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57040858Apr 07 201502:46PMFILEDSuperior Court of CaliforniaCounty of Los AngelesSherri R. CadRyIGAL-u.,,,,,cer erk ' depubwLALFREDO MORALES .o.SFSUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES:oordinated Proceedingjpecial Title (Rule 3.550)) CASE NO. JCCP 46741TGs,,AOSD ASBESTOS CASESThe Court, Honorable Emilie H. Elias presiding, conducted a hearing on June 20,20'egarding the Defense Discovery Committee's Motion Proposing Disclosure Requirements F'ersonal Injuly Claims Pursuant to 11 U.S.C.A. §524(G).After considering the moving and opposing papers and the arguments of counsel forlefendants and for plaintiffs, and good cause appearing, the Court hereby makes this ruling,d)rders that all plaintiffs and their counsel appearing in LAOSD Asbestos Cases comply withelisclosure requirements set forth herein.1.BANKRUPTCY TRUST RELATED INTERROGATORIES.The Court hereby incorporates into the August 11,2014 Case Management Standing I derie: Discovery In All Coordinated LAOSD Cases the following: (a) the additional interrogate es ttachedhereto as Exhibit I , and (b) the LAOSD Standard Interrogatories to Plaintiffs' attacl i-CASE MANAGEMENT ORDER REQUIRTNG DISCLOSURE OF BANKRUPTCY TRUST CLAIMS, CLAIMS-RIELMATERIALS, AND ADESI'OS EXPOSURE FACTSED

1hereto as Exhibit 2 which contains a revision to Interrogatory 68. In addition, the Court here; yorders that plaintiffs supplement and update their response s to Defendant's additionalinterrogatories (Exhibit 1) and interrogatories 68 to 72 of the LAOSD Standard Interrogatorids toPlaintiffs (Exhibit 2), no later than 5 days before trial. if new witnesses or documents have bJendiscovered.ItThe Court finds that facts relating to a plaintiffs andlor decedent's alleged exposures oasbestos are not privileged and are discoverable. Plaintiffs are required to disclose all facts1relating to all of their alleged exposures to asbestos, whether to the products or premisesattributable to named defendants, or to bankrupt or other entities, and regardless of whether thosefacts have been ,or ever will be, included in a claim to a third party for the purpose of obtainingcompensation for an asbestos-related injury. Plaintiffs may not object or refuse to produceinformation relating to exposure facts in response to appropriate discovery requests fromsuch facts may also appear in otherwise privileged documents such as signed affidavits or1unsubmitted bankruptcy trust claim forms. No waiver of attorney-client or work product1defendants for the reason that no claims have been or will be made based on such facts or be ausprivileges will result from the disclosures required herein.2.BANKRUPTCY TRUST AUTHORIZATIONS.Plaintiffs shall execute and provide a Bankruptcy Trust Authorization in the form1attached hereto as Exhibit 3 at the same time and in the same manner as the other authorizationspursuant to this Court' s Order regarding Plaintiffs' Authorization s.3.PRODUCTION OF BANKRUPTCY TRUST RELATED DOCUMENTS.i1IPlaintiffs shall produce all documents sent to, received from, shown to, exchanged with,lor otherwise disclosed to any established or pending asbestos trust funds (including but not limitecto their administrators and/or agents, supervising courts and their agents, claims processingfacilities and their agents), for any purpose including, but not limited to, supporting a claim foq anasbestos-related injury, or providing notice of, or reserving a place for, a future claim for-2-MATERIALS, AND ABESTOS EXPOSURE FACTS

