Case Doc 4599 Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Main Document Page 1 of 12

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1 Document Page 1 of 12 IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division IN RE: GARLOCK SEALING TECHNOLOGIES LLC, et al., Debtors. 1 Case No. 10-BK Chapter 11 Jointly Administered MOTION FOR LEAVE TO SERVE SUBPOENA ON MANVILLE TRUST Debtors through this motion (the Motion ) seek leave to serve a subpoena on the Manville Trust to obtain limited, non-privileged data about persons asserting non-mesothelioma claims against Garlock. The Court already approved discovery of similar kinds of information in connection with its estimation of mesothelioma claims, and the data are plainly relevant to estimation of Garlock s non-mesothelioma asbestos liabilities as well as the feasibility of Debtors Second Amended Plan of Reorganization (the Plan ). Moreover, the subpoena will pose no undue burden on the Manville Trust, which maintains the data in an easily accessible electronic form and as a matter of published practice makes the data available to asbestos defendants without objection upon payment of its expenses. Background 1. On January 14, 2014, the Court entered its order estimating Garlock s liability for mesothelioma claims. 504 B.R. 71 (Bankr. W.D.N.C. 2014) (the Estimation Opinion ). Prior to the mesothelioma estimation trial, Debtors obtained a significant amount of discovery 1 The debtors in these jointly administered cases are Garlock Sealing Technologies LLC; Garrison Litigation Management Group, Ltd.; and The Anchor Packing Company (hereinafter Garlock or Debtors )

2 Document Page 2 of 12 concerning both pending and settled mesothelioma claims against Garlock. The data formed the foundation of the estimate that the Court ultimately adopted: Garlock s estimate was derived in large part from its Analytical Database. That database was constructed primarily from questionnaires ( PIQ s ) and two supplemental questionnaires sent to the current claimants law firms. The responses were far from complete, but as the ACC described, the response was robust. This was a sizeable discovery request (or social science survey) and produced a wealth of data. The data included: job histories, asbestos exposure information relating to Garlock s and third-parties products, claims and recoveries made in the tort system and claims made to Trusts. It was supplemented with data from certain Trusts and from some bankruptcy cases. The result was the most extensive database about asbestos claims and claimants that has been produced to date. It is the most current data available and is the only data that accurately reflects the pool of claims against Garlock. It represents a reasonable and representative sample of claims against Garlock. Using in large part Garlock s Analytical Database its expert, Dr. Charles Bates, calculated his estimate of its liability based on a number of factors.... Estimation Opinion at At the confirmation hearing scheduled to begin on June 20, 2016, Debtors expect the Court will be called upon to estimate the aggregate amount of allowed non-mesothelioma claims. See Estimation Opinion at 74 (noting that estimation of mesothelioma claims was necessary to consideration of Debtors plan or any competing plan). An estimate of the aggregate allowed amount of non-mesothelioma claims will be relevant both to the feasibility of the Plan and to whether the Plan pays non-mesothelioma claimants in full (a fact relevant to various confirmation tests). 3. Debtors intend to offer Dr. Charles Bates to render an estimate of the aggregate amount of allowed non-mesothelioma claims, using the same estimation method the Court already accepted with respect to mesothelioma claims. As before, the method will depend on non-mesothelioma claimants job histories, asbestos exposure information relating to Garlock s - 2 -

3 Document Page 3 of 12 and third-parties products, claims and recoveries made in the tort system and claims made to Trusts. Estimation Opinion at In addition, the Official Committee of Asbestos Personal Injury Claimants (the Committee ) has already objected to the feasibility of Debtors Plan. See Preliminary Confirmation Objections of the Official Committee of Asbestos Personal Injury Claimants to the Debtors Second Amended Plan of Reorganization 3 (Docket No. 4586). In response, Debtors experts will render opinions projecting the payments that will be made to claimants under the Plan, including under the Claims Resolution Procedures (the CRP ) that will govern the Settlement Option, in order to show that the Plan sets aside assets much more than sufficient to meet Debtors Plan obligations. Under the CRP, payments to non-mesothelioma claimants depend on disease, the strength of the diagnosis, the history of exposure to asbestos (including occupation and industry), and age, among other factors. See CRP Appendix I, II. 5. Because the previous estimation proceeding was limited to mesothelioma claims, see Estimation Opinion at 75, Debtors have not yet obtained any discovery pertaining to nonmesothelioma claims against Garlock. The information currently available in their claims database with respect to such claims is limited, generally consisting only of the claimant s name, law firm, jurisdiction, and alleged disease. Thousands of the records do not even indicate the claimant s alleged disease (which often was not specified in the complaint). 6. Accordingly, Debtors through this Motion seek data relevant to estimation of nonmesothelioma claims and Plan feasibility. The data requested are similar to data upon which the Court based its estimate of mesothelioma claims. 7. Specifically, Debtors seek leave to serve a subpoena, with exhibit substantially in the form of Exhibit A attached hereto, on the Manville Trust. The exhibit requests production of - 3 -

