICT COURT 

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