Icompensation for an asbestos-related injury . This production shall include, but is not limited to,2ballots, questionnaires, submitted or filed forms, summaries, claims, "placeholder" claims,3requests for extensions, requests for details, all supporting documentation, all related4communications, and all documents filed, lodged and/or submitted on or after January 1,2015pursuant to Rule 201 9 of the Federal Rules of Bankruptcy Procedure. These communicationd are6not privileged and must be produced pursuant to this order in each case.1iiIn addition, declarations and/or affidavits that have been circulated to someone other t, an78Plaintiff and Plaintiffs' counsel (including hisher law firm) and set forth facts regarding a9plaintiffs and/or decedent's exposure to asbestos or an asbestos-related injury, are not privileged10121314IIIIIand must be produced pursuant to this order in each case.11II161l718Plaintiffs serve responses to Defendants ' Standard Interrogatories. In addition, the Court herdbyorders that Plaintiffs shall supplement this production of bankruptcy claim related documentsdeclarations no later than 5 days before trial.4.EFFECTIVE DATE OF ORDER.This Order applies to all LAOSD Asbestos Cases where the initial complaint, or any11 amendmentto complaint to assert wongful death and/or survival claims, is filed on or after11IIa19 February 1,2015, for a six month trial period. This Order shall remain in effect after the2011IT IS SO ORDEREDDATED:2526conclusion of the six month trial period unless amended ,vacated or otherwise superseded byfurther order of the Court.212324IIThis production shall be made pursuant to this Order in each case at the same time thaI1 / 7,2015Honorable Emilie H. EliasLos Angeles Superior Court JudgeMATERIALS, AND ABESTOS EXPOSURE FACTSII

FOR THE COUNTY OF LOS ANGELESIn re Los Angeles Asbestos Litigation General Orders Coordinated ProceedingSpecial Title (Rule 3.550)l1ISl6l7l819202122I/11111)1)1/I1)LAOSD STANDARD BANKKUP'I'CY) INTERROGATORIES TO PLAINTIFFSLAOSD ASBESTOS CASESj1[EXHIBIT 11tach plaintiff in the above-captioned asbestos litigation is required to respond to thefollowing Standard Bankruptcy Interrogatories separately and fully in writing, under oath,11pursuant to Code ofcivil Procedure #2030.010, et seq. In responding these interrogatories, tieplaintiff is required to furnish all information that ioor purporting to act on hishcr behalf, including, but not limited to, the plaintiffs counsel, age&,representatives, and employees. fthe plaintiffcannot answer an interrogatory completely, heikeishall answer to the fullest extent possible and specie the reason(s) for hisher inability to respgndfully.DEFINITIONS2528CASE NO. JCCP 4674'I2426271The fullowing definitions apply to the term s used in these interrogatories:I/IIIASBESTOS BANKRUPT ENTITY shall include all entities, trusts, and agents of allPERSONS who filed for bankruptcy due to asbestos liabilities including, but not limited to, thlselisted on Attachment A hereto.LAOSD STANDARD BANKRUPTCY MTERROGATORIES 'I'O PTAINTIFFS[EXHIBIT 11I

[email protected]) shall mean "writing" as defined in Evidence Code § 250 including, butnot limited to, any and all physical articles of admissible or imdmissible evidence, exemplarspackaging, invoices, contracts, agreements, purchase orders, memoranda, notes, instructions,catalogues, specifications, plans, formulas, bill s of lading, receipts, work orders, customer cadepositions, electronic mail, declarations, affidavits, written discovery DOCUMENTS ,photographs, videotapes, audiotapes, scanned DOCUMENTS, microfiche, databases of reconAdobe Acrobat.pdf files, jpg files, electronic images, digital images, digital files, hard drives,CD-KOMs, and DVD-ROM s. DOCUMENTS also include DOCUMENTS in the memory ocomputer systems, on diskettes, CD-ROMs, or on other computer memory storage devices.IDENTIFY and IDENTITY shall mean to describe in sufficient detail to satisfy therequirements of a request for production of DOCUMENTS under Code of Civil Procedure55 203 1.010 et seq., including but not limitcd to the title, date, author and publisher of theDOCUMENT, and lor stating the name and address and telephone number of each PERSONindicated.PLAINTIFFIDECEDENT shall mean the person whose alleged exposure to asbestos1 gives rise to the current lawsuit.PERSON(S) shall mean any individual penon, business, entity, or organization.YOU and YOUR or any derivative thereof shall mean PLAINTIFFIDECEDENT as \nanyone acting or purporting to act on hisher behalf, including, but not limited to, plaintiffs ardecedent's agents, representatives, counsel, and employees. But shall not include Plaintiffs (decedent's counsel.INTERROGATORIES73.For each claim identified in response to Interrogatory No. 68, state all factssupporting the claim including, but not limited to, the brand name, manufacturer and suppliereach asbestos-containing product, material and/or compound with which PLA INTIFFIDECEDENT worked, worked around, or to which PLAINTIFFDECEDENT was otherwiseexposed, when the exposure occurred, and how the exposure occurred.LI1LAOSD STANDARD BANKRUPTCY INTERROGATORIES 1'0 PLAINTIFFS[EXHIBIT I]

