Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64470 Filed 05/27/21 Page 1 of 18
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
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`In Re Flint Water Cases,
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`No.: 5:16-cv-10444-JEL-MKM
`(consolidated)
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`Hon. Judith E. Levy
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`Magistrate Mona K. Majzoub
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`CO-LIAISON COUNSEL’S BRIEF IN SUPPORT OF FINAL APPROVAL
`OF THE PROPOSED SETTLEMENT
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`Co-Liaison Counsel hereby submit this memorandum of law in support of
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`Plaintiffs’ Motion for Final Approval of Settlement, and in response to certain
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`“objections1” to the extent they address issues related to the individual non-class
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`claimants and that portion of the settlement. As explained more thoroughly herein,
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`Co-Liaison Counsel respectfully requests that the Court enter a final order approving
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`the Settlement and for such other and further relief the Court deems just and proper.
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`Dated: May 27, 2021
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` Respectfully submitted,
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`1 Article XX of the Amended Master Settlement Agreement (AMSA) allows eligible
`claimants to file objections to the AMSA, however the AMSA provides only one option to those
`voicing objections i.e., to not register. See Article XX.
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64471 Filed 05/27/21 Page 2 of 18
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`NAPOLI SHKOLNIK
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`By: /s/ Hunter Shkolnik
`Hunter J. Shkolnik, Esq.
`Paul Napoli, Esq.
`270 Munoz Rivera Avenue
`Hato Rey, Puerto Rico 00918
`(833) 271-4502
`hunter@nsprlaw.com
`pnapoli@nsprlaw.com
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`Patrick Lanciotti, Esq.
`360 Lexington Avenue, 11th Floor
`New York, NY 10017
`(212) 397-1000
`planciotti@napolilaw.com
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`LEVY KONIGSBERG, LLP
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`By: /s/ Corey M. Stern
`Corey M. Stern, Esq.
`800 Third Avenue
`Suite 11th Floor
`New York, NY, 10022
`(212) 605-6200
`cstern@levylaw.com
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`Co-Liaison Counsel for Individual
`Plaintiffs
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64472 Filed 05/27/21 Page 3 of 18
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`TABLE OF CONTENTS
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`PRELIMINARY STATEMENT ............................................................................... 1
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`FACTUAL BACKGROUND .................................................................................... 2
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`ARGUMENT ............................................................................................................. 5
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`I. SETTLING PARTIES HAVE MET THE WALK-AWAY PROVISIONS .... 5
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`II. THE OBJECTIONS OF THE INDIVIDUAL CLAIMANTS ARE
`WITHOUT MERIT .......................................................................................... 7
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`A.
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` Objections to the Program are not motivated by facts. ..................... 8
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`B.
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` Objections to the Program have been addressed by Experts and
`Scientific Research. ........................................................................... 9
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`CONCLUSION ........................................................................................................14
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64473 Filed 05/27/21 Page 4 of 18
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`PRELIMINARY STATEMENT
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`Co-Liaison Counsel hereby submit this memorandum of law in support of
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`Plaintiffs’ Motion for Final Approval of the Settlement. As signatories to the AMSA
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`Co-Liaison Counsel, firmly believe the settlement is fair, reasonable, and equitable.
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`This Court should approve all aspects of this landmark settlement that closes a
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`chapter in the Flint Water Crisis. The undersigned consider it important to separately
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`address certain issues that are not class related. This brief focuses on the individual
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`components of the proposed Settlement and various filed objections.
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`Under the terms of the AMSA, the only basis to deny approve of the individual
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`component of the settlement, which accounts for 85% of the total monies available
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`under the AMSA, is if a Settling Defendant is able to exercise it’s “walkaway rights”.
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`See generally Section 18. These “walkaway rights” can be exercised by the State of
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`Michigan and the other Settling Defendants if there was a failure to meet various
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`“Registration” thresholds. Id. Upon information and belief, and after extensive
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`interaction with the Special Master and the Settlement Administrator, that except for
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`the Legionella portion of the settlement as limited to Settling Defendant McLaren
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`Hospital, the registration numbers far surpassed the required the walkaway trigger
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`and, therefore, the non-class portion of the Settlement should be approved and
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`become binding as to the remaining Settling Defendants.2
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`2 As of this filing, ARCHER Systems, LLC has not completed its review of the registered
`claimant information as it pertains to persons listed on Exhibit 12 of the AMSA – those who have
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64474 Filed 05/27/21 Page 5 of 18
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`FACTUAL BACKGROUND
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`The Master Settlement Agreement (“MSA”) was filed on November 17, 2020.