4 Document Page 4 of 12 the following data with respect to claimants in the Manville Trust database who match one of the approximately 91,000 individuals listed as having pending non-mesothelioma or unidentified disease claims in Debtors claims database (the Database Claimants ) and, after the bar date has passed on October 6, claimants in the Manville Trust database who match any additional nonmesothelioma claimants who have filed claims in this bankruptcy case (the Additional Bar Date Claimants ): Social Security number; Date of birth; Gender; Address and contact information; Date of death (if applicable); Whether death was asbestos-related (if applicable); Personal representative (if any); Law firm representing claimant; Status of Manville Trust claim (and any related database fields); Date Manville Trust claim was filed; Disease level, both as filed and as approved, and related database fields including diagnosis date, diagnosing doctor, diagnosing facility, claimant B-reader, medical audit, disease category, and PFT; Claim type (i.e., first injury claim or second injury claim); Manville settlement offer (and any related database fields); Database fields containing exposure information, including occupation, industry, dates of exposure, and related database fields in the exposure table; - 4 -

5 Document Page 5 of 12 Database fields containing information about tort suit, including jurisdiction and other such database fields; Smoking history; Nature of co-worker s exposure (if applicable); Copies of medical records, exposure affidavits, death certificates, and other nonprivileged documents maintained by the Trust and typically provided to co-defendants upon request. 8. The Manville Trust has a published practice of providing exactly this kind of information, as a matter of course, to requesting tort defendants with respect to any person who asserts a claim against such defendant. See Frequently Asked Questions Related to Third Party Discovery of Information and Documents Pursuant to the 2002 Manville Trust TDP (attached as Ex. B) ( Manville FAQ ). The Trust provides the information in response to a subpoena (even an out-of-state subpoena), without objection (though it will stay production pending resolution of a timely filed objection by an individual claimant). Id. at 2-3. Thus, in civil discovery outside of bankruptcy, Garlock would be able to subpoena this information from the Manville Trust for those claimants who have lodged claims against it (like the Database Claimants and Additional Bar Date Claimants here). 9. The requested data are indisputably relevant to estimation of non-mesothelioma claims and Plan feasibility. Most of these data are identical to information the Court ordered all pending mesothelioma claimants to provide in response to the original mesothelioma PIQ and that formed the foundation of the Analytical Database upon which the Court s mesothelioma estimate rests. See Order Authorizing the Debtors to Issue Questionnaire to Holders of Pending Mesothelioma Claims and Governing the Confidentiality of Information Provided in Responses - 5 -

6 Document Page 6 of 12 (Docket No. 1390) (requiring claimants to provide information including social security number, date of birth, gender, address and contact information, date of death, personal representative, status of Manville Trust claim, date Manville Trust claim was filed, disease level, occupation and industry, duration of exposure, and information about tort suit). 10. The limited additional data not requested in the original mesothelioma PIQ are, under the Manville Trust s published practice, provided upon request to asbestos defendants, see supra, and are similar to information collected through the PIQ (gender), were requested through the Supplemental Exposure Questionnaire issued to a sample of mesothelioma claimants (exposure affidavits, nature of co-worker s exposure), or were not relevant to mesothelioma estimation but are relevant to non-mesothelioma estimation and feasibility. For example, the PIQ did not collect information regarding smoking history because smoking is not generally regarded as an alternative cause of mesothelioma. But smoking is a well-recognized alternative cause of non-mesothelioma diseases such as lung cancer, making smoking history relevant to estimation of non-mesothelioma claims. Smoking history is also relevant to non-mesothelioma claimants eligibility for settlement payments under the CRP, and thus is relevant to feasibility. See CRP, Appendix I and II. 11. Similarly, the original PIQ did not request claimants medical records because the parties accepted claimants allegations of mesothelioma for purposes of the estimation trial. By contrast, it will be important to understand the nature of medical records supporting nonmesothelioma conditions, which are highly relevant to the strength of those claims. See Estimation Opinion at 83 (noting with respect to claims for lung cancer, asbestosis, and other diseases, [t]here were some abuses involving mass screenings of potential claimants and bogus diagnoses of the disease ). Moreover, the diagnoses are relevant to feasibility because the - 6 -

