EXHIBIT C 

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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)

RESPONSE OF PLAINTIFFS TO BASF

CATALYST LLC’S SECOND SETS OF INTERROGATORIES

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

Williams, Nancy Pease, Marilyn L. Holley, Donna Ware, Donnette Wengerd, and Rosanne 

Chernick, (“Plaintiffs”) object and respond to Defendant BASF Catalysts LLC’s Second Sets of 

Interrogatories addressed to each Plaintiff in the following responses. In addition, Plaintiffs 

preface these responses by noting that:

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1. As Plaintiffs’ counsel has informed the Court, two Plaintiffs are incapacitated and 

are in the process of being substituted. Plaintiff Donna Ware and her personal representative,

Randall Ware, have both died. Accordingly, acting Representative Sheila Ware (Randall’s 

Ware’s surviving wife) answers on behalf of the Estate of Ralph Ware. Plaintiff Nancy Pease 

suffers from advanced dementia. Accordingly, acting Representative Gayle Williams (Nancy’s 

sister) answers on behalf of the Estate of Jim Clark.

DEFENDANT BASF’s DEFINITIONS

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 limit to the time, place, 

or circumstances of its occurrence; and/or any other transmittal of information by any media by 

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any manner.

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 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 [any of the following:] Charles L. Williams, Kathryn Darnell, Ralph 

Ware, Jennifer Graham or Steven Chernick.

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, 

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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.

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.

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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 government entities; and all 

subsidiaries, affiliates, divisions, departments, branches, and other units thereof or any 

combination thereof.

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 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. “Putative Class” means the putative class alleged in the Complaint.

19. “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.

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

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

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

Complaint.

18. “Putative Class” means the putative class alleged in the Complaint.

19. “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.

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

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

22. “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) or the similar respective actions identified in the 

Complaint filed by or behalf of the Decedents of the Named Plaintiffs.

23. “You” and “Your” mean Kimberlee Williams[, Nancy Pease, Marilyn L. Holley, Donna 

Ware, Donnette Wengerd, and Rosanne Chernick], as well as all present and former agents, 

attorneys or representatives of Kimberlee Williams[, Nancy Pease, Marilyn L. Holley, Donna 

Ware, Donnette Wengerd, and Rosanne Chernick] or Decedent[s].. 

24. 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. 

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

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“including but not limited to.” 

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

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. Defendant BASF’s 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 Plaintiffs’ 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, Plaintiffs do not waive the right to challenge the relevancy, materiality, and/or 

admissibility of the documents or information provided by 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 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 

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information obtained by Plaintiffs’ attorneys that involve their professional skill and experience; 

legal research, including delegated research—which includes research or investigation by 

Plaintiffs’ attorneys, or by persons hired by Plaintiffs’ attorneys and acting under their supervision; 

strategic litigation planning, mental impressions (or documents reflecting such planning or 

impressions); and documents gathered by Plaintiffs’ 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. They seek documents or information within the exclusive possession, custody or 

control of Defendant.

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

filed in this action.

8. They are “contention” type.

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

outweigh any likely benefits. 

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

calculated to lead to the discovery of admissible evidence. 

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

order, or confidentiality agreement.

12. They may cause or require Plaintiff to violate any confidentiality or non-disclosure 

provision of a Bankruptcy or Settlement Trust. 

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

interpretation.

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14. They are redundant to proceedings or requirements set by the Court or Special 

Discovery Master and to that extent Plaintiffs view the interrogatory as preempted by the Court’s 

management orders.

INTERROGATORIES

INTERROGATORY NO. 1:

Describe all damages, losses, harm, or other relief for which You contend BASF is 

responsible, including but not limited to:

(a) The amount of damages, loss, harm or other relief;

(b) The method for calculating that damage, loss, harm, or other relief;

(c) The basis for calculating that damage, loss, harm, or other relief;

(d) How that damage, loss, harm, or other relief differs, if at all, from the damages 

Decedent claimed in his original complaint in the Underlying Action.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as vague, ambiguous, and unduly burdensome. Plaintiffs further object that 

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

is otherwise set forth in Plaintiffs’ Second Amended Complaint. This interrogatory is also 

objectionable to the extent it calls for information protected by the attorney-client 

communication and work product privileges, particularly given that the definition of “You”

includes present and former attorneys.

