Exhibit A

Jeanne C. Finegan

Curriculum Vitae

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JEANNE C. FINEGAN, APR

BIOGRAPHY

Jeanne Finegan, APR, is President and Chief Media Officer of HF Media, 

LLC, a division of Heffler Claims Group. She is a member of the Board of 

Directors for the prestigious Alliance for Audited Media (AAM), and was 

named by Diversity Journal as one of the “Top 100 Women Worth 

Watching.” She is a distinguished legal notice and communications expert

with more than 30 years of communications and advertising experience. 

She was a lead contributing author for Duke University's School of Law, 

"Guidelines and Best Practices Implementing Amendments to Rule 23 Class Action Settlement 

Provisions." And more recently, she has been involved with New York School of Law and The 

Center on Civil Justice (CCJ) assisting with a class action settlement data analysis and 

comparative visualization tool called the Aggregate Litigation Project, designed to help judges 

make decisions in aggregate cases on the basis of data as opposed to anecdotal information. 

Moreover, her experience also includes working with the Special Settlement Administrator’s 

team to assist with the outreach strategy for the historic Auto Airbag Settlement, In re: Takata 

Airbag Products Liability Litigation MDL 2599.

During her tenure, she has planned and implemented over 1,000 high-profile, complex legal 

notice communication programs. She is a recognized notice expert in both the United States 

and in Canada, with extensive international notice experience spanning more than 170 

countries and over 40 languages. 

Ms. Finegan has lectured, published and has been cited extensively on various aspects of legal 

noticing, product recall and crisis communications. She has served the Consumer Product 

Safety Commission (CPSC) as an expert to determine ways in which the Commission can 

increase the effectiveness of its product recall campaigns. Further, she has planned and 

implemented large-scale government enforcement notice programs for the Federal Trade 

Commission (FTC) and the Securities and Exchange Commission (SEC). 

Ms. Finegan is accredited in Public Relations (APR) by the Universal Accreditation Board, which 

is a program administered by the Public Relations Society of America (PRSA), and is also a 

recognized member of the Canadian Public Relations Society (CPRS). She has served on 

examination panels for APR candidates and worked pro bono as a judge for prestigious PRSA 

awards. 

Ms. Finegan has provided expert testimony before Congress on issues of notice, and expert 

testimony in both state and federal courts regarding notification campaigns. She has conducted 

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numerous media audits of proposed notice programs to assess the adequacy of those programs

under Fed R. Civ. P. 23(c)(2) and similar state class action statutes. 

She was an early pioneer of plain language in notice (as noted in a RAND study,1) and continues 

to set the standard for modern outreach as the first notice expert to integrate social media into 

court approved legal notice programs.

In the course of her class action experience, courts have recognized the merits of, and admitted 

expert testimony based on, her scientific evaluation of the effectiveness of notice plans. She 

has designed legal notices for a wide range of class actions and consumer matters that include 

product liability, construction defect, antitrust, medical/pharmaceutical, human rights, civil 

rights, telecommunication, media, environment, government enforcement actions, securities, 

banking, insurance, mass tort, restructuring and product recall. 

JUDICIAL COMMENTS AND LEGAL NOTICE CASES

In evaluating the adequacy and effectiveness of Ms. Finegan’s notice campaigns, courts 

have repeatedly recognized her excellent work. The following excerpts provide some examples 

of such judicial approval. 

Fitzhenry- Russell et al., v Keurig Dr. Pepper Inc., Case No. :17-cv-00564-NC, (ND Cal). In the 

Order Granting Final Approval of Class Action Settlement, Dated April 10, 2019, the Honorable 

Nathanael Cousins stated:

“...the reaction of class members to the proposed Settlement is positive. The parties 

anticipated that 100,000 claims would be filed under the Settlement (see Dkt. No. 327-

5 ¶ 36)—91,254 claims were actually filed (see Finegan Decl ¶ 4). The 4% claim rate 

was reasonable in light of Heffler’s efforts to ensure that notice was adequately 

provided to the Class.”

Pettit et al., v. Procter & Gamble Co., Case No. 15-cv-02150-RS ND Cal. In the Order Granting 

Final Approval of the Class Action Settlement and Judgement, Dated March 28, 2019, p. 6, the 

Honorable Richard Seeborg stated: 

“The Court finds that the Notice Plan set forth in the Settlement Agreement, and 

effectuated pursuant to the Preliminary Approval Order, constituted the best notice 

practicable under the circumstances and constituted due and sufficient notice to the 

Settlement Class. ...the number of claims received equates to a claims rate of 4.6%, 

which exceeds the rate in comparable settlements.”

 1 Deborah R. Hensler et al., CLASS ACTION DILEMAS, PURSUING PUBLIC GOALS FOR PRIVATE GAIN. RAND (2000).

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Carter v Forjas Taurus S.S., Taurus International Manufacturing, Inc., Case No. 1:13-CV-24583 

PAS (S.D. Fl. 2016). In her Final Order and Judgment Granting Plaintiffs Motion for Final 

Approval of Class Action Settlement, the Honorable Patricia Seitz stated: 

“The Court considered the extensive experience of Jeanne C. Finegan and the notice 

program she developed. ...There is no national firearms registry and Taurus sale 

records do not provide names and addresses of the ultimate purchasers... Thus the 

form and method used for notifying Class Members of the terms of the Settlement was 

the best notice practicable. ...The court-approved notice plan used peer-accepted 

national research to identify the optimal traditional, online, mobile and social media 

platforms to reach the Settlement Class Members.”

Additionally, in January 20, 2016, Transcript of Class Notice Hearing, p. 5 Judge Seitz, 

noted: 

“I would like to compliment Ms. Finegan and her company because I was quite 

impressed with the scope and the effort of communicating with the Class.”

Cook et. al v. Rockwell International Corp. and the Dow Chemical Co., No. 90-cv-00181- KLK 

(D.Colo. 2017)., aka, Rocky Flats Nuclear Weapons Plant Contamination. In the Order Granting 

Final Approval, dated April 28, 2017, p.3, the Honorable John L. Kane said:

The Court-approved Notice Plan, which was successfully implemented by 

[HF Media- emphasis added] (see Doc. 2432), constituted the best notice practicable 

under the circumstances. In making this determination, the Court finds that the Notice 

Plan that was implemented, as set forth in Declaration of Jeanne C. Finegan, APR 

Concerning Implementation and Adequacy of Class Member Notification (Doc. 2432), 

provided for individual notice to all members of the Class whose identities and 

addresses were identified through reasonable efforts, ... and a comprehensive national 

publication notice program that included, inter alia, print, television, radio and 

internet banner advertisements. ...Pursuant to, and in accordance with, Rule 23 of the 

Federal Rules of Civil Procedure, the Court finds that the Notice Plan provided the best 

notice practicable to the Class.

In re: Domestic Drywall Antitrust Litigation, MDL. No. 2437, in the U.S. District Court for the 

Eastern District of Pennsylvania. For each of the four settlements, Finegan implemented and 

extensive outreach effort including traditional, online, social, mobile and advanced television 

and online video. In the Order Granting Preliminary Approval to the IPP Settlement, Judge 

Michael M. Baylson stated: 

“The Court finds that the dissemination of the Notice and summary Notice constitutes 

the best notice practicable under the circumstances; is valid, due, and sufficient notice 

to all persons... and complies fully with the requirements of the Federal rule of Civil 

Procedure.”

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Warner v. Toyota Motor Sales, U.S.A. Inc., Case No 2:15-cv-02171-FMO FFMx (C.D. Cal. 2017).

In the Order Re: Final Approval of Class Action Settlement; Approval of Attorney’s Fees, Costs & 

Service Awards, dated May 21, 2017, the Honorable Fernando M. Olguin stated:

Finegan, the court-appointed settlement notice administrator, has implemented the 

multiprong notice program. ...the court finds that the class notice and the notice 

process fairly and adequately informed the class members of the nature of the action, 

the terms of the proposed settlement, the effect of the action and release of claims, 

the class members’ right to exclude themselves from the action, and their right to 

object to the proposed settlement. (See Dkt. 98, PAO at 25-28).

Michael Allagas, et al., v. BP Solar International, Inc., et al., BP Solar Panel Settlement, Case 

No. 3:14-cv-00560- SI (N.D. Cal., San Francisco Div. 2016). In the Order Granting Final Approval, 

Dated December 22, 2016, The Honorable Susan Illston stated:

Class Notice was reasonable and constituted due, adequate and sufficient notice to all 

persons entitled to be provided with notice; and d. fully satisfied the requirements of 

the Federal Rules of Civil Procedure, including Fed. R. Civ. P. 23(c)(2) and (e), the 

United States Constitution (including the Due Process Clause), the Rules of this Court, 

and any other applicable law.

Foster v. L-3 Communications EOTech, Inc. et al (6:15-cv-03519), Missouri Western District 

Court.

