IN THE CIRCUIT COURT OF THE 17th
`JUDICIAL CIRCUIT IN AND FOR
`BROWARD COUNTY, FLORIDA
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`CASE NO: CACE-20-003820 (27)
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`Filing# 138906350 E-Filed 11/19/2021 02:43:15 PM
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`ALAN REECE,
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`Plaintiff.
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`V P
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`UBLIX SUPER MARKETS., et al.,
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`Defendants,
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`i
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`THE PROCTER & GAMBLE COMPANY'S ANSWER AND AFFIRMATIVE DEFENSES
`TO PLAINTIFF'S THIRD AMENDED COMPLAINT
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`Defendant The Procter & Gamble Company (Improperly sued as "Procter & Gamble
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`Productions, Inc., as successor in interest to The Shulton
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`"Procter &
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`Gamble" or "Defendant") by its undersigned attorneys, answers the Third Amended Complaint
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`and Demand for Jury Trial ("Complaint") filed by Plaintiff,and states as follows:
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`ANSWER
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`1. Defendant Procter & Gamble denies the allegationsin paragraph 1 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`2. Defendant Procter & Gamble is without sufficient knowledge to admit or deny the
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`allegationscontained in paragraph2 of Plaintiff's Complaint,and thus,these allegations
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`are denied and Procter & Gamble demands strict proof thereof at trial.
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`3. Paragraph 3 of Plaintiff' s Complaint, including all subparts,does not contain any
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`allegations.To the extent there is an allegation,Defendant Procter & Gamble denies these
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`allegationsand demands strict proof thereof at trial.
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`1
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`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/19/2021 02:43:15 PM.****
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`4. Defendant Procter & Gamble is without sufficient knowledge to admit or deny the
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`allegationscontained in paragraph 4 of Plaintiff's Complaint,and thus,these allegations
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`are denied and Procter & Gamble demands strict proof thereof at trial.
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`5. Defendant Procter & Gamble denies the allegationsin paragraph 5 of Plaintiff's
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`Complaint, includingall subparts,and demands strict proof thereof at trial.
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`6. Defendant Procter & Gamble denies the allegationsin paragraph 6 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`BACKGROUND FACTUAL ALLEGATIONS
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`7. Defendant Procter & Gamble denies the allegationsin paragraph 7 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`8. Paragraph 8 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`9. Defendant Procter & Gamble denies the allegationsin paragraph 9 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`10. Defendant Procter & Gamble denies the allegationsin paragraph 10 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`11. Defendant Procter & Gamble denies the allegationsin paragraph 11 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`12. Paragraph 12 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`13. Paragraph 13 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`2
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`14. Paragraph 14 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`15. Paragraph 15 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`16. Paragraph 16 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`17. Paragraph 17 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`18. Paragraph 18 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`19. Paragraph 19 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`20. Paragraph 20 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`21. Paragraph 21 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`22. Paragraph 22 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`23. Paragraph 23 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`24. Paragraph 24 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`3
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`25. Paragraph 25 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`26. Paragraph 26 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`27. Paragraph 27 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`28. Paragraph 28 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`29. Defendant Procter & Gamble denies the allegationsin paragraph 29 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`30. Defendant Procter & Gamble denies the allegationsin paragraph 30 of Plaintiff's
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`Complaint and demands strict proofthereof at trial.
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`BACKGROUND FACTUAL ALLEGATIONS APPLICABLE ONLY TO
`DEFENDANTS CARNIVAL CORPORATION, CARNIVAL PLC, CARNIVAL
`CORPORATION AND PLC, CUNARD LINE LIMITED, CUNARD LINE
`LIMITED, CO. AND CUNARD LINE LIMITED, INC.
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`31. Paragraph 31 of Plaintiff's Complaint, including all subparts,relates to Plaintiff's
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`allegationsagainsta Co-Defendant. To the extent a response is required,Procter &
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`Gamble denies all allegations.
