EXHIBIT J 

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Cohen, Placitella & Roth, P.C.

Christopher M. Placitella, Esq. (NJ Atty #: 027781981)

Michael Coren, Esq. (NJ Atty #: 024871979)

Jared M. Placitella, Esq. (NJ Atty #: 068272013)

127 Maple Avenue

Red Bank, NJ 07701

(732) 747-9003

Fox Rothschild LLP

Jeffrey M. Pollock, Esq. (NJ Atty #: 015751987)

Princeton Pike Corp. Center

997 Lennox Drive, Building 3

Lawrenceville, NJ 08648

(609) 896-7660

Attorneys for Plaintiffs and the Putative Class

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW JERSEY

KIMBERLEE WILLIAMS, et al.,

 Plaintiffs, 

 vs. 

BASF CATALYSTS, LLC, et al.,

 

Defendants.

HONORABLE JOSE L. LINARES

 

CIVIL ACTION NO. 11-1754 (JLL) (JAD)

PLAINTIFF KIMBERLEE WILLIAMS ANSWERS TO 

BASF CATALYSTS LLC’S FIRST SET OF INTERROGATORIES

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

Kimberlee Williams, objects and responds to Defendant BASF Catalysts LLC’s Special 

Interrogatories, Set One, as follows. In addition, Plaintiff notes that:

1. That Plaintiff is responding subject to, without intending to waive, and 

expressly preserving: (a) any objections as to relevance, privilege, and admissibility of

documents or information provided; and (b) the right to object to other discovery procedures 

involving or relating to the subject matter of BASF’s requests.

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2. That Plaintiff objects based on Plaintiff’s attorneys’ understanding of 

Defendant’s language. Where it may be found that something was intended to be construed

different from their interpretation, Plaintiff reserves the right to amend these objections. As 

Plaintiff’s factual investigation and legal analysis is ongoing, these objections are without 

prejudice to later amendment and supplementation.

GENERAL OBJECTIONS

All of the General Objections below are incorporated into each of the individual 

responses and have the same force and effect as if fully set forth therein. Plaintiff objects to

Defendant’s interrogatories to the extent that:

1. The definitions and instructions seek to impose obligations that exceed or 

differ from the requirements of the Federal Rules of Civil Procedure.

2. They seek to require responses or supplemental responses beyond the 

scope and/or requirements of the Federal Rules of Civil Procedure.

3. They seek to establish or imply a waiver of Plaintiff’s right to challenge the

relevancy, materiality, or admissibility of the documents or information provided by

Plaintiffs, or to object to the use of documents or information in any subsequent proceeding or 

trial. In responding, Plaintiff does not waive the right to challenge the relevancy, materiality,

and/or admissibility of the documents or information provided by her or her Co-plaintiffs, or 

to object to the use of the documents or information in any later proceeding or trial.

4. They call for legal conclusions, non-testifying expert discovery or premature 

expert discovery.

5. They seek disclosure of documents, communications, information, and things 

protected by the attorney-client privilege or that constitute attorney work-product/trial 

preparation materials or any other privileged documents or information, as well as documents 

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or information that were compiled or prepared at the request and direction of counsel in 

anticipation of, or in conjunction with, litigation that are protected by the attorney work 

product doctrine; items and information obtained by Plaintiff’s attorneys that involve their 

professional skill and experience; legal research, including delegated research — which 

includes research or investigation by Plaintiff’s attorneys, or by persons hired by Plaintiff’s 

attorneys and acting under their supervision; strategic litigation planning, mental impressions 

(or documents reflecting such planning or impressions); and documents gathered by 

Plaintiff’s attorneys while researching issues in this case. Further, it would also be unduly 

burdensome and oppressive to search for, compile, and make a description of the nature of 

each such document, communication, etc.

6. The inadvertent provision of information or the production by Plaintiff of 

documents pursuant to Fed. R. Civ. P. 33(d) containing information protected from discovery 

by the attorney-client privilege, work product doctrine or any other applicable privilege, shall 

not constitute a waiver of such privileges with respect to that information or those or any 

other documents. In the event that inadvertent production occurs, Defendant shall return all 

inadvertently produced documents to Plaintiff upon request, and/or shall make no use of the 

contents of such information or documents nor premise any further discovery on information 

learned therefrom.

7. None of the objections or responses contained herein is an admission 

concerning the existence of any documents or materials, the relevance or admissibility of any 

documents, materials or information, or the truth or accuracy of any statement or 

characterization contained in Defendant’s First Set of Interrogatories. Plaintiff’s written 

responses are made without waiving, but, on the contrary, expressly reserving: (a) the right to 

object, on the grounds of competency, privilege, relevancy, materiality or any other proper 

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grounds, to the use of the information provided herein, in whole or in part, in any subsequent 

proceeding in this action or any other action; (b) the right to object on any and all grounds, at 

any time, to other discovery requests involving or relating to the subject matter of these 

requests; and (c) the right at any time to revise, correct, add or clarify any of the responses 

provided herein.