In the Court’s Final Order, dated July 7, 2017, The Honorable Judge Brian Wimes 

stated: “The Court has determined that the Notice given to the Settlement Class fully 

and accurately informed members of the Settlement Class of all material elements of 

the Settlement and constituted the best notice practicable.”

In re: Skechers Toning Shoes Products Liability Litigation, No. 3:11-MD-2308-TBR (W.D. Ky.

2012). In his Final Order and Judgment granting the Motion for Preliminary Approval of 

Settlement, the Honorable Thomas B. Russell stated: 

... The comprehensive nature of the class notice leaves little doubt that, upon receipt, 

class members will be able to make an informed and intelligent decision about 

participating in the settlement.

Brody v. Merck & Co., Inc., et al, No. 3:12-cv-04774-PGS-DEA (N.J.) (Jt Hearing for Prelim App, 

Sept. 27, 2012, transcript page 34). During the Hearing on Joint Application for Preliminary 

Approval of Class Action, the Honorable Peter G. Sheridan acknowledged Ms. Finegan’s work, 

noting: 

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Ms. Finegan did a great job in testifying as to what the class administrator will do. So, 

I'm certain that all the class members or as many that can be found, will be given 

some very adequate notice in which they can perfect their claim.

Quinn v. Walgreen Co., Wal-Mart Stores Inc., 7:12 CV-8187-VB (NYSD) (Jt Hearing for Final

App, March. 5, 2015, transcript page 40-41). During the Hearing on Final Approval of Class 

Action, the Honorable Vincent L. Briccetti stated: 

"The notice plan was the best practicable under the circumstances. ... [and] “the proof 

is in the pudding. This settlement has resulted in more than 45,000 claims which is 

10,000 more than the Pearson case and more than 40,000 more than in a glucosamine 

case pending in the Southern District of California I've been advised about. So the 

notice has reached a lot of people and a lot of people have made claims.”

In Re: TracFone Unlimited Service Plan Litigation, No. C-13-3440 EMC (ND Ca). In the Final 

Order and Judgment Granting Class Settlement, July 2, 2015, the Honorable Edward M. Chen 

noted: 

“...[D]epending on the extent of the overlap between those class members who will 

automatically receive a payment and those who filed claims, the total claims rate is 

estimated to be approximately 25-30%. This is an excellent result...

In Re: Blue Buffalo Company, Ltd., Marketing and Sales Practices Litigation, Case No. 4:14-

MD-2562 RWS (E.D. Mo. 2015), (Hearing for Final Approval, May 19, 2016 transcript p. 49). 

During the Hearing for Final Approval, the Honorable Rodney Sippel said: 

It is my finding that notice was sufficiently provided to class members in the manner 

directed in my preliminary approval order and that notice met all applicable 

requirements of due process and any other applicable law and considerations.

DeHoyos, et al. v. Allstate Ins. Co., No. SA-01-CA-1010 (W.D.Tx. 2001). In the Amended Final 

Order and Judgment Approving Class Action Settlement, the Honorable Fred Biery stated:

[T]he undisputed evidence shows the notice program in this case was developed and 

implemented by a nationally recognized expert in class action notice programs. ... This 

program was vigorous and specifically structured to reach the African-American and 

Hispanic class members. Additionally, the program was based on a scientific 

methodology which is used throughout the advertising industry and which has been 

routinely embraced routinely [sic] by the Courts. Specifically, in order to reach the 

identified targets directly and efficiently, the notice program utilized a multi-layered 

approach which included national magazines; magazines specifically appropriate to 

the targeted audiences; and newspapers in both English and Spanish.

In re: Reebok Easytone Litigation, No. 10-CV-11977 (D. MA. 2011). The Honorable F. Dennis 

Saylor IV stated in the Final Approval Order:

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The Court finds that the dissemination of the Class Notice, the publication of the 

Summary Settlement Notice, the establishment of a website containing settlementrelated materials, the establishment of a toll-free telephone number, and all other 

notice methods set forth in the Settlement Agreement and [Ms. Finegan’s] Declaration 

and the notice dissemination methodology implemented pursuant to the Settlement 

Agreement and this Court’s Preliminary Approval Order... constituted the best 

practicable notice to Class Members under the circumstances of the Actions.

Bezdek v. Vibram USA and Vibram FiveFingers LLC, No 12-10513 (D. MA) The Honorable 

Douglas P. Woodlock stated in the Final Memorandum and Order:

...[O]n independent review I find that the notice program was robust, particularly in its 

online presence, and implemented as directed in my Order authorizing notice. ...I find 

that notice was given to the Settlement class members by the best means “practicable 

under the circumstances.” Fed.R.Civ.P. 23(c)(2).

Gemelas v. The Dannon Company Inc., No. 08-cv-00236-DAP (N.D. Ohio). In granting final 

approval for the settlement, the Honorable Dan A. Polster stated:

In accordance with the Court's Preliminary Approval Order and the Court-approved 

notice program, [Ms. Finegan] caused the Class Notice to be distributed on a 

nationwide basis in magazines and newspapers (with circulation numbers exceeding 

81 million) specifically chosen to reach Class Members. ... The distribution of Class 

Notice constituted the best notice practicable under the circumstances, and fully 

satisfied the requirements of Federal Rule of Civil Procedure 23, the requirements of 

due process, 28 U.S.C. 1715, and any other applicable law.

Pashmova v. New Balance Athletic Shoes, Inc., 1:11-cv-10001-LTS (D. Mass.). The Honorable 

Leo T. Sorokin stated in the Final Approval Order:

The Class Notice, the Summary Settlement Notice, the web site, and all other notices in 

the Settlement Agreement and the Declaration of [Ms Finegan], and the notice 

methodology implemented pursuant to the Settlement Agreement: (a) constituted the 

best practicable notice under the circumstances; (b) constituted notice that was 

reasonably calculated to apprise Class Members of the pendency of the Actions, the 

terms of the Settlement and their rights under the settlement ... met all applicable 

requirements of law, including, but not limited to, the Federal Rules of Civil Procedure, 

28 U.S.C. § 1715, and the Due Process Clause(s) of the United States Constitution, as 

well as complied with the Federal Judicial Center’s illustrative class action notices.

Hartless v. Clorox Company, No. 06-CV-2705 (CAB) (S.D.Cal.). In the Final Order Approving 

Settlement, the Honorable Cathy N. Bencivengo found:

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The Class Notice advised Class members of the terms of the settlement; the Final 

Approval Hearing and their right to appear at such hearing; their rights to remain in or 

opt out of the Class and to object to the settlement; the procedures for exercising such 

rights; and the binding effect of this Judgment, whether favorable or unfavorable, to 

the Class. The distribution of the notice to the Class constituted the best notice 

practicable under the circumstances, and fully satisfied the requirements of Federal 

Rule of Civil Procedure 23, the requirements of due process, 28 U.S.C. §1715, and any 

other applicable law.

McDonough et al v. Toys 'R' Us et al, No. 09:-cv-06151-AB (E.D. Pa.). In the Final Order and 

Judgment Approving Settlement, the Honorable Anita Brody stated:

The Court finds that the Notice provided constituted the best notice practicable under 

the circumstances and constituted valid, due and sufficient notice to all persons 

entitled thereto.

In re: Pre-Filled Propane Tank Marketing & Sales Practices Litigation, No. 4:09-md-02086-GAF 

(W.D. Mo.) In granting final approval to the settlement, the Honorable Gary A. Fenner stated:

The notice program included individual notice to class members who could be 

identified by Ferrellgas, publication notices, and notices affixed to Blue Rhino propane 

tank cylinders sold by Ferrellgas through various retailers. ... The Court finds the notice 

program fully complied with Federal Rule of Civil Procedure 23 and the requirements 

of due process and provided to the Class the best notice practicable under the 

circumstances.

Stern v. AT&T Mobility Wireless, No. 09-cv-1112 CAS-AGR (C.D.Cal. 2009). In the Final Approval 

Order, the Honorable Christina A. Snyder stated:

[T]he Court finds that the Parties have fully and adequately effectuated the Notice 

Plan, as required by the Preliminary Approval Order, and, in fact, have achieved better 

results than anticipated or required by the Preliminary Approval Order.

In re: Processed Egg Prods. Antitrust Litig., MDL No. 08-md-02002 (E.D.P.A.). In the Order 

Granting Final Approval of Settlement, Judge Gene E.K. Pratter stated:

The Notice appropriately detailed the nature of the action, the Class claims, the 

definition of the Class and Subclasses, the terms of the proposed settlement 

agreement, and the class members’ right to object or request exclusion from the 

settlement and the timing and manner for doing so.... Accordingly, the Court 

determines that the notice provided to the putative Class Members constitutes 

adequate notice in satisfaction of the demands of Rule 23.