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`32. Paragraph 32 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`33. Paragraph 33 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`34. Paragraph 34 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`4
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`35. Paragraph 35 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`36. Paragraph 36 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`37. Paragraph 37 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`COUNT I - FOR NEGLIGENCE AND UNSEAWORTHINESS OF VESSELS AT ISSUE
`UNDER THE JONES ACT (AS TO DEFENDANTS CARNIVAL CORPORATION,
`CARNIVAL PLC, CARNIVAL CORPORATION AND PLC, CUNARD LINE LIMITED,
`CUNARD LINE LIMITED CO, AND CUNARD LINE LIMITED, INC.)
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`38. Paragraph 38 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`39. Paragraph 39 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`40. Paragraph 40 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`41. Paragraph 41 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`42. Paragraph 42 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`43. Paragraph 43 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`44. Paragraph 44 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`45. Paragraph 45 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`46. Paragraph 46 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`47. Paragraph 47 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`48. Paragraph 48 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`COUNT II - NEGLIGENT FAILURE TO ADEQUATELY WARN (AS TO
`DEFENDANTS CARNIVAL CORPORATION, CARNIVAL PLC, CARNIVAL
`CORPORATION AND PLC, CUNARD LINE LIMITED, CUNARD LINE LIMITED
`CO, AND CUNARD LINE LIMITED, INC.)
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`49. Paragraph 49 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`50. Paragraph 50 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`51. Paragraph 51 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`52. Paragraph 52 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`53. Paragraph 53 of Plaintiff's Complaint, including all subparts,relates to Plaintiff's
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`allegationsagainsta Co-Defendant. To the extent a response is required,Procter &
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`Gamble denies all allegations.
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`54. Paragraph 54 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`55. Paragraph 55 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`COUNT III - NEGLIGENT FAILURE TO ADEQUATELY WARN (AS TO
`DEFENDANTS PUBLIX SUPER MARKETS, INC., BORGWARNER MORSE TEC
`LLC, CARLISLE COMPANIES, INC., CONOPCO, INC., FORD MOTOR
`COMPANY, GENUINE PARTS COMPANY, HARLEY-DAVIDSON, INC.,
`HONEYWELL INTERNATIONAL, INC., MACK TRUCKS, PNEUMO ABEX
`CORPORATION AND PROCTER & GAMBLE PRODUCTIONS, INC.)
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`56. Defendant Procter & Gamble incorporatesby reference each and every relevant answer,
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`response and defenses,includingall subparts,to Plaintiff's Complaint.
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`57. Defendant Procter & Gamble denies the allegationsin paragraph 57 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`58. Defendant Procter & Gamble denies the allegationsin paragraph 58 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`59. Defendant Procter & Gamble denies the allegationsin paragraph 59 of Plaintiff's
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`Complaint,includingall subparts,and demands strict proof thereof at trial.
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`60. Defendant Procter & Gamble denies the allegationsin paragraph 60 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`61. Defendant Procter & Gamble denies the allegationsin paragraph 61 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`COUNT IV - STRICT LIABILITY (AS TO DEFENDANTS PUBLIX SUPER
`MARKETS, INC., BORGWARNER MORSE TEC LLC,
`CARLISLE
`COMPANIES, INC., CONOPCO, INC., FORD MOTOR COMPANY, GENUINE
`HONEYWELL
`PARTS
`COMPANY,
`HARLEY-DAVIDSON,
`INC.,
`INTERNATIONAL, INC., MACK TRUCKS, PNEUMO ABEZ CORPORATION
`AND PROCTER & GAMBLE PRODUCTIONS, INC.)
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`62. Defendant Procter & Gamble incorporatesby reference each and every relevant answer,
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`response and defenses,includingall subparts,to Plaintiff's Complaint.
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`63. Defendant Procter & Gamble denies the allegationsin paragraph 63 of Plaintiff' s
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`Complaint and demands strict proof thereof at trial.
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`64. Defendant Procter & Gamble denies the allegationsin paragraph 64 o f Plaintiff' s
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`Complaint and demands strict proofthereof at trial.
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`65. Defendant Procter & Gamble denies the allegationsin paragraph 65 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`66. Defendant Procter & Gamble denies the allegationsin paragraph 66 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`67. Defendant Procter & Gamble denies the allegationsin paragraph 67 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`68. Defendant Procter & Gamble denies the allegationsin paragraph 68 of Plaintiff's
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`Complaint and demands strict proofthereof at trial.