8. Plaintiff objects to any interrogatory as unduly and unnecessarily burdensome 

to the extent that it seeks information that is a matter of public record, already in the 

Defendant’s possession, or otherwise readily available to Defendant, and, therefore, may be 

accessed and obtained by Defendant with less burden than Plaintiff can identify and provide 

requested information.

9. They seek documents or information contained in the pleadings and other 

papers filed in this action.

10. They are “contention” type discovery relating to claims, allegations 

contentions of pleadings, counts or claims. 

11. They seek to impose investigation, review, and production expense burdens 

that outweigh any likely benefits. 

12. They are neither relevant to the subject matter of this litigation nor reasonably 

calculated to lead to the discovery of admissible evidence. 

13. They may cause or require Plaintiff to violate any protective or confidentiality 

order, or confidentiality agreement.

14. They may cause or require Plaintiff to violate any confidentiality or nondisclosure provision of a Bankruptcy or Settlement Trust.

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15. They are vague, ambiguous, oppressive, not susceptible to a reasoned 

interpretation, require speculation to determine their meaning, or use imprecise specifications 

of the information sought.

16. Unless otherwise indicated, Plaintiff will not provide information 

encompassed by their general responses and objections or by their specific objections set 

forth below. Plaintiffs, however, are willing to meet and confer with counsel for BASF and 

other defendants to discuss the parties entering a consent order under F.R.E. 502(d) regarding 

limited waiver of certain privileged communications and information relating to the dismissal 

or resolution of the claims against BASF (Engelhard) in the Underlying Actions, as well as 

BASF’s and other Defendants’ limited waiver of certain privileged communications and 

information relating to the issues in this case as outlined in the Second Amended Complaint.

INTERROGATORIES

INTERROGATORY NO. 1: 

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

subject matter of their knowledge.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this interrogatory as vague and ambiguous. Plaintiff further objects on grounds 

information responsive to this interrogatory is in possession of the Defendants in this 

action. To the extent that it seeks the identity of “all persons”, the interrogatory is premature 

as discovery has only recently commenced. The question is also disproportionately 

burdensome.

Subject to and without waiving the foregoing Objections, Plaintiff is personally 

unaware of anyone with knowledge of her claims against BASF in the matter of Williams, et 

al. v. BASF Catalysts, LLC, et al., No. 11-cv-1754 (D.N.J.) other than her co-plaintiffs and 

her attorneys.

Persons not known personally to Plaintiff with knowledge may include former coworkers of Decedent who may attest to Decedent’s exposure to EMTAL talc, Plaintiff’s 

experts from the Underlying Action, and persons identified in Plaintiffs’ Second Amended 

Complaint, as well as identified in documents produced by Defendant, or other defendants in 

this and related cases. 

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Plaintiff further refers Defendant to those persons and entities set forth in the Second 

Amended Complaint, the documents produced by BASF Catalysts, LLC in Sampson v. 

BASF, et al., MID-L-5384-11 AS (N.J. Sup. Ct. Law Div.), her counsel, and possibly persons 

or entities identified in the parties Rule 26 Disclosures.

Plaintiff reserves the right to supplement her response as discovery continues.

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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as vague, ambiguous, and unduly burdensome. Plaintiff further objects 

that information responsive to this interrogatory is in possession of the Defendants in this 

action. 

Subject to and without waiving the foregoing Objections, Plaintiff’s attorneys in the 

Underlying Action, may have knowledge relating to claims against Engelhard or its 

subsidiaries in that action. Plaintiff has knowledge of the Decedent’s pain and suffering from 

his asbestos disease. 

Persons not known personally to Plaintiff with knowledge may include former coworkers of Decedent who may attest to Decedent’s exposure to EMTAL talc, Plaintiff’s 

experts from the Underlying Action, and persons identified in Plaintiffs’ Second Amended 

Complaint, as well as documents produced by Defendant, or other defendants in this and 

related cases. 

Plaintiff reserves the right to supplement her response as discovery continues.

INTERROGATORY NO. 3: 

Identify each Communication that occurred between You and Any other Person 

Relating 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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as overbroad and unduly burdensome. Plaintiff specifically objects to 

the terms “any other person”, “facts and circumstances” and “preparation for litigation” as 

these terms are vague, ambiguous, and undefined. Plaintiff further objects to the extent that 

the information requested invades the attorney-client privilege. 