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In re Polyurethane Foam Antitrust Litigation, 10- MD-2196 (N.D. OH). In the Order Granting

Final Approval of Voluntary Dismissal and Settlement of Defendant Domfoam and Others, the 

Honorable Jack Zouhary stated: 

The notice program included individual notice to members of the Class who could be 

identified through reasonable effort, as well as extensive publication of a summary 

notice. The Notice constituted the most effective and best notice practicable under the 

circumstances of the Settlement Agreements, and constituted due and sufficient notice 

for all other purposes to all persons and entities entitled to receive notice.

Rojas v Career Education Corporation, No. 10-cv-05260 (N.D.E.D. IL) In the Final Approval Order 

dated October 25, 2012, the Honorable Virgina M. Kendall stated:

The Court Approved notice to the Settlement Class as the best notice practicable under 

the circumstance including individual notice via U.S. Mail and by email to the class 

members whose addresses were obtained from each Class Member’s wireless carrier 

or from a commercially reasonable reverse cell phone number look-up service, 

nationwide magazine publication, website publication, targeted on-line advertising, 

and a press release. Notice has been successfully implemented and satisfies the 

requirements of the Federal Rule of Civil Procedure 23 and Due Process.

Golloher v Todd Christopher International, Inc. DBA Vogue International (Organix), No. C 

1206002 N.D CA. In the Final Order and Judgment Approving Settlement, the Honorable 

Richard Seeborg stated:

The distribution of the notice to the Class constituted the best notice practicable 

under the circumstances, and fully satisfied the requirements of Federal Rule of Civil 

Procedure 23, the requirements of due process, 28 U.S.C. §1715, and any other 

applicable law.

Stefanyshyn v. Consolidated Industries, No. 79 D 01-9712-CT-59 (Tippecanoe County Sup. Ct., 

Ind.). In the Order Granting Final Approval of Settlement, Judge Randy Williams stated:

The long and short form notices provided a neutral, informative, and clear explanation 

of the Settlement. ... The proposed notice program was properly designed, 

recommended, and implemented ... and constitutes the “best practicable” notice of 

the proposed Settlement. The form and content of the notice program satisfied all 

applicable legal requirements. ... The comprehensive class notice educated Settlement 

Class members about the defects in Consolidated furnaces and warned them that the 

continued use of their furnaces created a risk of fire and/or carbon monoxide. This 

alone provided substantial value.

McGee v. Continental Tire North America, Inc. et al, No. 06-6234-(GEB) (D.N.J.). 

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The Class Notice, the Summary Settlement Notice, the web site, the toll-free telephone 

number, and all other notices in the Agreement, and the notice methodology 

implemented pursuant to the Agreement: (a) constituted the best practicable notice 

under the circumstances; (b) constituted notice that was reasonably calculated to 

apprise Class Members of the pendency of the Action, the terms of the settlement and 

their rights under the settlement, including, but not limited to, their right to object to 

or exclude themselves from the proposed settlement and to appear at the Fairness 

Hearing; (c) were reasonable and constituted due, adequate and sufficient notice to all 

persons entitled to receive notification; and (d) met all applicable requirements of law, 

including, but not limited to, the Federal Rules of Civil Procedure, 20 U.S.C. Sec. 1715, 

and the Due Process Clause(s) of the United States Constitution, as well as complied 

with the Federal Judicial Center’s illustrative class action notices,

Varacallo, et al. v. Massachusetts Mutual Life Insurance Company, et al., No. 04-2702 (JLL) 

(D.N.J.). The Court stated that:

[A]ll of the notices are written in simple terminology, are readily understandable by 

Class Members, and comply with the Federal Judicial Center's illustrative class action 

notices. ... By working with a nationally syndicated media research firm, [Finegan’s 

firm] was able to define a target audience for the MassMutual Class Members, which 

provided a valid basis for determining the magazine and newspaper preferences of the 

Class Members. (Preliminary Approval Order at p. 9). . . . The Court agrees with Class 

Counsel that this was more than adequate. (Id. at § 5.2).

In re: Nortel Network Corp., Sec. Litig., No. 01-CV-1855 (RMB) Master File No. 05 MD 1659 

(LAP) (S.D.N.Y.). Ms. Finegan designed and implemented the extensive United States and 

Canadian notice programs in this case. The Canadian program was published in both French 

and English, and targeted virtually all investors of stock in Canada. See 

www.nortelsecuritieslitigation.com. Of the U.S. notice program, the Honorable Loretta A. 

Preska stated: 

The form and method of notifying the U.S. Global Class of the pendency of the action 

as a class action and of the terms and conditions of the proposed Settlement ... 

constituted the best notice practicable under the circumstances, and constituted due 

and sufficient notice to all persons and entities entitled thereto.

Regarding the B.C. Canadian Notice effort: Jeffrey v. Nortel Networks, [2007] BCSC 69 at para. 

50, the Honourable Mr. Justice Groberman said: 

The efforts to give notice to potential class members in this case have been thorough. 

There has been a broad media campaign to publicize the proposed settlement and the 

court processes. There has also been a direct mail campaign directed at probable 

investors. I am advised that over 1.2 million claim packages were mailed to persons 

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around the world. In addition, packages have been available through the worldwide 

web site nortelsecuritieslitigation.com on the Internet. Toll-free telephone lines have 

been set up, and it appears that class counsel and the Claims Administrator have 

received innumerable calls from potential class members. In short, all reasonable 

efforts have been made to ensure that potential members of the class have had notice 

of the proposal and a reasonable opportunity was provided for class members to 

register their objections, or seek exclusion from the settlement.

Mayo v. Walmart Stores and Sam’s Club, No. 5:06 CV-93-R (W.D.Ky.). In the Order Granting 

Final Approval of Settlement, Judge Thomas B. Russell stated:

According to defendants’ database, the Notice was estimated to have reached over 

90% of the Settlement Class Members through direct mail. The Settlement 

Administrator ... has classified the parties’ database as ‘one of the most reliable and 

comprehensive databases [she] has worked with for the purposes of legal notice.’... 

The Court thus reaffirms its findings and conclusions in the Preliminary Approval Order 

that the form of the Notice and manner of giving notice satisfy the requirements of 

Fed. R. Civ. P. 23 and affords due process to the Settlement Class Members.

Fishbein v. All Market Inc., (d/b/a Vita Coco) No. 11-cv-05580 (S.D.N.Y.). In granting final 

approval of the settlement, the Honorable J. Paul Oetken stated:

"The Court finds that the dissemination of Class Notice pursuant to the Notice 

Program...constituted the best practicable notice to Settlement Class Members under 

the circumstances of this Litigation ... and was reasonable and constituted due, 

adequate and sufficient notice to all persons entitled to such notice, and fully satisfied 

the requirements of the Federal Rules of Civil Procedure, including Rules 23(c)(2) and 

(e), the United States Constitution (including the Due Process Clause), the Rules of this 

Court, and any other applicable laws."

Lucas, et al. v. Kmart Corp., No. 99-cv-01923 (D.Colo.), wherein the Court recognized Jeanne 

Finegan as an expert in the design of notice programs, and stated: 

The Court finds that the efforts of the parties and the proposed Claims Administrator 

in this respect go above and beyond the "reasonable efforts" required for identifying 

individual class members under F.R.C.P. 23(c)(2)(B).

In re: Johns-Manville Corp. (Statutory Direct Action Settlement, Common Law Direct Action 

and Hawaii Settlement), No 82-11656, 57, 660, 661, 665-73, 75 and 76 (BRL) (Bankr. S.D.N.Y.). 

The nearly half-billion dollar settlement incorporated three separate notification programs, 

which targeted all persons who had asbestos claims whether asserted or unasserted, against 

the Travelers Indemnity Company. In the Findings of Fact and Conclusions of a Clarifying Order 

Approving the Settlements, slip op. at 47-48 (Aug. 17, 2004), the Honorable Burton R. Lifland, 

Chief Justice, stated:

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As demonstrated by Findings of Fact (citation omitted), the Statutory Direct Action 

Settlement notice program was reasonably calculated under all circumstances to 

apprise the affected individuals of the proceedings and actions taken involving their 

interests, Mullane v. Cent. Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950), such 

program did apprise the overwhelming majority of potentially affected claimants and 

far exceeded the minimum notice required. . . . The results simply speak for 

themselves.

Pigford v. Glickman and U.S. Department of Agriculture, No. 97-1978. 98-1693 (PLF) (D.D.C.). 

This matter was the largest civil rights case to settle in the United States in over 40 years. The 

highly publicized, nationwide paid media program was designed to alert all present and past 

African-American farmers of the opportunity to recover monetary damages against the U.S. 

Department of Agriculture for alleged loan discrimination. In his Opinion, the Honorable Paul L. 

Friedman commended the parties with respect to the notice program, stating;

The parties also exerted extraordinary efforts to reach class members through a 

massive advertising campaign in general and African American targeted publications 

and television stations. . . . The Court concludes that class members have received 

more than adequate notice and have had sufficient opportunity to be heard on the 

fairness of the proposed Consent Decree. 

