Attorneys know that civil and human rights litigation presents unique challenges around class notification, among other things. Claimants often come from marginalized communities and are geographically dispersed, making them hard to identify and notify. Class notice must often be multilingual and sensitively tailored to the needs these communities.
CEG has the tools to provide effective notice to class members in civil and human rights cases. Over the past 20+ years, our principals have administered some of the largest, most comprehensive global outreach programs involving Holocaust-era claims, Native American tribal litigation, domestic civil rights, and other challenging issues. CEG is able to provide customized services—from archival research to administering multilingual notice, maintaining call centers and partnering with advocacy groups—that meet Rule 23 and other due process requirements. CEG has the domestic and global reach and expertise in administering these unique and challenging matters. CEG’s experience makes the difference.
Innovative and flexible notice methods. Class notification in civil and human rights cases requires a customized approach that goes beyond traditional class notice to reach these marginalized communities.
Through its unparalleled expertise, CEG has developed innovative processes to identify and notify class members in civil and human rights cases, implementing flexible methods that are specific to the class and the case. We combine standard notice techniques with other methods—social and other digital media notice, text messaging notice, targeted local and community media, and partnering with advocacy groups and NGOs—to find and notify class members and their descendants.
Community third-party notice. In civil and human rights class actions, working closely with national and local rights advocates, nonprofits, and NGOs is essential to increasing the reach and frequency of class notice. These partners have access to class members that cannot always be replicated by traditional notice methods.
CEG understands the importance of developing deep relationships with advocates and organizations that work directly with impacted populations, with assistance of local outreach workers to assist in proactively reaching out to class members.
Archival research. Because civil and human rights cases often focus on righting historical wrongs, deep research can be required to identify survivors and their descendants, or to locate displaced persons.
CEG has the tools and expertise to review census archives, genealogical records, tax and property deeds, and large archival databases in order to quickly and efficiently extract the crucial information and put it to use.
Speaking the language. Language skills are crucial in civil and human rights cases, as many class members speak other languages or come from foreign countries.
CEG is a truly global organization, with staff throughout the U.S., Europe, and elsewhere. Members of our staff speak many languages, and we have deep experience in locating and tapping multilingual talent. We have the expertise and capacity to reach out to class members in any country, speaking any language.
Leslie Ann Wilkie Peltier v. Debra Haaland, Secretary of the Interior, No. 1:20-cv-03775-TFH (D.D.C.) A class action lawsuit to redress alleged breaches of trust by the U.S. Department of the Interior, the U.S. Department of the Treasury, and the U.S. of America with respect to the accounting and management of two Judgment Awards of the Indian Claims Commission. The $59 million settlement provides relief to several generations of tribal families. Ms. Verkhovskaya developed a novel class notification and claims adjudication process that quickly and efficiently distributed settlement funds to surviving tribal members and their heirs. At the preliminary approval hearing, the federal judge overseeing the settlement noted that CEG was “instrumental in helping to shape the deal…”
At the final settlement approval fairness hearing, class counsel noted that CEG “made extensive efforts to identify and reach” the class and that CEG’s class notification efforts “have met or gone beyond the Rule 23 and due process…requirements…The notice program here has been thorough…” In the order granting final settlement agreement approval, the court noted that CEG’s class notification process provided “the best notice practicable under the circumstances…and it was reasonably calculated to reach the class members.”
As an indication of the notice adequacy and its expansive reach, claimants were reached beyond the USA and claims were filed by class members from six additional countries: Australia, Austria, Canada, The Netherlands, Norway, and South Korea.
German Forced Labour Compensation Programme (GFLCP) CEG’s principal was appointed by the government of Germany to lead notice and claims collection efforts in the GFLCP. Under her direction, the program located more than 43,000 Romani survivors in 17 countries in central and eastern Europe who were potentially eligible for humanitarian aid. CEG’s principal oversaw creation of a comprehensive database for the GFLCP and the Holocaust Victim Assets Programme and coordinated direct assistance with claim completion for more than 11,000 Romanies in eight central and eastern European countries.
In re Holocaust Victim Assets Litig., 105 F. Supp. 2d 139 (E.D.N.Y. 2000) CEG’s principal played a key role in a worldwide Phase I notice program that resulted in the processing of more than 500,000 initial questionnaires relating to a $1.25 billion settlement. In Phase III of that matter, she coordinated delivering notice to more than 10,000 Jewish communities in 109 countries. In both Phases I and III of that matter,
CEG’s principal administered international help and call centers that directly assisted more than 100,000 potential claimants, created a class-appropriate notice targeting members of the Romani community in 48 countries, directed hundreds of staff in communicating with Romani communities and individuals, and notified more than two million people of the settlement.
International Commission of Holocaust Era Insurance Claims (ICHEC) CEG’s principal was appointed by Chairman Lawrence Eagleburger, former U.S. Secretary of State, to serve as consultant to ICHEIC on notice and outreach strategies and supervised the notification of claimants and face-to-face assistance programs in eastern Europe and the former Soviet Union.
Project HEART: Holocaust Era Asset Restitution Taskforce CEG’s principal was appointed by the Israeli government as the administrative director of Project HEART to provide essential tools, strategy, and information to enable Israel and its partners to secure restitution for eligible Jewish Holocaust victims and their heirs. Project HEART was one of the most comprehensive multilingual notice campaigns ever undertaken, covering 137 countries. She assisted in launching a multilingual, interactive website, establishing a 24-hour call center in 13 languages, distributing more than 500,000 documents to potentially eligible families of Holocaust victims, handling more than 80,000 telephone calls, conducting archival research, and creating the most comprehensive online database of looted Jewish property in history. CEG’s principal oversaw and directed the establishment of the largest and most complex data repository in the world, of nearly two million records identifying Jewish property stolen or looted during the Holocaust. In addition, under her supervision, Project HEART reached out to 15,000 non-governmental organizations (NGOs) to engage them in the project and provide personal assistance to thousands of Holocaust victims and their heirs in making their claims.