IN THE UNITED STATES BANKRUPTCY COURT FOR THE … · 2015. 9. 30. · IN THE UNITED STATES...

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

IN RE:

GARLOCK SEALING TECHNOLOGIES LLC, et al.,

Debtors.1

Case No. 10-BK-31607

Chapter 11

Jointly Administered

DEBTORS’ RESPONSE TO THE MOTION OF THE OFFICIAL COMMITTEE OF

ASBESTOS PERSONAL INJURY CLAIMANTS TO COMPEL DISCOVERY

Dated: September 29, 2015 ROBINSON BRADSHAW & HINSON, P.A.

Garland S. Cassada Jonathan C. Krisko Richard C. Worf, Jr. 101 North Tryon Street, Suite 1900 Charlotte, North Carolina 28246 Special Corporate and Litigation Counsel to the Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company

1 The debtors in these jointly administered cases are Garlock Sealing Technologies LLC (“Garlock”); Garrison Litigation Management Group, Ltd. (“Garrison”); and The Anchor Packing Company (hereinafter, collectively, “Debtors”).

Case 10-31607 Doc 4865 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Main Document of 29

TABLE OF CONTENTS

Page

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INTRODUCTION ......................................................................................................................... 1

BACKGROUND ........................................................................................................................... 4

A. Non-mesothelioma Claim Requests (Requests 2, 3, 4), Debtors’ Responses, and the Committee’s New Requests ................................................... 4

B. Mesothelioma Claim Estimation Documents (Request 25), Debtors’ Responses ............................................................................................................... 7

C. Debtors’ Privileged Documents Concerning Strategies, Settlements, Goals, and Specific Internal Presentations by Defense Counsel (Requests 16 & 17), Debtors’ Responses ............................................................................... 8

ARGUMENT ................................................................................................................................. 9

A. The Committee’s Claim of Waiver Rests on An Improper Attempt to Re-Argue the Previously Rejected “Settlement Approach” as a Foundation for Further Determinations in this Case ...................................................................... 9

B. The Process of Estimating the Relatively Insignificant Non-Mesothelioma Claims Does Not Justify Waiver .......................................................................... 10

C. The Motion Seeks to Overturn Judge Hodges’ Rulings That Made Clear that Debtors’ Waiver Was Limited in Scope ....................................................... 11

D. Applicable Precedent Concerning “At Issue” Waiver Does Not Support Waiver in This Case ............................................................................................. 15

1. The Fact That Privileged Materials Are Relevant to the Committee’s Settlement Approach Does Not Result In Waiver ............. 15

2. Other Cases that the Committee Relies On Do Not Support Waiver In This Context ........................................................................................ 19

3. Asbestos Settlement Litigation Cases Have Held There Should Be No Waiver ................................................................................................ 21

4. Precedential Considerations and Foresight Counsel Against Recognizing Broad Waiver ...................................................................... 22

E. The Court Should Not, Under the Guise of Enforcement, Order Debtors to Produce Documents the Committee Has Not Requested ..................................... 23

F. The Court Should Deny the Committee’s Apparent Demand That Debtors’ Outside Counsel Search for Information Related to Claims In Which They Had No Involvement ............................................................................................ 24

CONCLUSION ............................................................................................................................ 25


TABLE OF AUTHORITIES

Page(s)

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Cases

Banc of Am. Securities, LLC v. Evergreen Int’l Aviation, Inc., No. 03-CVS-9138, 2006 NCBC 2, 2006 WL 401679 (Diaz, J.) (N.C. Bus. Ct. Jan. 25, 2006) ....................................... 20

Charlotte Motor Speedway, Inc. v. Int’l Ins. Co., 125 F.R.D. 127 (M.D.N.C. 1989) .................. 21

Hearn v. Wray, 68 F.R.D. 574 (E.D. Wash. 1975) ................................................................. 19, 20

Ill. Cent. R.R. Co. v. Harried, No. CIVA 5:06CV160-DCB-JMR, 2009 WL 2425985 (S.D. Miss. Aug. 6, 2009) ......................................................................................................... 22

In re Allen, 106 F.3d 582 (4th Cir. 1997) ..................................................................................... 16

In re Garlock Sealing Technologies, LLC, 504 B.R. 71 (2014) ..................................................... 2

In re Kidder Peabody Sec. Litig., 168 F.R.D. 459 (S.D.NY. 1996) ............................................. 21

In re New Bern Riverfront Dev., LLC, No. 09-10340-8-SWH, 2015 WL 1320255 (Bankr. E.D.N.C. Mar. 17, 2015) ............................................................................................. 15

LendingTree, LLC v. Zillow, Inc., 2013 WL 6385297 (W.D.N.C. Dec. 6, 2013) ........................ 18

Livingston v. North Belle Vernon Borough, 91 F.3d 515 (3d Cir. 1996)...................................... 18

Rhone-Poulenc Rorer Inc. v. Home Indem. Co., 32 F.3d 851 (3d Cir. 1994) .................. 16, 17, 18

Small v. Hunt, 152 F.R.D. 509 (E.D.N.C. 1994) .......................................................................... 21

Truck Ins. Exch. v. St. Paul Fire & Marine Ins. Co., 66 F.R.D. 129 (E.D. Pa. 1975) .................. 21

Rules

Fed. R. Bankr. P. 7037(a)(3)(B) ................................................................................................... 23

Fed. R. Civ. P. 37(a) ..................................................................................................................... 23

Fed. R. Evid. 408 ......................................................................................................................... 22


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INTRODUCTION

The Committee has moved to compel Debtors to produce a wide variety of privileged

materials relating to their pre-petition settlements of asbestos claims. The Committee’s motion

(the “Motion”) proceeds from the premise that Debtors at confirmation will once again have to

demonstrate that the amounts of pre-petition settlements (both mesothelioma and non-

mesothelioma settlements) are not a reliable guide to the allowed amount of claims (or any other

fact relevant to confirmation), and further, that by presenting such evidence, Debtors will

necessarily waive attorney-client privilege and work production protections. This premise, and

the conclusions that flow from it, are incorrect, for many reasons.

In the first place, the Committee’s Motion largely constitutes an attempt to reopen the

mesothelioma estimation opinion, specifically the portion of that opinion relating to the

probative value of Debtors’ pre-petition settlements. In that prior litigation, Debtors introduced

testimony and documents showing that suppression of evidence occurred in a specific set of 210

cases. The Court held that this created a limited “at issue” waiver of attorney-client privilege and

work product protection with respect to those cases, and ordered production of a defined set of

privileged documents, while refusing to order the production of any more privileged documents.

The Committee now seeks additional privileged documents relating to these same cases, as well

as general privileged documents describing Debtors’ strategies in settling asbestos claims,

contending that Debtors at confirmation will necessarily have to make those cases an issue yet

again. See Motion at 17.

But the Committee ignores that the Court already made findings about Debtors’ pre-

petition mesothelioma settlements—including about those particular cases—such that there will

be no need to introduce further evidence on that topic. The Court found, after years of discovery

rulings and a lengthy trial, that Debtors’ pre-petition mesothelioma settlement payments have


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“no value to this proceeding” because Debtors’ past claims resolution values were “infected with

the impropriety of some law firms and inflated by the cost of defense.”2 The Court further found:

92. . . . The court has concluded that it cannot adopt the settlement approach of the ACC and FCR for two primary reasons: First, the settlement history data does not accurately reflect fair settlements because exposure evidence was withheld. While that practice was not uniform, it was widespread and significant enough to infect fatally the settlement process and historic data. It has rendered that data useless for fairly estimating Garlock’s liability to present and future claimants.

93. Second, Garlock’s settlement data represents insignificant [sic] part cost avoidance rather than its liability. The bankruptcy estimation process requires a pure (or more academic) analysis of Garlock’s “liability” to claimants; whereas the tort system produced a settlement based [on] both liability and avoidable defense costs. . . . The claims resolution history may be an appropriate measure only if it reliably reflects the debtor’s liability, and here it does not.3

These findings have been made, the Court rejected one attempt to reopen them, and there will be

no need to further litigate them at confirmation. The Committee’s argument that Debtors will

once again have to re-engage the probative value of their mesothelioma settlements, and will

thereby waive privilege, is a transparent attempt to reopen the findings Judge Hodges already

made on that issue.

The Committee’s Motion with respect to mesothelioma settlements is also an improper

attempt to relitigate the carefully crafted privilege rulings that Judge Hodges made in the course

of arriving at the Estimation Opinion. The Court did order production of certain privileged

documents (known as MEAs and TEFs) pertaining to the 210 specific cases.4 But the Court twice

rejected the Committee’s attempt to expand the scope of the waiver and production of documents

to include the additional documents the Committee now seeks through its Motion. The

2 In re Garlock Sealing Technologies, LLC, 504 B.R. 71, 73, 94 (2014) (“Estimation Opinion”). 3 Id. at 94 (emphasis in original). See also id. at 94-95 (further elaborating on findings). 4 Debtors continue to respectfully disagree that the Court’s two privileged rulings are supported by precedent. Debtors asked the Court to reconsider its June 6, 2013 ruling immediately after it was entered and sought, in the alternative, for the Court to certify the issue for immediate interlocutory review. See (Docket No. 2937).


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Committee does not even try to show that the standards for reopening those prior rulings have

been met. Indeed, the current attempt is doubly improper because the findings about

mesothelioma settlements will not be re-litigated, meaning the evidence is not even relevant to

any issue the Court will need to decide at confirmation.

The Committee’s Motion also fails with respect to non-mesothelioma claims because

Debtors will not offer the kind of evidence that the Court found created an “at issue” waiver in

the mesothelioma estimation litigation, nor will any of the evidence Debtors do plan to offer

create an “at issue” waiver. At confirmation, Debtors will prove the allowed amount of non-

mesothelioma claims (claims that all parties have recognized are relatively minor in the scheme

of things) through the legal liability approach already accepted by the Court. Debtors do not plan

to present the kind of evidence that Judge Hodges previously held created an “at issue” waiver—

i.e., evidence and contentions about evidence suppression in particular cases—even in rebuttal of

a potential Committee settlement approach. Non-mesothelioma claims were settled for extremely

small amounts, plainly for the purpose of saving defense costs, with little or no concerns about

adverse verdicts. Debtors will present expert testimony demonstrating this from an economic

perspective, as well as general fact testimony about the reasons why non-mesothelioma claims

were settled. This kind of proof does not create the “at issue” waiver the Court previously found.

Nor does it justify any expansion of the Court’s previous ruling, under precedent recognized by

this district.5 As described below, the non-mesothelioma part of the Committee’s motion suffers

from the additional defect of seeking to enforce discovery requests never made, pertaining to 600

5 Debtors in their discovery responses have reserved the right to examine evidence suppression in any particular non-mesothelioma cases the Committee holds up as reflecting Debtors’ liability. But as the Committee has not yet done so, Debtors have not made any contention with respect to any settled case. As described below, Debtors have made contentions with respect to two non-mesothelioma cases tried to verdict.


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still-unidentified cases rather than the discovery requests the Committee actually propounded.

This breach of proper discovery practice means Debtors have not had the chance to ascertain

whether any privileged documents relating to the proposed sample even exist.

In short, Debtors have done nothing to waive attorney-client privilege or work product

protection for purposes of the confirmation hearing. Debtors respectfully request that the Court

deny the Motion.

BACKGROUND

The discovery the Committee seeks in its Motion relates to six document requests that the

Committee propounded to Debtors. Although there are six separate requests, for discussion

purposes, those requests and Debtors’ responses are best grouped into three categories.

A. Non-mesothelioma Claim Requests (Requests 2, 3, 4), Debtors’ Responses, and the Committee’s New Requests

Requests 2, 3, and 4, and companion Interrogatories 1, 2, and 3, seek information

concerning Debtors’ contentions related to non-mesothelioma claims brought against Garlock.6

• Request 2 seeks documents for any specific settled non-mesothelioma case that

Debtors will contend was impacted by plaintiffs’ suppression of evidence;

• Request 3 seeks documents for any specific settled non-mesothelioma case that

Debtors will contend was impacted by plaintiffs’ submission of fraudulent or

otherwise improper medical diagnoses; and

6 The following relevant discovery requests and responses are attached as Exs. A, B, C, and D: Official Committee of Asbestos Personal Injury Claimants’ First Set of Interrogatories Directed to the Debtors Regarding Confirmation Issues, dated June 2, 2015 (“Interrogatories”) (Ex. A); Official Committee of Asbestos Personal Injury Claimants’ First Request for Production of Documents Directed to the Debtors on Confirmation Issues, dated June 2, 2015 (“Requests”) (Ex. B); Debtors’ Responses to Official Committee of Asbestos Personal Injury Claimants’ First Set of Interrogatories Directed to the Debtors Regarding Confirmation Issues, dated July 16, 2015 (“Interrogatory Responses”) (Ex. C); Debtors’ Responses to Official Committee of Asbestos Personal Injury Claimants’ First Requests For Production of Documents Directed to the Debtors Regarding Confirmation Issues, dated July 16, 2015 (“Responses”) (Ex. D).


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• Request 4 seeks documents for any specific non-mesothelioma case that Debtors

will contend was resolved to avoid Debtors’ costs of defense.

For each of these requests, the Committee asked for all settlement communications,

settlement agreements and, depending on the category, all discovery materials, medical

documents, or compiled cost information. For each of these requests, the Committee also seeks

privileged materials, namely “pre-settlement” evaluations and deliberations by Debtors related to

any cases about which it will make contentions at trial.

Debtors’ Responses. Debtors responded that they did not plan to introduce evidence with

respect to any particular settled non-mesothelioma cases where evidence suppression or

fraudulent diagnoses occurred, and only intended to offer general expert and fact testimony about

the role defense costs played in settlements of non-mesothelioma claims. Debtors also reserved

the right to demonstrate evidence suppression or fraudulent diagnoses with respect to particular

cases the Committee offers to demonstrate Debtors’ liability, but because the Committee has not

yet identified any such cases, Debtors did not either.

Debtors did identify two cases, Robertson and Dexter, in response to Request 2. Debtors

do not intend to put on evidence about these cases either (unless another party does), but because

they had identified those cases previously as ones where Debtors had evidence of plaintiffs’

suppression of product exposure evidence, they listed them in their Response. Neither case

involved a settlement, as both were litigated to verdict. Debtors have produced all requested

documents for both of these cases. Debtors did not need to produce privileged documents for

those cases because the privileged materials Request 2 seeks are those reflecting “pre-settlement

evaluation” and “internal settlement deliberation.” Both of these cases were tried to verdict.

Debtors’ intention not to introduce evidence with respect to specific non-mesothelioma


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settlements at confirmation stems from the nature of those claims and settlements. As a matter of

background, until the Committee’s Motion, there has never been any bona fide dispute about

whether Debtors historically resolved asbestos claims in large part to avoid costs of defense.

Early in the case, for instance, the Committee’s claims expert, Dr. Peterson, testified that the

desire of asbestos defendants to avoid defense costs is an important factor influencing the

decision to settle cases. In his testimony, he opined that “ninety-nine point nine percent of the

cases settle rather than going to trial because both sides know that these are expensive

propositions.” 10/27/2010 Tr. at 571-72. Consistent with those comments, Debtors’ historical

average payment for a non-mesothelioma claim resolved by settlement was less than $2,000.

That is an amount less than the cost for Debtors’ counsel to open a file and evaluate a claim.

Moreover, the parties have proceeded, throughout these cases, on the premise that the

value of non-mesothelioma claims is relatively insignificant compared to any liability for

mesothelioma claims. In the Estimation Opinion, the Court both rejected use of a “settlement

approach” as a basis for liability and found that the overwhelming majority of Garlock’ s

settlements, in the mesothelioma context, were to avoid costs of defense. Debtors thus see little

reason, absent interjection by the Committee or other parties of evidence regarding specific

cases, to present evidence about the settlements of specific past non-mesothelioma claims.

The Committee’s recent responses to Debtors’ discovery requests revealed that it plans an

evidentiary presentation similar to Debtors’ concerning non-mesothelioma claims. It confirmed

that it will not call any fact witness for the purpose of testifying that any settlement by Garlock

of a non-mesothelioma claim fairly reflects Garlock’ s liability for such claim. Instead, the

Committee has stated it will rely solely on opinions of experts to establish the relationship


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between Debtors’ non-mesothelioma settlements of past claims and Garlock’ s liability for

pending and future claims.

Debtors likewise plan to rely on expert testimony to establish the extent to which

historical non-mesothelioma settlements were influenced by defense costs as opposed to

Debtors’ actual legal responsibility. They did not identify any specific claimant in response to

either Request 3 or 4, and no settled claimant in response to Request 2. To the extent they will

offer evidence on these points, they plan to do so on a general basis using expert testimony, as

well as generalized fact testimony.

New Requests. Rather than seek enforcement of these Requests, the Committee’s Motion

asks the Court to approve new ones. In place of the actual Requests, which sought cases about

which Debtors would make made contentions at confirmation, the Committee’s Motion asks the

Court to authorize the Committee to identify 600 separate cases, 200 for each category in

Requests 2, 3, 4, and order Debtors to produce documents for those cases. In addition to these

600 cases, the Motion also seeks to add documents related to any non-mesothelioma verdict. In

other words, the Motion seeks an order to compel Debtors to produce documents that the

Committee has not requested before.

B. Mesothelioma Claim Estimation Documents (Request 25), Debtors’ Responses

Request 25 seeks discovery of 210 cases which were cases listed on trial exhibit GST-

8001. Debtors presented testimony about 205 of these cases at the estimation trial. (Five of the

cases were open claims or not mesothelioma claims and, for that reason, Debtors did not offer

evidence about them at the estimation trial.) These cases were the subject of discovery, litigation,

and findings in the Estimation Opinion.7 Debtors have already produced tens of thousands of

7 See Estimation Opinion at 85-86 (when referring to 205 cases, was referring to cases identified on GST-8001).


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documents from the underlying cases, including communications related to settlements and

settlement agreements from those cases. In two earlier privilege rulings, the Court ordered

Debtors (over Debtors’ objections) to produce privileged Material Expense Authorizations

(MEAs) concerning those cases and, for the 26 cases that were the subject of the first privilege

ruling, Trial Evaluation Forms (TEFs).

Debtors’ Responses. Debtors objected to this discovery request on the basis of privilege,

on the ground that it was not relevant to any issue that the Court needs to decide at the

confirmation hearing but was an improper effort to reopen the estimation record and re-litigate

the factors that determined mesothelioma settlements. Additionally, Debtors objected because

the Court had denied this discovery twice before, as described in more detail below. Both before

(in the 2013 Motion to Compel) and after the Estimation Opinion (in the 2014 Motion to Reopen

Estimation), the Committee sought these documents, arguing the same reasons it urges require

discovery here, and Judge Hodges denied the Committee’s requests.8

C. Debtors’ Privileged Documents Concerning Strategies, Settlements, Goals, and Specific Internal Presentations by Defense Counsel (Requests 16 & 17), Debtors’ Responses

Request 16 seeks documents setting forth Debtors’ historical settlement strategies,

settlement criteria, and internal goals for settling claims, and Request 17 seeks presentations by

Debtors’ defense counsel made at strategy meetings that are opinion work product and protected

by the attorney-client privilege. These Requests are identical to ones the Committee served, and

8 “2013 Motion to Compel” refers to the Motion of the Official Committee of Asbestos Personal Injury Claimants and Joseph W. Grier, III, Future Asbestos Claimants’ Representative, for an Order In Limine or, in the Alternative, to Compel Discovery (Docket No. 2894) (under seal). “2014 Motion to Reopen Estimation” refers to the Motion of the Official Committee of Asbestos Personal Injury Claimants to Reopen the Record of the Estimation Proceeding (Docket No. 3725) (the “2014 Motion to Reopen Estimation”). The Court denied discovery of these documents in its June 6, 2013 ruling. It also denied them when sought in the Committee’s 2014 Motion to Reopen Estimation Record. See Order Denying Motion of the Official Committee of Asbestos Personal Injury Claimants to Reopen the Record of the Estimation Proceeding (Dec. 9, 2014) (Docket No. 4260) (“Order Denying Motion to Reopen”).


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to which Debtors responded prior to the estimation trial. Although Request 16 is different than

previous requests in that it purports to apply only to non-mesothelioma claims, Debtors have

explained that documents responsive to Request 16 are not distinguished by the type of asbestos

claim and, accordingly, Debtors previously produced responsive, non-privileged documents.

Debtors’ Responses. Debtors similarly objected to these Requests to the extent they

sought privileged documents. Like the documents sought by Request 25, these documents were

the subject of earlier Committee requests Judge Hodges twice denied.9

ARGUMENT

A. The Committee’s Claim of Waiver Rests on An Improper Attempt to Re-Argue the Previously Rejected “Settlement Approach” as a Foundation for Further Determinations in this Case.

The Committee’s Motion rests on the premise that, to satisfy the confirmation tests and

prove an estimate of non-mesothelioma claims, Debtors must offer proof why claims may be

paid at a “discount” to what past claims were paid “outside of bankruptcy.”10 This is Committee

rhetoric that makes a false assumption that the Committee’s already-rejected “settlement

approach” must be used to evaluate confirmation tests and determine Debtors’ liability for non-

mesothelioma claims. In fact, the relevance of Debtors’ mesothelioma settlements was already

heavily litigated and the Court conclusively determined that they are not relevant to the allowed

amount of claims, as set forth in the findings cited above. These findings leave no room for the

Committee to re-contest the use of settlements as a proxy for liability, and they make it

9 See 2012 Motion to Compel; 2012 Motion to Compel Proposed Order (Docket No. 2117-1); Order Denying Motion to Compel (Docket No. 2315). They were also requested in the 2014 Motion to Reopen Estimation Record, which was also denied. See Order Denying Motion to Reopen supra. “2012 Motion to Compel” refers to the Motion of the Official Committee of Asbestos Personal Injury Claimants to Compel on Grounds of Waiver the Production of Certain Documents the Debtors Have Withheld as Privileged (Docket No. 2117). 10 Motion at 5 (describing necessity to prove why Debtors could pay “discounts” compared to previous settlement payment levels).


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unnecessary for Debtors to re-litigate these issues or present any new evidence on them that

would make any further privileged evidence relevant or justify revisiting prior privilege rulings.

The Committee also has a difficult time justifying why it should have discovery of

privileged materials concerning mesothelioma claims sought by Request 25. That feature of its

Motion reflects, quite obviously, an attempt to re-litigate matters already decided. The

Committee tries to claim that it needs these materials now because Debtors “will try to justify

their Plan to replace the tort system by invoking suppression of exposure evidence” and Debtors

“will cite suppression of exposure evidence when attempting to meet the [section 1129]

requirements for confirmation.” But to the extent plaintiffs’ suppression of evidence is important

to any of these issues, Debtors do not need to offer further evidence. Debtors can comfortably

rely on the Court’s findings for this point as well—findings made in the context of the Court’s

prior privilege rulings, with which Debtors complied. There is no reason to revisit these issues.

B. The Process of Estimating the Relatively Insignificant Non-Mesothelioma Claims Does Not Justify Waiver.

The fact that there remains an open question over the aggregate amount of allowed non-

mesothelioma claims does not create a waiver either. Debtors made clear that, in the context of

non-mesothelioma estimation, they intend to offer a “legal liability” approach to estimation of

these claims, which is the method already approved by the Court. This method does not put

Debtors’ settlement of any particular non-mesothelioma claim at issue at all. Rather, it depends

on projected potential verdicts, Garlock’s share of any verdicts, and claimants’ likelihood of

success.11

To the extent the Committee may contend that a “settlement approach” must be used to

estimate non-mesothelioma claims, Debtors will largely rely on findings the Court has already

11 See Estimation Opinion at 94.


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made without further evidence, as well as explaining the meaning of Garlock’s historical

settlement data the same way the Committee plans to—through expert analysis and testimony, of

a general, economic nature. There is no need for the Court to hear testimony from Debtors or

plaintiffs regarding what motivated their decisions to settle specific non-mesothelioma cases.

Moreover, all parties have recognized that non-mesothelioma liability in this case is

relatively insignificant. Even Committee counsel, when recently resisting discovery related to

non-mesothelioma claims, conceded at hearing that with respect to non-mesothelioma claims, at

best, “[t]hese claims are the tail and not the dog.”12 It defies common sense to conclude that

estimation of the relatively insignificant non-mesothelioma claims could justify the wide-ranging

waiver that the Committee seeks.

C. The Motion Seeks to Overturn Judge Hodges’s Rulings That Made Clear that Debtors’ Waiver Was Limited in Scope.

The Committee’s Motion also misleads the Court to believe that the Committee is merely

seeking to “enforce”13 Judge Hodges’ two, earlier privilege rulings when, in fact, it is seeking to

overturn them. Judge Hodges’ two rulings compelling Debtors to produce privileged documents

were careful, limited decisions that plainly held that waiver was limited to MEAs and TEFs for

specific cases and should go no further. The Committee previously pressed Judge Hodges to

expand the waiver of those rulings, just like it does here, and Judge Hodges refused.

The Committee first sought to compel production of the strategy presentation documents

it seeks in Requests 16 & 17 on the basis of “at issue” waiver in the 2012 Motion to Compel.14

That motion, like this one, argued that Garlock, by offering evidence “why” it settled claims,

12 9/16/15 Tr. at 45. 13 Motion at 10, 13, 16, 17. 14 See 2012 Motion to Compel at 2; Proposed Order for the 2012 Motion to Compel at 1-2 (listing defense counsel presentations as documents sought).


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created an “at issue” waiver that broadly authorized production of privileged materials. The

Debtors responded that the Committee’s use of the settlement methodology to prove the validity

and amount of claims against Garlock was improper under Rule 408 (which prohibits use of

settlements to prove the validity or amount of claims). Debtors argued that, if the Court

permitted the use of settlements over Debtors’ objection, it would be improper and unjust to rule

that Garlock could raise a defense to the settlement methodology only if it waived privileges.

The Court agreed with Debtors and denied the motion, holding that Garlock’s general

explanation for settlements, in and of itself, did not create a broad waiver.15

In May 2013, the Committee brought another motion to compel that similarly argued “at

issue” waiver.16 This time, the Motion sought materials related to specific cases Debtors had

identified they would offer evidence about at trial. Specifically, the 2013 Motion to Compel

sought production of an expansive list of privileged materials for cases listed on GST-8001 (then

described as RFA 1 & 2 cases) of roughly the same scope it now seeks in Request 25.17 The

main difference between the documents sought in that motion and the documents it seeks in

Request 25 is that in the 2013 Motion, the Committee sought privileged documents for a subset

of 26 cases (those on RFA List 1A) and 100 others that appeared on GST-8001 instead of for all

210 cases that it seeks now.

In a June 6, 2013 ruling, Judge Hodges granted the Committee’s motion in part but also

denied it in part. The ruling seemed to be animated by the fact that Debtors had identified 26

cases about which they may present specific evidence at trial. Although requested by the

15 Order Denying Motion of the Official Committee of Asbestos Personal Injury Claimants to Compel on Grounds of Waiver the Production of Certain Documents the Debtors Have Withheld as Privileged (Docket No. 2315). 16 See 2013 Motion to Compel. 17 See 2013 Motion to Compel Ex. A (under seal) (itemizing documents sought by motion).


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Committee, Judge Hodges declined to recognize a broad waiver of privilege by Debtors.

Consequently, he ordered Debtors to produce only MEAs and TEFs for those 26 cases. At the

same time, even for those cases, he denied the motion to the extent it sought the documents the

Committee now seeks in Request 25. Judge Hodges explained that he “[did not] believe that

there’s been a wholesale waiver of the privilege,” and on that basis, limited the waiver. 18

Notwithstanding the Court’s bench ruling, the Committee proposed an order that would

have recognized an expanded waiver of privilege and compelled production of the kind of

documents now sought in Request 25.19 Judge Hodges again rejected the notion of a broad

waiver that extended beyond MEAs and TEFs. He sent the order back to the Committee and

emphasized in a message to counsel the limited nature of his ruling:

All: I have just had the opportunity to read the ACC’s proposed order and letter relating to the June 6 ruling – and cannot agree with the proposal of the ACC. What I thought I said at the hearing, and at least intended to say, is that the production of documents I ordered is limited to the TEF’s and MEA’s. I understand that this may not be entirely coextensive with the case law allowing such discovery, but thought it best to limit the production to the TEF and MEA forms for several practical reasons: First, the whole notion of discovery of privileged material should be as limited as possible. Second, the forms should give the ACC and FCR sufficient insight into Garlock’s settlement decisions to permit effective cross-examination and rebuttal. Third, time is short and these documents are readily identifiable and not subject to interpretation. With respect to Coltec’s objection, I had not considered Coltec at all, but would suggest that the ruling should apply to it into the extent that any TEF or MEA forms were communicated to Coltec. Unless there is something else to be considered, I do not believe that a response from Garlock or Coltec is necessary. I would appreciate it if the ACC would submit an order along the lines indicated for signing. George20 (emphasis added)

Judge Hodges’ second privilege ruling came during the estimation trial. In that ruling, he

likewise specified the narrow nature of the waiver. Following fact testimony by Rick Magee

18 See 6/6/203 Tr. 159. 19 See Ltr. and Proposed Order (June 6, 2013) (attached as Ex. E) 20 See Court E-mail Ruling (June 11, 2013) (attached as Ex. F)


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(corporate counsel to Debtors) about Debtors’ assessments of the group of 205 (of the 210) cases

appearing on GST-8001, the Committee moved the Court to find waiver and compel production

of privileged documents.21 The Court granted the Committee motion and required the production

of MEAs, but again, Judge Hodges emphasized the limited nature of the waiver:

So let’s say by the end of the day Tuesday you all get together all the MEAs you can of those ones you haven’t already given them of the 204. And that will not be a waiver of anything else, and we will go from there.22 (emphasis added)

After the estimation trial, Judge Hodges remained steadfast that the waiver he recognized

was limited. In 2014, the Committee moved to reopen the record of the estimation trial, and tried

again to persuade Judge Hodges to recognize an expansive waiver that entitled the Committee to

additional privileged materials, including specifically, the same documents it now seeks in

Request 25 and Requests 16 & 17.23 The basis of that motion was the same as the argument it

makes here—that the Court should compel discovery on the basis that it would be merely

“enforcing” the waiver in Judge Hodges’s earlier rulings to their “full extent.”24 As before,

Judge Hodges denied the Committee’s request.

Accordingly, the relief that the Committee seeks, in substance, is relief that overturns

Judge Hodges’s 2012 decision, the limits he placed on waiver in his two privilege rulings, and

his 2014 denial of discovery of these same documents. The Motion seeks to expand the

production of privileged documents pertaining to mesothelioma claims beyond what Judge

Hodges ordered, and it seeks to compel production of privileged material relating to settled non-

mesothelioma claims even though Debtors have not put any particular non-mesothelioma

21 See Estimation Trial Tr. 7/26/2013 at pp. 1415-16. 22 See id. at pp. 1417. 23 See Motion to Reopen Proposed Order (itemizing documents sought) (Docket No. 3725-1). 24 2014 Motion to Reopen at 57.


15

settlement at issue. The Committee’s Motion thus seeks reconsideration of these rulings, but

ignores the standard that it must meet to undo them. See, e.g., In re New Bern Riverfront Dev.,

LLC, No. 09-10340-8-SWH, 2015 WL 1320255, at *2 (Bankr. E.D.N.C. Mar. 17, 2015) (“[T]he

grounds on which courts will grant reconsideration [of interlocutory orders] are fairly narrow,

and generally extend to only three scenarios: (1) intervening change in controlling law;

(2) additional, previously unavailable evidence; or (3) the prior decision was based on clear error

or would work manifest injustice”).

Judge Hodges’s decision to define a boundary to Debtors’ waiver in his oversight of

discovery is a subject committed to his sound discretion. That he believed the circumstances

dictated some inquiry into privileged matters,25 but at the same time chose not to authorize the

Committee to have wide-ranging access to substantial, privileged Debtor materials, is justifiable.

The Committee has not demonstrated why Judge Hodges’ earlier decisions should be overturned.

The case for overturning those rulings is particularly unconvincing because the reliability of

mesothelioma settlements as a proxy for liability has already been decided by the Court, and will

not need to be litigated further at the confirmation hearing.

D. Applicable Precedent Concerning “At Issue” Waiver Does Not Support Waiver in This Case

1. The Fact That Privileged Materials Are Relevant to the Committee’s Settlement Approach Does Not Result In Waiver

The Motion should also be denied because the doctrine of “at issue” waiver does not

support recognition of a waiver here, including with respect to the generalized testimony Debtors

intend to offer about non-mesothelioma resolutions. There is no dispute that the material sought

in the Committee’s six requests reflects material protected as opinion or “core” work product,

25 As noted above, Debtors continue to respectfully disagree that the Court’s two privileged rulings are supported by precedent.


16

material protected by the attorney-client privilege, or material that is protected by both. Courts

vigorously protect parties’ privileges and, with respect to the “core” work product protection

invoked here, such materials “enjoy[] a nearly absolute immunity and can be discovered only in

very rare and extraordinary circumstances.” In re Allen, 106 F.3d 582, 607 (4th Cir. 1997).

The basis of the Committee’s argument is its notion that a waiver obtains whenever “a

litigant asserts a claim that in fairness requires examination of protected communications.”26 As

noted, the Committee persists in its belief that its “settlement approach” should drive further

determinations in these proceedings and argues that, to the extent Debtors oppose the use of

settlements to measure their liability, Debtors must explain “why” they settled claims.27 When

they do, the Committee says, they make the “advice and work product of [Debtor’s] lawyers”

relevant and create “at issue” waiver.28

The Committee’s argument badly misses the mark. Under applicable precedent, the test

whether a party has put attorney advice “at issue,” and therefore waived privileges surrounding

that advice, is not whether advice is “relevant” or that “fairness” dictates waiver, the test is

whether a litigant has taken an “affirmative step” of disclosing, as an “element of his claim or

defense,” a privileged, attorney-client communication. Rhone-Poulenc Rorer Inc. v. Home

Indem. Co., 32 F.3d 851, 863-64 (3d Cir. 1994) (“Rhone”). Debtors have not done that here.

Should it be necessary for Debtors to further explain “why” they settled asbestos claims,

it will likely be because the Committee has sought to re-hash some version of its “settlement

approach” not because of an “affirmative step” by Debtors. Debtors have consistently opposed

the use of past settlements as a basis to value present and future claims, not only because that use

26 Motion at 6. 27 Id. at 9. 28 Id.


17

is prohibited by Fed. R. Evid. 408, but because settlements are not reflective of liability for many

of the reasons the Court recognized in the Estimation Opinion. Debtors, instead, will advance the

“legal liability” approach articulated above to estimate non-mesothelioma claims.

Moreover, by explaining “why” Debtors settled past cases, Debtors would not be

disclosing attorney communications or advice, another requisite to finding an “at issue” waiver.

Debtor witnesses can provide testimony concerning Debtors’ “state of mind,” viz., the “reasons

they settled cases,” without revealing actual advice that may have influenced their decisions.

Just because attorney counsel and advice may have been relevant to decisions does not mean the

advice has been put “at issue” and a waiver should obtain.29

The leading case on the subject—and the one that has been consistently applied in this

District—is the decision of the Third Circuit in Rhone. In that case, the Third Circuit extensively

discussed the question of “at issue” waiver, considered case law on the subject in depth, then

held that the circumstances where “at issue” waiver applied were very specific and limited to the

instance articulated above, where a party discloses advice to prove a claim or defense. Id. at 863-

64. The Rhone court provided an extensive discussion of cases that included examples of “at

issue” waiver, which it used to illustrate the narrow circumstances that compelled waiver. Thus,

for instance, where a plaintiff files a malpractice action against his lawyer, the plaintiff waives

the privilege through “at issue” waiver because he must disclose the advice he is complaining

about as an element of his claim. Id. at 864. Similarly, where a party asserts that his tax position

was reasonable because he relied on his attorney’s advice, he creates an “at issue” waiver by

revealing the content of that advice to justify his non-compliance. Id.; see also id. (identifying

other examples of “at issue” waiver).

29 Rhone, 32 F.3d at 864.


18

The Rhone court expressly rejected the position that the Committee takes here, that there

is “at issue” waiver where attorney advice is relevant to “state of mind”—here, the “reasons”

Debtors settled claims:

Advice is not in issue merely because it is relevant, and does not necessarily become an issue merely because the attorney’s advice might affect the client’s state of mind in a relevant manner. The advice of counsel is placed in issue where the client asserts a claim or defense, and attempts to prove that claim or defense by disclosing or describing an attorney client communication.

Id. at 863.

The Committee tries to argue that there might be some room under Rhone to find waiver,

but the cases the Committee cites say otherwise. The first case, Livingston v. North Belle Vernon

Borough, 91 F.3d 515 (3d Cir. 1996), was one where a plaintiff sought to avoid the effect of a

release on the basis that she did not appreciate the legal implications of what she was signing. Id.

at 537. Under case law relevant to her claim, the court held, disclosure of the content of “advice

of counsel” was necessary to prove her assertion, and so there was a waiver consistent with the

Rhone test. In finding waiver, the court made clear that where, like here, privileged matters are

merely relevant to “state of mind,” the court will not find waiver. Id. at n.36.

Similarly, the District Court’s decision in LendingTree, LLC v. Zillow, Inc., 2013 WL

6385297 (W.D.N.C. Dec. 6, 2013) cited by the Committee does not support waiver in this case.

In that case, a plaintiff, in response to defendant’s assertion that a claim was barred by laches,

stated that it became aware of defendant’s infringing conduct when that conduct was brought to

its attention by plaintiff’s counsel, one month after the date its claim would have been barred by

laches. Id. at *2-3. Because the plaintiff’s response to the assertion of laches cited, specifically,

the content of counsel’s communication to plaintiff notifying it of defendant’s infringing

conduct, Judge Keesler ruled, consistent with Rhone, that there was waiver. Id. at *8.


19

Notable about Judge Keesler’s decision is that he did not recognize the kind of waiver

sought by the Committee. In his decision, he pointed out that the discovery sought by defendant

was discovery specifically tailored to elicit “facts,” not to uncover privileged advice or counsel

opinions. Although he found waiver and ordered discovery, Judge Keesler limited that discovery

to facts surrounding plaintiff’s notice of defendant’s conduct, and allowed LendingTree leeway

to redact materials to avoid revealing attorney opinion and advice distinct from those facts. Id.

Debtors have not, like the plaintiff in LendingTree, referred to specific communications as part

of any claim—so the basis of waiver there does not apply here. Moreover, Judge Keesler’s

cautious handling of the limited waiver illustrates that a wide-ranging inquiry into years of

counsel opinion and advice is unsupported by law.

2. Other Cases that the Committee Relies On Do Not Support Waiver In This Context

The Committee tries to hang its hat on the 40-year old decision of Hearn v. Wray, 68

F.R.D. 574 (E.D. Wash. 1975).30 In that case, an incarcerated plaintiff had brought civil rights

claims against wardens responsible for his deplorable confinement, and the wardens, in response,

raised a qualified immunity defense, which required the wardens to prove they acted in good

faith in making decisions regarding the plaintiff’s confinement. Important to that defense, and in

particular the defendants’ states of mind, was guidance provided by the state attorney general to

the two wardens concerning the plaintiff’s confinement. The court held that the facts of the case

compelled recognition of a “new and narrowly limited exception to the attorney-client privilege”

that applied in civil rights suits against state officials where those officials “assert[] the

affirmative defense of good faith immunity.” Id. at 580. In those circumstances, the court held,

30 Motion at 6.


20

the wardens, by raising a qualified immunity defense, undertook an “affirmative act” of putting

the attorney general’s guidance at issue and waived any privilege. Id.

The facts of that case are distinguishable from those here; waiver in the context of advice

provided by a state attorney general to public officials concerning the treatment of prisoners is

far different from an effort by an asbestos defendant’s ongoing adversaries to obtain a broad

waiver of privilege for all former claims. Even if it were not, the ruling in Hearn requires as a

condition for waiver that the party take “some affirmative act” before waiver will be recognized.

Debtors have not done that here. Debtors acknowledge that Hearn has been cited by many other

courts, but its applicability outside the context of that case was severely limited by Rhone and its

continued applicability is doubtful.

Rhone, in fact, spoke directly to Hearn and eviscerated the decision to the extent that

litigants, such as the Committee, have held Hearn up for the proposition that a waiver exists

when privileged material is “relevant” and “fairness requires examination.”31 Granting a

mandamus petition to reverse a district court that had relied on Hearn, the Third Circuit said:

These decisions are of dubious validity. While the opinions dress up their analysis with a checklist of factors, they appear to rest on a conclusion that the information sought is relevant and should in fairness be disclosed. Relevance is not the standard for determining whether or not evidence should be protected from disclosure as privileged, and that remains the case even if one might conclude the facts to be disclosed are vital, highly probative, directly relevant or even go to the heart of an issue.32

The Motion cites other cases to try to support the relief it seeks, but they do not

support the Committee either. Those cases present completely different facts, all of

31 Id. 32 Rhone, 32 F.3d at 864. Notably, Fourth Circuit Judge Diaz, when writing for the North Carolina Business Court, examined, in depth, the doctrines of Rhone and Hearn and concluded that Rhone should control. Banc of Am. Securities, LLC v. Evergreen Int’l Aviation, Inc., No. 03-CVS-9138, 2006 NCBC 2, 2006 WL 401679, ¶¶ 23-28 (Diaz, J.) (N.C. Bus. Ct. Jan. 25, 2006).


21

which, by contrast to the circumstances here, involved circumstances where litigants

disclosed advice or otherwise specifically pointed to privileged materials as part of their

claim or defense. See Motion 7-8, n.13.33 None support the Committee’s broad waiver.

3. Asbestos Settlement Litigation Cases Have Held There Should Be No Waiver

At the same time, the Committee overlooks two particularly instructive federal district

court cases. Those are two cases where asbestos defendants sued asbestos plaintiffs’ counsel

asserting fraud in the settlement of asbestos claims. In CSX Transportation, Inc. v. Pierce, a case

that led to a jury verdict against plaintiffs’ counsel and affiliates,34 the District Court for the

Northern District of West Virginia considered the same argument for “at issue” waiver that the

Committee makes.35 There, defendants (who were asbestos plaintiffs’ counsel and affiliates)

argued that CSX, by challenging asbestosis settlements, had put “CSX’s state of mind, its

knowledge and information, its settlement practices in FELA asbestosis actions, and its ability to

defend against FELA actions” at “issue.”36 The defendants, like the Committee here, insisted that

the court should recognize an “at issue” waiver and compel production of privileged “internal

claims department files.”37

33 In re Kidder Peabody Sec. Litig., 168 F.R.D. 459, 470 (S.D.NY. 1996) (party disclosed findings of investigative report, thereby waiving protections); Small v. Hunt, 152 F.R.D. 509, 511-12 (E.D.N.C. 1994) (put in issue circumstance considered by public prison system negotiation committee when seeking to modify settlement based on changed circumstances); Charlotte Motor Speedway, Inc. v. Int’l Ins. Co., 125 F.R.D. 127 (M.D.N.C. 1989) (in insurance context insurer paying liability has access to circumstances that led to settlement); Truck Ins. Exch. v. St. Paul Fire & Marine Ins. Co., 66 F.R.D. 129 (E.D. Pa. 1975) (same). 34 See CSX Transportation Inc. v. Peirce, 5:05-cv-00202 Amended Judgment in a Civil Case (Sept. 25, 2013) (N.D. W.Va.) (Docket No. 1636). 35 See CSX Transportation Inc. v. Peirce, 5:05-cv-00202 Order dated March 27, 2012 at 10-11 (N.D. W.Va.) (attached as Ex. G) (hereafter, “CSX Order”). 36 See id. at 10-11. 37 See id.


22

The court rejected defendants’ argument, applying Rhone, and holding that CSX would

not create a waiver by putting its “state of mind” at issue.38 “[A]lthough [CSX] asserts claims of

fraud among others, for relying on representations made by Defendant Coulter and the other

Lawyer Defendants,” the court stated, “it has never put advice received by its attorneys at issue,

nor has it disclosed any of its attorney client communications.”39 Accordingly, CSX did not

create a “general ‘at issue’ implied waiver of the attorney-client privilege” even when it alleged

that plaintiffs’ counsel defrauded it in the context of resolving asbestos personal injury claims.

The District Court for the Southern District of Mississippi reached the same result in

response to a similar argument in Illinois Central Railroad Company v. Harried. In that case,

asbestos defendant Illinois Central also brought a fraud claim against plaintiffs’ counsel and a

plaintiff based on alleged misrepresentations in asbestos settlements it had made. Ill. Cent. R.R.

Co. v. Harried, No. CIVA 5:06CV160-DCB-JMR, 2009 WL 2425985, at *1 (S.D. Miss. Aug. 6,

2009). The defendants argued, like the Committee does here, that Illinois Central waived the

attorney-client privilege when it sued them for fraud by placing “at issue” the information it

relied on in settling the claim. Harried, 2010 WL 583938, at *1. The court rejected the argument.

Citing Rhone the court held: “[Illinois Central] has put at issue its reliance on the information

provided to it by [Harried] . . . . [Illinois Central] has not put at issue the advice or information

provided by its own attorneys.” Id.

4. Precedential Considerations and Foresight Counsel Against Recognizing Broad Waiver

Finally, the Court should recognize the broader principles at play in the Committee’s

Motion. Fed. R. Evid. 408 provides that parties’ compromises of legal claims cannot be

38 See id. at 12. 39 See id.


23

admitted in another proceeding to determine the validity or amount of a claim. Notwithstanding

that promise, if the Committee were right about the scope and basis for waiver, every debtor that

opposed the use of settlements to determine its liability—a use prohibited by Rule 408—would

broadly waive all of its privileges in application to any past case, an obviously absurd result.

Likewise, if there were a basis for the Committee’s Motion, that would mean that these

Debtors, in seeking confirmation of a Plan that provides for post-confirmation litigation, as a

condition to confirming that plan, must disclose to their presumptive adversaries in post-

confirmation litigation, the core work product material they utilized to defend against those

claims. That result is similarly absurd and obviously contrary to law.

E. The Court Should Not, Under the Guise of Enforcement, Order Debtors to Produce Documents the Committee Has Not Requested.

The Committee brought its motion to compel under the authority of Fed. R. Civ. P.

37(a)(3)(B) and Fed. R. Bankr. P. 7037(a)(3)(B) which allow parties to enforce discovery

requests that have properly been propounded and to which adversaries have improperly failed to

respond. With respect to Requests 2, 3, and 4, Debtors have complied with those requests and

provided responsive documents. It is true that Debtors identified only two cases, Robertson and

Dexter, in response to those requests, but that was all Debtors were required to do.

The sanctioning powers of Rule 37 are rooted in the principles that the moving party has

properly propounded discovery, the opposing party has responded, and the parties have conferred

and narrowed their dispute. See Fed. R. Civ. P. 37(a). Rule 37 is not a mechanism, however, for a

party to try to compel the production of discovery the party had not previously propounded and

to which his adversary did not have a chance to respond.

If it were, that would transform civil discovery from a practice undertaken by parties into

unending litigation that brings every discovery matter before the Court. The Committee’s effort


24

to compel, under the “guise” it has served document requests for 600 cases and all non-

mesothelioma verdicts,40 is an improper use of the authority of Rule 37 and should be denied.

Had the Committee bothered to serve the discovery proposed in its Motion or even to

confer with Debtors before filing its Motion, Debtors would have explained that, by and large,

discovery of the 600 non-mesothelioma claims it seeks is unlikely to yield documents useful to

the investigation of the subjects of Requests 2, 3, and 4. Almost all of Debtors’ non-

mesothelioma settlements were for low amounts that did not reflect any individual evaluation of

claims. It is thus probable that, once the Committee identifies the 600 claims it plans to

investigate, there will be few, if any, responsive documents (much less privileged documents) for

most of these claims, and it will be a substantial waste of time.

F. The Court Should Deny the Committee’s Apparent Demand That Debtors’ Outside Counsel Search for Information Related to Claims In Which They Had No Involvement

The Committee’s Motion appears to argue that, whatever documents are provided in

response to Requests 2 and 3,41 the Court should compel Debtors and Debtors’ counsel to

undertake a massive search beyond the persons who were involved in the claims subject to

discovery. Debtors set forth in their responses that they would provide responsive documents for

any identified claim and produce documents from their files and the files of attorneys “involved

in the representation of Debtors with respect to the asbestos claimant(s) identified.” See

Response 2. Nonetheless, the Committee’s Motion complains and argues that Debtors’ search

40 The Committee’s request that Debtors provide documents responsive to Request 2 for non-mesothelioma verdicts does not seek privileged materials because the privileged materials it seeks relate to “pre settlement” matters and those cases were not settled. Request 15 of the Committee’s Requests sought, and Debtors provided responsive documents, for non-mesothelioma plaintiff verdicts. There is no suggestion that Debtors have not complied with that request either. The Committee ‘s Motion appears seeks to additional documents non-mesothelioma defense verdicts that were never requested. 41 Motion at 14.


25

must extend to the files of all Garlock’s counsel, whether or not they were involved in the

specified claimant’s case.

That position is patently unreasonable. It is a substantial waste of resources to require

every lawyer who ever represented Debtors to search for documents that may be relevant to

cases in which they were never involved. To the extent the Committee proposes to involve

Debtors’ outside counsel in cases they had nothing to do with, the Motion should likewise be

denied.

CONCLUSION

For the foregoing reasons, the Committee’s Motion should be denied.


26

This 29th day of September. Respectfully submitted, /s/ Garland S. Cassada Garland S. Cassada N.C. Bar No. 12352 Jonathan C. Krisko N.C. Bar No. 28625 Richard C. Worf, Jr. N.C. Bar No. 37143 Robinson Bradshaw & Hinson, P.A. 101 North Tryon Street, Suite 1900 Charlotte, North Carolina 28246 Telephone: (704) 377-2536 Facsimile: (704) 378-4000 [email protected] [email protected] [email protected] Special Corporate and Litigation Counsel to the Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company


EXHIBIT A

1619511

UNITED STATES BANKRUPTCY COURT

FOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

:

In re: : Case No. 10-BK-31607

:

GARLOCK SEALING : Chapter 11

TECHNOLOGIES, LLC, et al., :

: Jointly Administered

Debtors. :

:

OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS’

FIRST SET OF INTERROGATORIES DIRECTED TO THE DEBTORS

REGARDING CONFIRMATION ISSUES

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, made applicable to

these proceedings by Rules 7026, 7033 and 9014 of the Federal Rules of Bankruptcy Procedure,

the Official Committee of Asbestos Personal Injury Claimants (“Committee”) hereby requests

that the “Debtors”1 answer under oath the following Interrogatories.

INSTRUCTIONS

1. Pursuant to Rule 26(e)(1) of the Federal Rules of Civil Procedure, as incorporated

by Rules 7026 and 9014 of the Federal Rules of Bankruptcy Procedure, these Interrogatories

shall be continuing and if, at any time after the date on which you produce responses to these

Interrogatories, you discover, obtain, or otherwise come into possession of additional

information or documents responsive to these Interrogatories, you must promptly supplement

your response hereto by producing such information or documents.

1 The Debtors are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd.,

and The Anchor Packing Company.

- 2 -

2. Where knowledge or information of a person is requested or possession or control

by a person is inquired of, such request or inquiry includes knowledge, information, possession

or control of or by the person’s employees, agents, representatives, and the person’s attorneys.

3. As used herein, the present tense shall include the past tense and the past tense shall

include the present tense.

4. As used herein, the singular shall include the plural and the plural shall include the

singular.

5. If any Interrogatory cannot be answered fully, answer to the extent possible,

specifying the reasons for your inability to answer the remainder and stating whatever

information, knowledge, or belief you do have concerning the unanswered portion.

6. Answer each Interrogatory separately. When an Interrogatory has several parts,

answer each part separately.

7. If any objection is made to an Interrogatory, or any portion thereof, specify the

precise ground of the objection.

8. If all or any part of any Interrogatory is objected to on the grounds that it seeks

privileged information, or all or any part of any response thereto is withheld under any claim of

privilege (including work product protections), for each such objection or claim, the responding

party shall identify the nature of the privilege that is being claimed, and provide as to each

communication for which the privilege is invoked sufficient information to enable the Court to

assess the applicability of the asserted privilege or protection. Such information shall include (i)

the name of the person(s) making the communication and the names of persons present while the

communication was made (or the recipients of the communication) and, where not apparent, the

relationship of the persons present to the person making the communication; (ii) the date and

- 3 -

place of the communication; (iii) the type of communication (e.g., letter, conversation, voice

mail message, electronic mail, etc.); and (iv) the general subject matter of the communication.

DEFINITIONS

1. “Anchor” means The Anchor Packing Company and its merged or acquired

predecessors-in-interest.

2. “Anchor Asbestos-containing Product” as used herein means any

Asbestos-containing Product at any time manufactured, sold, processed, installed, or distributed by

Anchor, and includes any such product that Anchor licensed others to manufacture, sell, process,

install, or distribute.

3. The word “and” includes “or” and vice versa.

4. The word “any” is also used in the inclusive sense, i.e., “any and/or all.”

5. “Asbestos” shall include all asbestos or asbestiform minerals of either the

amphibole or serpentine group, including, without limitation, chrysotile, amosite, crocidolite,

tremolite, anthophyllite, and actinolite.

6. An “Asbestos Claimant” is anyone who asserts or has asserted an Asbestos PI

Claim.

7. An “Asbestos PI Claim” means any formal or informal lawsuit, workers’

compensation claim, legal process, civil action, demand letter, notice of claim, proof of claim, or

any similar assertion advanced by an individual (or an individual’s personal representative) against

Garlock or Anchor alleging bodily injuries or wrongful death allegedly caused by exposure to

Asbestos or Asbestos-containing Products. “Asbestos PI Claims” includes any claim or demand

ever asserted against Garlock or Anchor regardless of how such claim was resolved (by settlement,

- 4 -

dismissal, or otherwise) and regardless of whether such claim resulted in the filing of a civil lawsuit

by the claimant.

8. “Asbestos-containing Product” is an inclusive term and includes, but is not limited

to, gaskets, sealants, Asbestos, raw Asbestos, mined Asbestos, milled Asbestos, Asbestos

compounds, materials and products or equipment containing Asbestos or Asbestos particles, as well

as dust and fibers resulting from Asbestos or Asbestos particles. “Asbestos-containing Product” is

specifically not limited with respect to product type or form and includes all product types and/or

forms.

9. The words “Asbestos-related Disease” or any similar words, as used herein

includes, but is not be limited to: asbestosis, mesothelioma, pleural plaques, pleural thickening,

pleural effusion, lung cancer, laryngeal cancer, gastro-intestinal cancers, or any other condition

associated with, or allegedly associated with, exposure to Asbestos or Asbestos-containing

Products.

10. “Causation Issues” means the following issues pertaining to an Asbestos PI

Claim:

a. whether use of or exposure to Garlock Asbestos-containing Products or

Anchor Asbestos-containing Products is capable of causing, or of being a

substantial factor contributing to the causation of, any Asbestos-related

Disease generally; and

b. whether a specific individual’s use of or exposure to a Garlock Asbestos-

containing Product or Anchor Asbestos-containing Product caused, or was a

substantial factor contributing to the causation of, that specific individual’s

Asbestos-related Disease.

- 5 -

11. “CMO” means the Case Management Order for Post-Confirmation Allowance of

Disputed GST Asbestos Claims Electing Litigation Option that forms part of the Plan.

12. “Coltec” means Coltec Industries, Inc., and its merged or acquired predecessors-in-

interest.

13. The words “Communication” or “Communications” include, without limitation,

any oral communication, whether transmitted in meetings, by telephone, telegraph, telex, cable, tape

recordings, voice-mail or otherwise, and all written communications, including communications by

e-mail or other Internet-based communications system.

14. The word “Correspondence” means any “document” (as defined below) that either

constitutes a communication between two or more entities or persons, or that records, memorializes,

or reflects such communication, whether made directly to the author of the Document or otherwise.

15. “CRP” means the Settlement Facility Claims Resolution Procedures that form

part of the Plan.

16. “Debtors” means Garlock Sealing Technologies LLC, Garrison Litigation

Management Group, Ltd., and The Anchor Packing Company, or any of them, and all of their

merged or acquired predecessors-in-interest, whether or not debtors.

17. The words “Document” or “Documents” mean all materials within the full scope

of Federal Rule of Civil Procedure 34, including: all writings and recordings, including the

originals and all non-identical copies, whether different from the original by reason of any

notation made on such copies or otherwise (including, without limitation, e-mail and

attachments, correspondence, memoranda, notes, diaries, minutes, statistics, letters, telegrams,

minutes, receipts, returns, summaries, pamphlets, books, interoffice and intraoffice

communications, offers, notations of any sort of conversations, working papers, applications,

- 6 -

permits, file wrappers, indices, telephone calls, meetings, printouts, teletypes, telefax, invoices,

worksheets, and all drafts, alterations, modifications, changes, and amendments of any of the

foregoing), graphic or aural representations of any kind (including, without limitation,

photographs, charts, microfiche, microfilm, videotape, recordings, motion pictures, plans,

drawings, surveys), and electronic, mechanical, magnetic, optical, or electronic records or

representations of any kind (including, without limitation, computer files and programs, tapes,

cassettes, discs, recordings, and metadata).

18. “Garlock” means Garlock Sealing Technologies LLC and its merged or acquired


19. “Garlock Asbestos-containing Product” as used herein means any


Garlock, and includes any such product that Garlock licensed others to manufacture, sell, process,


20. As used herein, “Identify” has the following meanings:

a. When used with reference to a Document, to “identify” means to provide

the following information: (i) to state the type of Document (e.g., letter, agreement,

memoranda, etc.); the date of the Document; its general subject matter; and the

total number of pages thereof; (ii) to give the name and address of each person who

authored or created the Document; of each person, if any, to whom the Document

was addressed; the names and addresses of all persons to whom copies of the

Document were to be or have been sent; and the firm or firms with which all such

persons were associated at the time the Document was prepared or sent; and (iii) to

- 7 -

state whether the original is within your possession, custody, or control, and to

identify each person in possession of the Document or a copy thereof.

b. When used with reference to a person or entity, other than an Asbestos

Claimant, to “identify” means to provide the following information: (i) with

respect to an individual, state the name, present address (or, if unknown, the last

known address), employer, title, and exact duties and responsibilities of such

individual; and (ii) with respect to any sole proprietorship, corporation, partnership,

trust, association, joint venture, and all other incorporated or unincorporated

governmental, public, social, or legal entities, to state the name of the organization

and the address of its principal office.

c. When used with reference to an Asbestos Claimant, to “identify” means to

provide the following information: (i) provide the full name and social security

number of the claimant; (ii) the claimant’s alleged Asbestos-related Disease; (iii)

the identifying number assigned to the claimant’s claim in the Debtors’ database

(the “Colt I.D. Number”); (iv) the name and address of the law firm that was

counsel of record for the claimant with respect to his or her Asbestos PI Claim; (v)

the date the claim was made; and, (vi) if resolved, the date of resolution.

21. “Including” or “includes” means “including without limitation.”

22. “Key Personnel” means President, Chief Executive Officer, Vice President,

General Counsel, Chief Financial Officer, Chief Operations Officer, General Manager, Trustee,

or any person with authority to pay or settle asbestos claims.

23. “Non-Debtor Affiliate” means any “Affiliate” as defined in the Plan, other than one

of the Debtors, and its merged or acquired predecessors-in-interest.

- 8 -

24. “Non-malignant Asbestos-related Disease” includes asbestosis, pleural plaques,

pleural thickening, pleural effusion, or any other Asbestos-related Disease which is non-cancerous.

25. “Non-malignant PI Claim” is an Asbestos PI Claim in which the bodily injury or

wrongful death is associated with a Non-malignant Asbestos-related Disease.

26. “Non-meso PI Claim” is an Asbestos PI Claim in which the bodily injury or

wrongful death is associated with an Asbestos-related Disease other than mesothelioma.

27. “Non-meso Cancer PI Claim” is an Asbestos PI Claim in which the bodily injury

or wrongful death is associated with a cancer or malignant Asbestos-related Disease other than

mesothelioma.

28. The word “or” is used in the all-inclusive sense.

29. The “Plan” means the Debtors’ Second Amended Plan of Reorganization [Dkt. No.

4306], filed on January 14, 2015, and all of its exhibits, including any amendments.

30. A Document is in the “possession, custody, or control” of a person or entity if

such person or entity has the legal right to obtain the Document, regardless of its source or

present location.

31. The words “you” and “your” means the Debtors as defined herein.

32. The words “concerning,” “relate to,” “relating to,” “refer to,” “referring to,” as

well as “pertain to” and “pertaining to,” mean recording, summarizing, constituting, digesting,

referencing, commenting on, describing, evidencing, reporting, listing, analyzing, studying, or

otherwise discussing or mentioning in any way an identified subject matter.

33. Capitalized words not defined herein shall have the meanings defined in the Plan.

- 9 -

INTERROGATORIES

1. Separately for Garlock and Anchor, and separately for (a) closed or resolved

claims, and (b) pending claims filed after December 31, 2005, please provide the following

information: Do the Debtors contend that Non-meso Cancer PI Claims or Non-malignant PI

Claims have been the subject of suppression, withholding, or misrepresentation of evidence of

exposure to Asbestos-containing Products on the part of Asbestos Claimants or their counsel? If

the answer is anything but an unqualified “no,” then:

a. Identify each Asbestos Claimant whose claim has been the subject of such

suppression, withholding, or misrepresentation of evidence of exposure to

Asbestos-containing Products;

b. Identify all persons with knowledge of the alleged suppression, withholding,

or misrepresentation of evidence; and

c. If the claim has been resolved, describe and quantify the effect of the alleged

suppression, withholding, or misrepresentation of evidence on the resolution

of the claim.