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`69. Defendant Procter & Gamble denies the allegationsin paragraph 69 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`COUNT V - STRICT LIABILITY (AS TO DEFENDANTS CARNIVAL
`CORPORATION, CARNIVAL PLC, CARNIVAL CORPORATION AND PLC,
`CUNARD LINE LIMITED, CUNARD LINE LIMITED CO, AND CUNARD LINE
`LIMITED, INC.)
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`70. Defendant Procter & Gamble incorporatesby reference each and every relevant answer,
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`response and defenses,includingall subparts,to Plaintiff's Complaint.
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`71. Paragraph 71 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`72. Paragraph 72 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`73. Paragraph 73 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`74. Paragraph 74 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`75. Paragraph 75 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`76. Paragraph 76 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`77. Paragraph 77 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`78. Paragraph 78 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`79. Paragraph 79 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`COUNT VI - FAILURE TO USE REASONABLE CARE (AS TO DEFENDANTS
`PUBLIX SUPER MARKETS, INC., BORGWARNER MORSE TEC LLC,
`CARLISLE COMPANIES, INC., CONOPCO, INC., FORD MOTOR COMPANY,
`GENUINE PARTS COMPANY, HARLEY-DAVIDSON, INC., HONEYWELL
`INTERNATIONAL, INC., MACK TRUCKS, PNEUMO ABEX CORPORATION
`AND PROCTER & GAMBLE PRODUCTIONS, INC.)
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`80. Defendant Procter & Gamble incorporatesby reference each and every relevant answer,
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`response and defenses,includingall subparts,to Plaintiff's Complaint.
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`81. Defendant Procter & Gamble denies the allegationsin paragraph 81 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`82. Defendant Procter & Gamble denies the allegationsin paragraph 82 of Plaintiff's
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`Complaint and demands strict proofthereof at trial.
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`83. Defendant Procter & Gamble denies the allegationsin paragraph 83 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`84. Defendant Procter & Gamble denies the allegationsin paragraph 84 of Plaintiff' s
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`Complaint and demands strict proofthereof at trial.
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`85. Defendant Procter & Gamble denies the allegationsin paragraph 85 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`86. Defendant Procter & Gamble denies the allegationsin paragraph 86 of Plaintiff's
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`Complaint and demands strict proof thereof at trial.
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`COUNT VII - NEGLIGENCE/FAILURE TO USE REASONABLE CAR (AS TO
`DEFENDANTS CARNIVAL CORPORATION, CARNIVAL PLC, CARNIVAL
`CORPORATION AND PLC, CUNARD LINE LIMITED, CUNARD LINE
`LIMITED CO, AND CUNARD LINE LIMITED, INC.)
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`87. Defendant Procter & Gamble incorporatesby reference each and every relevant answer,
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`response and defenses,includingall subparts,to Plaintiff's Complaint.
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`88. Paragraph 88 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`89. Paragraph 89 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`90. Paragraph 90 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`91. Paragraph 91 of Plaintiff's Complaint relates to Plaintiff's allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`92. Paragraph 92 of Plaintiff's Complaint relates to Plaintiff's allegationsagainst a Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`93. Paragraph 93 of Plaintiff' s Complaint relates to Plaintiff' s allegationsagainsta Co-
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`Defendant. To the extent a response is required,Procter & Gamble denies all allegations.
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`DAMAGES
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`94. In response to Paragraph 94 o f Plaintiff' s Complaint, mislabeled without any numeration,
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`includingall subparts,Defendant Procter & Gamble denies each and every allegationand
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`demands strict proof thereof at trial.
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`GENERAL DENIAL
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`Procter & Gamble denies all allegationsof the Complaint not specificallyadmitted,
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`controverted or denied and demands strict proof thereof at trial.
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`Procter & Gamble denies all allegationscontained in any remaining unnumbered
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`paragraphsof Plaintiff' s Complaint.
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`AFFIRMATIVE AND OTHER DEFENSES
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`1.
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`The Complaint fails to state a claim againstProcter & Gamble upon which relief
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`can be granted.
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`2.