74.For each claim identified in response to Interrogatory No. 68, identify allPERSONS who have knowledge of facts about each asbestos-containing product, materialI/andfor compound with which PLAINTIFFDECEDENT worked, worked around, or to whicPLAINTIFFIDECEDENT was otherwise exposed, which support the claim.75.For each ASBESTOS BANKRUPT ENTITY, state all facts in YOUR care,scustody or control that PLAINTIFFDECEDENT was exposed to any asbestos from an asbe toscontaining product, material andlor compound related to that ASBESTOS BANKRUPTENTITY, including, but not limited to, identiiication of the brand name, manufacturer andsupplier of each asbestos-containing product, material andlor compound, when the exposureoccurred, and how the exposure occurred.76.For each ASBESTOS BANKRUPT ENTITY referenced in response toInterrogatory No. 75, IDENTIFY all PERSONS who have knowledge of facts about the expo ure19including, but not limited to, identification of the brand name, manufacturer and supplier of edchIasbestos-containing product, material and/or compound, when the exposure occurred, and ho theexposure occurred.77.For each ASBESTOS BANKRUPT ENTITY referenced in response toInterrogatory No. 75, IDENTIFY all DOCUMENTS that relate to the exposure including, but not//limited to, identification of the brand name, manufacturer and supplier of each asbestos-contaihn;Iproduct, material and/or compound, when the exposure occurred, how the exposure occurred, an Iwitnesses to the exposure.78.IDENTIFY all DOCUMENTS not previously identified in response toInterrogatory Nos. 68 and 77 that relate to any existing claim by PLAINT IFFIDECEDENTagainst every ASBESTOS BANKRUPT ENTITY including, but not limited to, ballots,declarations, claims, all documents filed, lodged andlor submitted on or after January 1,2015pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure, claims or submissions,proofs of claim, and amendments or supplements thereto.[EXHIBIT I ]I

Asbestos Bankruntcy TrustsTrust NameA&l Corporation Asbestos Bodily Injury TrustA-Best Asbestos Settlement TrustAC&S Asbestos Settlemerlt TrustAmatex Asbestos Disease Trust FundAPG Asbestos TrustAPI, Inc. Asbestos Settlement TrustAnnstrong World Industries Asbestos Personal Injury Settlemerit TrustARTRA 524(g) Asbestos TrustASARCO LLC Asbestos Personal Injury Settlement TrustBabcock & Wilcox Company Asbestos Personal Injury Settlement TrustBartells Asbestos Settlement TrustSpecialty Products Holding Corp. (Bondex) Asbestos Settlement TrustBrauer 524(g) Asbestos TrustBums and Roe Asbestos Personal Injury Settlement TrustC. E. Thurston & Sons Asbestos TrustCelotex Asbestos Settlement TrustChristy Refractories Asbestos Personal Injury TrustCombustion Engineering 524(g) Asbestos PI TrustCongoleum Plan TrustDII Industries, LLC Asbestos P1 TrustDurabla Manufacturing Company Asbestos TrustEagle-Picher Industries Personal Injury Settlement TrustII1Federal Mogul U.S. Asbestos Personal Injury TrustFlintkote Company and Flintkote Mines Limited Asbestos Personal Injury TrustFuller-Austin Asbestos Settlement Trust G-1 Asbestos Settlement Trust-4-LAOSD STANDARD BANKRUPTCY IN'IERROGATONES TO PLMNTIFFS[EXHIBIT 11

