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Githieya v. GTL, GA, Declaration of Tiffany Janowicz, Prepaid Telephone Account, 2021

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Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 1 of 57

Exhibit 3

Declaration of Tiffaney Janowicz

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 2 of 57

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
BENSON GITHIEYA, et al.,
Plaintiffs,
v.

CIVIL ACTION NO:
1:15-CV-00986-AT

GLOBAL TEL*LINK CORP.,
Defendant.

DECLARATION OF TIFFANEY JANOWICZ
REGARDING NOTICE TO CLASS MEMBERS
I, Tiffaney Janowicz, hereby declare as follows:
1.

I am a senior vice president of Rust Consulting, Inc. (“Rust”), a

nationally recognized notice and administration firm. Rust designs and implements
notice and administration programs of all sizes and types, including consumer,
antitrust, securities, insurance, healthcare, labor and employment, property, finance,
telecom, and products liability class actions. A C.V. outlining Rust’s services and
experience is attached as Exhibit A.

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 3 of 57

2.

I have over 25 years of experience at Rust. I lead Rust’s consumer,

insurance, and healthcare practice areas, and I also have a significant depth of
experience in antitrust, consumer, and product liability matters. I have designed
and/or managed hundreds of class action notice and administration programs. I
speak on class action matters (Continuing Legal Education courses), and I have been
a co-author or panelist on relevant topics in the notice and administration industry.
Attached as Exhibit B is my C.V., which outlines my experience and qualifications.
3.

I submit this declaration in connection with the above-captioned matter

to describe the plan of notification and administration (“Notice Program”) and
notices. This declaration is based upon my personal knowledge and information
provided by my associates and staff. The information included in this declaration is
of a type reasonably relied upon in the fields of class notice and administration.
4.

Subject to the approval of the Court, the parties have agreed to jointly

request that the Court appoint Rust to fulfill the role of Settlement Administrator in
the above-captioned case to design the Notice Program and help implement the terms
and conditions of the Settlement Agreement. I submit this declaration to describe
the Notice Program to reach class members and why it is reasonable and adequate
under the circumstances.

2

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 4 of 57

OVERVIEW
5.

I understand that the class includes all persons nationwide who (1)

established and initially funded a prepaid account through GTL’s interactive-voiceresponse (“IVR”) system and (2) had a positive account balance that was reduced to
$0.00 due to account inactivity for 180 days or less from April 3, 2011, until October
6, 2021.
NOTICE PROGRAM
6.

The Notice Program is designed to reach the greatest practicable

number of class members; provide class members opportunities to learn about the
Settlement and act upon their rights; and ensure that they will be exposed to, see,
review, and understand the Notices. To achieve this goal, a three-part notification
program was designed, which includes:
a. Direct Notice (U.S Mail postcard and email);
b. Paid Media Notice - including print, digital, and social media
advertising; and
c. Earned Media coverage obtained through a national press release.
7.

The Notice Program also includes Notices designed to meet due process

requirements that are written in plain language.

3

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 5 of 57

Direct Notice
8.

Rust worked with Counsel to develop the following plan to disseminate

Notice to all known members of the class.
9.

For all class members, Rust expects to receive the telephone number

that was used to receive calls using the GTL AdvancePay account and the date range
that the related account was active.

GTL additionally will provide contact

information, including the name, last known address, or email address if found in its
records.

Due to the age of the data, the class’s likely mobility, and the

incompleteness of the class data, Rust will perform a skip trace to facilitate direct
notice. For records without either a complete mailing address or email address, Rust
will use the telephone number to search for the account holder’s current email
address. For records four years old or older, Rust will use the date of the GTL
account to attempt to locate the owner of the telephone number during that time
frame and obtain their current email address. This skip trace will be done through
TransUnion or a similar third-party vendor. TransUnion uses a variety of third-party
sources to compare the latest addresses for individuals and returns updated addresses
for them. Through this process, Rust will compile a listing of class member mailing
addresses and email addresses to effectuate direct notice.

4

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 6 of 57

10.

Rust will send a short form notice describing the Settlement via email

(“Email Class Notice”) to Settlement Class Members for whom an email address
was located within GTL’s records or obtained during the skip trace process. The
Email Class Notice will include a link to the Settlement Website where Class
Members will find the Settlement details, including the Settlement Agreement, Long
Form Notice, and Claim Form, and a direct link to the online Claim Form.
11.

Email delivery attempts will be tracked; if an item is returned as

undeliverable, commonly referred to as a “bounce,” the reason is noted. If the email
address is noted as non-existent as attempted, this is referred to as a “hard” bounce,
and no additional attempts to deliver the Notice to that email address will be made.
Responses, where the inbox is full or other circumstances prevent delivery are
referred to as “soft” bounces and will receive up to eight attempts for delivery. The
timeframe to complete soft bounce re-delivery attempts may vary based on the
volume of emails included in the campaign, but typically this process will be
complete within a few days of receiving the bounce notification.
12.

Rust will mail the summary notice via First Class U.S. Mail in the form

of a postcard, including a tear-off Claim Form, to all complete mailing addresses
provided in GTL’s records (“Mailed Class Notice”). Prior to mailing, Rust will
process the class member address information using the National Change of Address
5

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 7 of 57

(NCOA) system maintained by the United States Postal Service (USPS). The
NCOA system contains new addresses of people and businesses that have moved
over the past 48 months and notified USPS of their new addresses. Standardizing
and updating addresses prior to mailing using NCOA is industry standard and
improves delivery rates.
13.

Postcard Notices that are returned as non-deliverable will be reviewed

and re-mailed as appropriate. If notices are returned as non-deliverable with an
automatic forwarding order, the notices will be re-mailed to any address indicated
by the USPS. Notices returned as non-deliverable without a forwarding address will
be further traced through TransUnion or a similar vendor to obtain a more current
address. If any such address is found, the notice will be re-mailed.
14.

Additionally, Rust will send Reminder Notices via email to any email

address that previously received notice but for which a claim has not been received
within 90 days of the initial notice emailing. The Reminder Notice will remind class
members of their right to file a claim and provide the deadline to do so.
15.

Rust will also mail class notice via First Class U.S. Mail in the form of

a Long Form Notice (with included Claim Form) to any potential class member who
requests it.

The Long Form Notice includes detailed information about the

Settlement, including answers to frequently asked questions.
6

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 8 of 57

Paid Media Notice
16.

The proposed media program was designed to satisfy due process by

reaching a broad target audience that includes class members and targeting media to
populations and areas of the country that include the heaviest concentrations of
potential class members.
17.

The first step in determining what media is appropriate to reach

potential class members is to establish an equivalent demographic profile, otherwise
known as a target audience, of potential class members. The second step is to
analyze available data (demographics, media habits) about that target audience. This
information is used to select the most appropriate media to reach potential class
members.
18.

We used media survey data from MRI-Simmons 2021 Doublebase

Study (“MRI”)1 to choose the target audience and analyze the notice program. In this
case, MRI does not measure individuals with GTL prepaid accounts; therefore, the
Notice Program media was selected to target adults 18 years and older.
19.

We researched additional information about prisoners to help develop

our targeted media recommendations.
1

MRI-Simmons produces an annual survey, called a Doublebase Study. The study
includes survey responses from over 50,000 people and covers thousands of brands
and hundreds of product categories.
7

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 9 of 57

20.

The Bureau of Prisons reports that the federal population is 38% Black

and 30% Hispanic.2 Numerous research studies have also found that people from
low-income families are heavily represented in the prison population.3
21.

To tailor our media recommendations, we investigated areas of the

country that have the heaviest levels of incarceration and found:
a. The Top Five Most Populated Prisons:4
Prison
Location
Inmate Population
Los Angeles County Los Angeles, CA
19,836
Rikers Island

New York, NY

13,849

Harris County Jail

Houston, TX

10,000

Cook County Jail

Chicago, IL

9,900

Maricopa County Jail

Phoenix, AZ

9,265

2

Bureau of Prisons, Inmate Race,
https://www.bop.gov/about/statistics/statistics_inmate_race.jsp (last visited Oct.
27, 2021).
3
Institute for Research on Poverty, Connections Among Poverty, Incarceration,
And Inequality, https://www.irp.wisc.edu/resource/connections-among-povertyincarceration-and-inequality/ (last visited Oct. 27, 2021).
4
World Atlas, The Largest Jails in the United States,
https://www.worldatlas.com/articles/the-largest-jails-in-the-united-states.html (last
visited Dec. 5, 2021).
8

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 10 of 57

b. The Top Five States with the Largest Prison Populations:5
State
Texas

Inmate Population
154,479

California

122,417

Florida

96,009

Georgia

54,113

Ohio

50,338

c. Top Five States with Heaviest Concentration of Prison Population
per Capita:6
State
Louisiana

Inmate Population per 100,000
683

Mississippi

638

Oklahoma

635

Arkansas

584

Arizona

545

5

World Population Review, Prison Population by State 2021,
https://worldpopulationreview.com/state-rankings/prison-population-by-state (last
visited Dec. 5, 2021).
6
Id.
9

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 11 of 57

Paid Media
22.

The paid media notice is designed to ensure that the Notice is placed in

media outlets whose audiences are likely to include potential class members. This
paid media program includes print, digital, and social media.
Print Advertising
Consumer Magazines
23.

Most adults read one or more magazines during an average month, and

nearly three out of five adults read or look at a magazine daily. Adults 18+ read an
average of five magazines per month.
24.

The Publication Notice will appear once as a half-page ad in T.V. Guide

and twice as a half-page ad in Prison Legal News, national magazines with the
following circulation:
Magazine
T.V. Guide

Circulation
1,100,000

Prison Legal News

9,000

Target Audience Print Readership
25.

Readership includes both primary readers and pass-along readers.

