Exhibit F

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UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

KIMBERLEE WILLIAMS, et al.

Plaintiffs,

vs.

BASF CATALYSTS LLC, et al.

Defendants.

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

CIVIL ACTION

DECLARATION OF THE HONORABLE MARINA 

CORODEMUS, J.S.C. (RETIRED) IN SUPPORT OF 

APPOINTMENT AS SETTLEMENT TRUSTEE AND 

SPECIAL MASTER

MARINA CORODEMUS, being of majority age does pursuant to 28 

USCS §1746 declare as follows: 

1. I submit this declaration in support of the application by Class 

Counsel, Cohen Placitella & Roth, P.C., for my appointment as the 

Court’s Special Master and Settlement Trustee responsible for 

administering a Settlement Fund, a Cost Fund and other matters 

specified under the Plan of Distribution (“POD”) that is being presented

for preliminary approval by the Court under and pursuant to the terms 

of the Settlement Agreement dated March 13, 2020 in the Williams 

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Action”.1 The information I set forth herein is based on my first-hand 

knowledge except for where I indicate that I am relying on a different 

source, in which case I believe the source cited to be credible and

trustworthy and the information true. 

2. I am familiar with Williams Action from my review of the Second 

Amended Complaint and the published opinions by the Third Circuit 

and Court in this matter. 

3. I am also familiar with and understand the terms and provisions 

of the proposed Williams Action’s Settlement Agreement and the POD

distributing the Settlement’s Settlement Fund if the proposed 

settlement is approved by the Court based upon: (a) my review of the 

Settlement Agreement, the POD, the proposed Settlement Fund and 

Cost Fund escrow agreements and the Notice Plan; and (b) my 

discussions of their respective terms of these which pertain to the duties 

and responsibilities of the Settlement Trustee/Special Master with (1) 

Class Counsel, (2) Verus LLC (who I understand assisted Class Counsel 

in the design of the POD and is being nominated to serve as the 

1 For consistency I incorporate the definitions of the proposed Settlement Agreement and POD by 

reference. Capitalized terms appearing herein therefore shall have the same meanings as defined in 

these documents.

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Settlement Administrator), and (3) Edward Gentle, Esquire (who 

together with his law firm is being nominated for appointment as the 

Settlement Lien Administrator).

4. I believe, as I will elaborate on below, that I possess the 

credentials, experience, ability and reputation for fairness and 

practicality among asbestos and mass tort practitioners—and courts as 

well—to successfully carry out the duties of Settlement Trustee/

Settlement Master under the Settlement Agreement and POD, 

including:

(a) Participating in the creation and then overseeing the 

Qualified Settlement Funds holding the Settlement Fund and Cost 

Fund as provided for in the Settlement Agreement, POD, fund escrow 

agreements and Court Orders;

(b) Retaining and then overseeing the Administrator and Lien 

Administrator appointed by the Court;

(c) Overseeing execution of the settlement’s Notice Plan;

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(d) Executing the Plan of Distribution, including performing 

the adjudications under the Plan entrusted to the Special

Master/Settlement Trustee and making disbursements;

(e)Retaining independent auditors of the Settlement and Cost 

Funds as required or needed and thereafter taking appropriate action 

as the audit results indicate;

(f) Conducting Special Master/Settlement Trustee’s audits and 

administrative reviews required by the Settlement Agreement and 

POD;

(g) Compiling and submitting the Special Master/Settlement 

Trustee budgets claim schedules and reports required by the Settlement 

Agreement and POD, and

(h) Performing such other tasks or assignments as the Court 

may direct relating to the administration and oversite of the Settlement

Agreement and POD.

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Qualifications

5. I am an attorney at law, duly licensed and admitted to practice in 

the States of New Jersey and New York. I am in good standing before 

both Bars.

6. I was admitted to the Bar of New Jersey in 1981 and to the New 

York Bar in 1989. I am also duly admitted to the Roll of Attorneys of 

this District Court. 

7. Between 1981 and 1993 I worked at the law firm of Corodemus 

and Corodemus, Perth Amboy, New Jersey, where I was a partner.

Among other matters I handled products and environmental litigation 

matters.

8. In 1993, I was appointed to the New Jersey Superior Court where 

I served in New Brunswick, Middlesex County. Prior to the conclusion 

of my initial term I was reappointed to the Superior Court with life 

tenure. I retired from the bench in 2004. 

9. In 1997 the Superior Court’s administration appointed me to 

develop and implement a litigation program for management of mass 

tort cases which became known as the “New Jersey Mass Tort Court”. 

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This specialized Court’s mission over the years was expanded to 

encompass many other types of aggregate or multiple cases litigation

beyond tort matters and as a result is now called the “New Jersey 

Multi-County Litigation Court”.