7 Document Page 7 of 12 eligibility of non-mesothelioma claimants for CRP offers depends on certain characteristics of their diagnoses. See, e.g., CRP, Appendix I and II (settlement offers to lung cancer and laryngeal claimants depend on, among other things, whether diagnosing doctor is board-certified, whether diagnosis is supported by underlying asbestosis or elevated amphibole lung tissue fiber burden, and whether such support is appropriately documented according to enumerated criteria). 12. Obtaining this information from the Manville Trust is a cost-effective alternative to a new PIQ for non-mesothelioma claimants. It will permit Debtors to resort to a single source, instead of collecting data from 91,000 individual claimants. It will also spare law firms and claimants the unnecessary burden of assembling information they have already submitted to the Manville Trust. Debtors will reimburse the Manville Trust for its reasonable costs in providing such information. 13. The data will be underinclusive, because Debtors do not expect that all persons who assert non-mesothelioma claims against them will have asserted Manville claims. But Debtors experts believe the Database Claimants and Additional Bar Date Claimants will provide a sufficient sample because it is widely acknowledged that most asbestos claimants assert claims against the Manville Trust, which is responsible for the liabilities of the most prominent former asbestos defendant. See, e.g., Estimation Opinion at 83 ( [T]he largest participant in the asbestos tort litigation system was Johns Manville Corporation.... Manville had by far the largest share of the United States asbestos market as a manufacturer of asbestos insulation along with other end-use asbestos products and asbestos materials used for manufacture by others. ); Mark A. Peterson (Expert for Committee), USG Corporation Projected Liabilities for Asbestos Personal Injury Claims (May 2006), Estimation Trial Exhibit GST-6575, at 30 ( Manville data are universally regarded as the most comprehensive data on asbestos claims filing and have been - 7 -

8 Document Page 8 of 12 used repeatedly by analysts in forecasting liabilities for other defendants.... Further, the Manville data are remarkably clean... ). 14. The subpoena will not impose an undue burden on the Manville Trust. The Manville Trust maintains the requested information in database form, and provides it routinely to co-defendants in asbestos litigation. See Manville FAQ, Ex. B at 3-4 (data are maintained in database form, and medical records, exposure affidavits, and other documents are imaged upon receipt and filed by POC number in a document management system ). 15. In addition, Debtors experts are familiar with the Manville Trust database and would be willing and able to give the Manville Trust any necessary assistance. Through 2002, the Manville Trust sold complete copies of its claims database to members of the public, including Bates White, for a $10,000 fee. Then, between 2002 and 2007, the Manville Trust routinely licensed complete copies of its claims database to members of the public (including Bates White) for $10,000. Bates White possesses a copy of the 2002 Manville database, is familiar with its structure and contents, and would be available to consult with the Manville Trust as needed. See Report of Jorge R. Gallardo-Garcia, PhD, Estimation Trial Exhibit GST at 33 (noting that Bates White possesses and uses a copy of 2002 Manville Trust database). 16. In Exhibit A, Debtors also propose a procedure for claimant objections similar to the procedure followed after the Court granted Debtors motion for leave to serve a subpoena on the Delaware Claims Processing Facility and its ten constituent Trusts. 2 That subpoena sought information pertaining to the 11,000 mesothelioma claimants who settled with Debtors between 1999 and The DCPF Trusts matched the 11,000 mesothelioma claimants to their 2 See Order Granting in Part and Overruling in Part Objections to Subpoena by Delaware Claims Processing Facility, LLC and Associated Trusts, Establishing Claimant Objection Procedures, and Governing the Confidentiality of Information Provided in Response to the Subpoena (Docket No. 2430) ( Order Enforcing Trust Subpoena )