Primary readers purchase a publication or are members of a household where the

10

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 12 of 57

publication was purchased. Pass-along readers are those who read the publication
outside the home, in places such as a doctor’s office. The table below indicates the
estimated number of readers in the target audience of an average issue of the
magazine:
Magazine7
T.V. Guide

Readers
9,900,000

Shopper Newspapers
26.

The Print Notice will appear once as a one-sixth page ad in the highest-

circulating shopper newspapers in the top five states with the highest prison
population per capita. These newspapers provide shoppers with shopping deals,
coupons, or other promotional codes.
Title
Bargains Plus!

Circulation
20,959

State
Louisiana

Impact

38,024

Mississippi

Clipper

11,700

Oklahoma

Free Weekly

7,495

Arkansas

Ad-King

10,000

Arizona

7

Prison Legal News’ readership is not measured in MRI. Information provided by
the publisher notes that 65% to 70% of readers are inmates.
11

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 13 of 57

Digital Advertising
27.

The Notice Program includes Internet advertising to provide class

members with additional notice opportunities beyond the print placements. Over
94% of Adults 18+ have used the Internet in the past 30 days.8 Internet advertising
delivers an immediate message and allows the viewer of an advertisement to
instantly click through to the website for further information.
28.

An estimated 124,000,000 gross impressions9 will be delivered

nationally across mobile, tablet, and desktop platforms for six weeks on Google
Display Network, YouTube, Facebook, Instagram, and the Prison Legal News enewsletter. Facebook ads will appear in English and Spanish.
29.

Keywords and phrases will be implemented with all major search

engines, including Google AdWords, Bing (Microsoft Advertising), and their search
partners. When a user searches for one of the specified search terms or phrases (e.g.,
“GTL settlement,” “inmate call settlement”), sponsored links will appear on the
results page.

8

2021 MRI-Simmons Spring Study.
Gross impressions are the total number of times a digital ad will be shown. This
figure does not represent the total number of unique viewers of the ad, as some
viewers will see the ad on more than one website.
9

12

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 14 of 57

30.

Targeted Internet advertising will also be used to reach areas of the

country that include heavier concentrations of potential class members.

The

following tactics are recommended:
Tactic
Email Matching

Social Media
Support Groups

Definition
Ads targeted to users who have an email that matches a
known class member on Facebook and Google.
Ads targeted to Facebook fans of specialized pages and
groups that relate to prison-related categories (e.g., Prison
Wives Support Group, Prison Talk, Prison
Wives/Girlfriends, Families Supporting Prisoners, Prison
Wives, Moms of Prisoners).

Ads targeted to areas surrounding the five highest
Mobile Geofencing populated jails (Los Angeles County, Rikers Island, Harris
County Jail, Cook County Jail, and Maricopa County Jail).

Geotargeting

Ads targeted to lower-income households in the top five
states with the largest prison population (Texas, California,
Florida, Georgia, and Ohio).

Demographics

Ads targeted to Blacks and Latinos with a lower household
income.

Ads targeted to users who have viewed and browsed for
Channel/Contextual Pennysaver, extreme couponing, coupon codes, or coupon
and classified related topics.
Earned Media Program
31.

An earned media program also will be implemented to amplify the paid

media and provide additional notice to class members. The message will be
13

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 15 of 57

distributed to media outlets (newspapers, websites, and television and radio stations)
to spark press interest and generate coverage.
32.

The earned media program will focus on a press release highlighting

the toll-free telephone number and Settlement website address so that class members
can obtain complete information about the proceeding and settlement. The press
release will be distributed on P.R. Newswire’s US1 national wire. It will reach
approximately 5,400 traditional media outlets (T.V., radio, newspaper, magazine),
relevant trade publications, and 4,000 national websites.
Forms of Notice
33.

Attached as Exhibits C, D, E, F, and G are the Long Form Notice,

Emailed Class Notice, Mailed Class Notice, Publication Class Notice, and Reminder
Notice. The forms of Notice are written in plain, easily understood language. The
Notices effectively communicate the required information about the Settlement and
provide class members with opportunities to learn about the lawsuit and act upon
their rights.
34.

The short form notices (Emailed, Mailed, and Publication) are designed

to capture the class members’ attention with clear, concise, plain language. The
plain language text provides important information regarding the subject of the
litigation, the class definition, and the legal rights available to class members. No
14

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 16 of 57

important or required information is missing or omitted. The Notices state all
required information without omitting significant facts that class members need to
understand their rights. These Notices will feature the toll-free phone number and
the Settlement website address for potential class members to find more information
or request or access the Long Form Notice.
35.

The Long Form Notice will be available at the website, by calling the

toll-free number, or by mailing or emailing a request to the Settlement
Administrator. The Long Form Notice provides substantial information, including
background on the issues in the case and all specific instructions class members must
follow to properly exercise their rights. No important or required information is
missing or omitted. It is designed to encourage readership and understanding in a
well-organized and reader-friendly format. The Long Form Notice will be available
in English and Spanish.
Class Member Response Mechanisms
36.

Rust will establish a website to enable class members to get information

about the Settlement, including the Long Form Notice (in English and Spanish), the
Claim Form, frequently asked questions, the Settlement Agreement, and other court
documents from this action. Class members will be able to download materials and
the Claim Form and file a claim online. The stand-alone, single-page Claim Form
15

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 17 of 57

is attached as Exhibit H. The Settlement Website will be operational before the
Notice Program begins.
37.

Rust will establish a toll-free informational number to allow class

members to call and listen to answers to frequently asked questions 24 hours a day
and seven days a week. The toll-free informational number will be operational
before the Notice Program begins.
38.

Rust will establish a U.S. Mail Post Office Box to allow class members

to submit Requests for Exclusion, Claim Forms, and correspondence by mail with
any specific requests or questions.
CONCLUSION
39.

The Notice Program is expected to reach at least 70% of the class.

40.

The Notice Program incorporates a modern approach to Notice. The

reach is within the guidelines established by the Federal Judicial Center.10
41.

It is my opinion that the Notice Program is adequate and reasonably

designed to maximize the likelihood of reaching the largest number of class
members that is practicable under the circumstances. It is consistent with the

10

The Federal Judicial Center, Judges’ Class Action Notice and Claims Process
Checklist and Plain Language Guide, https://www.consumerclassdefense.com/wpcontent/uploads/sites/235/2013/06/FJC-Notice-Checklist-and-Plain-LanguageGuide.pdf (last visited Nov. 29, 2021).
16

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 18 of 57

standards employed by Rust in administering these types of class action settlements
and designing effective notice programs to reach class members.
I declare that the foregoing is true and correct to the best of my knowledge.

Executed in Niwot, Colorado this 5th day of December, 2021.

Tiffaney Janowicz

17

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 19 of 57

Exhibit A

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 20 of 57

I
RUST
CONS

U L T ING

An ExelaTechnologiesar.1nd

Qualifications Summary
This document outlines Rust Consulting’s qualifications to serve as the administrator for class action, mass tort,
and regulatory settlements, as well as to perform other similar, complex and time-sensitive matters such as
remediation programs, data breach responses, and product recalls. It includes summary information categorized
as follows:
 Firm Overview


Practice Area Organization



Personnel



Services



Representative Case Experience



Data and System Security

Firm Overview
Rust, an Exela Technologies brand, is an industry-leading consulting and administration firm that provides public
and private sector clients a full complement of services required to administer legal settlements and similar
programs. These services include consulting; project management; data management; notification; contact center
and websites; claims processing; and fund management, distribution, and tax reporting.
Rust grew out of the litigation support firm the Rust Consulting Group, which was founded in 1976. In 1988, the
Group administered its first class action settlement, eventually leading in 1995 to the formation of Rust
Consulting, Inc. as a separate entity focused on legal settlement administration. Since then, Rust has
administered more than 7,500 settlements and projects.
Headquartered in Minneapolis, Rust also has an office in Faribault, Minnesota. Our subsidiary Kinsella Media
maintains a Washington, D.C., location. Rust and Kinsella are wholly owned subsidiaries of Exela Technologies,
Inc. (NASDAQ: XELA, XELAW and XELAU), one of the largest global providers of transaction processing
solutions and enterprise information management.

Practice Area Organization
Rust administers programs spanning diverse subject matter. The depth and breadth of our legal settlement
administration experience spans all prominent practice areas, such as antitrust, consumer, finance, insurance and
healthcare, labor and employment, product liability, and securities matters on behalf of private sector clients and
governmental agencies at all levels. Our services also lend themselves to our clients’ non-settlement needs,
including data breach responses, recalls, and remediation programs.
Our leadership and certain operations and client services personnel focus on specific practice areas relevant to our
clients, deepening their subject matter expertise and directly relevant experience.

62 5 MARQUETTE AVENUE, SUITE 9 00

MINNEAPOLIS, MN 5540 2

I 612.3 59.2000

I 612.3 59. 2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 21 of 57
Rust Consulting Qualifications Summary, 2

Personnel
Our permanent staff of approximately 200 includes professionals with backgrounds and disciplines including
project management, information technology, finance, law, and operations. This cross-functional, innovative team
includes experts in their respective disciplines, such as CPAs, Ph.D.s, attorneys, and PMPs.
Rust’s team includes some of the most experienced practitioners in the industry, with much of that experience
Rust-specific. Our senior vice presidents average 17 years of Rust experience and our functional directors
average over 20 years.

Services
The Rust team provides high quality administrative services for matters of any size and scope. Specific
approaches may vary depending upon the requirements of each individual matter; however, the below services
are typical of our engagements.

Preliminary Consulting
Rust consults with clients prior to settlement to help set expectations based on our experience with similar matters
and to anticipate otherwise identified issues that may arise in administration based on a settlement or program’s
characteristics.