2. Separately for Garlock and Anchor, and separately for (a) closed or resolved

claims, and (b) pending claims filed after December 31, 2005, please provide the following

information: Do the Debtors contend that Non-meso Cancer PI Claims or Non-malignant PI

Claims are or were based on a fraudulent or otherwise improper screening, diagnosis, or medical

documentation of Asbestos-related Disease? If the answer is anything but an unqualified “no,”

then:

a. Identify each Asbestos Claimant whose Non-meso Cancer PI Claim or Non-

malignant PI Claim is or was based on fraudulent or otherwise improper

- 10 -

screening, diagnosis, or medical information, and state the nature of the fraud,

impropriety or other issue with the screening, diagnosis, or medical

information;

b. Identify all persons with knowledge of the alleged fraud or impropriety; and

c. If the claim has been resolved, describe and quantify the effect of the fraud or

impropriety on the resolution of the claim.

3. Separately for Garlock and Anchor, and separately for (a) claims settled for

payment in the 1990s and (b) claims settled for payment after December 31, 1999, please

provide the following information: Do the Debtors contend that settlements of Non-meso

Cancer PI Claims or Non-malignant PI Claims were inflated because of defense costs? If the

answer is anything but an unqualified “no,” then:

a. Identify each Asbestos Claimant whose settlement of a Non-meso Cancer PI

Claim or Non-malignant PI Claim was inflated because of defense costs;

b. Identify all persons with knowledge of the factual basis of the alleged

inflationary impact of defense costs on the resolution of the claim; and

c. Describe and quantify the effect of the defense costs on the resolution of the

claim.

4. Explain how, before the Debtors filed bankruptcy, they quantified, recorded, and

allocated defense costs for Asbestos PI Claims (including whether such costs were quantified,

recorded, or allocated on a per-claim basis), and describe any changes in the Debtors’ practices

over time.

- 11 -

5. For the period 1990 through June 4, 2010, separately state on a yearly basis the

Debtors’ aggregate costs of defending against (i) Non-malignant PI Claims, and (ii) Non-meso

Cancer PI Claims.

6. Do the Debtors contend that Garlock Asbestos-containing Products or Anchor

Asbestos-containing Products cannot cause, or cannot substantially contribute to causing, any

Asbestos-related Diseases other than pleural or peritoneal mesothelioma, including lung cancer,

laryngeal cancer, other cancers of the gastro-intestinal system, asbestosis, pleural effusions,

pleural plaques, pleural thickening, pericardial mesothelioma, testicular mesothelioma, or any

other Asbestos-related Disease or health condition associated with Asbestos? If the answer is

anything but an unqualified “no,” then identify all Documents forming the factual basis for the

contention.

7. Identify each individual whom Garlock or Anchor designated to testify as an

expert witness with respect to any of the Causation Issues in connection with any Non-meso PI

Claim, and, for each such individual, identify each Non-meso PI Claim in which Garlock or

Anchor designated that individual to testify on any of the Causation Issues between January 1,

2000, and June 4, 2010.

8. Has Garlock or Anchor ever received an Asbestos PI Claim in which the injured

person alleged pericardial or testicular mesothelioma? If so, identify the Asbestos Claimant, the

disease and the Asbestos Claimant’s counsel, and describe the status of the claim, including, if

resolved, the terms on which the claim was resolved.

9. Identify all individuals who were substantially involved in, and describe their role

in, determining the Maximum Settlements and Fixed Payments incorporated in the CRP, the

factors by which and manner in which the Maximum Settlements will be discounted, the

- 12 -

asbestos exposure elements incorporated into the CRP (including but not limited to the

Occupation and Industry definitions, the GST Product Contact Requirement, the Contact Groups,

the Contract Group Factor, the Contact Source Factor, and the Alternative Exposure Intensity

Factor), and the medical elements incorporated into the CRP.

10. Identify and state the nature of each Released Claim, give the dates when the

Debtors commenced and concluded an investigation into the Released Claims, identify the

individuals who conducted the investigation, identify all individuals interviewed or questioned in

the course of the investigation, identify all Documents reviewed in the course of the

investigation, and identify all Documents setting forth or discussing questions posed, issues

identified, observations made, evidence compiled, analyses conducted, inferences drawn, or

conclusions reached in or as a result of the investigation.

11. State whether Garlock or Anchor directly or indirectly supplied Asbestos-

containing Products to any present or former Affiliate of the Debtors, including but not limited to

EnPro Industries, Inc., Coltec Industries, Inc., Fairbanks Morse Pump, Fairbanks Morse Engine,

Central Moloney Transformer, and Quincy Compressors. If the answer is anything but an

unqualified “no,” identify any such Affiliate and, separately for each of them, identify the

Asbestos-containing Products supplied, state when such supply transactions began and ended,

and state the annual volume in units and dollars of the Asbestos-containing Products so supplied.

12. Has any of the Debtors ever resolved by payment of indemnity the Asbestos PI

Claim of any Asbestos Claimant who, personally, or by an attorney, or through another witness,

asserted that the Asbestos-containing Product of any Affiliate was a source of asbestos exposure

to the injured person? If the answer is other than an unqualified “no,” please provide the

following information:

- 13 -

a. Identify each Asbestos Claimant whose resolved Asbestos PI claim meets the

foregoing description and each Affiliate whose Asbestos-containing Product such

claimant asserted was a source of asbestos exposure to the injured person.

b. As to the Asbestos PI Claim of each identified Asbestos Claimant, state the

amount paid by any of the Debtors to such claimant; state what portion, if any, of

the Debtors’ payment was allocated to any Affiliate, and identify any Affiliate to

whom such a portion was allocated; state what additional or separate amount, if

any, was paid to the Asbestos Claimant by any Affiliate and identify each

Affiliate that made such an additional or separate payment.

13. Have the Debtors or any Non-Debtor Affiliates, or their representatives, had any

Communications with any insurer, reinsurer, claims-handling entity, or other third party about

the Settlement Facility or Trust, including the possibility of insuring, reinsuring or operating the

same? If so, identify each entity with which any of the Debtors, Non-Debtor Affiliates, or

representatives have had any such Communication and the dates and persons involved in any

such Communications.

14. Identify any individuals who will be nominated or appointed, or have been or are

being considered for nomination or appointment, to serve as Key Personnel of Reorganized

Anchor, Reorganized GST, Reorganized Garrison, or the Settlement Facility. For each

individual identified, describe the position the individual will or may fill, including the entity,

title, and principal responsibilities, identify the individual’s current employer, describe his or her

current position and responsibilities, set forth the individual’s relevant qualifications, and state

whether the individual has ever been employed by, or retained as a professional by, any of the

- 14 -

Debtors, any Non-Debtor Affiliate, or any former affiliate, including a description of such

employment or retention.

CAPLIN & DRYSDALE, CHARTERED

By: /s/ Trevor W. Swett III

Trevor W. Swett III

([email protected])

James P. Wehner

([email protected])

Todd E. Phillips

([email protected])

One Thomas Circle, NW, Suite 1100

Washington, D.C. 20005

Telephone: (202) 862-5000

Facsimile: (202) 429-3301

Elihu Inselbuch

([email protected])

600 Lexington Avenue, 21st Floor

New York, New York 10152-3500

Telephone: (212) 319-7125

Facsimile: (212) 644-6755

MOON WRIGHT AND HOUSTON, PLLC

Travis W. Moon

([email protected])

227 W. Trade Street, Suite 1800

Charlotte, North Carolina 28202

Tel: (704) 944-6560

Fax: (704) 944-0380

Attorneys for the Official Committee of Asbestos

Personal Injury Claimants

Dated: June 2, 2015

EXHIBIT B

Case 10-31607 Doc 4865-2 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. B-ACC First RFP on Confirmation Issues Page 1 of 96

1620041

UNITED STATES BANKRUPTCY COURT

FOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

:

In re: : Case No. 10-BK-31607

:

GARLOCK SEALING : Chapter 11

TECHNOLOGIES, LLC, et al., :

: Jointly Administered

Debtors. :

:

OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS

FIRST REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED

TO THE DEBTORS ON CONFIRMATION ISSUES

Pursuant to Federal Rules of Civil Procedure 26 and 34, which are made applicable by

Federal Rules of Bankruptcy Procedure 7026, 7034 and 9014, the Official Committee of

Asbestos Personal Injury Claimants (“Committee”) hereby requests that each of the debtors in

the above-captioned case (the “Debtors”)1 produce the Documents described in the requests

below (the “Requests”) for inspection and copying at the offices of Moon Wright & Houston,

PLLC, 227 West Trade Street, Suite 1800, Charlotte, NC 28202, within thirty (30) days of the

date of these Requests, or at such other time and place as may be ordered by the Court or agreed

to by counsel. The production of Documents in response to the Requests herein shall be in

accordance with the instructions and definitions set forth below.

INSTRUCTIONS

1. Each Request set forth herein refers to all Documents and property in each of the

Debtors’ possession, custody, or control, as well as Documents and property in the possession,

custody, or control of each Debtor’s counsel, representatives, agents, servants, employees, experts,

1 The Debtors are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and

The Anchor Packing Company.


- 2 -

investigators, or consultants, and their counsel, representatives, agents, servants, employees, experts,

investigators, or consultants.

2. You must produce all non-identical copies of Documents, including drafts and

copies upon which notations or additional writings have been made.

3. If “e-mail” or other Documents stored electronically have been “deleted” from a

computer, but are still retrievable in some form, any such responsive Document should be

retrieved and produced, either in hard copy or a readily readable electronically recorded form.

4. If you claim that any of the Documents or property requested is privileged or subject

to immunity from discovery as trial preparation material or otherwise under the work product

doctrine, please identify each such Document or property in each Debtor’s possession, custody, or

control, and include in the identification a description of the Document or property, the date of the

Document or property, the names of the addressee and the addressor, the identity of any person to

whom a copy was given or communicated, the general subject matter of the Document or property,

a statement of facts constituting the basis for any claim of privilege or immunity, and a specific

basis on which privilege or immunity is claimed.

5. These Requests are not intended to be duplicative. All Requests should be

responded to fully to the extent not covered by other Requests. If there are Documents that are

responsive to more than one Request, please note and produce each such Document first in response

to the Request that is more specifically directed to the subject matter of the particular Document.

6. These Requests are continuing, to the full extent required or permitted under the

Federal Rules of Bankruptcy Procedure and the Federal Rules of Civil Procedure, including Federal

Rule of Civil Procedure 26(e)(1), so as to require supplementary production when you obtain


- 3 -

knowledge and access to, or possession, custody, or control of, any Documents not previously

produced that are responsive to one or more of these Requests.

7. As used herein, the present tense includes the past tense, and vice-versa.

8. As used herein, the singular includes the plural, and vice-versa.

9. Unless otherwise specified, these requests seek Documents created during or

relating to the period from January 1, 1990, through to the present.

DEFINITIONS

1. “Anchor” means The Anchor Packing Company and its merged or acquired


2. “Anchor Asbestos-containing Product” as used herein means any


Anchor, and includes any such product that Anchor licensed others to manufacture, sell, process,


3. The word “and” includes “or” and vice versa.

4. The word “any” is also used in the inclusive sense, i.e., “any and/or all.”

5. “Asbestos” shall include all asbestos or asbestiform minerals of either the

amphibole or serpentine group, including, without limitation, chrysotile, amosite, crocidolite,

tremolite, anthophyllite, and actinolite.

6. An “Asbestos Claimant” is anyone who asserts or has asserted an Asbestos PI

Claim.

7. An “Asbestos PI Claim” means any formal or informal lawsuit, workers’

compensation claim, legal process, civil action, demand letter, notice of claim, proof of claim, or


- 4 -

any similar assertion advanced by an individual (or an individual’s personal representative) against

Garlock or Anchor alleging bodily injuries or wrongful death allegedly caused by exposure to

Asbestos or Asbestos-containing Products. “Asbestos PI Claims” includes any claim or demand

ever asserted against Garlock or Anchor regardless of how such claim was resolved (by settlement,

dismissal, or otherwise) and regardless of whether such claim resulted in the filing of a civil lawsuit

by the claimant.

8. “Asbestos-containing Product” is an inclusive term and includes, but is not limited

to, gaskets, sealants, Asbestos, raw Asbestos, mined Asbestos, milled Asbestos, Asbestos

compounds, materials and products or equipment containing Asbestos or Asbestos particles, as well

as dust and fibers resulting from Asbestos or Asbestos particles. “Asbestos-containing Product” is

specifically not limited with respect to product type or form and includes all product types and/or

forms.

9. The words “Asbestos-related Disease” or any similar words, as used herein

includes, but is not be limited to: asbestosis, mesothelioma, pleural plaques, pleural thickening,

pleural effusion, lung cancer, laryngeal cancer, gastro-intestinal cancers, or any other condition

associated with, or allegedly associated with, exposure to Asbestos or Asbestos-containing

Products.

10. “Causation Issues” means the following issues pertaining to an Asbestos PI

Claim:

a. whether use of or exposure to Garlock Asbestos-containing Products or

Anchor Asbestos-containing Products is capable of causing, or of being a

substantial factor contributing to the causation of, any Asbestos-related

Disease generally; and


- 5 -

b. whether a specific individual’s use of or exposure to a Garlock-Asbestos-

containing Product or Anchor Asbestos-containing Product caused, or was

a substantial factor contributing to the causation of, that specific

individual’s Asbestos-related Disease.

11. “CMO” means the Case Management Order for Post-Confirmation Allowance of

Disputed GST Asbestos Claims Electing Litigation Option that forms part of the Plan.

12. “Coltec” means Coltec Industries, Inc., and its merged or acquired predecessors-in-

interest.

13. The words “Communication” or “Communications” include, without limitation,

any oral communication, whether transmitted in meetings, by telephone, telegraph, telex, cable, tape

recordings, voice-mail or otherwise, and all written communications, including communications by

e-mail or other Internet-based communications system.

14. The word “Correspondence” means any “document” (as defined below) that either

constitutes a communication between two or more entities or persons, or that records, memorializes,

or reflects such communication, whether made directly to the author of the Document or otherwise.

15. “CRP” means the Settlement Facility Claims Resolution Procedures that form

part of the Plan.

16. “Debtors” means Garlock Sealing Technologies LLC, Garrison Litigation

Management Group, Ltd., and The Anchor Packing Company, or any of them, and all of their

merged or acquired predecessors-in-interest, whether or not debtors.

17. The words “Document” or “Documents” mean all materials within the full scope

of Federal Rule of Civil Procedure 34, including: all writings and recordings, including the

originals and all non-identical copies, whether different from the original by reason of any


- 6 -

notation made on such copies or otherwise (including, without limitation, e-mail and

attachments, correspondence, memoranda, notes, diaries, minutes, statistics, letters, telegrams,

minutes, receipts, returns, summaries, pamphlets, books, interoffice and intraoffice

communications, offers, notations of any sort of conversations, working papers, applications,

permits, file wrappers, indices, telephone calls, meetings, printouts, teletypes, telefax, invoices,

worksheets, and all drafts, alterations, modifications, changes, and amendments of any of the

foregoing), graphic or aural representations of any kind (including, without limitation,

photographs, charts, microfiche, microfilm, videotape, recordings, motion pictures, plans,

drawings, surveys), and electronic, mechanical, magnetic, optical, or electronic records or

representations of any kind (including, without limitation, computer files and programs, tapes,

cassettes, discs, recordings, and metadata).

18. “FCR” means Joseph W. Grier III, the Future Claimants’ Representative.

19. “Garlock” means Garlock Sealing Technologies LLC and its merged or acquired


20. “Garlock Asbestos-containing Product” as used herein means any


Garlock, and includes any such product that Garlock licensed others to manufacture, sell, process,


21. As used herein, “Identify” has the following meanings:

a. When used with reference to a Document, to “identify” means to provide

the following information: (i) to state the type of Document (e.g., letter, agreement,

memoranda, etc.); the date of the Document; its general subject matter; and the

total number of pages thereof; (ii) to give the name and address of each person who


- 7 -

authored or created the Document; of each person, if any, to whom the Document

was addressed; the names and addresses of all persons to whom copies of the

Document were to be or have been sent; and the firm or firms with which all such

persons were associated at the time the Document was prepared or sent; and (iii) to

state whether the original is within your possession, custody, or control, and to

identify each person in possession of the Document or a copy thereof.

b. When used with reference to a person or entity, other than an Asbestos

Claimant, to “identify” means to provide the following information: (i) with

respect to an individual, state the name, present address (or, if unknown, the last

known address), employer, title, and exact duties and responsibilities of such

individual; and (ii) with respect to any sole proprietorship, corporation, partnership,

trust, association, joint venture, and all other incorporated or unincorporated

governmental, public, social, or legal entities, to state the name of the organization

and the address of its principal office.

c. When used with reference to an Asbestos Claimant, to “identify” means to

provide the following information: (i) provide the full name and social security

number of the claimant; (ii) the claimant’s alleged Asbestos-related Disease; (iii)

the identifying number assigned to the claimant’s claim in the Debtors’ database

(the “Colt I.D. Number”); (iv) the name and address of the law firm that was

counsel of record for the claimant with respect to his or her Asbestos PI Claim; (v)

the date the claim was made; and (vi) if resolved, the date of resolution.

22. “Including” or “includes” means “including without limitation.”


- 8 -

23. “Key Personnel” means President, Chief Executive Officer, Vice President,

General Counsel, Chief Financial Officer, Chief Operations Officer, General Manager, Trustee,

or any person with authority to pay or settle asbestos claims.

24. “Non-Debtor Affiliate” means any “Affiliate” as defined in the Plan, other than one

of the Debtors, and its merged or acquired predecessors-in-interest.

25. “Non-malignant Asbestos-related Disease” includes asbestosis, pleural plaques,

pleural thickening, pleural effusion, or any other Asbestos-related Disease which is non-cancerous.

26. “Non-malignant PI Claim” is an Asbestos PI Claim in which the bodily injury or

wrongful death is associated with a Non-malignant Asbestos-related Disease.

27. “Non-meso PI Claim” is an Asbestos PI Claim in which the bodily injury or

wrongful death is associated with an Asbestos-related Disease other than mesothelioma.

28. “Non-meso Cancer PI Claim” is an Asbestos PI Claim in which the bodily injury

or wrongful death is associated with a cancer or malignant Asbestos-related Disease other than

mesothelioma.

29. The word “or” is used in the all-inclusive sense. If, for example, a request calls for

any Documents that indicate x or y, any Documents that indicate both x and y should be produced,

as well as any Documents that indicate either x or y.

30. The “Plan” means the Debtors’ Second Amended Plan of Reorganization filed on

January 14, 2015 [Dkt. No. 4306] and all of its exhibits, including any amendments.

31. A Document is in the “possession, custody, or control” of a person or entity if

such person or entity has the legal right to obtain the Document, regardless of its source or

present location.

32. The words “you” and “your” means the Debtors as defined herein.


- 9 -

33. The words “concerning,” “relate to,” “relating to,” “refer to,” “referring to,” as

well as “pertain to” and “pertaining to,” when used in any of the Requests, mean recording,

summarizing, constituting, digesting, referencing, commenting on, describing, evidencing,

reporting, listing, analyzing, studying, or otherwise discussing or mentioning in any way a subject

matter identified in the Request.

34. Capitalized words not defined herein shall have the meanings defined in the Plan.

DOCUMENT REQUESTS

Debtors are requested to produce for inspection and copying the following Documents:

1. All Documents identified or referred to in the Debtors’ responses to the Official

Committee of Asbestos Personal Injury Claimants’ First Set of Interrogatories Directed to the

Debtors Regarding Confirmation Issues.

2. For each Asbestos Claimant identified in response to Interrogatory No. 1(a):

a. All Documents that form the factual basis for the Debtors’ contention;

b. All work histories, interrogatory answers, responses to requests for

admissions, or testimony provided by the identified Asbestos Claimants or

their product-identification witnesses with respect to sources of exposure to

Asbestos-containing Products, and all Documents reflecting the Debtors’ and

their defense counsel’s knowledge or information concerning such claimants’

occupations, industries, jobsites, and exposures to Asbestos-containing

Products;

c. All Documents setting forth discovery requests to the identified Asbestos

Claimants and all Documents setting forth responses to such requests;


- 10 -

d. All Documents discussing or reflecting pre-settlement evaluation by the

Debtors or their counsel of the claims of the identified Asbestos Claimants, or

internal settlement deliberations of the Debtors or their counsel regarding such

claims, including all Documents constituting or discussing Communications

between or among the Debtors, Non-Debtor Affiliates, and defense counsel

about those subjects;

e. All Documents setting forth the terms of any settlements of the claims of the

identified Asbestos Claimants, and all Documents concerning the negotiation

of the settlements, including all Communications with Asbestos Claimants’

counsel regarding negotiation of the settlements; and

f. For each claim of an identified Asbestos Claimant that was presented or

resolved within the framework of a processing agreement, case flow

agreement, or similar arrangement, all Documents constituting or setting forth

such agreement or arrangement, and any Documents constituting or discussing

Communications with Asbestos Claimants’ counsel about the negotiation of

such agreement or arrangement.



b. All Documents reflecting medical or health-related information provided by

the identified Asbestos Claimants, and all Documents reflecting the Debtors’

and their defense counsels’ knowledge or information concerning the

identified Asbestos Claimants’ medical condition or health;


- 11 -

c. All Documents setting forth discovery requests to the identified Asbestos


d. All Documents discussing or reflecting pre-settlement evaluation of the claims

of the identified Asbestos Claimants by the Debtors or their counsel, or their

internal settlement deliberations regarding such claims, including all

Documents constituting or discussing Communications between or among the

Debtors, Non-Debtor Affiliates, and defense counsel about those subjects;

e. All Documents constituting or setting forth any settlements of the claims of

the identified Asbestos Claimants, and all Documents concerning the

negotiation of the settlements, including all Communications with Asbestos

Claimants’ counsel regarding negotiation of the settlements; and

f. For each claim of the identified Asbestos Claimants that was presented or



such agreement or arrangement and any Documents constituting or discussing




a. All Documents that form part of the factual basis for the Debtors’ contention;

b. All Documents reflecting or evidencing inflation of such Asbestos Claimants’

settlements;


- 12 -

c. All Documents evidencing, compiling, or quantifying the nature and amount

of the Debtors’ defense costs with respect to such Asbestos Claimants’

settlements, individually or as part of a group of settlements;

d. All Documents setting forth discovery requests to the identified Asbestos


e. All Documents discussing or reflecting pre-settlement evaluation of the claims

of the identified Asbestos Claimants by the Debtors or their counsel, or their

internal settlement deliberations regarding such claims, including all

Documents constituting or discussing Communications between or among the

Debtors, Non-Debtor Affiliates, and defense counsel about those subjects;

f. All Documents constituting or setting forth any settlements of the claims of

the identified Asbestos Claimants, and all Documents concerning the

negotiation of the settlements, including all Communications with Asbestos

Claimants’ counsel regarding negotiation of the settlements; and

g. For each claim of the identified Asbestos Claimants that was presented or



such agreement or arrangement and any Documents constituting or discussing



5. All Documents discussing or setting forth any analyses, forecasts, reports, liability

estimates, valuations, or liability reserves related to Non-meso Cancer PI Claims or Non-


- 13 -

malignant PI Claims under the Plan or in the tort system, including estimates as to liability,

indemnity payments, expenditures, or defense costs.

6. All Documents discussing or setting forth the factual basis, assumptions, or

methodologies for any of the matters described in the immediately preceding Document Request.

7. All Documents discussing or setting forth any analysis of, estimation of, valuation

of, or reserves for the Debtors’ and any Non-Debtor Affiliates’ contributions and contingent

contributions to the proposed Litigation Fund or to the Settlement Facility as defined by the Plan.



9. All Documents discussing or setting forth any estimation, valuation, analysis, or

forecasting of the number or characteristics of claims that would be litigated pursuant to the

Litigation Option under the Plan, the outcomes of such claims, the cost of defending against such

claims, legal liability for such claims, or indemnity to be paid to resolve the claims.



11. All Documents discussing or setting forth the Debtors’ estimation, valuation,

analysis, or forecasting of defense costs under the Litigation Option, including any Documents

which evidence how defense costs under the Litigation Option would be allocated between the

Litigation Fund and the Settlement Fund or would compare to Garlock’s or Anchor’s historical

defense costs.

12. All Documents discussing or setting forth the Debtors’ estimation, valuation,

analysis, or forecasting of the costs of administering the Trust and Settlement Facility as outlined in

the Plan.


- 14 -



14. All Documents concerning modifications of, or changes to, the Parent Settlement

or any previous version of the Parent Settlement set forth in any previous version of the Plan

raised by, discussed with, sought by, or suggested by or to the FCR (or his representatives),

including all Communications relating to such modifications or changes between or among the

Debtors (or their representatives), the FCR (or his representatives), and any Non-Debtor

Affiliates (or their representatives).

15. For each Non-meso Cancer PI Claim or Non-malignant PI Claim that resulted in a

trial verdict against Garlock or Anchor between January 1, 1990, and June 5, 2010, produce:

a. The complaint, including any case information sheet required by the court;

b. All written discovery directed to the Asbestos Claimant, Garlock, or Anchor,

and all responses thereto including any supplementation;

c. Transcripts of any depositions taken in the case;

d. The jury instructions rendered by the court;

e. The complete trial transcript, including closing arguments presented to the

jury by any party;

f. The verdict sheet as returned by the jury;

g. Documents sufficient to show the following: the portion of the verdict

allocated to Garlock or Anchor, and the amount of any post-verdict settlement

or judgment paid by Garlock or Anchor (or bonded by Garlock or Anchor if

the judgment was appealed); and

h. Any briefs and decisions on appeal.


- 15 -

16. All Documents discussing or setting forth the Debtors’ historical settlement

strategies, settlement criteria, and internal goals for settling, resolving or addressing:

a. Non-malignant PI Claims;

b. Asbestos PI Claims related to lung cancer; and

c. Asbestos PI Claims related to laryngeal cancer.

17. All Documents constituting or concerning presentations by the Debtors, Non-Debtor

Affiliates, or defense counsel at any periodic meeting at which the Debtors’ strategy for defending

or resolving Asbestos PI Claims was discussed, including but not limited to presentations by or to

the Debtors’ regional defense counsel.

18. Documents sufficient to identify all pending Non-malignant PI Claims against the

Debtors that have been placed on any inactive court docket and the court in which the claims are

filed.

19. All contracts, agreements, purchase orders or similar Documents pursuant to

which Garlock or Anchor directly or indirectly supplied Asbestos-containing Products to any

present or former Affiliate of the Debtors, including but not limited to EnPro Industries, Inc.,

Coltec Industries, Inc., Fairbanks Morse Pump, Fairbanks Morse Engine, Central Moloney

Transformer, and Quincy Compressors.

20. Any Documents concerning specification, recommendation, or promotion by any

present or former Affiliate of the Debtors of Garlock Asbestos-containing Products or Anchor

Asbestos-containing Products as a component of or replacement part for such Affiliates’ own

products.

21. All Documents or Communications concerning Coltec’s or any other present or

former Affiliate’s involvement in the design, formulation, manufacturing, marketing, patenting,


- 16 -

branding, marketing, labeling (including warnings), sale, or decision to discontinue the

manufacture or sale of any Garlock Asbestos-containing Product or Anchor Asbestos-containing

Product.

22. All Documents containing any release or covenant not to sue that was delivered to

the Debtors or their Affiliates by any Asbestos Claimant identified in response to Interrogatory No.

12.

23. All Documents constituting agreements to toll statutes of limitations or repose

entered into by Anchor after January 1, 1998.

24. All Documents discussing or setting forth any Communications between Debtors (or

their representatives) and any insurers, the Bank of America, or any investment bank, financial

institution, or financial analyst that in any way relate to the Plan.

25. For each Asbestos PI Claim listed on the Debtors’ Exhibit GST-8001, produce all

Documents discussing or setting forth;

a. the agreement to settle the Asbestos PI Claim or the terms of the settlement;

b. the reasons why the Debtors settled or agreed to settle the Asbestos PI Claim;

c. the information and assumptions relied upon by the Debtors in settling or

agreeing to settle such claim; and

d. all Documents setting forth or discussing case analyses, claim evaluations,

risk assessments, cost computations or projections, settlement

recommendations, or advice prepared or provided by the Debtors’ litigation

counsel, regional defense counsel, in-house attorneys, or consultants with

respect to the Asbestos PI Claim or the resolution thereof.


- 17 -

26. The most recent status memoranda concerning Garlock’s available insurance

coverage for Asbestos PI Claims, including the most recent iteration of any Document similar to

that produced at GST-EST-0121856.

27. All Documents discussing or referring to the impact, if any, that the Order

Estimating Aggregate Liability in In re Garlock Sealing Technologies LLC, 504 B.R. 71 (Bankr.

W.D.N.C. Jan. 10, 2014), has had, is having, or is likely to have on the propensity of individuals

to sue makers, sellers, or users of Asbestos-containing Products for asbestos-related personal

injuries or wrongful death, on the conduct of litigation with respect to such claims in non-

bankruptcy courts, or on the outcomes of such claims.

28. All Communications between the Debtors or their representatives and Lloyd

Dixon, Geoffrey McGovern or Amy Coombe or their assistants or representatives concerning

any RAND study or paper relating to asbestos litigation or asbestos bankruptcy trusts.

29. All Documents concerning any review, approval, disapproval, audit, or evaluation

by any insurer or reinsurer of Garlock’s or Anchor’s actual or proposed settlements of any

Asbestos PI Claims or Garlock’s or Anchor’s practices, goals, cost estimates, or budgets for

defending or settling Asbestos PI Claims.

30. All Documents related to the valuation factors and discounts to be utilized as part of

the CRP and Settlement Option as proposed under the Plan, including but not limited to:

a. Documents describing how the factors and discounts were derived or how they

would be applied;

b. Spreadsheets, computer programs, or other electronic Documents that embody

or apply the CRPs such that settlement in real or hypothetical cases may be

calculated;


- 18 -

c. Documents concerning the application of the CRP to any sample or population

of actual Asbestos PI Claims, including both input data and results; and,

d. Documents concerning any model or precedent for the CRP or any valuation

factors and discounts that form part of the CRP.

31. All Documents discussing or setting forth the assumptions, input data, analyses,

methodologies, or calculations underlying

a. the “Summary of Estimated Payments by Contact Group for Current and Future

Mesothelioma Claimants (Second Amended Plan)” that the Debtors used with

the Bankruptcy Court as an exhibit on or about November 17, 2014 or any

subsequent version (including the version attached hereto as Addendum A);

b. Exhibit 1 to Debtors’ Reply to Limited Objection of Official Committee of

Asbestos Personal Injury Claimants to Proposed Disclosure Statement for

Debtors’ Second Amended Plan of Reorganization [Dkt. No. 4384], filed

February 13, 2015 (a copy of which is attached hereto as Addendum B).

32. All Documents constituting models or precedents for the CRP or any of its

provisions, including, but not limited to the industry and occupation classifications, the prescribed

claim values, and the exposure certification requirements set forth in Sections 4.5(c), 4.6(b), and

4.6(e) of the CRP.

33. At page 3 of Debtors’ Statement in Response to Asbestos Committee’s

Preliminary Confirmation Objections, the Debtors assert that “[t]he CRP thereby avoid paying

frivolous claims that could dilute assets set aside for future claimants, which is a problem that

has prevented other trusts from providing equal treatment to future claims.” Please produce all

Documents discussing or referring to any failure by existing asbestos trusts to provide equal


- 19 -

treatment to future claims, including any Documents discussing or referring to reasons for any

such failure and any Documents concerning the factual basis for the Debtors’ assertion that any

such trust has failed to provide, or been prevented from providing, appropriate treatment to

future claims.

34. Any case management orders, standing orders, general orders or rules adopted by

state or federal courts that contain or constitute models or precedents for the certification

requirements, standardized discovery, or other provisions found in the CMO or its Exhibits.

35. With respect to any Released Claim identified in the response to Interrogatory No.

10:

a. All Documents reviewed as part of the investigation and any Communications

between or among the Debtors (or their representatives), any Non-Debtor

Affiliates (or their representatives), any former affiliates of the Debtors or

Coltec (or their representatives), or the FCR (or his representatives)

concerning the investigation; and

b. All Documents discussing or setting forth questions posed, issues identified,

observations made, evidence compiled, analyses conducted, inferences drawn,

or conclusions reached by the Debtors (or their representatives) in the course,

or as a result, of the investigation into the Released Claim.

36. All Documents concerning FTI Consulting Inc.’s valuation and liquidation analyses

attached to the Disclosure Statement, including, but not limited to, Documents concerning the scope

of the assignment; instructions given for the assignment; any analyses, summaries, evaluations, or

reports created in the course of the assignment, including all drafts and working papers; and any


- 20 -

Communications between FTI Consulting Inc. and the Debtors or Coltec with respect to the

assignment.

37. All Communications between or among the Debtors (or their representatives), any

Non-Debtor Affiliates (or their representatives), and insurers, reinsurers, claims handling entities,

or other third parties about the Settlement Facility or Trust’s post-confirmation operations.

CAPLIN & DRYSDALE, CHARTERED

By: /s/ Trevor W. Swett III

Trevor W. Swett III

([email protected])

James P. Wehner

([email protected])

Todd E. Phillips

([email protected])

One Thomas Circle, NW, Suite 1100

Washington, D.C. 20005

Telephone: (202) 862-5000

Facsimile: (202) 429-3301

Elihu Inselbuch

([email protected])

600 Lexington Avenue, 21st Floor

New York, New York 10152-3500

Telephone: (212) 319-7125

Facsimile: (212) 644-6755

MOON WRIGHT & HOUSTON, PLLC

Travis W. Moon

([email protected])

227 West Trade Street, Suite 1800

Charlotte, North Carolina 28202

Telephone: (704) 944-6560

Attorneys for the Official Committee of Asbestos

Personal Injury Claimants

Dated: June 2, 2015


Addendum A


Addendum B


EXHIBIT 1

Case 10-31607 Doc 4384-1 Filed 02/13/15 Entered 02/13/15 17:05:51 Desc Ex. A-GST Resp to Statement of ACC Page 16 of 87


CRP Offers for Claims Pending on Petition DateLast Name First Name Lawyer Settlement offer

HOWDESHELL DONALD ADAMS CESARIO ATKINSON 43,717$ MILLINGTON CLARENCE ALKON RHEA 1,000$ PRYNE JAMES ALWYN LUCKEY 1,000$ CURRY SAMUEL ALWYN LUCKEY 1,000$ CAUDEL STANLEY ANANIA BANDKLAYDER BLACKWELL BAUMGARTEN 1,000$ WILLIAMS CLEVE ANANIA BANDKLAYDER BLACKWELL BAUMGARTEN 1,000$ JOHNSON CHARLES ANAPOL SCHWARTZ 71,228$ HAMBY JESSE ANAPOL SCHWARTZ 53,192$ GIBSON JAMES ANAPOL SCHWARTZ 37,491$ HENNING WILLIAM ANAPOL SCHWARTZ 36,673$ HAMIL JANE ANAPOL SCHWARTZ 35,600$ KING CHARLES ANAPOL SCHWARTZ 23,715$ ROGERS NATHANIEL ANAPOL SCHWARTZ 22,416$ LATHROP JOHN ANAPOL SCHWARTZ 18,479$ FIORE JAMES ANAPOL SCHWARTZ 16,231$ POOLE JOHN ANAPOL SCHWARTZ 14,372$ WEYMAN LESLIE ANAPOL SCHWARTZ 7,541$ WARD KATHERINE ANAPOL SCHWARTZ 7,511$ PETRUSKA EDWARD ANAPOL SCHWARTZ 6,173$ REED EDWARD ANAPOL SCHWARTZ 6,079$ STANDIG BERNARD ANAPOL SCHWARTZ 6,035$ SULLY BENJAMIN ANAPOL SCHWARTZ 5,219$ BUMBAUGH DANIEL ANAPOL SCHWARTZ 3,592$ FICKLER ISADORE ANAPOL SCHWARTZ 3,071$ CHRISTEN KARL ANDERMAN 1,000$ EDMONDS CLARENCE ASHCRAFT GEREL 7,311$ BADGERLY TERRI BAGGETT MCCALL 116,356$ LEBOUEF FLOYD BAGGETT MCCALL 34,110$ OQUAIN ELRIDGE BAGGETT MCCALL 2,257$ HARDY ARTISE BAGGETT MCCALL 1,000$ VINCENT GORDON BAGGETT MCCALL 1,000$ WILKERSON WANDA BAILEY PERRIN BAILEY 183,705$ LUNA ABUNDIO BAILEY PERRIN BAILEY 170,029$ SLOBODJIAN EMMA BAILEY PERRIN BAILEY 70,829$ MILLER MARLIN BAILEY PERRIN BAILEY 51,714$ FLOYD PEGGY BAILEY PERRIN BAILEY 35,247$ BLAZER GERALDINE BAILEY PERRIN BAILEY 22,700$ KOLBY STANLEY BAILEY PERRIN BAILEY 19,526$ WILSON THOMAS BAILEY PERRIN BAILEY 15,056$ CARTER MEASKYLA BAILEY PERRIN BAILEY 11,263$ EDWARDS BARBARA BAILEY PERRIN BAILEY 10,676$ FOLLIS JOHN BAILEY PERRIN BAILEY 9,051$ HARMS CARL BAILEY PERRIN BAILEY 8,506$ HAMMOND BERNARD BAILEY PERRIN BAILEY 6,725$ RODRIGUEZ PEDRO BAILEY PERRIN BAILEY 5,557$ NEELY RUBY BAILEY PERRIN BAILEY 4,446$ ELLERS JAMES BAILEY PERRIN BAILEY 3,283$ GIBBS ROBERT BAILEY PERRIN BAILEY 3,013$ REED FLOYD BARON BUDD 24,350$ MOHR HEINRICH BARON BUDD 1,000$ ANTKOWIAK THOMAS BARON BUDD 1,000$ KING JAMES BARON BUDD 1,000$ FANCHER WILLIAM BARON BUDD 1,000$ WALRATH CYRIL BARON BUDD 1,000$



CRP Offers for Claims Pending on Petition Date

Last Name First Name Lawyer Settlement offerMEISSNER MARVIN BARON BUDD 1,000$ WOODMAN WILLIAM BARON BUDD 1,000$ HANSON KATHERINE BARON BUDD 1,000$ PRAG JAMES BARON BUDD 1,000$ WENTWORTH CLARENCE BARON BUDD 1,000$ KELLEY WILLIE BARON BUDD 1,000$ DUMSTORFF LEON BARON BUDD 1,000$ PRINCE IVY BARON BUDD 1,000$ SANCHEZ ERNIE BARON BUDD 1,000$ MCCLAIN JOHN BARON BUDD 1,000$ FLEMING JOAN BARON BUDD 1,000$ VANHOUTEN JOHN BARON BUDD 1,000$ SHANAHAN JAMES BARON BUDD 1,000$ JOHNS ADOLPH BARON BUDD 1,000$ SELF RICHARD BARON BUDD 1,000$ MORISSETTE ROY BARON BUDD 1,000$ SCHAEFER EDWARD BARON BUDD 1,000$ DEROWITSCH CHARLES BARON BUDD 1,000$ DOUGHTY WILLIAM BARON BUDD 1,000$ MORRIS LLOYD BARON BUDD 1,000$ KEELER ROBERT BARON BUDD 1,000$ DYSART EARL BARON BUDD 1,000$ HAWKS CONWAY BARON BUDD 1,000$ RIGG DALE BARON BUDD 1,000$ DRUMMOND VERNON BARON BUDD 1,000$ MARCUM KAREN BARON BUDD 1,000$ HIXON WILLIE BARON BUDD 1,000$ WHEELER LOUIS BARON BUDD 1,000$ MENYHARTH PAUL BARON BUDD 1,000$ BLUDWORTH JAMES BARON BUDD 1,000$ PITALO ANTHONY BARON BUDD 1,000$ MELLINGER JOHN BARON BUDD 1,000$ MULRY CATHERINE BARON BUDD 1,000$ ZACHARY PASCAL BARON BUDD 1,000$ MORELAND DONALD BARON BUDD 1,000$ ANDERSON MARY BARON BUDD 1,000$ BARKER RALPH BARON BUDD 1,000$ MORTON BELTON BARON BUDD 1,000$ RICHARDSON CLAYTON BARON BUDD 1,000$ KAZAKOFF GEORGE BARON BUDD 1,000$ COTTON VIRGIL BARON BUDD 1,000$ FORD ID BARON BUDD 1,000$ SWEARINGEN STEVEN BARON BUDD 1,000$ KRITZER HENRY BARON BUDD 1,000$ TAYLOR DONALD BARON BUDD 1,000$ TRAFFANSTEDT ROSCOE BARON BUDD 1,000$ ROMAN IGNACIO BARON BUDD 1,000$ KOWALCZYK ROBERT BARON BUDD 1,000$ GAINES JOHN BARON BUDD 1,000$ MCKAY EUGENE BARON BUDD 1,000$ ALLEN ROBERT BARON BUDD 1,000$ SHEPHERD BILLY BARON BUDD 1,000$ ALVAREZ RICARDO BARON BUDD 1,000$ CHINNERY DANIEL BARON BUDD 1,000$ KNAPP LAWRENCE BARON BUDD 1,000$ BAGIENSKI JOANNE BARON BUDD 1,000$

2




Last Name First Name Lawyer Settlement offerGLEASON PAUL BARON BUDD 1,000$ SMITH CHARLES BARON BUDD 1,000$ SMALARZ WILLIAM BARON BUDD 1,000$ POE ROBERT BARON BUDD 1,000$ WILSON ALBERT BARON BUDD 1,000$ GREGSON JOHN BARON BUDD 1,000$ FRANCIS ALEXANDER BARON BUDD 1,000$ LINDERMAN HERMAN BARON BUDD 1,000$ PETERSON IONE BARON BUDD 1,000$ MYERS HOWARD BARON BUDD 1,000$ WESSON CHARLES BARON BUDD 1,000$ MCBRIDE JAMES BARON BUDD 1,000$ MEYERS ROBERT BARON BUDD 1,000$ BOND WILLIAM BARON BUDD 1,000$ PINEO RAYMOND BARON BUDD 1,000$ PIETKA ALEXANDER BARON BUDD 1,000$ HOWELL T BARON BUDD 1,000$ HIPP BILLY BARON BUDD 1,000$ MAHONEY JOAN BARON BUDD 1,000$ ALEXANDER BARBARA BARON BUDD 1,000$ LEDFORD LOUIS BARON BUDD 1,000$ CHOY MALLON BARON BUDD 1,000$ JULIANO JOHN BARON BUDD 1,000$ DELAHANTY RICHARD BARON BUDD 1,000$ JEFFRIES CHESTER BARON BUDD 1,000$ SWANSON LEW BARON BUDD 1,000$ NEWELL WILLIAM BARON BUDD 1,000$ BEATTIE RONALD BARON BUDD 1,000$ GILMOUR GEORGE BARON BUDD 1,000$ NEPOMUCENO EUGENIO BARON BUDD 1,000$ LEE JERRY BARON BUDD 1,000$ KINZER RUSSELL BARON BUDD 1,000$ SCHMITZ WILLIAM BARON BUDD 1,000$ CARTER WILLIAM BARON BUDD 1,000$ GARRETT COLLIN BARON BUDD 1,000$ SOHR ANTON BARON BUDD 1,000$ GUERRA ANTHONY BARON BUDD 1,000$ GABLE GLEN BARON BUDD 1,000$ DURON ROY BARON BUDD 1,000$ JORDAN MICHAEL BARON BUDD 1,000$ ROJAS JUAN BARON BUDD 1,000$ SOLUM ALLEN BARON BUDD 1,000$ ROBINSON DOUGLAS BARON BUDD 1,000$ ALLEMAN CLEVELAND BARON BUDD 1,000$ BRANNAN MARION BARON BUDD 1,000$ BEITZEL ROBERT BARON BUDD 1,000$ KINNEY STEVEN BARON BUDD 1,000$ RICH FRANK BARON BUDD 1,000$ SHULL ROBERT BARON BUDD 1,000$ NOVY CLIFFORD BARON BUDD 1,000$ LONG GLEN BARON BUDD 1,000$ HODDER THURMAN BARON BUDD 1,000$ PORTER LEON BARON BUDD 1,000$ STATON ELLIS BARON BUDD 1,000$ MCRAE DONALD BARON BUDD 1,000$ RILEY CLARENCE BARON BUDD 1,000$

3




Last Name First Name Lawyer Settlement offerBIGMAN TOM BARON BUDD 1,000$ BOUDREAUX CHARLES BARON BUDD 1,000$ ALVARADO JOSE BARON BUDD 1,000$ ZANCHETTIN MARCUS BARON BUDD 1,000$ WEISS LESTER BARON BUDD 1,000$ CUNNINGHAM JAMES BARON BUDD 1,000$ COLEMAN MARVIN BARON BUDD 1,000$ FRANCIS ALEXANDER BARON BUDD 1,000$ BRESLAWSKI JOSEPH BARON BUDD 1,000$ KUNKEL ALICE BARON BUDD 1,000$ CONWAY MICHAEL BARON BUDD 1,000$ TRAHAN LEO BARON BUDD 1,000$ BERLIN STANLEY BARON BUDD 1,000$ WESTJOHN JOHN BARON BUDD 1,000$ SENG EDWARD BARON BUDD 1,000$ WONENBERG LOUIS BARON BUDD 1,000$ SCROM WILLIAM BARON BUDD 1,000$ STANGLE DAVID BARON BUDD 1,000$ ATKINSON DONALD BARON BUDD 1,000$ BARNHART ROBERT BARON BUDD 1,000$ COKER RICHARD BARON BUDD 1,000$ SADLER THOMAS BARON BUDD 1,000$ MARTIN JAMES BARON BUDD 1,000$ PINAMONTI MARION BARON BUDD 1,000$ LUZ RICARDO BARON BUDD 1,000$ ROGERS HUBERT BARON BUDD 1,000$ COLAPIETRO LOUIS BARON BUDD 1,000$ FLAIGG PETER BARON BUDD 1,000$ ROE JAMES BARON BUDD 1,000$ SCHAMP ROBERT BARON BUDD 1,000$ MYERS ROBERT BARON BUDD 1,000$ FULLER JANIE BARON BUDD 1,000$ GAROFOLO CHARLES BARON BUDD 1,000$ BELLMIRE CLARENCE BARON BUDD 1,000$ DIORIO ANTHONY BARON BUDD 1,000$ CREEL ELVIN BARON BUDD 1,000$ WHITE EVERETTE BARON BUDD 1,000$ WINCH TIMOTHY BARON BUDD 1,000$ PIZZA MICHAEL BARON BUDD 1,000$ BRATTON KENT BARON BUDD 1,000$ STEPHENSON THOMAS BARON BUDD 1,000$ BAXTER EDWIN BARON BUDD 1,000$ HALLAM ROBERT BARON BUDD 1,000$ SMITH EILEEN BARON BUDD 1,000$ GILES CALVIN BARON BUDD 1,000$ WILLMAN DAVID BARON BUDD 1,000$ GUIDON CHARLES BARON BUDD 1,000$ BARRY JOE BARON BUDD 1,000$ TUCKER ROBERT BARON BUDD 1,000$ DURHAM WILLIAM BARON BUDD 1,000$ KAMINSKI EDWARD BARON BUDD 1,000$ TRUJILLO JOSEPH BARON BUDD 1,000$ MCKINNIS DARRELL BARON BUDD 1,000$ BENNETT CLEOPATRA BARON BUDD 1,000$ PAYNE JAMES BARON BUDD 1,000$ OLSEN MERILYN BARON BUDD 1,000$

4




Last Name First Name Lawyer Settlement offerYOUNG DANIEL BARON BUDD 1,000$ SNYDER HAROLD BARON BUDD 1,000$ KOCHER EARLE BARON BUDD 1,000$ GASCA JOE BARON BUDD 1,000$ PARKER DARLENE BARON BUDD 1,000$ BELL RAYMOND BARON BUDD 1,000$ TALLENT CHRISTINE BARON BUDD 1,000$ DAVIS DOMINGA BARON BUDD 1,000$ HUBER JAMES BARON BUDD 1,000$ SERRANO REYNALDO BARON BUDD 1,000$ DRIVER KENNETH BARON BUDD 1,000$ HOFF RONALD BARON BUDD 1,000$ THOMPSON LLEWELLYN BARON BUDD 1,000$ INGRAM LEEALLEN BARON BUDD 1,000$ BROCKOVICH NICK BARON BUDD 1,000$ GIVAN RALPH BARON BUDD 1,000$ HARRISON KENNETH BARON BUDD 1,000$ TUBBS MICHAEL BARON BUDD 1,000$ CAMPBELL DANNA BARON BUDD 1,000$ HARVEY MARILYN BARON BUDD 1,000$ MILES BERTRAND BELLUCK FOX 137,074$ SCHANK GEORGE BELLUCK FOX 98,182$ MOORS GERALD BELLUCK FOX 65,406$ RUSSELL ROBERT BELLUCK FOX 59,873$ DEFAZIO SAMUEL BELLUCK FOX 53,666$ RUDGE JAMES BELLUCK FOX 47,381$ ROWND ROBERT BELLUCK FOX 46,910$ BELL ROY BELLUCK FOX 45,749$ MAZER MICHAEL BELLUCK FOX 37,819$ CHRISTIE DONALD BELLUCK FOX 30,420$ BATISTA RAFAEL BELLUCK FOX 28,235$ DUMMITT RONALD BELLUCK FOX 26,604$ FRANCK JOHN BELLUCK FOX 23,332$ KLAS NORMAN BELLUCK FOX 21,524$ POTTER LAWRENCE BELLUCK FOX 19,996$ SMITH TIMOTHY BELLUCK FOX 18,369$ TALL DONALD BELLUCK FOX 18,054$ PARSONS RICHARD BELLUCK FOX 18,008$ VIVONA ANTHONY BELLUCK FOX 14,745$ RAYMOND IRVING BELLUCK FOX 13,101$ BURGAN RICHARD BELLUCK FOX 12,817$ FLORKIEWICZ THEODORE BELLUCK FOX 12,518$ SIMMONS CARLOS BELLUCK FOX 12,511$ RUCYNSKI RICHARD BELLUCK FOX 11,654$ SEGAL ELI BELLUCK FOX 11,598$ BURNS DOROTHY BELLUCK FOX 11,313$ KINLEY RICHARD BELLUCK FOX 10,980$ SEIER EDWARD BELLUCK FOX 10,533$ MCCORMICK GORDON BELLUCK FOX 9,345$ HUGHES WILLIAM BELLUCK FOX 8,783$ DOW ROBERT BELLUCK FOX 8,649$ HOLMES BARBARA BELLUCK FOX 8,631$ ROMANO TONY BELLUCK FOX 8,405$ SPENCER HAZEL BELLUCK FOX 8,096$ HAUSERMAN BERNARD BELLUCK FOX 7,863$ COON ELMER BELLUCK FOX 7,758$

5




Last Name First Name Lawyer Settlement offerPHILLIPS DONALD BELLUCK FOX 7,616$ NOLAN LEO BELLUCK FOX 6,627$ NORLING CLIFFORD BELLUCK FOX 6,620$ WOJCIECHOWSKI JOHN BELLUCK FOX 6,608$ HUFF E BELLUCK FOX 6,530$ KRIVICIC CARLO BELLUCK FOX 6,459$ GENNONE RICHARD BELLUCK FOX 6,230$ MARTIN WILLIAM BELLUCK FOX 6,104$ SIMON DANIEL BELLUCK FOX 5,872$ GOLDSTEIN SIDNEY BELLUCK FOX 5,705$ TURNER WILLIAM BELLUCK FOX 5,691$ SPERANZA CARMINE BELLUCK FOX 5,629$ HANNON PAUL BELLUCK FOX 5,128$ MAZUR JOSEPH BELLUCK FOX 4,832$ KEYES MICHAEL BELLUCK FOX 4,830$ REMZA MARJORIE BELLUCK FOX 4,777$ HILLIKER WILLIAM BELLUCK FOX 4,695$ TODD VICTOR BELLUCK FOX 4,386$ WRIGHT JACK BELLUCK FOX 4,356$ KORNWEISER KERMAN BELLUCK FOX 3,722$ WALTON JOHN BELLUCK FOX 2,865$ LARSON DARLENE BELLUCK FOX 2,838$ BEENICK THOMAS BELLUCK FOX 2,240$ LADUKE SHARON BELLUCK FOX 1,913$ KASVEN IRENE BELLUCK FOX 1,830$ ZEH HERMAN BELLUCK FOX 1,757$ COONS VINCENT BELLUCK FOX 1,000$ ROBERTS GEORGE BELLUCK FOX 1,000$ PARKER PAUL BERGMAN FROCKT 133,923$ GERMAN STEPHEN BERGMAN FROCKT 36,773$ MARTELLO VINCENT BERRY MUNN 5,871$ BRADFIELD JAMES BEVAN ASSOCIATES 65,604$ OKOLISH JOSEPH BEVAN ASSOCIATES 64,848$ LEE HILDA BEVAN ASSOCIATES 51,709$ CARDER RAYMOND BEVAN ASSOCIATES 49,710$ ZAUCHA EDWARD BEVAN ASSOCIATES 43,276$ GARCIA ALEX BEVAN ASSOCIATES 42,206$ WORTS JAMES BEVAN ASSOCIATES 31,699$ STEINKER JEROME BEVAN ASSOCIATES 27,722$ GRAWEMEYER HARVEY BEVAN ASSOCIATES 24,589$ PETTIT RICHARD BEVAN ASSOCIATES 21,299$ TRAUTT BEVERLY BEVAN ASSOCIATES 21,266$ CONE JACK BEVAN ASSOCIATES 19,912$ MARTINEZ MAXIMIANO BEVAN ASSOCIATES 18,356$ GILCHRIST CHARLES BEVAN ASSOCIATES 16,385$ CODNER ARTHUR BEVAN ASSOCIATES 15,383$ COLLINS DONALD BEVAN ASSOCIATES 14,653$ BUDIC ROBERT BEVAN ASSOCIATES 13,496$ FAILS ROBERT BEVAN ASSOCIATES 13,430$ GALVIN THOMAS BEVAN ASSOCIATES 11,585$ WALLACE CLIFFORD BEVAN ASSOCIATES 10,972$ CULPEPPER ROSALIE BEVAN ASSOCIATES 10,773$ KELLER RAYMOND BEVAN ASSOCIATES 10,190$ ROYSTER DUANE BEVAN ASSOCIATES 9,882$ KIMBLE JOHN BEVAN ASSOCIATES 9,080$ GAROFOLO CHARLES BEVAN ASSOCIATES 8,429$

6




Last Name First Name Lawyer Settlement offerHAWKINS CATHERINE BEVAN ASSOCIATES 8,176$ HOLLAN CHARLES BEVAN ASSOCIATES 7,945$ RATLIFF ADA BEVAN ASSOCIATES 7,909$ ZGANJAR ROBERT BEVAN ASSOCIATES 7,671$ IHLE MARY BEVAN ASSOCIATES 6,965$ SANDERS BOBBIE BEVAN ASSOCIATES 6,766$ TERIBERY FREDERICK BEVAN ASSOCIATES 6,502$ GRIGGY EILEEN BEVAN ASSOCIATES 6,248$ GLUECK JEROME BEVAN ASSOCIATES 5,709$ HUBER DONALD BEVAN ASSOCIATES 5,512$ WIGAL DELBERT BEVAN ASSOCIATES 5,504$ ADKINS VIRGINIA BEVAN ASSOCIATES 5,385$ SPADAFORA FRANCIS BEVAN ASSOCIATES 5,371$ PAVKOV ALVIN BEVAN ASSOCIATES 4,876$ ANDERSON EARL BEVAN ASSOCIATES 4,770$ PORTER JACK BEVAN ASSOCIATES 4,492$ HALL EUGENE BEVAN ASSOCIATES 4,453$ TESTER EDWARD BEVAN ASSOCIATES 4,429$ STAMM RONALD BEVAN ASSOCIATES 3,850$ COLE ROBERT BEVAN ASSOCIATES 3,819$ ELDER IONA BEVAN ASSOCIATES 3,221$ GAVRAN JOHN BEVAN ASSOCIATES 3,037$ SOKA ELIZABETH BEVAN ASSOCIATES 2,911$ BOWLING HENDERSON BEVAN ASSOCIATES 2,907$ KATZ NATHAN BEVAN ASSOCIATES 2,744$ BAXTER ROBERT BEVAN ASSOCIATES 2,075$ LINDSEY NELLY BEVAN ASSOCIATES 1,499$ REYNOLDS HAROLD BEVAN ASSOCIATES 1,000$ ERVIN FREEMAN BEVAN ASSOCIATES 1,000$ STEINER WILLIAM BEVAN ASSOCIATES 1,000$ PALMER GLENN BEVAN ASSOCIATES 1,000$ MOSS JOSEPHINE BEVAN ASSOCIATES 1,000$ LAH JOSEPH BEVAN ASSOCIATES 1,000$ ROSS DANNY BEVAN ASSOCIATES 1,000$ TUCKER MICHAEL BEVAN ASSOCIATES 1,000$ ENGLERT CAROL BIFFERATO GENTILOTTI BIDEN 1,000$ THOMAS DAVID BLACKWELL 1,000$ KRAUSE KEN BOECHLER 72,608$ OLSON REGINALD BOECHLER 1,000$ BARKER DOUGLAS BOECHLER 1,000$ JACKSON WALTER BOECHLER 1,000$ ROBERTSON JAMES BOECHLER 1,000$ KASPRICK ERNEST BOECHLER 1,000$ WHATLEY JAMES BOGDAN LAWFIRM 59,488$ BAUCOM PATRICIA BRANCH LAWFIRM 3,630$ BLACK JUDITH BRAYTON PURCELL 85,131$ CASEY JOHN BRAYTON PURCELL 84,509$ MURPHY CORNELIUS BRAYTON PURCELL 80,543$ JOHNSON MARK BRAYTON PURCELL 52,705$ COX JACK BRAYTON PURCELL 45,397$ LOVETT CONNIE BRAYTON PURCELL 40,177$ FERNANDEZ JOSEPH BRAYTON PURCELL 36,689$ PISTILLI ALFRED BRAYTON PURCELL 26,117$ RABENER MICHAEL BRAYTON PURCELL 24,855$ AIKINS CHARLES BRAYTON PURCELL 22,700$ ROBERTS JON BRAYTON PURCELL 22,423$

7




Last Name First Name Lawyer Settlement offerKELL ROGER BRAYTON PURCELL 22,416$ BARNES PAUL BRAYTON PURCELL 22,071$ GOATES MAX BRAYTON PURCELL 21,938$ LUCAS GEORGE BRAYTON PURCELL 21,299$ COOK RUTH BRAYTON PURCELL 19,762$ EGGLETON GEORGE BRAYTON PURCELL 19,583$ BARAGAR JAMES BRAYTON PURCELL 18,599$ HILTON MARK BRAYTON PURCELL 18,369$ FONG SHERMAN BRAYTON PURCELL 17,727$ REECE ARVIN BRAYTON PURCELL 17,230$ REA GLORIA BRAYTON PURCELL 16,740$ LOUGHTON JON BRAYTON PURCELL 15,583$ BRUGMAN KEITH BRAYTON PURCELL 14,264$ HOLBROOK CLIFFORD BRAYTON PURCELL 13,913$ ELIASON CHARLES BRAYTON PURCELL 13,765$ HOSKINS CHERYL BRAYTON PURCELL 13,169$ MORILLAS HORTENSE BRAYTON PURCELL 11,375$ CRONIN RAYMOND BRAYTON PURCELL 11,005$ CUELL BARRY BRAYTON PURCELL 10,993$ THOMPSON NORMAN BRAYTON PURCELL 10,117$ OSULLIVAN JAMES BRAYTON PURCELL 9,452$ HAUCK MARGARET BRAYTON PURCELL 9,386$ BURNETT KENNETH BRAYTON PURCELL 9,175$ WARREN JACK BRAYTON PURCELL 8,767$ BUTTARS JEAROLD BRAYTON PURCELL 6,780$ COLLINS LESTER BRAYTON PURCELL 6,605$ STEWART JERRY BRAYTON PURCELL 6,221$ BRADLEY ANTHONY BRAYTON PURCELL 5,913$ CAREY ROBERT BRAYTON PURCELL 5,459$ STELLMACHER ELMER BRAYTON PURCELL 4,815$ AUSTIN ROBERT BRAYTON PURCELL 3,648$ PERCY ELAINE BRAYTON PURCELL 3,600$ JONES FLOYD BRAYTON PURCELL 3,263$ LEWIS JOHN BRAYTON PURCELL 3,000$ BELLACK PHYLLIS BRAYTON PURCELL 1,719$ OKEEFE DONALD BRAYTON PURCELL 1,378$ ALTMAN NANCY BRAYTON PURCELL 1,000$ LAMANTEA THOMAS BRAYTON PURCELL 1,000$ LAMBASE JOHN BRAYTON PURCELL 1,000$ BRUCE JAMES BRAYTON PURCELL 1,000$ EWING BAXTER BRAYTON PURCELL 1,000$ DELOYE CARROLL BRAYTON PURCELL 1,000$ CHIOLINO RICHARD BRAYTON PURCELL 1,000$ WADE RUBY BRAYTON PURCELL 1,000$ TRUITT JAMES BRAYTON PURCELL 1,000$ BOWEN BETTY BRENT COON 133,404$ TREVINO AVELARDO BRENT COON 88,678$ MEREDITH BUFORD BRENT COON 86,560$ JONES GEORGE BRENT COON 81,036$ MACRAE GERALD BRENT COON 80,853$ NELSON CARL BRENT COON 76,527$ ROSS FRED BRENT COON 69,694$ KNYFE ARTHUR BRENT COON 63,154$ LLOYD SAMUEL BRENT COON 61,947$ COOMBE WILLIAM BRENT COON 57,398$ DAWSON WILLIAM BRENT COON 56,154$