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`ECF No. 1319-1. The Amended Master Settlement Agreement (“AMSA”) was filed
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`on January 15, 2021. ECF No. 1393-2. The Settlement Agreement is the product of
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`the extensive mediation efforts in numerous sessions and communications over a
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`period of more than two years. These efforts facilitated a prudent, fair, and
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`reasonable resolution of vigorously litigated, factually, and legally complicated
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`disputes, in the best interest of all individual plaintiffs.
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`The proposed Settlement establishes a hybrid structure that includes both a
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`Class Action component and an individual (“non-class”) traditional mass tort
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`settlement that is triggered by a participation rate methodology. As this Court stated
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`in the Opinion and Order Granting Preliminary Approval (ECF NO. 1399)
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`(hereinafter the “Preliminary Approval Order”), “[t]he proposed settlement creates
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`a comprehensive settlement program that will address all individually represented
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`persons and all Minors (both represented and unrepresented.)” Preliminary Approval
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`Order, ECF No. 1399, PageID.54400.
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`Final approval of an adult claimants’ non-class personal injury lawsuit
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`typically does not require final approval. However, due to the hybrid structure of the
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`submitted a notice of intention to file a claim under the Michigan Court of Claims Act, Mich.
`Comp. Laws § 600.6431. See MSA ¶ 18.1.2.
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`2
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64475 Filed 05/27/21 Page 6 of 18
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`proposed Settlement which includes a class component and claims for Minors and
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`LII, this Court found that “preliminary approval of certain aspects of the proposed
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`settlement is both appropriate and necessary.” Preliminary Approval Order, ECF No.
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`1399, PageID.54402. Claims will be evaluated on the same objective factors,
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`including “as age, exposure to the water, test results, specific identified injuries,
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`property ownership or lease, payment of water bills, and commercial losses.”
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`Preliminary Approval Order, ECF No. 1399, PageID.54400. Further, the hybrid
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`structure calls for horizontal equity in that “compensation will be the same for
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`similarly situated individuals and entities—regardless of whether they are
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`represented, unrepresented, or are a member of the ‘class.’” Preliminary Approval
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`Order, ECF No. 1399, PageID.54400
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`Under the traditional mass tort component children and claimants who are
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`represented by a private attorney under a valid Michigan Contingency Fee Contract
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`were allowed to decide if they wish to voluntarily join into the mass tort settlement
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`program by “registering” for inclusion. See AMSA ¶ XX. This section of the AMSA
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`allowed registration for the following groups: (1) children, through their appropriate
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`representatives, may directly register to participate in the Settlement, (2) certain
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`Adults who retained counsel may proceed individually, and (3) Settlement
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`Subclasses, defined in the Settlement Agreement, will allow Adults, property
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`owners, and businesses in Flint to submit claims for relief. Among other provisions
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`set forth in Plaintiffs’ Motion for Preliminary Approval, the Master Settlement
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64476 Filed 05/27/21 Page 7 of 18
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`Agreement also provides a process for the settlement of claims of Minors and
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`Legally Incapacitated or Incompetent Individuals (“LII”).
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`As the Court is aware, the Settlement seeks to provide relief to the Flint
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`community for injuries stemming from exposure to hazardous water during the
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`relevant time frame. Plaintiffs have reached an agreement to resolve claims against
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`the State of Michigan and other Settling Defendants that would result in a Court-
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`monitored Qualified Settlement Fund of more than $640 million. The Settlement
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`provides for the establishing of several Sub-Qualified Settlement Funds for the
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`benefit of individuals who were minor children at the time of the crisis and thus more
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`susceptible to the hazards of lead exposure and related injury. Under the terms of the
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`AMSA this comprises approximately 79.5% of the Settlement Amount after
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`attorneys’ fees and costs. AMSA ¶ 5.2. To be eligible for compensation, Minors
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`must register and submit a claim. The registration and claims process is described
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`more fully in Plaintiffs’ Motion for Preliminary Approval. The Settlement does not
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`deprive non-settling minors of the opportunity to continue to pursue claims. Thus,
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`minors who do not register or submit a claim during the claims period are not parties
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`to the settlement and do not release or relinquish potential claims against any of the
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`Settling Defendants. See AMSA ¶ 6.1.