10. During the Mass Tort Court’s initial ten years I was the sole 

“Mass Tort” state judge in New Jersey, in which I presided over a wide 

variety of mass tort and class action litigation cases. The cases included

environmental, pharmaceutical, general products liability and asbestos

matters (which were assigned to and part of the Mass Tort Court when 

I was on the bench). Several of the matters that came before me have 

been recognized as landmark “mass tort” cases, including:

• The Ciba-Geigy Toms River Plant Superfund Site 

Litigation. This complex matter involved a large number of 

individual Superior Court personal injury suits—many claiming 

that a child developed a cancer disease—as well as several class 

actions seeking medical monitoring and property damages. All of 

the cases stemmed from alleged toxic chemical waste releases 

from waste storage lagoons and deteriorating buried drums 

located on the Ciba-Geigy chemical plant site in Toms River, New 

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Jersey. The environmental condition of the plant and surrounding 

community led to the plant complex and surrounding residential 

neighborhoods being placed on the National Contingency Plan 

(a/k/a/ “Superfund Site”) List. The Plaintiffs contended that the 

released hazardous chemicals included trichloroethylene, 

tetrachloroethylene, benzene and chloroform, and their release 

and migration into their neighborhood environments caused

among other things, a documented (and widely publicized) cluster 

of malignant disease occurrences among neighboring residential 

communities’ children; significant public and private nuisance

interfering with their lives, and substantial property value 

diminishment.

• New Jersey’s Fen-Phen Diet Drug Litigation. American 

Home Products (AHP) (later known as Wyeth Pharmaceuticals) in 

the 1990s was located and headquartered in New Jersey and had 

manufactured Pondimin and Redux, both drugs comprising the 

“Fen” component in the widely used “Fen-Phen” diet drug 

combination that was popular in the late 1990s. When the two 

drugs were recalled and taken off the market in 1997 due to being 

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associated with causing heart valve damage and a fatal 

pulmonary disease, thousands of personal injury suits were filed 

in New Jersey’s Superior Court alone and the New Jersey Mass 

Tort Court had one of the largest dockets of diet drug personal 

injury cases in the United States. During the original phase of this 

vast, long-lived litigation, i.e., up to the time of its national 

settlement, I managed the New Jersey cases which had a highly 

active State Plaintiffs Steering Committee (PSC) prosecuting the 

cases separate and apart from the federal Diet Drug MDL 

litigation’s PSC. In the summer of 1999, I presided over a two 

month long medical monitoring – consumer fraud class action 

trial. The trial, which was eventually stayed towards the 

conclusion of the Class Plaintiffs’ case in chief, is recognized for 

being highly instrumental in fostering agreement among the 

many, highly combative factions involved in the cases to meet and 

negotiate a $3.75 billion national settlement. The settlement was 

eventually executed in the related Diet Drug MDL, venued in the 

Eastern District of Pennsylvania, which was coordinated with the 

Superior Court’s Diet Drug litigation. On my watch thousands of 

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individual New Jersey Superior Court cases were resolved both in 

and outside of the national settlement.

• New Jersey’s Tobacco Litigation. New Jersey tobacco cases 

were in the vanguard of the nation’s tobacco litigation, and during 

my tenure on the bench tobacco litigation in various contexts and 

forms were continually before me. 

• Asbestos Litigation. New Jersey’s “Asbestos Case Program” was 

one of the Mass Tort Court’s parts throughout my tenure as 

presiding judge of the Mass Tort Court. Under this program each 

and every asbestos case filed in New Jersey State court was 

centralized and assigned to this court. To help me administer this

program’s massive docket I had two full time Special Masters along 

with a team of support staff assigned to me which I was responsible 

for managing in addition to my other judicial activities.

11. As I approached the end of my career on the bench, the New 

Jersey Mass Tort Court program’s docket grew to such size that more 

than one judge was needed to handle the wide array and volume of 

cases constantly being assigned to the court. Before retiring I trained 

several judges to take on the duties of presiding over New Jersey’s Mass 

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Tort Court. Upon my retirement the court’s docket was then divided 

and spread over three New Jersey Superior Court vicinages: Bergen, 

Middlesex and Atlantic counties. 

12. Among my major accomplishments in implementing and 

presiding over New Jersey’s Mass Tort Court are the results of my work 

on Federal-State Court cooperation/coordination initiatives, including 

ones that I was involved in under the auspices of the Association of 

Chief Justices and the Federal Rules Committee. The judicial system 

coordination methods that I and my colleagues developed during these 

efforts have become routine measures employed today where both 

federal MDL and State Court Mass Tort programs are proceeding 

simultaneously. For my work in this area, in 2014 I received of the 

Middlesex County Bar’s Robert T. Wilentz lifetime achievement award. 