In re: Louisiana-Pacific Inner-Seal Siding Litig., Nos. 879-JE, and 1453-JE (D.Or.). Under the 

terms of the Settlement, three separate notice programs were to be implemented at three-year 

intervals over a period of six years. In the first notice campaign, Ms. Finegan implemented the 

print advertising and Internet components of the Notice program. In approving the legal notice 

communication plan, the Honorable Robert E. Jones stated:

The notice given to the members of the Class fully and accurately informed the Class 

members of all material elements of the settlement...[through] a broad and extensive 

multi-media notice campaign.

Additionally, with regard to the third-year notice program for Louisiana-Pacific, the Honorable 

Richard Unis, Special Master, commented that the notice was: 

...well formulated to conform to the definition set by the court as adequate and 

reasonable notice. Indeed, I believe the record should also reflect the Court's 

appreciation to Ms. Finegan for all the work she's done, ensuring that noticing was 

done correctly and professionally, while paying careful attention to overall costs. Her 

understanding of various notice requirements under Fed. R. Civ. P. 23, helped to insure 

that the notice given in this case was consistent with the highest standards of

compliance with Rule 23(d)(2).

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In re: Expedia Hotel Taxes and Fees Litigation, No. 05-2-02060-1 (SEA) (Sup. Ct. of Wash. in and 

for King County). In the Order Granting Final Approval of Class Action Settlement, Judge 

Monica Benton stated:

The Notice of the Settlement given to the Class ... was the best notice practicable 

under the circumstances. All of these forms of Notice directed Class Members to a 

Settlement Website providing key Settlement documents including instructions on how 

Class Members could exclude themselves from the Class, and how they could object to 

or comment upon the Settlement. The Notice provided due and adequate notice of 

these proceeding and of the matters set forth in the Agreement to all persons entitled 

to such notice, and said notice fully satisfied the requirements of CR 23 and due 

process.

Thomas A. Foster and Linda E. Foster v. ABTco Siding Litigation, No. 95-151-M (Cir. Ct., 

Choctaw County, Ala.). This litigation focused on past and present owners of structures sided 

with Abitibi-Price siding. The notice program that Ms. Finegan designed and implemented was 

national in scope and received the following praise from the Honorable J. Lee McPhearson: 

The Court finds that the Notice Program conducted by the Parties provided individual 

notice to all known Class Members and all Class Members who could be identified 

through reasonable efforts and constitutes the best notice practicable under the 

circumstances of this Action. This finding is based on the overwhelming evidence of 

the adequacy of the notice program. ... The media campaign involved broad national 

notice through television and print media, regional and local newspapers, and the 

Internet (see id. ¶¶9-11) The result: over 90 percent of Abitibi and ABTco owners are 

estimated to have been reached by the direct media and direct mail campaign.

Wilson v. Massachusetts Mut. Life Ins. Co., No. D-101-CV 98-02814 (First Judicial Dist. Ct., 

County of Santa Fe, N.M.). This was a nationwide notification program that included all persons 

in the United States who owned, or had owned, a life or disability insurance policy with 

Massachusetts Mutual Life Insurance Company and had paid additional charges when paying 

their premium on an installment basis. The class was estimated to exceed 1.6 million 

individuals. www.insuranceclassclaims.com. In granting preliminary approval to the settlement, 

the Honorable Art Encinias found:

[T]he Notice Plan [is] the best practicable notice that is reasonably calculated, under 

the circumstances of the action. ...[and] meets or exceeds all applicable requirements 

of the law, including Rule 1-023(C)(2) and (3) and 1-023(E), NMRA 2001, and the 

requirements of federal and/or state constitutional due process and any other 

applicable law.

Sparks v. AT&T Corp., No. 96-LM-983 (Third Judicial Cir., Madison County, Ill.). The litigation 

concerned all persons in the United States who leased certain AT&T telephones during the 

1980’s. Ms. Finegan designed and implemented a nationwide media program designed to 

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Jeanne C. Finegan, APR CV 13

target all persons who may have leased telephones during this time period, a class that 

included a large percentage of the entire population of the United States. 

In granting final approval to the settlement, the Court found:

The Court further finds that the notice of the proposed settlement was sufficient and 

furnished Class Members with the information they needed to evaluate whether to 

participate in or opt out of the proposed settlement. The Court therefore concludes 

that the notice of the proposed settlement met all requirements required by law, 

including all Constitutional requirements.

In re: Georgia-Pacific Toxic Explosion Litig., No. 98 CVC05-3535 (Ct. of Common Pleas, Franklin 

County, Ohio). Ms. Finegan designed and implemented a regional notice program that included 

network affiliate television, radio and newspaper. The notice was designed to alert adults living 

near a Georgia-Pacific plant that they had been exposed to an air-born toxic plume and their 

rights under the terms of the class action settlement. In the Order and Judgment finally 

approving the settlement, the Honorable Jennifer L. Bunner stated:

[N]otice of the settlement to the Class was the best notice practicable under the 

circumstances, including individual notice to all members who can be identified 

through reasonable effort. The Court finds that such effort exceeded even reasonable 

effort and that the Notice complies with the requirements of Civ. R. 23(C).

In re: American Cyanamid, No. CV-97-0581-BH-M (S.D.Al.). The media program targeted 

Farmers who had purchased crop protection chemicals manufactured by American Cyanamid. 

In the Final Order and Judgment, the Honorable Charles R. Butler Jr. wrote: 

The Court finds that the form and method of notice used to notify the Temporary 

Settlement Class of the Settlement satisfied the requirements of Fed. R. Civ. P. 23 and 

due process, constituted the best notice practicable under the circumstances, and 

constituted due and sufficient notice to all potential members of the Temporary Class 

Settlement.

In re: First Alert Smoke Alarm Litig., No. CV-98-C-1546-W (UWC) (N.D.Al.). Ms. Finegan 

designed and implemented a nationwide legal notice and public information program. The 

public information program ran over a two-year period to inform those with smoke alarms of 

the performance characteristics between photoelectric and ionization detection. The media 

program included network and cable television, magazine and specialty trade publications. In 

the Findings and Order Preliminarily Certifying the Class for Settlement Purposes, Preliminarily 

Approving Class Settlement, Appointing Class Counsel, Directing Issuance of Notice to the Class, 

and Scheduling a Fairness Hearing, the Honorable C.W. Clemon wrote that the notice plan: 

...constitutes due, adequate and sufficient notice to all Class Members; and (v) meets 

or exceeds all applicable requirements of the Federal Rules of Civil Procedure, the 

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Jeanne C. Finegan, APR CV 14

United States Constitution (including the Due Process Clause), the Alabama State 

Constitution, the Rules of the Court, and any other applicable law. 

In re: James Hardie Roofing Litig., No. 00-2-17945-65SEA (Sup. Ct. of Wash., King County). The 

nationwide legal notice program included advertising on television, in print and on the Internet. 

The program was designed to reach all persons who own any structure with JHBP roofing 

products. In the Final Order and Judgment, the Honorable Steven Scott stated:

The notice program required by the Preliminary Order has been fully carried out... [and 

was] extensive. The notice provided fully and accurately informed the Class Members 

of all material elements of the proposed Settlement and their opportunity to 

participate in or be excluded from it; was the best notice practicable under the 

circumstances; was valid, due and sufficient notice to all Class Members; and complied 

fully with Civ. R. 23, the United States Constitution, due process, and other applicable 

law. 

Barden v. Hurd Millwork Co. Inc., et al, No. 2:6-cv-00046 (LA) (E.D.Wis.) ("The Court approves, 

as to form and content, the notice plan and finds that such notice is the best practicable under 

the circumstances under Federal Rule of Civil Procedure 23(c)(2)(B) and constitutes notice in a 

reasonable manner under Rule 23(e)(1).") 

Altieri v. Reebok, No. 4:10-cv-11977 (FDS) (D.C.Mass.) ("The Court finds that the notices ... 

constitute the best practicable notice... The Court further finds that all of the notices are 

written in simple terminology, are readily understandable by Class Members, and comply 

with the Federal Judicial Center’s illustrative class action notices.")

Marenco v. Visa Inc., No. CV 10-08022 (DMG) (C.D.Cal.) ("[T]he Court finds that the notice 

plan...meets the requirements of due process, California law, and other applicable precedent. 

The Court finds that the proposed notice program is designed to provide the Class with the 

best notice practicable, under the circumstances of this action, of the pendency of this 

litigation and of the proposed Settlement’s terms, conditions, and procedures, and shall 

constitute due and sufficient notice to all persons entitled thereto under California law, the 

United States Constitution, and any other applicable law.")

Palmer v. Sprint Solutions, Inc., No. 09-cv-01211 (JLR) (W.D.Wa.) ("The means of notice were

reasonable and constitute due, adequate, and sufficient notice to all persons entitled to be 

provide3d with notice.")