By way of further response, information regarding damages, losses, and harms will be 

provided in Plaintiffs’ Motion for Class Certification, the discovery that follows, and 

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accordingly, this response will be supplemented at the appropriate time by that filing and 

subsequent discovery. Plaintiffs further object to the extent this discovery is redundant to 

management order directed filings such as the Class Certification Motion. 

By way of further reply, this interrogatory calls for the opinion of an expert witness. 

Expert witnesses have not been identified at this time and Plaintiffs reserve the right to 

supplement this response when expert witnesses are identified.

This interrogatory also objectionably invades the province of the fact finder in 

determining remedies, damages, loss, and harm, and the calculation thereof.

Plaintiffs reserve the right to supplement this response as discovery continues.

INTERROGATORY NO. 2:

Identify each and every Person who previously filed an Action against BASF based on 

exposure to Emtal Talc, including for each Person: 

(a) The Person’s Name; 

(b) The Person’s Address; 

(c) The Person’s current legal representative, if any; 

(d) The case name, number, and venue for the Person’s previously-filed Action(s) against 

BASF;

(e) All other Action(s) for relief filed by the Person against any Other Defendant or nonparty based on exposure to Asbestos;

(f) The counsel of record for the Person’s previously-filed Action(s);

(g) The Person’s Asbestos-related Injury, if any;

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(h) The circumstances of the Person’s exposure to Emtal Talc;

(i) The Person’s total damages attributable to Asbestos exposure;

(j) The Person’s portion of total damages attributable to BASF;

(k) The Person’s damages attributable to the fraud and/or fraudulent concealment alleged 

in the Second Amended Complaint.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as vague, ambiguous, and unduly burdensome. Plaintiffs further object that 

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

has otherwise been provided to Defendants in discovery, to the extent that it is available. 

Plaintiffs reserve the right to supplement this response as discovery continues.

INTERROGATORY NO. 3:

Identify each and every Person who did not file an Emtal-related claim against BASF 

because of the fraud and fraudulent concealment alleged in the Second Amended Complaint, 

including for each Person:

(a) The Person’s Name; 

(b) The Person’s Address; 

(c) The Person’s current legal representative, if any; 

(d) All other Action(s) for relief filed by the Person against any Other Defendant or nonparty based on exposure to Asbestos;

(e) The counsel of record for the Person’s previously-filed Action(s); 

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(f) The person’s Asbestos-related Injury, if any; 

(g) The circumstances of the Person’s exposure to Emtal Talc; 

(h) The Person’s total damages attributable to Asbestos exposure; 

(i) The Person’s portion of total damages attributable to BASF; 

(j) The Person’s damages attributable to the fraud and/or fraudulent concealment alleged 

in the Second Amended Complaint.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as vague, ambiguous, and unduly burdensome. It is also improper, premature

class discovery and beyond the scope of discovery. Plaintiffs further object that information 

responsive to this interrogatory is in possession of the Defendants in this action or the individual 

members of the putative class members and/or their counsel. 

Plaintiffs reserve the right to supplement this response as discovery continues.

INTERROGATORY NO. 4:

Describe whether each Putative Class representative and Putative Class member has the 

“original” Documents (as opposed to copies or electronically scanned versions) from their 

Underlying Actions, including:

(a) Whether and when each Putative Class member’s or Putative Class representative’s 

“original” Documents were destroyed, discarded, or not retained; 

(b) Whether and when copies, electronically scanned versions, or other reproductions of 

the Documents were made, including who made them; 

(c) Whether You have copies, electronically scanned versions, or other reproductions of 

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all Documents from the Underlying Action; 

(d) Whether the Putative Class representative’s or Putative Class member’s Documents 

were subject to a document-retention policy. 