8




Last Name First Name Lawyer Settlement offerMCDOWELL DONALD BRENT COON 55,719$ HOLSTEAD EDWIN BRENT COON 53,754$ HOULETTE CHARLES BRENT COON 53,455$ MENA MARK BRENT COON 53,438$ MARQUEZ JUAN BRENT COON 52,787$ WALLING KRISTI BRENT COON 52,028$ FITZPATRICK KEVIN BRENT COON 51,055$ SMITH DELOSE BRENT COON 49,821$ COLLIER LEWIS BRENT COON 49,219$ CLEVENGER JAMES BRENT COON 46,827$ EASTER CLIFTON BRENT COON 46,256$ ROBINSON ELDEN BRENT COON 45,025$ ANDERSON HARRY BRENT COON 44,598$ SEAY EVERETT BRENT COON 43,300$ COPELAND MARGARET BRENT COON 41,137$ RANEY ANNE BRENT COON 39,238$ SANDERS SAMUEL BRENT COON 36,552$ GRAGG ROBERT BRENT COON 36,252$ BUCHANAN ROBERT BRENT COON 36,045$ MILLER HARRISON BRENT COON 35,970$ GRAUL THELMA BRENT COON 35,832$ THOMPSON ALLEN BRENT COON 35,561$ BARTUS FELIX BRENT COON 35,331$ REGEN JOHN BRENT COON 33,519$ ENOCH EARL BRENT COON 33,484$ WODARSKI NANCY BRENT COON 33,147$ MCGINNIS VAUGHN BRENT COON 31,550$ PELFREY JOHNIE BRENT COON 31,442$ CHURCH ROBERT BRENT COON 28,956$ BIEDE MARY BRENT COON 27,317$ KING HELEN BRENT COON 25,405$ SMITH JANN BRENT COON 24,107$ RAY ELIZABETH BRENT COON 23,945$ SPELLMAN VICTOR BRENT COON 23,895$ CHURCH WILLIAM BRENT COON 23,755$ MCMURROUGH REBECCA BRENT COON 22,333$ LUMPKIN J BRENT COON 22,265$ ANAYA BERENICE BRENT COON 21,816$ KEYS KATHERINE BRENT COON 20,680$ CODOG DOUGLAS BRENT COON 20,147$ BERG HAROLD BRENT COON 19,412$ TITTLE ALBERT BRENT COON 18,932$ KNOX JERRY BRENT COON 18,359$ BAIER RICHARD BRENT COON 17,954$ BASHAM JEFFREY BRENT COON 17,895$ LAY ARTHUR BRENT COON 17,648$ CROUSE WILLARD BRENT COON 17,573$ EWING ROBERT BRENT COON 17,087$ BAKER FURMAN BRENT COON 17,001$ HILL ROBERT BRENT COON 16,349$ CHRISTEN LLOYD BRENT COON 16,164$ MADDEN SUSAN BRENT COON 15,955$ BETZNER DAVID BRENT COON 15,908$ DOLT JIMMIE BRENT COON 15,680$ AKINS BURL BRENT COON 15,576$ SIMS BOBBY BRENT COON 15,569$

9




Last Name First Name Lawyer Settlement offerMOAK HERBERT BRENT COON 15,487$ JONES CARLAN BRENT COON 15,322$ STEVENS DWAINE BRENT COON 15,311$ BRYAN DAVID BRENT COON 14,777$ BALL EDWARD BRENT COON 14,459$ DYKE JOSEPH BRENT COON 14,353$ RICHARDS HARVEY BRENT COON 14,154$ ASHLOCK GEAROLD BRENT COON 13,997$ YECKLEY LEONARD BRENT COON 13,835$ ELLISON DEAN BRENT COON 13,673$ DAZZO JOSEPH BRENT COON 13,633$ AUSLEY DONALD BRENT COON 13,496$ HINZ ORVAL BRENT COON 13,471$ GRAPENTHIN LARRY BRENT COON 13,410$ WILBANKS JOSEPH BRENT COON 13,358$ LANG CARL BRENT COON 13,239$ REED WILLIAM BRENT COON 13,111$ MORALES SERGIO BRENT COON 11,707$ GARCIA MARIE BRENT COON 11,542$ GAGE ELLEN BRENT COON 11,311$ KUHN CLETUS BRENT COON 11,300$ PARKER CHARLIE BRENT COON 11,267$ BROADWELL MARY BRENT COON 10,982$ BARNES RUBY BRENT COON 10,560$ THEER GEORGE BRENT COON 10,030$ WENTWORTH KENNETH BRENT COON 9,799$ ADAMS AUDREY BRENT COON 9,779$ BAUSCH ALBERT BRENT COON 9,635$ JACKSON EDWIN BRENT COON 9,437$ ELLIS WILLIAM BRENT COON 9,261$ LAZARUS SILAS BRENT COON 9,053$ BEAVER HAROLD BRENT COON 8,913$ FREEMAN HORACE BRENT COON 8,846$ JOHNSON HAROLD BRENT COON 8,600$ LOHR ROBERT BRENT COON 8,527$ EASTER STEVEN BRENT COON 8,359$ SENNEBOGEN VETHA BRENT COON 8,199$ LAROCCA VICTOR BRENT COON 7,552$ CARACCIO MICHAEL BRENT COON 7,458$ HENDERSON MARCUS BRENT COON 7,423$ HILL WILLIAM BRENT COON 7,367$ WALLIN HELEN BRENT COON 7,196$ BAILEY THEODORE BRENT COON 7,191$ HAIRSTON RAYMOND BRENT COON 6,838$ LEE CORNELIUS BRENT COON 6,643$ CASTILLO REFUGIO BRENT COON 6,447$ MAGUIRE JOSEPH BRENT COON 6,272$ RIENIETS MELVIN BRENT COON 6,190$ DALY JOSEPH BRENT COON 6,176$ BUSH ROBERT BRENT COON 6,136$ DUNAGAN DOUGLAS BRENT COON 5,982$ WOOD BILL BRENT COON 5,925$ NAGY ALEX BRENT COON 5,876$ PAUL THOMAS BRENT COON 5,268$ BAKER JOHN BRENT COON 5,259$ HART VICTOR BRENT COON 5,122$

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Last Name First Name Lawyer Settlement offerSWANSON RENETTE BRENT COON 4,744$ WINSON PAUL BRENT COON 4,583$ MATTE JOSEPH BRENT COON 4,516$ CARDOZA ELIZABETH BRENT COON 4,394$ HULL HERMAN BRENT COON 4,361$ HAINES FOSTER BRENT COON 3,673$ JONES ALICE BRENT COON 3,635$ DAVIS DONALD BRENT COON 3,420$ FARRIS JAMES BRENT COON 3,367$ WONG BILL BRENT COON 3,306$ GOWIN MARGUERITE BRENT COON 3,241$ CURETON RUBY BRENT COON 3,064$ LAMIELLE LOUIS BRENT COON 2,572$ KOBUS FRANCIS BRENT COON 2,449$ FISCELLA JOSEPH BRENT COON 2,402$ SULEK RUDOLPH BRENT COON 2,234$ GALLAGHER JOSEPH BRENT COON 1,578$ FLOWERS HAZE BRENT COON 1,000$ ONEIL FRANK BRENT COON 1,000$ STEVENS WILLIAM BRENT COON 1,000$ REA JOHN BRENT COON 1,000$ MUHAMMAD YAHYA BRENT COON 1,000$ MCDANIEL JOHN BRENT COON 1,000$ PAYNE BRUCE BRENT COON 1,000$ JONES GLEN BRENT COON 1,000$ SMITH THOMAS BRENT COON 1,000$ DAWSON WILLIAM BRENT COON 1,000$ VIDRIOS EDWARD BRENT COON 1,000$ KANE DAVID BROOKMAN ROSENBERG 81,673$ MCADOO CHARLES BROOKMAN ROSENBERG 58,281$ SWEENEY JOSEPH BROOKMAN ROSENBERG 44,606$ GEIST WILLIAM BROOKMAN ROSENBERG 20,339$ DEMARCO SALVATORE BROOKMAN ROSENBERG 20,227$ MORRISEY JOAN BROOKMAN ROSENBERG 19,531$ DIRETTO RUTHANN BROOKMAN ROSENBERG 18,898$ HARRIS DONALD BROOKMAN ROSENBERG 17,861$ DIFORTE LUCY BROOKMAN ROSENBERG 17,620$ ADONI HOWARD BROOKMAN ROSENBERG 15,908$ BENDER FRANK BROOKMAN ROSENBERG 13,893$ BELL LARRY BROOKMAN ROSENBERG 13,875$ MORRIS SIDNEY BROOKMAN ROSENBERG 12,012$ CATHEART LESLIE BROOKMAN ROSENBERG 11,799$ ROBERTS RONALD BROOKMAN ROSENBERG 11,309$ TRAINER RONALD BROOKMAN ROSENBERG 10,417$ STATHIS CONSTANTINOS BROOKMAN ROSENBERG 10,312$ LIGHTNER M BROOKMAN ROSENBERG 9,921$ TOUB LEONARD BROOKMAN ROSENBERG 8,753$ CARLSON ED BROOKMAN ROSENBERG 8,525$ REDMOND JOHN BROOKMAN ROSENBERG 8,431$ QUAY DONALD BROOKMAN ROSENBERG 8,075$ KOEK HENDRIK BROOKMAN ROSENBERG 7,745$ BROWN CLARK BROOKMAN ROSENBERG 7,447$ WEIDNER LINDA BROOKMAN ROSENBERG 7,358$ TODORA SANTO BROOKMAN ROSENBERG 5,915$ JANNIE WILLIAM BROOKMAN ROSENBERG 5,554$ JACOBS MARTIN BROOKMAN ROSENBERG 5,329$

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Last Name First Name Lawyer Settlement offerKAY SANDRA BROOKMAN ROSENBERG 4,963$ UNGERMAN JOHN BROOKMAN ROSENBERG 4,554$ GALLUPPI GIDIO BROOKMAN ROSENBERG 4,306$ MAZZOCCA CAROLINE BROOKMAN ROSENBERG 3,871$ BOGARDUS DONALD BROOKMAN ROSENBERG 3,336$ SITKOWSKI DANIEL BROOKMAN ROSENBERG 2,781$ MONTE JOSEPH BROOKMAN ROSENBERG 1,657$ THOMPSON JOYCE BROOKMAN ROSENBERG 1,000$ KLINE JOHN BROOKMAN ROSENBERG 1,000$ WNUK LEO BROOKMAN ROSENBERG 1,000$ THOMPSON LEROY BROOKMAN ROSENBERG 1,000$ TYLER JOHN BROWN GOULD 59,963$ SAMMARTINO ARMANDO BROWN GOULD 14,365$ ARNDT DAVID BRUCE AHNFELDT LA 1,000$ HAYS WILLIAM BUCK 25,025$ THURMON WILLIAM BUCK 1,000$ CLAYBROOK LELAND BUTLER WILLIAM SKILLING 1,000$ PETERS HENRY CAREY DANIS LOWE 1,000$ LUNA MANUEL CARLSON CARLSON 1,000$ PER EDWARD CAROSELLI BEACHLER 54,867$ CONNER EDWARD CAROSELLI BEACHLER 44,606$ CURCI LEONARD CAROSELLI BEACHLER 42,805$ REMENSNYDER ROBERT CAROSELLI BEACHLER 28,742$ BURKE DANIEL CAROSELLI BEACHLER 28,049$ DODSON JAMES CAROSELLI BEACHLER 24,733$ LENHART JAMES CAROSELLI BEACHLER 17,828$ LABUDA VINCENT CAROSELLI BEACHLER 12,817$ PETERS RALPH CAROSELLI BEACHLER 12,421$ MURRAY MELVIN CAROSELLI BEACHLER 10,918$ BOARTS OLGA CAROSELLI BEACHLER 10,647$ KUSNISS JOSEPH CAROSELLI BEACHLER 10,188$ JORDAN CYNTHIA CAROSELLI BEACHLER 10,020$ DANIELS CHARLES CAROSELLI BEACHLER 9,642$ OPALKO ANNA CAROSELLI BEACHLER 9,458$ GALLAGHER ALOYSIUS CAROSELLI BEACHLER 8,873$ LEITERA ANTHONY CAROSELLI BEACHLER 7,945$ LATINI RICHARD CAROSELLI BEACHLER 6,452$ SIKO ROBERT CAROSELLI BEACHLER 6,292$ PIVETZ GEORGE CAROSELLI BEACHLER 6,109$ SCOTT GEORGE CAROSELLI BEACHLER 5,792$ HAMMERS NORBERT CAROSELLI BEACHLER 5,314$ MURPHEY MOSES CAROSELLI BEACHLER 5,050$ MAZZETTI BETTY CAROSELLI BEACHLER 4,896$ PROCARIO ANTONIETTA CAROSELLI BEACHLER 4,605$ MIZER SAMUEL CAROSELLI BEACHLER 4,579$ NOLL ALLEN CAROSELLI BEACHLER 4,347$ SLURKANICH FRANK CAROSELLI BEACHLER 3,703$ BETZNER WILLIAM CAROSELLI BEACHLER 3,596$ MORMAN VINCENT CARTER BRUCE ATTY COUNSELLOR 1,000$ COYNE THOMAS CASCINO VAUGHAN 47,116$ SERCI JOSEF CASCINO VAUGHAN 17,382$ KINNISON LAWRENCE CASCINO VAUGHAN 17,128$ PEHLKE FRANK CASCINO VAUGHAN 7,325$ DELSART MILLARD CASCINO VAUGHAN 3,942$ PENDER JOHN CASCINO VAUGHAN 2,980$ LORITZ JOHN CASCINO VAUGHAN 1,000$

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Last Name First Name Lawyer Settlement offerLARSON VICTOR CASCINO VAUGHAN 1,000$ PRATT FREDRICK CASEY GERRY REED 75,851$ BALL ALFRED CASEY GERRY REED 16,543$ BARRETT BREFFNI CASEY GERRY REED 6,550$ HERDT FREIDA CASEY GERRY REED 1,530$ NAWAL VIRGINIA CASSIDY MOTTL HARBARGER 9,076$ NICHOLS RONALD CATES 1,000$ BROCHU ADRIEN CHEVERIE ROBERT 1,000$ SNELL RORY CLAPPER PATTI 177,943$ GARWOOD STANLEY CLAPPER PATTI 60,542$ GVOZDENOVIC ZIVA CLAPPER PATTI 53,068$ SCHECHINGER DENNIS CLAPPER PATTI 50,673$ KELLEY DAVID CLAPPER PATTI 40,114$ GULICK ALLAN CLAPPER PATTI 34,104$ CESTER ORVILLE CLAPPER PATTI 31,609$ NAMES JACK CLAPPER PATTI 22,120$ DEILY BRIAN CLAPPER PATTI 17,545$ BENETTI PAUL CLAPPER PATTI 15,416$ CHAILLE PAUL CLAPPER PATTI 11,717$ FRIEND DICK CLAPPER PATTI 10,817$ WEAR DONALD CLAPPER PATTI 8,409$ ISABELLA MICHAEL CLAPPER PATTI 6,865$ RUTTER RAYMOND CLAPPER PATTI 6,174$ FINK DONALD CLAPPER PATTI 5,468$ BALOGH JAMES CLAPPER PATTI 4,892$ ROSEBERRY WILLIAM CLAPPER PATTI 1,692$ EARL RAYMOND CLARK DEPEW TRACEY LTD 1,000$ ARANT JAMES CLAY KENEALY WAGNER ADAMS HALL 1,000$ WHITING WILLIS COADY 55,879$ FUCILE JOHN COADY 17,921$ FINCH NORMAN COADY 14,159$ WILSON KENNETH COADY 13,283$ PEZZULO MICHAEL COADY 12,915$ VANDEMARK LOWELL COADY 8,310$ MACLEAN DONALD COADY 7,650$ HOOKER RICHARD COADY 3,656$ OCONNELL WILLIAM COADY 3,584$ ORLANDO AMBROSE COADY 3,421$ CODY PAUL COADY 1,000$ SPRINGER DAVID COCHRAN 6,952$ LEWIS THOMAS COHEN PLACITELLA ROTH 70,362$ PELUSO FRANCINE COHEN PLACITELLA ROTH 39,228$ DEUBER ARMAND COHEN PLACITELLA ROTH 21,060$ CHAVAN GARY COHEN PLACITELLA ROTH 17,545$ WALTER ROBERT COHEN PLACITELLA ROTH 13,540$ TANSEY ELIZABETH COHEN PLACITELLA ROTH 10,182$ HOEY JAMES COHEN PLACITELLA ROTH 6,758$ GRAU WILLIAM COHEN PLACITELLA ROTH 6,033$ GLOCK CHARELS COHEN PLACITELLA ROTH 3,974$ LOSITO ANTHONY COHEN PLACITELLA ROTH 1,306$ TULLIO ANNE COHEN PLACITELLA ROTH 1,000$ QUICK EDWIN COHEN PLACITELLA ROTH 1,000$ KRAUSS HENRY COHEN PLACITELLA ROTH 1,000$ SAVARESE KAREN COHEN PLACITELLA ROTH 1,000$ PATTERSON THURMAN COOK DOYLE BRADSHAW 21,510$ MURPHY DONALD COOKE MARCIS 1,000$

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Last Name First Name Lawyer Settlement offerFREEMAN MARILYN COONEY CONWAY 130,761$ WARGIN LEONARD COONEY CONWAY 91,018$ OLSON PHILLIP COONEY CONWAY 81,941$ HAYES HAROLD COONEY CONWAY 78,756$ BIBY GRADY COONEY CONWAY 77,729$ SHETLER ROLAND COONEY CONWAY 72,608$ WILEY ROBERT COONEY CONWAY 71,561$ UNDERWOOD ALBERT COONEY CONWAY 64,421$ PUJDAK FREDERICK COONEY CONWAY 57,677$ SCHULZ ERVIN COONEY CONWAY 57,302$ STOECKER MARY COONEY CONWAY 55,222$ RUHOLL AMBROSE COONEY CONWAY 54,368$ WATTS A COONEY CONWAY 51,045$ PHILLIPS ALICE COONEY CONWAY 50,580$ STEWART ROBERT COONEY CONWAY 49,633$ DOERR DOROTHY COONEY CONWAY 49,485$ FILION ARTHUR COONEY CONWAY 48,766$ KINDT HAROLD COONEY CONWAY 47,830$ NOVOSEL MICHAEL COONEY CONWAY 46,253$ PRITCHETT NOBLE COONEY CONWAY 45,529$ WARREN WILLIAM COONEY CONWAY 44,698$ TOWNSEND JAMES COONEY CONWAY 41,557$ TERRY GARY COONEY CONWAY 39,228$ GEREG DIANE COONEY CONWAY 37,365$ ROSAS MIGUEL COONEY CONWAY 35,787$ TERPSTRA WILLIAM COONEY CONWAY 33,064$ MURRAY GEORGE COONEY CONWAY 32,012$ SANK HOWARD COONEY CONWAY 30,607$ WILLIAMS DONALD COONEY CONWAY 30,492$ HALLOWELL BILL COONEY CONWAY 27,398$ LEVIEUX GREGORY COONEY CONWAY 26,499$ CHRISTIANSON RICHARD COONEY CONWAY 25,834$ VANSLYKE GEORGE COONEY CONWAY 25,538$ NELSON MAXWELL COONEY CONWAY 23,916$ CHAFFEE ROBERT COONEY CONWAY 23,000$ SPIEWAK RICHARD COONEY CONWAY 22,525$ GRAHAM SMEDLEY COONEY CONWAY 21,155$ LUNDBORG LEONARD COONEY CONWAY 21,090$ JURGETO RONALD COONEY CONWAY 20,833$ BAKER TERRY COONEY CONWAY 20,255$ SCHAEFFER EVELYN COONEY CONWAY 20,040$ RINALDI ROBERT COONEY CONWAY 19,858$ ROSSELLI AUGUST COONEY CONWAY 19,634$ STONE GAVIN COONEY CONWAY 18,941$ MACHALKA ZDENEK COONEY CONWAY 18,528$ GARNETT ESMER COONEY CONWAY 18,432$ KARAS BRUCE COONEY CONWAY 18,369$ LUDGATIS RICHARD COONEY CONWAY 18,356$ MEYER ROGER COONEY CONWAY 18,285$ SHOOP WILLIARD COONEY CONWAY 17,828$ ROBINSON RANDY COONEY CONWAY 17,545$ DAVIS RANDALL COONEY CONWAY 17,545$ HOEVE DONALD COONEY CONWAY 16,702$ MILLER ROGER COONEY CONWAY 16,419$ WOLTER GLENDON COONEY CONWAY 16,345$ DUNDER JOHN COONEY CONWAY 16,333$

14




Last Name First Name Lawyer Settlement offerBERRY JOHN COONEY CONWAY 16,224$ RICE DENNIS COONEY CONWAY 15,440$ BLACK MELVIN COONEY CONWAY 15,173$ LEWZADER ELMER COONEY CONWAY 14,512$ MCMURRAY NORM COONEY CONWAY 14,465$ WALKER RALPH COONEY CONWAY 14,462$ BROWN JAMES COONEY CONWAY 13,851$ WICHMANN LUTHER COONEY CONWAY 13,681$ ANDERSON GARY COONEY CONWAY 13,583$ MCCLUSKIE ROBERT COONEY CONWAY 13,430$ MISER WILLIAM COONEY CONWAY 13,338$ FOWLER GEORGE COONEY CONWAY 13,320$ WAHLIN KENNETH COONEY CONWAY 12,819$ NORDIN WAYNE COONEY CONWAY 12,684$ CHIARAMELLO FRANK COONEY CONWAY 12,617$ HERR GERALD COONEY CONWAY 12,308$ RIGG RAY COONEY CONWAY 12,171$ KARASEK WALTER COONEY CONWAY 12,059$ DIETERLE JOHN COONEY CONWAY 11,950$ FECH WILLIAM COONEY CONWAY 11,864$ MCCOY RALPH COONEY CONWAY 11,337$ BERRY MICHAEL COONEY CONWAY 11,175$ BOGGS DONALD COONEY CONWAY 11,159$ KINNEAR DONALD COONEY CONWAY 11,141$ TUZZOLINO JOSEPH COONEY CONWAY 10,745$ HUTCHINSON JOE COONEY CONWAY 10,555$ CULLEN THOMAS COONEY CONWAY 10,416$ SAGEL PETER COONEY CONWAY 10,268$ NUGENT SHARON COONEY CONWAY 10,220$ VANDENHEUVEL LAWRENCE COONEY CONWAY 10,072$ RAGLAND PAUL COONEY CONWAY 9,776$ CORNELL LAWRENCE COONEY CONWAY 9,583$ KAUFMAN DAVID COONEY CONWAY 9,570$ BRADY THOMAS COONEY CONWAY 9,344$ RUBINER BARBARA COONEY CONWAY 9,248$ KNIRS RONALD COONEY CONWAY 9,137$ REHBEIN FREDERICK COONEY CONWAY 9,097$ WOODARD ANDREW COONEY CONWAY 8,924$ CITRO ANTHONY COONEY CONWAY 8,697$ LUHRSEN MARLENE COONEY CONWAY 8,592$ KLING BLAIR COONEY CONWAY 8,299$ RAMEY CLOVIS COONEY CONWAY 8,227$ ANDERSON WARREN COONEY CONWAY 8,168$ HOFFMAN LEONARD COONEY CONWAY 8,061$ HEJZA ROGER COONEY CONWAY 7,890$ MILLER LYNN COONEY CONWAY 7,787$ MURPHY THOMAS COONEY CONWAY 7,770$ SMITH JAMES COONEY CONWAY 7,256$ STEWART ROBERT COONEY CONWAY 7,220$ BARUTHA WALTER COONEY CONWAY 7,070$ WALKER REID COONEY CONWAY 7,043$ MANGIARACINA JASPER COONEY CONWAY 6,487$ WIRTH JOHN COONEY CONWAY 6,401$ WISHNOFF EVELYN COONEY CONWAY 6,261$ OLSON LLOYD COONEY CONWAY 6,218$ KOZAK NICHOLAS COONEY CONWAY 6,180$

15




Last Name First Name Lawyer Settlement offerKELLY ROBERT COONEY CONWAY 6,161$ MEYERS PAUL COONEY CONWAY 6,051$ COZZOLA PHULLIS COONEY CONWAY 6,017$ JACKSON PERCY COONEY CONWAY 5,957$ PALMA JOHN COONEY CONWAY 5,957$ GROH ROBERT COONEY CONWAY 5,790$ LENNOX GERALD COONEY CONWAY 5,742$ FILBIN JOHN COONEY CONWAY 5,598$ EMANUELSON HOWARD COONEY CONWAY 5,432$ PANFILIO JAMES COONEY CONWAY 5,380$ MATEJA THEODORE COONEY CONWAY 5,353$ ROBINSON BETTY COONEY CONWAY 5,251$ RENKEN DONALD COONEY CONWAY 5,210$ FRIEDLANDER ALAN COONEY CONWAY 5,209$ HOLTZMAN ELAINE COONEY CONWAY 4,819$ WAGGONER ELDO COONEY CONWAY 4,634$ SYROWIK LEONARD COONEY CONWAY 4,576$ LAMPRECHT HOWARD COONEY CONWAY 4,545$ PARKER EUGENE COONEY CONWAY 4,257$ WEINGER NORMAN COONEY CONWAY 4,094$ LONG DONALD COONEY CONWAY 3,968$ HILLYER CHARLES COONEY CONWAY 3,321$ POGORZELSKI NORBERT COONEY CONWAY 3,290$ MCKANNA JAMES COONEY CONWAY 2,724$ LAPORTA ROCCO COONEY CONWAY 2,334$ HARLOFF LLOYD COONEY CONWAY 1,000$ MURPHY JOHN COONEY CONWAY 1,000$ COHEN ELI COONEY CONWAY 1,000$ RAPOSO DAVID COONEY CONWAY 1,000$ THOMPSON ROBERT COONEY CONWAY 1,000$ CLARK KERMIT COONEY CONWAY 1,000$ SHUPP BERNARD COOPER TUERK 29,455$ DUNCAN ENOCH CORY WATSON CROWDER DEGARIS 29,780$ RINIER JOHN CORY WATSON CROWDER DEGARIS 14,461$ SHEPHERD DAYTON CORY WATSON CROWDER DEGARIS 13,269$ MILLER WAYNE CORY WATSON CROWDER DEGARIS 4,950$ NEW CARRIE CRAIG BULLOCK 1,000$ HAYES BOBBY CUMBEST CUMBEST HUNTER MCCORMICK 5,242$ WALKER JACK CUMBEST CUMBEST HUNTER MCCORMICK 4,605$ CANNETTE ELVIN CUMBEST CUMBEST HUNTER MCCORMICK 1,000$ NETTLES NELIA CUMBEST CUMBEST HUNTER MCCORMICK 1,000$ SMITH EDWARD DACORSI PLACENCIO RUMSEY 17,581$ SELLERS GLORIA DARRELL GOSSETT 105,355$ MOORE ROBERT DARRELL GOSSETT 1,000$ WILSON MICHAEL DAVID 4,783$ FASOLD ROBERT DAVID 1,000$ TILOCCO JEANNETTE DAVID 1,000$ EVANS ELIZABETH DAVID 1,000$ KNIGHT CURTIS DAVID LIPMAN 128,329$ PEAVEY HOWARD DAVID LIPMAN 57,729$ AUSTIN ROBERT DAVID LIPMAN 50,477$ SNYDER LOUISE DAVID LIPMAN 38,418$ KOSITZKY MICHAEL DAVID LIPMAN 33,911$ BROWN WILLIAM DAVID LIPMAN 14,275$ LORENZ DAVID DAVID LIPMAN 14,130$ MERCIER SIDNEY DAVID LIPMAN 13,667$

16




Last Name First Name Lawyer Settlement offerOLSSON WARREN DAVID LIPMAN 9,818$ GILYARD DAVID DAVID LIPMAN 7,518$ PAINE ROBERT DAVID LIPMAN 5,545$ RODRIGUEZ SOLEDAD DAVID LIPMAN 1,000$ BROOKS ARTHUR DAVID LIPMAN 1,000$ GRAF MAXINE DAVID LIPMAN 1,000$ GLOBE CAROLE DAVID LIPMAN 1,000$ FRANCOIS LOUNEDA DAVID LIPMAN 1,000$ GORMLEY LUCILLE DAVID LIPMAN 1,000$ RICHRATH HANS DAVID LIPMAN 1,000$ WOOD ROBERT DAVID LIPMAN 1,000$ PIONTSKOWSKI RAYMOND DAVID LIPMAN 1,000$ ZITOMER ALBERT DAVID LIPMAN 1,000$ CARY LAWSON DEATON LAWFIRM 61,288$ CARVER CHARLES DEATON LAWFIRM 37,241$ DAIGLE EUGENE DEATON LAWFIRM 24,670$ BRANDT WILLIAM DEATON LAWFIRM 6,945$ PYNE TIMOTHY DEATON LAWFIRM 3,413$ HAMMONDS R DEATON LAWFIRM 1,000$ FUSCO JOSEPH DEATON LAWFIRM 1,000$ BLALOCK EDWARD DEBLASE BROWN EYERLY 1,000$ DUPRIEST RONALD DELUCA NEMEROFF 32,391$ CALAMIA CARL DIDRIKSEN LAWFIRM 64,266$ MOORE JOHN DIES DIES HENDERSON 7,992$ CURBY JOHN DOMNICK SHEVIN 21,966$ JULEN CLIFFORD DONALDSON BLACK 1,000$ PARKS MARTIN DUBOSE 1,000$ BOWELL ANTHONY DUFFY JOHN 43,715$ DEYOUNG JANIE DUFFY JOHN 1,000$ BOWLING HAROLD DUFFY JOHN 1,000$ GODDARD WILLIAM DUFFY JOHN 1,000$ STHILAIRE RALPH EARLY LUDWICK SWEENEY 170,029$ POWELL ROBERT EARLY LUDWICK SWEENEY 100,504$ SCHELP HENRY EARLY LUDWICK SWEENEY 80,668$ SHARP ALAN EARLY LUDWICK SWEENEY 80,160$ NASTRI ANTHONY EARLY LUDWICK SWEENEY 59,634$ JOHNS JAMES EARLY LUDWICK SWEENEY 48,473$ MAROHL JOHN EARLY LUDWICK SWEENEY 44,166$ CARLSON DAVID EARLY LUDWICK SWEENEY 42,478$ BATCH GARY EARLY LUDWICK SWEENEY 41,521$ BELENKY BORIS EARLY LUDWICK SWEENEY 39,304$ STRONG FRED EARLY LUDWICK SWEENEY 37,621$ MELOCK KAREN EARLY LUDWICK SWEENEY 33,222$ WEBB WILLIAM EARLY LUDWICK SWEENEY 31,280$ HASAN JOHN EARLY LUDWICK SWEENEY 26,176$ MOORE JENE EARLY LUDWICK SWEENEY 23,563$ HELLER ALDON EARLY LUDWICK SWEENEY 22,380$ KEARNEY JAMES EARLY LUDWICK SWEENEY 21,906$ FRANCOEUR ARMAND EARLY LUDWICK SWEENEY 21,253$ NEWBERRY CHARLES EARLY LUDWICK SWEENEY 21,090$ SMART JANE EARLY LUDWICK SWEENEY 20,530$ PARKER SHELDON EARLY LUDWICK SWEENEY 19,144$ LANE DIANNE EARLY LUDWICK SWEENEY 17,954$ WALKER FREDDIE EARLY LUDWICK SWEENEY 15,764$ FERRAIUOLO ANTHONY EARLY LUDWICK SWEENEY 14,923$ WIGLEY JUDY EARLY LUDWICK SWEENEY 14,808$

17




Last Name First Name Lawyer Settlement offerOKEEFE MICHAEL EARLY LUDWICK SWEENEY 13,123$ BELL PETER EARLY LUDWICK SWEENEY 13,021$ SHMARUK FRED EARLY LUDWICK SWEENEY 13,013$ VADNAIS LEO EARLY LUDWICK SWEENEY 12,780$ HOPKINS OLIVER EARLY LUDWICK SWEENEY 12,525$ KONING FREDERICK EARLY LUDWICK SWEENEY 12,085$ BLANCHARD FRANK EARLY LUDWICK SWEENEY 11,551$ BROOKSHIER CLYDE EARLY LUDWICK SWEENEY 11,445$ DYER JAMES EARLY LUDWICK SWEENEY 11,140$ CLAY TROY EARLY LUDWICK SWEENEY 10,593$ ROBERTS MICHAEL EARLY LUDWICK SWEENEY 10,496$ BASILICA JOSEPH EARLY LUDWICK SWEENEY 10,413$ LEHOTAY JOSEPH EARLY LUDWICK SWEENEY 10,299$ TRAMONT MARY EARLY LUDWICK SWEENEY 10,084$ ONLEY EDWARD EARLY LUDWICK SWEENEY 9,957$ MUIR RICHARD EARLY LUDWICK SWEENEY 9,920$ ROCHLIN ABRAHAM EARLY LUDWICK SWEENEY 9,858$ GOETZ EUGENE EARLY LUDWICK SWEENEY 9,818$ TREW STANLEY EARLY LUDWICK SWEENEY 9,689$ DORRER ROBERT EARLY LUDWICK SWEENEY 9,561$ MEADOWS GEORGE EARLY LUDWICK SWEENEY 9,458$ KEPLAR ROBERT EARLY LUDWICK SWEENEY 9,140$ PETERSON MELVIN EARLY LUDWICK SWEENEY 9,115$ BOUCHARD ROLAND EARLY LUDWICK SWEENEY 8,680$ RIEMANN DUANE EARLY LUDWICK SWEENEY 8,547$ HOWE RICHARD EARLY LUDWICK SWEENEY 8,499$ RUGGIERO ANTHONY EARLY LUDWICK SWEENEY 8,380$ MILLER WILLIAM EARLY LUDWICK SWEENEY 7,969$ BUTZKY LEON EARLY LUDWICK SWEENEY 7,939$ ZOESCH ALLEN EARLY LUDWICK SWEENEY 7,808$ BERGANTINO JOHN EARLY LUDWICK SWEENEY 7,796$ BRANNAN SILAS EARLY LUDWICK SWEENEY 7,616$ WISSINGER ALAN EARLY LUDWICK SWEENEY 7,212$ COUSINO GLEN EARLY LUDWICK SWEENEY 7,072$ CANNON LEO EARLY LUDWICK SWEENEY 7,039$ BRAY BROOKS EARLY LUDWICK SWEENEY 6,879$ OBROCHTA JOSEPH EARLY LUDWICK SWEENEY 6,828$ PEETZ ERVIN EARLY LUDWICK SWEENEY 6,816$ BIGDA RUDOLPH EARLY LUDWICK SWEENEY 6,800$ FUCHS WILLIAM EARLY LUDWICK SWEENEY 6,690$ HOWARD WILLIAM EARLY LUDWICK SWEENEY 6,383$ PIZZOLA DOMINICK EARLY LUDWICK SWEENEY 6,082$ KEENER ELDON EARLY LUDWICK SWEENEY 5,801$ MACHADO AMORIN EARLY LUDWICK SWEENEY 5,767$ PEZANKO RITA EARLY LUDWICK SWEENEY 5,635$ BAUER WILLIAM EARLY LUDWICK SWEENEY 5,617$ KUDRNA FRANK EARLY LUDWICK SWEENEY 5,577$ DEEMS ROWLAND EARLY LUDWICK SWEENEY 5,497$ HAYFORD ROBERT EARLY LUDWICK SWEENEY 5,492$ TOMLIN ROBERT EARLY LUDWICK SWEENEY 5,369$ KANICKI KATHLEEN EARLY LUDWICK SWEENEY 5,356$ PFAU LEONARD EARLY LUDWICK SWEENEY 5,295$ GROSS ALBERT EARLY LUDWICK SWEENEY 5,217$ HAMMER IRVING EARLY LUDWICK SWEENEY 5,064$ GREV STUART EARLY LUDWICK SWEENEY 5,001$ BISHOP PAUL EARLY LUDWICK SWEENEY 4,769$

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Last Name First Name Lawyer Settlement offerHARITON THEODORE EARLY LUDWICK SWEENEY 4,554$ BERK WALTER EARLY LUDWICK SWEENEY 4,426$ HENSHAW MAURICE EARLY LUDWICK SWEENEY 4,358$ PRAGER IRVING EARLY LUDWICK SWEENEY 4,184$ MACMASTER EVERETT EARLY LUDWICK SWEENEY 3,897$ PERKINS EPPS EARLY LUDWICK SWEENEY 3,870$ GERLEY VICTOR EARLY LUDWICK SWEENEY 3,725$ HEROLD DAVID EARLY LUDWICK SWEENEY 3,345$ SCHAFF DONALD EARLY LUDWICK SWEENEY 3,186$ DOMBROWSKI JENNIE EARLY LUDWICK SWEENEY 2,980$ REINDL THOMAS EARLY LUDWICK SWEENEY 2,837$ ALT JOHN EARLY LUDWICK SWEENEY 2,728$ WESTBROOKS ROSALYN EARLY LUDWICK SWEENEY 2,349$ FULTON KENNETH EARLY LUDWICK SWEENEY 1,815$ SASSO LAWRENCE EARLY LUDWICK SWEENEY 1,608$ GIUSTI GINO EARLY LUDWICK SWEENEY 1,000$ ADAMIK WALTER EARLY LUDWICK SWEENEY 1,000$ PAULUS WILLIAM EDDINS 50,978$ REED CARLA EDWARD MOODY 56,247$ CRAWFORD DONALD EDWARD MOODY 17,081$ VINYARD JAMES EDWARD MOODY 6,046$ HATLEY JIM EDWARD MOODY 3,759$ ZEMA JOHN EMBRY NEUSNER 60,847$ MOORE TIMOTHY EMBRY NEUSNER 47,904$ HALUGA STEPHEN EMBRY NEUSNER 15,993$ MURPHY PAUL EMBRY NEUSNER 14,130$ BAILEY LORING EMBRY NEUSNER 8,915$ BECKWITH ROBERT EMBRY NEUSNER 6,823$ THIBEAULT CHARLES EMBRY NEUSNER 3,550$ JARRELL JOHN FAIREY 7,682$ WILMOT GERALD FARRISE LAWFIRM 1,000$ HARPER IRA FARRISE LAWFIRM 1,000$ FARAG NASSEEM FARRISE LAWFIRM 1,000$ MARTNI JOSEPH FARRISE LAWFIRM 1,000$ MEDINA SECUNDINO FARRISE LAWFIRM 1,000$ SKEWES JAY FARRISE LAWFIRM 1,000$ COTTRELL RICHARD FARRISE LAWFIRM 1,000$ BURNETT JESSIE FARRISE LAWFIRM 1,000$ JONES CLARENCE FARRISE LAWFIRM 1,000$ JOHNSON PAUL FARRISE LAWFIRM 1,000$ HARRELL WILLIAM FARRISE LAWFIRM 1,000$ ROQUE JOHN FARRISE LAWFIRM 1,000$ DIEHL RODERICK FEITLIN YOUNGMAN KARAS YOUNGMAN 1,000$ OAKES EVERETT FERRAROASSOCIATES 150,299$ MARSH RAYMOND FERRAROASSOCIATES 84,740$ KRAUSE FREDERICK FERRAROASSOCIATES 63,069$ KLEWIN CHARLES FERRAROASSOCIATES 51,164$ GIANGIOBBE ANTHONY FERRAROASSOCIATES 34,013$ FADDISH JOHN FERRAROASSOCIATES 25,390$ ERTS STACY FERRAROASSOCIATES 20,399$ CARTER PAUL FERRAROASSOCIATES 16,440$ PISZ JOHN FERRAROASSOCIATES 15,011$ SCARLETT OLIVER FERRAROASSOCIATES 10,669$ SMITH DANIEL FERRAROASSOCIATES 8,666$ JONES KENNETH FERRAROASSOCIATES 8,346$ SCHUSTER DONALD FERRAROASSOCIATES 3,677$

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Last Name First Name Lawyer Settlement offerCORONITE JOSEPH FERRAROASSOCIATES 3,303$ BONANNO SANTE FERRAROASSOCIATES 3,011$ CAPEN ROBERT FERRAROASSOCIATES 2,711$ DOSTIE ROLAND FERRAROASSOCIATES 1,000$ HOSS WILLIAM FERRAROASSOCIATES 1,000$ MIGUES CHESTER FERRAROASSOCIATES 1,000$ ANDREWS JAMES FERRAROASSOCIATES 1,000$ THOMAS ROBERT FERRAROASSOCIATES 1,000$ RIMES JOHN FERRAROASSOCIATES 1,000$ BEHR HARRY FERRAROASSOCIATES 1,000$ KAMINSKI ARTHUR FERRAROASSOCIATES 1,000$ ELLISON CHARLES FERRAROASSOCIATES 1,000$ ALSTON JOHN FERRAROASSOCIATES 1,000$ HEIKKINEN BERNARD FERRAROASSOCIATES 1,000$ LUNNING KENNETH FERRAROASSOCIATES 1,000$ PICKLO DOMINICK FERRAROASSOCIATES 1,000$ RICE JOHN FERRAROASSOCIATES 1,000$ FORSYTH HELEN FERRAROASSOCIATES 1,000$ VINCENT RODNEY FERRAROASSOCIATES 1,000$ NALL MAURICE FERRAROASSOCIATES 1,000$ BRITT CHARLOTTE FERRAROASSOCIATES 1,000$ GIESE WALTER FERRAROASSOCIATES 1,000$ BOLTON GEORGE FERRAROASSOCIATES 1,000$ ANDERSON WILLIS FERRAROASSOCIATES 1,000$ BRUTLAG LIVERN FLACK 1,000$ HINES CURTIS FLACK 1,000$ JANSEN LEONARD FLACK 1,000$ PEASE HERBERT FLEMING NOLAN JEZ 77,741$ DAVIS WESLEY FLEMING NOLAN JEZ 65,262$ FOX EDWARD FLEMING NOLAN JEZ 41,946$ WALKER DANNY FLEMING NOLAN JEZ 33,911$ HULSE STEVEN FLEMING NOLAN JEZ 31,004$ MURRAY WAYNE FLEMING NOLAN JEZ 25,435$ DOBERSTEIN DONALD FLEMING NOLAN JEZ 20,643$ RICE VICTOR FLEMING NOLAN JEZ 19,380$ DREMEL DONALD FLEMING NOLAN JEZ 18,405$ ABBOTT ROBERT FLEMING NOLAN JEZ 14,595$ HAWORTH WILLIAM FLEMING NOLAN JEZ 14,069$ STONEROCK ROBERT FLEMING NOLAN JEZ 13,827$ SMITH JOHN FLEMING NOLAN JEZ 13,533$ TASKA IRENE FLEMING NOLAN JEZ 12,041$ WALSH DIANNA FLEMING NOLAN JEZ 11,707$ CLARK FRANK FLEMING NOLAN JEZ 11,274$ JORDAN GERALD FLEMING NOLAN JEZ 10,870$ FILARECKI WILLIAM FLEMING NOLAN JEZ 10,754$ ROTTMUND EDWARD FLEMING NOLAN JEZ 10,133$ MOORE SHERRIE FLEMING NOLAN JEZ 9,394$ WOOD PAUL FLEMING NOLAN JEZ 8,158$ MINER OSCAR FLEMING NOLAN JEZ 6,961$ OXFORD J FLEMING NOLAN JEZ 6,858$ MOSS PHILIP FLEMING NOLAN JEZ 6,554$ BROOKS VICTOR FLEMING NOLAN JEZ 6,224$ FANEUF LEO FLEMING NOLAN JEZ 6,067$ LANE THOMAS FLEMING NOLAN JEZ 6,008$ KOZOJED VIRGIL FLEMING NOLAN JEZ 5,359$ CORDOVA GEORGE FLEMING NOLAN JEZ 5,122$

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Last Name First Name Lawyer Settlement offerGILL JOSE FLEMING NOLAN JEZ 5,059$ SNYDER ROBERT FLEMING NOLAN JEZ 4,993$ WIERSMA LEE FLEMING NOLAN JEZ 4,909$ COLLINS RICHARD FLEMING NOLAN JEZ 4,882$ KIRKS WILBERT FLEMING NOLAN JEZ 4,182$ BEHREND HARRY FLEMING NOLAN JEZ 3,901$ THUNE GERALD FLEMING NOLAN JEZ 3,572$ MCKEITHAN SARAH FLEMING NOLAN JEZ 2,880$ DACHILLE CARMELA FORCENO ARANGIO 9,076$ EVELY RAYMOND FORCENO ARANGIO 5,433$ GILLMAN CONNIE FRANK WATHEN II 1,000$ RAMSEY MACK FRILOT PARTRIDGE KOHNKE CLEMENTS 72,608$ PAGAN PETER GALIHER DEROBERTIS 1,000$ SUTTLE THEODORE GALIHER DEROBERTIS 1,000$ BRISSON BERNARD GALIHER DEROBERTIS 1,000$ OLSON HARLAND GALIHER DEROBERTIS 1,000$ ISARA KENNETH GALIHER DEROBERTIS 1,000$ BLACKLER KEITH GALIHER DEROBERTIS 1,000$ FELLEZS SHERWIN GALIHER DEROBERTIS 1,000$ CHU JACK GALIHER DEROBERTIS 1,000$ SAKAMOTO ERNEST GALIHER DEROBERTIS 1,000$ BONGOLAN RUDY GALIHER DEROBERTIS 1,000$ RIO BARNEY GALIHER DEROBERTIS 1,000$ CRAIG JOHN GALIHER DEROBERTIS 1,000$ MEANS HOMER GALIHER DEROBERTIS 1,000$ KENT DANIEL GAVIN 1,000$ LANDRY GUY GILBERT ADAMS 1,000$ PHELPS CECIL GILLENWATER NICHOL 41,490$ SMITH FRANK GILLENWATER NICHOL 9,076$ JONES JAMES GILLENWATER NICHOL 4,538$ SCHOLES CALLIE GLASSER GLASSER 85,639$ BOUTOT JOSEPH GLASSER GLASSER 72,661$ LYONS PATRICK GLASSER GLASSER 57,733$ COULTER JAMES GLASSER GLASSER 53,492$ CRANSTON JAMES GLASSER GLASSER 51,449$ ADAMS JOHN GLASSER GLASSER 46,427$ MORRIS O GLASSER GLASSER 42,740$ HARMAN WILLIAM GLASSER GLASSER 30,176$ HENDRICKS FRANCIS GLASSER GLASSER 27,238$ CRAIG WILLIAM GLASSER GLASSER 19,066$ KNIGHT VICTOR GLASSER GLASSER 17,634$ COTTLE FRANCIS GLASSER GLASSER 16,938$ LITCHFIELD WILLIE GLASSER GLASSER 14,813$ CORNS HERBERT GLASSER GLASSER 13,681$ BAILEY VERNON GLASSER GLASSER 13,453$ GRIBBIN JOHN GLASSER GLASSER 11,270$ CLEMENS PAUL GLASSER GLASSER 10,520$ BROWN SARAH GLASSER GLASSER 9,487$ RATCLIFF THOMAS GLASSER GLASSER 9,367$ BROUGHTON HIRSIL GLASSER GLASSER 9,067$ MUELLNER HERMAN GLASSER GLASSER 7,428$ GREGORY THOMAS GLASSER GLASSER 6,866$ MOORE LENORE GLASSER GLASSER 6,810$ WILDE JOHN GLASSER GLASSER 5,949$ JOHNSON CLARENCE GLASSER GLASSER 5,710$ MARTINDALE BENJAMIN GLASSER GLASSER 5,708$

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Last Name First Name Lawyer Settlement offerSHARP KENNETH GLASSER GLASSER 5,263$ WARREN GARNIE GLASSER GLASSER 4,630$ DALY LEO GLASSER GLASSER 4,319$ ELLIS PERCY GLASSER GLASSER 3,579$ PETERS RICHARD GLASSER GLASSER 3,055$ DAUER JAMES GLASSER GLASSER 1,000$ YARBRO DAVID GLASSMAN JETER EDWARDS WADE 1,000$ SCANLON MYRA GLENN FEAGAN 5,721$ JOHNSON VERNON GOLDBERG MILLER RUBIN 1,000$ ALLEN JAMES GOLDBERG MILLER RUBIN 1,000$ BORING GARY GOLDBERG PERSKY 120,737$ LANCOUR JAMES GOLDBERG PERSKY 84,957$ PAVLIK ALBERT GOLDBERG PERSKY 67,345$ LEWIS DAVID GOLDBERG PERSKY 63,609$ STULL DAVID GOLDBERG PERSKY 55,554$ SHERMAN FRANK GOLDBERG PERSKY 54,915$ LINDSAY VICTOR GOLDBERG PERSKY 41,402$ BARKER JOHN GOLDBERG PERSKY 40,177$ ZEESE EARL GOLDBERG PERSKY 39,784$ LACHANCE DANIEL GOLDBERG PERSKY 39,238$ FORTIN WILLIAM GOLDBERG PERSKY 39,228$ DODSON CARL GOLDBERG PERSKY 37,365$ MCKINNEY BARBARA GOLDBERG PERSKY 35,600$ BASILE JOHN GOLDBERG PERSKY 33,066$ HAYES JUANITA GOLDBERG PERSKY 32,674$ KRAFFT MICHAEL GOLDBERG PERSKY 32,484$ ICKES CLARENCE GOLDBERG PERSKY 30,323$ TIMCHAC JAMES GOLDBERG PERSKY 29,394$ CHERRY NICHOLAS GOLDBERG PERSKY 29,037$ LAROSA FRANCIS GOLDBERG PERSKY 23,833$ STEWART ROBERT GOLDBERG PERSKY 23,346$ GUMP TINA GOLDBERG PERSKY 22,808$ ZIMMERMAN SAMUEL GOLDBERG PERSKY 22,808$ RAY JOSEPH GOLDBERG PERSKY 22,763$ SCHWARTZ KATHLEEN GOLDBERG PERSKY 22,421$ MAYHEW CHARLES GOLDBERG PERSKY 21,230$ VESPA DOMINIC GOLDBERG PERSKY 20,134$ CAMERON SCOT GOLDBERG PERSKY 17,545$ KRAPF DONALD GOLDBERG PERSKY 17,531$ YONKERS RICHARD GOLDBERG PERSKY 17,252$ TROWBRIDGE MAX GOLDBERG PERSKY 16,868$ DOHERTY WILLIAM GOLDBERG PERSKY 16,698$ SMITH RALPH GOLDBERG PERSKY 16,384$ MAVRIKAS HARRY GOLDBERG PERSKY 16,369$ FOSNAUGHT BARBARA GOLDBERG PERSKY 15,569$ PULLEN RICHARD GOLDBERG PERSKY 14,276$ DUBAY RICHARD GOLDBERG PERSKY 14,253$ HEARD JOHN GOLDBERG PERSKY 13,496$ FITING ROGER GOLDBERG PERSKY 12,994$ HERRON ALLEN GOLDBERG PERSKY 12,573$ GRAMLICH ARTHUR GOLDBERG PERSKY 12,049$ FOSSETT BARBARA GOLDBERG PERSKY 11,581$ FRENCH ROBERT GOLDBERG PERSKY 11,478$ DEEMER EDWARD GOLDBERG PERSKY 11,423$ VANNESS THOMAS GOLDBERG PERSKY 11,265$ SAUERS BERNARD GOLDBERG PERSKY 11,106$

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Last Name First Name Lawyer Settlement offerSMITH HARRY GOLDBERG PERSKY 10,801$ NARDO RUDOLPH GOLDBERG PERSKY 10,396$ LEBOEUF WILLIAM GOLDBERG PERSKY 10,260$ SABOL GEORGE GOLDBERG PERSKY 10,204$ CLINE MICHAEL GOLDBERG PERSKY 10,130$ WHITE BILLY GOLDBERG PERSKY 10,124$ ANDES PATRICIA GOLDBERG PERSKY 9,892$ LINDEMANN GEORGE GOLDBERG PERSKY 9,550$ ANDERSON FREDERICK GOLDBERG PERSKY 9,394$ BRIDGES GLORIA GOLDBERG PERSKY 9,223$ HAIGHT RICHARD GOLDBERG PERSKY 9,116$ CHRISTIAN CONSTANCE GOLDBERG PERSKY 8,869$ ALUISE DONALD GOLDBERG PERSKY 8,849$ MCCAFFERTY HELEN GOLDBERG PERSKY 8,788$ ATHANAS NIKOLAOS GOLDBERG PERSKY 8,634$ BATES REGINALD GOLDBERG PERSKY 8,500$ HALA JOHN GOLDBERG PERSKY 8,481$ NAYLOR DONALD GOLDBERG PERSKY 7,781$ BUCKO EDWARD GOLDBERG PERSKY 7,777$ WALL LEONARD GOLDBERG PERSKY 7,677$ MONGELLUZZO JAMES GOLDBERG PERSKY 7,616$ SHARP HARRY GOLDBERG PERSKY 7,330$ ROBINSON EARON GOLDBERG PERSKY 7,204$ PUCAK ROBERT GOLDBERG PERSKY 7,044$ RUSH RONALD GOLDBERG PERSKY 7,013$ SWANK ROBERT GOLDBERG PERSKY 6,916$ DIEHL JOHN GOLDBERG PERSKY 6,914$ KING JOHN GOLDBERG PERSKY 6,877$ GALARDE EDITH GOLDBERG PERSKY 6,860$ TENO ETHEL GOLDBERG PERSKY 6,663$ NOVAK EDWARD GOLDBERG PERSKY 6,651$ HOETZEL THOMAS GOLDBERG PERSKY 6,641$ NAGY GEORGE GOLDBERG PERSKY 6,539$ GILROY ROLAND GOLDBERG PERSKY 6,499$ WELSH EDWARD GOLDBERG PERSKY 6,471$ BLAGG RICHARD GOLDBERG PERSKY 6,439$ MARSHALL KENNETH GOLDBERG PERSKY 6,401$ GRZYBOWSKI THEODORE GOLDBERG PERSKY 6,341$ BENDLE JEAN GOLDBERG PERSKY 6,261$ HECK HARRY GOLDBERG PERSKY 6,248$ LOCKMAN HELEN GOLDBERG PERSKY 6,218$ MAHAR MYRTLE GOLDBERG PERSKY 6,110$ GOLASKI LOIS GOLDBERG PERSKY 6,094$ PALLAGUT EDWARD GOLDBERG PERSKY 5,958$ SCHIRRA RITA GOLDBERG PERSKY 5,873$ STOECKER HENRY GOLDBERG PERSKY 5,798$ SHAFFER WILLIAM GOLDBERG PERSKY 5,624$ GODDARD SHERWOOD GOLDBERG PERSKY 5,624$ KOCKS DONALD GOLDBERG PERSKY 5,608$ BUCKENHEIMER DORTHA GOLDBERG PERSKY 5,566$ OTT JACK GOLDBERG PERSKY 5,534$ MALLOY CHARLES GOLDBERG PERSKY 5,415$ YOCKEY JAMES GOLDBERG PERSKY 5,357$ BANCROFT DELBERT GOLDBERG PERSKY 5,328$ DOBER GLENNA GOLDBERG PERSKY 5,286$ ZENGEL JOSEPH GOLDBERG PERSKY 5,162$

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Last Name First Name Lawyer Settlement offerSTEFANOS FRANK GOLDBERG PERSKY 5,089$ MOSORA JOHN GOLDBERG PERSKY 4,990$ ZAGORT EDWARD GOLDBERG PERSKY 4,922$ MARTIN NEGLEY GOLDBERG PERSKY 4,883$ SEDDON FRED GOLDBERG PERSKY 4,879$ BREWER RAYMOND GOLDBERG PERSKY 4,855$ SMERECHENSKY STEPHEN GOLDBERG PERSKY 4,683$ WESTHEAD JOHN GOLDBERG PERSKY 4,591$ HOFELZER RALPH GOLDBERG PERSKY 4,439$ SCHMIDT HAROLD GOLDBERG PERSKY 4,098$ SEIGFRIED WILLIAM GOLDBERG PERSKY 3,964$ WIGAL JOHN GOLDBERG PERSKY 3,957$ GABRIEL ROBERT GOLDBERG PERSKY 3,740$ BIGHAM HARRY GOLDBERG PERSKY 3,356$ MERZENSKI TED GOLDBERG PERSKY 3,344$ POWERS ROBERT GOLDBERG PERSKY 3,129$ BURDITT BYRON GOLDBERG PERSKY 2,887$ MILLER FRANKLIN GOLDBERG PERSKY 2,712$ THOMAS HAROLD GOLDBERG PERSKY 2,506$ RONAN JAMES GOLDBERG PERSKY 1,167$ WALKER ROBERT GOLDBERG PERSKY 1,000$ SEGER STEVE GOLDBERG PERSKY 1,000$ WARMAN BOBBY GOLDBERG PERSKY 1,000$ GERAN JOSEPH GOLDBERG PERSKY 1,000$ YOST DANIEL GOLDBERG PERSKY 1,000$ PUTT GENE GOLDBERG PERSKY 1,000$ AUTRY FRANK GOLDENBERG HELLER ANTOGNOLI ROWLAND 143,635$ MONTGOMERY PAT GOLDENBERG HELLER ANTOGNOLI ROWLAND 95,044$ HENLEY PATSYE GOLDENBERG HELLER ANTOGNOLI ROWLAND 73,935$ FULLMER JACOB GOLDENBERG HELLER ANTOGNOLI ROWLAND 68,673$ KOZLOWSKI GREGORY GOLDENBERG HELLER ANTOGNOLI ROWLAND 61,995$ WORSTER JOHN GOLDENBERG HELLER ANTOGNOLI ROWLAND 57,050$ CLOUD DONNA GOLDENBERG HELLER ANTOGNOLI ROWLAND 46,582$ VANCE DONALD GOLDENBERG HELLER ANTOGNOLI ROWLAND 45,142$ KLING CLAUDE GOLDENBERG HELLER ANTOGNOLI ROWLAND 40,620$ WELCH HAROLD GOLDENBERG HELLER ANTOGNOLI ROWLAND 39,355$ APPELQUIST JOYCE GOLDENBERG HELLER ANTOGNOLI ROWLAND 37,365$ DUNAJSKI HELEN GOLDENBERG HELLER ANTOGNOLI ROWLAND 34,355$ AMARGOS ERNESTO GOLDENBERG HELLER ANTOGNOLI ROWLAND 31,832$ MCCLAIN JAMES GOLDENBERG HELLER ANTOGNOLI ROWLAND 31,517$ SMITH PAUL GOLDENBERG HELLER ANTOGNOLI ROWLAND 29,311$ ENDORF EUGENE GOLDENBERG HELLER ANTOGNOLI ROWLAND 29,049$ RING DONALD GOLDENBERG HELLER ANTOGNOLI ROWLAND 22,315$ ENG COURTENAY GOLDENBERG HELLER ANTOGNOLI ROWLAND 19,409$ PERKINS BLANNIE GOLDENBERG HELLER ANTOGNOLI ROWLAND 19,006$ LINDEN SANDRA GOLDENBERG HELLER ANTOGNOLI ROWLAND 17,545$ CHANEY ROBERT GOLDENBERG HELLER ANTOGNOLI ROWLAND 17,503$ VERNON LESLIE GOLDENBERG HELLER ANTOGNOLI ROWLAND 17,456$ DEHGHAN FARHAD GOLDENBERG HELLER ANTOGNOLI ROWLAND 16,740$ CURTIS CALVERT GOLDENBERG HELLER ANTOGNOLI ROWLAND 16,705$ HENDREN JAMES GOLDENBERG HELLER ANTOGNOLI ROWLAND 16,310$ THORNBURG HAROLD GOLDENBERG HELLER ANTOGNOLI ROWLAND 15,568$ ANDERSON MARY GOLDENBERG HELLER ANTOGNOLI ROWLAND 14,235$ LADD PAUL GOLDENBERG HELLER ANTOGNOLI ROWLAND 14,219$ KENEMORE DENAH GOLDENBERG HELLER ANTOGNOLI ROWLAND 13,496$ MURPHY JIMMY GOLDENBERG HELLER ANTOGNOLI ROWLAND 13,101$