In re: Tyson Foods, Inc., Chicken Raised Without Antibiotics Consumer Litigation, No. 1:08-md01982 RDB (D. Md. N. Div.) (“The notice, in form, method, and content, fully complied with the 

requirements of Rule 23 and due process, constituted the best notice practicable under the 

circumstances, and constituted due and sufficient notice to all persons entitled to notice of 

the settlement.”)

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Sager v. Inamed Corp. and McGhan Medical Breast Implant Litigation, No. 01043771 (Sup. Ct. 

Cal., County of Santa Barbara) (“Notice provided was the best practicable under the 

circumstances.”).

Deke, et al. v. Cardservice Internat’l, Case No. BC 271679, slip op. at 3 (Sup. Ct. Cal., County of 

Los Angeles) (“The Class Notice satisfied the requirements of California Rules of Court 1856 

and 1859 and due process and constituted the best notice practicable under the 

circumstances.”).

Levine, et al. v. Dr. Philip C. McGraw, et al., Case No. BC 312830 (Los Angeles County Super. 

Ct., Cal.) (“[T]he plan for notice to the Settlement Class ... constitutes the best notice 

practicable under the circumstances and constituted due and sufficient notice to the members 

of the Settlement Class ... and satisfies the requirements of California law and federal due 

process of law.”).

In re: Canadian Air Cargo Shipping Class Actions, Court File No. 50389CP, Ontario Superior 

Court of Justice, Supreme Court of British Columbia, Quebec Superior Court (“I am satisfied the 

proposed form of notice meets the requirements of s. 17(6) of the CPA and the proposed 

method of notice is appropriate.”).

Fischer et al v. IG Investment Management, Ltd. et al, Court File No. 06-CV-307599CP, Ontario 

Superior Court of Justice. 

In re: Vivendi Universal, S.A. Securities Litigation, No. 02-cv-5571 (RJH)(HBP) (S.D.N.Y.). 

In re: Air Cargo Shipping Services Antitrust Litigation, No. 06-MD-1775 (JG) (VV) (E.D.N.Y.).

Berger, et al., v. Property ID Corporation, et al., No. CV 05-5373-GHK (CWx) (C.D.Cal.).

Lozano v. AT&T Mobility Wireless, No. 02-cv-0090 CAS (AJWx) (C.D.Cal.).

Howard A. Engle, M.D., et al., v. R.J. Reynolds Tobacco Co., Philip Morris, Inc., Brown & 

Williamson Tobacco Corp., No. 94-08273 CA (22) (11th Judicial Dist. Ct. of Miami-Dade County, 

Fla.).

In re: Royal Dutch/Shell Transport Securities Litigation, No. 04 Civ. 374 (JAP) (Consolidated 

Cases) (D. N.J.). 

In re: Epson Cartridge Cases, Judicial Council Coordination Proceeding, No. 4347 (Sup. Ct. of 

Cal., County of Los Angeles).

UAW v. General Motors Corporation, No: 05-73991 (E.D.MI).

Wicon, Inc. v. Cardservice Intern’l, Inc., BC 320215 (Sup. Ct. of Cal., County of Los Angeles).

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In re: SmithKline Beecham Clinical Billing Litig., No. CV. No. 97-L-1230 (Third Judicial Cir., 

Madison County, Ill.). Ms. Finegan designed and developed a national media and Internet site 

notification program in connection with the settlement of a nationwide class action concerning 

billings for clinical laboratory testing services. 

MacGregor v. Schering-Plough Corp., No. EC248041 (Sup. Ct. Cal., County of Los Angeles). This 

nationwide notification program was designed to reach all persons who had purchased or used 

an aerosol inhaler manufactured by Schering-Plough. Because no mailing list was available, 

notice was accomplished entirely through the media program. 

In re: Swiss Banks Holocaust Victim Asset Litig., No. CV-96-4849 (E.D.N.Y.). Ms. Finegan 

managed the design and implementation of the Internet site on this historic case. The site was 

developed in 21 native languages. It is a highly secure data gathering tool and information hub, 

central to the global outreach program of Holocaust survivors. www.swissbankclaims.com. 

In re: Exxon Valdez Oil Spill Litig., No. A89-095-CV (HRH) (Consolidated) (D. Alaska). Ms. 

Finegan designed and implemented two media campaigns to notify native Alaskan residents, 

trade workers, fisherman, and others impacted by the oil spill of the litigation and their rights 

under the settlement terms.

In re: Johns-Manville Phenolic Foam Litig., No. CV 96-10069 (D. Mass). The nationwide multimedia legal notice program was designed to reach all Persons who owned any structure, 

including an industrial building, commercial building, school, condominium, apartment house, 

home, garage or other type of structure located in the United States or its territories, in which 

Johns-Manville PFRI was installed, in whole or in part, on top of a metal roof deck. 

Bristow v Fleetwood Enters Litig., No Civ 00-0082-S-EJL (D. Id). Ms. Finegan designed and 

implemented a legal notice campaign targeting present and former employees of Fleetwood 

Enterprises, Inc., or its subsidiaries who worked as hourly production workers at Fleetwood’s 

housing, travel trailer, or motor home manufacturing plants. The comprehensive notice 

campaign included print, radio and television advertising.

In re: New Orleans Tank Car Leakage Fire Litig., No 87-16374 (Civil Dist. Ct., Parish of Orleans, 

LA) (2000). This case resulted in one of the largest settlements in U.S. history. This campaign 

consisted of a media relations and paid advertising program to notify individuals of their rights 

under the terms of the settlement.

Garria Spencer v. Shell Oil Co., No. CV 94-074(Dist. Ct., Harris County, Tex.). The nationwide 

notification program was designed to reach individuals who owned real property or structures 

in the United States, which contained polybutylene plumbing with acetyl insert or metal insert 

fittings. 

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In re: Hurd Millwork Heat MirrorTM Litig., No. CV-772488 (Sup. Ct. of Cal., County of Santa 

Clara). This nationwide multi-media notice program was designed to reach class members with 

failed heat mirror seals on windows and doors, and alert them as to the actions that they 

needed to take to receive enhanced warranties or window and door replacement. 

Laborers Dist. Counsel of Alabama Health and Welfare Fund v. Clinical Lab. Servs., Inc, No. 

CV–97-C-629-W (N.D. Ala.). Ms. Finegan designed and developed a national media and Internet 

site notification program in connection with the settlement of a nationwide class action 

concerning alleged billing discrepancies for clinical laboratory testing services. 

In re: StarLink Corn Prods. Liab. Litig., No. 01-C-1181 (N.D. Ill).. Ms. Finegan designed and 

implemented a nationwide notification program designed to alert potential class members of 

the terms of the settlement.

In re: MCI Non-Subscriber Rate Payers Litig., MDL Docket No. 1275, 3:99-cv-01275 (S.D.Ill.). 

The advertising and media notice program, found to be “more than adequate” by the Court, 

was designed with the understanding that the litigation affected all persons or entities who 

were customers of record for telephone lines presubscribed to MCI/World Com, and were 

charged the higher non-subscriber rates and surcharges for direct-dialed long distance calls 

placed on those lines. www.rateclaims.com. 

In re: Albertson’s Back Pay Litig., No. 97-0159-S-BLW (D.Id.). Ms. Finegan designed and 

developed a secure Internet site, where claimants could seek case information confidentially. 

In re: Georgia Pacific Hardboard Siding Recovering Program, No. CV-95-3330-RG (Cir. Ct., 

Mobile County, Ala.). Ms. Finegan designed and implemented a multi-media legal notice 

program, which was designed to reach class members with failed G-P siding and alert them of 

the pending matter. Notice was provided through advertisements, which aired on national 

cable networks, magazines of nationwide distribution, local newspaper, press releases and 

trade magazines.

In re: Diet Drugs (Phentermine, Fenfluramine, Dexfenfluramine) Prods. Liab. Litig., Nos. 1203, 

99-20593. Ms. Finegan worked as a consultant to the National Diet Drug Settlement 

Committee on notification issues. The resulting notice program was described and 

complimented at length in the Court’s Memorandum and Pretrial Order 1415, approving the 

settlement, 

In re: Diet Drugs (Phentermine, Fenfluramine, Dexfenfluramine) Prods. Liab. Litig., 2000 WL 

1222042, Nos. 1203, 99-20593 (E.D.Pa. Aug. 28, 2002).

Ms. Finegan designed the Notice programs for multiple state antitrust cases filed against the 

Microsoft Corporation. In those cases, it was generally alleged that Microsoft unlawfully used 

anticompetitive means to maintain a monopoly in markets for certain software, and that as a 

result, it overcharged consumers who licensed its MS-DOS, Windows, Word, Excel and Office 

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software. The multiple legal notice programs designed by Jeanne Finegan and listed below 

targeted both individual users and business users of this software. The scientifically designed 

notice programs took into consideration both media usage habits and demographic 

characteristics of the targeted class members.