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`The Settlement also provides for a hybrid class component that provides for
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`the resolution of claims made by Flint Adults, property owners, lessees, and persons
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`legally responsible for the payment of water bills, and businesses, who will be
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64477 Filed 05/27/21 Page 8 of 18
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`eligible to make claims from the compensation fund for personal injuries, and
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`property and business damages. Id. ¶ 3.5. Those persons, who were represented by
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`lawyers during the pendency of settlement negotiations – all of whom are listed in
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`Exhibit 1 to the Settlement Agreement – were able to directly register to participate
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`in the Settlement, while all others have been considered members of the Settlement
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`Class and Subclasses.
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`ARGUMENT
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`I.
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`SETTLING PARTIES HAVE MET THE WALK-AWAY PROVISIONS
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`The AMSA provides each Settling Defendant with certain walk-away rights
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`to rescind, terminate, or cancel the Settlement if certain provisions are not met. See
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`generally AMSA, Article XVIII. The deadline to register into the Settlement was
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`March 29, 2021. See Opinion and Order Granting Preliminary Approval, ECF No.
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`1399, PageID.54467. Since that time, 50,614 unique individuals have registered. See
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`Notice of the Special Master Regarding Update on Registration Process for
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`Amended Settlement Agreement (ECF No. 1790, PageID.64248). With respect to
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`the non-class claims, below is a chart summarizing the circumstances under the
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`AMSA that would permit the Settling Defendants to terminate the Settlement
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`Agreement, and a summary of how the Individual Plaintiffs satisfied these
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`provisions.3
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`3 The AMSA provides the McLaren Defendants the “right to rescind, terminate, or cancel this
`Settlement Agreement as to the McLaren Defendants only if any of the persons listed on Exhibit
`19 who allege exposure to Legionella at McLaren Flint Hospital during the period of April 25,
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64478 Filed 05/27/21 Page 9 of 18
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`Walk-Away Provision under AMSA
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`More than five (5) percent of the Individual Plaintiffs listed on
`Exhibit 14 fail to timely register and provide required information to
`participate as a Claimant in the Settlement Program. AMSA ¶ 18.1.1.
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`More than seven (7) percent of the persons listed on Exhibit 12, who
`have submitted a notice of intention to file a claim under the Michigan
`Court of Claims Act, Mich. Comp. Laws § 600.6431 alleging
`personal injury, property damage, or business economic loss as a
`result of exposure to water received from the Flint Water Treatment
`Plant, fail to timely register and provide required information to
`participate as a Claimant in the Settlement Program. AMSA ¶ 18.1.2.
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`More than eight (8) percent of the persons listed on Exhibit 13, who
`have retained an attorney but have not filed claims in any court or
`filed a notice of intention to file a claim under the Michigan Court of
`Claims Act or the Federal Tort Claims Act alleging personal injury,
`property damage, or business economic loss as a result of exposure
`to water received from the Flint Water Treatment Plant or were
`legally liable for the payment of bills for such water fail to timely
`register and provide required information to participate as a Claimant
`in the Settlement Program. AMSA ¶ 18.1.3.
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`If fewer than 95% of the Minor Children, Minor Adolescent, and
`Minor Teens listed on the last Interim Report of the Special Master
`Regarding Data Compilation Based on Responses to the Amended
`Order Regarding Collection of Data, to be filed before the Federal
`Court enters the Preliminary Approval Orders relating to this
`Settlement Agreement register and provide required information to
`participate as a Claimant in the Settlement Program. AMSA ¶ 18.1.4.
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`Registration
`Response
`2.95% have not
`registered
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`ARCHER
`Systems, LLC is
`reviewing the
`registered
`claimant
`information
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`4.14% have not
`registered
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`98.1% have
`registered
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`2014 through December 31, 2018 fail to timely register and provide required information to
`participate as a Claimant in the Settlement Program.” AMSA ¶ 18.2.
