Exhibit O

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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 KIMBERLEE WILLIAMS IN SUPPORT OF MOTION 

FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT

I, Kimberlee Williams, pursuant to 28 USCS § 1746, declare as follows: 

1. My name is Kimberlee Williams. I am over twenty-one years of age and am fully 

competent to make the statements contained in this declaration.

2. I am one of the named plaintiffs in the above-captioned proposed class action (the 

"Action"). I submit this declaration in support of the Motion for Preliminary Approval of the 

Settlement Agreement reached in the Action and the application for conditional certification of a 

settlement class and preliminary approval of the proposed Plan of Distribution in connection with 

implementing the Settlement.

3. I was married to the late Charles L. Williams, who died on September 7, 1998. I am 

also the personal representative of his estate. 

4. I am, and have been, represented in the Action principally by the attorneys with the 

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law firm of Cohen, Placitella & Roth PC (“CPR”), who, along with another law firm was

associated with them over the course of the Action, have diligently prosecuted the Action.

5. I have been actively involved in all phases of this Action against the Defendants, 

including my review of and providing information and documents for court filings, my review of 

and providing information and documents for discovery, and my preparation for and attendance at 

my deposition. In particular, I have responded to five sets of interrogatories, five sets of requests 

for documents, and two sets of requests for admissions. I was deposed in the Action by the 

Defendants on April 4, 2018. My attorneys at CPR have kept me fully informed of the various 

activities that have occurred in the Action through in person meetings, correspondence, phone calls 

and copies of pleadings and orders. CPR has sought my input on many occasions, including my 

assent to the proposed settlement. I believe that I am fully up to date on the status of the case and 

have no questions that have not been answered.

6. The Settlement Agreement, Plan of Distribution and related settlement papers have 

been reviewed and explained to me by my attorneys and I believe I understand the proposed 

settlement and how it will be distributed among Class members. 

7. I believe that the proposed settlement is fair, reasonable and adequate, and should be 

approved by the Court.

8. I understand my duties as a class representative and will continue to act in the best 

interests of the Class and to actively participate in this case. 

9. I have no claim or interest that is adverse to other Class members.

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10. I am aware that the Settlement Agreement contains a provision for a request to be 

made to the Court to award a class representative service fee to me as well as the other class 

representatives. Throughout this case, I have not received nor been promised any form of

compensation, directly or indirectly, for prosecuting, serving as a representative party in, or settling

this class action in which I am a named plaintiff. My acceptance and support of the Settlement is 

not in any way conditioned upon my receipt of an award for serving as a representative of the 

Class.

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed this 3rd day of January 2020.

 

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