In presenting me with the award New Jersey Supreme Court Associate 

Justice Barry Albin praised my work “as having set the standard for 

how the State conducts Mass Torts cases.” 

13. Both on and off the bench I have been active in many legal 

academic and educational activities. I have served as an adjunct law 

professor at Rutgers Law School. I have and still do frequently lecture

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before professional society and organization meetings and conferences 

on mass tort litigation topics, including techniques and best practices 

for managing aggregate claims and mass tort settlement 

administration. I annually chair a national level seminar on mass torts 

in which many eminent state and federal jurists and mass tort 

practitioners make presentations and numerous mass torts

practitioners (both plaintiffs and defense) from across the country 

attend. I also have authored several of the original chapters of the New 

Jersey Mass Tort Handbook published by the New Jersey 

Administrative Office of the Courts. 

14. I am and have been active in a number of professional 

societies and organizations over my legal career. Currently I am 

member of the New Jersey State Bar Association. I am also an elected 

Member of the American Law Institute and have been appointed to its 

Aggregate Litigation Advisory Committee. Previously I served as an

officer and section leader of the Sedona Conference, a premier national 

organization noted for its work on developing best practices and 

procedures for electronic discovery and mass tort and complex litigation 

tasks and procedures. I am a former Chair of the Middlesex County 

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Vicinage Ethics Committee. I was also president of the New Jersey 

Trial Lawyers Association (now known as the New Jersey Association of 

Justice). 

15. I have been recognized by the New Jersey Bar Association as 

a Women Trail Blazer for my work and accomplishments as a lawyer 

and jurist.

16. On my retirement from the bench, I returned to legal 

practice, which I have limited to alternative dispute resolution 

engagements as a neutral and to serving various courts as a Special 

Master, Settlement Trustee, mediator or auditor.

17. I am a certified arbitrator for the American Association of 

Arbitrators (AAA) and the American Health Lawyers Association and

am admitted into the International Institute for Conflict Resolution. I 

am also a past President of the Academy of Court Appointed Masters. 

Judicial Appointments

18. Since 2004 I have been appointed by courts or by parties to 

serve as a special master, settlement trustee or mediator in a number of 

federal and state court matters. In addition to numerous assignments 

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regarding relatively small-scale consumer fraud and aggregate 

litigation matters, I have substantial experience in handling large-scale 

master/trustee assignments such as involved here in this Williams

Action ‘s proposed Settlement Agreement and POD. Some of the 

noteworthy of these include:

A. Federal Court Appointments

• MDL No. 1567 (Vioxx Products Liab. Actions). Appointed Special 

Master by Judge Fallon, U.S. District Court for Eastern District of 

Louisiana to handle settlement issues.

• MDL No. 1297 (DuPuy Orthopedic Devices Products Liab. 

Actions). Appointed by Judge Katz, U.S. District Court for

Northern District of Ohio, to handle settlement appeal issues.

• MDL No. 1335 (Propulsid Products Liab. Actions). Appointed

Special Master by Judge Fallon to handle settlement issues.

• MDL No. 2235 (American Medical Systems TVM Products Liab. 

Actions) Appointed Special Master by Judge Goodwin U.S. District 

Court for Southern District of West Virginia to handle settlement 

issues relating to private settlement agreements. 

• MDL No. 2602 (Benicar (Olmesartan) Products Liab. Litig.

Appointed Special Master on August 1, 2017 by Judge Kugler, 

U.S. District Court of New Jersey with responsibility for handling

and adjudicating applications to dismiss claims for failure to 

comply with the terms of a settlement agreement and making 

recommendation to the Court on the resolution of other motions 

related to the settlement specified in the agreement. The subject 

national settlement agreement covered 2,000 MDL cases from 

across the country as well as another 100 cases pending in New 

Jersey Superior Court in Atlantic County.

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• MDL No. 2641 (Bard IVC Products Liab. Actions). Appointed

Special Master by Judge Campbell, U.S. District Court for District 

of Arizona, to handle settlement issues.

• Fitzgerald v. Gann Law Books, Inc., CA:11-cv-04287. 

Appointed mediator by New Jersey District Court Judge CoxArleo in 2013 to mediate and resolve TCPA class action case.

Matter successfully settled and concluded.

• Ephedra bankruptcy. Appointed Special Master by Judge 

Wolin, U.S. District Court of New Jersey.

• GAF G1 §524(g) Bankruptcy Trust Trustee. Appointed by 

Judge Gambardella, U.S. Bankruptcy Judge, District of New 

Jersey, to serve as one of several court appointed trustees with 

responsibility for ongoing asbestos claims resolution trust, I 

oversee the work of Verus LLC who is that 524(g) trust’s thirdparty claims administrator.

B. State Court Appointments

• New Jersey Department of Environmental Protection v. 