9 Document Page 9 of 12 databases; provided electronic notice to each claimant s lawyer; and provided a list of the law firms to Debtors, who then served notice of a hearing seventeen days later to consider any claimants objections to release of the data. See id. Only four objections were filed, and the Court overruled them in a short order. See Order Overruling Objections By Individual Claimants to Subpoena of Information from Delaware Claims Processing Facility, LLC and Associated Trusts (Docket No. 2466). 17. To permit a similar objection process here, the proposed subpoena requests that the Manville Trust first produce, within fourteen (14) days after service, the names and addresses of law firms representing Database Claimants. Debtors will serve these law firms (as well as any other asbestos plaintiff firms that Debtors know about) with notice of a hearing on the next available Garlock hearing date to consider any claimant objections to production of their data. After the hearing, the Manville Trust will produce the requested data for any Database Claimants who do not object or whose objections are overruled, and after the bar date, will produce the requested data for any Additional Bar Date Claimants. 18. Finally, in conformity with the Court s Order on Motions to Seal Materials in Record of Estimation Proceeding and Protocol for Redaction of Record (Docket No. 4195), Debtors will move for entry of a protective order prohibiting Debtors from disclosing and requiring Debtors to redact the following information received in the Manville Trust production before making any of the produced data public, including at trial: a. Social Security numbers (except last four digits); b. Dates of birth (except year); c. Names of identifiable minors (except for their initials); d. Financial account numbers (except last four digits); and - 9 -

10 Document Page 10 of 12 e. Medical information (except claimed disease, such as mesothelioma, asbestosis, or lung cancer ). Jurisdiction 19. The Court has subject matter jurisdiction to consider this matter pursuant to 28 U.S.C. 157 and This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). Venue is proper before this Court pursuant to 28 U.S.C and Relief Requested 20. Debtors seek leave to file the subpoena described above, with exhibit substantially in the form of Exhibit A, on the Manville Trust. 21. Because the confirmation hearing is a contested matter, it is proper for parties to subpoena relevant evidence from third parties pursuant to Rule See Fed. R. Bankr. P ( Rule 45 F.R. Civ. P. applies in cases under the Code ); In re Symington, 209 B.R. 678, (Bankr. D. Md. 1997); In re Sunridge Assocs., 202 B.R. 761, 762 (Bankr. E.D. Cal. 1996) ( [P]roduction of documents in connection with an adversary proceeding or a contested matter can be compelled under Rule 7034 as to a party or Rule 9016 as to a non-party ). 22. The information requested is indisputably relevant to estimation of nonmesothelioma claims and the feasibility of Debtors Plan. The scope of discovery is construed liberally.... Discovery requests are undoubtedly proper when they lead to relevant or potentially relevant information that will advance the litigation by clarifying a party s contentions and apprising a party of what it must seek to disprove. Belmont Textile Mach. Co. v. Superba, S.A., 48 F. Supp. 2d 521, 524 (W.D.N.C. 1999). The scope of relevance is equally broad when evidence is proposed to be subpoenaed from third parties. See Dexia Credit Local v. Rogan, 231 F.R.D. 538, 541 n.2 (N.D. Ill. 2004) ( Rule 45 draws no distinction between parties and non

11 Document Page 11 of 12 parties concerning the scope of discovery ); Bridges v. Murray, 2009 U.S. Dist. LEXIS at *6 (W.D.N.C. 2009). 23. The information sought through this Motion easily meets these standards. The Court previously approved discovery of virtually the same information for purposes of the mesothelioma estimation trial. Those data were not only relevant in the discovery sense, they were material to the Court s decision. The Court adopted the estimate based on the data collected, and furthermore, criticized claimants experts for not considering it. See Estimation Opinion at During discovery for the mesothelioma estimation trial, the Court also recognized the propriety of reasonable data requests from Trusts. See Order Enforcing Trust Subpoena. Like Debtors earlier request authorized by the Court, the proposed subpoena is narrowly tailored and will not cause any undue burden. It seeks only information that the Manville Trust maintains in database form and discloses as a matter of published practice to asbestos defendants without objection pursuant to subpoena. See Manville FAQ, Ex. B. And as described above, Debtors will provide a reasonable time for compliance and will reimburse the Trust s reasonable expenses. Moreover, the proposed subpoena process provides an opportunity for claimant objections and will protect from public view the information the Court has decided should be kept confidential in this context, and Debtors will make experts familiar with the Manville database available to the Trust if necessary to facilitate the efficient production of information. 25. Debtors provided notice of this request to the Committee and FCR. The FCR does not object. Debtors met and conferred with counsel for the Committee concerning the request, and counsel later informed Debtors that the Committee does not anticipate objecting. Debtors also expect to confer with counsel for the Manville Trust after service of the subpoena

