LEGAL NOTICE BY ORDER OF THE COURT

If you are a Louisiana resident or business owner, or governmental entity impacted by the flooding that began on August 10, 2016 in certain areas of East Baton Rouge and Livingston Parishes and you were an owner of property, a governmental entity with jurisdiction over property, and or a business entity that operated from property the business owned or leased within the following class area being those portions of East Baton Rouge and Livingston Parishes that are bounded by I-12 along the southern boundary, O’Neil Lane as the western boundary, Old Hammond Highway and US 190 as part of the northern boundary and Colyell Creek as the eastern boundary, your rights may be affected by approval of a class action lawsuit.

A class action lawsuit alleging that residents, business owners, and governmental entities suffered damages resulting from the impoundment of water resultant from the construction of a solid concrete median crash barrier on 1-12 from the Amite River to Colyell Creek has been filed by representatives of the proposed class. The class representatives have agreed to settle their claims for injunctive relief and the payment of $21,350,000.00 against Defendants State of Louisiana through the Dept. of Transportation and Development (“DOTD”); ABMB Engineers, Inc. n/k/a Stantec Consulting Services, Inc.; Gilchrist Construction Co., L.L.C.; .Iames Construction Group, L.L.C.; Volkert. Inc.; and Evans-Graves Engineers, Inc. Defendant G.E.C., Inc. remains a Defcndant.

Pursuant to an Order of the Court dated December 12, 2024. the class settlement for Injunctive Relief was granted Preliminary Approval.

There is no opt out, but any Class Member may object to the Settlement, as long as the objection is proper and is submitted fifteen (15) days before the Final Hearing scheduled for February 3, 2025, 11:00 a.m. See the Bruno & Bruno website (https://www.brunobrunolaw.com) for further instructions regarding how to object to this Class Action Injunctive Relief Settlement.

To see a complete copy of the Settlement Agreement and/or Order preliminarily approving the class action settlement, contact Joshua Palmintier at Palmintier Law Group — (225) 398-8229, Joseph Bruno at Bruno & Bruno, LLP — 504-525-1335, or Mitchell A. To ups at Weller, Green, Toups & Terrell, L.L.P – (409) 838-0101, or on the Bruno & Bruno website (https://www.brunobrunolaw.com). You are also advised to consult your own counsel.

Short Form

NOTICE OF SETTLEMENT OF CLASS ACTION FOR INJUNCTIVE RELIEF ONLY

If you are a Louisiana resident or business owner, or governmental entity impacted by the flooding that began on August 10, 2016 in certain areas of East Baton Rouge and Livingston Parishes and you were an owner of property, a governmental entity with jurisdiction over property, and or a business entity that operated from property the business owned or leased within the following class area being those portions of East Baton Rouge and Livingston Parishes that are bounded by 1-12 along the southern boundary, O’Neil Lane as the western boundary, Old Hammond Highway and US 190 as part of the northern boundary and ColyeU Creek as the eastern boundary, your rights may be affected by approval of a class action lawsuit.

This notice was authorized by the Honorable Richard “Chip” Moore, Ill, Judge of the J9’h

Judicial District Court for the Parish of East Baton Rouge, State of Louisiana.

1. What is this notice?

• This notice is to infonn you of a proposed settlement in a class action lawsuit against the State of Louisiana through the Dept. of Transportation and Development (“DOTD”), ABMB Engineers, n/k/a Stantec Consulting Services, Inc., Gilchrist Construction Co., L.L.C., James Construction Group, L.L.C., Volkert, Inc., and Evans-Graves Engineers, Inc. (“Defendants”), pending in the 19^th Judicial District Court for the Parish of East Baton Rouge, State ofLouisiana
• The proposed Settlement, if approved, will affect residents, business owners, and governmental entities who were allegedly affected and damaged as a result of the impoundment of water resultant from the construction of a solid concrete median crash barrier on1-12 from the Amite River to Colyell
• Your rights are affected whether you act or do not Your rights and options-and the deadlines to exercise them-are explained in this Notice. Read this Notice carefully.