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`Plaintiff's Complaint improperlycomingles allegationsagainstall defendants such
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`that it is impossiblefor any individual defendant to answer Plaintiff's overlybroad and vague
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`allegationsdirected againstall defendants as a group.
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`4.
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`This Court is not the proper venue for this action.
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`Plaintiff's action is barred in this jurisdictionunder the doctrine of fbrum
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`non conveniens.
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`5.
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`6.
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`This Court lacks subjectmatterjurisdictionover the matters allegedin the Complaint.
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`The Complaint does not comply with the Florida Asbestos and Silica Compensation
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`Fairness Act (the"Act") and the claims are therefore barred.
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`7.
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`Plaintiff's claims are barred, in whole or in part, by the applicablestatute of
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`limitations,by the doctrine of laches, and by Florida's statute of Repose pursuant to section
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`95.031(2),Fla. Stat. Additionally,pursuant to the Act, Section 774.206, the applicablestatute of
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`limitations begins to run when the plaintiff"discovers,or through the exercise of reasonable
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`diligenceshould have discovered,that he or she is physicallyimpairedby an asbestos related
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`condition."
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`8.
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`9.
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`Plaintiff has failed to join all necessary or indispensableparties.
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`Plaintiff,ALAN REECE ("InjuredParty")was not exposed to any products of
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`Procter & Gamble, and there is no connection between this Defendant's activities in Florida or
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`the United Kingdom, if any, and the allegedinjuries.
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`10.
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`Procter & Gamble specificallydenies that any productsmanufactured and/or sold
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`by it caused or contributed to the allegeddamages or injuriesof InjuredParty and further denies
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`that it is liable to InjuredParty for the causes allegedor for any other cause whatsoever.
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`11.
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`InjuredParty's injurieswere caused by his own negligentconduct or by the
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`negligent conduct of another and, therefore, Injured Party is barred from recovery or,
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`alternatively,is barred from full recovery.
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`12.
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`If InjuredParty was injuredor damaged, which injuriesand damages are denied,
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`the injuriesand any damages were the result of interveningor supersedingacts, events, factors,
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`occurrences or conditions which were in no way caused by Procter & Gamble and for which
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`Procter & Gamble is not liable.
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`13.
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`InjuredParty's injuries,if any, were caused, in whole or in part, by the acts or
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`omissions of persons other than Procter & Gamble, whether individual,corporate, associate,or
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`otherwise,whether named or unnamed in the Complaint,and for whose conduct Procter & Gamble
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`is not liable. Procter & Gamble is not liable for damages proximately caused by non-parties,
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`pursuant to Fabre v. Marin, 623 So.2d 1182 (Fla.1993).Such partiesmay include,but are not
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`limited to, Alan Reece, Publix Super Markets, Inc.; Borg Warner Morse Tee, LLC; Carlisle
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`Companies; Carnival Corporation;Carnival PLC; Carnival Corporation and PLC; Conopco, Inc.;
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`Cunard Line Limited; Cunard Line Limited, Co.; Cunard Line Limited, Inc.; Ford Motor
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`Company; Genuine Parts Company; Harley Davidson, Inc.; Honeywell International,Inc.;
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`Johnson & Johnson; Johnson & Johnson Consumer Inc.;Mack Trucks; National Automotive Parts
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`Association; and Pneumo Abex Corporation;Air & Liquid Systems Corporation;Albany
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`International Corp.;Armstrong International,Inc.;AstenJohnson, Inc.;BorgWarner Morse TEC
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`LLC; Carrier Corporation;Cooper Industries,LLC; Crane Co.; Daniel International Corporation;
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`DCO, LLC; The Dow Chemical Company; E.I. Du Pont de Nemours and Company; Eaton
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`Corporation;Elliott Company; Flowserve Corporation.;Fluor Constructors International,Inc.;
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`Fluor Corporation; Fluor Daniel Illinois,Inc.; Fluor Daniel Services Corporation; Fluor
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`Enterprises,Inc.;Ford Motor Company; Foster Wheeler Energy Corporation;General Electric
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`Company; Genuine Parts Company; The Goodyear Tire & Rubber Company; Goulds Pumps,
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`Incorporated;Grinnell,LLC; Hercules LLC; Honeywell International,Inc.;IMO Industries,Inc.;
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`Ingersoll-RandCompany; ITT Corporation;Joy Technologies, Inc.; Met-Pro Technologies,
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`LLC; Milton Roy, LLC; Mount Vernon Mills, Inc.; Pensacola Rubber & Gasket Co., Inc.;
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`Perfection Hy-Test Company; Pneumo Abex, LLC; Ric-Wil, Inc.; Riley Power, Inc.; Rockwell
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`Automation, Inc.;Rubber & Specialties,Inc.;Schneider Electric USA, Inc.;Spirax Sarco, Inc.;
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`Trane U.S., Inc.; ViacomCBS Inc.; Vimasco Corporation;Voith Paper Fabrics Waycross Inc.;
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`Warren Pumps, LLC; The William Powell Company; AC & S., Inc., f/k/a Armstrong
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`Contracting and Supply; A.O.