12 Document Page 12 of 12 CONCLUSION For the foregoing reasons, Debtors respectfully request that the Court grant Debtors leave to serve the attached subpoena. This 8th day of May, Respectfully submitted, /s/ Garland S. Cassada Garland S. Cassada N.C. Bar No Jonathan C. Krisko N.C. Bar No Richard C. Worf, Jr. N.C. Bar No ROBINSON BRADSHAW & HINSON, P.A. 101 North Tryon Street, Suite 1900 Charlotte, North Carolina Telephone: (704) Facsimile: (704) Special Corporate and Litigation Counsel to the Debtors Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company

13 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. A Page 1 of 3 EXHIBIT A DEFINITIONS AND INSTRUCTIONS 1. You, Your, and Manville Trust shall mean the Manville Personal Injury Settlement Trust. 2. Debtors shall mean Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd., and The Anchor Packing Company. 3. Database Claimant shall mean each individual in the Manville Trust database who matches the first and last name of a claimant listed in the attached Exhibit 1, which contains a list of claimants who, according to Debtors claims database, asserted a claim against Garlock that is still open and is based on a non-mesothelioma condition or unidentified condition. 4. Additional Bar Date Claimant shall mean each individual in the Manville Trust database who matches the first name, last name, and social security number of any claimant who files a proof of claim in In re Garlock Sealing Technologies LLC, No (Bankr. W.D.N.C.) for a Current GST Asbestos Claim based on a non-mesothelioma or unidentified condition on or before the bar date for such claims on October 6, Document refers to all items subject to discovery under Federal Rule of Civil Procedure 34, including, but not limited to, any written or recorded material of any kind, including the originals and all non-identical copies, whether different from the originals by reason of any notation made on such copies or otherwise; notations of any sort of conversations, telephone calls, meetings, or other communications; all graphic or oral records or representations of any kind; and mechanical, electronic, or computer-stored records or representations of any kind, including writings, drawings, graphs, charts, photographs, video and audio tapes, cassettes, diskettes, records, CDs, , computer hard drives, software, or other data compilations from which information can be obtained through detection devices and translated into reasonably usable form. 6. Scope. These requests encompass all information and Documents in Your custody, possession, or control, whether or not such information was prepared by or for You. Information and Documents within Your custody, possession, or control include information and Documents that You have a legal right to obtain, regardless of their source or present location. 7. Form of Production. Responses to Requests 1 and 2(a) through 2(q) shall be produced in Excel format (or such other electronic format as may be agreed upon by Debtors counsel and You) and Responses to Request 2(r) shall be produced in searchable PDF format (or such other electronic format as may be agreed upon by Debtors counsel and You). 8. Time for Production. The Documents in Request 1 shall be produced by [14 days after service of subpoena]. Debtors will serve the identified law firms with notice of a hearing on the next available hearing date in In re Garlock Sealing Technologies LLC, No (Bankr. W.D.N.C.) to consider any claimant objections to production of their data. The Documents in Request 2 pertaining to Database Claimants shall be produced within thirty days after such - 1 -