In re: Florida Microsoft Antitrust Litig. Settlement, No. 99-27340 CA 11 (11th Judicial Dist. 

Ct. of Miami-Dade County, Fla.). 

In re: Montana Microsoft Antitrust Litig. Settlement, No. DCV 2000 219 (First Judicial Dist. Ct., 

Lewis & Clark Co., Mt.).

In re: South Dakota Microsoft Antitrust Litig. Settlement, No. 00-235(Sixth Judicial Cir., County 

of Hughes, S.D.). 

In re: Kansas Microsoft Antitrust Litig. Settlement, No. 99C17089 Division No. 15 Consolidated 

Cases (Dist. Ct., Johnson County, Kan.) (“The Class Notice provided was the best notice 

practicable under the circumstances and fully complied in all respects with the requirements of 

due process and of the Kansas State. Annot. §60-22.3.”).

In re: North Carolina Microsoft Antitrust Litig. Settlement, No. 00-CvS-4073 (Wake) 00-CvS1246 (Lincoln) (General Court of Justice Sup. Ct., Wake and Lincoln Counties, N.C.). 

In re: ABS II Pipes Litig., No. 3126 (Sup. Ct. of Cal., Contra Costa County). The Court approved 

regional notification program designed to alert those individuals who owned structures with 

the pipe that they were eligible to recover the cost of replacing the pipe.

In re: Avenue A Inc. Internet Privacy Litig., No: C00-1964C (W.D. Wash.).

In re: Lorazepam and Clorazepate Antitrust Litig., No. 1290 (TFH) (D.C.C.).

In re: Providian Fin. Corp. ERISA Litig., No C-01-5027 (N.D. Cal.).

In re: H & R Block., et al Tax Refund Litig., No. 97195023/CC4111 (MD Cir. Ct., Baltimore City).

In re: American Premier Underwriters, Inc, U.S. Railroad Vest Corp., No. 06C01-9912 (Cir. Ct., 

Boone County, Ind.).

In re: Sprint Corp. Optical Fiber Litig., No: 9907 CV 284 (Dist. Ct., Leavenworth County, Kan).

In re: Shelter Mutual Ins. Co. Litig., No. CJ-2002-263 (Dist.Ct., Canadian County. Ok).

In re: Conseco, Inc. Sec. Litig., No: IP-00-0585-C Y/S CA (S.D. Ind.).

In re: Nat’l Treasury Employees Union, et al., 54 Fed. Cl. 791 (2002). 

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In re: City of Miami Parking Litig., Nos. 99-21456 CA-10, 99-23765 – CA-10 (11th Judicial Dist. 

Ct. of Miami-Dade County, Fla.).

In re: Prime Co. Incorporated D/B/A/ Prime Co. Personal Comm., No. L 1:01CV658 (E.D. Tx.).

Alsea Veneer v. State of Oregon A.A., No. 88C-11289-88C-11300. 

INTERNATIONAL EXPERIENCE

Bell v. Canadian Imperial Bank of Commerce, et al, Court File No.: CV-08-359335 (Ontario 

Superior Court of Justice); (2016).

In re: Canadian Air Cargo Shipping Class Actions (Ontario Superior Court of Justice, Court File 

No. 50389CP, Supreme Court of British Columbia.

In re: Canadian Air Cargo Shipping Class Actions Québec Superior Court).

Fischer v. IG Investment Management LTD., No. 06-CV-307599CP (Ontario Superior Court of 

Justice).

In Re Nortel I & II Securities Litigation, Civil Action No. 01-CV-1855 (RMB), Master File No. 05 

MD 1659 (LAP) (S.D.N.Y. 2006).

Frohlinger v. Nortel Networks Corporation et al., Court File No.: 02-CL-4605 (Ontario Superior 

Court of Justice).

Association de Protection des Épargnants et Investissuers du Québec v. Corporation Nortel 

Networks, No.: 500-06-0002316-017 (Superior Court of Québec).

Jeffery v. Nortel Networks Corporation et al., Court File No.: S015159 (Supreme Court of British 

Columbia).

Gallardi v. Nortel Networks Corporation, No. 05-CV-285606CP (Ontario Superior Court).

Skarstedt v. Corporation Nortel Networks, No. 500-06-000277-059 (Superior Court of Québec).

SEC ENFORCEMENT NOTICE PROGRAM EXPERIENCE

SEC v. Vivendi Universal, S.A., et al., Case No. 02 Civ. 5571 (RJH) (HBP) (S.D.N.Y.).

The Notice program included publication in 11 different countries and eight different 

languages. 

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SEC v. Royal Dutch Petroleum Company, No.04-3359 (S.D. Tex.)

 FEDERAL TRADE COMMISSION NOTICE PROGRAM EXPERIENCE

FTC v. TracFone Wireless, Inc., Case No. 15-cv-00392-EMC.

FTC v. Skechers U.S.A., Inc., No. 1:12-cv-01214-JG (N.D. Ohio).

FTC v. Reebok International Ltd., No. 11-cv-02046 (N.D. Ohio)

FTC v. Chanery and RTC Research and Development LLC [Nutraquest], No :05-cv-03460 (D.N.J.)

BANKRUPTCY EXPERIENCE

Ms. Finegan has designed and implemented hundreds of domestic and international 

bankruptcy notice programs. A sample case list includes the following: 

In re AMR Corporation [American Airlines], et al., No. 11-15463 (SHL) (Bankr. S.D.N.Y.) ("due 

and proper notice [was] provided, and ... no other or further notice need be provided.")

In re Jackson Hewitt Tax Service Inc., et al., No 11-11587 (Bankr. D.Del.) (2011). The debtors 

sought to provide notice of their filing as well as the hearing to approve their disclosure 

statement and confirm their plan to a large group of current and former customers, many of 

whom current and viable addresses promised to be a difficult (if not impossible) and costly 

undertaking. The court approved a publication notice program designed and implemented by 

Finegan and the administrator, that included more than 350 local newspaper and television 

websites, two national online networks (24/7 Real Media, Inc. and Microsoft Media Network), a 

website notice linked to a press release and notice on eight major websites, including CNN and 

Yahoo. These online efforts supplemented the print publication and direct-mail notice provided 

to known claimants and their attorneys, as well as to the state attorneys general of all 50 

states. The Jackson Hewitt notice program constituted one of the first large chapter 11 cases to 

incorporate online advertising.

In re: Nutraquest Inc., No. 03-44147 (Bankr. D.N.J.)

In re: General Motors Corp. et al, No. 09-50026 (Bankr. S.D.N.Y.). This case is the 4th largest 

bankruptcy in U.S. history. Ms. Finegan and her team worked with General Motors 

restructuring attorneys to design and implement the legal notice program.

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In re: ACandS, Inc., No. 0212687 (Bankr. D.Del.) (2007) (“Adequate notice of the Motion and of 

the hearing on the Motion was given.”). 

In re: United Airlines, No. 02-B-48191 (Bankr. N.D Ill.). Ms. Finegan worked with United and its 

restructuring attorneys to design and implement global legal notice programs. The notice was 

published in 11 countries and translated into 6 languages. Ms. Finegan worked closely with 

legal counsel and UAL’s advertising team to select the appropriate media and to negotiate the 

most favorable advertising rates. www.pd-ual.com.

In re: Enron, No. 01-16034 (Bankr. S.D.N.Y.). Ms. Finegan worked with Enron and its 

restructuring attorneys to publish various legal notices.

In re: Dow Corning, No. 95-20512 (Bankr. E.D. Mich.). Ms. Finegan originally designed the 

information website. This Internet site is a major information hub that has various forms in 15 

languages. 

In re: Harnischfeger Inds., No. 99-2171 (RJW) Jointly Administered (Bankr. D. Del.). Ms. Finegan 

designed and implemented 6 domestic and international notice programs for this case. The 

notice was translated into 14 different languages and published in 16 countries.

In re: Keene Corp., No. 93B 46090 (SMB), (Bankr. E.D. MO.). Ms. Finegan designed and 

implemented multiple domestic bankruptcy notice programs including notice on the plan of 

reorganization directed to all creditors and all Class 4 asbestos-related claimants and counsel. 

In re: Lamonts, No. 00-00045 (Bankr. W.D. Wash.). Ms. Finegan designed an implemented 

multiple bankruptcy notice programs.

In re: Monet Group Holdings, Nos. 00-1936 (MFW) (Bankr. D. Del.). Ms. Finegan designed and 

implemented a bar date notice.

In re: Laclede Steel Co., No. 98-53121-399 (Bankr. E.D. MO.). Ms. Finegan designed and 

implemented multiple bankruptcy notice programs.

In re: Columbia Gas Transmission Corp., No. 91-804 (Bankr. S.D.N.Y.). Ms. Finegan developed 

multiple nationwide legal notice notification programs for this case. 