Project Management
Our project management personnel prepare plans of notice and administration, create or customize project
tracking tools and reports, and oversee the creation of project-specific databases designed to house and capture
appropriate information for use in claims administration. Throughout the administration process, project
management personnel coordinate all activities between the parties, vendors, and internal Rust departments to
ensure work is completed accurately and according to any service level agreements, internal standards,
settlement documents, etc. We provide regular and on-demand reports and statistics to the appropriate parties
and raise potential issues requiring their attention, as necessary. Upon completion of each major phase of
administration, or as required, we prepare declarations or affidavits attesting to the scope and results of our work.

Data Management
The secure and efficient handling of data underlies all aspects of claims administration; Rust creates and
customizes data management processes, databases, applications to meet the unique needs of each settlement or
project. Tasks associated with data management throughout administration may include:
 Intaking original client data.


Normalizing data for cross-platform usability, such as meeting mailing or other outreach requirements.



Consolidating and deduplicating data from multiple sources.



Extracting data for standard or customized trace services.



Extracting data for mailing or other outreach.



Calculating awards.

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 22 of 57
Rust Consulting Qualifications Summary, 3

Notification
Rust disseminates hundreds of millions of notices annually by mail and email. We also work with our subsidiary
Kinsella Media, the leading provider of notice to unidentified audiences and the only firm in the nation with
qualified, court-recognized notice expertise, to develop and implement notice plans.

With respect to legal settlements, these notice programs notify class members or other affected individuals of
their legal rights and options. With respect to data breach responses, recalls, or remediation, these programs
inform affected individuals about the situations and any options those affected individuals may have.

Among our notification-related services are:
 Designing notice programs (through Kinsella Media).


Drafting plain language materials (through Kinsella Media).



Designing and proofreading notice materials.



Locating unidentified individuals and updated addresses.



Printing and mailing.



Processing and forwarding undeliverable mail.



Opining about notice program adequacy (through Kinsella Media).

Contact Center
Rust supports the programs we administer through an assortment of contact center services including call center,
websites, and email support up to 24/7 and for class members and other affected individuals worldwide.
Our call center services include inbound and outbound calls in our own domestic, in-house call center. The call
center is located in our Minneapolis headquarters and is readily expandable to meet the needs of specific
programs of any size.
All customer service representatives (CSRs)—permanent or temporary—undergo background checks and training on
Rust’s policies and technology, customer service fundamentals, and project-specific information. Typical engagements
include English- and Spanish-speaking CSRs, while we provide support in additional languages, as required. In one
case, Rust CSRs took live inbound calls in 10 languages.
In lieu of or in conjunction with live customer service, Rust builds and maintains automated Interactive Voice
Response (IVR) systems that provide 24/7 service to toll-free numbers and include menus of prerecorded options
such as program overviews, frequently asked questions and answers, and options for requesting forms or filing
claims. Rust’s IVR systems regularly support English- and Spanish-language speakers and can be programmed
to support other languages, as required. In one case, Rust managed IVR support including translations of
information pre-recorded by native speakers in 67 languages.

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 23 of 57
Rust Consulting Qualifications Summary, 4

Claims Processing
Rust develops or executes claims processing or adjudication programs as required by the diverse terms of our
engagements. We use several proprietary software applications and tested, streamlined processes to provide the
most appropriate solutions for each engagement’s needs, whether for paper or online claims. Our systems
automate the claims administration process:
 Receipt.


Link to class member database record.



Data capture.



Review of supporting documentation.



Initial adjudication.



Deficiency processing.



Final adjudication.



Rejection letters.



Reporting/affidavits.

To meet the needs of each engagement, our systems can be configured to give clients or authorized parties
secure online access to claimant data and reporting, or to class members to facilitate online claims filing.

Fund Management, Distribution, and Tax Reporting
Rust annually distributes billions of dollars associated with settlements and similar programs. Our Bank and Tax
group is responsible for day-to-day banking and tax reporting functions for all settlement funds.
Banking Services

Tax Reporting Services



Account setup.



Tax identification numbers (federal and state).



Online bank reporting.





Escrow, investment and distribution
accounts.

Qualified Settlement Fund (QSF)
determination.



Claimant award taxability and reporting.



Escrow agent services.



W-9 review.



Positive Pay – all claimant checks are issued
with Positive Pay verification.



Annual 1120 SF tax returns and quarterly tax
deposits.



Check images.





Wire transfers.

IRS and state 1099 and 1042S reporting and
transmission.



Account reconciliation (daily, weekly or
monthly).



Backup withholding deposits and 945 annual
reporting.



Balance inquiry and reporting.



Employment payroll taxes: 941, 940, SUTA,
SIT, and local income taxes.

625 MARQUETTEAVENUE, SUITE 900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 24 of 57
Rust Consulting Qualifications Summary, 5

Representative Case Experience
Having administered more than 7,500 projects, a complete listing of our experience is voluminous. However, the
below tables demonstrate the scope of our experience and capacity.
Note: All numbers are rounded
Notices

Case

183 million

In re Domestic Airline Travel Antitrust Litigation, MDL 2656 (D.D.C.).

83 million

In re Target Corporation Customer Data Security Breach Litigation, MDL 2522 (D. Minn.).

31 million

In re Lawnmower Engine Horsepower Marketing and Sales Practices Litigation, No. 2:08-md-01999
(E.D. Wis.).

24 million

Microsoft I-V Cases, J.C.C.P. No. 4106 (Cal. Super. Ct. San Francisco County).

15.7 million

Blessing v. Sirius XM Radio, No. 09-cv-10035 (S.D.N.Y.).

Distributed

Case

$3.6 billion

Independent Foreclosure Review

$1.5 billion

National Mortgage Settlement

$800 million

Naef v. Masonite Corp., No. CV 944033 (Ala. Cir. Ct. Mobile County).

$800 million

Microsoft I-V Cases, J.C.C.P. No. 4106 (Cal. Super. Ct. San Francisco County).

$762 million

In re American International Group, Inc. Securities Litigation, No. 04 Civ. 8141 (S.D.N.Y.). (PwC,
Company, Starr, and Gen Re Settlements)

Claims

Case

3.5 million

In re Compact Disc Minimum Advertised Price Antitrust Litigation, MDL No. 1361 (D. Me.).

3.2 million

In re American International Group, Inc. Securities Litigation, No. 04-cv-8141 (S.D.N.Y.) (Company,
PwC, Starr, and Gen Re settlements).

3 million

Abbott Infant Formula Settlements

2.8 million

Fogel v. Farmers Group, Inc., No. BC300142 (Cal. Super. Ct. Los Angeles County).

1.2 million

National Mortgage Settlement

Calls

Case

3.6 million

Independent Foreclosure Review

1.5 million

Dyson v. Flagstar Corp., No. DKC93-1503 (D. Md.).

1.4 million

National Mortgage Settlement

1.3 million

Abbott Infant Formula Settlements

1 million

Naef v. Masonite Corp., No. CV 94-4033 (Ala. Cir. Ct. Mobile County).

625 MARQUETTEAVENUE, SUITE 900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 25 of 57
Rust Consulting Qualifications Summary, 6

Data and System Security
The security of systems and applications and confidentiality of data are of utmost importance to Rust, our clients,
the parties to engagements we administer, and members of the public impacted by our operations. Thus Rust
actively protects its systems and mitigates potential threats by adhering to a comprehensive assortment of
security best practices, certifications, and audits that we refer to collectively as our “unified compliance posture.”
As part of our unified compliance posture, Rust:
 Has received from three federal agencies (CFPB, FTC, and SEC) an Authority to Utilize Controlled
Unclassified Information under the guidelines of FISMA and NIST 800-171.


Undergoes an annual SSAE18 SOC 2 Type II Report audit of our data and system security controls and
protocols.



Complies with applicable laws, such as the Sarbanes-Oxley Act (SOX), Gramm-Leach-Bliley Act (GLBA)
and the Health Insurance Portability and Accountability Act (HIPAA).



Continues to adhere to the (now invalidated) controls formerly known as the U.S.-E.U. Privacy Shield
Framework.



Adheres to documented and audited processes.



Maintains a business continuity plan to ensure uninterrupted, secure service.



Has implemented controls to prevent unauthorized access or disclosure, maintain data accuracy, and
ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of
our clients.



Has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the
information we process.



Processes personal information only in ways compatible with the purpose for which it was collected or
subsequently authorized to do.

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 26 of 57

Exhibit B

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 27 of 57

I
RUST
CONSULT

I NG

Senior Vice President

Tiffaney A. Janowicz, Esq.
625 Marquette Avenue, Suite 900
Minneapolis, MN 55402
M: 612.770.8805
E: tjanowicz@rustconsulting.com

Education & Certifications


J.D. William Mitchell College of Law, 1995 (St. Paul, MN)



B.S. Marketing Education University of Minnesota, 1990 (Minneapolis, MN)

Tiffaney Janowicz leads Rust’s consumer, product liability, and insurance and healthcare practice areas, with a
depth of experience in antitrust matters. She also has been recognized as a class action notice and claims
administration expert by state and federal courts.
Janowicz began her career as a consultant at Rust in 1996 and was promoted to senior vice president in 2003. In
her current role, Janowicz specializes in customer relations and strategic consultation on class action notice and
claims administration programs. She also provides guidance to a team of project management professionals who
handle projects within her practice areas. Rust’s clients benefit from her expertise in developing and executing
strategies designed to achieve their settlement administration goals.
Janowicz has overseen all aspects of hundreds of settlements, including many of the firm’s largest claimsprocessing matters. Examples include Microsoft’s antitrust settlements for the states of California, Iowa,
Minnesota, New York and Wisconsin, as well as the multi-district litigation claiming that companies fixed the price
of Dynamic Random Access Memory (DRAM) in the United States. Janowicz has also lead many of Rust’s
insurance-related settlements and a number of credit life settlements.

Recent Declarations


Hamm v. Sharp, No. 19-cv-488 (M.D. Fla.).



Marya v. Warner Chappell, No. CV 13-04460 (C.D. Cal.).