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Last Name First Name Lawyer Settlement offerWHITE BILLY GOLDENBERG HELLER ANTOGNOLI ROWLAND 13,034$ WALTON JAMES GOLDENBERG HELLER ANTOGNOLI ROWLAND 12,065$ HAYES GLADYS GOLDENBERG HELLER ANTOGNOLI ROWLAND 11,410$ COMBS GLENNA GOLDENBERG HELLER ANTOGNOLI ROWLAND 11,340$ ALLARD PERRY GOLDENBERG HELLER ANTOGNOLI ROWLAND 11,084$ MCCARTHY MARGARET GOLDENBERG HELLER ANTOGNOLI ROWLAND 11,010$ ORTA PEDRO GOLDENBERG HELLER ANTOGNOLI ROWLAND 10,736$ BELL HERMAN GOLDENBERG HELLER ANTOGNOLI ROWLAND 10,483$ WORTHINGTON DAVID GOLDENBERG HELLER ANTOGNOLI ROWLAND 9,901$ WILSON PAUL GOLDENBERG HELLER ANTOGNOLI ROWLAND 9,385$ BURNETTE THOMAS GOLDENBERG HELLER ANTOGNOLI ROWLAND 9,300$ CANNON JOHN GOLDENBERG HELLER ANTOGNOLI ROWLAND 8,788$ CROUSE GENE GOLDENBERG HELLER ANTOGNOLI ROWLAND 8,223$ SANDOVAL MAE GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,861$ BROSS VALDIS GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,822$ STANEK EUGENE GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,796$ VEITE LAWRENCE GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,633$ BOWERS GLENN GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,171$ WEAR EARL GOLDENBERG HELLER ANTOGNOLI ROWLAND 7,055$ BLACK CHESTER GOLDENBERG HELLER ANTOGNOLI ROWLAND 6,978$ BREWSTER SALLY GOLDENBERG HELLER ANTOGNOLI ROWLAND 6,906$ BILLINGSLEY JAMES GOLDENBERG HELLER ANTOGNOLI ROWLAND 6,664$ JONES SAM GOLDENBERG HELLER ANTOGNOLI ROWLAND 6,597$ DUNAWAY GENEVA GOLDENBERG HELLER ANTOGNOLI ROWLAND 5,770$ MANACH GREGORY GOLDENBERG HELLER ANTOGNOLI ROWLAND 5,286$ ADDRISSI GERALD GOLDENBERG HELLER ANTOGNOLI ROWLAND 5,137$ HOUCK WILLIAM GOLDENBERG HELLER ANTOGNOLI ROWLAND 5,110$ GUTHRIE DORA GOLDENBERG HELLER ANTOGNOLI ROWLAND 5,010$ PERCIFIELD GROVER GOLDENBERG HELLER ANTOGNOLI ROWLAND 4,850$ FABRIZIUS KENNETH GOLDENBERG HELLER ANTOGNOLI ROWLAND 4,527$ HYBELS DONALD GOLDENBERG HELLER ANTOGNOLI ROWLAND 3,669$ VANDERMAR BERT GOLDENBERG HELLER ANTOGNOLI ROWLAND 3,499$ JAASKELA WAINO GOLDENBERG HELLER ANTOGNOLI ROWLAND 2,793$ MCQUISTON MARY GOLDENBERG HELLER ANTOGNOLI ROWLAND 2,580$ MIZE CLIFTON GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,989$ SODA CARL GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,889$ YEOMANS WILLIAM GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,605$ WRAY WILLIAM GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,000$ LAW ROBERT GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,000$ WHITFORD WILLIS GOLDENBERG HELLER ANTOGNOLI ROWLAND 1,000$ MATTHEWS BRUCE GOODMAN MEAGHER 13,920$ OCONNOR WILLIAM GOODMAN MEAGHER 2,010$ GONZALES BERINGO GOODMAN MEAGHER 1,000$ BURGER TIMOTHY GORI JULIAN 160,322$ HIGHLAND ROBERT GORI JULIAN 92,859$ PATRICK LARRY GORI JULIAN 79,185$ CHRISTOPHER WADE GORI JULIAN 67,798$ SCHULTZ DONALD GORI JULIAN 64,998$ HINES DELMAR GORI JULIAN 60,848$ BRAWLEY THOMAS GORI JULIAN 54,533$ SCOTT JAMES GORI JULIAN 51,192$ WELDON CHARLES GORI JULIAN 43,091$ FOSTER DANIEL GORI JULIAN 38,649$ TOBAR BARTHOLOMEW GORI JULIAN 36,887$ HUEY JACKIE GORI JULIAN 35,832$ NEEDHAM JOSEPH GORI JULIAN 28,683$

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Last Name First Name Lawyer Settlement offerPOST LARRY GORI JULIAN 27,929$ TIGNER PATRICIA GORI JULIAN 27,385$ DILLBECK VICTOR GORI JULIAN 27,096$ HUFF JOHN GORI JULIAN 25,241$ HAYNES JOSEPH GORI JULIAN 24,469$ MCGRUDER AARON GORI JULIAN 23,411$ GOLD CARL GORI JULIAN 21,352$ GRAHAM KELLEY GORI JULIAN 20,641$ MORRISON LANNA GORI JULIAN 20,078$ RAMSEY JAMES GORI JULIAN 19,321$ HANSEN RENEE GORI JULIAN 18,787$ FUNDERBURK ROBERT GORI JULIAN 18,369$ KIRN SOPHIA GORI JULIAN 18,064$ MURPHY MICHAEL GORI JULIAN 17,967$ BROOKS SCOTT GORI JULIAN 17,634$ WELCH SAM GORI JULIAN 17,504$ THOMPSON JAMES GORI JULIAN 17,177$ SWAIM ROBERT GORI JULIAN 17,140$ WEIBLE EUGENE GORI JULIAN 17,102$ GAFFEY CHARLES GORI JULIAN 16,893$ KORNMAN ROBIN GORI JULIAN 16,740$ MANSKE JOANN GORI JULIAN 16,740$ HUFF J GORI JULIAN 16,736$ WEBER JACOB GORI JULIAN 16,723$ LUETHYE MICHAEL GORI JULIAN 16,345$ SEAL GILBERT GORI JULIAN 15,569$ AWE VIRGINIA GORI JULIAN 15,218$ HAROLDSON MILTON GORI JULIAN 14,918$ CONNOR MARGARET GORI JULIAN 14,777$ SMOTHERMAN MELVIN GORI JULIAN 14,462$ BRYAN EDDIE GORI JULIAN 14,417$ DAVIS LESTER GORI JULIAN 14,353$ WHITE GARY GORI JULIAN 13,826$ GRISANTI RODNEY GORI JULIAN 12,273$ LANE LOIS GORI JULIAN 12,052$ STOCKTON KENNETH GORI JULIAN 12,041$ GROHOSKY JOHN GORI JULIAN 11,841$ LANDIS DENNIS GORI JULIAN 11,743$ LAZOWSKI PATRICIA GORI JULIAN 11,597$ WIECHENS DENNIS GORI JULIAN 11,419$ FREDERICK DEBORAH GORI JULIAN 11,346$ TENANT JUDY GORI JULIAN 11,183$ ANDERSON LEONARD GORI JULIAN 10,980$ WILCOX JOHN GORI JULIAN 10,860$ NAPIERALA PAUL GORI JULIAN 10,841$ MILLER WILFRED GORI JULIAN 10,641$ DRAKE NANCY GORI JULIAN 10,641$ MYERS DONALD GORI JULIAN 10,618$ CUNNINGHAM WILLIAM GORI JULIAN 10,235$ SIMONAR RONALD GORI JULIAN 10,150$ MALCOLM DANIEL GORI JULIAN 10,082$ CASANOVA RAFAEL GORI JULIAN 10,020$ CROSSLAND GEORGE GORI JULIAN 9,969$ NOE BRIAN GORI JULIAN 9,579$ RITZ KRISTY GORI JULIAN 9,340$ WAGNER AUDREY GORI JULIAN 9,209$

26




Last Name First Name Lawyer Settlement offerCARDENAS RAYSA GORI JULIAN 9,047$ KIND GERALD GORI JULIAN 8,931$ VINES MARY GORI JULIAN 8,788$ MILLS ROBERT GORI JULIAN 8,279$ POPE MICHAEL GORI JULIAN 8,131$ GATTO LOUIS GORI JULIAN 8,128$ DORATO EDWARDO GORI JULIAN 8,010$ LABATHE GERALD GORI JULIAN 7,921$ MCQUAIG WILLIAM GORI JULIAN 7,917$ SAMUEL ROOSEVELT GORI JULIAN 7,819$ MATHEWS SAMUEL GORI JULIAN 7,629$ INGHAM DAN GORI JULIAN 7,564$ PEREZ ADRIANA GORI JULIAN 7,475$ PHILLIPS GERTHA GORI JULIAN 7,358$ SMITH HARMON GORI JULIAN 7,353$ SCHULTZ MELVIN GORI JULIAN 7,347$ YOUNGERT BARBARA GORI JULIAN 7,293$ COOLEY DONALD GORI JULIAN 7,176$ KEATON KATHLEEN GORI JULIAN 7,167$ DAVIDSON SELMA GORI JULIAN 7,078$ NEVES JOHN GORI JULIAN 7,033$ MENDEZ JUAN GORI JULIAN 7,032$ WHITE WALTER GORI JULIAN 7,021$ BRACKBILL ESTHER GORI JULIAN 6,738$ MORTENSON CARL GORI JULIAN 6,680$ PIACENTINE EDWARD GORI JULIAN 6,559$ ARENT DOUGLAS GORI JULIAN 6,204$ DAHLEM JAMES GORI JULIAN 6,028$ LOCKWOOD HOWARD GORI JULIAN 6,020$ ZANKL AUDREY GORI JULIAN 5,892$ GLASS MARY GORI JULIAN 5,881$ OSTROWSKI ALICE GORI JULIAN 5,852$ FAULK AGOSTINA GORI JULIAN 5,770$ YOUNG FRED GORI JULIAN 5,745$ KING WILLARD GORI JULIAN 5,635$ BROBST ERNEST GORI JULIAN 5,560$ LAMAE ROBERT GORI JULIAN 5,428$ BRUNER DALE GORI JULIAN 5,374$ GLASS WILLIAM GORI JULIAN 5,349$ LASSITER VIRGINIA GORI JULIAN 5,273$ KUJAWA LEONARD GORI JULIAN 5,217$ FOLEY MICHAEL GORI JULIAN 5,198$ TRUITT SHIRLEY GORI JULIAN 5,110$ SPECKMAN KARL GORI JULIAN 4,999$ GAITHER JOHN GORI JULIAN 4,842$ KELLER WILLIAM GORI JULIAN 4,822$ TUDOR CHARLES GORI JULIAN 4,707$ QUIN MAGGIE GORI JULIAN 4,444$ TROIAN ROSEMARY GORI JULIAN 4,307$ WEIR DUANE GORI JULIAN 4,199$ KING LISA GORI JULIAN 4,010$ SIMS JOYCE GORI JULIAN 3,812$ CARTER PAULINE GORI JULIAN 3,797$ ANDERSON WILLIAM GORI JULIAN 3,674$ SITTE GERALD GORI JULIAN 3,552$ WILKERSON GUY GORI JULIAN 3,309$

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Last Name First Name Lawyer Settlement offerCATRAMBONE DOMENICK GORI JULIAN 3,291$ ZELLNER RAYMOND GORI JULIAN 2,252$ GRAVES GLORIA GORI JULIAN 1,849$ ODONOHOE JOSEPH GORI JULIAN 1,843$ FISHERMAN SHOSHANA GORI JULIAN 1,732$ MONTESANO RONNEY GORI JULIAN 1,230$ DINS RUDY GORI JULIAN 1,071$ ENGBERG GLEN GORI JULIAN 1,000$ LARIMORE JOHNEY GORI JULIAN 1,000$ MOERLIEN NORM GORI JULIAN 1,000$ HAVERLY PETER GORI JULIAN 1,000$ THOMAS RAYMOND GORI JULIAN 1,000$ MCMILLEN EDWARD GORI JULIAN 1,000$ PARKDS KIMBERLY GORI JULIAN 1,000$ WALKER LORENZO GORI JULIAN 1,000$ MARIAN EARL GORI JULIAN 1,000$ HALE CHARLEY GORI JULIAN 1,000$ REEVES JV GORI JULIAN 1,000$ SOLANO JOHN GORI JULIAN 1,000$ RUTAN CHARLES GREITZER LOCKS 56,793$ STRICKHOUSER DAVID GREITZER LOCKS 49,633$ DEENEY JANE GREITZER LOCKS 47,798$ CONLON MICHAEL GREITZER LOCKS 46,582$ MURRAY GENE GREITZER LOCKS 35,729$ SCHNURE DANIEL GREITZER LOCKS 32,630$ BAPTISTE FRANCIS GREITZER LOCKS 31,658$ CLARK JOHN GREITZER LOCKS 27,835$ NEMESH ELSIE GREITZER LOCKS 14,523$ MELFI ALBERT GREITZER LOCKS 13,268$ SPADONE PAUL GREITZER LOCKS 11,814$ PINIERO MARGARET GREITZER LOCKS 11,236$ JAYNES WILLIAM GREITZER LOCKS 8,957$ CRAWFORD CHARLES GREITZER LOCKS 8,219$ WASILEWSKI ALBERT GREITZER LOCKS 8,015$ FOLTZ FRANK GREITZER LOCKS 7,499$ MCVEY PATRICK GREITZER LOCKS 7,214$ STITT WILMER GREITZER LOCKS 6,891$ CECCORULLI LOUIS GREITZER LOCKS 5,983$ LIU JAMES GREITZER LOCKS 5,685$ DUFFY GEORGE GREITZER LOCKS 5,115$ KELLER WILLIAM GREITZER LOCKS 5,062$ MACLEOD DOUGLAS GREITZER LOCKS 4,870$ DAVIS MARY GREITZER LOCKS 4,717$ CROUCH NATHAN GREITZER LOCKS 4,226$ TANIER JOHN GREITZER LOCKS 4,080$ CONLON ROBERT GREITZER LOCKS 3,572$ RITTER ALPHONSO GREITZER LOCKS 2,805$ MAFFEI ALBERT GREITZER LOCKS 2,745$ WASEKANES WILLIAM GREITZER LOCKS 2,201$ PIERNIKOSKI FELIX GREITZER LOCKS 1,843$ LEWIS FREDERICK GREITZER LOCKS 1,000$ RAUSCH MARVIN GREITZER LOCKS 1,000$ SANTMIER HARVEY HAMBURG RUBIN 5,456$ RUSSOW DONALD HARTLEY OBRIEN 32,391$ WRIGHT EMMETT HARTLEY OBRIEN 18,325$ ROSE DEBORAH HARTLEY OBRIEN 15,908$

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Last Name First Name Lawyer Settlement offerSAYRE DONNA HARTLEY OBRIEN 15,569$ DUNLAP THOMAS HARTLEY OBRIEN 15,438$ GILLESPIE ROBERT HARTLEY OBRIEN 3,077$ FREUDENHAMMER GERD HARTLEY OBRIEN 1,000$ JOHNSON MARTHA HARTLEY OBRIEN 1,000$ WILLIAMS JIMMIE HARTLEY OBRIEN 1,000$ WILLIAMS KEITH HARVIT SCHWARTZ 100,585$ HOLTER DAVID HARVIT SCHWARTZ 56,152$ FIFE JAMES HARVIT SCHWARTZ 10,393$ LUPARDUS ROY HARVIT SCHWARTZ 9,901$ POST LYNN HARVIT SCHWARTZ 7,604$ BOSELY LORRAINE HARVIT SCHWARTZ 6,510$ GILLISPIE HASKELL HARVIT SCHWARTZ 5,158$ OPYOKE JOHN HARVIT SCHWARTZ 4,111$ ROBERTS EMMA HARVIT SCHWARTZ 2,614$ BRYANT JAMES HARVIT SCHWARTZ 1,000$ ALDERMAN THEODORE HARVIT SCHWARTZ 1,000$ SORSAIA MICHAEL HARVIT SCHWARTZ 1,000$ CREEL EDWARD HENINGER GARRISON DAVIS 46,802$ BONNEVAL ALBERT HENINGER GARRISON DAVIS 15,216$ BENJAMIN LARRY HENINGER GARRISON DAVIS 13,101$ HOWARD HURSHEL HENINGER GARRISON DAVIS 9,587$ SPERIDON PETE HENINGER GARRISON DAVIS 9,062$ MCGUFFIE ALFORD HENINGER GARRISON DAVIS 8,472$ BOBROW JERRY HENINGER GARRISON DAVIS 7,185$ MASON JOSEPH HENINGER GARRISON DAVIS 6,954$ TUCKER CHARLES HENINGER GARRISON DAVIS 2,573$ WATSON DENNIS HENINGER GARRISON DAVIS 1,000$ BURGESS CHARLIE HERSCHEL HOBSON 113,561$ PRICE PHILLIP HERSCHEL HOBSON 34,684$ FOSTER DONALD HERSCHEL HOBSON 13,313$ VICKERY LILLIE HERSCHEL HOBSON 1,000$ THIELE FLOYD HISSEY KIENTZ HERRON 61,316$ BACON FRED HISSEY KIENTZ HERRON 18,448$ BRAUN LARRY HISSEY KIENTZ HERRON 10,823$ STARR ROBERT HISSEY KIENTZ HERRON 8,298$ JENKINS CHARLES HISSEY KIENTZ HERRON 6,866$ OBRIEN LARRY HORWITZ HORWITZ 1,000$ RITTER JAMES HOSSLEY EMBRY 31,573$ COBB ALFRED HOSSLEY EMBRY 18,447$ RUIZ ANTONIO HOSSLEY EMBRY 4,846$ ELLIOTT JAMES HOWARD BRENNER 61,724$ NELSON CHARLES HOWARD BRENNER 28,140$ MURRAY DAVID HOWARD BRENNER 7,795$ WEBER WILLIAM HOWARD BRENNER 6,844$ TORREGANO LOUIS HOWARD LAUDUMIEY MANN REED GOLDSTEIN 6,691$ CALFO AUGUSTINE JACOBS CRUMPLAR 55,760$ TURCHEN JOSEPH JACOBS CRUMPLAR 48,916$ FIORAVANTI JULIO JACOBS CRUMPLAR 14,008$ NEAL WILLIAM JACOBS CRUMPLAR 7,914$ HELSEL ROBERT JACOBS CRUMPLAR 5,528$ NICKOLAS ARTHUR JACOBS CRUMPLAR 2,272$ PLUMMER EDMOND JACOBS CRUMPLAR 1,575$ LEE FREDERICK JACOBS CRUMPLAR 1,000$ THOMPSON TERRY JACOBS CRUMPLAR 1,000$ FOSTER JOHN JAMES HESSION 72,017$

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Last Name First Name Lawyer Settlement offerHUBBARD CHARLES JAMES HUMPHREYS 72,071$ SHINN CARL JAMES HUMPHREYS 56,501$ KIGER GERALD JAMES HUMPHREYS 25,925$ WILLIS DAVID JAMES HUMPHREYS 15,508$ MODLEY FRANKLIN JAMES HUMPHREYS 11,003$ QUEEN DEWEY JAMES HUMPHREYS 7,930$ CYRUS RONALD JAMES HUMPHREYS 7,229$ MILLER CLARENCE JEFFREY MUTNICK 29,297$ YORATH SCOTT JEFFREY MUTNICK 26,528$ MEEK DUANE JOHN KASSEL 1,000$ GEORGE CHARLES JOHN KASSEL 1,000$ CONANT DONALD JONATHAN SHUB 1,000$ DAVIS ELMER JONES MARTIN 74,685$ HUMPHREY WADE JONES MARTIN 42,819$ MORGAN ELMER JONES MARTIN 35,031$ WOOD NORWOOD JONES MARTIN 18,415$ GOINS PARILEE JONES MARTIN 18,280$ MCKEITHAN VINCENT JONES MARTIN 17,365$ MIHALOV ANDREW JONES MARTIN 16,859$ WILLIAMS RAYMOND JONES MARTIN 15,803$ WATLINGTON HENRY JONES MARTIN 11,963$ GARLAND SALVATORE JONES MARTIN 10,733$ HUDSON LULA JONES MARTIN 10,401$ JOYNER JOHN JONES MARTIN 9,090$ GREENE FRED JONES MARTIN 6,978$ KELLY DONALD JONES MARTIN 5,540$ MCMAHAN JEFFERSON JONES MARTIN 4,343$ SALEEBY MITCHELL JONES MARTIN 2,856$ WATKINS CHARLES JONES MARTIN 2,826$ WOODALL JOHN JONES MARTIN 2,513$ WALLACE ALBERT JONES MARTIN 1,520$ BERGERON RICHARD JONES MARTIN 1,000$ TINSLEY SAMUEL JONES MARTIN 1,000$ MARSHALL STEPHEN JOYCE JOYCE 1,000$ SNYDER ALAN KARST VON OISTE 1,000$ ENGEL JUANITA KARST VON OISTE 1,000$ BLATT RONALD KAZAN MCCLAIN 93,718$ BROWN M KAZAN MCCLAIN 61,082$ RILEY DENNIS KAZAN MCCLAIN 56,564$ LINDENMAYER ROBERT KAZAN MCCLAIN 40,988$ STRACHAN TERRY KAZAN MCCLAIN 40,177$ TOMMANEY JOHN KAZAN MCCLAIN 30,772$ PARIS EUGENE KAZAN MCCLAIN 29,464$ LEMIRE JOHN KAZAN MCCLAIN 23,063$ TURNER DARRELL KAZAN MCCLAIN 21,565$ DANIELS PETER KAZAN MCCLAIN 19,661$ GARDNER RICHARD KAZAN MCCLAIN 17,211$ BARKER TIMOTHY KAZAN MCCLAIN 16,480$ GARATE JOSEPHINE KAZAN MCCLAIN 12,881$ CANTRELL CHARLES KAZAN MCCLAIN 10,951$ HAUN ROBERT KAZAN MCCLAIN 8,890$ LAUGHLIN KAREN KAZAN MCCLAIN 5,253$ BRUNGARDT DELBERT KAZAN MCCLAIN 3,832$ ANDREOLI RENE KEEFE BARTELS CLARK 1,000$ YOUNG ELLA KELLER FISHBACK 1,000$ HOLLAND JOE KELLER FISHBACK 1,000$

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Last Name First Name Lawyer Settlement offerMILLER RALPH KELLER FISHBACK 1,000$ SHAFFER WANDA KELLEY FERRARO 165,443$ ECKARDT KURT KELLEY FERRARO 50,359$ DILLON ROBERT KELLEY FERRARO 26,402$ HANNA ROGER KELLEY FERRARO 22,970$ WALCHER ROSEANNA KELLEY FERRARO 16,345$ SCOTT JAMES KELLEY FERRARO 13,608$ BLARE BRADLEY KELLEY FERRARO 11,634$ RICHARDS TIMOTHY KELLEY FERRARO 10,874$ DEOMA MARY KELLEY FERRARO 9,424$ HUNT JOHN KELLEY FERRARO 8,772$ BIELINSKI FLORENCE KELLEY FERRARO 8,023$ BORNS MARY KELLEY FERRARO 6,216$ DEGROOT HARVEY KELLEY FERRARO 6,119$ KUZLIK ANNA KELLEY FERRARO 5,436$ STEVENSON WILLIAM KELLEY FERRARO 4,900$ HENRY PAUL KELLEY FERRARO 4,821$ STARK LOUIS KELLEY FERRARO 3,968$ TARTAGLIA GARY KELLEY FERRARO 3,190$ ASKEW RAYMOND KEVIN MCDERMOTT CO LPA 85,707$ LINKOUS CHARLES KEVIN MCDERMOTT CO LPA 13,122$ VENTERS CHARLIE KEVIN MCDERMOTT CO LPA 12,140$ DRAKE FREDDIE KEVIN MCDERMOTT CO LPA 10,521$ VORHIES CLYDE KEVIN MCDERMOTT CO LPA 6,999$ NEMETH LOUIS KEVIN MCDERMOTT CO LPA 5,542$ NOWAK FRANK KEVIN MCDERMOTT CO LPA 1,078$ PINNER EDWIN KEYES 1,000$ WEST WILLIAM KEYES 1,000$ BETANCUR HILARIO KIESEL BOUCHER LARSON 1,000$ DAVIS RONALD KIESEL BOUCHER LARSON 1,000$ GLEASON DAVID KIESEL BOUCHER LARSON 1,000$ REEVES ROBERT KIRKSEYASSOCIATES 9,076$ RITTER GERARD KLINE SPECTER 10,131$ KASKA EDWARD KLINE SPECTER 1,000$ MOCK LOREN KOREIN TILLERY 1,000$ PASQUALE AMERICO KOREIN TILLERY 1,000$ HINES RAYMOND KOREIN TILLERY 1,000$ TROSS OWEN LAKIN HERNDON 1,000$ WHITE ALLEN LANDRY SWARR 17,806$ HARDENSTEIN HOWARD LANDRY SWARR 11,457$ PATROLIA HENRY LANDRY SWARR 4,741$ BOUDREAUX LLOYD LANDRY SWARR 3,730$ ZIMMERMAN WENDY LANIER PARKER SULLIVAN 185,496$ COLE CHARLES LANIER PARKER SULLIVAN 160,322$ KEIDEL GAILANNE LANIER PARKER SULLIVAN 146,948$ BURCH ROBERT LANIER PARKER SULLIVAN 127,637$ KORTE RONALD LANIER PARKER SULLIVAN 127,637$ DUROSS RICHARD LANIER PARKER SULLIVAN 116,493$ JUNGHANS MARK LANIER PARKER SULLIVAN 107,969$ LABOVE LIONEL LANIER PARKER SULLIVAN 102,282$ HODGE CECIL LANIER PARKER SULLIVAN 100,277$ TURNER JO LANIER PARKER SULLIVAN 99,203$ WOOD ROBERT LANIER PARKER SULLIVAN 96,332$ MARTIN JIMMY LANIER PARKER SULLIVAN 95,808$ MESSER JESSE LANIER PARKER SULLIVAN 91,409$ FRIEDMAN PETER LANIER PARKER SULLIVAN 86,018$

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Last Name First Name Lawyer Settlement offerSIMS LARRY LANIER PARKER SULLIVAN 78,460$ REAGAN GARY LANIER PARKER SULLIVAN 78,180$ BAILEY JOHN LANIER PARKER SULLIVAN 76,504$ STEFFANS HERMAN LANIER PARKER SULLIVAN 75,643$ ZBYLUT FRANK LANIER PARKER SULLIVAN 73,484$ OLIVER MARVIN LANIER PARKER SULLIVAN 72,456$ DOIGG DAVID LANIER PARKER SULLIVAN 72,103$ BOWSER LARRY LANIER PARKER SULLIVAN 70,148$ GOSNELL WALTER LANIER PARKER SULLIVAN 68,470$ WACHS THOMAS LANIER PARKER SULLIVAN 67,541$ STALIK EDWARD LANIER PARKER SULLIVAN 65,588$ MCDANIELS LARRY LANIER PARKER SULLIVAN 63,245$ CRUM DON LANIER PARKER SULLIVAN 61,900$ MALLORY RALPH LANIER PARKER SULLIVAN 60,677$ ELLIOTT SHIRLEY LANIER PARKER SULLIVAN 60,642$ CAIN LARRY LANIER PARKER SULLIVAN 58,894$ BINGHAM JOHN LANIER PARKER SULLIVAN 56,704$ POLLOCK JEANIE LANIER PARKER SULLIVAN 55,832$ GLOWKA STANLEY LANIER PARKER SULLIVAN 55,588$ WALLS FREDERICK LANIER PARKER SULLIVAN 54,897$ GREINER ANTON LANIER PARKER SULLIVAN 54,857$ WELLS RICHARD LANIER PARKER SULLIVAN 54,019$ DUNHAM JAMES LANIER PARKER SULLIVAN 52,984$ LEWIS RUSSELL LANIER PARKER SULLIVAN 52,512$ KRAKOWSKI ALFRED LANIER PARKER SULLIVAN 52,295$ FURMAN DANIEL LANIER PARKER SULLIVAN 52,028$ FLETCHER ROBERT LANIER PARKER SULLIVAN 51,913$ WESTON CHRISTOPHER LANIER PARKER SULLIVAN 50,440$ LONGORIA DANIEL LANIER PARKER SULLIVAN 49,530$ POTCHOIBA WILLIAM LANIER PARKER SULLIVAN 48,245$ APITSCH JOHN LANIER PARKER SULLIVAN 47,892$ THIBODEAU JAMES LANIER PARKER SULLIVAN 46,838$ LORENZ RAYMOND LANIER PARKER SULLIVAN 46,192$ TURNER LOWELL LANIER PARKER SULLIVAN 45,112$ WADSWORTH GEORGE LANIER PARKER SULLIVAN 45,090$ MOSLEY DAVID LANIER PARKER SULLIVAN 44,084$ SIMKINS SHIRLEY LANIER PARKER SULLIVAN 43,165$ BINGHAM DARRELL LANIER PARKER SULLIVAN 43,096$ VERBA GORDON LANIER PARKER SULLIVAN 42,945$ THOMAS MARVIN LANIER PARKER SULLIVAN 42,942$ BLACK DAVID LANIER PARKER SULLIVAN 42,108$ SMALARZ JOHN LANIER PARKER SULLIVAN 42,106$ BOISCLAIR ROLAND LANIER PARKER SULLIVAN 40,627$ BUSH LLOYD LANIER PARKER SULLIVAN 40,336$ BRENNAN THOMAS LANIER PARKER SULLIVAN 40,177$ KILPATRICK ROBERT LANIER PARKER SULLIVAN 40,177$ NEWCOM JOHN LANIER PARKER SULLIVAN 40,177$ PRASAD BENAY LANIER PARKER SULLIVAN 40,114$ SWEARINGEN ROBERT LANIER PARKER SULLIVAN 40,025$ MORROW JOHNIE LANIER PARKER SULLIVAN 39,228$ HEID JOSEPH LANIER PARKER SULLIVAN 36,693$ DERRY VIRGINIA LANIER PARKER SULLIVAN 35,714$ GARBRY MARK LANIER PARKER SULLIVAN 35,503$ MARRERO SUSAN LANIER PARKER SULLIVAN 35,272$ CLINE LEE LANIER PARKER SULLIVAN 35,091$ SMITH RUTH LANIER PARKER SULLIVAN 34,982$

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Last Name First Name Lawyer Settlement offerCARTER FRANCES LANIER PARKER SULLIVAN 34,903$ MALONE FRANCIS LANIER PARKER SULLIVAN 34,378$ MARTEL ALANA LANIER PARKER SULLIVAN 34,262$ MOLINA YSABEL LANIER PARKER SULLIVAN 34,262$ WILSON ROBERT LANIER PARKER SULLIVAN 34,262$ MARTIN PAUL LANIER PARKER SULLIVAN 33,965$ BARROSO JESUS LANIER PARKER SULLIVAN 33,911$ TALLEY LYNN LANIER PARKER SULLIVAN 33,759$ COOKE PATRICIA LANIER PARKER SULLIVAN 33,729$ STRAUB STANLEY LANIER PARKER SULLIVAN 33,700$ NIMMONS SHIRLEY LANIER PARKER SULLIVAN 32,391$ DUNNAM RAYFORD LANIER PARKER SULLIVAN 32,366$ MEYER JOHN LANIER PARKER SULLIVAN 31,853$ EMERY LLOYD LANIER PARKER SULLIVAN 31,644$ SCHEIDEMAN EDWARD LANIER PARKER SULLIVAN 31,159$ NOLL WILLIAM LANIER PARKER SULLIVAN 30,905$ ZAMEROSKI JOHN LANIER PARKER SULLIVAN 30,905$ TWIFORD DONALD LANIER PARKER SULLIVAN 30,903$ LODEN BENNY LANIER PARKER SULLIVAN 30,565$ STARNA HENRY LANIER PARKER SULLIVAN 30,516$ MOORE ALFRED LANIER PARKER SULLIVAN 30,138$ LEWIS CHARLES LANIER PARKER SULLIVAN 30,138$ HAMACHER KENNETH LANIER PARKER SULLIVAN 30,127$ MURDZIA RODNEY LANIER PARKER SULLIVAN 29,753$ AMABILE PATRICK LANIER PARKER SULLIVAN 29,648$ KIRK KENNETH LANIER PARKER SULLIVAN 29,515$ HOBBS JAMES LANIER PARKER SULLIVAN 29,455$ MCDONALD DAVID LANIER PARKER SULLIVAN 29,230$ JACOBI GALE LANIER PARKER SULLIVAN 28,900$ COLLINS BILLY LANIER PARKER SULLIVAN 28,861$ BEEKMAN LARRY LANIER PARKER SULLIVAN 28,779$ PAUL GEORGE LANIER PARKER SULLIVAN 28,742$ FLAHERTY KEVIN LANIER PARKER SULLIVAN 28,287$ BATES FRANCIS LANIER PARKER SULLIVAN 27,916$ WARREN WILLIAM LANIER PARKER SULLIVAN 27,835$ HENDERSON JOEL LANIER PARKER SULLIVAN 27,610$ ALLISON PATSY LANIER PARKER SULLIVAN 27,524$ ROYS JAMES LANIER PARKER SULLIVAN 27,361$ MERIDETH BRUNETTA LANIER PARKER SULLIVAN 26,694$ STUCK PATTY LANIER PARKER SULLIVAN 26,604$ BAGLEY EDWARD LANIER PARKER SULLIVAN 26,472$ MICHAELI CHARLES LANIER PARKER SULLIVAN 26,340$ RICKLES DAVID LANIER PARKER SULLIVAN 26,289$ HAMBICKI MACK LANIER PARKER SULLIVAN 26,226$ DAVIS CARL LANIER PARKER SULLIVAN 26,062$ STRICKLER BARRY LANIER PARKER SULLIVAN 26,026$ ROSEN CLIFFORD LANIER PARKER SULLIVAN 25,819$ BOURG LEE LANIER PARKER SULLIVAN 25,811$ PARKER GARY LANIER PARKER SULLIVAN 25,713$ SCOTT JOHN LANIER PARKER SULLIVAN 25,607$ ORTEGA DAMIAN LANIER PARKER SULLIVAN 25,553$ MEAD WILLIAM LANIER PARKER SULLIVAN 25,154$ HARRIS DAVID LANIER PARKER SULLIVAN 25,087$ MCCLURE MICHAEL LANIER PARKER SULLIVAN 24,892$ MYERS WANDA LANIER PARKER SULLIVAN 24,812$ MALLETTE THERESA LANIER PARKER SULLIVAN 24,748$

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Last Name First Name Lawyer Settlement offerKIDD DENNIS LANIER PARKER SULLIVAN 24,514$ PIERCE RICHARD LANIER PARKER SULLIVAN 24,396$ SODERBERG ROBERT LANIER PARKER SULLIVAN 24,385$ SHREVE GLENN LANIER PARKER SULLIVAN 24,298$ CAUDILL DAVID LANIER PARKER SULLIVAN 24,146$ MAYFIELD DANIEL LANIER PARKER SULLIVAN 24,110$ VOGT ARTHUR LANIER PARKER SULLIVAN 23,852$ THOMAS RICHARD LANIER PARKER SULLIVAN 23,778$ POLLAND ROBERT LANIER PARKER SULLIVAN 23,580$ NICHOLS GREGORY LANIER PARKER SULLIVAN 23,001$ MICHOR PATRICIA LANIER PARKER SULLIVAN 22,958$ ZIMMERMAN CLARENCE LANIER PARKER SULLIVAN 22,899$ METEVIA JOSEPH LANIER PARKER SULLIVAN 22,825$ REEVES RICHARD LANIER PARKER SULLIVAN 22,750$ MCGINN STANLEY LANIER PARKER SULLIVAN 22,552$ ALBERT KATHRYN LANIER PARKER SULLIVAN 22,525$ WOOD JENELL LANIER PARKER SULLIVAN 22,491$ SANCHEZ JOE LANIER PARKER SULLIVAN 21,961$ HENNIGIN WILLIAM LANIER PARKER SULLIVAN 21,922$ ORDUNO OSBALDO LANIER PARKER SULLIVAN 21,883$ HUBBARD DAVID LANIER PARKER SULLIVAN 21,427$ PANCOE RICHARD LANIER PARKER SULLIVAN 21,413$ BENEDICT WILLIAM LANIER PARKER SULLIVAN 21,390$ LOMBARDI JAMES LANIER PARKER SULLIVAN 21,324$ MCENTEE GERALD LANIER PARKER SULLIVAN 21,259$ BRAESE RICHARD LANIER PARKER SULLIVAN 21,223$ LUND LARRY LANIER PARKER SULLIVAN 21,009$ MILLSAPS RALPH LANIER PARKER SULLIVAN 20,959$ WEST JIMMY LANIER PARKER SULLIVAN 20,794$ MONTGOMERY BARBARA LANIER PARKER SULLIVAN 20,713$ LOWERY RICKY LANIER PARKER SULLIVAN 20,680$ SHAUD MICHAEL LANIER PARKER SULLIVAN 20,637$ LARSON RONALD LANIER PARKER SULLIVAN 20,553$ JONES RAYMOND LANIER PARKER SULLIVAN 20,547$ KNIGHT KENNETH LANIER PARKER SULLIVAN 20,452$ MCGINNIS LLOYD LANIER PARKER SULLIVAN 20,400$ DUCKWORTH JOHNNY LANIER PARKER SULLIVAN 20,324$ SOLTIS FRANCIS LANIER PARKER SULLIVAN 20,003$ GRANT DONALD LANIER PARKER SULLIVAN 19,917$ MIHALIS STEPHEN LANIER PARKER SULLIVAN 19,909$ VIETMEIER LEO LANIER PARKER SULLIVAN 19,886$ BONILLA EVELIO LANIER PARKER SULLIVAN 19,813$ HASKELL CLARENCE LANIER PARKER SULLIVAN 19,763$ SEAVOY DANIEL LANIER PARKER SULLIVAN 19,697$ PARROTT ROBERT LANIER PARKER SULLIVAN 19,671$ MARTIN MILDRED LANIER PARKER SULLIVAN 19,555$ FLURY DONALD LANIER PARKER SULLIVAN 19,515$ DIXON KENNETH LANIER PARKER SULLIVAN 19,211$ BOLT RAY LANIER PARKER SULLIVAN 19,129$ AGUILAR ANTONIO LANIER PARKER SULLIVAN 18,941$ GLICK EVA LANIER PARKER SULLIVAN 18,862$ HAILE THOMAS LANIER PARKER SULLIVAN 18,850$ BAXTER WILLIAM LANIER PARKER SULLIVAN 18,723$ MILLER PAUL LANIER PARKER SULLIVAN 18,543$ DEAN MYRNA LANIER PARKER SULLIVAN 18,534$ LIEDEL MELVIN LANIER PARKER SULLIVAN 18,521$

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Last Name First Name Lawyer Settlement offerRICHARDSON JAMES LANIER PARKER SULLIVAN 18,416$ HOWELL ROBERT LANIER PARKER SULLIVAN 18,405$ AYALA LEWIS LANIER PARKER SULLIVAN 18,269$ DRUMEL WILLIAM LANIER PARKER SULLIVAN 18,175$ CARD RUDOLPH LANIER PARKER SULLIVAN 18,102$ GILES OLIN LANIER PARKER SULLIVAN 17,888$ WHITBY WILLIAM LANIER PARKER SULLIVAN 17,808$ WEST ROBERT LANIER PARKER SULLIVAN 17,761$ HAFLEY BARBARA LANIER PARKER SULLIVAN 17,651$ LINDLEY WILLIAM LANIER PARKER SULLIVAN 17,424$ WOLIVER CAM LANIER PARKER SULLIVAN 17,086$ BEAGLEHOLE ANNA LANIER PARKER SULLIVAN 17,032$ LIEBAU RALPH LANIER PARKER SULLIVAN 16,913$ NOEL RAYMOND LANIER PARKER SULLIVAN 16,902$ PEARCE ROBERT LANIER PARKER SULLIVAN 16,813$ STANCIL JACQUELINE LANIER PARKER SULLIVAN 16,740$ JOHNSON BRUCE LANIER PARKER SULLIVAN 16,548$ GARLAND GLENN LANIER PARKER SULLIVAN 16,531$ KILLEBREW RONALD LANIER PARKER SULLIVAN 16,515$ BRECKENRIDGE MARY LANIER PARKER SULLIVAN 16,486$ YOUNG JAMES LANIER PARKER SULLIVAN 16,460$ CLAPP DONALD LANIER PARKER SULLIVAN 16,381$ OWENS JOHN LANIER PARKER SULLIVAN 16,314$ SHAW ROBERT LANIER PARKER SULLIVAN 16,261$ SANDERS ERNEST LANIER PARKER SULLIVAN 16,250$ KOVALESKI ALEX LANIER PARKER SULLIVAN 15,998$ BOLT JUDY LANIER PARKER SULLIVAN 15,908$ SIERRA DOROTEO LANIER PARKER SULLIVAN 15,765$ HENCK MICHAEL LANIER PARKER SULLIVAN 15,733$ ANTILL PAUL LANIER PARKER SULLIVAN 15,716$ RIDEN CHARLES LANIER PARKER SULLIVAN 15,676$ TORRES DIANA LANIER PARKER SULLIVAN 15,416$ KEECH KENNETH LANIER PARKER SULLIVAN 15,251$ KILMAN MARK LANIER PARKER SULLIVAN 15,205$ PARKER HOWARD LANIER PARKER SULLIVAN 15,183$ HEINRACH AGNES LANIER PARKER SULLIVAN 15,174$ SORENSEN HENRY LANIER PARKER SULLIVAN 15,080$ ARRINGTON MORRIS LANIER PARKER SULLIVAN 14,936$ BLAND CRAIG LANIER PARKER SULLIVAN 14,930$ RENDON EMILIO LANIER PARKER SULLIVAN 14,921$ MITCHEM RONALD LANIER PARKER SULLIVAN 14,911$ DESORMEAUX ROBERT LANIER PARKER SULLIVAN 14,799$ VAGENAS JAMES LANIER PARKER SULLIVAN 14,549$ PATRICK RAYMOND LANIER PARKER SULLIVAN 14,468$ ANDERSON CLIFFORD LANIER PARKER SULLIVAN 14,459$ SETLIFF MARY LANIER PARKER SULLIVAN 14,452$ ZAVADIL EDWIN LANIER PARKER SULLIVAN 14,367$ SELF BARBARA LANIER PARKER SULLIVAN 14,276$ MARRERO OLGA LANIER PARKER SULLIVAN 14,271$ JONES OLIVER LANIER PARKER SULLIVAN 14,202$ WILLIAMS GARY LANIER PARKER SULLIVAN 14,202$ MARIETTA EUGENE LANIER PARKER SULLIVAN 14,068$ MCCORMICK THOMAS LANIER PARKER SULLIVAN 14,021$ WALLACE JAMES LANIER PARKER SULLIVAN 13,970$ SOLIS JONAS LANIER PARKER SULLIVAN 13,956$ MAHARREY ALTON LANIER PARKER SULLIVAN 13,811$

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Last Name First Name Lawyer Settlement offerGERTISER GERALD LANIER PARKER SULLIVAN 13,768$ NELSON FRED LANIER PARKER SULLIVAN 13,768$ COOK DOUGLAS LANIER PARKER SULLIVAN 13,719$ SINDA WALTER LANIER PARKER SULLIVAN 13,710$ WHITE DONALD LANIER PARKER SULLIVAN 13,659$ BAILEY EVELYN LANIER PARKER SULLIVAN 13,514$ MONKMAN CLIFFORD LANIER PARKER SULLIVAN 13,483$ GOBIN PHILLIP LANIER PARKER SULLIVAN 13,445$ VILLONT JACK LANIER PARKER SULLIVAN 13,397$ SLIGH GARLAND LANIER PARKER SULLIVAN 13,308$ ANGELIS FERDINAND LANIER PARKER SULLIVAN 13,249$ ARAIZA SANTIAGO LANIER PARKER SULLIVAN 13,234$ CUJAR JOANNE LANIER PARKER SULLIVAN 13,185$ BECK JAIGNE LANIER PARKER SULLIVAN 13,185$ MOONEY JOHN LANIER PARKER SULLIVAN 13,147$ OSMULSKI ROBERT LANIER PARKER SULLIVAN 13,094$ ANDERSEN DAVID LANIER PARKER SULLIVAN 13,080$ LEHNEN ROBERT LANIER PARKER SULLIVAN 13,063$ MEYERS WALTER LANIER PARKER SULLIVAN 13,026$ BLAKES MARLENE LANIER PARKER SULLIVAN 12,877$ COODY STEVEN LANIER PARKER SULLIVAN 12,877$ DOYLE BRUCE LANIER PARKER SULLIVAN 12,877$ GARCIA CARMELO LANIER PARKER SULLIVAN 12,877$ TOCHER LARRY LANIER PARKER SULLIVAN 12,573$ JONES BRIAN LANIER PARKER SULLIVAN 12,573$ PRESTON WILLIE LANIER PARKER SULLIVAN 12,545$ BESS NED LANIER PARKER SULLIVAN 12,540$ VIGER BERNARD LANIER PARKER SULLIVAN 12,534$ COWE ROY LANIER PARKER SULLIVAN 12,526$ DEPAUL JOHN LANIER PARKER SULLIVAN 12,452$ JONES ROBBIE LANIER PARKER SULLIVAN 12,386$ NOCCO ROBERT LANIER PARKER SULLIVAN 12,268$ HARRISON JAMES LANIER PARKER SULLIVAN 12,249$ BELL WILLIAM LANIER PARKER SULLIVAN 12,192$ CATO WILFRED LANIER PARKER SULLIVAN 12,161$ GAU LONNIE LANIER PARKER SULLIVAN 12,104$ CORDY LEE LANIER PARKER SULLIVAN 12,097$ BROOKSHIRE MARGARET LANIER PARKER SULLIVAN 12,040$ JACKSON OLIVER LANIER PARKER SULLIVAN 12,012$ KATTERHEINRICH SUSAN LANIER PARKER SULLIVAN 11,976$ SMITH GLENNA LANIER PARKER SULLIVAN 11,712$ TROXEL JIM LANIER PARKER SULLIVAN 11,664$ SPRADLIN AMOS LANIER PARKER SULLIVAN 11,627$ SWITZER ROBERT LANIER PARKER SULLIVAN 11,615$ LIPAROTO VITO LANIER PARKER SULLIVAN 11,600$ MOORE JERRY LANIER PARKER SULLIVAN 11,551$ MARKEL CECIL LANIER PARKER SULLIVAN 11,463$ COX WENDELL LANIER PARKER SULLIVAN 11,299$ LOUTENSOCK JOHN LANIER PARKER SULLIVAN 11,219$ BATEMAN CLIFTON LANIER PARKER SULLIVAN 11,103$ BROWN DAVID LANIER PARKER SULLIVAN 11,085$ FORESTER MARLENE LANIER PARKER SULLIVAN 11,043$ MACIAG SOPHIA LANIER PARKER SULLIVAN 10,982$ KENNEDY ROBERT LANIER PARKER SULLIVAN 10,969$ CRIPPEN BASIL LANIER PARKER SULLIVAN 10,940$ POWERS JAMES LANIER PARKER SULLIVAN 10,887$

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Last Name First Name Lawyer Settlement offerBERGGREN MARVIN LANIER PARKER SULLIVAN 10,770$ SHANKUS WILLIAM LANIER PARKER SULLIVAN 10,753$ SCHROEDER GERALD LANIER PARKER SULLIVAN 10,678$ BENARD HOWARD LANIER PARKER SULLIVAN 10,659$ GEORGE JAMES LANIER PARKER SULLIVAN 10,546$ UNGAR SHARLENE LANIER PARKER SULLIVAN 10,487$ HENDERSHOTT AMOS LANIER PARKER SULLIVAN 10,272$ RUSSELL ROBERT LANIER PARKER SULLIVAN 10,035$ SELTZER HAROLD LANIER PARKER SULLIVAN 9,977$ KLING HAROLD LANIER PARKER SULLIVAN 9,934$ STAHL JOYCE LANIER PARKER SULLIVAN 9,905$ LONON BARBARA LANIER PARKER SULLIVAN 9,858$ VANDERLICK ROBERT LANIER PARKER SULLIVAN 9,645$ KUHNS JOHN LANIER PARKER SULLIVAN 9,624$ ARTHUR WILBURN LANIER PARKER SULLIVAN 9,545$ BRAZEE GEORGE LANIER PARKER SULLIVAN 9,497$ DIXON RALPH LANIER PARKER SULLIVAN 9,418$ MCNAMARA DANIEL LANIER PARKER SULLIVAN 9,400$ JAJUGA JAMES LANIER PARKER SULLIVAN 9,365$ BRAUN EVART LANIER PARKER SULLIVAN 9,333$ OVERBEE VERGIE LANIER PARKER SULLIVAN 9,333$ SCHADE GEORGE LANIER PARKER SULLIVAN 9,322$ STAUCH DORIS LANIER PARKER SULLIVAN 9,305$ FARRELL FREDRICK LANIER PARKER SULLIVAN 9,284$ STRICKLAND JAMES LANIER PARKER SULLIVAN 9,181$ PARKER KENNETH LANIER PARKER SULLIVAN 9,117$ DOIG RONALD LANIER PARKER SULLIVAN 9,104$ SCHABILION OTTO LANIER PARKER SULLIVAN 9,065$ FOSTER DAVID LANIER PARKER SULLIVAN 9,011$ JOSEPHSON RICHARD LANIER PARKER SULLIVAN 8,853$ PUTNAM HANNAH LANIER PARKER SULLIVAN 8,834$ JUAREZ RAYMUNDO LANIER PARKER SULLIVAN 8,772$ MARINI JOHN LANIER PARKER SULLIVAN 8,772$ MARTIN BILLY LANIER PARKER SULLIVAN 8,661$ SPIVEY HAROLD LANIER PARKER SULLIVAN 8,527$ ALBERT CLARENCE LANIER PARKER SULLIVAN 8,390$ PRIDDY CRESTON LANIER PARKER SULLIVAN 8,387$ MOORE WILLIAM LANIER PARKER SULLIVAN 8,236$ GRAVES JAMES LANIER PARKER SULLIVAN 8,207$ JONES J LANIER PARKER SULLIVAN 8,193$ CZACHOR LUCILLE LANIER PARKER SULLIVAN 8,166$ ESTERLUND WILLIAM LANIER PARKER SULLIVAN 8,129$ CLEMENTS JESSE LANIER PARKER SULLIVAN 8,044$ DAMELIO ALFRED LANIER PARKER SULLIVAN 8,010$ KINSEY WALTER LANIER PARKER SULLIVAN 8,004$ OCONNOR FRANCIS LANIER PARKER SULLIVAN 7,915$ POLLACK AUDREY LANIER PARKER SULLIVAN 7,905$ JELOSEK RONALD LANIER PARKER SULLIVAN 7,868$ BARNES IRVIN LANIER PARKER SULLIVAN 7,861$ BAGLIO MAURICE LANIER PARKER SULLIVAN 7,847$ OAKE VICTOR LANIER PARKER SULLIVAN 7,808$ DURANTE CLEMENT LANIER PARKER SULLIVAN 7,793$ DAMBRISI JOSEPH LANIER PARKER SULLIVAN 7,727$ PADALINO PAUL LANIER PARKER SULLIVAN 7,723$ FAUGHN WILLIAM LANIER PARKER SULLIVAN 7,623$ WILCOX HAROLD LANIER PARKER SULLIVAN 7,606$

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Last Name First Name Lawyer Settlement offerTUCKEY LLOYD LANIER PARKER SULLIVAN 7,579$ KEYS JACK LANIER PARKER SULLIVAN 7,573$ BROADUS JAMES LANIER PARKER SULLIVAN 7,567$ GUTSCHOW JAMES LANIER PARKER SULLIVAN 7,558$ BRENNER JAY LANIER PARKER SULLIVAN 7,554$ HATCH BELA LANIER PARKER SULLIVAN 7,552$ HATCH OAKLEY LANIER PARKER SULLIVAN 7,543$ SANDERSON LELAND LANIER PARKER SULLIVAN 7,518$ GUYETTE BERNARD LANIER PARKER SULLIVAN 7,403$ SHACKELFORD PAUL LANIER PARKER SULLIVAN 7,372$ GARNETT OSCAR LANIER PARKER SULLIVAN 7,356$ VANDRESS MICHAEL LANIER PARKER SULLIVAN 7,354$ COCHRAN ELAINE LANIER PARKER SULLIVAN 7,301$ CURTIS JAMES LANIER PARKER SULLIVAN 7,276$ BEASLEY MALCOLM LANIER PARKER SULLIVAN 7,256$ NYDEGGER PAUL LANIER PARKER SULLIVAN 7,218$ LANGER JUERGEN LANIER PARKER SULLIVAN 7,197$ HEROLD DAVID LANIER PARKER SULLIVAN 7,190$ YANNO GUY LANIER PARKER SULLIVAN 7,181$ MENKEE ALFRED LANIER PARKER SULLIVAN 7,155$ FLYNN LORETTA LANIER PARKER SULLIVAN 7,149$ SEKADLO WAYNE LANIER PARKER SULLIVAN 7,031$ BROWNE WILLIAM LANIER PARKER SULLIVAN 7,020$ PANIAGUA ELIAS LANIER PARKER SULLIVAN 7,010$ BEBEE GEORGE LANIER PARKER SULLIVAN 6,952$ MCCAFFERY WILLIAM LANIER PARKER SULLIVAN 6,804$ CATRELL NORMAN LANIER PARKER SULLIVAN 6,781$ DZIEDZIC ALEXANDER LANIER PARKER SULLIVAN 6,761$ UPCHURCH CLARENCE LANIER PARKER SULLIVAN 6,685$ ROOK ALBERT LANIER PARKER SULLIVAN 6,653$ DICKENS FRANK LANIER PARKER SULLIVAN 6,633$ SOMMER GEORGE LANIER PARKER SULLIVAN 6,613$ QUIBLE FRANK LANIER PARKER SULLIVAN 6,596$ WEBB BILL LANIER PARKER SULLIVAN 6,511$ NUISSL CARL LANIER PARKER SULLIVAN 6,471$ XARRAS FORTEOS LANIER PARKER SULLIVAN 6,346$ MARCH SEYMOUR LANIER PARKER SULLIVAN 6,218$ WALTZ THOMAS LANIER PARKER SULLIVAN 6,161$ CHERRY DELMON LANIER PARKER SULLIVAN 6,096$ PICK RAYMOND LANIER PARKER SULLIVAN 6,068$ SAUCERMAN CLYDE LANIER PARKER SULLIVAN 5,962$ MAYFIELD GLORIA LANIER PARKER SULLIVAN 5,946$ DAMICO ROCCO LANIER PARKER SULLIVAN 5,912$ LONGSTREET PHILLIP LANIER PARKER SULLIVAN 5,900$ GREEN EDWARD LANIER PARKER SULLIVAN 5,892$ HASTINGS PATRICK LANIER PARKER SULLIVAN 5,883$ SHARPE NELSON LANIER PARKER SULLIVAN 5,778$ BROWN WILLIAM LANIER PARKER SULLIVAN 5,756$ SMYSER ROBERT LANIER PARKER SULLIVAN 5,750$ TERRY HOWARD LANIER PARKER SULLIVAN 5,736$ PERKINSON BERNARD LANIER PARKER SULLIVAN 5,652$ RATLIFF SPARREL LANIER PARKER SULLIVAN 5,622$ COLBJORSEN HAROLD LANIER PARKER SULLIVAN 5,607$ SHUMSKI EVELYN LANIER PARKER SULLIVAN 5,607$ BUTLER LADD LANIER PARKER SULLIVAN 5,603$ DUHON CORBETT LANIER PARKER SULLIVAN 5,595$

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Last Name First Name Lawyer Settlement offerDELONG ESTHER LANIER PARKER SULLIVAN 5,517$ GUY ROBERT LANIER PARKER SULLIVAN 5,482$ MILLER ANN LANIER PARKER SULLIVAN 5,474$ MORTIER MAURICE LANIER PARKER SULLIVAN 5,429$ CONSTANTE RAYMOND LANIER PARKER SULLIVAN 5,409$ MULLEN BENJAMIN LANIER PARKER SULLIVAN 5,405$ SIMMONS ROSE LANIER PARKER SULLIVAN 5,341$ AZIZI NARIMAN LANIER PARKER SULLIVAN 5,287$ GRENGA CARLO LANIER PARKER SULLIVAN 5,270$ MUTSCHLER CARL LANIER PARKER SULLIVAN 5,248$ WEST JOHN LANIER PARKER SULLIVAN 5,228$ TRAUB KURT LANIER PARKER SULLIVAN 5,221$ HARRIS CHESTER LANIER PARKER SULLIVAN 5,163$ MOYER GENE LANIER PARKER SULLIVAN 5,129$ GUMPRICH ANNA LANIER PARKER SULLIVAN 5,118$ LEMAN ALBERT LANIER PARKER SULLIVAN 5,084$ UNGARO ROCCO LANIER PARKER SULLIVAN 4,983$ SELF PAUL LANIER PARKER SULLIVAN 4,958$ WHIPPLE MARVIN LANIER PARKER SULLIVAN 4,917$ GUALANDI LOUIS LANIER PARKER SULLIVAN 4,777$ DERBY RICHARD LANIER PARKER SULLIVAN 4,641$ WALLER WILLIS LANIER PARKER SULLIVAN 4,610$ JOHNSTON GEORGE LANIER PARKER SULLIVAN 4,465$ POWELL WILLIAM LANIER PARKER SULLIVAN 4,435$ PATTERSON GEORGE LANIER PARKER SULLIVAN 4,421$ MATHEWS DOLORES LANIER PARKER SULLIVAN 4,332$ WALKER LEROY LANIER PARKER SULLIVAN 4,306$ WHITE GEORGE LANIER PARKER SULLIVAN 4,291$ OUELLETTE EDWARD LANIER PARKER SULLIVAN 4,168$ DAVIS NORMAN LANIER PARKER SULLIVAN 4,116$ CROWLEY MARIE LANIER PARKER SULLIVAN 4,045$ RAMIREZ ALBERTO LANIER PARKER SULLIVAN 4,019$ HARRIS VIOLA LANIER PARKER SULLIVAN 4,003$ HICKEY PATRICK LANIER PARKER SULLIVAN 3,940$ STENSON RICHARD LANIER PARKER SULLIVAN 3,931$ GRETLER MAX LANIER PARKER SULLIVAN 3,901$ THORNE GRANT LANIER PARKER SULLIVAN 3,744$ CHRISTENSON OSCAR LANIER PARKER SULLIVAN 3,607$ WOODFIN CHRISTINE LANIER PARKER SULLIVAN 3,564$ LETHCOE RONALD LANIER PARKER SULLIVAN 3,055$ HEPBURN LAWSON LANIER PARKER SULLIVAN 2,823$ POWELL JOSEPH LANIER PARKER SULLIVAN 1,000$ DERUSSON DANIEL LANIER PARKER SULLIVAN 1,000$ TURNER DAVID LAUDIG GEORGE 31,644$ BURGET DEAN LAUDIG GEORGE 7,733$ HAYNES TERRY LAUDIG GEORGE 7,534$ KERN DONALD LAUDIG GEORGE 7,022$ WEST DONALD LAUDIG GEORGE 6,530$ WAINSCOTT HORACE LAUDIG GEORGE 5,471$ GEYMAN RAYMOND LAUDIG GEORGE 5,268$ ROSS SCOTT LAWRENCE MADEKSHO 3,535$ MCGLOTHLIN MECOM LAWRENCE MADEKSHO 3,512$ MAPLES SIMEON LEBLANC MAPLES WADDELL 26,808$ COLLINS CALDWELL LEBLANC MAPLES WADDELL 21,782$ BREAUX CLAIBORNE LEBLANC MAPLES WADDELL 9,076$ RICHOUX RONALD LEBLANC MAPLES WADDELL 8,833$

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Last Name First Name Lawyer Settlement offerGRIGSBY RAYMOND LEBLANC MAPLES WADDELL 1,000$ LOCKHART KATHERINE LEBLANC MAPLES WADDELL 1,000$ LANG JIMMY LEBLANC MAPLES WADDELL 1,000$ ROSS JAMES LEBLANC MAPLES WADDELL 1,000$ BARNES GERALD LEBLANC MAPLES WADDELL 1,000$ BUECHE JAMES LEBLANC MAPLES WADDELL 1,000$ DAVIS ALBERT LEBLANC MAPLES WADDELL 1,000$ LEWIS ALTON LEBLANC MAPLES WADDELL 1,000$ BARROIS PATRICIA LEBLANC MAPLES WADDELL 1,000$ LEBLANC CLEVELAND LEBLANC MAPLES WADDELL 1,000$ WYNN DAVID LEBLANC MAPLES WADDELL 1,000$ ODOM JIMMY LEMLE KELLEHER 47,872$ HYMEL RALPH LEMMON 19,527$ NOLAN RICHARD LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 33,139$ MOORE WILLIAM LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 25,699$ WEBB GEORGE LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 24,527$ WESTMORELAND JOSEPH LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 19,430$ OSTERKAMP DALE LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 18,550$ ULIBARRI THOMAS LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 16,989$ WALSINGHAM BONNIE LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 14,506$ DALTON TOMMY LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 9,567$ WHITE FREDERICK LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 7,904$ KISER DONALD LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 6,464$ FEENEY WILLIAM LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 4,231$ WILLIAMS ALFRED LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 1,000$ MOUNTCASTLE DAVID LEVIN PAPANTONIO THOMAS MITCHELL ECHSNER PROC 1,000$ VANDERHYDE DAVID LEVIN SIMES KAISER 165,443$ KIM YOUNG LEVIN SIMES KAISER 140,360$ CALANDE WILLIAM LEVIN SIMES KAISER 70,537$ WHITE ALLEN LEVIN SIMES KAISER 60,120$ SMITH JAMES LEVIN SIMES KAISER 57,941$ HOFFMAN TERENCE LEVIN SIMES KAISER 49,016$ RUIZ CHRISTOHPER LEVIN SIMES KAISER 44,412$ HOWES ADRIAN LEVIN SIMES KAISER 35,600$ CZECH ROBERT LEVIN SIMES KAISER 32,561$ BAKER KENNETH LEVIN SIMES KAISER 31,401$ LENT FRANK LEVIN SIMES KAISER 30,470$ CHABOT BERT LEVIN SIMES KAISER 29,964$ HIGGINS WILLIAM LEVIN SIMES KAISER 27,481$ GARDETTO JOHN LEVIN SIMES KAISER 25,638$ STILLWELL CALVIN LEVIN SIMES KAISER 24,445$ BOUCHER JANET LEVIN SIMES KAISER 23,626$ MENDOZA FREDDIE LEVIN SIMES KAISER 22,388$ ROWLISON RICHARD LEVIN SIMES KAISER 22,121$ CAMACHO HELEN LEVIN SIMES KAISER 22,039$ SASSOUNIAN HAROUTIOUN LEVIN SIMES KAISER 21,254$ BRUNO MICHAEL LEVIN SIMES KAISER 20,339$ WOOD ROGER LEVIN SIMES KAISER 19,403$ RADEBAUGH JACQUELINE LEVIN SIMES KAISER 17,954$ CARPENTER CRAIG LEVIN SIMES KAISER 16,676$ STAYTON EDWARD LEVIN SIMES KAISER 16,617$ RICE WILLIAM LEVIN SIMES KAISER 15,550$ CONTRERAS LOUIS LEVIN SIMES KAISER 14,329$ SAMORA LOYD LEVIN SIMES KAISER 14,157$ BAICHTAL RONNY LEVIN SIMES KAISER 13,500$ KIRCHMANN ROBERT LEVIN SIMES KAISER 13,389$