In re: U.S.H. Corp. of New York, et al. (Bankr. S.D.N.Y). Ms. Finegan designed and implemented 

a bar date advertising notification campaign. 

In re: Best Prods. Co., Inc., No. 96-35267-T, (Bankr. E.D. Va.). Ms. Finegan implemented a 

national legal notice program that included multiple advertising campaigns for notice of sale, 

bar date, disclosure and plan confirmation.

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In re: Lodgian, Inc., et al., No. 16345 (BRL) Factory Card Outlet – 99-685 (JCA), 99-686 (JCA) 

(Bankr. S.D.N.Y). 

In re: Internat’l Total Servs, Inc., et al., Nos. 01-21812, 01-21818, 01-21820, 01-21882, 01-

21824, 01-21826, 01-21827 (CD) Under Case No: 01-21812 (Bankr. E.D.N.Y).

In re: Decora Inds., Inc. and Decora, Incorp., Nos. 00-4459 and 00-4460 (JJF) (Bankr. D. Del.). 

In re: Genesis Health Ventures, Inc., et al, No. 002692 (PJW) (Bankr. D. Del.).

In re: Tel. Warehouse, Inc., et al, No. 00-2105 through 00-2110 (MFW) (Bankr. D. Del.). 

In re: United Cos. Fin. Corp., et al, No. 99-450 (MFW) through 99-461 (MFW) (Bankr. D. Del.).

In re: Caldor, Inc. New York, The Caldor Corp., Caldor, Inc. CT, et al., No. 95-B44080 (JLG) 

(Bankr. S.D.N.Y).

In re: Physicians Health Corp., et al., No. 00-4482 (MFW) (Bankr. D. Del.). 

In re: GC Cos., et al., Nos. 00-3897 through 00-3927 (MFW) (Bankr. D. Del.). 

In re: Heilig-Meyers Co., et al., Nos. 00-34533 through 00-34538 (Bankr. E.D. Va.).

PRODUCT RECALL, CRISIS AND MASS TORT EXPERIENCE

Reser’s Fine Foods. Reser’s is a nationally distributed brand and manufacturer of food products

through giants such as Albertsons, Costco, Food Lion, WinnDixie, Ingles, Safeway and Walmart. 

Ms. Finegan designed an enterprise-wide crisis communication plan that included 

communications objectives, crisis team roles and responsibilities, crisis response procedures, 

regulatory protocols, definitions of incidents that require various levels of notice, target 

audiences, and threat assessment protocols. Ms. Finegan worked with the company through 

two nationwide, high profile recalls, conducting extensive media relations efforts. 

Gulf Coast Claims Facility Notice Campaign. Finegan coordinated a massive outreach effort 

throughout the Gulf Coast region to notify those who have claims as a result of damages caused 

by the Deep Water Horizon Oil spill. The notice campaign included extensive advertising in 

newspapers throughout the region, Internet notice through local newspaper, television and 

radio websites and media relations. The Gulf Coast Claims Facility (GCCF) was an independent 

claims facility, funded by BP, for the resolution of claims by individuals and businesses for 

damages incurred as a result of the oil discharges due to the Deepwater Horizon incident on 

April 20, 2010. 

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City of New Orleans Tax Revisions, Post-Hurricane Katrina. In 2007, the City of New Orleans 

revised property tax assessments for property owners. As part of this process, it received 

numerous appeals to the assessments. An administration firm served as liaison between the 

city and property owners, coordinating the hearing schedule and providing important 

information to property owners on the status of their appeal. Central to this effort was the 

comprehensive outreach program designed by Ms. Finegan, which included a website and a 

heavy schedule of television, radio and newspaper advertising, along with the coordination of 

key news interviews about the project picked up by local media.

ARTICLES

Author, “Creating a Class Notice Program that Satisfies Due Process” Law360, New York, 

(February 13, 2018 12:58 PM ET).

Author, “3 Considerations for Class Action Notice Brand Safety” Law360, New York, (October 2, 

2017 12:24 PM ET).

Author, “What Would Class Action Reform Mean for Notice?” Law360, New York, (April 13, 

2017 11:50 AM ET).

Author, “Bots Can Silently Steal your Due Process Notice.” Wisconsin Law Journal, April 2017.

Author, “Don’t Turn a Blind Eye to Bots. Ad Fraud and Bots are a Reality of the Digital 

Environment.” LinkedIn article March 6, 2107.

Co-Author, “Modern Notice Requirements Through the Lens of Eisen and Mullane” –

Bloomberg - BNA Class Action Litigation Report, 17 CLASS 1077, (October 14, 2016).

Author, “Think All Internet Impressions Are The Same? Think Again” – Law360.com, New York 

(March 16, 2016, 3:39 ET).

Author, “Why Class Members Should See an Online Ad More Than Once” – Law360.com, New 

York, (December 3, 2015, 2:52 PM ET).

Author, ‘Being 'Media-Relevant' — What It Means and Why It Matters - Law360.com, New York 

(September 11, 2013, 2:50 PM ET).

Co-Author, “New Media Creates New Expectations for Bankruptcy Notice Programs,” ABI 

Journal, Vol. XXX, No 9, (November 2011).

Quoted Expert, “Effective Class Action Notice Promotes Access to Justice: Insight from a New 

U.S. Federal Judicial Center Checklist,” Canadian Supreme Court Law Review, (2011), 53 S.C.L.R. 

(2d).

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Co-Author, with Hon. Dickran Tevrizian – “Expert Opinion: It’s More Than Just a Report...Why 

Qualified Legal Experts Are Needed to Navigate the Changing Media Landscape,” BNA Class 

Action Litigation Report, 12 CLASS 464, May 27, 2011.

Co-Author, with Hon. Dickran Tevrizian, Your Insight, "Expert Opinion: It's More Than Just a 

Report -Why Qualified Legal Experts Are Needed to Navigate the Changing Media Landscape,"

TXLR, Vol. 26, No. 21, May 26, 2011.

Quoted Expert, “Analysis of the FJC’s 2010 Judges’ Class Action Notice and Claims Process 

Checklist and Guide: A New Roadmap to Adequate Notice and Beyond,” BNA Class Action 

Litigation Report, 12 CLASS 165, February 25, 2011.

Author, Five Key Considerations for a Successful International Notice Program, BNA Class Action 

Litigation Report, April, 9, 2010 Vol. 11, No. 7 p. 343.

Quoted Expert, “Communication Technology Trends Pose Novel Notification Issues for Class 

Litigators,” BNA Electronic Commerce and Law, 15 ECLR 109 January 27, 2010.

Author, “Legal Notice: R U ready 2 adapt?” BNA Class Action Report, Vol. 10 Class 702, July 24, 

2009.

Author, “On Demand Media Could Change the Future of Best Practicable Notice,” BNA Class 

Action Litigation Report, Vol. 9, No. 7, April 11, 2008, pp. 307-310.

Quoted Expert, “Warranty Conference: Globalization of Warranty and Legal Aspects of 

Extended Warranty,” Warranty Week, warrantyweek.com/archive/ww20070228.html/ 

February 28, 2007. 

Co-Author, “Approaches to Notice in State Court Class Actions,” For The Defense, Vol. 45, No. 

11, November, 2003.

Citation, “Recall Effectiveness Research: A Review and Summary of the Literature on Consumer 

Motivation and Behavior,” U.S. Consumer Product Safety Commission, CPSC-F-02-1391, p.10, 

Heiden Associates, July 2003.

Author, “The Web Offers Near, Real-Time Cost Efficient Notice,” American Bankruptcy Institute, 

ABI Journal, Vol. XXII, No. 5., 2003. 

Author, “Determining Adequate Notice in Rule 23 Actions,” For The Defense, Vol. 44, No. 9 

September, 2002.

Author, “Legal Notice, What You Need to Know and Why,” Monograph, July 2002.

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Co-Author, “The Electronic Nature of Legal Noticing,” The American Bankruptcy Institute 

Journal, Vol. XXI, No. 3, April 2002.

Author, “Three Important Mantras for CEO’s and Risk Managers,” - International Risk 

Management Institute, irmi.com, January 2002.

Co-Author, “Used the Bat Signal Lately,” The National Law Journal, Special Litigation Section, 

February 19, 2001. 

Author, “How Much is Enough Notice,” Dispute Resolution Alert, Vol. 1, No. 6. March 2001.

Author, “Monitoring the Internet Buzz,” The Risk Report, Vol. XXIII, No. 5, Jan. 2001. 

Author, “High-Profile Product Recalls Need More Than the Bat Signal,” - International Risk 

Management Institute, irmi.com, July 2001.

Co-Author, “Do You Know What 100 Million People are Buzzing About Today?” Risk and 

Insurance Management, March 2001.

Quoted Article, “Keep Up with Class Action,” Kentucky Courier Journal, March 13, 2000.