Gold v. Lumber Liquidators, No. 3:14-cv-05373 (N.D. Cal.).



Fleisher v. Phoenix, No. 11-cv-8405 (S.D.N.Y.).



Farar v. Bayer, No. 3:14-cv-04601 (N.D. Cal.).



Royal Mile Company v. UPMC, No. 2:10-cv-01609 (W.D. Penn.).

6 25 MARQUETTE AVENUE, SUITE 9 00

MI NNEAPOLIS, MN 5540 2

I 612.3 59.2000

I 6 12.3 59. 2050

RUSTCONSULT ING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 28 of 57



In re CenturyLink Sales Practices and Securities Litigation, MDL 17-2795 (D. Minn.).



Opalka v. Amalie Oil, No. 18-40605 (Fla. Cir. Ct. Miami-Dade County).

Case Experience
Following are some additional details of cases that Rust has administered under the leadership of Janowicz.


In re: CenturyLink Sales Practices and Securities Litigation, No. 17-2795 (D. Minn.). Rust received
several data files that constituted the class list and which included more than 17 million rows of
information. The data team at Rust concatenated that data, sent it to National Change of Address,
appended emails through a trace processes, and formatted the data to prepare for notification. Rust
ultimately sent notice of the settlement to 6.5 million potential class members via email, and 6.7 million via
First-Class Mail, eventually distributing 122,000 payments totaling nearly $8.5 million.



Parko v. Shell Oil Company, No. 3:12-cv-00336 (S.D. Ill.). Janowicz was personally appointed as the
neutral arbitrator in this $4.83 million class action settlement resolving claims against Shell and
ConocoPhillips over groundwater contamination in Roxana, Illinois.



Stinson v. The City of New York, No. 10 Civ. 4228 (S.D.N.Y.). In a major civil rights class action
settlement valued at up to $75 million, the City of New York agreed to provide compensation to class
members who received summonses from New York police officers that had been issued without probable
cause, allegedly in response to a summons quota within the NYPD. Rust mailed 922,000 notices and
managed a website that received 131,000 unique visitors.



Chaudhri v. Osram Sylvania, No. 11-CV-05504 (D. N.J.). A lawsuit claimed that Sylvania made
misrepresentations regarding the performance of certain premium automotive lighting. The notice
program used a mix of direct and media notice that included 1.6 million mailed postcards along with
television, radio, and Internet advertising. Rust mailed 1.4 million checks totaling $16 million; Sylvania
also changed the packaging for the covered products to address the issues in the lawsuit.



In re: Target Corporation Customer Data Security Breach Litigation, MDL No. 14-2522 (D. Minn.).
Plaintiffs claimed that Target did not adequately protect their payment card data and personal information
and that Target delayed in providing notice of a widespread data breach. Rust’s direct notice program
consisted of 12 million mailed notices and 71 million email notices.



In re Dynamic Random Memory (DRAM) Antitrust Litigation, MDL No. 1486 (N.D. Cal.). The lawsuits
combined into this multi-district litigation claimed that the Defendant companies fixed the price of DRAM
in the United States, causing individuals and businesses to pay more for DRAM and DRAM-containing
devices. The combined direct and indirect settlements totaled $310 million.



Maksimovic v. Sony of Canada Ltd., Ontario Superior Court of Justice, No. CV-11 425487-00CP.
This Canadian settlement resolved allegations that Sony failed to adequately safeguard the computer
systems used to provide the Sony PlayStation Network, the Qriocity service, and the Sony Online
Entertainment services, which were attacked by criminal intruders in April 2011. Rust managed the
translation of all materials into French and provided all documentation and communication in both English
and French. Rust also established a Canadian P.O. box for the matter and drop-shipped the mail to our
processing center in Minnesota.

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 29 of 57



In re Nutella Marketing and Sales Practices Litigation, No. 3:11-cv-01086-FLW-DEA (D.N.J.).
Plaintiffs claimed that Defendant Ferrero U.S.A., Inc. made representations through its marketing and
advertising of Nutella® brand hazelnut spread, improperly suggesting that Nutella is healthier than it
actually is. Rust placed notice of the settlement in magazines and banner ads on popular websites; the
settlement website received over 1 million visits and over a quarter million consumers filed claims.



In re Online DVD Rental Antitrust Litig., MDL No. 2029 (N.D. Cal.). Rust sent over 34 million email
notices to potential class members in this project. Rust has processed more than 1.1 million claims for gift
cards or cash benefit in this ongoing project. Rust also created a settlement website which has to-date
received over 2.2 million site visits.



Microsoft I-V Cases, J.C.C.P. No. 4106, (Cal. Super. Ct. S.F. County). Janowicz was responsible for
the design and management of the direct mail notice program that involved the mailing of 18 million
notice-and-claim form packages and deployment of 7 million email notices to a class consisting of
consumers who purchased at retail selected Microsoft software for use in California. During the first years
of the multi-year program, Janowicz was actively involved in the daily project activities and second in
project responsibility only to the company president. Janowicz was and continues to be responsible for
overseeing project management, claims and voucher processing, benefits and cy pres distribution, and
call center activities.



The Authors Guild, Inc. v. Google, Inc., No. 05-cv-8135 (S.D.N.Y.). Janowicz led and continues to lead
her team in the administration services provided this settlement involving rights-holders around the world.
Janowicz oversaw the translations of the claim forms and supporting materials and well as the provision
of telephone support in more than 30 languages. For this ongoing project, Rust’s CSRs assist rightsholders in claiming their books and inserts, responding to questions related to the complex settlement and
providing technical support throughout the online claims process.



Thompson v. Metropolitan Life, No. 00-CIV-5071 (W.D. Pa.). Janowicz was second in project
responsibility only to the company president in overseeing Rust’s provision of services for this settlement,
which included an estimated 25 million policies. Rust mailed more than 550,000 customized and 104,000
generic notices to potential class members. In this race-based underwriting insurance settlement, Rust
received 220,000 claim forms, forwarded them on a rolling basis to the company for their research into
class membership, and followed up on the company’s direction by mailing 80,000 “cure” letters and more
than 270,000 response letters to claimants. Rust’s call centers answered calls generated by both the
mailed notice and an extensive media campaign. During the national TV noticing campaign, there were
500 call center operators in two sites.



McNeil v. American General Life & Accident, No. 3:99-1157 (D. Tenn.). Janowicz was second in
project responsibility only to the company president in the management of Rust’s claims administration
services for a settlement covering 9 million class members. Rust mailed over 3 million notices within
approximately two weeks. Rust also arranged for an ad campaign to help reach class members for whom
the company did not have current addresses. Rust received 600,000 calls on this project, and printed and
mailed more than 440,000 payments.



Naef v. Masonite Corp., No. CV 944033 (Ala. Cir. Ct. Mobile County). Project involved receiving and
processing according to pre-determined criteria (including proof of property ownership, proof of product
ownership, and proof of damage) more than 400,000 claims, eventually distributing more than $800

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 30 of 57

million to more than 260,000 claimants whose claims were validated. Janowicz co-directed the initial
design of the claims intake process of this 10-year claims program, and managed claims review and
contact center operations.

Thought Leadership

















Co-Author, “The Plain Language Toolkit for Class Action Notice,” in A Practitioner’s Guide to Class
Actions, 3rd Ed. (Marcy Greer ed., 2021).
Speaker, “How to Get Your Notice Actually Noticed: Claims Stimulation 3.0,” Women Antitrust
Plaintiffs’ Attorneys, Napa, CA (June 2018).
Webinar Speaker, “Balancing Due Process and Claims: A Conversation on Strategies to Safeguard
Your Settlement,” American Association for Justice (Sept. 2016).
Speaker, “Balancing Due Process and Claims: A Conversation on Strategies to Safeguard Your
Settlement,” Plaintiffs’ Forum, Rancho Palos Verdes, CA (Apr. 2015).
Co-Author, “Estimating Claims – What Every Attorney Should Know,” What We’ve Noticed, Feb.
2015
Co-Author, “Increasing Judicial Attention to Claims-Filing Rates,” What We’ve Noticed, Oct. 2014
Co-Author, “The Case for Simplified Notice and Claims,” What We’ve Noticed, July 2014
Co-Author, “Tracking Ted…,” What We’ve Noticed, April 2014
Panelist, “Crafting Class Settlement Notice Programs: Due Process, Reach, Claims Rates, and
More – Minimizing Court Scrutiny and Overcoming Objector Challenges,” Strafford CLE Webinar,
Feb. 2014
Co-Author, “Efficient, Cost-Effective Notification and Administration in Antitrust Class Actions,”
Class Action Perspectives, 2013
Co-Author, “Recent Court Decisions Indicate Greater Scrutiny of Class Notice Programs,” What
We’ve Noticed, Dec. 2013
Panelist, “Mechanics, Logistics & Statistics: How to Settle a Class Action Lawsuit,” FDCC Section
Presentations for CLE 2013 Winter Program, March 2013
Panelist, “Emerging Trends in Class Action Notice,” CLE International 6th Annual Conference Class
Actions: Hot Topics, Winning Strategies and More, June 2010
Speaker, “Class Action Notice and Claims Administration: Trends and Innovation,” Women
Antitrust Plaintiffs' Attorneys Networking Event, Aug. 2009
Author, “Anticipating Claims Filing Rates in Class Action Settlements,” Class Action Perspectives,
Nov. 2008

Bar Admissions


Licensed to practice law in Minnesota

625 MARQUETTEAVENUE, SUITE900

MINNEAPOLIS, MN 55402

I 612.359.2000

I 612.359.2050

RUSTCONSULTING.COM

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 31 of 57

Exhibit C

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 32 of 57

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA

If you used Global Tel*Link services to speak by phone with someone in jail or prison
between 2011 and 2021, you could get money from a settlement.
A federal court directed this notice. This is not a solicitation from a lawyer. You are not being sued.
A Settlement has been reached in a class action lawsuit claiming Global Tel*Link (“GTL”)
improperly retained money that was deposited in prepaid “AdvancePay” accounts after the account
was inactive for 180 days or less. GTL denies any and all wrongdoing of any kind, and denies any
liability. The Court has not decided who is right.
The Settlement will provide either a credit or refund to current and former GTL customers.
Eligible Class Members may receive up to 100% of the money that was retained from their
account.
If you are a current or former GTL customer, your legal rights may be affected by the Settlement
whether you act or do not act. To determine if you are included in the Class, please review Section
6 below.
IMPORTANT: PLEASE READ THIS NOTICE CAREFULLY

A SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
CURRENT GTL CUSTOMERS: If you have an active AdvancePay account with GTL when the
settlement is finalized in mid to late 2022, you will
GET AUTOMATIC CREDIT
automatically receive a credit to your GTL account (see
Question 7 for more information).
FORMER GTL CUSTOMERS:
SUBMIT A CLAIM FORM

If you do not currently or will not have an active AdvancePay
account with GTL when the settlement is finalized in mid to
late 2022, you must file a claim by Month XX, 2022 to receive
a refund (see Question 8 for more information).