Trust Name - Cont'd.H.K. Porter Asbestos TrustHercules Chemical Company, Inc. Asbestos TrustJ.T. Thorpe Settlement TrustJT l'horpe Company Successor TrustKaiser Asbestos Personal Injury TrustKeene Creditors TrustLeslie Controls, Inc. Asbestos Personal Injury TrustLummus 524(g) Asbestos PI TrustManville Personal Injury Settlement TrustMetex Asbestos PI TrustM.H. Detrick Company Asbestos TrustMotors Liquidation Company Asbestos Personal Injury TrustNGC Bodily Injury TrustNorth American Refractories Company Asbestos Personal Injury Settlement TrustOwens Coming Fibreboard Asbestos Personal lnjury TrustPacor Settlement TrustPittsburgh Corning Corporation Asbestos PI TrustPlant Insulation Company Asbestos Settlement TrustPlibrico Asbestos TrustPorter Hayden Bodily Injury TrustQuigley Company, Inc. Asbestos PI TrustRaytech Corporation Asbestos Personal Injury Settlement TrustRock Wool Mfg. Conlpany Asbestos TrustRutland Fire Clay Company Asbestos TrustShook & Fletcher Asbestos Settlement TrustStone and Webster Asbestos Trust-5LAOSD STANDARD BANKRUPTCY INTERROGATORIES TO PLAINTIFFS[EXHIBIT I]

Trust Name - Cont'd.Swan Asbestos and Silica Settlement Trust'I' H Agriculture & Nutrition, LLC Industries Asbestos Personal Injury TrustThorpe Insulation Company Asbestos Personal Injury Settlement TrustUnited States Gypsum Asbestos Personal Injury Settlement TmstUnited States Mineral Products Company Asbestos Personal Injury Settlement TrustUNR Asbestos-Disease Claims T n s tUtex Industries, Inc. Successor TrustWallace & Gale Company Asbestos Settlement TrustWestern MacAtthur-Western Asbestos Trust-6LAOSD STANDARD BANKRUPTCY INTERROGATORIES TO PLAINTIFFS[EXHBK I ]

SUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELESn re Los Angeles Asbestos Litigation 3eneral Orders Coordinated Proceedingspecial Title (Rule 3.550),AOSD ASBESTOS CASES) CASE NO. JCCP 4674I) LAOSD STANDARD INTERROGATORIE) TO PLAINTIFFS)) [EXHIBIT 21)1INTRODUCTIONEach plaintiff in the above-captioned asbestos litigation is required to respond to thebllowing general order inte ogatoriesseparately and fully in writing, under oath, pursuant tc,ode ofcivil Procedure §§2030.010, et seq. In responding these interrogatories, the plaintif.equired to furnish all information that is available to the plaintiff and anyone acting or pu pco act on hisher behalf, including, but not limited to, the plaintiffs counsel, agents,.epresentatives, and employees. If the plaintiff cannot answer an interrogatory completely, h;hall answer to the fullest extent possible and specify the reason(s) for hislher inability to res]ully.DEFINITIONSAs used in these interrogatories ,the term "YOU" and "YOUR or any derivative the!neans plaintiff andlor decedent, as well as anyone acting or purporting to act on histher behancluding, but not limited to, plaintiffs agents, representatives, counsel, and employees.-1LAOSD STANDARD BANKRUPTCY INTERROGATORlES TO PLAINTIFFS[EXHIBIT 21