2. What is this lawsuit about?

This case arises out of the flooding of East Baton Rouge and Livington Parishes in August 2016. Plaintiffs filed this class action lawsuit on January 5, 2017, against the Defendants, State of Louisiana through the Dept. of Transportation and Development (“DOTD”), ABMB Engineers, Inc. n/k/a Stantec Consulting Services, Inc., Gilchrist Construction Co., L.L.C., James Construction Group, L.L.C., Volkert, Inc., Evans-Graves Engineers, Inc., and G.E.C., Inc. alleging that the Defendants designed and/or installed a concrete median crash barrier along a 19-mile stretch of Interstate 12 as part of several

highway widening projects designated as State Project Nos. 454-01-0047, 454-02-0025, 454-02-0071, 454-02-0074, and H.009836 (hereinafter collectively referred to as “Geaux Wider Construction Projects”), and alleging among other things that the Defendants failed to perform to perform hydrologic testing and modeling prior to beginning the Geaux Wider 1-12 widening project. Plaintiffs further alleged that due to the acts and failure of the Defendants, the flooding of August 2016 was made worse due to the Geaux Wider 1-12 widening project, namely the construction of a 5-foot concrete median crash barrier, and that the barrier caused flood waters to back up, thereby increasing the amount of water that flooded homes and business in the areas of the class definition. Representative Plaintiffs further alleged that the crash barrier acted as a flood wall that impounded the flood waters and interrupted the natural flow of surface waters to the south. Representative Plaintiffs alleged that tens of thousands of people were harmed by the negligence of the Defendants. Defendant G.E.C., Inc. remains a Defendant.

Defendants have asserted substantial legal and factual defenses against Plaintiffs’ claims and deny Plaintiffs’ allegations in the Lawsuit. Defendants deny any liability to the Plaintiffs, Settlement Class, or any Settlement Class Member, for any claims, causes of action, costs, expenses, attorneys’ fees, or damages of any kind.

3. Will the Settlement affect me?

The Court has preliminarily certified the following class of people who will be bound by the Settlement (the “Class”). “All governmental entities, commercial businesses or individuals located entirely or partially within East Baton Rouge and Livingston Parishes north of 1-12 and all individuals and/or other entities who owned property and/or possessed a right in property located entirely or partially within East Baton Rouge and Livingston Parishes north of 1-12 as of August 10, 2016. See Class Definition in Plaintiffs’ Motion for Class Certification (specifically, Paragraph II, Page 3, for Diagram and Latitude-Longitude coordinate bounds).”

Class members have the opportunity to oppose the Settlement (see Question No. 6). If the Court decides not to approve the Settlement, however, the lawsuit will continue as if there had been no Settlement or certification of a Class.

4. Why is there a settlement?

The Court has not decided in favor of either side in this case. The Defendants deny all allegations of wrongdoing but are settling to avoid the expense and inconvenience of continuing to litigate the case. Plaintiffs and the lawyers representing them (“Class Counsel”) believe the Settlement is in the best interest of the Settlement Class because it provides substantial Injunctive Relief Benefits to the class which Class Members would not receive if Plaintiffs lost the lawsuit or were only partially successful. In addition, the Settlement avoids the expense and delay of pursuing the case through trial and any appeals, which might otherwise continue for many more years.

5. What does the Settlement do?

The Defendants (other than DOTO) will deposit $21,350,000.00 into a Qualified Settlement Fund to be administered by a Special Master and a CADA. DOTO will use these funds to design, procure, and implement a “Drainage Enhancement Program” (“DEP”) to construct crash barriers with openings along certain portions of Interstate 12 in East Baton Rouge or Livingston Parishes between mile markers 6 and 20 (the “DEP Area”), retrofitting openings into existing crash barriers in the DEP Area, or taking other actions to enhance drainage in the DEP Area. If any funds remain in the DEP Account following completion of all work described above, DOTO may use the remaining funds for other actions to enhance drainage in the DEP Area under the same conditions as provided above.

a. Benefits of the Settlement for Class Members

The Settlement benefits Class Members by enhancing the drainage along certain portions of Interstate 12 in East Baton Rouge or Livingston Parishes between mile markers 6 and 20, which will alleviate some of the excess flooding in the future like occurred in the August 20 I6 flood.

b. Class Member Obligations

If you have no objection to the Settlement, you do not need to do anything. If you wish to object to the Settlement, see Question 6 below.

c. Release of All Pending and Future Claims

If approved, the Settlement will release the Defendants, State of Louisiana through the Dept. of Transportation and Development (“DOTD”), ABMB Engineers, Inc. n/k/a Stantec Consulting Services, Inc., Gilchrist Construction Co., L.L.C., James Construction Group, L.L.C., Volkert, Inc., Evans-Graves Engineers, Inc., from liability for all claims that relate to the flooding that occurred North of Interstate 12 in East Baton Rouge and Livingston Parishes. This broad release includes all claims for declaratory or equitable relief (including injunctive relief) as well as claims for money damages.

d. Attorneys’ Fees and Costs

The Settlement Agreement provides for payment of attorney’s fees to be approved by the court without objection from Defendants. Class Counsel expects to seek 33 1/3 percent attorney’s fees for work over the past six years and no more than 6 2/3 percent attorney’s fees for their future work over the next five years.

