EXHIBIT I 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 1 of 11 PageID: 15815
IN THE UNITED STATES DISTRICT COURT 

DISTRICT OF NEW JERSEY 

KIMBERLEE WILLIAMS, individually, as personal 

representative of the Estate of Charles L. Williams, 

deceased on behalf of said estate, and as representative of 

others similarly situated; NANCY PEASE, individually, 

as personal representative of the Estate of William Clark, 

deceased on behalf of said estate, and as representative of 

others similarly situated; MARILYN L. HOLLEY, as 

personal representative of the Estate of Kathryn Darnell, 

deceased on behalf of said estate, and as representative of 

others similarly situated; DONNA WARE, individually as 

personal representative of the Estate of Ralph Ware, 

deceased on behalf of said estate, and as representative of 

others similarly situated; and DONNETTE WENGERD, 

individually, as personal representative of the Estate of 

Jennifer Graham, deceased on behalf of said estate, and as 

representative of others similarly situated, and 

ROSANNE CHERNICK, individually, as personal 

representative of the Estate of Steven Chernick, deceased 

on behalf of said estate, and as representative of others 

similarly situated, 

 Plaintiffs, 

 v. 

BASF CATALYSTS LLC, CAHILL GORDON & 

REINDEL LLP, CAHILL GORDON & REINDEL, a 

partnership including a professional corporation, 

THOMAS D. HALKET, ARTHUR A. DORNBUSCH 

II, GLENN HEMSTOCK, HOWARD G. SLOANE 

(A/K/A “PETER SLOANE”), IRA J. DEMBROW, 

JOHN DOE BUSINESS ENTITIES 1 to 100; JOHN 

DOE BUSINESS ENTITIES 101 to 200; JOHN DOE 

LAWYERS 1 to 500; and, JOHN DOE 1 to 500, 

 Defendants. 

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

:

: 

Civil Action No. 11-cv-1754 (JLL) (JAD) 

CIVIL ACTION 

BASF CATALYSTS LLC’S FIRST SET OF 

INTERROGATORIES TO KIMBERLEE WILLIAMS 

Pursuant to Federal Rule of Civil Procedure 33, defendant BASF Catalysts LLC 

(“BASF”) hereby requests that plaintiff Kimberlee Williams (“Plaintiff”) answer in writing, 

within thirty (30) days after service thereof, the following Special Interrogatories, Set One 

(“Interrogatories”). In answering, Plaintiff is required to furnish all information that is available 

to her, regardless of whether this information is possessed by Plaintiff, her agent(s), attorney(s), 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 2 of 11 PageID: 15816
 2 

or anyone else. If any of these Interrogatories cannot be answered in full, Plaintiff must answer 

to the extent possible, specifying the reason for her inability to answer the remainder and stating 

whatever information, knowledge, or belief she has concerning the unanswered portion. In 

serving these Interrogatories, BASF does not admit that it made, sold, manufactured, marketed, 

or distributed any product, or had any customers. 

DEFINITIONS 

As used in these Requests, the following definitions shall apply unless otherwise noted: 

1. “Action” means any federal or state litigation, arbitration, administrative agency 

proceeding, bankruptcy proceeding, claims process, or proceeding of any kind in any forum in 

which a claim for relief of any kind is made. 

2. The terms “And” and “Or” include each other within their meaning, whether both 

are referenced or otherwise. 

3. The terms “Any” and “All” include each other within their meaning, whether both 

are referenced or otherwise. 

4. “Asbestos” has the same meaning as that term is used in the Complaint. 

5. “BASF” means defendant BASF Catalysts LLC and any of its predecessors or 

successors in interest, all parents, subsidiaries, sisters, affiliates, and divisions, as well as current 

and former assigns, agents, employees, officers, directors, partners, attorneys and any other 

persons or entities acting or purporting to act on behalf of Any of them. 

6. “Communication(s)” or “Communicate” means any form of information, 

exchange, or attempted exchange, including but not limited to written, oral, or electronic 

exchanges; exchanges by letter, telephone, facsimile, email, face-to-face conversation, meeting 

or conference; any exchange whether or not written, taped, or recorded; any exchange without 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 3 of 11 PageID: 15817
 3 

limit to the time, place, or circumstances of its occurrence; and/or any other transmittal of 

information by any media by any manner. 

7. “Complaint” means the “Second Amended Class Action Complaint” filed by You 

in Williams v. BASF Catalysts, Civil Action No. 11-cv-01754 (D.N.J.) on July 16, 2015. 

8. “Decedent” means Charles L. Williams. 