EXCLUDE YOURSELF

If you do not wish to be part of the Settlement, you may
request to be excluded no later than Month XX, 2022 and
receive no payment or credit from the Settlement. This is the
only option that allows you to be part of any other lawsuit
against GTL about the legal claims in the Settlement.

OBJECT

You may also write to the Court by Month XX, 2022 about
why you do not like the Settlement.

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

1

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 33 of 57
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA

GO TO A HEARING
(On Month XX, 2022)

You may ask to speak in Court about the fairness of the
Settlement.

DO NOTHING

You may give up your right to be part of this Settlement or any
other lawsuit against GTL about the legal claims in this
Settlement. Former GTL customer will receive no payment
(unless you reactivate your account within two years of final
approval – see Question 22).

These rights and options—and the deadlines to exercise them—are explained in this Notice.
The Court preliminarily approved the Settlement on Month XX, 2022. But the Court still must
decide whether to finally approve the Settlement after considering any objections and holding the
Fairness Hearing. If it does, and after any appeals are resolved, payments or credits will be
distributed to eligible Class Members. Please be patient.

W HAT T HIS N OTICE C ONTAINS

I

A. BASIC INFORMATION ............................................................................................................. [X]
1.
2.
3.
4.

Why is there a notice? ....................................................................................................
What is the Case about?
Why is this a class action?
Why is there a Settlement?

I

B. WHO IS PART OF THE SETTLEMENT ...................................................................................... [X]
5.
6.

Who is included in the Settlement?
What should I do if I am still not sure if I am included?

I

C. THE BENEFITS OF THE SETTLEMENT AND HOW TO MAKE A CLAIM ........................................ [X]
7.
8.
9.
10.

What benefits does the Settlement provide to the Class?
How do I get a refund?
How much will my refund be?
What happens after I file a Claim Form?

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

2

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 34 of 57

11. When will I receive my payment?

I

D. EXCLUDING YOURSELF FROM THE SETTLEMENT .................................................................... [X]
12. How do I get out of the Settlement?
13. If I exclude myself, can I still get a payment?
14. What am I giving up if I do not exclude myself?

I

E. THE LAWYERS REPRESENTING ALL CLASS MEMBERS ............................................................. [X]
15. Do I have a lawyer in the Case?
16. How will the lawyers be paid?

I

F. OBJECTING TO THE SETTLEMENT ............................................................................................. [X]
17. How do I tell the Court if I do not like the Settlement?
18. What is the difference between objecting and asking to be excluded?

I

G. THE COURT’S FAIRNESS HEARING........................................................................................... [X]
19. When and where will the Court decide whether to approve the Settlement?
20. Do I have to attend the hearing?
21. May I speak at the hearing?

I

H. IF YOU DO NOTHING ................................................................................................................ [X]
22. What happens if I do nothing at all?

I

I. GETTING MORE INFORMATION.................................................................................................. [X]
23. How do I get more information?

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

3

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 35 of 57

A.

BASIC INFORMATION

1. Why is there a notice?
This notice is to inform you about the proposed Settlement of a class action lawsuit and your rights
and options. This notice describes the lawsuit, the proposed Settlement, your legal rights, payments
(“refunds”) and credits that are available.
District Court Judge Amy Totenberg of the United States District Court for the Northern District
of Georgia is overseeing the proposed Settlement in the case titled Githieya, et al. v. Global Tel
Link Corp., Civil Action No. 1:15-cv-00986-AT (the “Case”). The proposed Settlement will
resolve the claims made against GTL in the Case. The persons who sued on behalf of the Class are
called the “Plaintiffs.” GTL is the “Defendant.”

2. What is this Case about?
The lawsuit claims that, between April 3, 2011, and October 6, 2021 (the “Class Period”), GTL
had an Inactivity Policy. This Policy allowed GTL to keep any money deposited into customers’
AdvancePay accounts that was not used for a period of 180 days or less. Plaintiffs claimed in the
lawsuit that GTL’s Inactivity Policy violated GTL’s contracts with its AdvancePay customers who
signed up using GTL’s automated telephone system and unjustly enriched GTL.
The Settlement resolves the Case. The Court has not decided who is right. Instead, the Parties
agreed to a Settlement. By agreeing to a Settlement, the Parties avoid the costs and risk of a trial
and the Class will get benefits described in the Settlement. The Class Representatives and their
attorneys believe that the Settlement is in the best interest of Class Members.

3. Why is this a class action?
In a class action, one or more people called “class representatives” sue on behalf of themselves
and people who have similar claims. The Class Representatives in this case are Benson Githieya,
Darlene Byers, the Estate of Nellie Lockett, Michelle Mendoza, Sarai Morris, Betty Davis, and
Adrian Mohamed. This notice refers to the Class Representatives as the “Plaintiffs.” The Plaintiffs
and the people who have similar claims are individual “Class Members” and, together, they are
the “Class.”

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

4

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 36 of 57

The Class in the Case is defined in Question 5 below. In a class action, one court resolves the
issues for everyone in the Class, except for those people who choose to exclude themselves from
the Class.

4. Why is there a Settlement?
GTL has denied all liability and wrongdoing in this case and has asserted various defenses to the
Plaintiffs’ claims. The Court has not decided in favor of the Plaintiffs or GTL. Instead, both sides
have agreed to a Settlement. That way, they avoid the cost and risk of a trial, and if the Settlement
is approved by the Court, Class Members will receive the refunds, credits, and other benefits of
the Settlement that are described in this notice sooner.
This Settlement is the product of extensive negotiations between lawyers for the Plaintiffs and
GTL. The Plaintiffs and Class Counsel think the Settlement is fair and in the best interests of all
Class Members.

B.

WHO IS PART OF THE SETTLEMENT

TO SEE IF YOU ARE AFFECTED BY THE SETTLEMENT,
YOU FIRST HAVE TO DETERMINE IF YOU ARE A CLASS MEMBER.

5. Who is included in the Settlement?
The Settlement Class includes:
All persons nationwide who (i) established and funded a prepaid account through
GTL’s interactive-voice-response (“IVR”) system and (ii) had a positive account
balance that was reduced to $0.00 due to account inactivity for 180 days or less on
or after April 3, 2011, and through and including October 6, 2021.
The following people are not members of the Class: (a) any Class Member who timely and validly
elects to be excluded from the Class in accordance with the procedure described in the Court’s
Preliminary Approval Order (the “Opt-Outs”); (b) GTL and its respective parents, subsidiaries,
divisions, affiliates, associated entities, business units, predecessors in interest, successors,
successors in interest, representatives, and each of their respective immediate family members; (c)
Class Counsel; and (c) the Judges who have presided over the Case and any related cases.

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

5

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 37 of 57

6. What should I do if I am still not sure if I am included in the Class?
If you are still not sure whether you are included in the Class, you can visit www.XXXXXX.com
or call 1-8XX-XXX-XXXX for more information. You may contact the Settlement Administrator
for further information or assistance at: PO Box 2627, Faribault, MN 55021-9627.

C.

THE BENEFITS OF THE SETTLEMENT
AND HOW TO MAKE A CLAIM

7. What benefits does the Settlement provide to the Class?
Under the Settlement, GTL has agreed to pay up to $67 million in refunds and credits (the
“Settlement Fund”) to reimburse Class Members for deposits retained under its Inactivity Policy.
The Settlement Fund will also be used to pay: attorneys’ fees and Class Counsel expenses, the
costs associated with administering the Settlement, and Plaintiffs for their service as Class
Representatives in this case.
GTL will reimburse Class Members for deposits taken under its Inactivity Policy in three ways:
1. Active AdvancePay Customers: GTL will automatically credit 100% of the amount of
money retained under the Inactivity Policy into the Class Member’s AdvancePay account.
These Class Members will receive credits without having to file a Claim Form. Please
note, you must have an active account at the time the Settlement funds are disbursed. We
estimate that this will occur in mid-to-late 2022, after the Court grants final approval to the
Settlement and any appeals have been resolved.
2. Former AdvancePay Customers - File a Valid Claim: GTL will refund 100% of the
amount of money GTL retained from the Class Members’ account under the Inactivity
Policy (see Question 8). If the total amount of credits and refunds to current and former
customers exceeds the remaining amount of the Settlement Fund, the refunds paid out will
be reduced proportionally.
3. Former AdvancePay Customers – Do Not File Claim But Reactivate Account: For
former customers who reactivate their AdvancePay accounts at any time during the two
years after the Settlement is approved by the Court, GTL will credit 100% of the amount
of money GTL retained from the Class Member’s account under the Inactivity Policy into
the Class Member’s AdvancePay account. If at any point during this two-year period the
QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

6

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 38 of 57

total amount of refunds and credits exceeds the remaining amount of the Settlement Fund,
GTL will stop providing automatic credits.
In addition to refunds and credits, GTL has also agreed in the Settlement to change its Inactivity
Policy in ways that benefit Class Members and others. This includes:
1. Lengthening the baseline Inactivity Policy that applies to most AdvancePay accounts from
90 days to 180 days.
2. Ensuring that customers affirmatively agree to the Inactivity Policy as a part of the account
sign-up process.
3. Disclosing the Inactivity Policy conspicuously in a banner on GTL’s website homepage,
in its automated telephone system, and in all of its advertising materials.
4. Providing notice by text message and email to customers who opt in before their accounts
will be subject to the Inactivity Policy.
5. Permitting customers to obtain a refund of any money remaining in their accounts while
the account remains active.
6. And training GTL’s customer-service personnel to fully disclose GTL’s Inactivity Policy
and its refund policies.
A complete description of the benefits that the Settlement provides can be found in the Settlement
Agreement, which is available at www.XXXXXX.com.