6. What do I need to do now?

If you are satisfied with the proposed Settlement, you don’t.have to do anything at this time.

You cannot “opt out” or exclude yourself from the Settlement. If the Settlement is approved by the Court, you will be bound by the Settlement if you meet the definition of a Class Member. However, if you are not satisfied with the proposed Settlement, you may object and explain why you do not like the proposed Se,ttlement by submitting your objection in writing to both Class Counsel and Defendants’ Counsel at:

PlalndfTs’ Counsel	Defendants’ Counsel
Joseph M. Bruno	Nicholas Panayolopoulos
BRUNO & BRUNO	WEINBERG, WHEELER, HUDGINS, GUNN & DIAL, L.L.C.
ATTN: Gcaux Wider ClassAction Objection	ATTN: Geaux Wider Class ActionObjection
855BaroMe Street	3344 Peachtree Road,NE,Suitc2400
New Orleans, Louisiana 70113	Adanta,GA 30326

 

Specifically, you can ask the Court to deny approval by filing an objection. You cannot ask the Court to order a different settlement; the Court can only approve or reject the proposed Settlement. If the Court denies approval, this lawsuit will continue. If that is what you want to happen, you must object. Your objection must be received by both Class Counsel and Defendants’ Counsel no later than fifteen (15) days prior to the Final Fairness Hearing (See Paragraph 8 below regarding the time and location of the Final Fairness Hearing). Any objection must be in writing. All objections and supporting papers must (a) clearly identify the case name and number (City of Williams, et al vs. State of Louisiana, through the Department of Transportation and Development, et al, Case No. 654278), (b) include the Class Member’s full name, current address, telephone number and email address; (c) include an explanation as to why the Class Member objects to theSettlement; (d) include a list of all objections filed in the last ten (10) years in any class action case; and (e) include the name, address, telephone number and email address of your attorney or legal representative, or state that you do not have an attorney

or legal representative. ff you file a timely written objection that complies with the requirements above, you may, but are not required to, appear at the Fairness Hearing, either in person or through your own attorney (see Question No. 8 for more details on the Fairness Hearing).

7. Who represents the Class?

The Court has appointed the law firms of BRUNO & BRUNO, and its attorney, Joseph Bruno; MITCHELL A. TOUPS, LTD., of Weller, Green, Toups & Terrell, L.L.P., and its attorney, Mitchell A. Toups; and PALMINTIER LAW GROUP, and its attorney, Joshua M. Palmintier, to represent all Class Members in this litigation. If you have any questions about this case, you can contact Plaintiffs· Counsel by phone at (504) 525- 1335. Wl1ile Plaintiffs’ Counsel represents your interests as a Class Member in th.is litigation, they do not represent you individually in this matter. If you want a lawyer to represent you in these matters, you are responsible for hiring that lawyer separately.

8. When and where will the Court hold a hearing on the fairness of the Settlement?

The Court has scheduled a Fairness Hearing for February 3, 2025 at I I:00 a.m. in the Courtroom for the Honorable Richard “Chip” Moore, III, Judge, 19 1 Judicial District Court, Parish of East Baton Rouge, 300 North Boulevard, Room 9D, Baton Rouge, LA 70801. At the hearing, the Court will decide if the Settlement is fair, reasonable, and adequate. lf the Court approves the Settlement, the Settlement will become effective on the date of approval. If the Court rejects the Settlement, the Parties will continue to litigate the case.

At the hearing, the Court will hear any comments, objections, and arguments concerning the fairness of the Settlement. If you wish to speak at the Fairness Hearing, you must send written notice to Class Counsel and Defendants’ Counsel using the addresses listed in Question No. 6 above. Your request should also include the information listed in Question No. 6 above. Your request must be received no later than fifteen (15) days prior to the Fairness Hearing.

If you intend to appear at the Fairness Hearing through your own attorney, your attorney will need to file a notice of intent to appear with the Court. You are responsible for hiring and paying that attorney.

NOTE: This date, time and method of the Fairness Hearing are subject to change by Court Order without further notice. Please check the website of Class Counsel, https://www.brnnobrunolaw.com, for the latest information.

9. Where can I get more information?

This notice provides only a summary of the matters relating to the proposed Settlement. For the complete terms of the Settlement, please refer to the Settlement Agreement, available at https://www.brunobrnnolaw.com, by contacting Class Counsel (see contact information at Question No. 7 above), or by visiting the office of the Clerk of Court for the I 9^th Judicial District Court for the Parish of East Baton Rouge, Division 26. To access the actual filings in the case, you must visit the Clerk’s office in person. If after reviewing the Settlement Agreement you still have questions, you can contact Plaintiffs’ Counsel (see Question No. 7 above).