9. The term “Document” is used herein in its customary and broadest sense under 

Federal Rule of Civil Procedure 34(a)(1), and includes, without limitation: the original or a copy 

as well as drafts and all versions of all writings and recordings; material that is stored, compiled 

or organized by means of any electronic, magnetic, optical or mechanical device, such as by 

handwriting, typewriting, printing, photostating, or filming; agreements, analytical data, art 

work, audio recordings, books, bulletins, calendars, computer tapes, computer storage media, 

contracts, correspondence, diagrams, diaries, drawings, email, facsimiles, forms, interoffice 

communications, keypunch cards, letters, memoranda, messages, notes, papers, photographs, 

pictures, pleadings, proposals, reports, studies, surveys, sketches, telexes, telegrams, telecopies, 

telegraphs, telex communications, video recordings, and worksheets; and any writing or 

recording prepared on or with any other physical objects. 

10. “Emtal Talc” means the talc mined, milled, manufactured, and processed at the 

talc mine and mill in Johnson, Vermont, operated by the Eastern Magnesia Talc Company from 

1967 to 1983, which was marketed and sold under the brand name “Emtal” and distributed in 

various grade numbers, including, among others, 41, 42, 43, 44, 4190, 500, 549, and 599. 

11. “Exposure” and “Exposed” have the same meaning as those terms are used in the 

Complaint. 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 4 of 11 PageID: 15818
 4 

12. “Identify” or “Identity” means: (a) when used in reference to a natural person, 

state his or her full name, address, and telephone number; (b) when used in reference to a 

corporation, state its full corporate name, any names under which it does business, and its place 

of incorporation; (c) when used in reference to a partnership, state its full name, any name under 

which it does business, the place or any certificate of partnership, state its full name, any name 

under which it does business, the place or any certificate of partnership (or other similar 

Document) filing, and the address of its principal place of business; (d) when used in reference to 

a Document, state the Document, litigation number or Bates number, if applicable, otherwise the 

number of pages and the nature of the Document (e.g., letter, memorandum, etc.), its title, its 

date, the name or names of its authors or recipients, and its present location or custodian; 

(e) when used in reference to a Communication, if any part of the Communication was written, 

identify the Document or Documents which refer to, relate to, or evidence the Communication, 

and, to the extent that the Communication was non-written, identify the Persons, participating in 

or witnessing the Communication, and state the date and substance of the Communication. 

13. “Injury” has the same meaning as that term is used in the Complaint. 

14. “Manufactured” means manufactured, fabricated, designed, modified, labeled, 

assembled, manufactured for others, or packaged. 

15. “Other Defendant” means Any of the defendants, aside from BASF, identified in 

the Complaint or, where specified, in the Underlying Action. 

16. “Person” means not only natural persons, but also firms, partnerships, 

associations, corporations, subsidiaries, divisions, departments, joint ventures, proprietorships, 

syndicates, trusts, groups, and organizations; federal state, state, or local governments or 

government agencies, offices, bureaus, departments, or entities; other legal, business, or 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 5 of 11 PageID: 15819
 5 

government entities; and all subsidiaries, affiliates, divisions, departments, branches, and other 

units thereof or any combination thereof. 

17. “Product” and “Products” have the same meaning as those terms are used in the 

Complaint. 

18. “Relating To” means Relating To, reflecting, concerning, referring to, 

constituting, embodying, connected to, in connection with, comprising, regarding, evidencing, 

describing, identifying, stating, analyzing, containing information concerning, and/or in any way 

pertaining to the subject matter of this action. 

19. “Smoking History” as used herein means a summary that provides information 

regarding the extent of Decedent’s use of tobacco products, including but not limited to 

cigarettes, cigarillos, and cigars. 

20. “Sold” means sold, offered for sale, distributed, or marketed. 

21. “Substantial Factor” is defined in Ohio Rev. Code Ann. § 2307.91(FF). 

22. “Supplied” means supplied, distributed, or furnished. 

23. “Underlying Action” means Charles L. Williams, et al. v. Abex Corp., et al., Case 

No. 92-229108 filed in the Court of Common Pleas, Cuyahoga County, Ohio on or about March 

19, 1992, and removed to the United States District Court for the Northern District of Ohio on or 

about May 4, 1992 (Case No. 1:92-CV-10471). 

24. “You” and “Your” mean Kimberlee Williams, as well as all present and former 

agents, attorneys or representatives of Kimberlee Williams or Decedent. 

25. For purposes of construing the scope of these Requests: 

(a) The use of the singular form of any word includes the plural and vice 

versa. 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 6 of 11 PageID: 15820
 6 

(b) The word “including” shall be construed to introduce a non-exhaustive 

list, and and to mean “including, but not limited to.” 

(c) The terms “all,” “any,” and “each” shall each be construed as addressing 

any and all. 

(d) The connectives “and” or “or” shall be construed either disjunctively or 

conjunctively as necessary to bring within the scope of the discovery request all 

responses that might otherwise be construed to be outside of its scope. 

(e) The scope of these Requests shall not be construed narrowly based on any 

inferences drawn from the phrasing of any other Request. 

(f) Any reference to communications “between” two parties shall include any 

and all communications involving both parties whether or not additional parties are 

involved and whether or not both parties are recipients of the communication. 