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Last Name First Name Lawyer Settlement offerQUINTINO LEOPOLD LEVIN SIMES KAISER 12,963$ HENDRICKS GILBERT LEVIN SIMES KAISER 12,928$ LONGSTREET NORMAN LEVIN SIMES KAISER 11,622$ WEINER DARRYL LEVIN SIMES KAISER 10,839$ HOLT LEE LEVIN SIMES KAISER 10,484$ LARSEN HARRY LEVIN SIMES KAISER 10,264$ ENGLISH MICHAEL LEVIN SIMES KAISER 10,026$ LOPEZ HENRY LEVIN SIMES KAISER 9,970$ KLEVE HAROLD LEVIN SIMES KAISER 9,754$ BALLERT MILDRED LEVIN SIMES KAISER 9,574$ HENRY LEWELLYN LEVIN SIMES KAISER 9,220$ WALDEN EDWARD LEVIN SIMES KAISER 9,115$ MCCUIN LANDON LEVIN SIMES KAISER 9,013$ WILLIAMS DUDLEY LEVIN SIMES KAISER 8,815$ HERNANDEZ ROBERT LEVIN SIMES KAISER 8,246$ BROWN HAROLD LEVIN SIMES KAISER 7,651$ GOODENBOUR JOHN LEVIN SIMES KAISER 7,520$ DARROW PETER LEVIN SIMES KAISER 7,518$ CAMPBELL CLAUDE LEVIN SIMES KAISER 7,220$ HOVER JOHN LEVIN SIMES KAISER 7,216$ COCHRAN JOHN LEVIN SIMES KAISER 6,936$ MONTGOMERY ROBERT LEVIN SIMES KAISER 6,931$ BARANCO ALVINA LEVIN SIMES KAISER 6,888$ VALDEZ EMILIO LEVIN SIMES KAISER 6,859$ CLARK ETHEL LEVIN SIMES KAISER 6,755$ NABORS BUFORD LEVIN SIMES KAISER 6,637$ REENTS HOWARD LEVIN SIMES KAISER 6,353$ PEASLEE PAUL LEVIN SIMES KAISER 6,327$ FERNANDEZ FRANK LEVIN SIMES KAISER 6,001$ PRESTON HOMER LEVIN SIMES KAISER 5,890$ INCE ALICE LEVIN SIMES KAISER 5,758$ HEWITT ROBERT LEVIN SIMES KAISER 5,678$ DORNER WILLIAM LEVIN SIMES KAISER 5,557$ BORGESE NUNZIO LEVIN SIMES KAISER 5,496$ PRYOR DAVID LEVIN SIMES KAISER 5,386$ WHITMAN LOVELL LEVIN SIMES KAISER 5,374$ LUNA TROY LEVIN SIMES KAISER 5,096$ SMITH JAMES LEVIN SIMES KAISER 4,964$ WILLOUGHBY PAUL LEVIN SIMES KAISER 4,544$ WARREN FREDA LEVIN SIMES KAISER 4,237$ GUTHRIE JR LEVIN SIMES KAISER 4,022$ MCCOY WILLIE LEVIN SIMES KAISER 3,911$ HATLAN VASILY LEVIN SIMES KAISER 3,609$ BARRERA ALBERTO LEVIN SIMES KAISER 3,312$ HERNANDEZ PAUL LEVIN SIMES KAISER 2,261$ ANDERSON OTIS LEVIN SIMES KAISER 1,855$ KRYSINSKI THEODORE LEVIN SIMES KAISER 1,000$ HARRIS ROBERT LEVIN SIMES KAISER 1,000$ MUSLADIN SCOTT LEVIN SIMES KAISER 1,000$ HOEFER LAWRENCE LEVY PHILLIPS 115,717$ BARTLETT HARRY LEVY PHILLIPS 115,288$ FELL DAVID LEVY PHILLIPS 80,784$ DADDIO LOUIS LEVY PHILLIPS 74,946$ DONN ALAN LEVY PHILLIPS 73,131$ PENCE JACKIE LEVY PHILLIPS 69,371$ DECUIR ROLAND LEVY PHILLIPS 54,510$

41




Last Name First Name Lawyer Settlement offerKELLY DAVID LEVY PHILLIPS 54,491$ HARRIETT WILLIAM LEVY PHILLIPS 42,485$ HART ROBERT LEVY PHILLIPS 35,526$ LELL ROBERT LEVY PHILLIPS 35,506$ CORK JEAN LEVY PHILLIPS 30,138$ BIGLEY DONALD LEVY PHILLIPS 23,563$ WAGNER RHODA LEVY PHILLIPS 23,085$ BUNN JAMES LEVY PHILLIPS 22,047$ MORRIS LAWRENCE LEVY PHILLIPS 20,770$ BROWNING SIDNEY LEVY PHILLIPS 18,369$ MELENDEZ JOHN LEVY PHILLIPS 17,954$ SEITZ FREDERICK LEVY PHILLIPS 17,435$ NAPOTNIK JACOB LEVY PHILLIPS 17,244$ MEYERS EDWARD LEVY PHILLIPS 16,712$ CURRY MICHAEL LEVY PHILLIPS 16,530$ MCKENZIE DIANE LEVY PHILLIPS 16,345$ BRUCE DONALD LEVY PHILLIPS 15,715$ MUELLER HAROLD LEVY PHILLIPS 15,236$ HARLEY CLAUDE LEVY PHILLIPS 14,358$ ELLIS GRACE LEVY PHILLIPS 14,037$ LANE HARVEY LEVY PHILLIPS 13,276$ CALDWELL LLOYD LEVY PHILLIPS 13,166$ JONES LARRY LEVY PHILLIPS 11,987$ KNAPP ROLAND LEVY PHILLIPS 11,098$ MELLACE JOSEPHINE LEVY PHILLIPS 10,843$ GROVES BERNARD LEVY PHILLIPS 10,768$ SCARDINO XAVIER LEVY PHILLIPS 10,632$ GULL SAM LEVY PHILLIPS 10,430$ JONES KENNETH LEVY PHILLIPS 10,164$ ADLER STANLEY LEVY PHILLIPS 9,922$ GREENE DONALD LEVY PHILLIPS 9,868$ TRAVIS FRANCIS LEVY PHILLIPS 9,584$ AGANA ALFREDO LEVY PHILLIPS 9,568$ SANTIAGO GILBERTO LEVY PHILLIPS 9,555$ PARKER ODELL LEVY PHILLIPS 8,643$ UKENS KENNETH LEVY PHILLIPS 8,597$ NAGEL JAMES LEVY PHILLIPS 8,333$ GILDE MAURICE LEVY PHILLIPS 8,323$ MATUSKA JOSEPH LEVY PHILLIPS 8,263$ SANTINI ANTHONY LEVY PHILLIPS 8,201$ WEBSTER BILLIE LEVY PHILLIPS 8,023$ LASALLE JOHN LEVY PHILLIPS 7,844$ TREFURT CHARLES LEVY PHILLIPS 7,757$ SAPP LEWIS LEVY PHILLIPS 7,354$ STILLWAGON FRANCIS LEVY PHILLIPS 7,305$ NELSON VANROBERT LEVY PHILLIPS 7,132$ MCCARTHY EDWARD LEVY PHILLIPS 6,947$ JOCKERS DONALD LEVY PHILLIPS 6,939$ GIBBONS ROBERT LEVY PHILLIPS 6,429$ HAYES JOSEPH LEVY PHILLIPS 6,184$ MOLLOY EVELYN LEVY PHILLIPS 5,957$ KERN EDWARD LEVY PHILLIPS 5,921$ FALCONE JOHN LEVY PHILLIPS 5,887$ COSTON HERBERT LEVY PHILLIPS 5,733$ HOCHBERG BERNARD LEVY PHILLIPS 5,561$ GRAHAM GEORGE LEVY PHILLIPS 5,321$

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Last Name First Name Lawyer Settlement offerJOHNSON WILLIAM LEVY PHILLIPS 5,290$ ROLLOCK DONALD LEVY PHILLIPS 4,849$ GOODMAN IRWIN LEVY PHILLIPS 4,785$ RICKERT FREDERICK LEVY PHILLIPS 4,479$ LOZO DONALD LEVY PHILLIPS 4,224$ EDEN ROY LEVY PHILLIPS 3,969$ EBS WILLIAM LEVY PHILLIPS 3,908$ SMITH JAMES LEVY PHILLIPS 3,888$ HOWELL HARRY LEVY PHILLIPS 3,007$ MINKEMA MILTON LEVY PHILLIPS 2,970$ FREY GENE LEVY PHILLIPS 2,855$ ROCKMAKER GORDON LEVY PHILLIPS 2,320$ EICHEN GEORGE LEVY PHILLIPS 2,318$ LOBAITO BENNIE LEVY PHILLIPS 1,986$ DARMOFAL GENEVIEVE LEVY PHILLIPS 1,650$ DECARO MICHAEL LEVY PHILLIPS 1,000$ OAKLEY SPENCER LEVY PHILLIPS 1,000$ FRANKLIN WILLIAM LEVY PHILLIPS 1,000$ RESKER JOHN LEVY PHILLIPS 1,000$ LUDWIG HARRY LEWIS DAVIDSON HETHERINGTON 5,752$ QUARLES FLOYD LIPSITZ GREEN 7,953$ GINTER JAMES LIPSITZ PONTERIO 29,652$ REALS RUSSELL LIPSITZ PONTERIO 17,262$ WATSON GERALD LIPSITZ PONTERIO 14,452$ SKINDELL JAMES LIPSITZ PONTERIO 13,958$ YOHE WILLIAM LIPSITZ PONTERIO 9,200$ MILLER ROBERT LIPSITZ PONTERIO 6,823$ JOHNSON WARD LIPSITZ PONTERIO 5,243$ LOMBARDI VINCENT LIPSITZ PONTERIO 4,616$ SCIASCIA DINO LIPSITZ PONTERIO 4,163$ STORM ROGER LIPSITZ PONTERIO 2,217$ COPPOLA RICHARD LIPSITZ PONTERIO 1,000$ SUPANEK HAROLD LIPSITZ PONTERIO 1,000$ RANDAZZO SAMUEL LIPSITZ PONTERIO 1,000$ FERRERAS RONNIE LUJAN UNPINGCO AGUIGUI PEREZ 1,000$ OLMO CESS LUJAN UNPINGCO AGUIGUI PEREZ 1,000$ GARY DOROTHY LUNDY DAVIS 1,000$ HANSEN MICHAEL LYONS RANTA 2,717$ GUTIERREZ AGUSTIN MANDELBROT 97,160$ COLOMBO GASTONE MANLEY BURKE LIPTON COOK 4,250$ THOMAS ODESTER MARTZELL BICKFORD 97,754$ STERLING ALBERT MARTZELL BICKFORD 30,161$ TRASCHER JOSEPH MARTZELL BICKFORD 20,420$ ROYAL DONALD MARTZELL BICKFORD 12,877$ HAMPTON LOFETTE MARTZELL BICKFORD 10,540$ BENOIT BRANDON MARTZELL BICKFORD 2,584$ MARCEL HENRY MARTZELL BICKFORD 1,606$ RHODES JOSEPH MARTZELL BICKFORD 1,179$ BODINE JOSEPH MARTZELL BICKFORD 1,000$ DOWNS JUNIOR MARTZELL BICKFORD 1,000$ TUNDER GEORGE MASTERS SIVINSKI 6,531$ FORTESQUE DENNIS MASTERS SIVINSKI 3,488$ SULLIVAN JAMES MASTERS SIVINSKI 1,000$ KIGHTLINGER ROSE MATTHEW THEIL 1,000$ HASKE RAYMOND MAUNE RAICHLE HARTLEY FRENCH MUDD 96,332$ ROBINETTE WALTER MAUNE RAICHLE HARTLEY FRENCH MUDD 23,821$

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Last Name First Name Lawyer Settlement offerGLEIN BETTY MAUNE RAICHLE HARTLEY FRENCH MUDD 20,713$ ALBRIGHT CHESTER MAUNE RAICHLE HARTLEY FRENCH MUDD 13,967$ CLARK THOMAS MAUNE RAICHLE HARTLEY FRENCH MUDD 12,558$ BUNDY EDWARD MAUNE RAICHLE HARTLEY FRENCH MUDD 11,551$ HARRIS JUDITH MAUNE RAICHLE HARTLEY FRENCH MUDD 11,060$ HULTGREN ROY MAUNE RAICHLE HARTLEY FRENCH MUDD 9,771$ MILLER JOHN MAUNE RAICHLE HARTLEY FRENCH MUDD 7,515$ SHRAMEK ROBERT MAUNE RAICHLE HARTLEY FRENCH MUDD 6,384$ CEPLINA ALOIS MAUNE RAICHLE HARTLEY FRENCH MUDD 5,962$ KOWCHECK REGIS MAUNE RAICHLE HARTLEY FRENCH MUDD 3,050$ MILLER EMMA MAZUR KITTEL 70,323$ WINDHAM LONNIE MAZUR KITTEL 62,760$ VANWYNEN ROBERT MAZUR KITTEL 58,978$ TANK BURTON MAZUR KITTEL 41,398$ HOLLISTER JOHN MAZUR KITTEL 36,407$ CASTRONOVA RALPH MAZUR KITTEL 35,828$ MCNEW GROVER MAZUR KITTEL 35,630$ THOMPSON FRANK MAZUR KITTEL 27,835$ JONES ALVARETTA MAZUR KITTEL 21,877$ JACKSON CLIFFORD MAZUR KITTEL 20,680$ MILLS WAYNE MAZUR KITTEL 18,491$ UEBERROTH WILLIAM MAZUR KITTEL 18,164$ CAPUANO ROBERT MAZUR KITTEL 14,930$ LAMOREAUX JAMES MAZUR KITTEL 13,917$ RAE JAMES MAZUR KITTEL 13,007$ SELF LOIS MAZUR KITTEL 12,877$ HICKS MARY MAZUR KITTEL 9,923$ LABAERE HENRY MAZUR KITTEL 9,583$ WOZNIAK NANCY MAZUR KITTEL 9,543$ ENTZI MARY MAZUR KITTEL 9,458$ LITTLETON WILMA MAZUR KITTEL 8,906$ HART PAUL MAZUR KITTEL 8,820$ VENDITTI ANTHONY MAZUR KITTEL 8,651$ PRESTON ROBERT MAZUR KITTEL 8,177$ ADOLINE HAROLD MAZUR KITTEL 8,176$ FERRETTI FRANK MAZUR KITTEL 8,111$ HILL HAROLD MAZUR KITTEL 7,217$ PADALINO ANTHONY MAZUR KITTEL 7,128$ BERGMAN DELORES MAZUR KITTEL 6,875$ DUIGNAN PATRICK MAZUR KITTEL 6,753$ KOLENKO AMALIA MAZUR KITTEL 6,468$ SIGLER DON MAZUR KITTEL 6,112$ ALLRED PAULINE MAZUR KITTEL 5,958$ GEPFERT BONNIE MAZUR KITTEL 5,741$ BENNETT HENRY MAZUR KITTEL 5,549$ MOSLEY AL MAZUR KITTEL 5,306$ SMETANKA CATHERINE MAZUR KITTEL 5,203$ KOSKI MARION MAZUR KITTEL 5,040$ BRAY CHARLES MAZUR KITTEL 4,576$ ROGERS EDWARD MAZUR KITTEL 4,322$ WHITE VIRGIL MAZUR KITTEL 3,760$ HYDUKE ANDREW MAZUR KITTEL 3,196$ PADDEN THOMAS MAZUR KITTEL 3,065$ LEMUEL CLIFFORD MAZUR KITTEL 2,853$ STROBA PATRICIA MAZUR KITTEL 2,510$ JETT THERESA MAZUR KITTEL 2,335$

44




Last Name First Name Lawyer Settlement offerSWEITZER DALE MCCLURE MCCLURE DAVIS 1,000$ BROKELMEIER ROBERT MCCLURE MCCLURE DAVIS 1,000$ MERCSAK ROBERT MCDERMOTT CLAWSON 1,000$ BRADLEY JACK MCDERMOTT CLAWSON 1,000$ MCKEITHEN MILLARD MCKAY 1,000$ CROWLEY JAMES MCTEAGUE HIGBEE 113,386$ RICHARD EMILE MCTEAGUE HIGBEE 67,996$ HULL ROBERT MCTEAGUE HIGBEE 4,011$ BOATWRIGHT DUANE MICHAEL BILBREY 8,118$ HORNBERGER GLENN MICHAEL BILBREY 5,140$ SOTO PUBLIO MICHAEL BILBREY 4,246$ VICKROY LLOYD MICHAEL BILBREY 2,633$ HOFFMAN FAYE MICHAEL BILBREY 1,000$ KUNSELMAN CAROLE MICHAEL BILBREY 1,000$ HONEYCUTT THOMAS MICHAEL BILBREY 1,000$ HOLLOWAY JAMES MICHAEL BILBREY 1,000$ BARNES WILLIAM MICHAEL BILBREY 1,000$ SIMMONS MYRON MICHAEL BILBREY 1,000$ JOPPA DOLORES MICHAEL BILBREY 1,000$ PRATT WILLIAM MICHAEL BILBREY 1,000$ SWANSON KENNETH MICHAEL BILBREY 1,000$ SCHOENFELDT RONALD MICHAEL BILBREY 1,000$ SEWARD ROBIN MICHAEL BILBREY 1,000$ VANAKION LEONARD MICHAEL SERLING 29,306$ MONAGHAN MARSHA MICHAEL SERLING 17,954$ CHAFFEE LYMAN MICHAEL SERLING 3,454$ MURPHY FRANCIS MICHAEL SERLING 1,000$ CARTER DREWRY MICHIE HAMLETT 112,335$ HARTSTORN BRENDA MICHIE HAMLETT 91,181$ JONES JIMMIE MICHIE HAMLETT 80,848$ MILLER HELEN MICHIE HAMLETT 62,233$ GIBBS KENNETH MICHIE HAMLETT 24,906$ CHANDLER ALDEN MICHIE HAMLETT 17,653$ WITCHER SARAH MICHIE HAMLETT 14,920$ MARSHALL BRYAN MICHIE HAMLETT 8,772$ MILTIER DOROTHY MICHIE HAMLETT 8,162$ LINK RUBY MICHIE HAMLETT 6,837$ DOWDY BERNARD MICHIE HAMLETT 6,314$ MARCUS HENRY MICHIE HAMLETT 4,863$ LARSEN DOROTHY MICHIE HAMLETT 2,300$ BERRY FRED MICHIE HAMLETT 1,000$ WOLF LYNN MICHIE HAMLETT 1,000$ VEST ELLIS MICHIE HAMLETT 1,000$ EDWARDS DOROTHY MICHIE HAMLETT 1,000$ NEWCORN HARRY MIDDLETON MATHIS ADAMS TATE 1,000$ BATTEIGER WARREN MILLER MOSELEY CLARE TOWNES 1,000$ LAPARL WILLIAM MILLER STILLMAN BARTEL 1,000$ LESIAK TED MILLER STILLMAN BARTEL 1,000$ LANDESS GEORGE MOORE THOMPSON THOMAS PAPILLION CULLENS 1,000$ BROWN RAYMOND MORGAN MORGAN 67,441$ SCHULTZ PAUL MORGAN MORGAN 1,000$ CORDES GEORGE MUMPHREY 30,905$ ROBINSON JOHN MUNDY SINGLEY 35,191$ NAQUIN HUEY MURRAY STEPHEN 1,000$ WILLIAMS DAVID MURRAY STEPHEN 1,000$ HINOJOSA JUAN NAPOLI BERN RIPKA SHKOLNICK 10,656$

45




Last Name First Name Lawyer Settlement offerMETZGER GLENN NAPOLI BERN RIPKA SHKOLNICK 3,240$ JOHNSON JONI NESS MOTLEY / MOTLEY RICE 140,360$ OVERMAN HARVEY NESS MOTLEY / MOTLEY RICE 140,360$ WEIR ROBERT NESS MOTLEY / MOTLEY RICE 137,416$ RAYNOR ROBERT NESS MOTLEY / MOTLEY RICE 119,474$ ROUNTREE RONALD NESS MOTLEY / MOTLEY RICE 108,747$ ANDREOLI BENITO NESS MOTLEY / MOTLEY RICE 102,834$ WILLIAMS ROBERT NESS MOTLEY / MOTLEY RICE 98,182$ BERGMANN ABRAM NESS MOTLEY / MOTLEY RICE 95,808$ MANNIX MICHAEL NESS MOTLEY / MOTLEY RICE 81,654$ TREWHELLA GARY NESS MOTLEY / MOTLEY RICE 81,555$ TRIMBLE EMBRY NESS MOTLEY / MOTLEY RICE 79,320$ GARCIA AMBROSIA NESS MOTLEY / MOTLEY RICE 72,668$ DEPRIEST DONALD NESS MOTLEY / MOTLEY RICE 67,397$ MARKLE ARTHUR NESS MOTLEY / MOTLEY RICE 65,316$ SYDNOR MARVIN NESS MOTLEY / MOTLEY RICE 61,747$ WALKER MARVIN NESS MOTLEY / MOTLEY RICE 60,494$ BONDI PRIMO NESS MOTLEY / MOTLEY RICE 53,089$ SMITH WILLIAM NESS MOTLEY / MOTLEY RICE 52,028$ AKERS JOHN NESS MOTLEY / MOTLEY RICE 48,020$ HARTLEY KIRK NESS MOTLEY / MOTLEY RICE 47,353$ HENDERSON GERALD NESS MOTLEY / MOTLEY RICE 47,276$ CULLIGAN WALTER NESS MOTLEY / MOTLEY RICE 46,582$ BOIVIN REVAL NESS MOTLEY / MOTLEY RICE 45,442$ OXLEY CHARLES NESS MOTLEY / MOTLEY RICE 42,689$ LESKO MICHAEL NESS MOTLEY / MOTLEY RICE 39,228$ WELCH JACK NESS MOTLEY / MOTLEY RICE 36,575$ DOUCETTE GERALD NESS MOTLEY / MOTLEY RICE 36,475$ EASTON ROBERT NESS MOTLEY / MOTLEY RICE 34,346$ JOHNSON RUSSELL NESS MOTLEY / MOTLEY RICE 33,149$ WILSON GORDON NESS MOTLEY / MOTLEY RICE 32,391$ KORCHI BRICK NESS MOTLEY / MOTLEY RICE 30,905$ ROBERTS RALPH NESS MOTLEY / MOTLEY RICE 28,970$ ESTES GRADY NESS MOTLEY / MOTLEY RICE 27,338$ KUSZ GERALD NESS MOTLEY / MOTLEY RICE 26,280$ NELSON WILLIAM NESS MOTLEY / MOTLEY RICE 25,539$ PARNELL THOMAS NESS MOTLEY / MOTLEY RICE 24,361$ POLK THOMAS NESS MOTLEY / MOTLEY RICE 22,753$ HOOKS MARSHALL NESS MOTLEY / MOTLEY RICE 22,147$ LUIKEN NICHOLAS NESS MOTLEY / MOTLEY RICE 21,556$ PAUL HUBERT NESS MOTLEY / MOTLEY RICE 20,812$ STOCKER ELEANORE NESS MOTLEY / MOTLEY RICE 20,769$ BAKER LEON NESS MOTLEY / MOTLEY RICE 19,973$ ZAIN BETTY NESS MOTLEY / MOTLEY RICE 19,804$ ADAMS BRUCE NESS MOTLEY / MOTLEY RICE 19,694$ ACREE JAMES NESS MOTLEY / MOTLEY RICE 19,273$ GOODWIN BILLY NESS MOTLEY / MOTLEY RICE 18,287$ SIDDALL ALLAN NESS MOTLEY / MOTLEY RICE 18,159$ MCCLINTOCK WILLIAM NESS MOTLEY / MOTLEY RICE 18,109$ HARRIS RALPH NESS MOTLEY / MOTLEY RICE 17,776$ WHITMIRE JOHNNY NESS MOTLEY / MOTLEY RICE 17,758$ REYNOLDS MARCIA NESS MOTLEY / MOTLEY RICE 17,177$ SMITH ARTHUR NESS MOTLEY / MOTLEY RICE 17,140$ HOWARD HAYWARD NESS MOTLEY / MOTLEY RICE 17,120$ STREIB MARK NESS MOTLEY / MOTLEY RICE 17,055$ LOVEJOY ETHEL NESS MOTLEY / MOTLEY RICE 16,834$

46




Last Name First Name Lawyer Settlement offerTETZ ANDREW NESS MOTLEY / MOTLEY RICE 16,349$ BOWERS VERNON NESS MOTLEY / MOTLEY RICE 16,002$ HAIZLIP JUDSON NESS MOTLEY / MOTLEY RICE 15,908$ WARD STEVEN NESS MOTLEY / MOTLEY RICE 15,908$ MCSWAIN JACQUE NESS MOTLEY / MOTLEY RICE 15,322$ SHERER ROBERT NESS MOTLEY / MOTLEY RICE 14,639$ HENSLEY JEROME NESS MOTLEY / MOTLEY RICE 14,294$ HAMMOND DEBORAH NESS MOTLEY / MOTLEY RICE 13,811$ DION ROBERT NESS MOTLEY / MOTLEY RICE 13,720$ BRADSHAW JAKE NESS MOTLEY / MOTLEY RICE 13,673$ GREENWOOD JESSE NESS MOTLEY / MOTLEY RICE 13,464$ SHORT RUTH NESS MOTLEY / MOTLEY RICE 13,462$ JOHNSON KENNETH NESS MOTLEY / MOTLEY RICE 13,185$ MATTIE ALVIN NESS MOTLEY / MOTLEY RICE 13,185$ HAWKINS LONNIE NESS MOTLEY / MOTLEY RICE 13,101$ MCKINNON JOHN NESS MOTLEY / MOTLEY RICE 12,573$ JONES MICHAEL NESS MOTLEY / MOTLEY RICE 12,078$ RUTKOWSKI JOHN NESS MOTLEY / MOTLEY RICE 11,844$ BEEBE GLEN NESS MOTLEY / MOTLEY RICE 11,460$ MATHER PHILIP NESS MOTLEY / MOTLEY RICE 11,289$ TUGGLE WILLIAM NESS MOTLEY / MOTLEY RICE 11,259$ JOHNSTON DEBORAH NESS MOTLEY / MOTLEY RICE 11,121$ CRAWFORD CEBERT NESS MOTLEY / MOTLEY RICE 11,067$ MOSIER JOHN NESS MOTLEY / MOTLEY RICE 11,062$ HUNT GEORGE NESS MOTLEY / MOTLEY RICE 10,884$ BABLE PAUL NESS MOTLEY / MOTLEY RICE 10,801$ KELSEY DONALD NESS MOTLEY / MOTLEY RICE 10,641$ RODGERS HOMER NESS MOTLEY / MOTLEY RICE 10,587$ RUSSIAN BERNARD NESS MOTLEY / MOTLEY RICE 10,578$ CARTON STEPHEN NESS MOTLEY / MOTLEY RICE 10,500$ WELCH DONALD NESS MOTLEY / MOTLEY RICE 10,444$ MCCULLOUGH OLIN NESS MOTLEY / MOTLEY RICE 9,810$ FLOKSTRA HILBERT NESS MOTLEY / MOTLEY RICE 9,791$ LOUDERMILK FRED NESS MOTLEY / MOTLEY RICE 9,454$ KITCHEN GLEN NESS MOTLEY / MOTLEY RICE 8,935$ EAKER JOSEPH NESS MOTLEY / MOTLEY RICE 8,832$ REID DONALD NESS MOTLEY / MOTLEY RICE 8,156$ JANDREAU JOSEPH NESS MOTLEY / MOTLEY RICE 8,057$ LOVE WILLIAM NESS MOTLEY / MOTLEY RICE 7,870$ WILLIAMS ROBERT NESS MOTLEY / MOTLEY RICE 7,687$ JORDAN RAYMOND NESS MOTLEY / MOTLEY RICE 7,542$ KEAL RICHARD NESS MOTLEY / MOTLEY RICE 7,496$ MORPHY VICTOR NESS MOTLEY / MOTLEY RICE 7,465$ WIEBE JACOB NESS MOTLEY / MOTLEY RICE 7,253$ FELL KEITH NESS MOTLEY / MOTLEY RICE 7,167$ PHILLIPS WYMAN NESS MOTLEY / MOTLEY RICE 7,090$ YOUNG WILLIAM NESS MOTLEY / MOTLEY RICE 7,064$ MAHOVLIC JOHN NESS MOTLEY / MOTLEY RICE 7,045$ HALL FRED NESS MOTLEY / MOTLEY RICE 6,804$ COSTELLO JOHN NESS MOTLEY / MOTLEY RICE 6,746$ ROGERS CLINTON NESS MOTLEY / MOTLEY RICE 6,688$ LAWSON KENNETH NESS MOTLEY / MOTLEY RICE 6,643$ HOUSE DONALD NESS MOTLEY / MOTLEY RICE 6,571$ PRUDEN ALLAN NESS MOTLEY / MOTLEY RICE 6,287$ TROUP GLENN NESS MOTLEY / MOTLEY RICE 6,161$ TANT PHYLLIS NESS MOTLEY / MOTLEY RICE 6,136$

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Last Name First Name Lawyer Settlement offerSHEALY ROBERT NESS MOTLEY / MOTLEY RICE 5,938$ KING EARL NESS MOTLEY / MOTLEY RICE 5,873$ SONNENBERG LEANDE NESS MOTLEY / MOTLEY RICE 5,799$ FAULKNER DOUGLAS NESS MOTLEY / MOTLEY RICE 5,625$ TREADWAY ARNOLD NESS MOTLEY / MOTLEY RICE 5,612$ PRICE BRIAN NESS MOTLEY / MOTLEY RICE 5,588$ HICKS DONALD NESS MOTLEY / MOTLEY RICE 5,534$ GUZOWSKI WALTER NESS MOTLEY / MOTLEY RICE 5,352$ LIVINGSTON GEORGE NESS MOTLEY / MOTLEY RICE 5,042$ MOUNT HENRY NESS MOTLEY / MOTLEY RICE 4,926$ KAUTZ DALE NESS MOTLEY / MOTLEY RICE 4,876$ CROSS EDWARD NESS MOTLEY / MOTLEY RICE 4,829$ JENSEN ROBERT NESS MOTLEY / MOTLEY RICE 4,694$ SNELLINGS CHARLES NESS MOTLEY / MOTLEY RICE 4,615$ SMITH RAYMOND NESS MOTLEY / MOTLEY RICE 4,538$ ANDERSON GRANT NESS MOTLEY / MOTLEY RICE 4,404$ LUND MAURICE NESS MOTLEY / MOTLEY RICE 4,360$ COLLINS BETTY NESS MOTLEY / MOTLEY RICE 4,237$ MISHOE GEORGE NESS MOTLEY / MOTLEY RICE 4,177$ HERN BEULAH NESS MOTLEY / MOTLEY RICE 4,115$ LARSON ALF NESS MOTLEY / MOTLEY RICE 3,904$ MIDDLETON MARGUERITE NESS MOTLEY / MOTLEY RICE 3,789$ NIELSEN INGEMANN NESS MOTLEY / MOTLEY RICE 3,535$ MEEKS JAMES NESS MOTLEY / MOTLEY RICE 3,459$ ZESS ROGER NESS MOTLEY / MOTLEY RICE 3,419$ DYAL HENRY NESS MOTLEY / MOTLEY RICE 3,334$ EMES FRANK NESS MOTLEY / MOTLEY RICE 3,222$ WEISSENBORN FRANK NESS MOTLEY / MOTLEY RICE 3,085$ JASINSKAS KAZYS NESS MOTLEY / MOTLEY RICE 3,081$ MYERS JOSEPH NESS MOTLEY / MOTLEY RICE 3,015$ RICHARDSON WILLIAM NESS MOTLEY / MOTLEY RICE 2,686$ STERZIK PAUL NESS MOTLEY / MOTLEY RICE 2,645$ PEELER SHIRLEY NESS MOTLEY / MOTLEY RICE 2,626$ CONSOLE ALDO NESS MOTLEY / MOTLEY RICE 2,542$ FUGATE JOHN NESS MOTLEY / MOTLEY RICE 2,309$ LANGDON ROY NESS MOTLEY / MOTLEY RICE 2,231$ GARDNER JOHN NESS MOTLEY / MOTLEY RICE 2,095$ COBURN JACK NESS MOTLEY / MOTLEY RICE 2,072$ CORTAN MILAN NESS MOTLEY / MOTLEY RICE 1,261$ BOUCHER CHARLES NESS MOTLEY / MOTLEY RICE 1,255$ GODDARD DAVID NESS MOTLEY / MOTLEY RICE 1,000$ PITTMAN ROBERT NESS MOTLEY / MOTLEY RICE 1,000$ PARKES TREVOR NESS MOTLEY / MOTLEY RICE 1,000$ HOGARTH JOHN NESS MOTLEY / MOTLEY RICE 1,000$ HAMRICK NATHAN NESS MOTLEY / MOTLEY RICE 1,000$ JELLES JOHN NESS MOTLEY / MOTLEY RICE 1,000$ GANE LOUELL NESS MOTLEY / MOTLEY RICE 1,000$ DOYLE STEPHEN NESS MOTLEY / MOTLEY RICE 1,000$ ADAMS LOWELL NESS MOTLEY / MOTLEY RICE 1,000$ HENNINGS WILLIAM NESS MOTLEY / MOTLEY RICE 1,000$ SING GEORGE NESS MOTLEY / MOTLEY RICE 1,000$ SHERMAN DOUGLAS NESS MOTLEY / MOTLEY RICE 1,000$ WELCH JOHN NESS MOTLEY / MOTLEY RICE 1,000$ REED URSULA NESS MOTLEY / MOTLEY RICE 1,000$ RIMER ERNEST NESS MOTLEY / MOTLEY RICE 1,000$ PLEVA JOHN NICHOLAS VOGELZANG 1,000$

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Last Name First Name Lawyer Settlement offerVIZGIRDA PETER NICHOLAS VOGELZANG 1,000$ ANDERSON GERALD NICHOLAS VOGELZANG 1,000$ ZACH FRANCIS NICHOLAS VOGELZANG 1,000$ PAUS JOSEPH NICHOLAS VOGELZANG 1,000$ HILL LOIS NICHOLAS VOGELZANG 1,000$ HELLER AUREL NICHOLAS VOGELZANG 1,000$ PAULAUSKY GEORGE NICHOLAS VOGELZANG 1,000$ ORTEN JERRY NIX PATTERSON 26,321$ HUNT CLIFFORD NIX PATTERSON 11,038$ COOPER ALTON NIX PATTERSON 6,528$ WISE OLIN NIX PATTERSON 5,925$ BENOIST MARY OBRIEN ANDREW 170,029$ DINNEEN JAMES OBRIEN ANDREW 119,102$ DARROUGH CHARLES OBRIEN ANDREW 113,625$ OLDHAM EMMA OBRIEN ANDREW 68,889$ LAXTON LARRY OBRIEN ANDREW 65,406$ WHITMAN ROBERT OBRIEN ANDREW 63,210$ THEISEN PAUL OBRIEN ANDREW 62,139$ PATE C OBRIEN ANDREW 61,365$ CUNNINGHAM PATRICIA OBRIEN ANDREW 57,626$ COREY MICHAEL OBRIEN ANDREW 40,486$ WATTS VIRGIL OBRIEN ANDREW 34,645$ SMITH WAYNE OBRIEN ANDREW 31,807$ PARKS PAUL OBRIEN ANDREW 29,455$ KENDZORA JANE OBRIEN ANDREW 24,220$ RILEY JUANITA OBRIEN ANDREW 22,700$ WHITTIER JENNIFER OBRIEN ANDREW 22,525$ QUICK KAREN OBRIEN ANDREW 21,480$ CHILDRESS CHARLES OBRIEN ANDREW 21,348$ PIERSON DELBERT OBRIEN ANDREW 17,591$ LAMB RICHARD OBRIEN ANDREW 17,366$ BUSSARD NORMAN OBRIEN ANDREW 16,844$ EDGAR NORMAN OBRIEN ANDREW 16,313$ JANISSE DENIS OBRIEN ANDREW 15,416$ FANDL JOHN OBRIEN ANDREW 15,312$ LAPPIN JOHN OBRIEN ANDREW 14,944$ CORRELL VIRGIL OBRIEN ANDREW 14,686$ ELLIS VIOLA OBRIEN ANDREW 14,651$ HAM WILLIAM OBRIEN ANDREW 13,534$ TURNER PAUL OBRIEN ANDREW 12,581$ COOPER CALVIN OBRIEN ANDREW 11,809$ THOMAS CLAUD OBRIEN ANDREW 11,570$ NELSON VICTOR OBRIEN ANDREW 11,181$ STEELE JOHN OBRIEN ANDREW 10,772$ MEYER WILLIAM OBRIEN ANDREW 10,389$ SULLIVAN KARON OBRIEN ANDREW 10,224$ WARD LAURA OBRIEN ANDREW 10,188$ WRIGHT SCOTT OBRIEN ANDREW 9,098$ STALSBERG SHARON OBRIEN ANDREW 8,709$ ASHER URA OBRIEN ANDREW 8,484$ WOODS DENNIS OBRIEN ANDREW 8,387$ HESS ANNA OBRIEN ANDREW 8,176$ DAVIS DEAN OBRIEN ANDREW 7,870$ LARGURA LEO OBRIEN ANDREW 7,661$ ROBINETTE JAMES OBRIEN ANDREW 7,447$ REISENLEITER PHILIP OBRIEN ANDREW 7,348$

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Last Name First Name Lawyer Settlement offerYATES EARL OBRIEN ANDREW 7,233$ WINTERMANN MAURICE OBRIEN ANDREW 7,036$ FRIDMANSKI ROBERT OBRIEN ANDREW 6,697$ THOMPSON HAROLD OBRIEN ANDREW 6,662$ TRAPP LESLIE OBRIEN ANDREW 6,621$ LACEY WILLIAM OBRIEN ANDREW 5,947$ TREECE CHARLES OBRIEN ANDREW 5,846$ MORTON MARIAN OBRIEN ANDREW 5,537$ MCGOVNEY WILLIAM OBRIEN ANDREW 5,480$ WALTEMATE RUDOLPH OBRIEN ANDREW 5,220$ CONLEY LEROY OBRIEN ANDREW 4,982$ FIELDS LAWSON OBRIEN ANDREW 4,927$ GREER CHARLES OBRIEN ANDREW 4,769$ TRUEBLOOD RALPH OBRIEN ANDREW 4,679$ WHALEN WILLARD OBRIEN ANDREW 4,625$ MADDEN MARY OBRIEN ANDREW 4,431$ TALLEY LLOYD OBRIEN ANDREW 4,330$ LEMBERGER JEROME OBRIEN ANDREW 4,201$ SCHAFER ROBERT OBRIEN ANDREW 3,952$ SCHULTE EDWIN OBRIEN ANDREW 3,938$ BISCH LEO OBRIEN ANDREW 3,882$ MONTANARO JOSEPH OBRIEN ANDREW 3,837$ WELLAND CAROL OBRIEN ANDREW 3,581$ DUNCAN CHARLES OBRIEN ANDREW 3,466$ CURRAN ELMER OBRIEN ANDREW 3,219$ MUSE RAYMOND OBRIEN ANDREW 2,635$ TEATER HOWARD OBRIEN ANDREW 2,600$ BROUGHTON JAMES OBRIEN ANDREW 2,564$ HEIDORN JUNE OBRIEN ANDREW 2,479$ TOMLINSON ROBERT OBRIEN ANDREW 2,460$ RICHARDSON CLIFFORD OBRIEN ANDREW 2,420$ WHITTEN TERRY OBRIEN ANDREW 2,312$ KETTLER FREDERICK OBRIEN ANDREW 2,299$ DOBBINS JAMES OBRIEN ANDREW 2,056$ YEAMANS DAVID OBRIEN ANDREW 1,868$ DAUGHTRY LUCILLE OBRIEN ANDREW 1,856$ BANYCKY HELEN OBRIEN ANDREW 1,145$ MEISENHELTER E OBRIEN ANDREW 1,095$ SCHAFER ROBERT OBRIEN ANDREW 1,000$ MCCOOL RUTH OBRIEN ANDREW 1,000$ FUWELL BUFORD OBRIEN ANDREW 1,000$ PINE GEORGE OBRIEN ANDREW 1,000$ LETTENBERGER DONALD OBRIEN ANDREW 1,000$ BOEDING LINUS OBRIEN ANDREW 1,000$ HARRIS JOANN OBRIEN ANDREW 1,000$ FORMBY MILDRED OBRIEN ANDREW 1,000$ TAYLOR RICHARD OWENS JAMES 1,000$ SMILEY LARRY PATTEN WORNOM HATT 110,488$ LEWIS CARROLL PATTEN WORNOM HATT 97,160$ CASH HARRY PATTEN WORNOM HATT 89,190$ POSEY THOMAS PATTEN WORNOM HATT 74,550$ HERMAN JOHN PATTEN WORNOM HATT 55,633$ TURNER GENE PATTEN WORNOM HATT 51,225$ DUDLEY MARION PATTEN WORNOM HATT 30,932$ BARRETT DONALD PATTEN WORNOM HATT 29,825$ CARNEY ROBERT PATTEN WORNOM HATT 26,808$

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Last Name First Name Lawyer Settlement offerBENJAMIN F PATTEN WORNOM HATT 24,527$ MINTON RUBERT PATTEN WORNOM HATT 23,563$ WALKER ROBERT PATTEN WORNOM HATT 21,256$ BURRIS WILLIAM PATTEN WORNOM HATT 18,698$ JOYCE CHARLES PATTEN WORNOM HATT 15,325$ BROOKS LARRY PATTEN WORNOM HATT 14,860$ CATTIN PAUL PATTEN WORNOM HATT 14,702$ TREVILLIAN HUGH PATTEN WORNOM HATT 14,054$ MASON LAWRENCE PATTEN WORNOM HATT 12,209$ CHRISTENSEN ALFRED PATTEN WORNOM HATT 11,423$ BROWN ELLIS PATTEN WORNOM HATT 11,023$ LANKES JOHN PATTEN WORNOM HATT 10,020$ HEALY EMMETT PATTEN WORNOM HATT 8,762$ PILAND WILLIAM PATTEN WORNOM HATT 7,381$ MONROE HARRY PATTEN WORNOM HATT 6,879$ KEENAN MICHAEL PATTEN WORNOM HATT 6,619$ LANDS BOBBY PATTEN WORNOM HATT 6,575$ MADISON EARL PATTEN WORNOM HATT 6,042$ CARNEY ROBERT PATTEN WORNOM HATT 5,571$ MAXFIELD PETER PATTEN WORNOM HATT 5,178$ BACCUS MURRAY PATTEN WORNOM HATT 5,170$ GALLAGHER JOHN PATTEN WORNOM HATT 5,097$ HILL DUDLEY PATTEN WORNOM HATT 5,062$ FLETCHER ROBERT PATTEN WORNOM HATT 4,370$ SAVAGE FLORENCE PATTEN WORNOM HATT 3,857$ BOLDIN CHARLES PATTEN WORNOM HATT 3,092$ CROCKER JAMES PATTEN WORNOM HATT 2,482$ WHITAKER MILTON PATTEN WORNOM HATT 2,472$ HOGGE JOHN PATTEN WORNOM HATT 1,930$ SMITH G PATTEN WORNOM HATT 1,000$ TAYLOR WILLIAM PATTEN WORNOM HATT 1,000$ JOHNSON WALTER PATTEN WORNOM HATT 1,000$ MILES DON PATTERSON KEAHEY 114,208$ VIDAK LAZLO PATTERSON KEAHEY 16,921$ STANDEN MARY PATTERSON KEAHEY 8,354$ ANDERSON JOSEPH PATTERSON KEAHEY 8,325$ MONTGOMERY HARVEY PATTERSON KEAHEY 7,540$ RUMERY DONALD PAUL BOOTS 1,000$ KINNEY WILLIS PAUL BOOTS 1,000$ MITCHELL DANIEL PAUL HANLEY 164,756$ BARRETT BRUCE PAUL HANLEY 150,299$ TIPTON RONALD PAUL HANLEY 61,519$ DUNKIN PATRICK PAUL HANLEY 34,698$ MORRIS GEORGE PAUL HANLEY 33,045$ CONNER SIDNEY PAUL HANLEY 29,943$ HATCHER AUBURN PAUL HANLEY 23,577$ WEBER NOEL PAUL HANLEY 17,391$ SMITH THAD PAUL HANLEY 13,616$ WEBB WILLIAM PAUL HANLEY 11,551$ NAVARRO ADOLFO PAUL HANLEY 8,674$ BUCCOLA RICHARD PAUL HANLEY 8,176$ TURNER ARTHUR PAUL HANLEY 7,641$ ENTEMAN DON PAUL HANLEY 6,738$ BECK GARVIN PAUL HANLEY 6,374$ ROMAN THEODORE PAUL HANLEY 5,756$ EDEM RICHARD PAUL HANLEY 2,914$

51




Last Name First Name Lawyer Settlement offerCABRAL ANTHONY PAUL HANLEY 2,825$ NIELSEN JOHN PAUL HANLEY 2,284$ BRADFORD JOHN PAUL HANLEY 1,973$ BARNETT WAYNE PAUL HANLEY 1,000$ REYNOLDS MAURICE PAUL HANLEY 1,000$ MANLEY NILAS PAUL REICH MYERS 42,744$ YOUNG CHARLES PAUL REICH MYERS 41,848$ CARSON RUSSELL PAUL REICH MYERS 12,975$ ZIMMERMAN FREDERICK PAUL REICH MYERS 12,679$ PORRETTA CHARLES PAUL REICH MYERS 10,276$ HOROWITZ HARRY PAUL REICH MYERS 8,699$ KAY ARTHUR PAUL REICH MYERS 8,176$ STRUNK WALTER PAUL REICH MYERS 6,736$ POWERS LAURA PAUL REICH MYERS 6,676$ FALLON RUTH PAUL REICH MYERS 6,287$ ERNDL JOHN PAUL REICH MYERS 5,913$ DISANTO HELEN PAUL REICH MYERS 1,000$ FRANTZ KENNETH PAUL REICH MYERS 1,000$ TULLY DENNIS PAUL REICH MYERS 1,000$ JONES THOMAS PAUL REICH MYERS 1,000$ DIGRAZIO JOHN PAUL REICH MYERS 1,000$ DABASHINSKY JOSEPH PAUL REICH MYERS 1,000$ ZUSKIN BENJAMIN PAUL WEYKAMP 12,688$ BELVIN THOMAS PAUL WEYKAMP 6,879$ SMITH ROBERT PAUL WEYKAMP 5,813$ CHERRY WILLIAM PAUL WEYKAMP 2,800$ HODGES JUNIUS PAUL WEYKAMP 2,757$ PROVANCE IVAN PENN RAKAUSKI 47,186$ RAUCH NORMAN PEPPLE JOHNSON CANTU SCHMIDT 1,000$ YOST EVA PEPPLE JOHNSON CANTU SCHMIDT 1,000$ MCRAE WILLIAM PERRY SENSOR 1,000$ REED CARL PERRY SENSOR 1,000$ MONTONEY MAUREEN PETER ANGELOS 170,029$ THOMAS WILLIAM PETER ANGELOS 155,274$ NORDAAS BETTY PETER ANGELOS 127,637$ HOLLAND JAMES PETER ANGELOS 123,325$ SWINNEY NORVAL PETER ANGELOS 121,290$ COX PHILIP PETER ANGELOS 113,096$ BROWN MICHAEL PETER ANGELOS 105,756$ CALDWELL TASHA PETER ANGELOS 91,403$ HAROLD WILLIAM PETER ANGELOS 83,604$ AMIS KENNETH PETER ANGELOS 68,041$ RICKARD R PETER ANGELOS 67,114$ BORGESON DAVID PETER ANGELOS 63,026$ RUPPENKAMP JAMES PETER ANGELOS 62,384$ WATERS WALTER PETER ANGELOS 58,836$ NASH JAMES PETER ANGELOS 54,343$ MCKEMY BERNICE PETER ANGELOS 54,232$ MCCURDY MICHAEL PETER ANGELOS 53,569$ HARTRANFT JACOB PETER ANGELOS 48,824$ LESCALLEET KRISTI PETER ANGELOS 45,090$ MENSACK HARRY PETER ANGELOS 42,638$ MARTIN RAY PETER ANGELOS 42,108$ ALBERT HERMAN PETER ANGELOS 39,430$ WELSHANS PAUL PETER ANGELOS 38,363$ GRAVES ALFRED PETER ANGELOS 37,819$

52




Last Name First Name Lawyer Settlement offerHAMILTON JAMES PETER ANGELOS 35,384$ KLOVENSKY DONALD PETER ANGELOS 29,242$ ROMSPERT RAYMOND PETER ANGELOS 28,287$ NAY JAMES PETER ANGELOS 26,594$ BARKER WILLARD PETER ANGELOS 25,846$ CASHMAN FRANK PETER ANGELOS 25,272$ CASNER RANDALL PETER ANGELOS 23,763$ VOILES LLOYD PETER ANGELOS 22,584$ EDELBLUTE RICHARD PETER ANGELOS 22,243$ SHANEYBROOK WALTER PETER ANGELOS 21,782$ KAMINSKI JOSEPH PETER ANGELOS 21,090$ DALY FRANCES PETER ANGELOS 20,327$ TRIPLETT GERARD PETER ANGELOS 19,769$ MILES ALBERT PETER ANGELOS 18,640$ SABATINO ALLEN PETER ANGELOS 18,127$ KATZ ARTHUR PETER ANGELOS 17,954$ VENT JO PETER ANGELOS 17,954$ OTT RICHARD PETER ANGELOS 17,880$ VAUGHN ROBERT PETER ANGELOS 17,350$ WALLACE JAMES PETER ANGELOS 17,140$ COMBS MARIE PETER ANGELOS 17,110$ MATSAGO JAMES PETER ANGELOS 16,041$ ROWE THOMAS PETER ANGELOS 15,955$ GULLEY WILLIAM PETER ANGELOS 15,887$ RAPONE PASQUALE PETER ANGELOS 15,859$ STURGILL EARL PETER ANGELOS 15,619$ OCHS KENNETH PETER ANGELOS 15,139$ WESCOAT PAUL PETER ANGELOS 15,070$ WALKER GALE PETER ANGELOS 15,000$ WILLIAMS JOHN PETER ANGELOS 14,954$ GILBERT MARSHALL PETER ANGELOS 14,746$ ELLERBE JERRARD PETER ANGELOS 14,336$ LIRAKIS STEVE PETER ANGELOS 14,289$ HEINICKE CHARLES PETER ANGELOS 13,346$ JONES WILLIAM PETER ANGELOS 13,145$ MILLER WAYNE PETER ANGELOS 13,063$ TAYLOR MARLENE PETER ANGELOS 12,994$ HEUCKEROTH LESTER PETER ANGELOS 12,637$ BURNS ROBERT PETER ANGELOS 11,216$ MORRISON CHARLES PETER ANGELOS 10,658$ WEBSTER WILLIE PETER ANGELOS 10,398$ HARTMAN WILLIAM PETER ANGELOS 10,272$ JACKSON LEROY PETER ANGELOS 10,213$ WAGNER JOHANN PETER ANGELOS 9,947$ JAWORSKI ROBERT PETER ANGELOS 9,835$ GRAUER RICHARD PETER ANGELOS 8,747$ MELZER CATHERINE PETER ANGELOS 8,279$ WYATT HOWARD PETER ANGELOS 8,093$ CASTAGNA BART PETER ANGELOS 7,997$ DUNN JAMES PETER ANGELOS 7,880$ TABB GEORGE PETER ANGELOS 7,658$ KROH EDWARD PETER ANGELOS 7,632$ KOSTISHION JOHN PETER ANGELOS 7,550$ KASSIN RICHARD PETER ANGELOS 7,354$ BORDES NICK PETER ANGELOS 6,946$ HESSONG DON PETER ANGELOS 6,899$

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Last Name First Name Lawyer Settlement offerDEAN ANDREW PETER ANGELOS 6,851$ KOPIE PATRICIA PETER ANGELOS 6,575$ NOVAK THEODORE PETER ANGELOS 6,484$ BRANDENBURG JAMES PETER ANGELOS 6,184$ OCONNELL PATRICK PETER ANGELOS 6,007$ MACE CHARLES PETER ANGELOS 5,999$ LIMERICK ENEVER PETER ANGELOS 5,837$ HAAS GLADYS PETER ANGELOS 5,821$ SAUERS KENNETH PETER ANGELOS 5,796$ BUCH JAMES PETER ANGELOS 5,528$ GILBREATH JOHN PETER ANGELOS 5,492$ SPECK GORDON PETER ANGELOS 5,487$ HOBART SAMUEL PETER ANGELOS 5,462$ GRIER JOHN PETER ANGELOS 5,423$ CRANDELL WILLARD PETER ANGELOS 5,421$ LEMEL IRVIN PETER ANGELOS 5,388$ NIESS JOHN PETER ANGELOS 5,354$ BEDNAR ERMA PETER ANGELOS 5,152$ MANNING THOMAS PETER ANGELOS 4,919$ WHEELER THEODORE PETER ANGELOS 4,890$ CAMP ROBERT PETER ANGELOS 4,838$ RUTH ROBERT PETER ANGELOS 4,686$ FRY ELSIE PETER ANGELOS 4,287$ MATETICH WILLIAM PETER ANGELOS 4,240$ WARFIELD WILLIAM PETER ANGELOS 4,121$ TRINKLE RUTH PETER ANGELOS 4,065$ HAMILTON ELIZABETH PETER ANGELOS 3,979$ SOLTYSIAK JOHN PETER ANGELOS 3,816$ GOSZCYNSKI THERESA PETER ANGELOS 3,500$ RAHNEFELD PHILLIP PETER ANGELOS 3,453$ FELDER LOIS PETER ANGELOS 3,348$ ASHCRAFT DOROTHY PETER ANGELOS 2,972$ SMITH DONALD PETER ANGELOS 2,802$ HENEBERRY WILLIAM PETER ANGELOS 2,781$ FORD GRAYSON PETER ANGELOS 2,396$ STUMPF JOHN PETER ANGELOS 2,382$ DERITA NICK PETER ANGELOS 2,152$ BROOKHART WILLIAM PETER ANGELOS 2,064$ PIASECKI MICHAEL PETER ANGELOS 1,984$ MITCHELL HELEN PETER ANGELOS 1,875$ HAACKE C PETER ANGELOS 1,740$ PEDOLSKY MORRIS PETER ANGELOS 1,000$ CLASS MELVA PETER ANGELOS 1,000$ PERRY RONALD PETER ANGELOS 1,000$ PLEINES WALTER PETER ANGELOS 1,000$ SWEENE WILLIAM PETER ANGELOS 1,000$ KENNELL LEROY PETER ANGELOS 1,000$ FOX JUDITH PETER ANGELOS 1,000$ TELLJOHANN EDITH PETER ANGELOS 1,000$ CUDDY JACKIE PETER NICHOLL 34,911$ SADLER PHILIP PETER NICHOLL 25,168$ CUSTALOW CLYDE PETER NICHOLL 18,063$ BYER ROBERT PETER NICHOLL 9,075$ WILLS BARBARA PETER NICHOLL 8,622$ EADDY SHIRLEY PETER NICHOLL 1,000$ SMITH PATRICIA PETER NICHOLL 1,000$

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Last Name First Name Lawyer Settlement offerSORTOR HOWARD PETERSEN PARKINSON ARNOLD 1,000$ STOOR JOHN PETERSEN PARKINSON ARNOLD 1,000$ BRANCH ROBERT PETERSEN PARKINSON ARNOLD 1,000$ FRASURE WILLIAM PETERSEN PARKINSON ARNOLD 1,000$ FULGHAM KENNETH PORTER MALOUF 113,037$ FISHER JOHN PORTER MALOUF 81,757$ LOBELL HAROLD PORTER MALOUF 1,000$ BANET PAUL PRIDDY CUTLER MILLER MEADE 1,000$ FELLIN JAMES PRIM LAWFIRM 14,703$ HOWELL STACEY PRIM LAWFIRM 1,000$ LAWHORN OREN PRIM LAWFIRM 1,000$ LIVELY BOYD PRIM LAWFIRM 1,000$ BROWN JOHN PRIM LAWFIRM 1,000$ LAWSON ROBERT PRIM LAWFIRM 1,000$ HALL JAMES PRIM LAWFIRM 1,000$ MCALLISTER NANCY PRIM LAWFIRM 1,000$ TAYLOR ROSS PRIM LAWFIRM 1,000$ SANMIGUEL SAMUEL PRIM LAWFIRM 1,000$ ROBERTSON CECIL PROVOST UMPHREY 124,550$ OSBORNE MICHAEL PROVOST UMPHREY 122,578$ WAGNER BOYD PROVOST UMPHREY 90,881$ SAXE THOMAS PROVOST UMPHREY 70,613$ GREEN ROY PROVOST UMPHREY 57,689$ BERGERON GLIESE PROVOST UMPHREY 47,995$ SANDELLA JAMES PROVOST UMPHREY 47,468$ DUROUSSEAU MERLIN PROVOST UMPHREY 33,911$ OLSEN GERALD PROVOST UMPHREY 23,566$ BARTON JOHN PROVOST UMPHREY 18,453$ SCHROEDER WARREN PROVOST UMPHREY 17,149$ THOMAS LOLA PROVOST UMPHREY 13,782$ STANDRIDGE ERNEST PROVOST UMPHREY 13,636$ SHERIDAN NUGENT PROVOST UMPHREY 13,456$ TAYLOR GEORGE PROVOST UMPHREY 13,185$ GROS ANDREW PROVOST UMPHREY 13,080$ SCHULTZ FREDERICK PROVOST UMPHREY 12,572$ CAMPISE JOHNNY PROVOST UMPHREY 11,737$ CUTLER JACK PROVOST UMPHREY 11,427$ SIMS DONALD PROVOST UMPHREY 11,086$ TURNER FRANK PROVOST UMPHREY 10,636$ MILES ROGER PROVOST UMPHREY 8,572$ RIPPEY LEO PROVOST UMPHREY 8,141$ BOMBEK FRANK PROVOST UMPHREY 7,734$ MILLER STEPHEN PROVOST UMPHREY 7,252$ BRISTER GEORGE PROVOST UMPHREY 6,818$ BERG FRED PROVOST UMPHREY 5,838$ GIMENEZ LOUIS PROVOST UMPHREY 5,825$ FORTENBERRY VERA PROVOST UMPHREY 5,745$ LOZICA FRANK PROVOST UMPHREY 5,422$ SMART HAROLD PROVOST UMPHREY 5,391$ CAMPBELL LANDIETH PROVOST UMPHREY 5,306$ PAGE J PROVOST UMPHREY 5,235$ SOLLY MAGDALENE PROVOST UMPHREY 4,165$ WAINWRIGHT VOIGHT PROVOST UMPHREY 3,910$ DROUT JAMES PROVOST UMPHREY 3,783$ DAVIS BERNICE PROVOST UMPHREY 2,377$ GILBERT CHARLES PROVOST UMPHREY 2,345$

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Last Name First Name Lawyer Settlement offerMUNN FRANCIS PROVOST UMPHREY 2,321$ HEBERT SAMUEL PROVOST UMPHREY 1,000$ BLACK JOSEPH RATHMAN OBRIEN 1,000$ MITCHELL JAMES RATINER REYES OSHEA 105,756$ BELLOMY JOHN RATINER REYES OSHEA 57,527$ BLAKLEY CHARLES RATINER REYES OSHEA 51,807$ DAVIS CARL RATINER REYES OSHEA 44,665$ HEDRICK ROBERT RATINER REYES OSHEA 32,391$ WEAVER ALBERT RATINER REYES OSHEA 25,332$ BASSETT RONNIE RATINER REYES OSHEA 13,391$ KNIGHT RICHARD RATINER REYES OSHEA 9,026$ RULAPAUGH JAMES RATINER REYES OSHEA 8,423$ CROUSE JAMES RATINER REYES OSHEA 8,415$ YOUNG JOSEPH RATINER REYES OSHEA 7,727$ SMITH CHRIS RATINER REYES OSHEA 7,651$ SMITH EDWARD RATINER REYES OSHEA 6,290$ DOUGHERTY DENNIS RATINER REYES OSHEA 6,194$ BURNS ROBERT RATINER REYES OSHEA 5,636$ HUMMEL MERVIN RATINER REYES OSHEA 4,898$ HARKNESS WILLIAM RATINER REYES OSHEA 4,496$ LADY JOSEPH RATINER REYES OSHEA 4,059$ FRENCH JOE RATINER REYES OSHEA 1,456$ MILLER ELWOOD REAUD MORGAN QUINN 39,171$ LINDER JOHNNIE REAUD MORGAN QUINN 16,333$ BILLS ROBERT RG TAYLOR II 43,218$ VAUGHAN EDWARD RG TAYLOR II 42,317$ GAVIN WILLIAM RG TAYLOR II 13,220$ TAYLOR PHILLIP RG TAYLOR II 10,114$ CRAIN ERNEST RG TAYLOR II 8,444$ WALKER KENNETH RG TAYLOR II 5,248$ BAILES GEORGE RG TAYLOR II 1,000$ ONEY FLOYD RICHARD ALAN DODD 38,750$ BRANVILLE VICKI RIGGS ABNEY NEAL TURBEN ORBISONLEWIS 1,000$ SACHSE DANIEL ROBERT KLUNG SR 1,000$ HOPKINS ROBERT ROBERT KLUNG SR 1,000$ BROWN WAYNE ROBERT PEIRCE 27,920$ HAWRYLAK PETER ROBERT PEIRCE 19,264$ MILLER CLIFFORD ROBERT PEIRCE 5,063$ ZEMBALA BERNADETTE ROBERT STEINBERG 12,984$ RILEY BRUCE ROBERT SWEENEY 86,877$ CARSEY FRANKLIN ROBERT SWEENEY 68,099$ HALL ELZA ROBERT SWEENEY 67,203$ RICHARDSON WILLIAM ROBERT SWEENEY 54,324$ TURNER JOHN ROBERT SWEENEY 44,020$ PYERS JAMES ROBERT SWEENEY 42,784$ FIFIELD SHERWIN ROBERT SWEENEY 36,429$ FELLENBAUM RONALD ROBERT SWEENEY 32,816$ JOHNSON CLARENCE ROBERT SWEENEY 29,455$ CREIGHTON JOHN ROBERT SWEENEY 27,517$ TEKAVCIC LOUIS ROBERT SWEENEY 21,252$ SHACKLEFORD ROBERT ROBERT SWEENEY 20,756$ ERKKILA RAYMOND ROBERT SWEENEY 16,345$ YOUNG CLAUDY ROBERT SWEENEY 15,569$ BUNDE LOUISE ROBERT SWEENEY 14,986$ TOTTEN CONWARD ROBERT SWEENEY 13,513$ CARLO FRANK ROBERT SWEENEY 12,975$