8. How do I get a refund if I don’t have an active GTL account?
To receive a refund, you must fill out and submit a Claim Form by Month XX, 2022.
If you are a Class Member who does not have an active AdvancePay Account and you do not
exclude yourself from the Settlement, you are eligible to receive a refund payment from the
Settlement Fund. To receive a refund, you must fill out and timely submit a Claim Form. Claim
Forms can be downloaded from www.XXXXXX.com, or you can obtain one by calling the tollfree number 1-8XX-XXX-XXXXX. To submit a Claim Form, either:
1. Mail the Claim Form by Month XX, 2022 to: GTL Settlement Administrator, PO Box
2627, Faribault, MN 55021-9627.
-orQUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

7

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 39 of 57

2. Submit a Claim Form online at www.XXXXXX.com by Month XX, 2022.
Please read the Claim Form carefully and provide all the information required. You may be asked
to verify the accuracy of the information provided in your Claim Form. Your claim must be valid
to receive a refund. If the Court approves the Settlement (see “The Court’s Fairness Hearing,”
Questions 18-20 below), refunds and credits will be distributed at a later date to members of the
Class who submit valid Claim Forms.

9. How much will my refund be?
Eligible current and former GTL customers will receive 100% of the money GTL retained from
their accounts under the Inactivity Policy. Current GTL customers will receive a credit to their
account and former GTL customers need to file a valid claim to receive a refund.
Important! Class Members who exclude themselves using the process outlined in Question 12
below will not get money from the Settlement Fund.

10. What happens after I submit a Claim Form?
GTL will provide refunds to Class Members with inactive accounts only if they timely submit a
Claim Form. Once a Claim Form is submitted, the Settlement Administrator will check the
AdvancePay account telephone number submitted on the Claim Form against GTL’s records (i) to
verify that the person submitting the Claim is a Class Member entitled to a refund and (ii) to
determine the amount of the Class Member’s refund.
There may be circumstances in which a person who submits a Claim Form will not be entitled to
a refund. For example, GTL’s records could show that the person submitting the Claim Form did
not set up their account using GTL’s automated telephone IVR system. Similarly, GTL’s records
could show that GTL did not retain any money from the person’s account under its Inactivity
Policy.
If you submit an incomplete Claim Form, the Settlement Administrator will contact you, and you
will have 21 days to fix it. If the Settlement Administrator is unable to confirm that you are a Class
Member and entitled to a refund relying on the information you provide on the Claim Form, the
Settlement Administrator will contact you, and you will have 30 days to produce records showing
the amount and validity of your claim to a refund. After reviewing any additional information, you
provide, the Settlement Administrator’s decision about the amount and validity of any claim to a
refund will be final.
QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

8

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 40 of 57

11. When will I receive my payment?
Refunds and credits will be made only after the Settlement Administrator resolves valid claims,
and the Court enters a Final Order and Judgment granting approval of the Settlement, as well as
after any appeals are resolved and the final approval of the Settlement is upheld. If there are
appeals, resolving them can take time. We do not know how much time it could take to resolve
any appeals that may be filed. Please be patient. If the Court does not approve the Settlement or
the Settlement is not approved in any appeal that may be brought, you will not receive a payment
or credit through this Settlement.
In addition, if your refund totals $600 or more, the law might require you to provide your Taxpayer
ID or a W-9 to the Settlement Administrator in order to comply with IRS reporting requirements.
If such information is required but you do not provide it within the specified time, then you will
lose the opportunity to obtain your refund. The Settlement Administrator will let you know
whether you need to provide your Taxpayer ID or a W-9. You do not need to include a Taxpayer
ID on your Claim Form.

D.

EXCLUDING YOURSELF FROM THE SETTLEMENT

12. How do I get out of the Settlement?
If you want to keep the right to sue or continue to sue GTL on your own about the legal issues
being resolved by the Settlement, then you must take steps to get out of the Class. This is called
excluding yourself or “opting out.” If you opt out of the Class, you will not receive any payment
from the Settlement.
To opt out of the Settlement, you must send a letter to: GTL Opt Outs, PO Box 2627, Faribault,
MN 55021-9627.
Your opt-out request must be personally signed by you and contain a statement that you are a
member of the Class but desire to be excluded. Your opt-out request must also contain the
following information: (i) your name; (ii) your current street address and email address (if any);
(iii) the phone number(s) associated with your AdvancePay account; (iv) and the name, address,
telephone number, and email address of your lawyer, if a lawyer is representing you in connection
with your opt-out.

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

9

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 41 of 57

Your opt-out request must be postmarked by Month XX, 2022. You cannot opt out by phone, by
email, or in any other way. If your request for exclusion is sent after the deadline, your request to
opt out will be considered invalid and you will not be excluded from the Class.
You may opt out of the Settlement Class only for yourself, not for anyone else.
Please Note: Unless you exclude yourself, if the Court approves the Settlement, you give up any
right to sue GTL for the claims that the Settlement resolves. If you have a pending lawsuit against
GTL, speak to your lawyer in that case immediately. You may need to exclude yourself from the
Settlement Class in order to continue your own lawsuit against GTL.

13. If I exclude myself, can I still get a payment?
No. If you exclude yourself from the Settlement, you will not receive a refund or credit from the
Settlement.

14. What am I giving up if I do not exclude myself?
Unless you exclude yourself using the process outlined in Question 12 above, you will remain in
the Class. If you remain in the Class, you cannot sue, continue to sue, or be part of any other
lawsuit against GTL related to its Inactivity Policy or any other claims that were or could have
been brought in the Case from April 3, 2011, to the date the Court finally approves the Settlement.
Section VI of the Settlement Agreement says:
If the Final Approval Order approving this Settlement Agreement becomes Final,
then the Class Plaintiffs, in consideration of this Settlement Agreement and the
benefits extended to the Settlement Class, on behalf of themselves, the Settlement
Class Members, and each Settlement Class Member, and his/her respective
successors, assigns, past, present, and future parents, subsidiaries, joint venturers,
partnerships, related companies, affiliates, directors, officers, shareholders,
employees, agents, representatives, servants, partners, executors, administrators,
assigns, predecessors, descendants, dependents, and heirs, fully release and forever
discharge the Released Parties from the Released Claims, arising on or before the
Effective Date.
That section of the Settlement Agreement also says:

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

10

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 42 of 57

This Agreement may be pleaded as a full and complete defense to, and may be used
as the basis for a temporary restraining order or preliminary or permanent
injunction against, any action, suit, or other proceeding, which has been or may be
instituted, prosecuted, continued to be prosecuted, or attempted, asserting any of
the Released Claims.
The words “Released Claims” are defined in the Settlement Agreement to mean “any and all claims
that were brought or could have been brought in the Action, including, but not limited to, any and
all claims arising out of or relating to the Inactivity Policy.”
The words “Released Parties” are defined in the Settlement Agreement to mean “Global Tel*Link
Corporation and its past and present parent companies, subsidiaries, joint ventures, partnerships,
affiliates, controlled entities, assignees, and all of their respective predecessors, assigns, and
successors-in-interest, and all of their respective present or former directors, officers, members,
shareholders, agents, employees, representatives, administrators, insurers, and indemnitees.”
The complete Settlement Agreement is available at www.XXXXXX.com, emailing
XXXXXX@XXXXXX.com, or writing to Settlement Administrator, PO Box 2627, Faribault, MN
55021-9627. The Settlement Agreement provides more detail about the release of claims with
specific legal terminology, so read it carefully.

E. THE LAWYERS REPRESENTING ALL CLASS MEMBERS
15. Do I have a lawyer in the Case?
Yes. The Court has appointed three law firms as “Class Counsel” to represent you and all other
Class Members. Those three firms are: (i) Caplan Cobb LLP; (ii) Goldstein, Borgen, Dardarian &
Ho; and (iii) Radford & Keebaugh, LLC.
You will not be charged for these lawyers’ services. Their attorneys’ fees and expenses will be
paid by GTL. If you want to be represented by another lawyer, you may hire one at your own
expense.

16. How will the lawyers be paid?
The Court has to approve any payment to Class Counsel. Class Counsel will ask the Court to
award up to $18,425,000 in attorneys’ fees, reimbursement of up to $250,000 in actual expenses
they have incurred in the Case, and an amount not to exceed $25,000 for each of the Plaintiffs.
The fees will compensate counsel for the six and a half years they spent pursuing the Case on
QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

11

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 43 of 57

behalf of the Class, and much of the work they will continue to do on the Case until the Settlement
Agreement terminates. The fees, costs, expenses, and payments awarded by the Court will be paid
by GTL out of the Settlement Fund.
Class Counsel’s request for attorneys’ fees, expenses and awards to the Plaintiffs will be on file
with the Court, and available for review at www.XXXXXX.com no later than Month XX, 2022.

F.