1As used in these Interrogatories, the term "PERSON(S)" includes a natural PERSON,2association, organization, partnership, business, trust, corporation, or public entity.in Evidence Code 3 250, and includes the original or a copy of any handwriting, printing,456iAs used in these Interrogatories, the term "DOCUMENT(S) " means a writing as defined3IIi IPhotostatting, photographing, and every other means of recording upon any tangible thing in om1Iof communication or representation, including letters, words, pictures ,sounds, or symbols, od7combinations of them. The term "DOCUMENT(S)" specifically includes, but is not limited to8and all JOB files, contracts, invoices, work orders, JOB logs, specifications, blueprints, maps,9purchase orders, and permits.1011IAs used in these Interrogatories, the term "DESCRIBE as it relates to equipment, Prdductlor material means provide a complete description of the equipment, product or12but not limited' to the name, manufacturer, supplier, distributor, color, texture, consistency,13size and any markings; a description of the container and/or packaging including size,14writing on the container and or packaging and a description of how the equipment, product or15material was used .ItAs used in these interrogatories, "ASBESTOS-CONTAINING PRODUCT(S)" mean.16any and all products that contain any amount of asbestos dust or fiber.1718As used in these interrogatories, "RESPIRATORY PROTECTION EQUIPMENT"19means any device or item of apparel used to prevent or reduce the inhalation of asbestos, or other201) dusts or fibers such as, but not limited to, kerchiefs, dust masks, respirators, hoods, and respiraltor' Ifilters, cartridges and canisters.21"IDENTIFY" in regards to WORKSITES means to state the name, street address22(including city, state and zip code), property owner, building number, floor number, cross-232425IIstreet(s), parcel number, or other identifying characteristics of each WORKSITE alleged to be1iissue."IDENTIFY" in regards to DOCUMENTS means to describe the DOCUMENT(S) wit2627I11sufficient particularity to issue a subpoena, request for production and/or notice to produce,I I

lcluding the title, date, author, addressee or other recipient(s) ,and the name, address or otheontact information for the custodian(s) of each DOCUMENT."IDENTIFY" in regards to PERSONS means to state the full name, JOB title, last knoddress (including city, state and zip code), telephone number and/or other contact informatioach PERSON, if known to the Plaintiff answering these Interrogatories and/or hisher attorne"IDENTIFY in regards to ASBESTOS-CONTAINING PRODUCTS means to state t.ade name, brand name andor manufacturer of the product(s) , and any other markings, writir logos associated with the product.As used in these interrogatories, the term "CONTRACTOR DEFENDANT(S)" meansIefendant who allegedly exposed YOU to asbestos as a result of their work involving thestalla at ion, use, handling, abatement, removal or disturbance of ASBESTOS or ASBESTOS.1ONTAINING PRODUCTS.As used in these interrogatories, the term "WORKSITE" means each premise, LOCAr area where YOU contend YOU were exposed to asbestos, including but not limited toomrnercial buildings, tract housing, refinery facilities, shipyards, and vesselsiships."LOCATION " or "LOCATIONS" means the city, state, country, street address,ntersection or shipyard. For work aboard ship, please IDENTIFY the ship and where it was catedduring the time YOU worked on board."OCCASION" refers to a day, any part of a day, or a series of day(s), week(s), month(ear(s) during which YOU worked continuously at a WORKSITE."SAFETY PECAUTION" means respirators, masks, fans, air blowers, tarps, wet do?irocedures, isolation and any other equipment and/or methods used to limit or prevent expostlust.When the word "AUTOMOBILE" or "AUTOMOTIVE" is used herein, it refers to an:notor vehicle or mobile equipment and their systems or parts including, but not limited to, a Iruck, tractor, trailer, bus or heavy motorized equipment, upon which plaintiff claims he perfcny repairs or work that resulted in an exposure to asbestos.-3LAOSD STANDARD BANKRUPTCY INIERROGATORIES TO PLAIN'I IFFS[EXHIBIT 21

The term "FRICTION MATERIAL DEFENDANTS" means those defendants whomIplaintiff(s) hasihave named in the complaint and who plaintiff(s) alIege(s) are in the business ofselling, manufac-ingor distributing "BRAKE LINTNGS" or "ASBESTOS-CONTAININGFRICTION PRODUCTS" andlor any other AUTOMOTIVE parts which plaintiff(s) allege(s)contain asbestos.The term "ASBESTOS-CONTAINING FRICTION PRODUCTS" means "BRAKELININGS" as defined above and AUTOMOBILE transmission parts such as clutches, clutchplates, clutch discs, clutch facings and linings, or any other AUTOMOBILE parts which containor have parts made from asbestos, such as gaskets.INTERROGATORIES1213I.BACKGROUND1.State YOUR full name, present address, date and place of birth, social security14number, height, and weight, and, if YOU have a driver's license, the state of issuance and the15number of that driver's license.1617182.State any other name or