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Last Name First Name Lawyer Settlement offerWEIRICK NELSON ROBERT SWEENEY 12,314$ WOODS EDWIN ROBERT SWEENEY 12,273$ MISSIG KENNETH ROBERT SWEENEY 11,600$ MORGAN ROBERT ROBERT SWEENEY 11,242$ HAYES WILLIAM ROBERT SWEENEY 10,482$ WHELPLEY GUY ROBERT SWEENEY 9,746$ BLAMBLE FRANKLIN ROBERT SWEENEY 9,546$ VONVILLE BONNIE ROBERT SWEENEY 8,599$ SHAFFER KENNETH ROBERT SWEENEY 8,545$ TODARO ANGELO ROBERT SWEENEY 7,946$ CLUTTER FRED ROBERT SWEENEY 7,576$ PITSINGER DALE ROBERT SWEENEY 6,684$ CARTER JAMES ROBERT SWEENEY 6,082$ PREZIOSO JOHN ROBERT SWEENEY 5,107$ SHIPTA FRANK ROBERT SWEENEY 5,054$ GODDARD FLOYD ROBERT SWEENEY 4,063$ BRAUN CONRAD ROBERT SWEENEY 3,914$ COLANTONI VICTOR ROBERT SWEENEY 3,296$ BARATH BERTALAN ROBERT SWEENEY 2,923$ STIDHAM LEE ROBERT SWEENEY 1,178$ FEICK CLARENCE ROBERT SWEENEY 1,000$ CIPRIANO PASCHAL ROBERT SWEENEY 1,000$ KRIST ANN ROBERT SWEENEY 1,000$ BUTLER STACHI ROBERT SWEENEY 1,000$ AUBRY JOSEPH ROBERT SWEENEY 1,000$ VOLION VIVIAN ROBICHAUX VAN 1,000$ GALLOWAY ERNEST ROBINS CLOUD 44,521$ ROBESON WILLIAM ROBINS CLOUD 14,106$ PEREZ JOSE ROBINS CLOUD 11,834$ BARRIENTES JESUS ROBINS CLOUD 6,437$ ROBERTSON BELDON ROBINS CLOUD 6,184$ BOSWELL WILLIE ROBINS CLOUD 5,446$ SANDERS LEELAND ROBINS CLOUD 4,985$ RAMSEY DONALD ROBINS CLOUD 4,779$ RUIZ RAYMOND ROBINS CLOUD 4,582$ HARGRAVE RODNEY ROBINS CLOUD 1,000$ LUNA MANUEL ROBINS CLOUD 1,000$ RUIZ RAYMOND ROBINS CLOUD 1,000$ RODRIGUEZ PEDRO ROBINS CLOUD 1,000$ RAMSEY MARTHA ROBLES GONZALEZ 9,076$ MANDEL SHIRLEY ROBLES GONZALEZ 7,520$ MANGEL RALPH ROBLES GONZALEZ 5,859$ TURNER RICHARD ROSE KLEIN MARIAS 4,807$ PICHON LEON ROUSSEL ROUSSEL 60,930$ MARCHAND COLLEEN ROUSSEL ROUSSEL 5,999$ STPIERRE WAYNE ROUSSEL ROUSSEL 1,000$ ROME ELODIE ROUSSEL ROUSSEL 1,000$ BELL CHRISTOPHER ROWLAND ROWLAND 1,000$ BRAHAM RONALD RUSSELL SMITH 11,499$ PHILLIPS MAURICE RUSSELL SMITH 4,739$ SINGLETON DON RUSSELL SMITH 1,000$ WRIGHT NATHAN RYAN FOSTER 8,695$ BISHOP EVELYN RYAN FOSTER 3,350$ KAZEE ORA SALES TILLMAN WALLBAUM 83,759$ SMITH HARRY SALES TILLMAN WALLBAUM 11,782$ ANG CHARLES SALES TILLMAN WALLBAUM 5,013$

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Last Name First Name Lawyer Settlement offerFINNEY BENJAMIN SALES TILLMAN WALLBAUM 1,000$ IRVIN GERALD SALES TILLMAN WALLBAUM 1,000$ MUSSELMAN LISA SAVILLE EVOLA FLINT 127,264$ STEPHENS JOHN SAVILLE EVOLA FLINT 42,353$ JOHNSON ARVID SAVILLE EVOLA FLINT 40,506$ HALTERMAN RODNEY SAVILLE EVOLA FLINT 34,886$ SPRACKLEN LEE SAVILLE EVOLA FLINT 24,527$ TUCKER CHARLES SAVILLE EVOLA FLINT 18,551$ BOCEK MILDRED SAVILLE EVOLA FLINT 14,298$ BROOKSHIRE FLORENE SAVILLE EVOLA FLINT 11,117$ PUCKETT CHARLES SAVILLE EVOLA FLINT 11,008$ SOUZA JOHN SAVILLE EVOLA FLINT 10,977$ MILANO JOHN SAVILLE EVOLA FLINT 9,667$ COCHRAN DAN SAVILLE EVOLA FLINT 8,434$ PADRON AMADO SAVILLE EVOLA FLINT 5,965$ HONEA ETHEL SAVILLE EVOLA FLINT 5,761$ SOMMERMAN EDWARD SAVILLE EVOLA FLINT 5,151$ HEBERT DURWOOD SAVILLE EVOLA FLINT 4,779$ KUHN JAMES SAVILLE EVOLA FLINT 4,743$ REES LESLIE SAVILLE EVOLA FLINT 2,806$ JAMES THOMAS SAVILLE EVOLA FLINT 2,382$ FRITTS EMILY SAVILLE EVOLA FLINT 1,000$ MAISANO MICHAEL SAVINIS DAMICO KANE 44,226$ PETRINA JOSEPH SAVINIS DAMICO KANE 29,684$ CHLYSTEK MARTIN SAVINIS DAMICO KANE 18,464$ NEWCOMER DANIEL SAVINIS DAMICO KANE 14,639$ LILLIQUIST CARL SAVINIS DAMICO KANE 9,631$ GENTILE THEODORE SAVINIS DAMICO KANE 8,181$ MCCARTY DONALD SAVINIS DAMICO KANE 7,505$ SHAW JOHN SAVINIS DAMICO KANE 7,048$ SERAGO FRANK SAVINIS DAMICO KANE 5,354$ PINI A SAVINIS DAMICO KANE 3,623$ HRECHUN VIRGINIA SAVINIS DAMICO KANE 1,000$ SCHAAF WILLIAM SAVINIS DAMICO KANE 1,000$ EYLER HARRY SAVINIS DAMICO KANE 1,000$ BLACKMON CHRISTINE SCHOEN 1,000$ GOODMAN ALBERT SCHROETER GOLDMARK 160,322$ FARROW MICHAEL SCHROETER GOLDMARK 70,196$ SPALDING ROBERT SCHROETER GOLDMARK 48,043$ MOORE LLOYD SCOPELITIS GARVIN LIGHT HANSON 72,608$ MONTALBANO JAKE SCOTT HENDLER 10,881$ ALIRES SALOMON SCOTT HENDLER 6,894$ TANNER LEON SCOTT SCOTT 41,927$ MCRAE DONALD SCRUGGS MILLETTE LAWSON BOZEMAN DENT 1,000$ GUSTKE BRUCE SEEGER WEISS 1,000$ MARTIN JAMES SEEGER WEISS 1,000$ EGEA FRANCISCO SEEGER WEISS 1,000$ CASTLE JIMMIE SHACKELFORD STEPHEN 1,000$ TURNER RONNIE SHEIN LAW CENTER 56,417$ WALKER THOMAS SHEIN LAW CENTER 49,743$ MILLS STANLEY SHEIN LAW CENTER 47,659$ HARTLEY GLEN SHEIN LAW CENTER 29,455$ HAKE DOUGLAS SHEIN LAW CENTER 28,794$ BANAS RONALD SHEIN LAW CENTER 27,185$ PFEIFER ALBERT SHEIN LAW CENTER 23,545$ SMITH ROBERT SHEIN LAW CENTER 17,779$

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Last Name First Name Lawyer Settlement offerGRABOWSKI JOHN SHEIN LAW CENTER 8,734$ LANSDOWNE ELMAN SHEIN LAW CENTER 7,002$ MILLER OLIN SHEIN LAW CENTER 6,071$ KYLER JAMES SHEIN LAW CENTER 5,693$ THOMAS EDWARD SHEPARD HOFFMAN 1,000$ BISGAARD SOREN SHEPARD LAWFIRM 40,177$ DAVIS GUY SHEPARD LAWFIRM 39,228$ DANDREA FREDRICK SHEPARD LAWFIRM 30,295$ MACDOWELL KENNETH SHEPARD LAWFIRM 16,740$ MARTINEZ CECILIO SHEPARD LAWFIRM 16,415$ SNOW JAMES SHEPARD LAWFIRM 15,718$ MONARCH DONNA SHEPARD LAWFIRM 14,096$ DIFRANCO SALVATORE SHEPARD LAWFIRM 10,017$ MACDOWELL RICHARD SHEPARD LAWFIRM 9,569$ CINSERULI JOSEPH SHEPARD LAWFIRM 6,822$ SCAFIDI ALFRED SHEPARD LAWFIRM 6,331$ FINN LOIS SHEPARD LAWFIRM 6,093$ KNIGHT JOHN SHEPARD LAWFIRM 3,855$ TEDFORD JOHN SHEPARD LAWFIRM 1,000$ WARFEL GEORGIANA SHIVERS SPIELBERG 12,573$ WESOLOWSKI RICHARD SHIVERS SPIELBERG 8,727$ BRIDGES ROBERT SHIVERS SPIELBERG 5,862$ HULTGREN CARL SHIVERS SPIELBERG 5,856$ STACHIOTTI LOUIS SHIVERS SPIELBERG 4,664$ MILLER ROBERT SHIVERS SPIELBERG 4,457$ DAMIANI ALAN SHIVERS SPIELBERG 1,000$ HADLEY BILLY SHRADER 98,833$ ROQUE EDWARD SHRADER 7,571$ BERGER DOUGLAS SHRADER 4,951$ DOTSON GEORGE SHRADER 1,000$ FRANKS ARNOLD SHRADER 1,000$ BENNETT MICHAEL SHRADER 1,000$ KIMBLE DIXIE SHRADER 1,000$ ASKIN EDITH SHRADER 1,000$ REESE DARWIN SHRADER 1,000$ STUMPF WILLIAM SHRADER 1,000$ HARRISON BARBARA SHRADER 1,000$ CROUCH JANET SHRADER 1,000$ FROST JAMES SHRADER 1,000$ MULLIGAN SIMONE SHRADER 1,000$ MORELLI MICHELLE SHRADER 1,000$ HINCKLEY LARRY SHRADER 1,000$ JOHNSON RUSSELL SHRADER 1,000$ BURNS JACKY SHRADER 1,000$ WRIGHT M SHRADER 1,000$ KILIAN JOHN SHRADER 1,000$ MORBY CHARLES SHRADER 1,000$ FARRINGTON NATHANIEL SHRADER 1,000$ PALELLA FRANCES SHRADER 1,000$ FERDINAND HARRY SHRADER 1,000$ HUBBARD VERLIE SHRADER 1,000$ KIEFFER MARJORIE SIEBEN POLK 21,045$ GIEFER WAYNE SIEBEN POLK 20,451$ LATOCKI MICHAEL SIEBEN POLK 15,077$ JOHNSON JAMES SIEBEN POLK 6,118$ KAUFMAN JOHN SIEBEN POLK 3,064$

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Last Name First Name Lawyer Settlement offerSALLEE TERRY SIMMONS BROWDER 115,614$ BREEDLOVE SHEILA SIMMONS BROWDER 113,037$ JENSEN HANS SIMMONS BROWDER 91,668$ PILCHER FLOYD SIMMONS BROWDER 90,790$ DUFOUR RICHARD SIMMONS BROWDER 86,300$ ODONNELL JOHN SIMMONS BROWDER 81,827$ BRADFORD DOUGLAS SIMMONS BROWDER 70,899$ MUHEIM RONALD SIMMONS BROWDER 70,200$ CARRUTHERS ROBERT SIMMONS BROWDER 61,195$ WILLIAMS ERIC SIMMONS BROWDER 55,416$ MCPHATTER BRUCE SIMMONS BROWDER 53,778$ MONTEZ MARK SIMMONS BROWDER 52,705$ RICCARDI LEON SIMMONS BROWDER 49,350$ JOYCE KELLY SIMMONS BROWDER 45,683$ MAHONEY PAULINE SIMMONS BROWDER 45,580$ BROOKS ALONZO SIMMONS BROWDER 43,091$ MCCOY JANINE SIMMONS BROWDER 42,108$ SCHOLER LLOYD SIMMONS BROWDER 41,737$ MAXWELL STEPHEN SIMMONS BROWDER 39,238$ MCGREW KAREN SIMMONS BROWDER 39,228$ ADAMS LEONARD SIMMONS BROWDER 38,649$ KAISERSATT THOMAS SIMMONS BROWDER 38,205$ MOREHOUSE ALMOND SIMMONS BROWDER 38,035$ WHITBECK GERALD SIMMONS BROWDER 37,227$ HELLAMS MACK SIMMONS BROWDER 33,223$ ADAMS ROSEMARY SIMMONS BROWDER 32,816$ MEDLER ROBERT SIMMONS BROWDER 32,401$ MOORMAN WILFRED SIMMONS BROWDER 32,256$ GALLAGHER ARNOLD SIMMONS BROWDER 32,162$ VICARS JUDITH SIMMONS BROWDER 31,442$ MOSLEY JERRY SIMMONS BROWDER 28,738$ WARREN NATHAN SIMMONS BROWDER 28,633$ MORONEY JAMES SIMMONS BROWDER 26,884$ BUTLER V SIMMONS BROWDER 26,151$ GILROY HARVEY SIMMONS BROWDER 24,721$ WHITEHEAD JOSEPH SIMMONS BROWDER 24,361$ SCHOOLEY RICHARD SIMMONS BROWDER 24,361$ KNUDSON DIANE SIMMONS BROWDER 23,563$ GONNEVILLE LISA SIMMONS BROWDER 23,436$ COWIN SHANE SIMMONS BROWDER 23,299$ JARUS RICHARD SIMMONS BROWDER 22,344$ SCOLARO SALVATORE SIMMONS BROWDER 21,090$ PETERKA LADDIE SIMMONS BROWDER 20,781$ HELSBY WILLIAM SIMMONS BROWDER 20,713$ HARRIS WILLIAM SIMMONS BROWDER 20,189$ ANDRESS JAMES SIMMONS BROWDER 19,768$ BROWN RALPH SIMMONS BROWDER 18,403$ MCCOURTNEY CECIL SIMMONS BROWDER 17,762$ STEIB ROBERT SIMMONS BROWDER 17,651$ WILLIAMS URAL SIMMONS BROWDER 17,651$ PAFFEL PHILIP SIMMONS BROWDER 17,610$ DUNKERLY CHARLES SIMMONS BROWDER 17,579$ ALLEN LAWRENCE SIMMONS BROWDER 17,511$ NORBERG JOHN SIMMONS BROWDER 17,049$ NELSON BEVERLY SIMMONS BROWDER 16,603$ LINNANE MICHAEL SIMMONS BROWDER 16,542$

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Last Name First Name Lawyer Settlement offerBROWN FRANK SIMMONS BROWDER 16,383$ MILESKI ROBERTA SIMMONS BROWDER 16,081$ CAMPBELL MARCY SIMMONS BROWDER 15,908$ RESSLER MERVIN SIMMONS BROWDER 15,837$ SHERIDAN RONALD SIMMONS BROWDER 15,623$ SPARKS RAYMOND SIMMONS BROWDER 15,416$ LITAWAY MICHAEL SIMMONS BROWDER 15,064$ SMITH CHARLES SIMMONS BROWDER 14,566$ WARREN WILLIAM SIMMONS BROWDER 14,290$ DIETRICH RICHARD SIMMONS BROWDER 14,222$ ROSE DAVID SIMMONS BROWDER 13,811$ DIDOMENICO ANTHONY SIMMONS BROWDER 13,662$ INMAN BARRY SIMMONS BROWDER 13,543$ BEALL PAUL SIMMONS BROWDER 13,400$ BALWIERZ FRANK SIMMONS BROWDER 12,853$ MITCHELL WILILAM SIMMONS BROWDER 12,372$ WILSON CHARLES SIMMONS BROWDER 12,118$ CHILQUIST ARLENE SIMMONS BROWDER 12,111$ SCHAUER WILLARD SIMMONS BROWDER 12,062$ BOWLING RAYMOND SIMMONS BROWDER 11,536$ DUNLAP LEON SIMMONS BROWDER 11,524$ ARTHUR ARMAND SIMMONS BROWDER 11,404$ KAPLUN YAKOV SIMMONS BROWDER 11,072$ DUBOIS MILDRED SIMMONS BROWDER 11,026$ HAMM REBECCA SIMMONS BROWDER 10,931$ JACOBSEN OLEY SIMMONS BROWDER 10,641$ BILBROUGH WILLIAM SIMMONS BROWDER 9,917$ SCHROEDER CHARLES SIMMONS BROWDER 9,870$ ARMSTRONG STANLEY SIMMONS BROWDER 9,627$ HOLT CHERYL SIMMONS BROWDER 9,560$ TREVINO FRANCISCO SIMMONS BROWDER 9,304$ MYHRMAN RICHARD SIMMONS BROWDER 9,292$ MOSBY LEO SIMMONS BROWDER 9,291$ REDLINE ERNEST SIMMONS BROWDER 9,165$ HERSEL HENRY SIMMONS BROWDER 9,115$ WALLER ROBERT SIMMONS BROWDER 8,974$ RYAPPY LEROY SIMMONS BROWDER 8,704$ JAMES ROBERT SIMMONS BROWDER 8,629$ WITTES JAMES SIMMONS BROWDER 8,278$ THOMPSON WESTERN SIMMONS BROWDER 8,213$ RITSEMA GERHARD SIMMONS BROWDER 8,177$ ROSS ROBERT SIMMONS BROWDER 8,176$ WILLIAMSON MELVIN SIMMONS BROWDER 7,705$ BLAUVELT WAYNE SIMMONS BROWDER 7,594$ HAMILTON ROBERT SIMMONS BROWDER 7,503$ WRIGHT CHARLES SIMMONS BROWDER 7,486$ DEWEY JOAN SIMMONS BROWDER 7,456$ GAFFNEY RICHARD SIMMONS BROWDER 7,321$ ALEXANDER THOMAS SIMMONS BROWDER 7,266$ KNOTEK HOWARD SIMMONS BROWDER 7,228$ BOLLIGER DONALD SIMMONS BROWDER 7,110$ AGNEY THOMAS SIMMONS BROWDER 6,936$ WARWICK PATSY SIMMONS BROWDER 6,935$ GONZALES EULALIO SIMMONS BROWDER 6,639$ GARDINER FERRIS SIMMONS BROWDER 6,563$ MARTIN RODGER SIMMONS BROWDER 6,455$

61




Last Name First Name Lawyer Settlement offerERICKSON AGNES SIMMONS BROWDER 6,407$ BURTON LAWRENCE SIMMONS BROWDER 6,265$ JONES DON SIMMONS BROWDER 6,235$ HUFF GERALD SIMMONS BROWDER 6,218$ JOSEPH VIOLA SIMMONS BROWDER 6,111$ ASHWORTH SHERMAN SIMMONS BROWDER 5,981$ ADKINS BARRY SIMMONS BROWDER 5,894$ LEE ALFRED SIMMONS BROWDER 5,861$ YOUNG JAMES SIMMONS BROWDER 5,788$ LOSH ALBERT SIMMONS BROWDER 5,786$ CANNON ROBERT SIMMONS BROWDER 5,758$ LAMB DONALD SIMMONS BROWDER 5,736$ MALONEY ALFRED SIMMONS BROWDER 5,716$ BILTZ CLAIR SIMMONS BROWDER 5,564$ MCLOUGHLIN JOSEPH SIMMONS BROWDER 5,459$ ARMSTRONG EARL SIMMONS BROWDER 5,426$ NIEDER ROBERT SIMMONS BROWDER 5,345$ PARKER MARGUERITTE SIMMONS BROWDER 5,309$ BOWLER RUTH SIMMONS BROWDER 5,241$ FOOTE MINNIE SIMMONS BROWDER 5,044$ BURTON LEONA SIMMONS BROWDER 4,909$ MUNN WILLIAM SIMMONS BROWDER 4,699$ COOK NAOMI SIMMONS BROWDER 4,666$ HARVEY CHARLES SIMMONS BROWDER 4,231$ HALLEY MARY SIMMONS BROWDER 4,089$ POOL LAWRENCE SIMMONS BROWDER 3,926$ KAHMANN WILLIAM SIMMONS BROWDER 3,924$ ZAMBER GERALD SIMMONS BROWDER 3,888$ WEAVER DENNIS SIMMONS BROWDER 3,382$ IAUKEA R SIMMONS BROWDER 3,086$ CLEM JOHN SIMMONS BROWDER 2,973$ AMBROSE CLARENCE SIMMONS BROWDER 2,734$ PIGUE EDWARD SIMMONS BROWDER 2,380$ HAYES DENSIC SIMMONS BROWDER 2,187$ STEVENS SARAH SIMMONS BROWDER 1,939$ SPENCER ERNIE SIMMONS BROWDER 1,786$ BAUMER ALFRED SIMMONS BROWDER 1,729$ RYAN JOSEPH SIMMONS BROWDER 1,000$ GARRIGUS EDWARD SIMMONS BROWDER 1,000$ WEBB RONALD SIMMONS BROWDER 1,000$ EVERETT ALETHA SIMMONS BROWDER 1,000$ JACKSON BRUCE SIMMONS BROWDER 1,000$ BOYD DONALD SIMMONS BROWDER 1,000$ MULLENS DWIGHT SIMMONS BROWDER 1,000$ SIMONIS FRANICS SIMMONS BROWDER 1,000$ LAWSON NAYMAN SIMMONS BROWDER 1,000$ SHELLEBY ROBERT SIMMONS BROWDER 1,000$ MICHLIG LEANDER SIMMONS BROWDER 1,000$ PAVLICK JOHN SIMMONS BROWDER 1,000$ BRYAN ASHLEY SIMMONS BROWDER 1,000$ PAPAPASCHOS DIMITRIUS SIMMONS BROWDER 1,000$ DEAN ALFRED SIMMONS BROWDER 1,000$ KOEHNEN GORDON SIMMONS BROWDER 1,000$ GUINN ROBERT SIMMONS BROWDER 1,000$ SCHREUR ROBERT SIMMONS BROWDER 1,000$ ALLEN JOHN SIMON GREENSTONE 92,780$

62




Last Name First Name Lawyer Settlement offerKINSETH LARRY SIMON GREENSTONE 80,141$ SMART CHARLES SIMON GREENSTONE 72,608$ KISLING ALLAN SIMON GREENSTONE 42,949$ PFEIFER WILLIAM SIMON GREENSTONE 34,172$ DRENNAN RICKY SIMON GREENSTONE 33,911$ DAVIS CHESTER SIMON GREENSTONE 32,784$ GEIST RONALD SIMON GREENSTONE 32,481$ PUTMAN RONNIE SIMON GREENSTONE 28,173$ CARTY EDWARD SIMON GREENSTONE 24,397$ FOLSTON BILLY SIMON GREENSTONE 23,028$ OBRIEN LARRY SIMON GREENSTONE 22,537$ CURRY CHARLES SIMON GREENSTONE 21,179$ SPIVEY CARL SIMON GREENSTONE 20,742$ HARRISON DONALD SIMON GREENSTONE 18,325$ BYRD TERRY SIMON GREENSTONE 14,276$ RABOVSKY VALENT SIMON GREENSTONE 13,107$ EISLER LEROY SIMON GREENSTONE 12,882$ SORBOM NILS SIMON GREENSTONE 12,649$ CERNY KENTON SIMON GREENSTONE 11,620$ HALL RICHARD SIMON GREENSTONE 10,650$ MASSEY WALLACE SIMON GREENSTONE 9,729$ KIMBLEY ROLLIE SIMON GREENSTONE 9,479$ BURLESON FRANK SIMON GREENSTONE 8,787$ GALBERAITH JAMES SIMON GREENSTONE 7,557$ REASONER ROSS SIMON GREENSTONE 6,837$ SEARL IRVIN SIMON GREENSTONE 6,279$ PARKEY LAWRENCE SIMON GREENSTONE 5,843$ GARVER CHARLES SIMON GREENSTONE 4,822$ SOMMERFELD MYRON SIMON GREENSTONE 4,323$ DAVIS BERNICE SIMON GREENSTONE 4,172$ LAMBINE RICHARD SIMON GREENSTONE 3,032$ AERY CARL SIMON GREENSTONE 2,746$ GRAY GEORGE SIMON GREENSTONE 2,548$ COATES MERTON SIMON GREENSTONE 2,136$ SMITH RONALD SIMON GREENSTONE 1,775$ HOLDREN FRANKLIN SIMON GREENSTONE 1,000$ HALL RICHARD SIMON GREENSTONE 1,000$ ALTHAUSEN WALTER SIMON GREENSTONE 1,000$ OCONNOR JOHN SIMON GREENSTONE 1,000$ ANDERSON DAVID SIMON GREENSTONE 1,000$ DYER JERRY SIMON GREENSTONE 1,000$ MUNOZ MARTHA SIMON GREENSTONE 1,000$ ALLEN JOHN SIMON GREENSTONE 1,000$ REASER ROBERT SIMON GREENSTONE 1,000$ VAUGHT JAMES SIMON GREENSTONE 1,000$ TUNISON CLARK SIMON GREENSTONE 1,000$ OROZCO HENRY SIMON GREENSTONE 1,000$ JOHNSTON JOHNNY SIMON GREENSTONE 1,000$ HOWARD JAMES SIMON GREENSTONE 1,000$ RODEN STEPHEN SIMON GREENSTONE 1,000$ MULCAHY JOHN SIMON GREENSTONE 1,000$ EVANS DAVID SIMON GREENSTONE 1,000$ WEBSTER WILLIAM SIMON GREENSTONE 1,000$ LABRENZ CLARA SIMON GREENSTONE 1,000$ PARKER HARVEY SIMON GREENSTONE 1,000$ RICH WALTER SIMON GREENSTONE 1,000$

63




Last Name First Name Lawyer Settlement offerZITO ANGELO SIMON GREENSTONE 1,000$ SUMNER PAUL SIMON GREENSTONE 1,000$ WILLIS CHARLES SIMON GREENSTONE 1,000$ WOEPPEL DALE SIMON GREENSTONE 1,000$ CARVER MICHAEL SIMON LAWFIRM 1,000$ WOTNOSKE MAX SIMON LAWFIRM 1,000$ SPONSLER GREGORY SIMON LAWFIRM 1,000$ KLAPPERICH JOSEPHINE SIMON LAWFIRM 1,000$ TAYLOR GENE SIMON LAWFIRM 1,000$ BERNATOWICZ FRED SPANGENBERG SHIBLEY TRACI LANCIONE 21,782$ TUTEN GOWIN SPEIGHTS RUNYAN 53,971$ CORBIN LUTHER SPEIGHTS RUNYAN 9,076$ STREBLER GERALD STARK KNOLL CO 2,699$ GUIDON CHARLES STEVEN COOPERSTEIN 1,000$ THOMPSON RICHARD STUART CALWELL 54,738$ OSTEN PETER STUART CALWELL 4,870$ GOFF LEONARD STUART CALWELL 1,000$ BURGESS CHARLES STUART CALWELL 1,000$ RUEHLING HURL SUMMERS WYATT 19,116$ BUCKNER DOROTHY SUMMERS WYATT 15,860$ CARPENTER JAMES SUMMERS WYATT 6,763$ JOHNSON CLYDE SUTTER ENSLEIN 35,017$ MCINTYRE EUGENE SUTTER ENSLEIN 13,545$ NEWMAN CLEVELAND TATE MARK 13,230$ HESSLER WILLIAM TAYLOR CAMPBELL 1,000$ HENDERSON ROBERT TAYLOR CIRE 1,000$ WILLIAMS ROBERT TAYLOR CIRE 1,000$ HOLLOWAY DERYL TERRELL HOGAN 186,105$ NEWMAN JAMES TERRELL HOGAN 173,426$ ASH DAVID TERRELL HOGAN 26,076$ STAIER JOSEPH TERRELL HOGAN 9,576$ HILL EUGENE TERRELL HOGAN 9,154$ LEHMAN ROBERT TERRELL HOGAN 6,125$ KERCHEVAL BLANCHE TERRELL HOGAN 4,998$ GROCE RUBY TERRELL HOGAN 1,000$ ANTOINE FRANCIS THOMAS ALKON 1,000$ BOYLE J THORNTON NAUMES 127,637$ WENYON LEONARD THORNTON NAUMES 49,155$ BROOKS DOROTHY THORNTON NAUMES 35,986$ NORBUT JOSEPH THORNTON NAUMES 32,457$ SPELLBERG MICHAEL THORNTON NAUMES 31,644$ WIRWICZ ROBERT THORNTON NAUMES 31,442$ HICKEY MICHAEL THORNTON NAUMES 27,639$ GRIGG ROBERT THORNTON NAUMES 25,942$ MILNER RICHARD THORNTON NAUMES 22,386$ BROWN WILLIAM THORNTON NAUMES 17,188$ SILVERIO RICHARD THORNTON NAUMES 16,435$ ROLLINS EDWARD THORNTON NAUMES 15,286$ HAUN RICHARD THORNTON NAUMES 14,968$ JERABEK CHARLES THORNTON NAUMES 12,575$ MORSE LAURENCE THORNTON NAUMES 12,573$ PLASSE ROGER THORNTON NAUMES 12,533$ LITTLE CHARLES THORNTON NAUMES 10,990$ COHAN ARTHUR THORNTON NAUMES 10,220$ DEAL RICHARD THORNTON NAUMES 10,149$ COLE HAROLD THORNTON NAUMES 9,720$

64




Last Name First Name Lawyer Settlement offerBARRETT WILLIAM THORNTON NAUMES 9,238$ PICARD THOMAS THORNTON NAUMES 9,145$ CLAVEAU JUDITH THORNTON NAUMES 8,570$ GIARRUSSO WILLIAM THORNTON NAUMES 7,890$ URBAN ALFRED THORNTON NAUMES 7,043$ CAPUANO BENNIE THORNTON NAUMES 6,706$ FORSYTH JOHN THORNTON NAUMES 5,955$ MASON DOUGLAS THORNTON NAUMES 5,773$ BELLEGARDE ROLAND THORNTON NAUMES 5,483$ ZAJAC ALPHONSE THORNTON NAUMES 5,288$ CEDRONE CARMELO THORNTON NAUMES 5,135$ DERRAH DONALD THORNTON NAUMES 4,717$ BANKS EDWIN THORNTON NAUMES 4,049$ WISE CLIFFORD THORNTON NAUMES 4,017$ STEWARD JOHN THORNTON NAUMES 3,530$ ABROMEIT RICHARD THORNTON NAUMES 3,220$ OLSON ERIC THORNTON NAUMES 2,421$ RICHELLI AIDO THORNTON NAUMES 1,902$ SMITH WILLIAM THORNTON NAUMES 1,000$ LEWIS NORINE THORNTON NAUMES 1,000$ BOLDUC FERNAND THORNTON NAUMES 1,000$ MORVANT ARTNEY TYNER MITCHELL 9,076$ REASER ROBERT UNKNOWN 16,161$ WILSON CHARLES UNKNOWN 14,314$ MCDADE HAROLD UNKNOWN 6,573$ BURGAN GROVER UNKNOWN 5,277$ DONALDSON JIMMIE UNKNOWN 4,235$ BREWER PATRICK UNKNOWN 1,000$ SHEPARD CHARLES UNKNOWN 1,000$ WILCOXSON ROBERT UNKNOWN 1,000$ WATTS CLARENCE UNKNOWN 1,000$ SPENCE HARMAN UNKNOWN 1,000$ ELDRIDGE NEAL UNKNOWN 1,000$ RICHARDSON BEVERLY UNKNOWN 1,000$ PHILLIPS WILLIAM UNKNOWN 1,000$ COPELAN HERMAN UNKNOWN 1,000$ MARSECO ANTHONY UNKNOWN 1,000$ NOTTOLI VICTOR UNKNOWN 1,000$ FURLAN LOUIS UNKNOWN 1,000$ PHILLIPS JOSEPH UNKNOWN 1,000$ MCCOY WILLIAM UNKNOWN 1,000$ WEST GORDON UNKNOWN 1,000$ OTT LAWRENCE UNKNOWN 1,000$ VERBICKY JOHN UNKNOWN 1,000$ GETTLE JOHN UNKNOWN 1,000$ DODGEN RALPH UNKNOWN 1,000$ THERIAULT ROBERT UNKNOWN 1,000$ SCOTT ALLAN UNKNOWN 1,000$ JACKSON RICHARD UNKNOWN 1,000$ SCORE DOMINICK UNKNOWN 1,000$ YATES JOHNNY UNKNOWN 1,000$ SACK ANTHONY UNKNOWN 1,000$ BRIGGS THOMAS UNKNOWN 1,000$ YOST JOHN UNKNOWN 1,000$ JANSEMA DIRK UNKNOWN 1,000$ KRAUSS HENRY UNKNOWN 1,000$

65




Last Name First Name Lawyer Settlement offerSTANICH NICK UNKNOWN 1,000$ WORTHINGTON LEE UNKNOWN 1,000$ PEARN JACK UNKNOWN 1,000$ ALTHOUSE EDGAR UNKNOWN 1,000$ JOHNSEN GEORGE UNKNOWN 1,000$ STOTTS LARRY UNKNOWN 1,000$ HAWKINS KATHLEEN UNKNOWN 1,000$ HANDY CHARLES UNKNOWN 1,000$ LEE HOLLIS UNKNOWN 1,000$ NISI LOIS UNKNOWN 1,000$ RUSSELL JOHN UNKNOWN 1,000$ KIELBASA STANISLAWA UNKNOWN 1,000$ FIORE LEONARD UNKNOWN 1,000$ KING JAMES UNKNOWN 1,000$ SAVOY GEORGE UNKNOWN 1,000$ LICHTENWALNER ELAINE UNKNOWN 1,000$ PINEAU FRANCIS UNKNOWN 1,000$ DUKE LESLIE UNKNOWN 1,000$ PORTER RICHARD UNKNOWN 1,000$ BURCHFIELD VIRGINIA UNKNOWN 1,000$ ZEIT RUTH UNKNOWN 1,000$ PRATER WILLIAM UNKNOWN 1,000$ ROSAMOND FLOYD UNKNOWN 1,000$ WARSZAWSKI JOHN UNKNOWN 1,000$ ZILLMER HOWARD UNKNOWN 1,000$ GODFREY MICHAEL UNKNOWN 1,000$ NELSON IRVIN UNKNOWN 1,000$ BORREGO GEORGE UNKNOWN 1,000$ CARTER WILLIAM UNKNOWN 1,000$ WILSON DAVID UNKNOWN 1,000$ DEMARCUS JOHN UNKNOWN 1,000$ STABLEY RONALD UNKNOWN 1,000$ LEBLUE LEROY UNKNOWN 1,000$ BROWN ROY UNKNOWN 1,000$ THOMPSON JOHN UNKNOWN 1,000$ WATSON WILLIE UNKNOWN 1,000$ CHARNOKI JOSEPH UNKNOWN 1,000$ BLENKINSOP ROBERT UNKNOWN 1,000$ THAMES BENJAMIN UNKNOWN 1,000$ MCRAY WILLIAM UNKNOWN 1,000$ KEAN RAY UNKNOWN 1,000$ JASON LOUIS UNKNOWN 1,000$ POSS AMBROSE UNKNOWN 1,000$ DAVIS ROBERT UNKNOWN 1,000$ FOLEY C UNKNOWN 1,000$ PASKO EDWARD UNKNOWN 1,000$ DONELY ALLEN UNKNOWN 1,000$ MUSCARELLI HARRY UNKNOWN 1,000$ LOVITTO WALTER UNKNOWN 1,000$ WETTSTEIN WILLIAM UNKNOWN PLAINTIFF LAW FIRM 1,000$ RHODEN DAVID VARAS MORGAN 1,000$ HOBBS WILBERT WALLACE GRAHAM 49,222$ HELMS TERRY WALLACE GRAHAM 14,717$ WHITE LAWRENCE WALLACE GRAHAM 8,258$ SUTTON FLOYD WALLACE GRAHAM 6,920$ CAMPBELL DONALD WALLACE GRAHAM 1,000$

66




Last Name First Name Lawyer Settlement offerSCHAB GEORGE WARTNICK CHABER / HAROWITZ TIGERMAN 70,604$ LOPEZ THOMAS WARTNICK CHABER / HAROWITZ TIGERMAN 42,295$ BARNES BENNIE WARTNICK CHABER / HAROWITZ TIGERMAN 37,596$ DONLON PATRICK WARTNICK CHABER / HAROWITZ TIGERMAN 28,457$ VELIKANEYE JOSEPH WARTNICK CHABER / HAROWITZ TIGERMAN 24,062$ LUKA RICHARD WARTNICK CHABER / HAROWITZ TIGERMAN 15,511$ SOPRITO JOSEPHINE WARTNICK CHABER / HAROWITZ TIGERMAN 14,992$ REYNOLDS EVEA WARTNICK CHABER / HAROWITZ TIGERMAN 13,202$ WARREN HOWARD WARTNICK CHABER / HAROWITZ TIGERMAN 10,314$ NINE BARBARA WARTNICK CHABER / HAROWITZ TIGERMAN 5,963$ ROBERTS JEANNE WARTNICK CHABER / HAROWITZ TIGERMAN 4,793$ PALMER RONALD WARTNICK CHABER / HAROWITZ TIGERMAN 3,936$ SHAFFER RONALD WARTNICK CHABER / HAROWITZ TIGERMAN 1,002$ RUBINO CARMINE WARTNICK CHABER / HAROWITZ TIGERMAN 1,000$ DEMERSSEMAN CLEON WATERS KRAUS 95,808$ PEAVY HIRAM WATERS KRAUS 94,187$ STONE JAMES WATERS KRAUS 85,131$ FREEMAN JOE WATERS KRAUS 81,757$ ADLER ROGER WATERS KRAUS 77,071$ CONNER ROBERT WATERS KRAUS 76,844$ CONTRERAS HERMAN WATERS KRAUS 75,018$ COFFEY DOROTHY WATERS KRAUS 50,837$ NICHOLAS LEROY WATERS KRAUS 49,795$ STEVENS MICHAEL WATERS KRAUS 49,330$ CHALER CHARLES WATERS KRAUS 47,446$ HARTSFIELD FREDERICK WATERS KRAUS 46,520$ CHABOUDY ROBERT WATERS KRAUS 40,639$ PRANGE JAMES WATERS KRAUS 37,140$ CHRISTOPHER PHILLIP WATERS KRAUS 27,681$ MITCHELL JUDITH WATERS KRAUS 25,452$ THORNTON TAMMY WATERS KRAUS 23,263$ BLACK TIMMY WATERS KRAUS 21,272$ ADLER SANDRA WATERS KRAUS 19,409$ FLOYD BOBBY WATERS KRAUS 19,056$ DELLINGER DOUGLAS WATERS KRAUS 14,276$ BEIREMANN HARRY WATERS KRAUS 11,410$ CARDEN EDWARD WATERS KRAUS 11,325$ NELSON ROBERT WATERS KRAUS 11,313$ ROHR JOHN WATERS KRAUS 9,617$ HENSLEY EARL WATERS KRAUS 9,115$ BANGAOIL JIMMY WATERS KRAUS 8,801$ HUTCHINS DONALD WATERS KRAUS 8,629$ GRAMMER KENNETH WATERS KRAUS 8,389$ WEST KEITH WATERS KRAUS 7,125$ ZERDA KENNETH WATERS KRAUS 6,646$ TALBOTT WILLIAM WATERS KRAUS 6,606$ FLORIO GAIL WATERS KRAUS 5,972$ BRICKEY PHILIP WATERS KRAUS 5,415$ MOSSMAN ALLEN WATERS KRAUS 3,955$ WOLFF JULIAN WATERS KRAUS 1,000$ THAUT RODNEY WATERS KRAUS 1,000$ THIEBAULT EDWARD WATERS KRAUS 1,000$ WOLFF FRED WATERS KRAUS 1,000$ KOEBERLE JOHN WATERS KRAUS 1,000$ DOMBROWSKI ROBERT WATERS KRAUS 1,000$ LANPHER DAVID WATERS KRAUS 1,000$

67




Last Name First Name Lawyer Settlement offerLAVIGNE NADYNE WATERS KRAUS 1,000$ DOUGLAS RONNY WATERS KRAUS 1,000$ GARCIA RAMON WATERS KRAUS 1,000$ SUNDAY JOHN WATERS KRAUS 1,000$ TRETTE ORVILLE WATERS KRAUS 1,000$ DUNCAN CHARLES WATERS KRAUS 1,000$ ERICKSON ALICE WATERS KRAUS 1,000$ BARD JAMES WATERS KRAUS 1,000$ SCHUMACHER JOHN WATERS KRAUS 1,000$ WARDEN KENNETH WATERS KRAUS 1,000$ ECHAVES FREDDY WATERS KRAUS 1,000$ COCKRILL RAYMOND WATERS KRAUS 1,000$ HORN ROBERT WATERS KRAUS 1,000$ HALL PATRICIA WATERS KRAUS 1,000$ WICKER BENJAMIN WATERS KRAUS 1,000$ JANKOWSKI RICHARD WEITZ LUXENBERG 116,310$ KLIMBACK JAMES WEITZ LUXENBERG 113,316$ SABA DAVID WEITZ LUXENBERG 79,792$ FAN WEICHI WEITZ LUXENBERG 73,111$ COLACHINO LOUIS WEITZ LUXENBERG 69,316$ BELVICK RICHARD WEITZ LUXENBERG 67,486$ FAUL NORMAN WEITZ LUXENBERG 67,112$ SEEMAN THOMAS WEITZ LUXENBERG 65,487$ SMITH KENNETH WEITZ LUXENBERG 64,872$ OCONNOR GEORGE WEITZ LUXENBERG 57,856$ CZUKIEWSKI JOZEF WEITZ LUXENBERG 53,569$ OMARA DESMOND WEITZ LUXENBERG 53,391$ PALZER KARL WEITZ LUXENBERG 53,196$ FREUND CHARLES WEITZ LUXENBERG 50,774$ ANDREWS JOAN WEITZ LUXENBERG 50,592$ PETERS GEORGE WEITZ LUXENBERG 47,116$ BEMESDERFER LILLIAN WEITZ LUXENBERG 44,807$ RIVADENEYRA MARIO WEITZ LUXENBERG 41,137$ ROSE WILLIAM WEITZ LUXENBERG 35,526$ FARLEY TONA WEITZ LUXENBERG 31,644$ MILLER CARL WEITZ LUXENBERG 26,116$ OLSON ARLAND WEITZ LUXENBERG 23,136$ RUSSANO GENNARO WEITZ LUXENBERG 22,133$ RYBICKI RONALD WEITZ LUXENBERG 21,500$ SMYTH THOMAS WEITZ LUXENBERG 21,047$ MANECKE DEAN WEITZ LUXENBERG 20,040$ VERALDO RANDY WEITZ LUXENBERG 18,633$ CRUZ VICTOR WEITZ LUXENBERG 17,140$ PARKER STEWART WEITZ LUXENBERG 16,740$ PASHA ALAMIN WEITZ LUXENBERG 16,626$ FOUCHA RAYMOND WEITZ LUXENBERG 16,345$ GETTY BARBARA WEITZ LUXENBERG 15,569$ VILLAFLOR JUAN WEITZ LUXENBERG 15,569$ HERNANDEZ JORGE WEITZ LUXENBERG 15,568$ EASTON CYNTHIA WEITZ LUXENBERG 15,322$ SPARTA LAWRENCE WEITZ LUXENBERG 13,692$ CARROLL THOMAS WEITZ LUXENBERG 13,645$ WITMAN LARRY WEITZ LUXENBERG 12,797$ HAAS KENNETH WEITZ LUXENBERG 12,162$ DENNIS GEORGE WEITZ LUXENBERG 11,857$ RUGGLES WILLIAM WEITZ LUXENBERG 11,811$

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Last Name First Name Lawyer Settlement offerWHITAKER DONALD WEITZ LUXENBERG 11,363$ WADDELL RICHARD WEITZ LUXENBERG 11,297$ GONZALEZ ISMENIA WEITZ LUXENBERG 10,826$ TINSLEY LARRY WEITZ LUXENBERG 10,708$ SHIRLEY JAMES WEITZ LUXENBERG 10,447$ BECHTEL JOSEPH WEITZ LUXENBERG 10,185$ TOULANTIS TERRY WEITZ LUXENBERG 10,150$ CARRIER VIVIAN WEITZ LUXENBERG 9,679$ PICINICH IVAN WEITZ LUXENBERG 9,316$ BOGERMAN RONALD WEITZ LUXENBERG 9,316$ MCCALLY ROBERT WEITZ LUXENBERG 9,144$ PUZA STANLEY WEITZ LUXENBERG 9,127$ SCHRANK CHARLOTTE WEITZ LUXENBERG 8,756$ UHE DONALD WEITZ LUXENBERG 8,596$ DRESSLER WILLIAM WEITZ LUXENBERG 8,318$ GLOUNER GARY WEITZ LUXENBERG 8,303$ JOHNSON DWIGHT WEITZ LUXENBERG 8,176$ HOLBROOK DONALD WEITZ LUXENBERG 8,027$ NEUBIG NORMAN WEITZ LUXENBERG 7,840$ CALVIN CHARLES WEITZ LUXENBERG 7,598$ BLANK CLIFFORD WEITZ LUXENBERG 7,456$ DEITZ CHARLES WEITZ LUXENBERG 7,208$ FIRMIN DALE WEITZ LUXENBERG 7,205$ AUCOIN THOMAS WEITZ LUXENBERG 7,172$ COPPOLA FRANK WEITZ LUXENBERG 7,168$ AMSLER ROBERT WEITZ LUXENBERG 6,827$ WILKINSON THOMAS WEITZ LUXENBERG 6,258$ KUTKO ANDREW WEITZ LUXENBERG 6,180$ MACHADO JOHN WEITZ LUXENBERG 6,081$ BURROWS EDWARD WEITZ LUXENBERG 5,800$ POWELL JOHN WEITZ LUXENBERG 5,786$ VIKELIS JOHN WEITZ LUXENBERG 5,645$ CASS ORISON WEITZ LUXENBERG 5,551$ BOURGALT LEO WEITZ LUXENBERG 5,383$ MCGUINESS JACK WEITZ LUXENBERG 5,354$ ZIMBERG SHELDON WEITZ LUXENBERG 4,847$ SANTOMAURO ALEXANDER WEITZ LUXENBERG 4,742$ SINGER WARREN WEITZ LUXENBERG 4,214$ DOBSON GILBERT WEITZ LUXENBERG 3,814$ BULL JAMES WEITZ LUXENBERG 3,745$ BAIRD HAROLD WEITZ LUXENBERG 3,587$ CABALLERO MIGUEL WEITZ LUXENBERG 3,470$ BARTELL RICHARD WEITZ LUXENBERG 3,121$ DEVINE HARRY WEITZ LUXENBERG 3,086$ STEINBERG LEON WEITZ LUXENBERG 2,557$ BUFFUM GENE WEITZ LUXENBERG 2,380$ GENSLER JOEL WEITZ LUXENBERG 2,063$ LOFASO JOHN WEITZ LUXENBERG 2,027$ MEYER ROCHELLE WEITZ LUXENBERG 1,742$ FIPPINGER CARMELLA WEITZ LUXENBERG 1,204$ LEHNERT ROBERT WEITZ LUXENBERG 1,000$ DELLARCIPRETE ALBERT WEITZ LUXENBERG 1,000$ HARVAN PAUL WEITZ LUXENBERG 1,000$ DACQUISTO JACK WEITZ LUXENBERG 1,000$ HIGHT WILLIAM WEITZ LUXENBERG 1,000$ DELGROSSO CONSTANCE WEITZ LUXENBERG 1,000$

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Last Name First Name Lawyer Settlement offerCOTTEN LLOYD WEITZ LUXENBERG 1,000$ FREEMAN WILBURN WEITZ LUXENBERG 1,000$ PERRINO ANTONIO WEITZ LUXENBERG 1,000$ WANNER WALTER WEITZ LUXENBERG 1,000$ PUSKULIAN NOUBAR WEITZ LUXENBERG 1,000$ FOOSE RALPH WEITZ LUXENBERG 1,000$ HOVERMALE HUGH WEITZ LUXENBERG 1,000$ SALTZMAN AUDREY WEITZ LUXENBERG 1,000$ BRIGGIN ALEX WEITZ LUXENBERG 1,000$ BONELLI NANCY WEITZ LUXENBERG 1,000$ FRISONE JOHN WEITZ LUXENBERG 1,000$ PLUHOWSKI STANLEY WEITZ LUXENBERG 1,000$ LUCAS ANTONIO WEITZ LUXENBERG 1,000$ SCHINELLA ALDO WEITZ LUXENBERG 1,000$ FIGUEIREDO CELESTINO WEITZ LUXENBERG 1,000$ ONEIL JACK WELLBORN HOUSTON ADKISON MANN SADLER 1,000$ BROWN HAROLD WELLBORN HOUSTON ADKISON MANN SADLER 1,000$ WARNER ALTON WELLBORN HOUSTON ADKISON MANN SADLER 1,000$ LEONE JAMES WESTMORELAND INJURY LAWYERS 1,000$ PECK WAYNE WESTON CASEY HARRIS 1,000$ LEROUX THOMAS WILENTZ GOLDMAN 98,182$ DENATALE FRANK WILENTZ GOLDMAN 59,511$ GOURLEY EUGENE WILENTZ GOLDMAN 52,962$ SLIVKA GEORGE WILENTZ GOLDMAN 51,556$ PUPPO PATRICK WILENTZ GOLDMAN 51,239$ SIEGEL NORMAN WILENTZ GOLDMAN 45,254$ GUTKOWSKI THADDEUS WILENTZ GOLDMAN 42,415$ ALANCOURT JOHN WILENTZ GOLDMAN 40,177$ WOOD ALLEN WILENTZ GOLDMAN 34,449$ SHAW ROBERT WILENTZ GOLDMAN 31,613$ BRADBURY RICHARD WILENTZ GOLDMAN 27,298$ BROSIE DIANA WILENTZ GOLDMAN 26,306$ MIGLIACCIO JOHN WILENTZ GOLDMAN 22,955$ GRIOLI ANTONIO WILENTZ GOLDMAN 21,981$ FLYNN JAMES WILENTZ GOLDMAN 20,095$ JONES WEBSTER WILENTZ GOLDMAN 18,439$ FOGARTY ROBERT WILENTZ GOLDMAN 18,369$ MRUK JOSEPH WILENTZ GOLDMAN 17,940$ MASSARO ANTHONY WILENTZ GOLDMAN 17,602$ LANCELLOTTI VINCENZO WILENTZ GOLDMAN 17,044$ DIGIAIMO FRANK WILENTZ GOLDMAN 15,119$ HIGGINS JAMES WILENTZ GOLDMAN 14,809$ NOVEMBRE THOMAS WILENTZ GOLDMAN 12,395$ RIPIC JAMES WILENTZ GOLDMAN 11,786$ WILLIAMS THOMAS WILENTZ GOLDMAN 11,731$ THIEDE ROBERT WILENTZ GOLDMAN 11,690$ SANDERS CLARENCE WILENTZ GOLDMAN 10,994$ DONNELLY FRANCIS WILENTZ GOLDMAN 10,825$ MCGOWAN JAMES WILENTZ GOLDMAN 10,641$ RIDGWAY ALAN WILENTZ GOLDMAN 10,492$ CINQUEMANI SALVATORE WILENTZ GOLDMAN 9,128$ RODRIGUEZ JUAN WILENTZ GOLDMAN 8,618$ MARTIN ROBERT WILENTZ GOLDMAN 8,584$ SIEGEL ISRAEL WILENTZ GOLDMAN 7,917$ NORTON GEORGE WILENTZ GOLDMAN 7,587$ STEELE EARLE WILENTZ GOLDMAN 7,535$

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Last Name First Name Lawyer Settlement offerMCGOLDRICK JOHN WILENTZ GOLDMAN 5,910$ PEREZ JOSE WILENTZ GOLDMAN 5,502$ FOLEY JOAN WILENTZ GOLDMAN 5,290$ VENIER ANDREW WILENTZ GOLDMAN 5,249$ BUCK KENNETH WILENTZ GOLDMAN 4,957$ LOGAN DENNIS WILENTZ GOLDMAN 4,952$ OLSIAN JOSEPH WILENTZ GOLDMAN 4,948$ HERB RICHARD WILENTZ GOLDMAN 4,441$ SWEENEY HUGH WILENTZ GOLDMAN 4,436$ LANGBORGH HOWARD WILENTZ GOLDMAN 4,078$ PINTO JOHN WILENTZ GOLDMAN 3,887$ MONELLO JOSEPH WILENTZ GOLDMAN 3,117$ MOSKOWITZ ALLEN WILENTZ GOLDMAN 3,036$ LAWLER STELLA WILENTZ GOLDMAN 2,942$ MOTTERSHEAD GEORGE WILENTZ GOLDMAN 2,794$ ROMAN JOSEPH WILENTZ GOLDMAN 2,083$ TALLMAN FLOYD WILENTZ GOLDMAN 1,621$ OSUCH ROBERT WILENTZ GOLDMAN 1,058$ GOLDSTEIN JACOB WILENTZ GOLDMAN 1,000$ GRAHAM SHARON WILENTZ GOLDMAN 1,000$ COLE CHARLES WILENTZ GOLDMAN 1,000$ LOW PETRINA WILENTZ GOLDMAN 1,000$ GARCIA JUAN WILENTZ GOLDMAN 1,000$ WORTAS PHILIP WILENTZ GOLDMAN 1,000$ BLACKWELL ROBERT WILLIAMS KHERKHER HART BOUNDAS 34,702$ PAGNAC EUGENE WILLIAMS KHERKHER HART BOUNDAS 18,787$ TETTLETON LONNIE WILLIAMS KHERKHER HART BOUNDAS 16,418$ BERRYHILL GROVER WILLIAMS KHERKHER HART BOUNDAS 13,685$ RICHARD CARL WILLIAMS KHERKHER HART BOUNDAS 12,573$ MONROE ROBERT WILLIAMS KHERKHER HART BOUNDAS 7,987$ SLAUGHTER JOHNNIE WILLIAMS KHERKHER HART BOUNDAS 7,718$ DUNCAN LEONARD WILLIAMS KHERKHER HART BOUNDAS 4,294$ ODONNELL VENCIL WILLIAMS KHERKHER HART BOUNDAS 3,726$ GARCIA NASARIO WILLIAMS KHERKHER HART BOUNDAS 2,905$ HOWARD ROBERT WILLIAMS KHERKHER HART BOUNDAS 1,000$ HARRIS JAMES WILLIAMS KHERKHER HART BOUNDAS 1,000$ DOBELL JUDY WILLIAMS TRINE 10,150$ HARTMAN ARTHUR WYLDER CORWIN KELLY 61,157$ BARDEN FREDA WYLDER CORWIN KELLY 16,676$ CARAKER BILLIE WYLDER CORWIN KELLY 7,056$ ADAMS GEORGE WYLDER CORWIN KELLY 5,188$ SHOOPMAN NORMAN WYLDER CORWIN KELLY 1,000$ WALLACE ULYSSES WYSOKER GLASSNER 1,000$ CIANCIA RICHARD WYSOKER GLASSNER 1,000$ GRAY HARLEY YOUNG REVERMAN 1,000$ COTTRELL RICHARD ZAMLER MELLEN 62,108$ CAMPAU RICHARD ZAMLER MELLEN 54,372$ ONEILL JAMES ZAMLER MELLEN 46,873$ RETTMANN JAMES ZAMLER MELLEN 16,908$ TIEMANN HERBERT ZAMLER MELLEN 3,628$

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EXHIBIT C

Case 10-31607 Doc 4865-3 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. C-GST Resps to 1st ACC Confirmation Rogs Page 1 of 27

UNITED STATES BANKRUPTCY COURTFOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

IN RE:GARLOCK SEALING TECHNOLOGIES LLC, et al.,

Debtors.


Chapter 11


DEBTORS’ RESPONSES TO OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS’

FIRST SET OF INTERROGATORIES DIRECTED TO THE DEBTORS REGARDING CONFIRMATION ISSUES

Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group,

Ltd., and The Anchor Packing Company (“Debtors”), pursuant to Federal Rules of Civil

Procedure 26 and 33, and Federal Rules of Bankruptcy Procedure 7026, 7033, and 9014, by and

through counsel, hereby respond and object (these “Responses”) to the Official Committee of

Asbestos Personal Injury Claimants’ First Set of Interrogatories Directed to the Debtors

Regarding Confirmation Issues. Below, Debtors set forth their Specific Responses and

Objections to each of the Interrogatories. These Specific Responses and Objections are subject

to and incorporate Debtors’ General Responses and Objections (“General Objections”) and

Definitions, which are attached as Exhibit A.

SPECIFIC RESPONSES AND OBJECTIONS TO INTERROGATORIES

1. Separately for Garlock and Anchor, and separately for (a) closed or resolved claims, and (b) pending claims filed after December 31, 2005, please provide the following information: Do the Debtors contend that Non-meso Cancer PI Claims or Non-malignant PI Claims have been the subject of suppression, withholding, or misrepresentation of evidence of exposure to Asbestos-containing Products on the part of Asbestos Claimants or their counsel? If the answer is anything but an unqualified “no,” then:

a. Identify each Asbestos Claimant whose claim has been the subject of such suppression, withholding, or misrepresentation of evidence of exposure to Asbestos-containing Products;


2

b. Identify all persons with knowledge of the alleged suppression, withholding, or misrepresentation of evidence; and

c. If the claim has been resolved, describe and quantify the effect of the alleged suppression, withholding, or misrepresentation of evidence on the resolution of the claim.

RESPONSE: Settled and Pending Non-Mesothelioma Claims. Based on the fact that

suppression of evidence occurred in mesothelioma litigation against Debtors, Debtors suspect

that some settled non-mesothelioma claims may also have been the subject of suppression,

withholding, or misrepresentation of exposure to asbestos-containing products, but Debtors do

not plan to advance that contention with respect to settled non-mesothelioma claims in support of

confirmation of the Plan. To estimate the aggregate allowed amount of non-mesothelioma

claims, Debtors will present a legal liability approach that depends on the characteristics of the

claims, including facts such as claimant diagnosis, exposure history, age, and other relevant

factors. Debtors will prove the feasibility of the Plan with respect to non-mesothelioma claims by

determining the payments claimants would be entitled to receive under the Plan and showing that

the amount of Plan funding is sufficient to cover such payments. As a result, Debtors have not

undertaken an investigation of the extent to which evidence was suppressed in non-mesothelioma

cases Debtors settled. Discovery into (among other topics) Trust claims filed by such claimants

would be necessary to assess fully the extent to which evidence suppression occurred in such

cases. For the same reason, Debtors do not plan to advance contentions regarding suppression of

exposure evidence in pending non-mesothelioma claims, and have not undertaken an

investigation of whether any such suppression occurred.

Debtors reserve the right, however, to contend that evidence suppression occurred with

respect to settled non-mesothelioma claims, and offer evidence to support such a contention, to

rebut contentions the Committee may make in opposition to the Plan. In particular, if the


3

Committee offers evidence of some of Garlock’s historical settlements in connection with the

Committee’s positions regarding the Plan (including in connection with the estimated aggregate

amount of allowed non-mesothelioma claims or the feasibility of the Plan), Debtors may decide

to rebut the Committee’s contentions with evidence that the resolutions of some of the non-

mesothelioma claims relied on by the Committee were affected by suppression, withholding, or

misrepresentation of evidence of exposure to asbestos-containing products on the part of asbestos

claimants or their counsel.

Debtors have served interrogatories on the Committee seeking information about its

contentions in opposition to the Plan. Among other things, Debtors have asked the Committee

whether it contends that any of Debtors’ historical settlements should be admitted into evidence

with respect to estimation of the aggregate validity or value of pending and future allowed non-

mesothelioma claims or the feasibility of the Plan and, if so, which historical non-mesothelioma

claims it will offer. Debtors will supplement their answer to this Interrogatory if necessary once

they obtain information regarding the Committee’s contentions and obtain any discovery

necessary to assess whether cases the Committee relies on were affected by suppression,

withholding, or misrepresentation of evidence of exposure to asbestos-containing products on the

part of asbestos claimants or their counsel.

