Eugene F. Assaf, P.C. (pro hac vice)

Michael F. Williams

Daniel A. Bress (pro hac vice)

Peter A. Farrell (pro hac vice)

KIRKLAND & ELLIS LLP

655 15th St., N.W.

Washington, D.C. 20005

Phone: (202) 879-5000

Facsimile: (202) 879-5200

Justin T. Quinn 

ROBINSON MILLER LLC

One Newark Center, 19th Floor

Newark, New Jersey 07102

Phone: (973) 690-5400

Facsimile: (973) 466-2761

Counsel for Defendant BASF Catalysts LLC

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

KIMBERLEE WILLIAMS, ET AL.,

Plaintiffs,

v.

BASF CATALYSTS LLC, ET AL.,

Defendants.

:

:

:

:

:

:

:

:

:

:

:

No. 2:11-cv-01754 (JLL) (JAD)

CIVIL ACTION

DECLARATION OF 

JUSTIN T. QUINN, ESQ.

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 1 of 6 PageID: 30518
2

I, Justin T. Quinn, of full age, hereby declare as follows: 

1. I am an attorney at law and a partner with the law firm Robinson Miller 

LLC in Newark, New Jersey. 

2. I am one of the counsel of record for Defendant BASF Catalysts LLC 

in this action. 

3. Attached hereto as Exhibit A is a true and correct excerpt of an oral 

argument hearing transcript before the Special Discovery Master dated April 2, 

2018.

4. Attached hereto as Exhibit B is a true and correct copy of a U.S. 

Geological Survey Preliminary Report dated April 12, 1951.

5. Attached hereto as Exhibit C is a true and correct copy of Alfred 

Chidester’s Geological Survey Study titled “Petrology and Geochemistry of 

Selected Talc-bearing Ultramafic Rocks and Adjacent Country Rocks in NorthCentral Vermont” dated March 3, 1949.

6. Attached hereto as Exhibit D is a true and correct copy of the 

Deposition Transcript of Alfred H. Chidester dated October 23, 1983 in the matter 

of Westfall v. Whittaker, Clark & Daniels, et al.

7. Attached hereto as Exhibit E is a true and correct copy of the Maryanne 

G. Boundy, et al. study titled “Occupational Exposures to Non-Asbestiform Talc in 

Vermont.”

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 2 of 6 PageID: 30519
3

8. Attached hereto as Exhibit F is a true and correct copy of the Sherry 

G. Selevan, et al. study titled “Mortality Patterns Among Miners and Millers of NonAsbestiform Talc: Preliminary Report.”

9. Attached hereto as Exhibit G is a true and correct copy of a letter from 

John Dement of the Department of Health, Education, and Welfare Public Health 

Service Center for Disease Control to William Burgess of Harvard University 

School of Public Health dated April 19, 1976.

10. Attached hereto as Exhibit H is a true and correct copy of a National 

Institute for Occupational Safety and Health Bulletin titled “Asbestos Fibers and 

Other Elongated Mineral Particles: State of the Science and Roadmap for Research” 

dated January 20. 2009.

11. Attached hereto as Exhibit I is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. Customer Report dated July 8, 1971.

12. Attached hereto as Exhibit J is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. Technical Service Request dated October 3, 1972.

13. Attached hereto as Exhibit K is a true and correct copy of a letter from 

Lucy McCrone of Walter C. McCrone & Associates, Inc. to Emil Triglia of 

Engelhard Minerals and Chemicals Corp. dated December 7, 1973.

14. Attached hereto as Exhibit L is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. Technical Service Request dated December 17, 1973.

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 3 of 6 PageID: 30520
4

15. Attached hereto as Exhibit M is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. Technical Service Request dated December 2, 1977.

16. Attached hereto as Exhibit N is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. Technical Service Request dated February 1, 1979.

17. Attached hereto as Exhibit O is a true and correct copy of a 

conversation memorandum concerning the events of a February 6, 1979 visit of 

representatives from Exxon, Ribelin, and Engelhard Minerals and Chemical Corp. 

regarding Minerals Present in Emtal Talcs.

18. Attached hereto as Exhibit P is a true and correct copy of the 

Declaration of Drew Van Orden in this matter dated January 15, 2018.

19. Attached hereto as Exhibit Q is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. inter-department memorandum from P. Gale to E. 

Triglia dated April 11, 1979.

20. Attached hereto as Exhibit R is a true and correct copy of BASF 

Catalyst LLC’s Brief in Opposition to Plaintiff’s Motion to Compel dated April 24, 

2018. This document was filed ex parte and in camera before the Special Discovery 

Master and is also being filed ex parte and in camera here.

21. Attached hereto as Exhibit S is a true and correct copy of an email from 

Justin Quinn of Robinson Miller LLC to the Special Discovery Master dated May 1, 

2018, 9:34 AM.

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 4 of 6 PageID: 30521
5

22. Attached hereto as Exhibit T is a true and correct copy of an email from 

Jared Placitella of Cohen, Placitella & Roth, P.C. to Justin Quinn of Robinson Miller 

LLC and the Special Discovery Master dated May 1, 2018, 10:17 AM.

23. Attached hereto as Exhibit U is a true and correct copy of an email 

from Jared Placitella of Cohen, Placitella & Roth, P.C. to the Special Discovery 

Master dated May 3, 2018, 4:49 PM.

24. Attached hereto as Exhibit V is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. memorandum from E. Triglia dated May 14, 1979. 

This document is privileged and so was filed ex parte and in camera before the 

Special Discovery Master and is also being filed ex parte and in camera here.

25. Attached hereto as Exhibit W is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. memorandum from E. Triglia to J. Brush, et al. dated

May 2, 1979. This document is privileged and so was filed ex parte and in camera

before the Special Discovery Master and is also being filed ex parte and in camera

here.

26. Attached hereto as Exhibit X is a true and correct copy of a Talc 

Meeting Memorandum dated May 17, 1979.

27. Attached hereto as Exhibit Y is a true and correct copy of an Engelhard 

Minerals and Chemical Corp. memorandum from J. Brush to R. Graf, G. Hemstock 

and R. McIlwain dated June 18, 1979. This document is privileged and so was filed 

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 5 of 6 PageID: 30522
6

ex parte and in camera before the Special Discovery Master and is also being filed 

ex parte and in camera here.

28. Attached hereto as Exhibit Z is a true and correct copy of a letter from 

James Hubbard of Georgia Institute of Technology’s Engineering Experiment 

Station to E. Triglia of Engelhard Minerals & Chemicals Corp. dated September 19, 

1979.

29. Attached hereto as Exhibit AA is a true and correct copy of Plaintiff’s 

PowerPoint Slides from February 23, 2018 hearing in this matter.

30. Attached hereto as Exhibit BB is a true and correct copy of R. Edward 

Lomas’ Expert Report dated April 12, 2013.

31. Attached hereto as Exhibit CC is a true and correct copy of an 

Engelhard Minerals and Chemical Corp. inter-department memorandum from E. 

Triglia to G. Hemstock dated May 22, 1979.

32. Attached hereto as Exhibit DD is a true and correct copy of an 

Engelhard Minerals and Chemical Corp. Technical Service Request dated May 9, 

1979.

I declare under penalty of perjury that the above statements are true and 

correct to the best of my knowledge and belief. 

s/ Justin T. Quinn

Justin T. Quinn

Dated: May 17, 2018

Case 2:11-cv-01754-BRM-AME Document 521-2 Filed 05/17/18 Page 6 of 6 PageID: 30523