(e) Whether any Document (original or copy) from the Underlying Action is no longer 

available, including the reason(s) the Documents are no longer available; and

(f) Whether each Putative Class representative and Putative Class member contends that 

copies, electronically-scanned versions, or other reproductions of “original” Documents are 

adequate substitutes for the “original” Documents.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as seeking information beyond the scope of discovery under the Federal Rules 

of Civil Procedure. As posed the questions are also vague, ambiguous, harassing, unduly 

burdensome and not in good faith and presume and/or suggest a duty upon plaintiffs and/or their 

family members who were plaintiffs in any underlying action that did and does not exist. To the 

extent it seeks case specific information from putative absent class members it is improper absent 

class member discovery.

Plaintiffs further object on the basis that information and documents responsive to this 

interrogatory may already be in the possession, custody or control of the Defendants from the 

proceedings and discovery in each of their respective Decedents’ Underlying Actions.

To the extent representative plaintiffs have documents responsive to this interrogatory, 

they or their copies, as permitted by FRCP 34 (2)(B) have been provided or identified as 

privileged in response to defendants’ requests for production of documents. 

. To the extent this interrogatory concerns documents in the possession of putative class 

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members, Plaintiffs have no information upon which to form a response at this time. 

Plaintiffs reserve the right to supplement this response as discovery continues.

INTERROGATORY NO. 5:

As Putative Class representative, describe Your trial plan for this case, including but not 

limited to Your trial plan for the following issues:

(a) Your process for establishing, without undertaking person-by-person inquiries, the 

existence of injury for a particular plaintiff, causation for a particular plaintiff, reliance by a 

particular plaintiff, materiality for a particular plaintiff, and the amount of any damages for that 

particular plaintiff;

(b) Your process for determining, without undertaking person-by-person inquiries, 

whether a person is a member of the Putative Class you seek to represent;

(c) Your process for identifying and providing notice to Putative Class members;

(d) Your process for determining whether heirs or other individuals have legal authority 

to act on behalf of Putative Class members who may be deceased;

(e) Your process for calculating and distributing any damages that may be awarded in this 

case to Putative Class members.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as vague, ambiguous, and unduly burdensome and not proportionate discovery. 

The question is also preempted by the Court’s case management orders as it concerns matters 

relating to class certification discovery under the management of the Court’s Special Discovery 

Master. This interrogatory is also objectionable to the extent it calls for information protected by 

the attorney-client communication and work product privileges. The question is objectionable as 

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it calls for special expertise in class action procedures and class action notice and benefit 

administration,which is not a proper fact question to pose to the representative Plaintiffs. 

Furthermore, Plaintiffs object to this interrogatory to the extent it is premature, as we are in the

early stages of pre-certification class discovery.

Plaintiffs will provide information regarding exhibits and trial witnesses in accordance 

with the Federal Rules of Civil Procedure at such time as required by appropriate case

management orders. 

INTERROGATORY NO. 6:

Identify all common questions of law or fact that You contend exist under Federal Rule 

of Civil Procedure 23(a) (2) and/or predominate under Rule 23(b) (3) and state specifically:

(a) The Identity of the putative class(es) that you contend satisfies Rule 23(a)(2) 

commonality and Rule 23(b)(3) predominance;

(b) Each issue that You contend satisfies Rule 23(a) (3) commonality and Rule 23(b) (3) 

predominance;

(c) Each material fact that supports Your contention(s);

(d) The Documents that support your contention(s).

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

this Interrogatory as vague, ambiguous, and unduly burdensome. It is also an objectionable

contention interrogatory. 

This interrogatory is further objectionable to the extent it calls for information protected 

by the attorney-client communication and work product privileges. Furthermore, Plaintiffs object 

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to this interrogatory to the extent it is premature, as the case is in the early stages of precertification class discovery and any beyond those already set out in the Second Amended 

Complaint, will be specified in Plaintiffs’ motion for class certification. 

Without waiver of objections, Plaintiffs refer defendant to their Second Amended 

Complaint which lists numerous common questions responsive to this interrogatory, along with 

the documents attached to the Complaint. Defendant is also referred to the testimony of the 

following witnesses and documents marked during their depositions:

1. Depositions of Ellen Poole in Paduano case (October 14, 2010; May 25, 2010) and the 

Sampson case (May 23, 2012 and April 2, 2014).