OBJECTING TO THE SETTLEMENT

17. How do I tell the Court if I do not like the Settlement?
If you are a Class Member (and do not opt out of the Class), and you do not agree with the
Settlement, you can object to any part of it. However, you can only ask the Court to deny approval
of the Settlement ¾ you cannot ask the Court to just change some part of it. To object, you must
submit a written document signed by you that includes the following:
1. Your name, address, telephone number, and email address (if you have one);
2. If a lawyer represents you in connection with your objection, the name, address, telephone
number, and email address of your counsel;
3. Any telephone number or numbers you used to receive calls on your AdvancePay Account;
4. A signed declaration stating that you are a member of the Settlement Class;
5. A clear statement in detail of all your objections to the Settlement;
6. Attach copies of any materials that you or your lawyer may submit at the Fairness Hearing;
and
7. A statement of whether you intend to appear at the Fairness Hearing, either with or without
counsel, and if with counsel, the name, address, telephone number, and email address of
your counsel who will attend.
You must file your objection with the Court and mail your objection by Month XX, 2022 to each
of the following:
Settlement Administrator
PO Box 2627

Class Counsel
Michael A. Caplan

GTL’s Counsel
Josh Belinfante

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

12

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 44 of 57

Faribault, MN 55021-9627

James W. Cobb
T. Brandon Waddell
CAPLAN COBB LLP
75 Fourteenth Street,
NE, Suite 2750
Atlanta, Georgia 30309

Jeremy U. Littlefield
Evan C. Dunn
ROBBINS ALLOY BELINFANTE
LITTLEFIELD LLC
500 14th Street, NW
Atlanta, Georgia 30318

18. What is the difference between objecting and asking to be excluded?
Objecting is telling the Court that you want her to reject the Settlement because you do not like
something about the Settlement. You can object to the Settlement only if you do not opt out.
Opting out is telling the Court that you do not want to be part of the Settlement. If you opt out, you
have no basis to object to the Settlement because it no longer affects you.

G. THE COURT’S FAIRNESS HEARING
The Court will hold a hearing to decide whether to approve the Settlement and Class Counsel’s
requests for fees and expenses and a payment to the Plaintiffs (the “Fairness Hearing”).

18. When and where will the Court decide whether to approve the Settlement?
The Court has scheduled a Fairness Hearing on Month XX, 2022, at X:XX xm at the United State
District Court for the Northern District of Georgia, in the Richard B. Russell Federal Building,
2211 United States Courthouse, 75 Ted Turner Drive, SW Atlanta, GA 30303-3309. The hearing
may be moved to a different date or time without additional notice.
At the Fairness Hearing, the Court will consider whether the Settlement is fair, reasonable, and
adequate and whether to approve Class Counsel’s request for attorneys’ fees and expenses and
awards to the Plaintiffs. If there are objections, the Court will consider them at that time. After the
Fairness Hearing, the Court will decide whether to approve the Settlement and the requests for
attorneys’ fees and expenses and awards to the Plaintiffs. We do not know how long these
decisions will take.

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

13

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 45 of 57

19. Do I have to attend the hearing?
No. Class Counsel will answer any questions the Court may have. But you are welcome to attend
the hearing at your own expense. If you send an objection, you do not have to come to Court to
talk about it. As long as you mailed your written objection on time, to the proper addresses, and it
complies with the other requirements listed in Question 17 above, the Court will consider it. You
also may pay your own lawyer to attend the hearing, but it is not necessary.

20. May I speak at the hearing?
You may ask the Court for permission to speak at the Fairness Hearing. To do so, your filed
objection must include a statement that you intend to appear at the Fairness Hearing.
You cannot speak at the hearing if you opt out of the Settlement.

H.

IF YOU DO NOTHING

21. What happens if I do nothing at all?
If you are a member of the Class and do nothing, you will remain in the Class and be bound by the
terms of the Settlement. If you do not have an active AdvancePay account, you will recieve no
money from the Settlement, although you may receive credits if you reactivate your account later.
Unless you opt out, you will not be able to start a lawsuit, continue with a lawsuit, or be part of
any other lawsuit, arbitration, or proceeding against GTL over the Released Claims.

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

14

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 46 of 57

I.

GETTING MORE INFORMATION

22. How do I get more information?
This notice summarizes the proposed Settlement. More details are in the Settlement Agreement,
which is available at www.XXXXXX.com, by calling 1-8XXX-XXX-XXXX, or writing to
Settlement Administrator, PO Box 2627, Faribault, MN 55021-9627. The Settlement Agreement
provides more detail about the release of claims with specific legal terminology, so read it
carefully.
PLEASE DO NOT WRITE OR CALL THE
COURT OR THE CLERK’S OFFICE FOR
INFORMATION.
DATED:

, 2021

BY ORDER OF THE COURT
UNITED STATES DISTRICT
COURT FOR THE NORTHERN
DISTRICT OF GEORGIA

QUESTIONS? VISIT www.XXXXXX.com OR CALL 1-8XX-XXX-XXXX TOLL-FREE

Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX

15

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 47 of 57

Exhibit D

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 48 of 57

To:
From:
Subject:

<<ClaimantEmailAddress>>
GTL Settlement Administrator
Global Tel*Link Settlement

If You Used Global Tel*Link Services to Receive Inmate Phone Calls
Between 2011 and 2021
You Could Get Benefits from a Settlement
Para una notificacion en espanol, visite www.XXXXXX.com o llame gratis al 1-8XX-XXX-XXXX
There is a class action Settlement with Global Tel*Link (“GTL”). The lawsuit claims that GTL improperly
retained money that was deposited in prepaid “AdvancePay” accounts after the account was inactive for 180 days
or less. GTL denies it did any and all wrongdoing of any kind, and denies any liability. GTL will provide up to
$67 million that will pay (1) credits/refunds to eligible Class Members, (2) the costs of notice and administration,
(3) attorneys’ fees and costs, and (4) special service payments to the Class Representatives. GTL has also agreed
to change its Inactivity Policy in ways to benefit the Class Members and others. Visit www.XXXXXX.com to
learn more about the Settlement.
Why Did I Receive This Notice? You received this notice because you may be a member of the Settlement
Class, if you (1) established and initially funded a prepaid account through GTL’s automated telephone system
(also called interactive-voice-response or IVR) and (2) had a positive account balance that was reduced to $0.00
due to account inactivity for 180 days or less from April 3, 2011, until October 6, 2021.
How Can I Get a Payment? If you have an active GTL AdvancePay account at the time the Settlement is finally
approved in mid to late 2022, you will receive an automatic credit to your account. If you have or will have an
inactive GTL AdvancePay account at the time the Settlement is approved, you need to submit a Claim Form
online or by mail by Month XX, 2022 to receive a refund. If you are not sure you will continue to use your GTL
AdvancePay account through 2022, you should file a claim. Anyone who has both active and inactive GTL
AdvancePay accounts will receive an automatic credit on their active account but will need to file a claim for their
inactive account(s) to get a refund.
GTL will credit or refund 100% of the amount that GTL retained from your account due to inactivity. Payments
to former customers may be reduced if the total credits/refunds exceed the available Settlement fund.
What Are My Rights? Even if you do nothing, you will be bound by the Court’s decisions. Former GTL
customers who do nothing will receive no refund (unless they reactivate their account within two years of
final approval and funds remain available, in which case they may be eligible to receive a credit). If you
want to keep your right to sue GTL yourself, you must exclude yourself from the Settlement by Month
XX, 2022. If you stay in the Settlement, but do not agree with the terms, you may object to it by Month
XX, 2022. The Court will hold a hearing on Month XX, 2022 to consider whether to approve the
Settlement, a request for attorneys’ fees and costs up to $18,675,000, and special service payments of
$25,000. You or your lawyer may appear and speak at the hearing at your own expense.
For more information or a Claim Form visit www.XXXXXX.com or call 1-8XX-XXX-XXXX.

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 49 of 57

Exhibit E

Case
1:15-cv-00986-AT Document 326-3
Filed 12/06/21 Page 50 of 57
approved, you need to submit a Claim Form online or by
There is a class action Settlement with Global Tel*Link
(“GTL”). The lawsuit claims that GTL improperly retained
money that was deposited in prepaid “AdvancePay”
accounts after the account was inactive for 180 days or
less. GTL denies any and all wrongdoing of any kind, and
denies any liability.
Who is included in the Settlement? The Class includes
anyone who (1) established and initially funded a prepaid
account through GTL’s automated telephone system (also
called interactive-voice-response or IVR) and (2) had a
positive account balance that was reduced to $0.00 due to
account inactivity for 180 days or less from April 3, 2011,
until October 6, 2021.

mail by Month XX, 2022 to receive a refund. If you are not
sure you will continue to use your GTL AdvancePay account
through 2022, you should file a claim. Anyone who has both
active and inactive GTL AdvancePay accounts will receive
an automatic credit on the active account but will need to file
a claim for their inactive account(s) to get a refund.

GTL will credit or refund 100% of the amount that GTL
retained from your account due to inactivity. Payments
to former customers may be reduced if the total credits/
refunds exceed the available Settlement fund.

What does the Settlement provide? GTL will provide up
to $67 million that will pay (1) credits/refunds to eligible
Class Members, (2) the costs of notice and administration,
(3) attorneys’ fees and costs, and (4) special service
payments to Class Representatives. GTL has also agreed to
change its Inactivity Policy to benefit Class Members and
others. Additional details are in the Settlement Agreement
available on the website.

What are my rights?
Even if you do nothing, you will be bound by the Court’s
decisions. Former GTL customers who do nothing will
receive no refund (unless they reactivate their account
within two years of final approval and funds remain
available, in which case they may be eligible to receive a
credit). If you want to keep your right to sue GTL yourself,
you must exclude yourself from the Settlement by Month
XX, 2022. If you stay in the Settlement but do not agree
with the terms, you may object to it by Month XX, 2022.