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`Smith Corp.; A.P. Green Refractories Company; A.W.
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`Chesterton Company; A-Best Products Company; Aero Facilities,Inc.; Akebono Brake
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`Corporation;Allied Signal,Inc.; Alstom Power, Inc.; Amatex Corporation,f/k/a American
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`Asbestos Textile Corporation;American Honda Motor Company, Inc.; American Shipbuilding;
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`American Standard, Inc.; Ancor Holdings, Inc., and its subsidiary,National Gypsum
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`Company; Standard Asbestos Manufacturing & Insulation Company, a/k/a Standard Asbestos
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`Manufacturing & Insulating Company; Anchor Packing Company; Aqua-Chem, Inc.;
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`Armstrong World Industries,Inc.;Artra Group (Synkoloid);Arvinmeritor, Inc.;Asbestos Claim
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`Management Corp; Asbestos Corporation,Ltd.;Asbestos Spray Corporation;Atlas Adhesives;
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`Atlas Asbestos; Atlas Corporation and subsidiaries, including Hidden Splendor Mining
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`Company; Aviation Brake Services;Aviation International Corporation;The Babco*ck & Wilcox
`Company and subsidiaries Americon, Inc.,B&W Construction Company, and Diamond Power
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`International, Inc.; BAE Systems
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`Aerospace, Inc.; BAE Systems, Inc.; BAE Systems
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`Information and Electronic Systems Integration,Inc.; Banner Supply Co.; Bechtel Corp.;
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`Belden, Inc.; Bell Asbestos Mines, Ltd; Bennett Auto Supply, Inc.; Bethlehem Steel
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`Corporation; Bigelow-Liptak Corporation; Bigham Insulation & Supply Company; Boeing
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`Company; Bird,Inc.; Boeing North American, Inc.; Borgwarrner Morse Tee LLC; Bridgestone
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`Americas Tire Operations, LLC; Bridgestone/FirestoneNorth American Tire, LLC as
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`successor by merger to Bridgestone/Firestone,Inc., as successor by merger to Worldbestos;
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`Briggs Stratton Corp.; Brock & Blevins Company, Inc.; Brown & Williamson Tobacco Corp.;
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`Cafco Pipe Company; Canadian Johns-Manville; CAPCO Pipe Company; Cape Asbestos
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`Company, Ltd.,and related companies North American Asbestos Corporation and Continental
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`Producers Corporation;Carrier Corporation,Carlisle Companies, Inc. through its subsidiaries
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`Motion Control Industries,Inc.; Carlisle Companies, Inc.; Carlisle Brake & Friction, Inc.;
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`Cassiar Mines, Cassiar Mining Corporation Ltd., Cassiar Asbestos Corporation, and Cassiar
`