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`4 ECF No. 1319-2, PageID.40413.
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64479 Filed 05/27/21 Page 10 of 18
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`As outlined in the above chart, it appears that the Settling Parties have met the
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`walk-away provisions as agreed upon in the AMSA. In fact, the massive outpouring
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`of support as shown by the registration numbers in of themselves support the
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`conclusion that this settlement was widely accepted by the Flint community. Over
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`50,000 individuals have determined that they want this settlement approved. Of
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`equal if not greater import is that only a negligible number of “objections” were filed
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`and of those many actually registered to participate in the settlement yet chose to
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`voice “objections’ to minor aspects of the settlement.
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`The Settlement should be approved as fair and reasonable as to the Individual
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`Claimants because it provides settlement participants with valuable consideration
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`and it was accepted by the overwhelming number of the eligible claimants who chose
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`to register and to participate.
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`II. THE OBJECTIONS OF THE INDIVIDUAL CLAIMANTS ARE
`WITHOUT MERIT
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`The objections filed against the Settlement do not warrant denial of final
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`approval because they are without merit. The objections pertain mainly to the X-Ray
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`Fluorescence bone lead testing program (hereinafter the “Program”) implemented in
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`Flint. On May 25, 2021, Co-Liaison Counsel filed its memorandum of law in
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`opposition to the Washington and Chapman Plaintiffs’ Motion to Extend the 90-Day
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`Deadline regarding Bone Scanning and submission of medical linking reports (ECF.
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`No. 1789) (hereinafter the “Co-Liaison Counsel’s Response to Objections”). Co-
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64480 Filed 05/27/21 Page 11 of 18
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`Liaison Counsel’s Response to Objections details exactly why the Hall, Washington,
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`and Chapman objections to the Program are without merit. Co-Liaison Counsel
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`incorporate that submission herein. The relevant points are as follows:
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`A. Objections to the Program are not motivated by facts.
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`Counsel for Chapman and Washington, in the above-mentioned Motion to
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`Extend the 90-day Deadline (hereinafter the “Motion to Extend”) objected to the
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`Program as an excuse for their failures to adequately represent their clients. The
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`Program was available to their clients during the period set by the Court’s
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`Preliminary Approval Order (ECF No. 1399), but they did not encourage their clients
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`to participate in the Program by scheduling bone lead tests. Instead, they objected to
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`the Program – their objections ranged from the need for more access to the Program,
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`to the Program’s safety and transparency, and the cost of the Program. None of their
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`objections have been substantiated by facts and evidence, whether in the form of
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`scientific research or expert declarations.
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`Objecting Counsel were aware, or should have been well aware, of the need
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`to establish causation and damages in a complex environmental case such the Flint
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`Water Crisis Litigation. They also should have been aware of the challenges
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`involved in establishing causation and damages. Moreover, one of the Objecting
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`Counsel told this Court on October 30, 2020 that he is no stranger to the testing and
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`that he contacted Mt. Sinai in 2016 “to explore whether it’s feasible to use it in Flint.”
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`(Dkt. No. 1312, p. 26, lines 22 to 25). All this points to the simple assertion that
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64481 Filed 05/27/21 Page 12 of 18
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`objections to the Program are without merit. The objections are not based on facts,
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`but rather a lack of preparedness and proper representation of their clients by the
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`objectors. Several other lawyers’ clients have successfully availed themselves of the
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`Program. See Exhibit C, Exhibit D, and Exhibit F of the Opposition (ECF No. 1789).
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`These are declarations from Attorneys Ben Crump, Ari Kresch, and Paul Napoli, all
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`of whom represent several thousand plaintiffs in the Flint Water Crisis Litigation.
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`They affirm that the Program was made available to their clients, and clients of other
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`firms. Further, Attorneys Ben Crump and Ari Kresch investigated the Program. They
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`concluded it is a safe and accurate method to test for exposure to lead and
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`recommended them to 1000s of their clients.
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`Simply put, the objections to the Program are without merit and do not warrant
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`denial of final approval.
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`B. Objections to the Program have been addressed by Experts and
`Scientific Research.