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Subject to and without waiving the foregoing Objections, Plaintiff has no personal 

information responsive to this request. Plaintiff reserves the right to supplement her response 

as discovery continues.

INTERROGATORY NO. 4: 

Identify all resolutions of claims or dispositions 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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as vague, ambiguous, and unduly burdensome. Plaintiff further objects 

to the extent that the information requested invades the attorney-client privilege and requests 

Confidential/Privileged Information. 

Subject to and without waiving the foregoing Objections, Plaintiff possesses no 

information responsive to this request beyond that which is available in records relating to 

the Underlying Action. Plaintiff reserves the right to supplement her response as discovery 

continues.

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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects

to this Interrogatory as overbroad and unduly burdensome. Subject to and without waiving 

the foregoing Objections, Plaintiff, in her document production, will provide any nonprivileged information and documentation responsive to this request. 

Persons not known personally to Plaintiff with knowledge may include former coworkers of Decedent who may attest to her late husband’s exposure to EMTAL talc, 

Plaintiff’s experts from the Underlying Action, and persons identified in Plaintiffs’ Second 

Amended Complaint, as well as documents produced by Defendant, or other defendants in 

this and related cases. 

Plaintiff reserves the right to supplement her response as discovery continues. 

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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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as irrelevant, overbroad and not calculated to lead to the discovery of 

admissible evidence. Subject to and without waiving the foregoing Objections, Plaintiff is 

not aware of any of Decedent’s blood relatives that had cancer of any type. Plaintiff reserves 

the right to supplement her response as discovery continues. 

INTERROGATORY NO. 7: 

Describe Decedent’s Smoking History.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as overbroad, vague and ambiguous. Subject to and without waiving the 

foregoing Objections, Plaintiff estimates her husband smoked approximately one-half pack 

of cigarettes per day. Plaintiff reserves the right to supplement her response as discovery 

continues. 

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.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as overbroad and unduly burdensome. Plaintiff further objects that 

information responsive to this interrogatory is in possession of the Defendants in this action.

Subject to and without waiving the foregoing Objections, Plaintiff recalls her 

husband discussing that he worked with and around asbestos-containing products at 

Goodyear. He also mentioned how he would work with talc, which required him to wash his 

hands in benzene in order to remove from his skin. Plaintiff further recalls her husband 

returning home from work with talc covering his clothing which she laundered.

By way of further response, Plaintiff refers Defendant to any evidence adduced in her 

husband’s Underlying Action to the extent it still exists. Plaintiff reserves the right to 

supplement her response as discovery continues.

 

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INTERROGATORY NO. 9: 

Identify every workplace where Decedent was employed during her lifetime.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects

to this Interrogatory as vague and ambiguous. Subject to and without waiving the foregoing 

Objections, Plaintiff is aware only of Decedent’s employment with Goodyear Tire & Rubber

Co. Plaintiff refers Defendant to any evidence adduced in her husband’s Underlying Action 

to the extent it still exists. Plaintiff reserves the right to supplement her response as 

discovery continues. 

INTERROGATORY NO. 10: 

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

address and dates of residence.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as irrelevant, and not calculated to the lead to the discovery of 

admissible evidence. Subject to and without waiving the foregoing Objections, Plaintiff 

responds as follows:

 Decedent resided on Sparhawk Avenue in Akron. OH prior to the early 1970 (specific 

address unknown); 

 Decedent resided 888 Bertha Avenue, Akron, OH 44306 from 1985 to 1986;

 Decedent resided on Rosalind Avenue in Akron, OH from 1986 to 1990 (specific 

address unknown); 

 Decedent resided at 2299 Winter Parkway, Cuyahoga Falls, OH 44306

INTERROGATORY NO. 11: 

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

Engelhard in Decedent's Underlying Action.

RESPONSE: Plaintiff objects that information responsive to this interrogatory is in 

possession of the Defendants in this action, and accordingly, this interrogatory is unduly 

burdensome. 

Subject to and without waiving the foregoing Objections, Plaintiff is not personally 

aware of or recollect the information provided to her husband and her counsel by counsel for 

Engelhard in Decedent’s Underlying Action other than that which is set forth in the Second 

Amended Complaint. Plaintiff refers Defendant to information in its and/or its codefendants’ possession. 

Plaintiff reserves the right to supplement this response as discovery continues.

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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.

RESPONSE: In addition to the General Objections set forth above, including but not 

limited to Objection No. 16, Plaintiff objects to this Interrogatory as overbroad and unduly 

burdensome. Plaintiff further objects to the extent that the information requested invades the 

attorney-client privilege. 

Subject to and without waiving the foregoing Objections, my husband’s attorneys in 

the Underlying Action had frequent conversations with my husband regarding the 

Underlying Action when my husband was alive and the case still pending. 