`Resources Ltd.; Caterpillar,Inc.; CBS Corporation f/k/a Viacom, Inc., successor by merger
`
`to CBS corporationf/k/a Westinghouse Electric Corporation;CE Thurston & Son, Inc.;
`
`Celotex Corporation and its various subsidiaries and predecessors in interest,includingCarey
`
`Canada, Inc.,Carey Canadian Mines, Ltd.,Brinco Mining Ltd.,Panacon, Phil* Carey Company,
`
`PhilipCarey Manufacturing Company, and Smith, Sr. & Kanzler; Cemex Construction Materials
`
`Florida, LLC f/k/a Rinker Materials of Florida, Inc., as wholly owned subsidiaryof Cemex
`
`Materials,LLC; Certainteed Corporation;Chicago Mastic Company; Ciba- Geigy Corporation;
`
`Cleaver-Brooks, Inc.;Combustion EngineeringCorp.;Combustion Engineering,Inc.;Congoleum
`
`Corporation;Continental Wire & Cable Company; Controls Installation Company of Florida;
`
`Cooper Industries,LLC, individuallyand as successor in interest,alter ego and equitable
`
`trustee of Pneumo Abex, LLC and Abex Corporation; Cox Lumber Co.; Crane Company;
`
`Crown Cork and Seal Co.; CSR; CSX Transportation,Inc., individuallyand as successor in
`
`interest to Seaboard System Railroad,Inc.,the Seaboard Coast Line Railroad,the Atlantic Coast
`
`Line Railroad and the Seaboard Air Line Railroad; Curtiss- Wright Corporation;Cytec Industries,
`
`Inc. f/k/a American Cyanamid; Dana Companies, Inc.;Dana Corporation d/b/a Dana Racine
`
`Corporation f/Wa Spice Manufacturing Corp.; Daniel International Corporation,DAP Products,
`
`Inc.; Deere & Co.; Inc.; Delaware Insulation,a/k/a DI Distributors,Inc.; Dexter Corporation;
`
`Dexter Hysol Aerospace LLC; Devcon Corporation;DII Industries,f/Wa Dresser Industries;D-
`
`O
`
`Holding
`
`Company,
`
`Inc.; Dowman
`
`Products,
`
`Inc.; Dresser, Inc. through its
`
`subdivisions/business unit Waukesha Engine; The Dunn Corporation;Durabla Manufacturing
`
`Company; EAFCO, Inc.; E.J. Bartells Company; Eagle-PicherIndustries,Inc.; Eads North
`
`15
`
`
`
`America, Inc.;Eastco Industrial SafetyCorporation;Eaton Aeroquip, Inc.;Elliot Turbomachinery
`
`Co., Inc.;Ericsson, Inc.,as successor in interest to Anaconda Wire & Cable; Exedy Global Parts
`
`Corporation f/k/a Daikin Clutch Corporation;Farrel Birmingham; Federal Mogul Asbestos
`
`Personal InjuryTrust; Federal Mogul, includingGasket Holdings,Inc. (Flexitallic),Felt Products
`
`Mfg. Company (Fel-Pro),Ferodo America, Inc.,Moog Automotive (Wagner Brake Products),
`T&N Plc (includingTurner & Newall, Turner Asbestos Fibres Company, and other T&N
`
`subsidiaries),and Velbesto and Beater Addition brands; Ferro Corporation; Fibreboard
`
`Corporation;Flinkote Company; Flintkote Corporation;Florida Power & Light Co.; Ford Motor
`
`Company; Forty-EightInsulations,Inc.;Foseco, Inc.;Fuller-Austin Insulation Company; Furane
`
`Products Company; GAF Corp.;Gardner Denver, Inc.;Garlock SealingTechnologies,LLC fjk/a
`
`Garlock, Inc.; Gatke Corporation;General Cable Technologies Corporation,f/k/a The General
`
`Cable Corporation,individuallyand as successor in interest to Collyer Insulated Wire and
`
`Phillips,Inc.;General Dynamics Corporation;General Electric Company; General Refractories
`
`Company; Georgia-PacificLLC f/k/a Georgia-PacificCorporation; G-I Holdings, Inc., and
`
`its predecessorsin interest,GAF Corporation and Rubberoid Company; Guard-Line, Inc.;
`
`H.B. Fuller Company; H.K. Ferguson Company; H.K. Porter Company and its subsidiaries
`
`and predecessors in interest,including Thermoid and Southern Asbestos Company, a/kja
`