Occidental, et al. I was commissioned by presiding Judge 

Goldman to assist the parties’ effort to voluntarily resolve a 

massive environmental injury case involving chemical pollution of 

the Passaic River by Diamond Shamrock Chemicals Co. and 

others. My efforts helped foster a $355.4 million settlement 

agreement which was approved by the court in late 2014.

• Mirena IUD Products Liability Litig. Bergen County MCL 

Case 297. I was appointed Settlement Master by Judge Harz to 

adjudicate claimant appeals in the case’s private mass tort 

settlement program.

• In Re Corey Lidle Litigation. On October 11, 2006 a small 

private airplane owned by the famed former Yankee pitcher Cory 

Lidle crashed into upper floors of a skyscraper located along the 

East River, killing Mr. Lidle along with a flight instructor in the 

plane with him. Numerous other people in the building were also

injured. Among the issues in the ensuing litigation was who was 

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actually piloting the plane at the time of the crash. I was jointly

appointed by the courts in New York, New Jersey and California 

to mediate multiple, multi-million dollar lawsuits pending before 

the several courts following the crash. The cases all resolved with 

settlements.

• Jersey City water pipes-asbestos litigation. Appointed by 

New Jersey Superior Court to work with New Jersey Department 

of Environmental Protection and other parties to reach settlement 

of the matter. Case resolved in settlement.

• Hurricane Sandy Claims. Appointed by presiding New Jersey 

Superior Courts to mediate disputed insurance coverage and 

payment claims broght following the massive property damage 

within New Jersey caused by Superstorm Sandy.

Rule 53 and 28 USC §455 Certifications

19. Pursuant to Fed R. Civ. P. 53(a)(2), I certify that I do not 

have a relationship to the parties, attorneys, action, or court in this 

matter that would require disqualification of a judge under 28 U.S.C. 

§ 455.

20. Pursuant to 28 U.S.C. § 455(a), I certify that my impartiality 

cannot be and has not been reasonably questioned in this matter.

21. Pursuant to 28 U.S.C. § 455(b)(1), I certify that I have no 

personal bias or prejudice concerning a party or counsel in this matter, 

nor do I have any personal knowledge of disputed evidentiary facts 

concerning these proceedings.

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22. Pursuant to 28 U.S.C. § 455(b)(2), I certify that I have not 

served as a lawyer in the matter in controversy or the Underlying 

Lawsuits at issue in Williams. Nor has a lawyer with whom I previously 

practiced law served during such association as a lawyer concerning 

this matter or in the Underlying Lawsuits at issue in Williams. Neither 

I nor any such lawyer have been a material witness concerning this 

matter or in the Underlying Lawsuits at issue in Williams.

23. Pursuant to 28 U.S.C. § 455(b)(3), I certify that, although I 

served in governmental employment -- as a Judge of the Supreme Court 

of New Jersey -- I never participated as counsel, adviser or material 

witness concerning this proceeding nor have I expressed an opinion

concerning the merits of this particular case.

24. Pursuant to 28 U.S.C. § 455(b)(4) and (5), I certify that I 

individually or as a fiduciary, do not have a financial interest in the 

subject matter in controversy or in a party to this proceeding, or any 

other interest that could be substantially affected by the outcome of this 

proceeding. I do not have a spouse or children. 

25. Pursuant to 28 U.S.C. § 455(b) (5), I certify that I do not 

have a spouse and that neither I or any person within the third degree 

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of relationship to me (i) is a party to this proceeding, or an officer, 

director, or trustee of a party; (ii) is acting as a lawyer in this 

proceeding; (iii) is known by me to have an interest that could be 

substantially affected by the outcome of this proceeding; or (iv) is to my 

knowledge likely to be a material witness in this proceeding.

Compensation

26. The parties and I have tentatively agreed upon, and subject 

to the Court’s approval, a fee and terms of compensation for my services 

as Settlement Master and Trustee, which will be paid from the Cost 

Fund to the extent there are available funds and otherwise from the 

Settlement Fund. The amount agreed upon is an annualized fee of 

$125,000 payable in equal monthly installments on the last day of each 

calendar month, with the fee prorated as to any period in which I cease 

or no longer are required to serve. I will also receive reimbursement for 

any travel, necessary out-of-pocket, secretarial or clerical costs and 

expenses I incur in performing my work, which will be invoiced without 

any mark-up and shall be paid on a monthly basis along with payment 

of my fee.

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27. Where my time for services rendered in this matter under 

the POD or Order of Court are not to be paid from the Cost Fund but , 

rather, are to be paid or taxed against a claimant or other person, my 

hourly fee is $600 per hour.

I certify under penalty of perjury that the foregoing is true and 

correct.

Dated: April 17, 2020

_____________________________

Marina Corodemus

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