Author, “The Great Debate - How Much is Enough Legal Notice?” American Bar Association –

Class Actions and Derivatives Suits Newsletter, winter edition 1999.

SPEAKER/EXPERT PANELIST/PRESENTER

Chief Litigation Counsel Speaker, “Four Factors Impacting the Cost of Your Class Action

Association (CLCA) Settlement and Notice,” Houston TX, May 1, 2019

CLE Webinar “Rule 23 Changes to Notice, Are You Ready for the Digital Wild,

Wild West?” October 23, 2018, https://bit.ly/2RIRvZq

American Bar Assn. Faculty Panelist, 4th Annual Western Regional CLE Class Actions, 

“Big Brother, Information Privacy, and Class Actions: How Big Data 

and Social Media are Changing the Class Action Landscape” San 

Francisco, CA June, 2018.

Miami Law Class Action Faculty Panelist, “ Settlement and Resolution of Class Actions,”

& Complex Litigation Forum Miami, FL December 2, 2016.

The Knowledge Group Faculty Panelist, “Class Action Settlements: Hot Topics 2016 and 

Beyond,” Live Webcast, www.theknowledgegroup.org, October 

2016.

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ABA National Symposium Faculty Panelist, “Ethical Considerations in Settling Class Actions,” 

New Orleans, LA, March 2016.

S.F. Banking Attorney Assn. Speaker, “How a Class Action Notice can Make or Break your 

Client’s Settlement,” San Francisco, CA, May 2015.

Perrin Class Action Conf. Faculty Panelist, “Being Media Relevant, What It Means and Why 

It Matters – The Social Media Evolution: Trends, Challenges and 

Opportunities,” Chicago, IL May 2015.

Bridgeport Continuing Ed. Speaker, Webinar “Media Relevant in the Class Notice Context.”

July, 2014.

Bridgeport Continuing Ed. Faculty Panelist, “Media Relevant in the Class Notice Context.”

Los Angeles, California, April 2014.

CASD 5th Annual Speaker, “The Impact of Social Media on Class Action Notice.” 

Consumer Attorneys of San Diego Class Action Symposium, San 

Diego, California, September 2012.

Law Seminars International Speaker, “Class Action Notice: Rules and Statutes Governing FRCP 

(b)(3) Best Practicable... What constitutes a best practicable 

notice? What practitioners and courts should expect in the new 

era of online and social media.” Chicago, IL, October 2011. 

*Voted by attendees as one of the best presentations given.

CASD 4th Annual Faculty Panelist, “Reasonable Notice - Insight for practitioners on 

the FJC’s Judges’ Class Action Notice and Claims Process Checklist 

and Plain Language Guide. Consumer Attorneys of San Diego Class 

Action Symposium, San Diego, California, October 2011.

CLE International Faculty Panelist, Building a Workable Settlement Structure, CLE 

International, San Francisco, California May, 2011.

CASD Faculty Panelist, “21st Century Class Notice and Outreach.” 3nd

Annual Class Action Symposium CASD Symposium, San Diego, 

California, October 2010.

CASD Faculty Panelist, “The Future of Notice.” 2nd Annual Class Action

Symposium CASD Symposium, San Diego California, October 2009.

American Bar Association Speaker, 2008 Annual Meeting, “Practical Advice for Class Action 

Settlements: The Future of Notice In the United States and 

Internationally – Meeting the Best Practicable Standard.”

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Section of Business Law Business and Corporate Litigation 

Committee – Class and Derivative Actions Subcommittee, New 

York, NY, August 2008.

Women Lawyers Assn. Faculty Panelist, Women Lawyers Association of Los Angeles 

“The Anatomy of a Class Action.” Los Angeles, CA, February, 2008.

Warranty Chain Mgmt. Faculty Panelist, Presentation Product Recall Simulation. Tampa, 

Florida, March 2007.

Practicing Law Institute. Faculty Panelist, CLE Presentation, 11th Annual Consumer 

Financial Services Litigation. Presentation: Class Action Settlement 

Structures – Evolving Notice Standards in the Internet Age. New 

York/Boston (simulcast), NY March 2006; Chicago, IL April 2006 

and San Francisco, CA, May 2006.

U.S. Consumer Product Ms. Finegan participated as an invited expert panelist to the CPSC

Safety Commission to discuss ways in which the CPSC could enhance and measure the 

recall process. As a panelist, Ms Finegan discussed how the CPSC 

could better motivate consumers to take action on recalls and 

how companies could scientifically measure and defend their 

outreach efforts. Bethesda, MD, September 2003.

Weil, Gotshal & Manges Presenter, CLE presentation, “A Scientific Approach to Legal Notice 

Communication.” New York, June 2003.

Sidley & Austin Presenter, CLE presentation, “A Scientific Approach to Legal 

Notice Communication.” Los Angeles, May 2003.

Kirkland & Ellis Speaker to restructuring group addressing “The Best Practicable 

Methods to Give Notice in a Tort Bankruptcy.” Chicago, April 

2002.

Georgetown University Law Faculty, CLE White Paper: “What are the best practicable methods 

to Center Mass Tort Litigation give notice? Dispelling the 

communications myth – A notice Institute disseminated is a 

notice communicated,” Mass Tort Litigation Institute. Washington 

D.C., November, 2001.

American Bar Association Presenter, “How to Bullet-Proof Notice Programs and What 

Communication Barriers Present Due Process Concerns in Legal 

Notice,” ABA Litigation Section Committee on Class Actions & 

Derivative Suits. Chicago, IL, August 6, 2001.

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McCutchin, Doyle, Brown Speaker to litigation group in San Francisco and simulcast to four 

other McCutchin locations, addressing the definition of effective 

notice and barriers to communication that affect due process in 

legal notice. San Francisco, CA, June 2001.

Marylhurst University Guest lecturer on public relations research methods. Portland, 

OR, February 2001.

University of Oregon Guest speaker to MBA candidates on quantitative and qualitative 

research for marketing and communications programs. Portland, 

OR, May 2001.

Judicial Arbitration & Speaker on the definition of effective notice. San Francisco and Los

Mediation Services (JAMS) Angeles, CA, June 2000.

International Risk Past Expert Commentator on Crisis and Litigation Communications.

Management Institute www.irmi.com.

The American Bankruptcy Past Contributing Editor – Beyond the Quill. www.abi.org.

Institute Journal (ABI)

BACKGROUND

Ms Finegan’s past experience includes working in senior management for leading Class 

Action Administration firms including The Garden City Group (“GCG”) and Poorman-Douglas

Corp., (“EPIQ”). Ms. Finegan co-founded Huntington Advertising, a nationally recognized leader 

in legal notice communications. After Fleet Bank purchased her firm in 1997, she grew the 

company into one of the nation’s leading legal notice communication agencies.

Prior to that, Ms. Finegan spearheaded Huntington Communications, (an Internet 

development company) and The Huntington Group, Inc., (a public relations firm). As a partner 

and consultant, she has worked on a wide variety of client marketing, research, advertising, 

public relations and Internet programs. During her tenure at the Huntington Group, client 

projects included advertising (media planning and buying), shareholder meetings, direct mail, 

public relations (planning, financial communications) and community outreach programs. Her 

past client list includes large public and privately held companies: Code-A-Phone Corp., ThriftyPayless Drug Stores, Hyster-Yale, The Portland Winter Hawks Hockey Team, U.S. National Bank, 

U.S. Trust Company, Morley Capital Management, and Durametal Corporation. 

Prior to Huntington Advertising, Ms. Finegan worked as a consultant and public relations 

specialist for a West Coast-based Management and Public Relations Consulting firm.

Additionally, Ms. Finegan has experience in news and public affairs. Her professional 

background includes being a reporter, anchor and public affairs director for KWJJ/KJIB radio in 

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Portland, Oregon, as well as reporter covering state government for KBZY radio in Salem, 

Oregon. Ms. Finegan worked as an assistant television program/promotion manager for KPDX 

directing $50 million in programming. She was also the program/promotion manager at KECH22 television. 

Ms. Finegan's multi-level communication background gives her a thorough, hands-on 

understanding of media, the communication process, and how it relates to creating effective 

and efficient legal notice campaigns.

MEMBERSHIPS, PROFESSIONAL CREDENTIALS 

APR Accredited. Universal Board of Accreditation Public Relations Society of America 

• Member of the Public Relations Society of America

• Member Canadian Public Relations Society

Board of Directors - Alliance for Audited Media

Alliance for Audited Media (“AAM”) is the recognized leader in cross-media verification. It was 

founded in 1914 as the Audit Bureau of Circulations (ABC) to bring order and transparency to the 

media industry. Today, more than 4,000 publishers, advertisers, agencies and technology vendors 

depend on its data-driven insights, technology certification audits and information services to 

transact with trust.

SOCIAL MEDIA 

LinkedIn: www.linkedin.com/in/jeanne-finegan-apr-7112341b

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