Verdicts in Non-Mesothelioma Cases. Debtors have already contended in these Cases

that plaintiffs or their counsel (or both) suppressed, withheld, or misrepresented evidence of

exposure to other asbestos-containing products in the cases of Dexter and Robertson, and

Debtors still so contend. Both of these cases were tried to an adverse jury verdict and, for the

same reasons noted by the Court in its Estimation Opinion with respect to adverse mesothelioma

verdicts, the suppression of exposure evidence prejudiced Debtors’ defenses in those cases and


4

helped the plaintiff win a verdict. Debtors identified Dexter and Robertson on RFA Lists 1 and 2

during discovery prior to the Estimation Trial, and Robertson is the subject of proceedings

seeking relief from judgment initiated by Debtor GST in Kentucky state court (in which the

Committee has intervened as a party). Persons knowledgeable regarding the suppression,

withholding, or misrepresentation of evidence that Debtors have alleged include Kenneth L.

Sales, Esq., J. Robert Shelton, Esq., Joseph P. Satterly, Esq., and Dolores Ann Robertson.

Debtors have also asked the Committee whether it contends that any of Debtors’

historical trial verdicts should be admitted into evidence or otherwise relied upon with respect to

estimation of the aggregate validity or value of pending and future allowed non-mesothelioma

claims or the feasibility of the Plan and, if so, which trial verdicts it will offer. In addition,

Debtors are independently undertaking discovery to determine whether (and the extent to which)

plaintiffs or their trial counsel suppressed, withheld, or misrepresented evidence of alternative

exposures in cases that resulted in an adverse verdict. Debtors will supplement their answer to

this Interrogatory if necessary once they obtain discovery regarding other adverse verdict cases,

including cases identified by the Committee.

2. Separately for Garlock and Anchor, and separately for (a) closed or resolved claims, and (b) pending claims filed after December 31, 2005, please provide the following information: Do the Debtors contend that Non-meso Cancer PI Claims or Non-malignant PI Claims are or were based on a fraudulent or otherwise improper screening, diagnosis, or medical documentation of Asbestos-related Disease? If the answer is anything but an unqualified “no,” then:

a. Identify each Asbestos Claimant whose Non-meso Cancer PI Claim or Non-malignant PI Claim is or was based on fraudulent or otherwise improper screening, diagnosis, or medical information, and state the nature of the fraud, impropriety or other issue with the screening, diagnosis, or medical information;

b. Identify all persons with knowledge of the alleged fraud or impropriety; and


5

c. If the claim has been resolved, describe and quantify the effect of the fraud or impropriety on the resolution of the claim.

RESPONSE: First, for closed or resolved claims, Debtors believe that Garlock and

Anchor resolved tens of thousands, perhaps hundreds of thousands of non-mesothelioma claims

that were based on fraudulent or otherwise improper screenings, diagnoses, or medical

documentation. A full listing of affected claims would be impossible to compile, and in any

event would be unduly burdensome to produce and Debtors object to doing so. For instance,

between 1995 and 1999, Debtors paid on average 27,000 non-malignant asbestos claims per

year. Determining which of those claims were based on fraudulent or otherwise improper

screenings, diagnoses, or medical documentation would require collecting case files for tens of

thousands of claims, in files across the United States, which in many cases no longer exist.

At the confirmation hearing, Debtors will offer expert testimony that will describe in

general the nature of the improper practices that produced mass non-mesothelioma claims; the

impact of the practices on asbestos litigation; and the massive decline in such claims once those

improper practices were revealed. These practices were described by Professor Lester Brickman

in his testimony at the Estimation Trial and associated expert report, and have also been

described in more detail in Order No. 29: Addressing Subject-Matter Jurisdiction, Expert

Testimony and Sanctions, In re Silica Prods. Liab. Litig., MDL Docket No. 1553 (S.D. Tex. June

30, 2005) (the “Silica MDL Order”) and numerous publications by Professor Brickman, such as

Disparities Between Asbestosis and Silicosis Claims Generated by Litigation Screenings and

Clinical Studies, 29 Cardozo L. Rev. 513 (2007).

Debtors do not plan to quantify the effect of the fraud and impropriety on the resolution

of non-mesothelioma claims in their case-in-chief in support of confirmation of the Plan.

However, after learning whether the Committee will rely on particular past settlements or


6

verdicts in opposition to the Plan, as requested in Debtors’ discovery to the Committee, Debtors

may seek to determine whether it is possible to collect claim files for such cases, and may seek to

determine the effect of fraud, impropriety, or unreliable medical practices on resolution of such

claims in order to respond to the Committee’s contentions. Consistent with the Case

Management Order and applicable rules of procedure, Debtors will timely identify any such

documents.

In addition, with respect to pending non-mesothelioma claims filed after December 31,

2005, Debtors believe that numerous (and perhaps the vast majority of) such claims are the

product of unreliable medical diagnoses. Debtors believe that many such claims may be based on

fraudulent or otherwise improper screenings, diagnoses, or medical documentation. The specific

number of pending non-mesothelioma claims that are based on fraudulent or otherwise improper

screenings, diagnoses, or medical documentation cannot be known without further discovery and

investigation. Regardless of whether pending non-mesothelioma claims after December 31, 2005

are the product of misconduct, however, Debtors contend the majority of such claims are likely

based on unreliable medical support.

The Court has authorized Debtors to serve a subpoena on the Manville Trust that will

permit Debtors to obtain data relevant to this issue as well as copies of many pending claimants’

diagnoses and other medical documents related to their diagnoses. These documents will be

made available to the Committee, and expert opinions about these subjects will be disclosed to

the Committee in accordance with the Court’s Case Management Order.

The reliability of diagnoses of pending claims is relevant to several Plan confirmation

issues, including the estimation of the Allowed Amounts (as defined in the Plan) of the claims,

the settlement values of claims under the Plan’s CRP, and the feasibility of the Plan. Debtors


7

plan to offer expert testimony that will quantify the Allowed Amounts and CRP Values (as

defined in the Plan) of all pending non-mesothelioma claims, including such claims that are not

supported by reliable diagnoses or medical records.

Persons knowledgeable about this misconduct include: Tim Hennessy, Chris Drake,

Brian Henzel, Richard Magee, John Turlik, David Glaspy, Tom Tyner, Max Swetman, William

Mahoney, local defense counsel who represented Garlock (or Anchor) in the settlement of such

claims, plaintiffs’ counsel who represented such claimants, and physicians and screening

companies who participated in rendering unreliable diagnoses, including those identified in the

Silica MDL Order.

3. Separately for Garlock and Anchor, and separately for (a) claims settled for payment in the 1990s and (b) claims settled for payment after December 31, 1999, please provide the following information: Do the Debtors contend that settlements of Non-meso Cancer PI Claims or Non-malignant PI Claims were inflated because of defense costs? If the answer is anything but an unqualified “no,” then:

a. Identify each Asbestos Claimant whose settlement of a Non-meso Cancer PI Claim or Non-malignant PI Claim was inflated because of defense costs;

b. Identify all persons with knowledge of the factual basis of the alleged inflationary impact of defense costs on the resolution of the claim; and

c. Describe and quantify the effect of the defense costs on the resolution of the claim.

RESPONSE: The Court has already made findings in its Estimation Order that

Garlock’s settlements of asbestos claims were inflated by the cost of defense. Debtors object to

this Interrogatory to the extent it seeks to relitigate this issue.

The Court’s Estimation Order’s findings included:

72. Another factor also makes Garlock’s settlement amounts a dubious reflection of liability. One of the unique aspects of Asbestos injury litigation is its high cost to all parties. . . .


8

73. In addition, the time and effort required to prepare and try an Asbestos case is significant. Because of the number of defendants and the length of work history to be examined, the deposition of the plaintiff often requires weeks. Preparation also often requires extensive investigative efforts to determine the products to which the plaintiff was exposed during a forty-year work life.

74. . . . The overwhelming majority of cases Garlock settled were done in groups of large numbers of claims without real analysis of the “liability” to any individual claimant. . . . [T]he overwhelming majority of cases were settled in groups without regard to liability and virtually entirely for cost avoidance. Many cases ultimately were simply dismissed.

Estimation Order, 504 B.R. 71 at 87.

Consistent with these findings, Debtors contend that both before and after December 31,

1999, settlements of non-mesothelioma claims were inflated to avoid defense costs. For both

Garlock and Anchor, all asbestos claims, including both Non-meso Cancer PI Claims and Non-

malignant PI Claims (whether before or after December 31, 1999) that were settled, were settled

to a significant degree to avoid defense costs.

Debtors will refer to and rely on the Court’s previous findings at the confirmation

hearing. In addition, Debtors will present expert testimony describing and quantifying the effect

of avoidable defense costs on Debtors’ settlements of non-mesothelioma claims. Consistent with

the confirmation hearing Case Management Order and applicable rules of procedure, Debtors

will timely identify expert witnesses and provide applicable reports and supporting materials.

All settled non-mesothelioma claims are listed and identified in the Garlock Analytical

Database and FADA, and pursuant to Federal Rule of Bankruptcy Procedure 7033(d), Debtors

respond by directing the Committee to those records, which have already been produced.

Debtors have already identified persons knowledgeable about the effect of avoidable

defense costs on Garlock’s resolution of asbestos claims, many of whom provided testimony in

connection with the Estimation Trial, including Tim Hennessy, Chris Drake, Brian Henzel,

Richard Magee, John Turlik, David Glaspy, Melissa Ferrell, and William Mahoney. In addition,


9

expert witnesses testified about the effect of avoidable defense costs on resolution of asbestos

claims, including Dr. Bates and Dr. Peterson.

4. Explain how, before the Debtors filed bankruptcy, they quantified, recorded, and allocated defense costs for Asbestos PI Claims (including whether such costs were quantified, recorded, or allocated on a per-claim basis), and describe any changes in the Debtors’ practices over time.

RESPONSE: Debtors recorded amounts paid to each firm that represented and advised

Garlock in the defense of asbestos personal injury claims. Debtors aggregated these costs and

produced reports totaling the costs of defense among all of Debtors’ outside counsel. Debtors

did not track the costs of defending asbestos claims on a claim-by-claim basis, nor did they

segregate costs among claims of different disease types. To the extent Debtors desired to

calculate the costs of defense of a single claim, they would calculate those costs by reviewing

invoices from law firms and experts involved in the particular case and identifying and

segregating the fees and expenses directly attributable to the claim.

5. For the period 1990 through June 4, 2010, separately state on a yearly basis theDebtors’ aggregate costs of defending against (i) Non-malignant PI Claims, and (ii) Non-meso Cancer PI Claims.

RESPONSE: As explained above, Debtors did not separately record costs of defense by

claim or disease type. Debtors did compile defense costs on an annual basis for all claims.

Pursuant to Fed. R. Civ. P. 33(d), Debtors respond to this Interrogatory by reference to the

“Bluebook” documents produced to the Committee in response to Estimation Requests. Such

Bluebooks provide Debtors’ annual aggregate defense costs by year.

6. Do the Debtors contend that Garlock Asbestos-containing Products or Anchor Asbestos-containing Products cannot cause, or cannot substantially contribute to causing, any Asbestos-related Diseases other than pleural or peritoneal mesothelioma, including lung cancer,


10

laryngeal cancer, other cancers of the gastro-intestinal system, asbestosis, pleural effusions, pleural plaques, pleural thickening, pericardial mesothelioma, testicular mesothelioma, or any other Asbestos-related Disease or health condition associated with Asbestos? If the answer is anything but an unqualified “no,” then identify all Documents forming the factual basis for the contention.

RESPONSE: Garlock’s asbestos-containing products are not a cause of the development

of asserted asbestos-related diseases whether such asserted claims are mesothelioma claims, non-

mesothelioma malignant asbestos claims, or non-malignant asbestos claims.

The subject of this Interrogatory is the subject of anticipated expert testimony at the

confirmation hearing, and Debtors object to providing a response at this time. Consistent with


will timely identify expert witnesses and provide applicable reports and supporting materials.

7. Identify each individual whom Garlock or Anchor designated to testify as an expert witness with respect to any of the Causation Issues in connection with any Non-meso PI Claim, and, for each such individual, identify each Non-meso PI Claim in which Garlock or Anchor designated that individual to testify on any of the Causation Issues between January 1, 2000, and June 4, 2010.

RESPONSE: Debtors object to this Interrogatory as unduly burdensome because it calls

for Debtors to list every case in which an expert was merely designated—a response that would

require review of perhaps thousands of cases and a compilation of information Debtors did not

previously track. Notwithstanding the foregoing objection, attached as Exhibit B is a list of

persons who, according to a review of Debtors’ available records, were deposed or who testified

as Garlock’s designated expert witness in any Non-meso PI Claims about any of the Causation

Issues. Additionally, Debtors refer the Committee to the documents that they will produce in

response to Request 15, which may contain information about such testifying experts. Finally,

because Debtors’ investigation as to this Interrogatory is ongoing, Debtors will supplement their

answer if necessary as any additional responsive information is obtained.


11

8. Has Garlock or Anchor ever received an Asbestos PI Claim in which the injured person alleged pericardial or testicular mesothelioma? If so, identify the Asbestos Claimant, the disease and the Asbestos Claimant’s counsel, and describe the status of the claim, including, if resolved, the terms on which the claim was resolved.

RESPONSE: Debtors object to this Interrogatory because it appears to seek information

related to the estimation of asbestos-related mesothelioma personal injury claims which have

already been the subject of litigation and ruling in the Court’s Estimation Order.

Notwithstanding the foregoing objection, Debtors do not have knowledge or a

recollection that any claimant asserted, as the basis for his or her claim, pericardial or testicular

mesothelioma caused by exposure to asbestos products for which Debtors were responsible.

9. Identify all individuals who were substantially involved in, and describe their role in, determining the Maximum Settlements and Fixed Payments incorporated in the CRP, the factors by which and manner in which the Maximum Settlements will be discounted, the asbestos exposure elements incorporated into the CRP (including but not limited to the Occupation and Industry definitions, the GST Product Contact Requirement, the Contact Groups, the Contract Group Factor, the Contact Source Factor, and the Alternative Exposure Intensity Factor), and the medical elements incorporated into the CRP.

RESPONSE: The capitalized term “Fixed Payments” is not defined in these

Interrogatories and is vague and ambiguous. Debtors therefore object to the term.

Notwithstanding the foregoing objection, the Debtors respond that the only individuals

who were substantially involved in determining the CRP’s provision for the payment of

settlements to Settlement Option GST Asbestos Claimants were Richard Magee and Joseph

Grier. Mr. Magee and Mr. Grier relied on, respectively, Debtors’ counsel and FCR’s counsel,

and experts who advised them.

10. Identify and state the nature of each Released Claim, give the dates when the Debtors commenced and concluded an investigation into the Released Claims, identify the individuals who conducted the investigation, identify all individuals interviewed or questioned in the course of the investigation, identify all Documents reviewed in the course of the


12

investigation, and identify all Documents setting forth or discussing questions posed, issues identified, observations made, evidence compiled, analyses conducted, inferences drawn, or conclusions reached in or as a result of the investigation.

RESPONSE: Debtors object to this Interrogatory because it seeks privileged

information, including information subject to the attorney-client privilege and attorney work

product privilege. Debtors also object that this Interrogatory does not provide any time frame,

and will respond for the period commencing on the Petition Date.

Subject to and without waiver of the objections, the Released Claims are identified in and

defined by the Plan and include, without limitation all causes of action set forth in the proposed

complaint attached as Exhibit A to the Joint Motion of the Official Committee of Asbestos

Personal Injury Claimants and the Future Claims Representative for Leave to Control and

Prosecute Certain Claims as Estate Representatives [Docket No. 2150] (the “Proposed

Complaint”). The Debtors conducted an investigation into potential claims against their non-

debtor affiliates, including those listed in the Proposed Complaint, as well as the risks and

benefits to the Debtors’ estates that could result from the Debtors’ pursuit or a third party’s

pursuit of the claims set forth in the Proposed Complaint on the Debtors’ behalf, beginning no

later than April 12, 2012, and the investigation concluded no later than the date on which the

proposed Parent Settlement was agreed to. The investigation by the Debtors was carried out

primarily by the following attorneys, all with Rayburn Cooper & Durham, P.A.: C. Richard

Rayburn, Jr., Albert F. Durham, John R. Miller, Jr., Shelley K. Abel, William S. Smoak, Jr., and

Michelle Earp. These attorneys conducted the investigation through interviews with the Debtors

through Rick Magee, Don Pomeroy, Dan Grgurich, and Liz Barry. These attorneys also

consulted with attorneys with Robinson, Bradshaw & Hinson, P.A. The Debtors, through their

attorneys with Rayburn Cooper & Durham, P.A., reviewed a number of documents, including at

least: corporate constituent documents at 2005 and 2010, resolutions approving the 2005 and


13

2010 transactions, the 2005 transaction documents, the Duff & Phelps (then S&P) reports, the

2010 notes and negotiation communications, and the Proposed Complaint, and conducted their

own independent legal research on the elements of the alleged claims and defenses. The detail of

the Debtors’ and the Debtors’ attorneys’ legal research, conversations, and questions are

privileged and/or constitute protected work product. The Debtors’ conclusions regarding the

Released Claims are described in detail in Section 2.3.5.5 of the Disclosure Statement filed

January 16, 2015, beginning on page 22 of that document.

11. State whether Garlock or Anchor directly or indirectly supplied Asbestos - containing Products to any present or former Affiliate of the Debtors, including but not limited to EnPro Industries, Inc., Coltec Industries, Inc., Fairbanks Morse Pump, Fairbanks Morse Engine, Central Moloney Transformer, and Quincy Compressors. If the answer is anything but an unqualified “no,” identify any such Affiliate and, separately for each of them, identify the Asbestos-containing Products supplied, state when such supply transactions began and ended, and state the annual volume in units and dollars of the Asbestos-containing Products so supplied.

RESPONSE: Debtors object to this Interrogatory because it does not seek information

that is relevant to confirmation or reasonably calculated to lead to the discovery of admissible

evidence at the confirmation hearing. Instead, it seeks information relevant to asbestos-related

claims that may be directly asserted against Garlock’s affiliates which does not concern the

Released Claims (defined in the Plan) and is not relevant to the Plan or disputed issues of

confirmation.

12. Has any of the Debtors ever resolved by payment of indemnity the Asbestos PI Claim of any Asbestos Claimant who, personally, or by an attorney, or through another witness, asserted that the Asbestos-containing Product of any Affiliate was a source of asbestos exposure to the injured person? If the answer is other than an unqualified “no,” please provide the following information:

a. Identify each Asbestos Claimant whose resolved Asbestos PI claim meets the foregoing description and each Affiliate whose Asbestos-containing Product


14

such claimant asserted was a source of asbestos exposure to the injured person.

b. As to the Asbestos PI Claim of each identified Asbestos Claimant, state the amount paid by any of the Debtors to such claimant; state what portion, if any, of the Debtors’ payment was allocated to any Affiliate, and identify any Affiliate to whom such a portion was allocated; state what additional or separate amount, if any, was paid to the Asbestos Claimant by any Affiliate and identify each Affiliate that made such an additional or separate payment.

RESPONSE: Debtors object to the phrase “resolved by payment of indemnity” because

it is vague and ambiguous. Debtors further object to this Interrogatory because it does not seek

information that is relevant to confirmation or reasonably calculated to lead to the discovery of

admissible evidence at the confirmation hearing. The information sought by this Interrogatory

does not seek information that (a) relates to the Released Claims (defined in the Plan) because

Debtors never allocated any portion of any settlement payment they paid to any affiliate or (b) is

relevant to the Plan or disputed issues of confirmation.

13. Have the Debtors or any Non-Debtor Affiliates, or their representatives, had any Communications with any insurer, reinsurer, claims-handling entity, or other third party about the Settlement Facility or Trust, including the possibility of insuring, reinsuring or operating the same? If so, identify each entity with which any of the Debtors, Non-Debtor Affiliates, or representatives have had any such Communication and the dates and persons involved in any such Communications.

RESPONSE: Debtors object to this Interrogatory to the extent it seeks information

concerning communications by non-Debtor affiliates.

To the extent this Interrogatory seeks information concerning communications by

Debtors, Debtors respond: No.

14. Identify any individuals who will be nominated or appointed, or have been or are being considered for nomination or appointment, to serve as Key Personnel of Reorganized Anchor, Reorganized GST, Reorganized Garrison, or the Settlement Facility. For each individual identified, describe the position the individual will or may fill, including the entity, title, and principal responsibilities, identify the individual’s current employer, describe his or her current


15

position and responsibilities, set forth the individual’s relevant qualifications, and state whether the individual has ever been employed by, or retained as a professional by, any of the Debtors, any Non-Debtor Affiliate, or any former affiliate, including a description of such employment or retention.

RESPONSE: As set forth in the Plan, Anchor will be dissolved, such that there is no

“Reorganized Anchor.” Debtors have not yet specifically identified Key Personnel of

Reorganized GST, Reorganized Garrison, or the Settlement Facility who they will propose be

nominated or appointed. Prior to confirmation, Debtors will seasonably identify such personnel,

their qualifications, and affiliations as requested by this Interrogatory. In the meantime, Debtors

refer the Committee to the schedules to the Disclosure Statement that list Debtors’ current

directors and officers.

This 16th day of July, 2015. Respectfully submitted,

/s/ Garland S. CassadaGarland S. CassadaN.C. Bar No. 12352Jonathan C. KriskoN.C. Bar No. 28625Richard C. Worf, Jr.N.C. Bar No. 37143

ROBINSON BRADSHAW & HINSON, P.A.101 North Tryon Street, Suite 1900 Charlotte, North Carolina 28246Telephone: (704) 377-2536Facsimile: (704) 378-4000

[email protected]@[email protected]

Special Corporate and Litigation Counsel to the Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company


16

/s/ John R. Miller, Jr.C. Richard Rayburn, Jr.N.C. State Bar No. 6357John R. Miller, Jr.N.C. State Bar No. 28689

RAYBURN COOPER & DURHAM, P.A.227 West Trade Street, Suite 1200Charlotte, NC 28202(704) 334-0891

Counsel to the Debtors

[email protected]@rcdlaw.net


17

EXHIBIT A

GENERAL RESPONSES AND OBJECTIONS

1. These Responses are provided in good faith and based only upon such

information that is presently available to, and specifically known to, Debtors. The information

provided may include hearsay and other information that is neither reliable nor admissible in

evidence for various reasons, including material that is not admissible under Fed. R. Evid. 408.

Nothing in these Responses reflects any waiver or admission that any information or material

sought by the Interrogatories constitutes admissible evidence.

2. It is possible that further discovery and independent investigation may supply

additional facts, and/or add new meaning to the known facts, which may lead to additions to,

changes in, and variations from, the information herein set forth. As a result, these Responses

are given without prejudice to Debtors’ right to amend or revise these Responses, as additional

facts are ascertained.

3. These Responses are made without waiving (and Debtors expressly reserve)

Debtors’ rights (a) to object on any ground to the use of the information provided in this

proceeding and (b) to object on any ground to other discovery requests that involve or relate to

the subject matter of the Interrogatories. In submitting these Responses, Debtors do not admit,

adopt, or acquiesce in any factual or legal contention, assertion, or characterization in the

Interrogatories. The assertion of similar or additional objections, or the provision of partial

responses in the individual responses to the Interrogatories, do not waive any of Debtors’ general

objections.


18

4. Debtors object to the Interrogatories to the extent they seek the production of

information protected by the attorney-client privilege, the work product doctrine, and/or any

other applicable protection, restriction or immunity from discovery.

5. Debtors object to the Interrogatories to the extent they require Debtors to compile

or assemble information to formulate a response, and do not permit Debtors reasonable time to

provide a response.

6. Debtors object to the Instructions and Definitions contained in the Interrogatories

to the extent that they are inconsistent with the Definitions of these Responses or attempt to

impose obligations upon Debtors that are inconsistent with and/or in addition to those imposed

by the Federal Rules of Civil Procedure, the Federal Rules of Bankruptcy Procedure, applicable

Local Rules, the applicable law, and/or any orders issued by the Court.

7. Debtors object to these Interrogatories to the extent they seek to reopen subjects

of discovery and disputes which have already been ruled upon by the Court whether in the

Court’s Estimation Order or otherwise.

8. Debtors object to the use, in the Interrogatories, of the terms or phrases “all,”

“any,” “every,” and/or “each” on the grounds that these terms and phrases are (a) overly broad,

(b) unduly burdensome, (c) vague and ambiguous, and (d) seek information and/or documents

that are neither relevant to the scope of the order nor reasonably calculated to lead to the

discovery of admissible evidence.

Definitions Not Elsewhere Defined in These Responses

9. “Anchor” means Debtor The Anchor Packing Company, and unless otherwise

indicated, excludes any other person or entity.

10. “Coltec” means Coltec Industries, Inc. the sole equity holder of Garlock.


19

11. “Debtors” means Garlock, Garrison, and Anchor.

12. “Estimation Requests” refer to interrogatories and document requests in discovery

preceding the trial to estimate Garlock’s liability for mesothelioma claims.

13. “Estimation Trial” means the trial to estimate Garlock’s aggregate liability for

asbestos claims, for which the Court made findings of fact and conclusions of law, and upon

which entered judgment embodied in the Estimation Order.

14. “Estimation Order” means the January 10, 2014 Order Estimating Aggregate

Liability entered by the Court, In re Garlock Sealing Technologies LLC, 504 B.R. 71 (2014)

(Docket No. 3296).

15. “Garlock” means Debtor Garlock Sealing Technologies LLC, and unless

otherwise indicated, excludes any other person or entity.

16. “Garrison” means Debtor Garrison Litigation Management Corp., Ltd., and unless


17. “Non-meso Cancer PI Claims” and “Non-malignant PI Claims” have the same

definitions as indicated in the Official Committee of Asbestos Personal Injury Claimants’ First

Set of Interrogatories Directed to the Debtors Regarding Confirmation Issues.


20

EXHIBIT B

FREDERICK WILLIAM BOELTER, C.I.H.ENVIRON International Corporation333 West Wacker Drive, Suite 2700Chicago, Illinois 60606(312) 288-3800

NAME1 COURT STATE DATE2CIVIL ACTION

NO.Vieira Circuit Court, Morgan County IL 9/24/2004 02L-52White Circuit Court, McLean County IL 11/21/2005 02L-136Nolan Circuit Court, Vermilion County IL 1/26/2004 01-L-117Stalter Circuit Court, McLean County IL 8/4/2003 02-L-79

Babineaux District Court, Montgomery County TX 4/9/2003 00-10-06613

Lunak District Court, Dallas County TX 3/18/2004 01-02328-HBrundrett et al District Court, Calhoun County TX 6/28/2005 01-CV-210Flores et al District Court, Milam County TX 5/3/2004 26,496 et alBaer District Court, Harris County TX 4/10/2006 2004-70800Pyburn District Court, Travis County TX 7/16/2003 010133-CSiegwald District Court, Harris County TX 9/12/2006 2004-30104Ward District Court, El Paso County TX 2003 2001-1217Clark Common Pleas, Cuyahoga County OH 6/26/2006 522024Kleineke et al Common Pleas, Cuyahoga County OH 8/29/2005 521635

PHILIP CAGLE, M.D.Baylor College of MedicineOne Baylor Plaza6565 Fannin, MS 205Houston, Texas 77030(713) 790-2370

NAME COURT STATE DATECIVIL ACTION

NO.Lemons District Court, Brazoria County TX 10/2000 3308-BH-97

1 Throughout the exhibit, this column reflects the identification employed in Debtors’ records.2 Throughout the exhibit, this column indicates the approximate date of the expert’s deposition or trial testimony.


21

JAMES CRAPO, M.D.National Jewish Medical and Research Center1400 Jackson StreetDenver, Colorado 80206(303) 398-1436


NO.

Babineaux District Court, Montgomery County TX 4/10/2003 00-10-00613

Ward District Court, El Paso County TX 2001-1217 2003Lemons District Court, Brazoria County TX 10/18/2000 3308-BH-97

ILAN ALLAN FEINGOLD, M.D.South Miami Hospital6200 Southwest 73rd StreetMiami, Florida 33143(305) 661-4611


NO.Babineaux District Court, Montgomery County TX 2/24/2003 00-10-06613Hart Supreme Court, St. Lawrence

CountyNY 11/15/1999 101569/98

STANLEY FIEL, M.D.Pulmonary Disease & Critical CareMorristown Memorial Hospital100 Madison AvenueMorristown, New Jersey 07962(973) 971-5136


NO.Cowgill USDC - Eastern District PA 10/21/1986 83-4196

Cwon Common Pleas, Allegheny County PA 12/3/1986 84-21895

Lonasco Common Pleas, Philadelphia PA 10/22/2002 91-1424Osik Common Pleas, Philadelphia PA 10/26/1995 91-2571Finocchio Common Pleas, Philadelphia PA 6/18/1997 1484Batten Common Pleas, Philadelphia PA 9/2008 0601-1901Virginia Consolidated Trial Circuit Court, Newport News

VA 12/4/2002 CL99-2000

Charlot District Court LA 3/27/1996 91-18397


22

LARRY LIUKONEN, C.I.H.TechCon5990 Scania LaneBurleson, Texas 76028(817) 453-0382


NO.

Colzie Common Pleas, 1st Judicial District PA 2/3/1997 2584

Hunt et al District Court, Dallas County TX7/19/2004 03-03157-J

Virginia Consolidated Trial Circuit Court, Newport News

VA 12/3/2002

CL99-2000

CARL MANGOLD, C.I.H.Deceased


NO.Beverage & Roppelt Circuit Court, Baltimore City MD

10/25/1989 88 235726/CL

Lanier USDC - Middle District TN 2/3/1986 3-84-1054Virginia Consolidated Trial Circuit Court, Newport News

VA 11/26/2002

CL99-2000

Breuer Circuit Court, La Crosse County WI 11/12/1991

90CV246

Cwon Common Pleas, Allegheny County PA 12/3/1986 84-21895

Osik Common Pleas, Philadelphia PA 10/26/1995

91-2571

Castillo District Court, El Paso County TX 11/1/1999 98-627Malone District Court, Brazoria County TX 11/15/199

37868

DONNA M. RINGO, C.I.H.DMR & AssociatesPost Office Box 24467604 Pennyroyal WayLouisville, Kentucky 40223(502) 245-5289

NAME COURT STATE DATE CIVIL ACTION NO.Nelson Circuit Court for Baltimore City MD 11/18/1997 97-314701West Circuit Court for Baltimore City MD 1997 96-061508Lonasco Common Pleas, Philadelphia PA 10/22/2002 91-1424Batten Common Pleas, Philadelphia PA 9/2008 0601-1901


23

NAME COURT STATE DATE CIVIL ACTION NO.Gray Circuit Court, Boyd County KY 6/18/1998 94-CI-00873Berger Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Brown Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Callahan Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Campbell Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Martin Circuit Court, Boyd County KY 6/18/1998 94-CI-00873Johnson Circuit Court, Boyd County KY 6/18/1998 94-CI-00873Dexter Circuit Court, Marshall County KY 2005 02-CI-00310Dexter Circuit Court, Marshall County KY 2006 02-CI-00310Clephas Circuit Court, Jefferson County KY 4/8/2003 93-CI-05770Robertson Circuit Court, Jefferson County KY 11/5/2008 07-CI-05178Clephas Circuit Court, Jefferson County KY 2007 93-CI-05770Charlot District Court LA 3/27/1996 91-18397Bolin District Court, East Baton Rouge LA 11/2/1995 406632ALemons District Court, Brazoria County TX 10/18/2000 3308-BH97

ROBERT SAWYER, M.D.Preventive and Occupational Medicine149 Prospect Avenue, P. O. Box 1407Guilford, Connecticut 06437(203) 453-3060(800) 278-6433

NAME COURT STATE DATE CIVIL ACTION NO.Colzie Common Pleas, 1st Judicial District PA 1/31/1997 2584Castillo District Court, El Paso County TX 11/1/1999 98-627Brown Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Callahan Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Campbell Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Gray Circuit Court, Boyd County KY 6/18/1998 94-CI-00873Berger Circuit Court, Boyd County KY 6/18/1998 94-CI-00874Clephas Circuit Court, Jefferson County KY 4/8/2003 93-CI-05770Clephas Circuit Court, Jefferson County KY 2007 93-CI-05770Dexter Circuit Court, Marshall County KY 2006 02-CI-00310Breuer Circuit Court, La Crosse County WI 11/12/1991 90CV246


24

JOHN SPENCER, C.I.H.Environmental Profiles803 Frederick RoadBaltimore, Maryland 21228(410) 744-0700

NAME COURT STATE DATE CIVIL ACTION NO.Virginia Consolidated Trial Circuit Court, Newport News

VA 12/5/2002 CL99-2000

Hart Supreme Court, St. Lawrence County

NY 11/15/1999 101569/98

Lemons District Court, Brazoria County

TX 10/18/2000 3308-BH-97

STEVEN RICHARD SMITH, M.D.Community Hospital EastBuilding Four-First Floor1500 North Ritter AvenueIndianapolis, Indiana 46219(317) 355-6343

NAME COURT STATE DATE CIVIL ACTION NO.Vieira Circuit Court, Morgan County IL 9/24/2004 02L-52White Circuit Court, McLean County IL 11/21/2005 02L-136

MICHAEL GRAHAM, M.D.Division of Forensic and Environmental PathologySt. Louis University School of Medicine3556 Caroline St., Room C305St. Louis, Missouri 63104(314) 977-7841

NAME COURT STATE DATE CIVIL ACTION NO.Robertson Circuit Court, Jefferson County KY 11/5/2008 07-CI-05178Dexter Circuit Court, Marshall County KY 2008 02-CI-00310

JOHN DINEEN, M.D.Lexington Clinic Ambulatory Surgery Center1221 South BroadwayLexington, KY 40504(859) 258-4568

NAME COURT STATE DATE CIVIL ACTION NO.Robertson Circuit Court, Jefferson County KY 11/5/2008 07-CI-05178


25

CERTIFICATE OF SERVICE

I hereby certify that the foregoing DEBTORS’ RESPONSES TO OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS’ FIRST SET OF INTERROGATORIES DIRECTED TO THE DEBTORS REGARDING CONFIRMATION ISSUES was served via electronic mail and first-class mail, postage prepaid, to the following:

Jeanna Rickards Koski ([email protected]) (email and mail)Trevor W. Swett ([email protected]) (email only)James P. Wehner ([email protected]) (email only)Caplin & Drysdale, CharteredOne Thomas Circle, NW, Ste. 1100Washington, DC 20005

Jonathan P. Guy ([email protected]) (email and mail)Kathleen A. Orr ([email protected]) (email only)Gregory Beaman ([email protected]) (email only)Orrick, Herrington & Sutcliffe LLP1152 15th Street, N.W.Washington, DC 20005

Mark Nebrig ([email protected]) (email and mail)Taylor Stukes ([email protected]) (email only)Moore & Van Allen PLLCSuite 4700100 North Tryon St.Charlotte, NC 28202

This 16th day of July, 2015.

/s/ Garland S. CassadaGarland S. Cassada


EXHIBIT D

Case 10-31607 Doc 4865-4 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. D-GST Resps to 1st ACC Confirmation RFPs Page 1 of 29

UNITED STATES BANKRUPTCY COURTFOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

IN RE:GARLOCK SEALING TECHNOLOGIES LLC, et al.,

Debtors.


Chapter 11


DEBTORS’ RESPONSES TO OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS’

FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO THEDEBTORS REGARDING CONFIRMATION ISSUES

Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group,

Ltd., and The Anchor Packing Company (“Debtors”), pursuant to Federal Rules of Civil

Procedure 26 and 33, and Federal Rules of Bankruptcy Procedure 7026, 7033, and 9014, by and

through counsel, hereby respond and object (these “Responses”) to the Official Committee of

Asbestos Personal Injury Claimants’ First Requests for Production of Documents Directed to the

Debtors Regarding Confirmation Issues (the “Requests”). Below, Debtors set forth their Specific

Responses and Objections to each of the Requests. These Specific Responses and Objections are

subject to and incorporate Debtors’ General Responses and Objections (“General Objections”)

and Definitions, which are attached as Exhibit A.

SPECIFIC RESPONSES AND OBJECTIONS

1. All Documents identified or referred to in the Debtors’ responses to the Official Committee of Asbestos Personal Injury Claimants’ First Set of Interrogatories Directed to the Debtors Regarding Confirmation Issues.

RESPONSE: To the extent Debtors identify or refer specifically to a particular

document(s) in their responses to the Official Committee of Asbestos Personal Injury Claimants’

First Set of Interrogatories Directed to the Debtors Regarding Confirmation Issues, Debtors will

produce such document(s).


2



b. All work histories, interrogatory answers, responses to requests for admissions, or testimony provided by the identified Asbestos Claimants or their product-identification witnesses with respect to sources of exposure to Asbestos-containing Products, and all Documents reflecting the Debtors’ and their defense counsel’s knowledge or information concerning such claimants’ occupations, industries, jobsites, and exposures to Asbestos-containing Products;

c. All Documents setting forth discovery requests to the identified Asbestos Claimants and all Documents setting forth responses to such requests;

d. All Documents discussing or reflecting pre-settlement evaluation by the Debtors or their counsel of the claims of the identified Asbestos Claimants, or internal settlement deliberations of the Debtors or their counsel regarding such claims, including all Documents constituting or discussing Communications between or among the Debtors, Non-Debtor Affiliates, and defense counsel about those subjects;

e. All Documents setting forth the terms of any settlements of the claims of the identified Asbestos Claimants, and all Documents concerning the negotiation of the settlements, including all Communications with Asbestos Claimants’ counsel regarding negotiation of the settlements; and

f. For each claim of an identified Asbestos Claimant that was presented or resolved within the framework of a processing agreement, case flow agreement, or similar arrangement, all Documents constituting or setting forth such agreement or arrangement, and any Documents constituting or discussing Communications with Asbestos Claimants’ counsel about the negotiation of such agreement or arrangement.

RESPONSE: Debtors object to this Request because it seeks documents protected from

disclosure by the attorney-client privilege and work product immunity. This Request, in

particular, part d., seeks the production of privileged communications among Debtors’ counsel

and Debtors and documents that contain attorney work product.

Debtors also object to this Request to the extent it seeks to require the production of

documents from persons other than Debtors and Debtors’ counsel involved in the representation

of Debtors with respect to the asbestos claimant(s) identified in response to Interrogatory 1(a)


3

that could relate to such claimant’s occupation, industry, or jobsite(s). The identification and

production of such documents from persons and entities not involved in the identified claimant’s

case would be unduly burdensome and would not yield information that is relevant nor

reasonably calculated to lead to the discovery of admissible evidence.

Subject to the foregoing objections, Debtors have already produced in connection with

Estimation Trial discovery the documents requested in subparagraphs a, b, and c with respect to

the Dexter and Robertson cases. Debtors object to subparts d, e, and f with respect to Dexter and

Robertson because those claims were not resolved through settlement. Whether Debtors make

contentions regarding additional claims that are the subject of Interrogatory 1 depends upon the

results of Debtors’ discovery regarding cases that resulted in verdicts against Debtor GST and

contentions of the Committee, as explained in Debtors’ response to Interrogatory 1. Debtors

cannot identify and produce further documents responsive to this Request until after Debtors

receive (1) responses to Debtors’ discovery to third parties regarding non-mesothelioma cases

that are the subject of trial verdicts, or (2) responses from the Committee identifying any Garlock

historical settlements or trial verdicts for non-mesothelioma claims about which it intends to

offer evidence in connection with its positions regarding the Plan, and which Debtors thereafter

identify to supplement their response to Interrogatory 1.



b. All Documents reflecting medical or health-related information provided by the identified Asbestos Claimants, and all Documents reflecting the Debtors’ and their defense counsels’ knowledge or information concerning the identified Asbestos Claimants’ medical condition or health;

c. All Documents setting forth discovery requests to the identified Asbestos Claimants and all Documents setting forth responses to such requests;


4

d. All Documents discussing or reflecting pre-settlement evaluation of the claims of the identified Asbestos Claimants by the Debtors or their counsel, or their internal settlement deliberations regarding such claims, including all Documents constituting or discussing Communications between or among the Debtors, Non-Debtor Affiliates, and defense counsel about those subjects;

e. All Documents constituting or setting forth any settlements of the claims of the identified Asbestos Claimants, and all Documents concerning the negotiation of the settlements, including all Communications with Asbestos Claimants’ counsel regarding negotiation of the settlements; and

f. For each claim of the identified Asbestos Claimants that was presented or resolved within the framework of a processing agreement, case flow agreement, or similar arrangement, all Documents constituting or setting forth such agreement or arrangement and any Documents constituting or discussing Communications with Asbestos Claimants’ counsel about the negotiation of such agreement or arrangement.

RESPONSE: Debtors object to this request because it seeks documents protected from

disclosure by the attorney-client privilege and work product immunity. This Request, in

particular, part d., seeks the production of privileged communications among Debtors’ counsel

and Debtors and documents that contain attorney work product.

With respect to resolved claims, Debtors also object to this Request because it is unduly

burdensome. As explained in response to Interrogatory 2, Debtors believe they resolved

thousands of claims based on diagnoses from sources that were later demonstrated to be

fraudulent or otherwise improper. Identifying all such claimants would be impossible for the

reasons described in the response to Interrogatory 2, and production of the requested documents

for all such claimants would be impossible for the same reason.

Debtors are willing to confer with the Committee to narrow the scope of the Request to

facilitate the production of non-privileged documents of a reasonable scope and usefulness. To

the extent this Request seeks documents that are the subject of expert testimony, consistent with


will provide applicable reports and supporting materials.


5

Subject to the foregoing objections, whether Debtors make contentions about particular

resolved claims that are the subject of Interrogatory 2 depends upon the contentions of the

Committee, as explained in Debtors’ response to Interrogatory 2. Debtors will produce any

documents responsive to this Request after the Committee identifies any Garlock historical

settlements or trial verdicts for non-mesothelioma claims about which it intends to offer evidence

in connection with its positions regarding the Plan, and after Debtors seasonably supplement

their response to Interrogatory 2.

With respect to pending claims, Debtors will produce to the Committee the Manville

Trust data that they will obtain in discovery. Debtors object to production of the other requested

documents because they are not relevant or reasonably calculated to lead to the discovery of

admissible evidence, and would be unduly burdensome to assemble, as they would require

obtaining case files (to the extent they exist) for over 90,000 pending claims, scattered in

counsel’s files across the United States. Debtors are willing to confer with the Committee to

narrow the scope of the Request to facilitate the production of non-privileged documents of a

reasonable scope and usefulness.


a. All Documents that form part of the factual basis for the Debtors’ contention;

b. All Documents reflecting or evidencing inflation of such Asbestos Claimants’ settlements;

c. All Documents evidencing, compiling, or quantifying the nature and amount of the Debtors’ defense costs with respect to such Asbestos Claimants’ settlements, individually or as part of a group of settlements;

d. All Documents setting forth discovery requests to the identified Asbestos Claimants and all Documents setting forth responses to such requests;


6

e. All Documents discussing or reflecting pre-settlement evaluation of the claims of the identified Asbestos Claimants by the Debtors or their counsel, or their internal settlement deliberations regarding such claims, including all Documents constituting or discussing Communications between or among the Debtors, Non-Debtor Affiliates, and defense counsel about those subjects;

f. All Documents constituting or setting forth any settlements of the claims of the identified Asbestos Claimants, and all Documents concerning the negotiation of the settlements, including all Communications with Asbestos Claimants’ counsel regarding negotiation of the settlements; and

g. For each claim of the identified Asbestos Claimants that was presented or resolved within the framework of a processing agreement, case flow agreement, or similar arrangement, all Documents constituting or setting forth such agreement or arrangement and any Documents constituting or discussing Communications with Asbestos Claimants’ counsel about the negotiation of such agreement or arrangement.

RESPONSE: Debtors object to this Request because it seeks documents that are not

relevant to confirmation of the Plan. The Court has already found that Debtors’ settlements of

asbestos claims were inflated by avoidable defense costs. Debtors will rely on these findings at

the confirmation hearing and Debtors object to any attempt by the Committee to re-litigate this

issue.

Debtors also object to this Request because it seeks documents protected from disclosure

by the attorney-client privilege and work product immunity. This Request, in particular, part e.,

seeks the production of privileged communications among Debtors’ counsel and Debtors and

documents that contain attorney work product.

Debtors also object because this Request is unduly burdensome. Debtors identified all of

their settled non-mesothelioma claims in response to Interrogatory 3, and assembling the

requested documents would require obtaining case files for hundreds of thousands of cases (to

the extent they exist), scattered in counsel’s files across the United States. Because these claims

were settled to avoid defense costs, many of these files (if they exist) would not contain

information that is relevant or calculated to lead to the discovery of admissible evidence.


7

Debtors will present expert testimony describing and generally quantifying the effect of

defense costs on the resolution of non-mesothelioma claims. Consistent with the confirmation

hearing Case Management Order and applicable rules of procedure, Debtors will timely identify

expert witnesses and provide applicable reports and supporting materials.

5. All Documents discussing or setting forth any analyses, forecasts, reports, liabilityestimates, valuations, or liability reserves related to Non-meso Cancer PI Claims or Non-malignant PI Claims under the Plan or in the tort system, including estimates as to liability, indemnity payments, expenditures, or defense costs.

RESPONSE: Debtors object to the terms “analyses” and “reports” because those terms

are vague and ambiguous. At least one interpretation of such terms would make this Request

immense, and apply to virtually any consideration of asbestos claims in the tort system which

would mean this Request is unduly burdensome and overbroad. Debtors additionally object to

this Request to the extent it seeks documents protected by the attorney-client privilege and work

product immunity.

To the extent that this Request seeks forecasts, estimates, valuations, or reserves related

to non-mesothelioma claims under the Plan, this Request is one of the subjects of anticipated

expert testimony at the confirmation hearing. Consistent with the confirmation hearing Case

Management Order and applicable rules of procedure, Debtors will timely identify expert

witnesses and provide applicable reports and materials which would be responsive to this

Request.

To the extent that this Request seeks forecasts, estimates, valuations, or reserves related

to non-mesothelioma claims in the tort system prepared prior to the Petition Date, those

documents were already produced in response to the Committee’s Estimation Requests,


8

including Requests 25 and 28 of the Committee’s First Estimation Requests. Debtors’ responses

to those Requests are incorporated herein.

6. All Documents discussing or setting forth the factual basis, assumptions, ormethodologies for any of the matters described in the immediately preceding Document Request.

RESPONSE: To the extent that this Request seeks documents related to those sought in

Request 5 concerning the Plan, this Request is the subject of anticipated expert testimony at the

confirmation hearing. Consistent with the confirmation hearing Case Management Order and

applicable rules of procedure, Debtors will timely identify expert witnesses and provide

applicable reports and materials which would be responsive to this Request.

To the extent that this Request seeks documents related to those sought in Request 5

concerning non-mesothelioma claims in the tort system prepared prior to the Petition Date, those

documents were already produced in response to the Committee’s Estimation Requests,

including Requests 25 and 28 of the Committee’s First Estimation Requests. Debtors’ responses

to those Requests are incorporated herein.

Debtors also refer the Committee to the testimony of Dr. Bates and Mr. Magee during the

Estimation Trial, and their related deposition testimony.

7. All Documents discussing or setting forth any analysis of, estimation of, valuationof, or reserves for the Debtors’ and any Non-Debtor Affiliates’ contributions and contingent contributions to the proposed Litigation Fund or to the Settlement Facility as defined by the Plan.

RESPONSE: The subject of this Request is anticipated expert testimony at the





9

Debtors will also produce other non-privileged documents responsive to this Request.


RESPONSE: No documents additional to those that will be produced in response to

Request 7 are responsive to this Request.

9. All Documents discussing or setting forth any estimation, valuation, analysis, orforecasting of the number or characteristics of claims that would be litigated pursuant to the Litigation Option under the Plan, the outcomes of such claims, the cost of defending against such claims, legal liability for such claims, or indemnity to be paid to resolve the claims.




applicable reports and materials which would be responsive to this Request. Debtors also refer

the Committee to the documents produced in response to Request 7.






11. All Documents discussing or setting forth the Debtors’ estimation, valuation,analysis, or forecasting of defense costs under the Litigation Option, including any Documents which evidence how defense costs under the Litigation Option would be allocated between the


10

Litigation Fund and the Settlement Fund or would compare to Garlock’s or Anchor’s historical defense costs.





12. All Documents discussing or setting forth the Debtors’ estimation, valuation,analysis, or forecasting of the costs of administering the Trust and Settlement Facility as outlined in the Plan.




applicable reports and materials which would be responsive to this Request. To the extent

Debtors identify any additional responsive documents, they will produce them.







14. All Documents concerning modifications of, or changes to, the Parent Settlementor any previous version of the Parent Settlement set forth in any previous version of the Plan raised by, discussed with, sought by, or suggested by or to the FCR (or his representatives),


11

including all Communications relating to such modifications or changes between or among the Debtors (or their representatives), the FCR (or his representatives), and any Non-Debtor Affiliates (or their representatives).

RESPONSE: Debtors object to this Request to the extent it seeks documents that are

subject to the attorney-client privilege or work product immunity. Subject to the foregoing

objection, Debtors will produce responsive communications between Debtors (or their affiliates)

and the FCR.

15. For each Non-meso Cancer PI Claim or Non-malignant PI Claim that resulted in atrial verdict against Garlock or Anchor between January 1, 1990, and June 5, 2010, produce:

a. The complaint, including any case information sheet required by the court;

b. All written discovery directed to the Asbestos Claimant, Garlock, or Anchor, and all responses thereto including any supplementation;

c. Transcripts of any depositions taken in the case;

d. The jury instructions rendered by the court;

e. The complete trial transcript, including closing arguments presented to the jury by any party;

f. The verdict sheet as returned by the jury;

g. Documents sufficient to show the following: the portion of the verdict allocated to Garlock or Anchor, and the amount of any post-verdict settlement or judgment paid by Garlock or Anchor (or bonded by Garlock or Anchor if the judgment was appealed); and

h. Any briefs and decisions on appeal.

RESPONSE: Debtors will produce non-privileged documents responsive to this

Request.

16. All Documents discussing or setting forth the Debtors’ historical settlement strategies, settlement criteria, and internal goals for settling, resolving or addressing:


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a. Non-malignant PI Claims;

b. Asbestos PI Claims related to lung cancer; and

c. Asbestos PI Claims related to laryngeal cancer.

RESPONSE: Debtors object to this Request because it seeks documents protected by

the attorney-client privilege and work product immunity concerning Debtors’ settlement

strategies. Documents responsive to this Request were previously the subject of Estimation

Requests, including Requests 15, 22 and 23 of the Committee’s First Estimation Requests, and

Debtors produced some documents in response those Requests and provided a privilege log

identifying other documents. Debtors’ responses to those Requests are incorporated herein.

Subject to the foregoing objection, Debtors refer the Committee to SEC filings that

provided broad, non-privileged outlines of Debtors’ resolution strategies which are responsive to

this Request.

Debtors object to the term “settlement criteria” because it is vague and ambiguous and

because it may presume, incorrectly, that Debtors entered into uniform settlement agreements

based on “settlement criteria” with all asbestos claimants. The terms of settlement agreements

with claimants varied widely.

To the extent Debtors established internal goals for the resolution of asbestos claims;

such goals were not correlated to the type of disease alleged by claimants. Responsive non-

privileged documents concerning any internal goals (which related to the management of all

asbestos claims) were already produced to the Committee in response to the Committee’s First

Estimation Requests, including Request 23. Debtors’ responses to those Requests are

incorporated herein.


13

17. All Documents constituting or concerning presentations by the Debtors, Non-Debtor Affiliates, or defense counsel at any periodic meeting at which the Debtors’ strategy for defending or resolving Asbestos PI Claims was discussed, including but not limited to presentations by or to the Debtors’ regional defense counsel.

RESPONSE: Debtors object to this Request because it seeks documents that are

protected by the attorney-client privilege and subject to attorney work product immunity.

Documents responsive to this Request were previously the subject of Estimation Requests,

including Request 22 of the Committee’s First Estimation Requests, and Debtors provided a

privilege log identifying such documents. Debtors’ responses to those Requests are incorporated

herein. The Committee moved the Court to compel Debtors to provide documents covered by

this Request in response to Request 22 of the Committee’s First Estimation Requests. The Court

denied the Committee’s motion by Order dated June 19, 2012 (Docket No. 2315).

18. Documents sufficient to identify all pending Non-malignant PI Claims against theDebtors that have been placed on any inactive court docket and the court in which the claims are filed.

RESPONSE: Debtors object to the term “inactive court docket” because it is vague and

ambiguous in its use in this Request. There is no uniform definition of this term because courts

across the country employ a variety of policies and procedures for handling asbestos personal

injury claims. Producing documents that describe the procedures for all of these courts and that

identify all Non-malignant PI Claims on any “inactive court docket” would be unduly

burdensome and unnecessary. To Debtors’ best knowledge, except for trial courts in the state of

Michigan, there are no courts which will place an unimpaired non-malignant asbestos personal

injury claim on their active trial dockets.

Debtors did not always specifically record in their asbestos claims database, FADA, or

otherwise, whether a claim resided on a docket where it would not be called for trial and was


14

thus “inactive.” Debtors sometimes marked claims in FADA with a status code of “I,” indicating

the claim was inactive, or “A,” indicating the claim was administratively closed. Debtors have

not undertaken to comprehensively identify all claims that may reside on inactive court dockets,

and cannot produce documents that identify every claim against Debtors that resides on an

inactive court docket. Doing so would be an undue burden, and Debtors object on that basis. The

claims database, however, generally contains the date on which claims were filed, from which

one can determine that large numbers of old claims have not been prosecuted and are likely

inactive.

Whether a claim under local court rules is placed on an inactive docket depends upon the

disease alleged and identified in related medical diagnoses. Without such information for

pending claims, Debtors cannot determine precisely which claims would be subject to treatment

as “inactive” under court rules.

19. All contracts, agreements, purchase orders or similar Documents pursuant towhich Garlock or Anchor directly or indirectly supplied Asbestos-containing Products to any present or former Affiliate of the Debtors, including but not limited to EnPro Industries, Inc., Coltec Industries, Inc., Fairbanks Morse Pump, Fairbanks Morse Engine, Central Moloney Transformer, and Quincy Compressors.

RESPONSE: Debtors object to this Request because it does not seek documents that are

relevant to confirmation or reasonably calculated to lead to the discovery of admissible evidence

at the confirmation hearing. Instead, it seeks documents relevant to asbestos-related claims that

may be directly asserted against Garlock’s affiliates which does not concern the Released Claims

(defined in the Plan) and is not relevant to the Plan or disputed issues of confirmation.

20. Any Documents concerning specification, recommendation, or promotion by anypresent or former Affiliate of the Debtors of Garlock Asbestos-containing Products or Anchor


15

Asbestos-containing Products as a component of or replacement part for such Affiliates’ own products.






21. All Documents or Communications concerning Coltec’s or any other present orformer Affiliate’s involvement in the design, formulation, manufacturing, marketing, patenting,branding, marketing, labeling (including warnings), sale, or decision to discontinue the manufacture or sale of any Garlock Asbestos-containing Product or Anchor Asbestos-containing Product.






22. All Documents containing any release or covenant not to sue that was delivered tothe Debtors or their Affiliates by any Asbestos Claimant identified in response to Interrogatory No. 12.



at the confirmation hearing. Subject to the foregoing objection, Debtors respond that they did

not identify any asbestos claimants in their response to Interrogatory 12 because of their

objections to that Interrogatory.


16

23. All Documents constituting agreements to toll statutes of limitations or reposeentered into by Anchor after January 1, 1998.

RESPONSE: Debtors entered numerous tolling agreements with plaintiffs or their

representatives beginning in approximately 1997. Production of all documents responsive to this

request would be unduly burdensome and duplicative given that such agreements are

substantially similar in form.

Debtors would be willing to confer with the Committee to narrow the scope of the

Request to facilitate the production of non-privileged documents of a reasonable scope and

usefulness that would substantially demonstrate the terms of such tolling agreements, which are

unlikely to be the subject of a material dispute.

24. All Documents discussing or setting forth any Communications between Debtors (or their representatives) and any insurers, the Bank of America, or any investment bank, financial institution, or financial analyst that in any way relate to the Plan.

RESPONSE: Debtors have no documents that reflect Communications to any specific

insurer, Bank of America, or any specific investment bank, financial institution, or financial

analyst related to the Plan. Debtors will produce transcripts and presentations, and associated

news releases, for investor conference calls held by EnPro Industries which may reflect

communications by Garlock’s affiliates to financial industry analysts in a public forum

concerning the Plan.

25. For each Asbestos PI Claim listed on the Debtors’ Exhibit GST-8001, produce allDocuments discussing or setting forth;

a. the agreement to settle the Asbestos PI Claim or the terms of the settlement;

b. the reasons why the Debtors settled or agreed to settle the Asbestos PI Claim;


17

c. the information and assumptions relied upon by the Debtors in settling or agreeing to settle such claim; and

d. all Documents setting forth or discussing case analyses, claim evaluations, risk assessments, cost computations or projections, settlement recommendations, or advice prepared or provided by the Debtors’ litigation counsel, regional defense counsel, in-house attorneys, or consultants with respect to the Asbestos PI Claim or the resolution thereof.

RESPONSE: Debtors object to this Request because it seeks documents relevant only to

issues that are the subject of findings and conclusions in the Estimation Order. This Request is an

obvious attempt to try to reopen the Estimation Record related to the claims described in GST-

8001. The Court has already denied the Committee’s motion to reopen the Estimation Record.

Debtors object to any further discovery concerning these claims.

Notably, the cases listed on GST-8001 were already the subject of substantial discovery

before and during the Estimation Trial pursuant to a stipulation with the Committee and

supplemented by the production of privileged documents over Debtors’ objection.

Irrespective of their objections to further discovery of claims, Debtors additionally object

to any effort by the Committee to re-litigate issues surrounding these claims at the confirmation

hearing.

26. The most recent status memoranda concerning Garlock’s available insurancecoverage for Asbestos PI Claims, including the most recent iteration of any Document similar to that produced at GST-EST-0121856.

RESPONSE: Debtors will produce the requested document.

27. All Documents discussing or referring to the impact, if any, that the OrderEstimating Aggregate Liability in In re Garlock Sealing Technologies LLC, 504 B.R. 71 (Bankr. W.D.N.C. Jan. 10, 2014), has had, is having, or is likely to have on the propensity of individuals to sue makers, sellers, or users of Asbestos-containing Products for asbestos-related personal injuries or wrongful death, on the conduct of litigation with respect to such claims in non-bankruptcy courts, or on the outcomes of such claims.


18



at the confirmation hearing. Further, neither Debtors nor their professionals have undertaken to

study or assess whether the Estimation Order would have any impact on the propensity of

individuals to sue other asbestos defendants in non-bankruptcy courts or would have any impact

on the outcome of such suits. Some commentators, attorneys, and other contributors have

written articles or other content that may be responsive to this Request, but such articles and

other content are available to the Committee in the same way they would be available to Debtors.

Accordingly, Debtors object to identifying and providing the Committee documents that would

be responsive to this Request.

28. All Communications between the Debtors or their representatives and LloydDixon, Geoffrey McGovern or Amy Coombe or their assistants or representatives concerning any RAND study or paper relating to asbestos litigation or asbestos bankruptcy trusts.

RESPONSE: Debtors object to this Request because it seeks documents that are not

relevant to issues of confirmation and are not reasonably calculated to lead to the discovery of

admissible evidence at the confirmation hearing.

29. All Documents concerning any review, approval, disapproval, audit, or evaluationby any insurer or reinsurer of Garlock’s or Anchor’s actual or proposed settlements of any Asbestos PI Claims or Garlock’s or Anchor’s practices, goals, cost estimates, or budgets for defending or settling Asbestos PI Claims.

RESPONSE: Debtors object to this Request because it seeks documents protected from

disclosure by the attorney-client privilege and work product immunity. In addition, Debtors

object to this Request because it seeks documents that are not relevant or reasonably calculated

to lead to the discovery of admissible evidence. The Committee moved the Court to compel


19

Debtors to provide documents in response to an identical Estimation Request. The Court denied

the Committee’s motion by Order dated September 14, 2011 (Docket No. 1500).

30. All Documents related to the valuation factors and discounts to be utilized as part of the CRP and Settlement Option as proposed under the Plan, including but not limited to:

a. Documents describing how the factors and discounts were derived or how they would be applied;

b. Spreadsheets, computer programs, or other electronic Documents that embody or apply the CRPs such that settlement in real or hypothetical cases may be calculated;

c. Documents concerning the application of the CRP to any sample or population of actual Asbestos PI Claims, including both input data and results; and,

d. Documents concerning any model or precedent for the CRP or any valuation factors and discounts that form part of the CRP.




applicable reports and materials which would be responsive to this Request. In addition, the Plan

and its Exhibits contain the criteria that would be applied under the CRP. With respect to

Request 30(b), Debtors refer the Committee to the Garlock settlement option internet calculator

available at http://gstonlinecalculator.com/. With respect to Request 30(c), responsive documents

will be produced in response to Request 31. With respect to Request 30(d), Debtors refer the

Committee to the Western Asbestos Trust Distribution Procedures available at

http://www.wastrust.com/sites/default/files/documents/WAST%20Second%20Amendment%20t

o%20and%20Complete%20Restatement%20of%20TDP.pdf.