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`Co-Liaison Counsel’s Response to Objections addresses objections to the
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`Program by presenting the Court with affidavits and reports from relevant experts.
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`The Program was implemented under the leadership of Harvard University’s
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`Aaron Specht, PhD., and overseen by New York University’s Medical Director Dr.
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`Michael Weitzman. Dr. Aaron Specht is a research associate at the Harvard T.H.
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`Chan School of Public Health in Boston, and he has dedicated his career to
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`researching and developing application of a non-invasive X-ray Fluorescence
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64482 Filed 05/27/21 Page 13 of 18
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`(“XRF”) technology to quantify lead in human bones. Aaron Specht has worked with
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`the inventor of the XRF device to customize the device so it can be used safely on
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`humans. The procedure and device are the same as that used in validation and
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`research studies. It has been internally reviewed and approved at Purdue University
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`and Harvard University. Dr. Specht explains that the Program is (1) not a research
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`project because the sole purpose is to determine levels of lead exposures for litigation
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`purposes, (2) scientific research proves that objections to the Program are false, and
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`(3) the radiation dose associated with the test is significantly less than that associated
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`with a common x-ray procedure and is “equivalent to 9 hours of natural background
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`radiation sources which are unavoidable exposures to everyone.” See Exhibit A,
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`Affidavit of Dr. Aaron Specht.
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`The XRF device used in the Program does not need to be approved by the
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`Food and Drug Administration (“FDA”), as confirmed by Michael Drues, PhD.
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`Michael Drues is an independent regulatory consultant who has worked in the
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`medical device industry for over 25 years. He has been involved in designing and
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`testing a wide variety of medical devices and is familiar with their regulatory
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`requirements. He is extremely well-versed in the FDA regulations pertaining to
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`medical devices. After his review of the Program and the portable x-ray fluorescence
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`device used, he concludes that the Program is not intended to diagnose or treat a
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`medical condition., Therefore, the device does not need to be approved for use by
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`the FDA. See Exhibit B, Expert Report by Michael Drues, Ph.D.
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64483 Filed 05/27/21 Page 14 of 18
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`The American College of Obstetricians and Gynecologists recommends the
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`use of diagnostic imaging procedures such as CT scans and x-rays during pregnancy,
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`procedures which emit a much higher dose of radiation than does a bone lead test
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`from the XRF device. See Exhibit A of Co-Liaison Counsel’s Response to
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`Objections, Declaration of William Bithoney, MD, FAAP (ECF No. 1789-2). Dr.
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`Bithoney is a leading pediatrician with over thirty-five (35) years of experience,
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`including academics and consulting positions pertaining to pediatrics. He explains
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`that radiation exposure from the XRF bone lead test is negligible and the risk
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`associated with the test is negligible. He states, “the radiation dose these children
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`receive is less than what they would receive simply by taking a typical airplane ride,
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`which exposes us to approximately 0.003 millisieverts per hour, or about 3.0 micro-
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`sievert’s per hour, approximately the same amount of exposure to radiation a child
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`receives during the XRF bone test.” ECF No. 1789-2, PageID.64065. His
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`Declaration identifies a similar Program at Boston Children’s Hospital – Nuclear
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`Medicine and Molecular Imaging Program for bone scan tests on children, which is
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`ensured to be safe. Based on his education and experience in pediatric medicine and
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`health, he concludes that the Program is safe and an accurate means of measuring
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`long-term lead exposure.
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`Professional radiation safety specialist and consultant Walt Cofer confirms
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`that the Program implemented in Flint “conforms to applicable requirements of the
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`Michigan radiation control regulations. The x-ray safety program is comprehensive
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`and applies best safety practices.” ECF No. 1789-3, PageID.64100. Walt Cofer has
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`over thirty (30) years of experience, including Sr. Health Physicist/Environmental
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`Specialist at the Florida Department of Health, Bureau of Radiation Control
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`Radioactive Materials. He is extremely well versed in radiation related regulations
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`and confirms that (1) the Program conforms to the applicable regulations, (2) Dr.