2. Deposition of Glenn A. Hemstock, Ph.D. in Sampson May 9, 2012 (Vol. I); May 29, 

2012 (Vol II); June 25, 2012 (Vol. III); and June 27, 2012 (Vol. IV).

3. Deposition of David Swanson June 15, 2009 in Paduano

4. Deposition of Daniel Steinmetz dated July 18, 19, and August 2, 2017 in Sampson and 

on October 11, 2017 in Ross.

Plaintiffs reserve the right to supplement this response at such time as after the class 

certification memoranda is filed and briefed 

INTERROGATORY NO. 7:

Identify all Facts, including Documents, that support Your contention that the Putative 

Class representatives satisfy the requirements of typicality and/or adequacy under Rules 23(a) 

(3)-(4).

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

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this Interrogatory as vague, ambiguous, and unduly burdensome. This interrogatory is also 

objectionable to the extent it calls for information protected by the attorney-client 

communication and work product privileges. Furthermore, Plaintiffs object to this interrogatory 

to the extent it is premature, as we are in the early stages of pre-certification class discovery.

Without waiver of objections, Plaintiffs refer defendant to their Second Amended 

Complaint which explains how and why they and their claims are typical. 

Plaintiffs reserve the right to supplement this response at such time as after the class 

certification memoranda is filed and briefed.

INTERROGATORY NO. 8:

Identify all Facts, including Documents, that support Your contention that the Putative 

Class satisfies the superiority requirement of Rule 23(b) (3), including the reasons why You 

contend that a class action method of adjudication is superior to alternative methods.

RESPONSE: In addition to the General Objections set forth above, Plaintiffs object to 

this Interrogatory as vague, ambiguous, and unduly burdensome. This interrogatory is also 

objectionable to the extent it calls for information protected by the attorney-client 

communication and work product privileges. Furthermore, Plaintiffs object to this interrogatory 

to the extent it is premature, as we are in the early stages of pre-certification class discovery.

Without waiver of objections, Plaintiffs refer defendant to their Second Amended 

Complaint which explains how and why a class action adjudication of thousands of similar 

fraudulent concealment and fraud claims arising out of defendants’ common spoliation of 

evidence and uniform fraudulent misrepresentations and concealment is superior to alternative 

methods.

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Plaintiffs reserve the right to supplement this response at such time as after the class 

certification memoranda is filed and briefed

December 7, 2017 COHEN, PLACITELLA & ROTH, P.C.

 

 /s/ Jared M. Placitella u 

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

 As to Objections 

 FOX ROTHSCHILD LLP

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

 Attorneys for Plaintiffs and the Putative Class

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CERTIFICATE OF SERVICE

I hereby certify that on December 7, 2017, I served the foregoing Plaintiff’s Responses to 

Defendant BASF’s Catalysts Second Set of Interrogatories on the following attorneys via email:

COHEN, PLACITELLA & ROTH, P.C.

 

 /s/ Jared M. Placitella 2

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

Eugene F. Assaf, P.C.

Michael F. Williams, Esq.

Kirkland & Ellis, LLP

655 15th St., N.W.

Washington, D.C. 20005

eassaf@kirkland.com

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 A. Boyle, Esq.

Marino, Tortorella & Boyle, P.C.

437 Southern Boulevard 

Chatham, New Jersey 07928

jboyle@khmarino.com

Attorneys for Defendant Dornbusch

John K. Villa, Esq.

David Blatt, Esq.

Williams & Connolly, LLP

725 12th Street, N.W.

Washington, D.C. 20005

jvilla@wc.com

dblatt@wc.com

Robert E. Ryan, Esq.

Connell Foley, LLP

85 Livingston Avenue

Roseland, New Jersey 07068

rryan@connellfoley.com

Attorneys for Cahill Defendants

Eric Tunis, Esq.

Herold Law, P.A.

25 Independence Boulevard

Warren, New Jersey 07059

etunis@heroldlaw.com

Attorney for Defendant Halket

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