How can I get a payment? If you have an active GTL
AdvancePay account at the time the Settlement is finally
approved in mid to late 2022, you will receive an automatic
credit to your account. If you have or will have an inactive
GTL AdvancePay account at the time the Settlement is

The Court will hold a hearing on Month XX, 2022 to
consider whether to approve the Settlement, a request for
attorneys’ fees and costs up to $18,675,000, and special
service payments of $25,000. You or your lawyer may
appear and speak at the hearing at your own expense.

□
PLACE
CORRECT
POSTAGE
HERE

*clmnt_IDnO* - UAP - <<SequenceNo>>

SETTLEMENT ADMINISTRATOR
C/O RUST CONSULTING INC - 7513
PO BOX 2627
FARIBAULT, MN 55021-9627

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 51 of 57
Did you use Global Tel*Link
services to receive inmate phone
calls between 2011 and 2021?

SETTLEMENT ADMINISTRATOR
C/O RUST CONSULTING - 7513
PO BOX 2627
FARIBAULT, MN 55021-9627

□
PRESORTED
FIRST-CLASS MAIL
U.S. POSTAGE
PAID

You could get benefits from a
settlement

Rust Consulting, Inc.

Active GTL Account Customers: If
you have an active GTL account that you
created and funded through the automated
payment method of an interactive voice
response system (IVR), you may be eligible
to receive automatic credits.
Inactive GTL Account Customers: If you
do not have an active GTL account, but you
signed up for and funded a GTL account
using GTL’s IVR, the deadline to file a
claim for money is Month XX, 2022.
Go to www.XXXXXX.com or call toll-free
1-8XX-XXX-XXXX to get more detailed
information.
Para una notificacion en espanol, visite
www.XXXXXX.com o llame gratis al 1-8XXXXX-XXXX.

*CLMNT_IDNO* - UAP - <<SequenceNo>>
<<NAME1>>
<<NAME2>>
<<ADDRESS1>>
<<ADDRESS2>>
<<ADDRESS3>>
<<CITY>> <<STATE>> <<ZIP>>
<<COUNTRY>>

*BARCODE39* - <<SequenceNo>>

TO RECEIVE A PAYMENT UNDER THE SETTLEMENT,
YOU MUST COMPLETE AND RETURN THIS CARD
OR FILE YOUR CLAIM ONLINE BY MONTH XX, 2022

G L O B A L T E L* L I N K S E T T L E M E N T C L A I M F O R M

I. CLASS MEMBER INFORMATION:
Name:
Street Address:
City:

State:

Zip Code

Telephone Number: ( ---------)
Email: If this information changes, you MUST notify the Settlement Administrator in writing.
II. ADVANCEPAY ACCOUNT INFORMATION: Please provide the telephone number or numbers you used to receive calls from inmates
through your GTL AdvancePay Account from 2011 to 2021. This only includes accounts that were set up and initially funded using
the GTL automated telephone system (IVR).
III.
1.
2.
3.
4.

VERIFICATION: By signing below, you are verifying under penalty of perjury that:
The information provided in this Claim Form is accurate and complete;
You established and initially funded your AdvancePay Account using the GTL automated telephone system (IVR);
You owned the GTL AdvancePay Account(s) associated with the telephone number(s) above; and
You agree to submit to the jurisdiction of the U.S. District Court for the Northern District of Georgia, where the Case is pending,
for purposes of resolving any issues related to or arising from your Claim.

Signature:

*XXXX*

*CF*

*RUST*

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 52 of 57

Exhibit F

Legal Notice

86-AT Document 326-3 Filed 12/06/2
Did you use Global Tel*Link services
to receive inmate phone calls
between 2011 and 2021?

You could get benefits from a settlement
There is a class action Settlement with Global Tel*Link
(“GTL”). The lawsuit claims that GTL improperly
retained money that was deposited in prepaid
“AdvancePay” accounts after the account was inactive
for 180 days or less. GTL denies any and all wrongdoing
of any kind, and denies any liability.
Who is included in the Settlement?
The Class includes anyone who (1) established and
initially funded a prepaid account through GTL’s
automated telephone system (also called interactivevoice-response or IVR) and (2) had a positive account
balance that was reduced to $0.00 due to account
inactivity for 180 days or less from April 3, 2011, until
October 6, 2021.
What does the Settlement provide?
GTL will provide up to $67 million that will pay (1)
credits/refunds to eligible Class Members, (2) the costs of
notice and administration, (3) attorneys’ fees and costs,
and (4) special service payments to Class Representatives.
GTL has also agreed to change its Inactivity Policy to
benefit Class Members and others. Additional details are
in the Settlement Agreement available on the website.
How can I get a payment?
If you have an active GTL AdvancePay account at the time
the Settlement is finally approved in mid to late 2022, you
will receive an automatic credit to your account. If you
have or will have an inactive GTL AdvancePay account
at the time the Settlement is approved, you need to submit
a Claim Form online or by mail by Month XX, 2022 to
receive a refund. If you are not sure you will continue to use
your GTL AdvancePay account through 2022, you should
file a claim. Anyone who has both active and inactive GTL
AdvancePay accounts will receive an automatic credit on
the active account but will need to file a claim for their
inactive account(s) to get a refund.
GTL will credit or refund 100% of the amount that GTL
retained from your account due to inactivity. Payments
to former customers may be reduced if the total credits/
refunds exceed the available Settlement fund.
What are my rights?
Even if you do nothing, you will be bound by the Court’s
decisions. Former GTL customers who do nothing will
receive no refund (unless they reactivate their account
within two years of final approval and funds remain
available, in which case they may be eligible to receive
a credit). If you want to keep your right to sue GTL
yourself, you must exclude yourself from the Settlement
by Month XX, 2022. If you stay in the Settlement but do
not agree with the terms, you may object to it by Month
XX, 2022.
The Court will hold a hearing on Month XX, 2022 to
consider whether to approve the Settlement, a request for
attorneys’ fees and costs up to $18,675,000, and special
service payments of $25,000. You or your lawyer may
appear and speak at the hearing at your own expense.

For More Information:
1-8XX-XXX-XXXX
www.XXXXXX.com

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 54 of 57

Exhibit G

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 55 of 57

To:
From:
Subject:

<<ClaimantEmailAddress>>
GTL Settlement Administrator

Claim Money Now in GTL Settlement

Global Tel*Link Settlement
File a Claim Now to Get a Refund
You previously received notice of a Settlement in a case involving Global Tel*Link services that
were used to receive inmate phone calls between 2011 and 2021. This is a reminder that you must
submit a Claim Form to get a refund if you have an inactive ActivePay account.
Who’s Included? Anyone who (1) established and initially funded a prepaid account through
GTL’s automatic telephone system (also called interactive-voice-response or IVR) and (2) had a
positive account balance that was reduced to $0.00 due to account inactivity for 180 days or less
from April 3, 2011, until October 6, 2021.
What Can You Get? GTL will credit or refund 100% of the amount that GTL retained from your
account due to inactivity. Payments to former customers may be reduced if the total credits/refunds
exceed the available Settlement fund.
How to Get a Payment. File a Claim Form by mail or online to get a refund. The Claim Form is
available at the www.XXXXXX.com or by calling 1-8XX-XXX-XXXX.
The deadline to submit a Claim Form is Month XX, 2022.

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 56 of 57

Exhibit H

Case 1:15-cv-00986-AT Document 326-3 Filed 12/06/21 Page 57 of 57
SETTLEMENT ADMINISTRATOR
C/O RUST CONSULTING INC - 7513
PO BOX 2627
FARIBAULT MN 55021-9627

FOR OFFIC I AL USE ON LY

03

IMPORTANT LEGAL MATERIALS

Page 1of 1

GLOBAL TEL*LINK SETTLEMENT CLAIM FORM
This Claim Form must be submitted online or mailed and postmarked by Month XX, 2022. To be eligible for a refund, you
must be a Settlement Class Member. If you are not sure you will continue to use your GTL AdvancePay Account through
2022, you should file a claim. Please review the Notice at www.XXXXXXX.com to learn more.
I. CLASS MEMBER INFORMATION
Name:

________________________________________________________________________________

Street Address:

________________________________________________________________________________

City:

________________________________

Telephone Number:

(__ __ __) __ __ __ - __ __ __ __

State:

____ ____

Zip Code:

________________

Email:

_______________________________________

If this information changes, you MUST notify the Settlement Administrator in writing.
II. ADVANCEPAY ACCOUNT INFORMATION
Please provide the telephone number or numbers you used to receive calls from inmates through your GTL AdvancePay
Account from 2011 to 2021. This only includes accounts that were set up and initially funded using the GTL automated
telephone system (IVR).
(__ __ __) __ __ __ - __ __ __ __

(__ __ __) __ __ __ - __ __ __ __

(__ __ __) __ __ __ - __ __ __ __

(__ __ __) __ __ __ - __ __ __ __

(__ __ __) __ __ __ - __ __ __ __

(__ __ __) __ __ __ - __ __ __ __

III. VERIFICATION
By signing below, you are verifying under penalty of perjury that:
1. The information provided in this Claim Form is accurate and complete;
2. You established and initially funded your AdvancePay Account using the GTL automated telephone system (IVR);
3. You owned the GTL AdvancePay Account(s) associated with the telephone number(s) above; and
4. You agree to submit to the jurisdiction of the District Court for the Northern District of Georgia, where the Case is
pending, for purposes of resolving any issues related to or arising from your Claim.
Signature:
Questions? Call 1-8XX-XXX-XXXX or visit www.XXXXXXX.com
YOU MUST COMPLETE AND SUBMIT THIS CLAIM FORM BY MONTH XX, 2022, TO:
Settlement Administrator
c/o Rust Consulting, Inc. - 7513
PO Box 2627
Faribault MN 55021-9627

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