`Southern Textile; Harbison-Walker Refractories, a/k/a INDRESCO, Inc.;Henkel Corporation,
`
`individuallyand as successor in interest to SIA Adhesives; Hexcel Corporation;Hillsborough
`
`Holdings Corporation and its predecessors in interest,Jim Walter Industries,Celotex, and
`
`Panacon; Honeywell International,Inc. f/kja Allied Signal,as successor in interest to Allied
`
`Corporation,as successor in interest to The Bendix Corporation;Imperial Industries,Inc.,
`
`individuallyand as parent company to Premix-Marbletite Mfg. Co., and as successor to Adobe
`
`16
`
`
`
`Brick and Supply; Independent Parts Warehouse, Inc.; Industrial Holdings Corporation f/k/a
`
`The Carborundum Corporation;ITW Devcon, a division of Illinois Tool Works, Inc.;Jack &
`
`Heintz, Inc.; Jacksonville Sh*yard; John Crane, Inc.; Johns Manville; Johns-Manville Corp.;
`
`Johns-Manville
`
`Corporation; Johns-Manville
`
`Sales Corporation;Johnson Controls, Inc.;
`
`Johnson Mines; National Asbestos Mines, Ltd.;Joy Global Inc.,f/k/a Harnischfeger Industries,
`
`Inc.; JT Thorpe; Burns and Roe, Inc.; KCG, Inc.; Keasbey & Mattison Company; Keasby and
`
`Mattison; Keene Corporation,individuallyand as successor in interest to Baldwin-Ehret-Hill;
`
`Kelly-Moore Paint Company; Kellogg Brown & Root; Kentile Floors; Kidde-Fenwal, Inc.;Lake
`
`Asbestos of Quebec; Lear SieglerDiversified Holdings Corp.;Lipe Rollway; Lorillard Tobacco
`
`Co.; Lykes Brothers Steamship; M.H. Automotive, Inc.; Mack Trucks, Inc.; Maremont
`
`Corporation; McCord Corporation; McKoy Helgerson Company, Inc.; McDonnell Douglas
`
`Corporation,individuallyand as successor-in-interest to North American Aviation; Mclean
`
`Industries and First Colony Farms and their subsidiaries,U.S. Lines and United States Lines
`
`(S.A.);Metropolitan Life Insurance Company; Milton Roy LLC, Morton International,Inc.;
`
`Muralo Company (includingSynkoloid) and its affiliate,Norton & Son of California, Inc.;
`
`Flintkote; National Gypsum Company; Navistar, Inc., Nicolet, Inc.; Nissan North America,
`
`Inc.;Norfolk Southern Railway Company; North American Refractories Corporation (NARCO);
`
`Novartis Corporation,individuallyand as successor-in-interest to Stratoflex;Owens Coming
`
`Corporation and its subsidiaries and predecessors in interest,including,but not limited to,
`
`Fibreboard Corporation (f/k/aPlant Rubber & Asbestos Works), Owens-Coming Fiberglass
`
`Technology, Inc.,CDC Corporation,and Pabco; Owens Coming Corporation; Owens Coming
`
`Fiberglass,Inc.; Owens-Illinois, Inc.; Paccar, Inc.; Pacific Asbestos; Permalastic Products
`
`Company; The Pep Boys - Manny, Moe & Jack; Pfizer,Inc.;Philip Carey Mfg. Co.; Philip
`
`17
`
`
`
`Morris, Inc.; Pittsburgh Coming Corp.; Plibrico Company; Pneumo Abex Corporation,
`
`individuallyand as successor to Abex Corporation;Porter-HaydenCompany and its predecessors,
`
`H. W. Porter & Company, Inc.,and Reid Hayden, Inc.;Powhatan Mining Company; Pacor, Inc.,
`
`a/k/a PhiladelphiaAsbestos Corporation,and Pacor Material Supply Company; PPG Industries,
`
`Inc., as successor-in-interest to PRC DeSoto International,Inc.;PRC-DESOTO International,
`
`Inc.;Premix-Marbletite Manufacturing Co., individuallyand as subsidiaryof ImperialIndustries,
`
`Inc.;PregisInnovative Packaging,Inc.;PergisIntellipackCorp.; Products Research & Chemical
`
`Corp.; Proko Industries, Inc.; Prudential
`
`Lines, Inc.; Quigley Company, Inc.; R&M
`
`Manufacturing Company; R.J. Reynolds Tobacco Company; Rapid Amer