After my husband’s death, I too had conversations with Mr. Bevan about the status of 

the Underlying Action, but to a much lesser extent. Still, I am confident Mr. Bevan 

explained to us the decision to dismiss Engelhard from the Underlying Action, as he had with 

other events related to the case. My husband and I relied upon Mr. Bevan and agreed to his 

recommendation.

By way of further answer, on information and belief I understand there is evidence 

that my husband’s case, and numerous other talc asbestos cases against Engelhard/BASF, 

were dismissed or resolved cheaply and without just compensation by Engelhard and BASF, 

based upon Engelhard/BASF’s and Cahill’s representations to attorneys, such as my and my

husband’s attorneys in the Underlying Action, that there was no asbestos in EMTAL talc and 

there was no evidence that there was any asbestos in EMTAL talc. 

Plaintiff refers Defendant to the Second Amended Complaint, which was based upon 

her current attorney’s investigation prior to this litigation, including the investigation results 

in the New Jersey lawsuits referred to in the Complaint. 

Plaintiff reserves the right to supplement her response as discovery in this and related 

matters such as the Sampson case continue.

INTERROGATORY NO. 13: 

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

develop and prosecute claims against Engelhard and its subsidiaries.

RESPONSE: In addition to the General Objections set forth above, Plaintiff objects 

to this Interrogatory as overbroad and unduly burdensome. Plaintiff specifically objects to 

the term “develop” as this term is vague, ambiguous, and undefined. Plaintiff further objects 

to the extent that the information requested invades the attorney-client privilege. Subject to 

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and without waiving the foregoing Objections, Plaintiff possesses no personal information 

responsive to this request at this time, and refers Defendant to Plaintiff’s Response to 

Interrogatory No. 12. 

By way of further answer, Plaintiff is generally aware that there was discovery and 

investigation conducted by her and her husband’s attorneys as set out in the Second 

Amended Complaint which sought information about EMTAL talc. The Second Amended 

Complaint and attached exhibits also discuss the Bevan Law Firm’s communications with the 

Cahill Gordon law firm who represented Engelhard/BASF. Plaintiff reserves the right to 

supplement her response as discovery continues.

Dated: December 23, 2016 COHEN, PLACITELLA & ROTH, P.C.

 /s/ Jared M. Placitella )

 Jared M. Placitella, Esq. (NJ Atty #: 068272013)

 As to Objections 

Fox Rothschild LLP

Jeffrey M. Pollock, Esq. (NJ Atty #: 015751987)

Princeton Pike Corp. Center

997 Lennox Drive, Building 3

Lawrenceville, NJ 08648

(609) 896-7660

Attorneys for Plaintiffs and the Putative Class

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CERTIFICATE OF SERVICE

I hereby certify that on December 23, 2016, I served the foregoing Plaintiff’s Responses 

to Defendant’s First Set of Interrogatories on the following attorneys via Email:

Eugene F. Assaf, P.C.

Kirkland & Ellis, LLP

655 15th St., N.W.

Washington, D.C. 20005

eassaf@kirkland.com

Michael F. Williams, Esq.

Kirkland & Ellis, LLP

655 15th St., N.W.

Facsimile: (202) 879-5200

mwilliams@kirkland.com

Justin T. Quinn, Esq.

Robinson Miller LLC

One Newark Center, 19th Floor

Newark, New Jersey 07102

jquinn@rwmlegal.com

Attorneys for Defendant, BASF Catalysts, LLC

John K. Villa, Esq.

Williams & Connolly, LLP

725 12th Street, N.W.

Washington, D.C. 20005

jvilla@wc.com

Grant A. Geyerman, Esq.

Williams & Connolly, LLP

725 12th Street, N.W.

Washington, D.C. 20005

ggeyerman@wc.com

Robert E. Ryan, Esq.

Connell Foley, LLP

85 Livingston Avenue

Roseland, New Jersey 07068

rryan@connellfoley.com

Attorneys for Cahill Defendants

Kevin H. Marino, Esq.

Marino, Tortorella & Boyle, P.C.

437 Southern Boulevard

Chatham, New Jersey 07928

kmarino@khmarino.com

John A. Boyle, Esq.

Marino, Tortorella & Boyle, P.C.

437 Southern Boulevard

Chatham, New Jersey 07928

jboyle@khmarino.com

Attorneys for Defendant Arthur Dornbusch

Eric Tunis, Esq.

Herold Law, P.A.

25 Independence Boulevard

Warren, New Jersey 07059

etunis@heroldlaw.com

Attorneys for Defendant Thomas Halket

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Dated: December 23, 2016 COHEN, PLACITELLA & ROTH, P.C.

 /s/ Jared M. Placitella 

 Jared M. Placitella 

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