26. The masculine form of a word should be read to include the feminine, and the 

feminine form of a word should be read to include the masculine. And any pronouns shall be 

construed to refer to the masculine, feminine, or neuter gender as is most appropriate in each 

case. 

SPECIAL INTERROGATORIES

INTERROGATORY NO. 1: 

 Identify all Persons with knowledge Relating To Your claims against BASF and the 

subject matter of their knowledge. 

INTERROGATORY NO. 2: 

 Identify all Persons with knowledge Relating To the Underlying Action against 

Engelhard or its subsidiaries and the subject matter of their knowledge. 

INTERROGATORY NO. 3: 

 Identify each Communication that occurred between You and Any other Person Relating 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 7 of 11 PageID: 15821
 7 

To the facts and circumstances alleged in the Underlying Action, including any Communication 

Relating To Your or Decedent’s preparation for litigation in the Underlying Action. 

INTERROGATORY NO. 4: 

Identify all resolutions or dispositions of claims with Any Defendant named in the 

Underlying Action and/or any party who was not named in the Underlying Action, including for 

each settlement: the parties to the settlement, the amount of the settlement, the date of the 

settlement, and the reason why the claim was settled. 

INTERROGATORY NO. 5: 

Identify all evidence, including any Documents (and excluding Your own Testimony) 

that support Your contention that Decedent was exposed to Emtal Talc. 

INTERROGATORY NO. 6: 

If any of Decedent’s blood relatives (i.e., parents, grandparents, siblings, aunts, uncles, or 

cousins) had cancer of any type, describe the circumstances of the disease, including the name 

and relationship with each such Person and the type of cancer. 

INTERROGATORY NO. 7: 

Describe Decedent’s Smoking History. 

INTERROGATORY NO. 8: 

Identify all Asbestos-containing Products to which Decedent was Exposed, including for 

each Product: the name of the Product, the dates of Exposure, the quantum of Exposure, and the 

places where the Exposure took place. 

INTERROGATORY NO. 9: 

Identify every workplace where Decedent was employed during his lifetime. 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 8 of 11 PageID: 15822
 8 

INTERROGATORY NO. 10: 

Identify all locations where Decedent lived during his lifetime, including the specific 

address and dates of residence. 

INTERROGATORY NO. 11: 

Identify all information provided to Decedent and his counsel by counsel for Engelhard 

in Decedent’s Underlying Action. 

INTERROGATORY NO. 12: 

Describe in detail the process behind Decedent’s decision to settle with or dismiss 

Engelhard or its subsidiaries in the Underlying Action, including the Persons involved, the 

information reviewed, and the basis for the decision. 

INTERROGATORY NO. 13: 

Describe all efforts made by Decedent and his counsel in the Underlying Action to 

develop and prosecute claims against Engelhard and its subsidiaries. 

 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 9 of 11 PageID: 15823
 9 

CERTIFICATION OF SERVICE

 I certify that on this day counsel for the following parties were served electronically with 

Defendant BASF Catalysts LLC’s First Set of Interrogatories to Kimberlee Williams: 

Christopher M. Placitella, Esquire 

Micheal Coren, Esquire 

Cohen Placitella & Roth PC 

127 Maple Avenue 

Red Bank, NJ 07701 

Attorneys for Plaintiffs 

John K. Villa, Esquire 

David S. Blatt, Esquire 

Grant A. Geyerman, Esquire 

WILLIAMS & CONNOLLY LLP 

725 Twelfth Street, N.W. 

Washington, DC 20005 

Robert E. Ryan, Esquire 

Marc D. Haefner, Esquire 

Craig Demareski, Esquire 

Connell Foley LLP 

85 Livingston Avenue 

Roseland, NJ 07068 

Attorneys for Defendants Cahill Gordon & Reindel LLP, 

Cahill Gordon & Reindel, Howard Sloane, and Ira J. Dembrow 

Eric Tunis, Esquire 

Oliver Salvagno, Esquire 

Greenbaum Rowe Smith & Davis LLP 

99 Wood Avenue South 

Iselin, NJ 08830 

Attorneys for Defendant Thomas D. Halket 

Kevin Marino, Esquire 

John A. Boyle, Esquire 

Marino, Tortorella & Boyle PC 

437 Southern Blvd. 

Chatham, NJ 07928 

Attorneys for Defendant Arthur A. Dornbusch II 

 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 10 of 11 PageID:

15824
 10 

Walter Timpone, Esquire 

Walter R. Krzastek, Esquire 

McElroy, Deutsch, Mulvaney & Carpenter LLP 

1300 Mt. Kemble Avenue 

P.O. Box 2075 

Morristown, NJ 07962 

Attorneys for Defendant Glenn Hemstock 

 _____/s/ Michael F. Williams____ 

 Michael F. Williams 

Dated: October 23, 2015 

Case 2:11-cv-01754-BRM-AME Document 384-10 Filed 12/15/17 Page 11 of 11 PageID:

15825