20

31. All Documents discussing or setting forth the assumptions, input data, analyses,methodologies, or calculations underlying

a. the “Summary of Estimated Payments by Contact Group for Current and Future Mesothelioma Claimants (Second Amended Plan)” that the Debtors used with the Bankruptcy Court as an exhibit on or about November 17, 2014 or any subsequent version (including the version attached hereto as Addendum A);

b. Exhibit 1 to Debtors’ Reply to Limited Objection of Official Committee of Asbestos Personal Injury Claimants to Proposed Disclosure Statement for Debtors’ Second Amended Plan of Reorganization [Dkt. No. 4384], filed February 13, 2015 (a copy of which is attached hereto as Addendum B).




applicable reports and materials which would be responsive to this Request. Debtors will also

produce documents sufficient to demonstrate the assumptions, input data, analyses,

methodologies, and calculations underlying the referenced documents.

32. All Documents constituting models or precedents for the CRP or any of itsprovisions, including, but not limited to the industry and occupation classifications, the prescribed claim values, and the exposure certification requirements set forth in Sections 4.5(c), 4.6(b), and 4.6(e) of the CRP.





Further, documents responsive to this Request were already produced to the Committee

prior to the Estimation Trial as part of pre-trial discovery, the disclosure of expert reports and

supporting materials (primarily related to the opinions of Dr. Bates and Mr. Henshaw), and


21

documents which were exhibits offered at the Estimation Trial. To the extent Debtors identify

any additional responsive documents, they will produce them.

33. At page 3 of Debtors’ Statement in Response to Asbestos Committee’sPreliminary Confirmation Objections, the Debtors assert that “[t]he CRP thereby avoid paying frivolous claims that could dilute assets set aside for future claimants, which is a problem that has prevented other trusts from providing equal treatment to future claims.” Please produce all Documents discussing or referring to any failure by existing asbestos trusts to provide equaltreatment to future claims, including any Documents discussing or referring to reasons for any such failure and any Documents concerning the factual basis for the Debtors’ assertion that any such trust has failed to provide, or been prevented from providing, appropriate treatment to future claims.






34. Any case management orders, standing orders, general orders or rules adopted bystate or federal courts that contain or constitute models or precedents for the certification requirements, standardized discovery, or other provisions found in the CMO or its Exhibits.

RESPONSE: Debtors object to the Request as overbroad and unduly burdensome

because the Request seeks every asbestos case management order in the United States, inasmuch

as the CMO and its Exhibits contain features found in all such orders, including standard

interrogatories and requests for production pertaining to the plaintiff’s alleged disease and

exposure to asbestos, as well as many other topics. Debtors will produce case management

orders that exemplify these features as contained in the CMO and its Exhibits. In addition, to the

extent the Request seeks case management orders constituting models or precedents for the Trust

claim disclosure provisions in the CMO and its Exhibits, Debtors will produce responsive


22

documents. Many of these documents were produced to the Committee prior to the Estimation

Trial as part of pre-trial discovery and were exhibits offered at the Estimation Trial. Debtors

further refer the Committee to the expert report of Mark A. Behrens produced on April 23, 2013

prior to the Estimation Trial that discussed, among other things, asbestos case management

orders entered in courts across the country. Finally, as the Committee is aware, many states

(including Arizona, Texas, Wisconsin, Ohio, Oklahoma, and West Virginia) have enacted

legislation regarding Trust claim disclosure that make it unnecessary for courts in those states to

adopt case management orders with such provisions.

35. With respect to any Released Claim identified in the response to Interrogatory No.10:

a. All Documents reviewed as part of the investigation and any Communications between or among the Debtors (or their representatives), any Non-Debtor Affiliates (or their representatives), any former affiliates of the Debtors or Coltec (or their representatives), or the FCR (or his representatives) concerning the investigation; and

b. All Documents discussing or setting forth questions posed, issues identified, observations made, evidence compiled, analyses conducted, inferences drawn, or conclusions reached by the Debtors (or their representatives) in the course, or as a result, of the investigation into the Released Claim.

RESPONSE: Subject to and without waiver of the Debtors’ objections contained in the

response to Interrogatory 10, Debtors will produce non-privileged documents responsive to this

Request.

36. All Documents concerning FTI Consulting Inc.’s valuation and liquidation analyses attached to the Disclosure Statement, including, but not limited to, Documents concerning the scope of the assignment; instructions given for the assignment; any analyses, summaries, evaluations, or reports created in the course of the assignment, including all drafts and working papers; and any Communications between FTI Consulting Inc. and the Debtors or Coltec with respect to the assignment.


23

RESPONSE: Debtors will produce non-privileged documents responsive to this

Request.

37. All Communications between or among the Debtors (or their representatives), anyNon-Debtor Affiliates (or their representatives), and insurers, reinsurers, claims handling entities, or other third parties about the Settlement Facility or Trust’s post-confirmation operations.

RESPONSE: There are no documents responsive to this Request.

This 16th day of July, 2015. Respectfully submitted,

/s/ Garland S. CassadaGarland S. CassadaN.C. Bar No. 12352Jonathan C. KriskoN.C. Bar No. 28625Richard C. Worf, Jr.N.C. Bar No. 37143

ROBINSON BRADSHAW & HINSON, P.A.101 North Tryon Street, Suite 1900 Charlotte, North Carolina 28246Telephone: (704) 377-2536Facsimile: (704) 378-4000

[email protected]@[email protected]

Special Corporate and Litigation Counsel to the Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company

/s/ John R. Miller, Jr.C. Richard Rayburn, Jr.N.C. State Bar No. 6357John R. Miller, Jr.N.C. State Bar No. 28689

RAYBURN COOPER & DURHAM, P.A.


24

227 West Trade Street, Suite 1200Charlotte, NC 28202(704) 334-0891

Counsel to the Debtors

[email protected]@rcdlaw.net


25

EXHIBIT A

GENERAL RESPONSES AND OBJECTIONS

1. These Responses are provided in good faith and based only upon such

information that is presently available to, and specifically known to, Debtors. The information

provided may include hearsay and other information that is neither reliable nor admissible in

evidence for various reasons, including material that is not admissible under Fed. R. Evid. 408.

Nothing in these Responses reflects any waiver or admission that any information or material

sought by the Interrogatories constitutes admissible evidence.

2. It is possible that further discovery and independent investigation may supply

additional facts, and/or add new meaning to the known facts, which may lead to additions to,

changes in, and variations from, the information herein set forth. As a result, these Responses

are given without prejudice to Debtors’ right to amend or revise these Responses, as additional

facts are ascertained.

3. These Responses are made without waiving (and Debtors expressly reserve)

Debtors’ rights (a) to object on any ground to the use of the information provided in this

proceeding and (b) to object on any ground to other discovery requests that involve or relate to

the subject matter of the Requests. In submitting these Responses, Debtors do not admit, adopt,

or acquiesce in any factual or legal contention, assertion, or characterization in the

Interrogatories. The assertion of similar or additional objections, or the provision of partial

responses in the individual responses to the Requests, do not waive any of Debtors’ general

objections.


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4. Debtors object to the Requests to the extent they seek the production of

information protected by the attorney-client privilege, the work product doctrine, and/or any

other applicable protection, restriction or immunity from discovery.

5. Debtors object to the Requests to the extent they require Debtors to compile or

assemble information to formulate a response, and do not permit Debtors reasonable time to

provide a response.

6. Debtors object to the Instructions and Definitions contained in the Requests to the

extent that they are inconsistent with the Definitions of these Responses or attempt to impose

obligations upon Debtors that are inconsistent with and/or in addition to those imposed by the

Federal Rules of Civil Procedure, the Federal Rules of Bankruptcy Procedure, applicable Local

Rules, the applicable law, and/or any orders issued by the Court.

7. Debtors object to these Requests to the extent they seek to reopen subjects of

discovery and disputes which have already been ruled upon by the Court whether in the Court’s

Estimation Order or otherwise.

8. Debtors object to the use, in the Requests, of the terms or phrases “all,” “any,”

“every,” and/or “each” on the grounds that these terms and phrases are (a) overly broad, (b)

unduly burdensome, (c) vague and ambiguous, and (d) seek information and/or documents that

are neither relevant to the scope of the order nor reasonably calculated to lead to the discovery of

admissible evidence.

Definitions Not Elsewhere Defined in These Responses

9. “Anchor” means Debtor The Anchor Packing Company, and unless otherwise

indicated, excludes any other person or entity.

10. “Coltec” means Coltec Industries, Inc. the sole equity holder of Garlock.


27

11. “Debtors” means Garlock, Garrison, and Anchor.

12. “Estimation Requests” refer to interrogatories and document requests in discovery

preceding the trial to estimate Garlock’s liability for mesothelioma claims.

13. “Estimation Trial” means the trial to estimate Garlock’s aggregate liability for

asbestos claims, for which the Court made findings of fact and conclusions of law, and upon

which entered judgment embodied in the Estimation Order.

14. “Estimation Order” means the January 10, 2014 Order Estimating Aggregate

Liability entered by the Court, In re Garlock Sealing Technologies LLC, 504 B.R. 71 (2014)

(Docket No. 3296).

15. “Garlock” means Debtor Garlock Sealing Technologies LLC, and unless


16. “Garrison” means Debtor Garrison Litigation Management Corp., Ltd., and unless


17. “Stipulated Protective Order” means the stipulated protective order entered by the

Court March 22, 2011 (Docket No. 1225).


28

CERTIFICATE OF SERVICE

I hereby certify that the foregoing DEBTORS’ RESPONSES TO OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY CLAIMANTS’ FIRST REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED TO THE DEBTORS REGARDING CONFIRMATION ISSUES was served via electronic mail and first-class mail, postage prepaid, to the following:

Jeanna Rickards Koski ([email protected]) (email and mail)Trevor W. Swett ([email protected]) (email only)James P. Wehner ([email protected]) (email only)Caplin & Drysdale, CharteredOne Thomas Circle, NW, Ste. 1100Washington, DC 20005

Jonathan P. Guy ([email protected]) (email and mail)Kathleen A. Orr ([email protected]) (email only)Gregory Beaman ([email protected]) (email only)Orrick, Herrington & Sutcliffe LLP1152 15th Street, N.W.Washington, DC 20005

Mark Nebrig ([email protected]) (email and mail)Taylor Stukes ([email protected]) (email only)Moore & Van Allen PLLCSuite 4700100 North Tryon St.Charlotte, NC 28202

This 16th day of July, 2015.

/s/ Garland S. CassadaGarland S. Cassada


EXHIBIT E

Case 10-31607 Doc 4865-5 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. E June 2013 Proposed Order Page 1 of 7

851815v.4

UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA

Charlotte Division

________________________________________ )

In Re: ) Chapter 11 )

GARLOCK SEALING TECHNOLOGIES ) Case No. 10-31607 LLC, et al. ) ) Debtors.1 ) Jointly Administered ________________________________________ )

ORDER GRANTING IN PART AND DENYING IN PART THE MOTION OF THE OFFICIAL COMMITTEE OF ASBESTOS PERSONAL INJURY

CLAIMANTS AND JOSEPH W. GRIER, III, FUTURE ASBESTOS CLAIMANTS’ REPRESENTATIVE, FOR AN ORDER IN LIMINE

OR, IN THE ALTERNATIVE, TO COMPEL DISCOVERY

This matter came before the Court upon the motion of the Official Committee of

Asbestos Personal Injury Claimants (the “ACC”) and Joseph W. Grier, III, the legal

representative for future asbestos claimants in these chapter 11 cases (the “FCR”) for an order in

1 The Debtors in these jointly administered cases are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and the Anchor Packing Company.


- 2 -

limine or, in the alternative, to compel discovery [Dkt. No. 2984] (the “Motion”). The matter

was heard on June 6, 2013 (the “Hearing”). Upon consideration of the Motion, the oppositions

thereto, and the oral arguments and submissions of the parties, the Court is satisfied that good

cause exists to grant the Motion to the limited extent set forth below. Accordingly,

IT IS HEREBY ORDERED THAT:

1. The Motion is GRANTED IN PART and DENIED IN PART, on the terms

provided in this Order.

2. Under the doctrine of “at issue” waiver, the Debtors have waived all privileges,

including the attorney-client privilege and work product protection, with respect to all aspects of

the twenty-six mesothelioma claims (the “Designated Claims”) listed on the ACC’s Exhibit #

133 introduced into evidence at the Hearing. The ACC and the FCR are entitled to full discovery

with respect to the Designated Claims and the Debtors’ handling, investigation, litigation,

evaluation, settlement, and disposition thereof, including their reasons for settling any of the

Designated Claims, their alleged reliance on alleged misrepresentations and concealments of

claimants or their counsel with respect to any Designated Claims, and any alleged connection

between such alleged misrepresentations and concealments and the amount of any settlement

payments made to resolve any Designated Claims.

3. On a rolling basis, to be completed as soon as reasonably possible and in all

events by June 17, 2013, the Debtors shall produce all documents pertaining to the Designated

Claims that discuss any of the following

a. trial risk or predicted outcomes,

b. exposures to asbestos-containing products,

c. bankruptcy ballots,

d. actual or potential asbestos trust claims,


- 3 -

e. evaluations concerning the resolution of the case, including settlement recommendations or trial strategies, and,

f. reports of settlement discussions with opposing counsel,

g. alleged fraud or concealment by claimants or their counsel,

including but not limited to emails or correspondence between or among counsel for the Debtors,

the Debtors’ management, or the Debtors’ corporate parents, trial or case evaluation memoranda,

and forms such as Trial Evaluation Forms and Major Expense Authorizations.

4. All objections to production of the foregoing materials, including objections

based on privilege or work product protection, are overruled.

5. On June 28, 2013, or such other date as the parties may agree upon, the Debtors

shall make available one or more designated corporate witnesses under Rule 30(b)(6), Fed. R.

Civ. P., to testify upon deposition about the Designated Claims.

6. At the aforementioned Rule 30(b)(6) deposition and the upcoming depositions of

John A. Turlik and David M. Glaspy, Debtors, the witnesses, and their counsel shall not

interpose any objection, or any instruction not to answer, that is inconsistent with the foregoing

finding of waiver.

7. Testimony confined to the Designated Claims shall not be deemed to effect a

waiver as to any mesothelioma claims other than the Designated Claims. If, however, the

Debtors make any contention specific to any other asbestos claims that they were defrauded by

any alleged misrepresentation, concealment, or misconduct on the part of the claimant or the

claimant’s counsel, or that they otherwise relied on any such alleged misrepresentation,

concealment, or misconduct or paid an inflated settlement as a result thereof, the waiver

determined by this Order shall apply to such other asbestos claims as well.

8. At the trial for estimation of Garlock’s aggregate liability for pending and future

mesothelioma claims, the Court shall not receive or consider evidence of any matter as to which


- 4 -

Debtors blocked or cut off discovery or testimony by the assertion of a claim of privilege or

work product protection or by an instruction not to answer; nor will the Debtors be permitted to

introduce evidence not timely disclosed in discovery as to their deliberations or decision making

with respect to the handling or resolution of any specific asbestos claim.

9. Except as set forth above, the Motion is denied.

10. This Court shall retain jurisdiction with respect to all matters relating to the

interpretation or implementation of this Order.

This Order has been signed electronically. The Judge's signature and Court's seal appear at the top of this Order.

United States Bankruptcy Court


EXHIBIT F

Case 10-31607 Doc 4865-6 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. F-June 11 2013 Court Email Ruling Page 1 of 2

1

From: George Hodges <[email protected]>Sent: Tuesday, June 11, 2013 7:11 PMTo: Jonathan Guy; Krisko, Jonathan; Ted Swett; Hillary CrabtreeCc: Alex Kenny; Chris Badger; Joe Grier; Tom Moon; Cassada, GarlandSubject: Garlock - proposed order.

All: I have just had the opportunity to read the ACC's proposed order and letter relating to the June 6 ruling - and cannot agree with the proposal of the ACC. What I thought I said at the hearing, and at least intended to say, is that the production of documents I ordered is limited to the TEF's and MEA's. I understand that this may not be entirely coextensive with the case law allowing such discovery, but thought it best to limit the production to the TEF and MEA forms for several practical reasons: First, the whole notion of discovery of privileged material should be as limited as possible. Second, the forms should give the ACC and FCR sufficient insight into Garlock's settlement decisions to permit effective cross-examination and rebuttal. Third, time is short and these documents are readily identifiable and not subject to interpretation. With respect to Coltec's objection, I had not considered Coltec at all, but would suggest that the ruling should apply to it into the extent that any TEf or MEA forms were communicated to Coltec. Unless there is something else to be considered, I do not believe that a response from Garlock or Coltec is necessary. I would appreciate it if the ACC would submit an order along the lines indicated for signing. George

Case 10-31607 Doc 4865-6 Filed 09/29/15 Entered 09/29/15 22:02:38 Desc Ex. F-June 11 2013 Court Email Ruling Page 2 of 2

EXHIBIT G

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF WEST VIRGINIA

CSX TRANSPORTATION, INC. Plaintiff, v. Civil Action No. 5:05-cv-202 ROBERT N. PEIRCE, et al., Defendants. ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFF’S MOTION FOR

PROTECTIVE ORDER CONCERNING MARK COULTER’S FIRST SET OF DOCUMENT REQUESTS TO PLAINTIFF REGARDING THIRD AMENDED

COMPLAINT, GRANTING IN PART AND DENYING IN PART DEFENDANT MARK T. COULTER’S MOTION TO COMPEL AND GRANTING IN PART AND DENYING

IN PART PLAINTIFF’S MOTION TO COMPEL RESPONSES TO ITS FIRST REQUESTS FOR PRODUCTION TO DEFENDANTS ROBERT PEIRCE, LOUIS

RAYMOND AND MARK COULTER

This matter comes before the Court on Plaintiff CSX Transportation, Inc.’s (“CSX”)

Motion for Protective Order Concerning Mark Coulter’s First Set of Document Requests to

Plaintiff Regarding Third Amended Complaint,1 Defendant Mark Coulter’s Motion to Compel,2

and CSX’s Motion to Compel Responses to its First Requests for Production to Defendants

Robert Peirce, Louis Raymond, and Mark Coulter.3

The Court held an evidentiary hearing and argument on the motions on February 28, 2012.

Plaintiff appeared by Marc E. Williams, Esq. and Mitchell K. Morris, Esq., in person. The Lawyer

Defendants appeared by David J. Berardinelli, Esq. and Walter P. DeForest, Esq., in person.

Defendant Ray Harron, M.D. appeared by Jerald E. Jones, Esq., by telephone. At the hearing,

Plaintiff submitted all the exhibits attached to their filings, admitted without objection. 1Dkt. No. 931.

2Dkt. No. 933.

3Dkt. No. 934.

Case 5:05-cv-00202-FPS-JES Document 993 Filed 03/27/12 Page 1 of 28 PageID #: 17536

2

Defendants submitted Exhibits A-K attached to docket number 944, Exhibits 1-8 attached to

docket number 943, and Exhibits A-I attached to docket number 933, each admitted without

objection. Plaintiff offered the testimony of Darin Waylett, an attorney involved with document

production and discovery from McGuire Woods. Defendants offered the testimony of Robert N.

Peirce, Jr. and Robert Daily, attorneys from Robert Peirce and Associates. No other testimony

was taken nor was any other evidence adduced.

I. Introduction

A. Background

Original defendants Robert V. Gilkison, Robert N. Peirce, Jr., Louis A. Raimond, Mark T.

Coulter, and Robert Peirce and Associates, P.C., a law firm, represented persons diagnosed with

asbestosis, a breathing disorder caused by inhaling asbestos fibers, in claims against CSX, using

health screenings to identify people with potential claims against it. After CSX learned that some

claims had been brought against it even though the claimants had tested negative for asbestosis, it

brought claims against the lawyer defendants, the law firm, a staff member of the firm alleged to

have been involved, as well as Dr. Harron, a doctor who read many of the x-rays, alleging

violations of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. §

1961, et seq., common law fraud, and civil conspiracy, all arising allegedly from the successful

efforts of the defendants to deliberately fabricate and prosecute objectively unreasonable, false

and fraudulent asbestosis claims against CSX.

On September 15, 2009, Judge Stamp granted Dr. Harron’s Motion for Summary

Judgment as well as the Motion for Summary Judgment regarding Counts 3 and 4 filed by

defendants Robert Peirce, Jr. and Louis A. Raymond, but the decision was appealed, and the


3

Fourth Circuit Court of Appeals, on December 30, 2010, affirmed in part and vacated in part the

Court’s judgment and remanded the case for further proceedings. On October 19, 2011, CSX filed

its Third Amended Complaint, pleading causes of action for civil RICO, RICO conspiracy,

common law fraud and common law conspiracy against the Lawyer Defendants and Dr. Harron

based on their alleged fraudulent manufacturing, filing and prosecution of eleven claims identified

in the complaint (“the eleven claims at issue”). On October 24, 2011, Defendant Mark Coulter

Served his First Set of Documents Requests to Plaintiff Regarding Allegations in CSX’s Third

Amended Complaint. CSX then served written responses and objections to Defendant Coulter’s

requests for production on December 12, 2011. CSX served its first requests for production

related to its Third Amended Complaint on the Lawyer defendants on October 25, 2011, and the

Lawyer Defendants served their responses and objections on December 12, 2011. The parties,

having met and conferred extensively by telephone and in writing, but being unable to resolve

their remaining points of disagreement, brought their issues before this Court.

B. The Motions

1 Plaintiff CSX Transportation, Inc.’s Motion for Protective Order Concerning Mark Coulter’s First Set of Document Requests to Plaintiff Regarding Third Amended Complaint

2. Defendant Mark Coulter’s Motion to Compel 3. Plaintiff CSX Transportation, Inc’s Motion to Compel Responses to its First

Requests for Production to Defendants Robert Peirce, Louis Raymond, and Mark Coulter

C. Findings of Fact

1. Plaintiff’s Third Amended Complaint alleges a conspiracy beginning in the late 1990s. P.’s Third Am. Compl. ¶ 18.


4

2. Plaintiff’s Third Amended Complaint alleges the Peirce Law Firm acted differently from other firms involved in asbestosis litigation. P.’s Third Am. Compl. ¶ 18-19.

3. CSX has only produced the files related to the asbestos-related claims the Peirce

Firm brought against CSX; it has not produced the other 10,000 documents relating to asbestos claims brought by firms other than the Peirce firm. Waylett Aff., Dkt. No. 931, Exh. 3.

4. The estimated cost to CSX of producing the additional documents requested by

Defendant Coulter is $1.5 million. Waylett Aff., Dkt. No. 931, Exh. 3. 5. CSX had a profit of $3.1 billion dollars in 2010. Dkt No. 943, Exh. 8. 6. Defendants need five pieces of information about past settlements in order to

adequately prepare their defenses: a. The name of the expert(s) used in pursuing the underlying claim. b. The name of the Plaintiff’s lawyer in the underlying claim. c. The settlement amount of the claim. d. Whether the case was a cancerous case, a non-cancerous case, or a mixed

case. e. The ILO read or a copy of the International Labor Office (“ILO”) form

used. 7. Defendants have completed a search of the titles of the documents in their records

but not the text of the documents themselves to respond to Plaintiff’s discovery requests. Defs’ Resp. in Opp. to P.’s MTC at 18.

8. The cost to Defendants of completing a search of the text of their records is

$85,000. This is not an unusual cost for lawyers and law firms in major litigation in this day and time. Defs’ Resp. in Opp. To P.’s MTC at 20.

9. The Court cannot further limit the subject matter of this litigation because Plaintiff

has declined to narrow its allegations or enter into a stipulation that the scope of the instant litigation is limited to those eleven claimants mentioned in the complaint. P.’s MPO at 5 n.5, Exh. 4, at10 n.3.

10. There is no unreasonable burden in ordering the requested discovery considering

the nature of the allegations in this case, the parties’ duties as litigants, and the assets of the parties compared to the estimated costs of production.


5

E. Decisions

CSX’s Motion for Protective Order Concerning Mark Coulter’s First Set of Document

Requests to Plaintiff Regarding Third Amended Complaint is granted in part and denied in part

with respect to Requests for Production of Documents Numbers 7, 8, and 9. Plaintiff is directed to

provide five categories of information via interrogatory response and document production.

CSX’s Motion for Protective Order is denied with respect to Request for Production of

Documents Number 6, and Plaintiff is ordered to produce all documents.

Defendant Mark Coulter’s Motion to Compel is granted in part and denied in part. First,

the Court finds there has been no at-issue implied waiver, but it will address the other privilege

and work product concerns by subsequent order. Defendant’s Motion to Compel is granted with

respect to Interrogatory Number 1. The Motion to Compel is granted in part and denied in part

with respect to Interrogatory Number 2. The Motion to Compel is granted with respect to

Interrogatories 11 and 12 and Request for Production of Documents Number 4. Requests for

Production of Documents 6, 7, 8, and 9 are discussed in this Court’s analysis of Plaintiff’s Motion

for Protective Order and is subject to the same ruling as above. Defendant Coulter’s Motion to

Compel is granted with respect to Requests for Production of Documents 11 and 12. The Motion

to Compel is denied with respect to Requests for Production of Documents 13, 16, 17, and 21.

Finally, Defendant’s Motion to Compel is granted with respect to Request for Production of

Documents Number 22.

CSX’s Motion to Compel Responses to its First Requests for Production to Defendants

Robert Peirce, Louis Raymond, and Mark Coulter is granted in part and denied in part. Plaintiff’s

Motion to Compel is granted with respect to Request for Production of Documents Number 6.


6

The Peirce Firm is also ordered to request that the Circuit Court unseal the deposition transcripts

and, if they are unsealed, they are ordered to produce these transcripts to Plaintiff. As to the

internal documents listed on the privilege log and the letters from November 11, 2011, the Court

will address these issues by subsequent order. The Defendants are ordered to completed full-text

searches of the documents in their database. Finally, Plaintiff’s request that certain intake

questionnaires be produced is denied.

II. Plaintiff CSX Transportation, Inc.’s Motion for Protective Order Concerning Mark Coulter’s First Set of Document Requests to Plaintiff Regarding Third Amended Complaint

A. Contentions of the Parties

First, in its Motion for Protective Order, Plaintiff contends that the Court should overrule

Requests for Production of Documents Numbers 7, 8 and 9 because they are overly broad and

unduly burdensome in that they ask for “[a]ll communications, files and/or claims files” related to

the approximately 13,000 cases that have been settled by CSX, either with the Peirce Firm, other

law firms, or based on an x-ray read or ILO firm signed by Dr. Harron, even though the instant

Complaint only involves the eleven claims at issue, only one of which was settled. Next, Plaintiff

argues that Request for Production of Documents Number 6 should be overruled in that it poses

an undue burden since responding would require Plaintiff to go through approximately 10,000

files spread across forty different law firms on a case-by-case basis to collect and identify

responsive documents from those files. Plaintiff also asks the Court to establish appropriate

procedures governing the discovery of private information relating to the eleven claimants at issue


7

and that it overrule Mark Coulter’s requests for private information about current and former CSX

employees, which will be discussed in the next section of this Order.4

Defendant Coulter contends that although there are only eleven distinct claims at issue in

the instant litigation, Requests for Production of Documents Numbers 7, 8 and 9 are designed to

discover the information that forms the background narrative that Plaintiff may use to frame the

case. As to Request for Production of Documents Number 6, Defendant Coulter contends that

because he is attempting to defend a fraud case, he needs all documents that could possibly

contain admissions and all documents that might bear on the statute of limitations, and these

documents, which mention of Dr. Harron, might have this information.

B. Discussion

1. Motion for Protective Order Governing Requests for Production of Documents Numbers 7, 8 and 9

The issue before the Court is whether Defendant Coulter’s requests for production of

settled asbestos case files should be overruled because they are overly broad, unduly burdensome,

and/or irrelevant. As a general rule, a party “may obtain discovery regarding any matter, not

privileged, that is relevant to the claim or defense of any party.” Fed. R. Civ. P. 26(b)(1). In

addition, “the discovery rules are given ‘a broad and liberal treatment.’” Nat’l Union Fire Ins. Co.

of Pittsburgh v. Murray Sheet Metal Co. Inc., 967 F.2d 980, 983 (4th Cir. 1992) (quoting

Hickman v. Taylor, 329 U.S. 495, 507 (1947)). However, courts have the discretion to limit the

scope of discovery where the information sought would prove unduly burdensome to produce.

Fed. R. Civ. P. 26(b)(2). Specifically, the Federal Rules of Civil Procedure instruct the district

4CSX’s motion also requested an extra twenty-one days to submit a revised privilege log, but Defendants’ Response did not contain an objection to this request, and a revised privilege log was produced.


8

courts to limit discovery where its burden or expense outweighs its likely benefit, taking into

account the needs of the case, the amount in controversy, the parties’ resources, the importance of

the issues at stake in the litigation, and the importance of the proposed discovery in resolving the

issue. Fed. R. Civ. P. 26(b)(2)(C)(iii). In this case, although CSX’s Third Amended Complaint

mentions only eleven specific clients of the Peirce Firm and the requested information does not

directly concern these eleven clients, information about how CSX prosecuted and settled

asbestosis cases could be used to develop an argument that CSX was not actually defrauded or

that a cognizable pattern of racketeering activity does not exist to support claims brought under

RICO. See Robinson v. Coastal Family Health Ctr., Inc., 756 F. Supp. 958, 963 (S.D. Miss.

1990). These documents could also bear on a potential statute of limitations defense, or to

disprove allegations that Dr. Harron entered into a conspiracy with Defendants. Accordingly, the

Court finds that this information is discoverable under Rule 26. But, although this information is

relevant to Mark Coulter’s and the other Lawyer Defendants’ defenses, that does not mean that

the information must be turned over via full document production when Defendant could discover

this relevant information by a pointed interrogatory. Per Federal Rule of Civil Procedure 26(b)(2),

any discovery device “shall be limited by the court if it determines that...the discovery sought...is

obtainable from some other source that is more convenient, less burdensome, or less expensive.”

Here, providing interrogatory responses will be less burdensome that providing a full document

production. Accordingly, the Court orders that Plaintiff must collect and review these documents

and provide Defendant with: 1) The name of the expert(s) used in the claim, 2) the name of the

Plaintiff’s lawyer(s), 3) the settlement amount, and 4) whether the case was a cancerous or non-


9

cancerous asbestosis claim. Furthermore, it must produce the ILO read or a copy of the

International Labor Office (“ILO”) form.1

2. Motion for Protective Order Governing Request for Production of Documents Number 6

The next question posed to this Court is whether Defendant Coulter’s Request for

Production of Documents Number 6 should be overruled because it is unduly burdensome in that

it seeks documents relating to claims brought by law firms other than the Peirce firm and the

documents are in the possession of over forty different law firms. As a general rule, courts have

the discretion to limit the scope of discovery where the information sought would prove unduly

burdensome to produce. Fed. R. Civ. P. 26(b)(2). Specifically, the Federal Rules of Civil

Procedure instruct the district courts to limit discovery where its burden or expense outweighs its

likely benefit, taking in to account the needs of the case, the amount in controversy, the parties’

resources, the importance of the issues at stake in the litigation, and the importance of the

proposed discovery in resolving the issue. Fed. R. Civ. P. 26(b)(2)(C)(iii). In this case, similar to

the analysis provided above, these requested claims files could contain important information that

Defendants could use to support a statute of limitations defense or to assert other substantive

defenses, so they are relevant. Although Plaintiff estimates that it will cost $1,500,000 to produce

this information, under Federal Rule of Civil Procedure 26(b)(3), a balancing approach is taken to

determine whether documents must be produced. In this case, Plaintiff’s net income was over 3.1

billion dollars last year, and although this does serve to particularize the burden that would be

created by requiring production, given the strong financial posture of the company, in addition to

the lack of evidence that ordering production would be impossible for lack of manpower or that it

would adversely impact operational capabilities, the Court finds it will not present an undue 1 The Court undertakes a more detailed analysis of the production of the ILOs infra p. 19.


10

burden. Therefore, this Court denies Plaintiff’s Motion for a Protective Order with respect to

Request for Production of Documents Number 6.

III. Defendant Mark T. Coulter’s Motion to Compel

A. Contentions of the Parties

First, Defendant Mark T. Coulter contends that the Court should compel production of

certain documents listed on CSX’s privilege log since it has over-designated privileged materials

including communications with opposing counsel and internal claims department files.

Defendant also argues that CSX has waived its right to withhold on privilege grounds by placing

the subject of certain requests for production of documents directly at issue in this case, such as

its state of mind, its knowledge, and the possible application of the statute of limitations, and that

the privilege log is deficient because it lacks specificity. Next, Defendant Coulter argues that CSX

should be compelled to produce documents that it has withheld based on privacy-related

objections because the proper procedure is not to withhold these documents but to either redact

documents or enter a protective order. Then, Defendant Coulter argues that CSX should be

compelled to fully respond to Interrogatories Numbers 1, 2, 11, and 12 for a variety of reasons,

for example because the work product doctrine does not apply, because CSX’s scope objections

are unfounded, and because privilege does not apply to purely statistical information. Finally,

Defendant Coulter argues CSX should be compelled to fully respond to Requests for Production

of Documents Numbers 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 21, and 22 for a variety of reasons, for

example because, again, CSX’s scope objections are unfounded, because production would not be

overly burdensome, because the evidence is relevant to impeachment, development of their


11

defenses, assessing credibility, and because privacy concerns are not a valid basis for

withholding.

Plaintiff contends that it has properly asserted privilege and work product protection, and

that Defendant Coulter’s argument that internal claims department files were improperly withheld

is baseless because they were communications made between employees and in-house counsel for

the purpose of securing legal assistance. Plaintiff also contends that it has not waived its right to

assert privilege because the mere act of placing a subject at issue in a lawsuit does not amount to a

waiver of privilege. As to work product protection, Plaintiff argues Defendant has not specifically

articulated the need for these documents, nor has he demonstrated why he cannot obtain these

documents through other means. Then, Plaintiff argues that it should not be compelled to provide

additional responses to Interrogatories Numbers 1, 2, 11, and 12 for a variety of reasons, for

example because the information would reveal the pattern of investigation by its attorneys,

because of undue burden and expense, because the interrogatory is vague, because the

information requested is irrelevant, and because the request is overly broad. Finally, Plaintiff

argues that it should not be compelled to fully respond to Requests for Production of Documents

Numbers 4, 6, 7, 8, 9, 11, 12, 13, 16, 17, 21, and 22 for a variety of reasons, for example because

the information requested is irrelevant, because obtaining the requested information would be

unduly burdensome, because the information is protected by the work product doctrine and the

consulting expert privilege, because the document requests are overly broad, and because

Plaintiff’s document collection and preservation efforts have not yet been called into question.

B. Discussion 1. Privacy, Privilege and Work Product


12

The first question posed to this Court is whether Plaintiff has improperly withheld certain

documents under claims of privilege of work product protection. Defendant first argues that CSX

has waived its rights to assert privilege by placing certain subjects directly at issue in this case,

such as CSX’s state of mind, its knowledge and information, its settlement practices in FELA

asbestosis actions, and its ability to defend against FELA actions. Although “at issue” implied

waiver of the attorney-client privilege has been defined rather inconsistently by various circuit

and district courts, and even though it is true that a party can waive the privilege by putting the

advice of an attorney in issue, the Third Circuit in Rhone-Poulenc Rorer v. Home Indemnity Co.

succinctly addressed the issue now before this Court. There, the Court held there is no “at issue”

implied waiver of the attorney-client privilege where no party has “interjected the advice of

counsel as an essential element of a claim.” Rhone-Poulenc Rorer v. Home Indem. Co., 32 F.3d

851 (3d Cir. 1994). Rather, it held that “a party does not lose the privilege to protect attorney

client communications from disclosure in discovery when his or her state of mind is put in issue

in the action.” Id. at 864. Similarly, here, although Plaintiff asserts claims of fraud among others,

for relying on representations made by Defendant Coulter and the other Lawyer Defendants, it has

never put advice received by its attorneys at issue, nor has it disclosed any of its attorney-client

communications. Accordingly, this Court must find that there has been no general “at issue”

implied waiver of the attorney-client privilege.

As to individual documents which may have been mistakenly withheld under claims of

attorney-client privilege or work product protection, this Court will consider these documents by

reviewing documents representative of a categories of documents listed in the more than 1,300

pages of the privilege log. This Court held a telephone conference for March 7, 2012 to further


13

elucidate these categories and the documents on the privilege log. Accordingly, the Court will

address these issues by separate order and thus declines to address the issues here.

2. Interrogatory Number 1

Interrogatory Number 1 asks for the names of Peirce Firm clients CSX has contacted

regarding representation by the Peirce Firm in asserting a claim based on asbestos exposure

against CSX and claims in the instant action. While these names and addresses alone are not the

thoughts or impressions of counsel, the totality of the names and addresses in globo has the

potential to reveal the pattern of investigation and exploration undertaken by a party’s attorney.

Massachusetts v. First Nat’l Supermarkets, Inc., 112 F.R.D. 149, 153-54 (D. Mass. 1986); Uinta

Oil Ref. Co. v. Cont’l Oil Co., 226 F. Supp. 495, 506 (D. Utah 1964)(finding the “detailed

pattern of investigation and exploration in and of itself s not a proper subject for discovery.”).

Accordingly, this Court must deny Defendant Coulter’s Motion to Compel with respect to

Interrogatory Number 1. However, the Court notes that this issue essentially boils down to

semantics. Plaintiff concedes that Defendants have a right to ask for the identity of people with

knowledge about representation by the Peirce Firm in asserting a claim based on asbestos

exposure, however it argues that asking for the names of people interviewed or contacted by the

Plaintiff for this litigation is protected work product. What this means is that a rephrased

interrogatory that asks for the names and addresses of people who might have knowledge of

these facts would be permissible, and would provide Defendant Coulter with the information he

requests without revealing Plaintiff’s attorneys’ pattern of investigation, although many of the

people might only have minor pieces of information.

3. Interrogatory Number 2


14

Interrogatory Number 2 inquires about historical and statistical information about CSX’s

past settlements in asbestosis cases. The substance of this interrogatory was essentially covered

via the Court’s analysis of Requests for Production of Documents Number 7, 8, and 9, supra p. 9,

and order that Plaintiff must respond by interrogatory response by answering four questions with

respect to the settlement documents: 1) The name of the expert(s) used in the claim, 2) the name

of the Plaintiff’s lawyer, 3) the settlement amount, 4) whether the case was a cancerous or non-

cancerous asbestosis claim. Also, Plaintiff must provide the ILO read or a copy of the

International Labor Office (“ILO”) form. Accordingly, this Court declines to further discuss

Interrogatory Number 2.

4. Interrogatories Numbers 11 and 12

Interrogatories 11 and 12 ask for the total number of B-reads of chest x-rays involved in

asbestos litigation and the total number of x-rays read as positive for asbestosis by each of CSX’s

doctors from 2000 to October 2010.5 Although Plaintiff argues these are not relevant because

none of the B readers identified in response to Interrogatory Number 10 were involved with the

eleven claims at issue in this case, in keeping with the Court’s discussion of relevance above with

regard to Requests for Production of Documents Numbers 7, 8 and 9, the Court takes a broader

view of relevance that extends beyond just the eleven claims at issue. Here, Dr. Harron’s rate of

reading positive x-rays is at issue, but if these statistics show CSX’s own doctors had similar

positive reading rates, then this undercuts CSX’s fraud claim, and, if the converse is true, that

CSX’s own doctors were not confirming Dr. Harron’s positive reads, then CSX may have been

put on notice of potentially fraudulent conduct. Accordingly, these statistics are relevant. Plaintiff

5Although the original Interrogatories were worded more broadly, Defendants voluntarily limited the requests. See Reply Brief of Def. Coulter in Support of MTC at pg. 8.


15

also argues that these are protected under the consulting expert privilege, but as this Court noted

in its January 19, 2012 Order, plain statistical information such as this is not protected by the law

of privilege. See State ex rel. U.S. Fid. and Guar. Co. v. Canady, 194 W.Va. 431 (1995)(noting

distinction between communications and facts). Therefore, this Court grants the Motion to

Compel with respect to Interrogatories 11 and 12.

5. Request for Production of Documents Number 4

Request for Production of Documents Number 4 requests documents that reflect that other

law firms used mass screenings for asbestosis claims and that CSX was aware of this. As a

general rule, a party “may obtain discovery regarding any matter, not privileged, that is relevant

to the claim or defense of any party,” Fed. R. Civ. P. 26(b)(1), and this Court assigns this Rule a

broad and liberal treatment. Furthermore, information is relevant “if it is germane and has any

bearing on the subject matter of the case.” West Penn Power Co. v. NLRB, 394 F.3d 233, 242

(4th Cir. 2005). Courts have broad discretion in determining whether proposed discovery is

relevant. See Watson v. Lowcountry Red Cross, 974 F.2d 482, 489 (4th Cir. 1992). In this case,

Plaintiff’s Third Amended Complaint makes a reference to what it believes were inappropriate

mass screenings conducted by the Peirce Law Firm. Accordingly, if Plaintiff had knowledge that

this was common practice among law firms litigating asbestos cases, or if it had knowledge that

this was not common practice among law firms, then this information would be relevant to both

Plaintiff’s claim and to Defendants’ defense. Therefore, the Court finds that this Request for

Production of Documents is relevant and therefore grants Defendant Coulter’s Motion to Compel

with respect to this request.

6. Request for Production of Documents Numbers 6, 7, 8, and 9


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Requests for Production of Documents Numbers 6, 7, 8, and 9 ask for documents related

to Dr. Harron, case files for claims settled with a client of the Peirce Firm, case files for claims

settled with clients of other firms, and cases involving x-rays read or ILO forms signed by Dr.

Harron, respectively. The substance of these Requests for Production of Documents was covered

in the Court’s analysis of CSX’s Motion for Protective Order Concerning Mark Coulter’s First

Set of Document Requests to Plaintiff Regarding Third Amended Complaint supra pp. 8-11, and

order that Plaintiff must respond to the Requests. Accordingly, this Court declines to further

discuss these requests for production of documents.

7. Requests for Production of Documents Numbers 11 and 12

Requests for Production of Documents Numbers 11 and 12 ask for ILO forms from B-

readers for CSX in cases settled with Peirce firm clients and with clients of other law firms. As

discussed in the Court’s analysis of Requests for Production of Documents Numbers 7, 8, and 9,

supra p. 9, and as discussed in the Courts analysis of Interrogatories Numbers 11 and 12, supra

pps. 15-16, the Court takes a broader view of relevance that extends beyond just the eleven claims

at issue. Here, Dr. Harron’s rate of reading positive x-rays is at issue, but if these statistics show

CSX’s own doctors then this undercuts CSX’s fraud claim, and, if the converse is true, that CSX’s

own doctors were not confirming Dr. Harron’s positive reads, then CSX may have been put on

notice of potentially fraudulent conduct. Accordingly, these statistics are relevant. Plaintiff also

argues that these are protected under the consulting expert privilege. Rule 26(b)(4)(D) contains

the so-called consulting expert privilege, which provides that “ a party may not, by interrogatories

or deposition, discover facts known or opinions held by an expert who has been retained or

specially employed by another party in anticipation of litigation or to prepare for trial and who is


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not expected to be called as a witness as trial.” However, a party may do so “on showing

exceptional circumstances under which it is impracticable for the party to obtain facts or opinions

on the same subject by other means.” Fed. R. Civ. P. 26(b)(4)(D)(ii). In this case, the Court finds

that such exceptional circumstances exist. In the typical case, doctors who have provided medical

reports do not meet the “exceptional circumstances” test because the opposing party can have its

own experts analyze the medical records to defend a claim. In this case, however, it is just these

conflicting medical reports, and the rates at which their findings were similar or dissimilar, that

are at issue. This is unique knowledge that Defendants would not otherwise be able to acquire. In

addition, the Plaintiff may have relied on these non-testifying experts’ ILOs in forming the basis

for their settlement offers, and this also creates a unique circumstance. See Transcript of

Telephone Conference Before James T. Giles, In re Asbestos Prods. Liab. Litig., No. 2:01-MD-

00875, at 17 (E.D. Pa. Apr. 1, 2008)(noting that an exceptional circumstance existed when

plaintiff relied on a non-testifying expert’s diagnosis in making a claim against a trust). Thus,

Defendant Coulter’s Motion to Compel is granted with respect to Requests Numbers 11 and 12

and Plaintiff is required to produce these ILO forms, both with respect to Peirce Firm clients and

for clients from other firms.


Request for Production of Documents Number 13 asks for three categories of documents

from the personnel files of seventeen CSX employees who were involved with settling asbestosis

cases including 1) documents related to discipline and termination, 2) documents related to

asbestos and asbestosis claims, and 3) documents related to the Peirce Firm or Peirce Firm

attorneys. Numerous courts have recognized that personnel files of employees are subject to


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discovery only in limited circumstances. This is because “personal privacy and accurate,

employee evaluations are important public policy concerns.” Blount v. Wake Elec. Membership

Corp., 162 F.R.D. 102, 105 (E.D.N.C.1993). If courts frequently allowed discovery of employee

files, they “would discourage future candid evaluations of employees, making it difficult for the

firm to maintain its standards and improve its performance.” Id. Nevertheless, courts have

recognized the broad scope of discovery provided in the Federal Rules competes with the interest

of employee privacy. In re Hawaii Corp., 88 F.R.D. 518, 524 (D.Haw.1980). Therefore, courts

have formulated a two-part test to determine if material in an employee personnel file should be

discoverable. It “is permissible only if ‘(1) the material sought is clearly relevant and (2) the need

for discovery is compelling because the information sought is not otherwise readily obtainable.’”

Coker v. Duke & Co., 177 F.R.D. 682, 685 (M.D.Ala.1998) (quoting In re One Bancorp Secs.

Litig., 134 F.R.D. 4, 12 (D.Me.1991)). The party seeking discovery bears the burden of showing

that it meets these criteria. Twigg v. Pilgrim’s Pride Corp., 2007 U.S. Dist. LEXIS 14669, at *42

(N.D. W.Va. Feb. 28, 2007). In applying the above test, a distinction exists between employees

whose conduct is directly at issue and other employees, and a discovering party must make a

separate showing of why the personnel files of other employees are discoverable. Cason v.

Builders Firstsource-Southeast Grp., Inc., 159 F.Supp. 2d 242, 248 (W.D.N.C. 2001).

In this case, Defendants seek the personnel files of these seventeen employees “to

discover evidence for potential impeachment of these witnesses,” Mot. to Compel 19, indicating

that this information is not critical to its defenses or to Plaintiff’s claims. Furthermore, Defendants

have offered no evidence to indicate why this information is unavailable by other discovery

methods, and it is not difficult to imagine that this would be available from other sources, such as


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a deposition. Where a party merely “identifies generic ways in which evidence found in a

personnel file could be used to impeach a witness,” this is not enough to overcome privacy

concerns to merit discovery. Dzanis v. JP Morgan Chase & Co., 2011 U.S. Dist. LEXIS 137256,

at *17-18 (S.D.N.Y. Nov. 30, 2011). Accordingly, this Court finds that Defendants have failed to

meet their burden to show that these employee personnel files are discoverable. Therefore, the

Court denies Defendant Coulter’s Motion to Compel with respect to Request for Production of

Documents Number 13.

9. Request for Production of Documents Number 16 Request for Production of Documents Number 16 asks for all yearly budgets for CSX’s

legal department, any other department performing legal work for CSX and for outside counsel

from 1993 to the present. Defendant Coulter argues he has asked for this information in order to

refute CSX’s allegation in the Third Amended Complaint that it was unable to defend itself

against the tort filings by the Peirce firm. As noted above with respect to Defendants’ request for

a list of all witnesses contacted by Plaintiff, while a single financial total alone is not enough to

reveal the thoughts or impressions of counsel, the totality of an itemized legal budget has the

potential to reveal the opinions of counsel and would reveal information about their impressions

of various law suits. At the February 28, 2012 hearing, counsel explained that CSX has already

produced its financial statements to defendant Coulter including its yearly budgets for the years

requested, and the Court finds these are sufficient. Accordingly, Defendant Coulter’s Motion to

Compel is denied with respect to Request for Production of Documents Number 16.



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Request for Production of Documents Number 17 asks for the document retention or

preservation policies in effect at CSX from 1993 to the present so that Defendant Coulter is able

to assess CSX’s possible failure to produce documents. This Court has held that “mere

speculation that documents exist is not a sound basis for a motion to compel production. Rather,

the moving party must have a colorable basis for its belief that relevant, responsive documents

exist and are being improperly withheld.” Susko v. City of Weirton, 5:09-cv-2, 2011 WL 98557,

at * 4 (N.D. W.Va. Jan. 12, 2011). See also Health Care Serv. Corp. v. Mylan Labs., Inc., 219

F.R.D. 12 (D.D.C.2003) (“The federal courts are often confronted with a party's complaint that its

opponent must have documents that it claims not to have. Such suspicion is, however, insufficient

to warrant granting a motion to compel.”). Here, Defendant Coulter’s naked assertion of

discovery impropriety is unwarranted and improper without any substantive evidence to support

his claims. Furthermore, Rule 26(g) of the Federal Rules of Civil Procedure requires that an

attorney certify that he or she has made a reasonable effort to assure that the client has provided

all the information and documents available to the client that are responsive to the discovery

request. In this case, Plaintiff has made such a certification, so without more, the Court cannot

compel production of the document retention or preservation policies. However, this Court may

reconsider this request at a later date if Defendants produce information indicating that not all

documents have been produced. Accordingly, Defendant Coulter’s Motion to Compel is denied

with respect to Request for Production of Documents Number 17.


Request for Production of Documents Number 21 asks for documents relating to any

Peirce Firm client mentioned by name in the Third Amended Complaint. In Plaintiff CSX


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Transportation, Inc.’s Opposition to Defendant Mark Coulter’s Motion to Compel and also at the

February 28, 2012 hearing Plaintiff agreed that it would produce these documents. Therefore,

Defendant Coulter’s Request for Production of Documents Number 21 is denied as moot.


Request for Production of Documents Number 22 asks for all documents relating to the

Peirce Firm or to any Peirce Firm lawyer’s FELA asbestos practice. As this Court has repeatedly

reiterated throughout this opinion, it takes a broader perspective of relevance than counsel for

CSX. Here, Defendant Coulter argues these documents are relevant to its theory that the Peirce

Firm was not being used as a racketeering enterprise by collecting documents that show CSX

knew it was operating as a typical law firm would. Furthermore, if CSX has documents that

reflect it was suspicious about the Peirce Firm or its attorneys at some early date, these could be

relevant to Defendants’ defenses. Accordingly, this Court finds that CSX’s relevancy objections

with respect to this document request are without merit. However, Plaintiff also raises scope

objections to this request for production of documents. As a rule, a request can fail for

overbreadth it is not reasonably limited with respect to time. Williams v. Havlin, 2011 U.S. Dist.

LEXIS 88508, *7-9 (E.D. Cal. Aug. 10, 2011) (party justified in not responding to request that “is

overly broad in that it is wholly unlimited in time”); Bitler Inv. Venture II, LLC v. Marathon

Ashland Petroleum LLC, 2007 U.S. Dist. LEXIS 29159, *18-19 (N.D. Ind. Apr. 18, 2007)

(denying motion to compel responses to requests “unlimited in scope and largely unlimited as to

time” and finding that “these overly broad requests amount to little more than a fishing

expedition”). In this case, Plaintiff alleges that the conspiracy began in the late 1990s, which this

Court will interpret as meaning 1998. As this Court has previously stated, where a conspiracy is


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alleged, the scope of discovery may include documents that predate or postdate the conduct

immediately giving rise to the legal action. See Wilder Enters., Inc. v. Allied Artists Pictures

Corp., 632 F.2d 1135, 1143 (4th Cir. 1980); Erone Corp. v. Skouras Theatres Corp., 22 F.R.D.

494, 499 (1958)(allowing discovery to extend to period five years before formation of alleged

conspiracy); In re Folding Carton Antitrust Litig., 83 F.R.D. 251, 254 (D. Ill. 1978)(allowing

discovery of information beyond the date the conspiracy is alleged to have ended). Therefore,

allowing for a five-year period extending before the start of the alleged conspiracy, this Court

orders that Defendant Coulter’s Request for Production of Documents Number 22 is granted but

restricted to documents from 1993 to the present.

IV. CSX Transportation, Inc.’s Motion to Compel Responses to its First Requests for Production to Defendants Robert Peirce, Louis Raymond, and Mark Coulter

A. Contentions of the Parties First, in its Motion to Compel, Plaintiff contends that the Court should compel the Lawyer

Defendants to provide all correspondence with each of the eleven claimants at issue related to

physical or medical examinations because such correspondence could be probative of their intent

to defraud CSX. Next, Plaintiff argues that this Court should compel production of deposition

testimony given by Defendants Peirce and Raymond in a malpractice lawsuit. Plaintiff also argues

that Defendants should be compelled to produce the internal notes and ESI regarding the eleven

claimants at issue because the fact and circumstances of a communication are not privileged, or in

the alternative, because the crime-fraud exception applies or because it has a substantial need for

these documents and it cannot obtain them through other means without undue hardship. With

regard to the letters Defendants sent to clients on November 11, 2011, Plaintiff argues these are

not privileged because Judge Stamp’s order terminated the attorney-client relationship as to


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claimants’ FELA claims against CSX. Plaintiff then argues that Defendants should be compelled

to fully comply with Rule 34 by completing full-text searches of the documents in their Practice

Management database because by only searching certain database fields, Defendants have failed

to identify and produce responsive documents. Finally, Plaintiff contends that Defendants should

be compelled to produce the client intake questionnaires because these likely contain evidence

that the Lawyer Defendants falsified claims about alleged exposure to asbestosis.

Defendants claim that medical and physical correspondence related to the eleven

claimants at issue constitutes third-party practice information and is protected by the attorney-

client privilege and the work product doctrine. With respect to the deposition testimony,

Defendants contend that the deposition transcripts have been sealed by the trial court in that case,

and that basic federalism concerns prevent this court from overriding that court’s sealing order.

Defendants contend that the Court should not compel production of their internal notes or ESI

regarding the eleven claimants at issue because these are protected by the privilege rules and work

product doctrine, because the communications are not purely factual, because Plaintiff can obtain

this information through interrogatories or requests for admissions, and because the crime/fraud

exception does not apply. With regard to the letters from November 11, 2011, Defendants claim

these are privileged because they have ongoing relationships with their clients regarding third

party claims and because Judge Stamp’s order recognized that they have ongoing duties to their

former clients. Defendants also argue that they have complied with their obligations under Rule

34, and that Plaintiff’s request that they complete full-text searches of all the documents in their

database is overly burdensome since the documents are not currently in a text-searchable form.

Finally, Defendants contend the client intake questionnaires should not be produced because these


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are the equivalent to initial client interviews and are thus protected by the attorney-client

privilege.

B. Discussion


Request for Production of Documents Number 6 asks for all correspondence with each of

the eleven claimants at issue relating to physical or medical examinations arranged or requested

by the Peirce Firm or the Lawyer Defendants. Plaintiff contends this correspondence is probative

of the Lawyer Defendants’ intent to defraud while the Lawyer Defendants claim this information

is protected by the attorney-client privilege and the work product doctrine. As previously noted in

this Order, the Court will address issues of privilege and work product in a separate order.

Accordingly, Defendants are ordered to produce these documents for the Court to conduct an in

camera review.

2. Request for Production of Documents Number 11 Request for Production of Documents Number 11 asks for complete transcripts and/or

audio or video recordings of all testimony given by Defendants Peirce and Raymond. This request

for production of documents turns on two depositions given by Defendants Peirce and Raymond

in a malpractice lawsuit. Plaintiff contends that it needs these deposition transcripts because the

defendants gave testimony about firm’s occupational claims practice including screenings,

settling claims with CSX, and CSX’s settlement mentality. These depositions were sealed at the

request of the Peirce firm by the Kenton Circuit Court in Kentucky on May 19, 2003 and remain

under seal. At the February 28, 2012 hearing, the Court asked Plaintiff to provide the Court with a

copy of the sealing orders, and this Court has reviewed them. As a rule, “the public’s right of


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access to judicial records and documents may be abrogated only in unusual circumstances.”

Stone v. Univ. of Maryland Med. Sys., 855 F.2d 178, 182 (4th Cir. 1988). However, this

presumption of access is not absolute, and the trial court, in its discretion, has supervisory power

over its own records and may seal documents if the public’s right of access is outweighed by

competing interests. At the same time, the principles of comity and federalism have “traditionally

counseled a federal court to stay its hand...[to] avoid unseemly conflict between two sovereignties

[and] the unnecessary impairment of state functions.” Martin v. Creasy, 360 U.S. 219, 224 (1959).

Accordingly, this Court will not intrude upon the decision of the circuit court by ordering it to

unseal the deposition. However, the Peirce Firm is able to ask the court to unseal the records for

the purposes of this case. Accordingly, it is ordered that the Peirce Firm request the Kenton

County Circuit Court to unseal these depositions, and, if the Circuit Court agrees, it must produce

copies of these depositions to Plaintiff, but subject to the terms of the protective order that limits

their use only to this action and prohibits any further disclosure or dissemination.

3. Internal Documents Listed on the Privilege Log and Letters from November 11, 2011

As the Court has indicated above, it will issue a separate opinion covering issues related to

privilege and work product. Plaintiff also argues that Defendants should be compelled to produce

the internal notes and ESI regarding the eleven claimants at issue because the fact and

circumstances of a communication are not privileged, or in the alternative, because the crime-

fraud exception applies or because it has a substantial need for these documents and it cannot

obtain them through other means without undue hardship. Defendants contend that the Court

should not compel production of their internal notes or ESI regarding the eleven claimants at issue

because these are protected by privilege and work product, because the communications are not


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purely factual, because Plaintiff can obtain this information through interrogatories or requests for

admissions, and because the crime/fraud exception does not apply. With regard to the letters

Defendants sent to clients on November 11, 2011, Plaintiff argues these are not privileged

because Judge Stamp’s order terminated the attorney-client relationship as to claimants’ FELA

claims against CSX. Defendants claim these are privileged because they have ongoing

relationships with their clients regarding third party claims and because Judge Stamp’s order

recognized that they have ongoing duties to their former clients. Accordingly, the Court will rule

on these issues after it has undertaken an in camera review of these documents.

4. Failure to Comply with Rule 34

Next, CSX argues that Defendants should be required to run full-text searches of the

documents in their Practice Manager document management system. To date, the searches

Defendants have performed were only of the “to/from” field in the system, the title field in the

system, and the document description field.. In contrast, Defendants argue that the Practice

Manager database does not currently have the ability to run full-text searches of the documents,

and that to do so would cost it approximately $85,000 to convert the files to readable electric

versions through an optical character recognition (“OCR”) process. As a general rule, courts have

the discretion to limit the scope of discovery where the information sought would prove unduly

burdensome to produce. Fed. R. Civ. P. 26(b)(2). Specifically, the Federal Rules of Civil

Procedure instruct the district courts to limit discovery where its burden or expense outweighs its

likely benefit, taking in to account the needs of the case, the amount in controversy, the parties’

resources, the importance of the issues at stake in the litigation, and the importance of the

proposed discovery in resolving the issue. Fed. R. Civ. P. 26(b)(2)(C)(iii). The Court has


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considered the factors listed and finds Defendants have not made any showing that compliance

with Plaintiff’s production request would be excessively burdensome, thus outweighing the likely

benefits of the requested documents. First, although the cost of running the documents through an

OCR process would be $85,000, but this cost is small relative to the great expenses associated

with modern-day discovery. In addition, other courts have found similarly, holding that it is not

unduly burdensome to require a party to convert its files to a text-searchable format. See J.C.

Assocs. v. Fid. & Guar. Ins. Co., No. 01-2437, 2006 U.S. Dist. LEXIS 32919, at *2-5 (D.D.C.

May 25, 2006). Furthermore, since the Lawyer Defendants performed their initial search of the

database, they have produced additional documents related to Dr. Harron and Dr. Corbitt in

response to specific inquiries by CSX, indicating that a the current restrictive field searches are

not finding all documents responsive to CSX’s discovery requests. Therefore, the Court finds

Defendants’ arguments based on undue burden are without merit and CSX’s Motion to Compel is

granted with respect to these documents.

5. Prospective Client Questionnaires

Finally, CSX contends that it has the right to discover the pages relating to claimed

exposures to asbestos in client intake Occupational Disease Screening Questionnaires because

they may contain evidence that the Lawyer Defendants falsified the claimants’ alleged exposures

to asbestos. Defendants argue that these are protected by the attorney-client privilege because they

are the written equivalent of an initial client consultation, while CSX maintains that there could

have been no reasonable expectation of privacy with respect to these questionnaires. As

previously noted in this Order, the Court will address issues of privilege and work product in a

separate order. Accordingly, Defendants are ordered to produce five client intake Occupational


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Disease Screening Questionnaires, only the pages relating to claimed exposures, for the Court to

conduct an in camera review.

V. Decision

It is ORDERED:

Plaintiff’s Motion for Protective Order Concerning Mark Coulter’s First Set of Document

Requests to Plaintiff Regarding Third Amended Complaint is GRANTED IN PART AND

DENIED IN PART. Defendant Mark Coulter’s Motion to Compel is GRANTED IN PART

AND DENIED IN PART. Plaintiff’s Motion to Compel Responses to its First Requests for

Production to Defendants Robert Peirce, Louis Raymond and Mark Coulter is GRANTED IN

PART AND DENIED IN PART. All production ordered shall be done within thirty (30) days of

the date of this order

Filing of objections does not stay this Order.

Any party may, within fourteen (14) days of the date of this order, file with the Clerk of

the Court written objections identifying the portions of the Order to which objection is made, and

the basis for such objection. A copy of such objections should also be submitted to the Honorable

Frederick P. Stamp, Jr., United States District Judge. Failure to timely file objections to the Order

set forth above will result in waiver of the right to appeal from a judgment of this Court based

upon such Order.

The Clerk of the Court is directed to mail a copy of this Order to parties who appear pro se

and any counsel of record, as applicable.

DATED: March 27, 2012

/s/ James E. Seibert JAMES E. SEIBERT UNITED STATES MAGISTRATE JUDGE


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