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`Specht has established the appropriate protocols and practices to ensure compliance,
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`(3) the radiation dose associated with the test is within the approved limits and is so
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`negligible that it is has to quantify the risk involved, and (4) overall, the program is
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`a safe and compliant method of measuring long-term lead exposure. See Exhibit B
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`of Co-Liaison Counsel’s Objection, Declaration of Walt Cofer, ECF No. 1789-3.
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`Yuwonia Speights-Beaugard, a registered radiology technician who has
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`worked at Hurley Medical Center as the Director of Radiological Services from 2015
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`to 2019 affirms that the Program is safe and an accurate means of measuring long
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`term lead exposure. She visited Co-Liaison Counsel’s Flint Center to observe the
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`Program in operation. She confirmed that the Program followed best practices and
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`the proper protocols when administering the test and that “all the protocols that
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`would be followed at Hurley and the other places I worked for testing children and
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`adults were followed at this facility.” ECF No. 1789-6, PageID.64123. Ms. Speights-
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`Beaugard further declared radiation dose emitted from the test was significantly less
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`than what test-takers are exposed to, including children, from x-rays machines, CT
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64485 Filed 05/27/21 Page 16 of 18
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`scans, and MRI scans. See Exhibit E of Co-Liaison Counsels Response to
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`Objections, Declaration of Yuwonia Speights-Beaugard, ECF No. 1789-6.
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`Expert report from Jon Merz, Associate Professor in the Department of
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`Medical Ethics & Health Policy at University of Pennsylvania explains how the
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`Program does not comprise research or a clinical trial. He refutes objections made
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`by Dr. Lawrence A. Reynold, particularly that the Program is not approved by any
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`regulatory agency and that the Program comprises research. His report outlines what
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`comprises research or a clinical trial and then explains how the Program does not fit
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`into that description. “[I]t is my opinion that the Test Protocol is being implemented
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`for the sole purpose of determining children’s exposure for litigation settlement
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`purposes and does not comprise research” he concluded. See Exhibit G of Co-
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`Liaison Counsel’s Response to Objections, Report of Jon Merz, ECF No. 1789-8,
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`PageID.64190.
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`Reginald Davidson is the manager of Co-Liaison Counsel’s Flint Center
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`where the Program is operated. He oversees the day-to-day operations of the Center.
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`Mr. Davidson declares that the staff administering the tests are registered nurses or
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`certified nurse assistances who have been properly trained by Dr. Specht. The Center
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`is compliant with all the required COVID-19 protocols relating to cleanliness and
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`hygiene and is professionally cleaned periodically. Further, the Center is
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`appropriately zoned to operate as an office or a clinic. See Exhibit H of Co-Liaison
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`Counsel’s Response to Objections, Declaration of Reginald Davidson, ECF No.
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`1789-9, PageID.64195.
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`CONCLUSION
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`For the foregoing reasons, Co-Liaison Counsel respectfully requests this
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`Court to enter an order approving Plaintiffs’ Motion for Final Approval, and for such
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`other and further relief the Court deems just and proper.
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`Dated: May 27, 2021
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` Respectfully submitted,
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`LEVY KONIGSBERG, LLP
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`By: /s/ Corey M. Stern
`Corey M. Stern, Esq.
`800 Third Avenue
`Suite 11th Floor
`New York, NY, 10022
`(212) 605-6200
`cstern@levylaw.com
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`Co-Liaison Counsel for Individual
`Plaintiffs
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`By: /s/ Hunter Shkolnik
`Hunter J. Shkolnik, Esq.
`Paul Napoli, Esq.
`270 Munoz Rivera Avenue
`Hato Rey, Puerto Rico 00918
`(833) 271-4502
`hunter@nsprlaw.com
`pnapoli@nsprlaw.com
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`Patrick Lanciotti, Esq.
`360 Lexington Avenue, 11th Floor
`New York, NY 10017
`(212) 397-1000
`planciotti@napolilaw.com
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`Case 5:16-cv-10444-JEL-MKM ECF No. 1795, PageID.64487 Filed 05/27/21 Page 18 of 18
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`CERTIFICATE OF SERVICE
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`I hereby certify that on May 27, 2021, the foregoing was electronically filed
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`with the Clerk of the Court using the CM/ECF system which will send notification
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`of such filing upon counsel of record.
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`Dated: May 27, 2021
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` _____/s/ Patrick J. Lanciotti______
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