14 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. A Page 2 of 3 hearing date. The Documents in Request 2 pertaining to Additional Bar Date Claimants shall be produced within thirty days after Debtors provide a list of claimants who file proofs of claim in In re Garlock Sealing Technologies LLC, No (Bankr. W.D.N.C.) for a Current GST Asbestos Claim based on a non-mesothelioma or unidentified condition on or before the bar date for such claims on October 6, Privilege or Immunity from Production. To the extent that any Documents are not produced on the basis of a claim of privilege or immunity: (a) submit a list identifying each such Document; (b) identify the nature of the privilege (including work product) which is being claimed; and (c) identify each person having knowledge of the factual basis, if any, on which the claim of privilege or immunity is based. For these purposes, identify shall mean in the case of a Document, to state the Document s date, its author, its recipient or the person for whom it was prepared, its present location or custodian, a summary of its contents, and any other information necessary to render the Document distinguishable from all others and subject to ready location. 10. Destroyed Materials. If any Documents requested herein were at one time in Your possession, custody, or control, but have since been lost, discarded, or destroyed, the Documents so lost, discarded, or destroyed shall be identified as completely as possible, including, without limitation, the following data: date of disposal, manner of disposal, reason for disposal, person authorizing the disposal, and the person disposing of the Document. 11. Incomplete Information. If You contend that no information or Documents exist relating to all or part of a request, state this contention and respond as fully as possible to the portions of the request for which information or Documents exist. Additionally, if any of the requested information cannot be produced in full, it shall be produced to the maximum extent possible, and You shall specify the reasons for the inability to produce the remainder. 12. Grammatical Points. All singular nouns shall include the plural, all plural nouns the singular, all present-tense verbs the past tense, all male genders the neuter and female genders, and vice versa. Additionally, the connectives and and or shall be construed either disjunctively or conjunctively as necessary to bring within the scope of the Document request all responses that might otherwise be construed to be outside of its scope. Similarly, the terms any, all, and each shall be construed to bring within the scope of the Document request all responses that might otherwise be construed to be outside of its scope. 13. Objections. If any Document request, definition, or instruction is objected to in whole or in part, specify all grounds on which the objection rests. Respond to all portions of each such request to which no objection is asserted. In addition, state whether any responsive information has been omitted from a response or whether, and in what way, the search for responsive information has been delimited or circumscribed on the basis of any such objection. 14. Ambiguities. If in answering any Document request You encounter any ambiguity in construing either the request or a definition or instruction relevant to that request, set forth the matter deemed ambiguous and the construction selected or used in answering the request

15 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. A Page 3 of Protective Order. Debtors will move for entry of a protective order prohibiting Debtors from disclosing and requiring Debtors to redact the following information received in the Manville Trust production before making any of the produced data public, including at trial: a. Social Security numbers (except last four digits); b. Dates of birth (except year); c. Names of identifiable minors (except for their initials); d. Financial account numbers (except last four digits); and e. Medical information (except claimed disease, such as mesothelioma, asbestosis, or lung cancer ). DOCUMENT REQUEST 1. The names and mailing addresses of all law firms representing any Database Claimant. 2. For each Database Claimant and Additional Bar Date Claimant: a. Social Security number; b. Date of birth; c. Gender; d. Address and contact information; e. Date of death (if applicable); f. Whether death was asbestos-related (if applicable); g. Personal representative (if any); h. Law firm representing claimant; i. Status of Manville Trust claim (and any related database fields); j. Date Manville Trust claim was filed; k. Disease level, both as filed and as approved, and related database fields including diagnosis date, diagnosing doctor, diagnosing facility, claimant B-reader, medical audit, disease category, and PFT; l. Claim type (i.e., first injury claim or second injury claim); m. Manville Trust settlement offer (and any related database fields); n. Database fields containing exposure information, including occupation, industry, dates of exposure, and related database fields in the exposure table; o. Database fields containing information about tort suit, including jurisdiction and other such database fields; p. Smoking history; q. Nature of co-worker s exposure (if applicable); r. Copies of medical records, exposure affidavits, death certificates, and other nonprivileged documents maintained by the Trust and typically provided to codefendants upon request

16 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. B Page 1 of 7 EXHIBIT B

17 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. B Page 2 of 7 Frequently Asked Questions related to Third Party Discovery of Information and Documents Pursuant to the 2002 Manville Trust TDP CRMC releases information as directed by the 2002 Manville Trust Distribution Process ( TDP ), Section I.1, which governs litigation between Trust Beneficiaries (asbestos Co-Defendants, like claimants, are included as Beneficiaries of the Manville Trust). The information and documents released are to be used solely as provided by applicable law in the jurisdiction in which their production has been sought. The relevant provisions of the 2002 Manville TDP Section I are as follows: I. All Trust Beneficiaries Treated Alike. In order to conserve the assets of the Trust, except as set forth below, Trust Beneficiaries both plaintiffs and defendants will dismiss, without prejudice, all present cases, are enjoined from filing future litigation against Manville or the Trust, and are required to pursue their claims against the Trust only as provided in this TDP. Except as provided in Section F above and subsection 1(c) below, the Trust will make no appearance in any court, and no Trust Beneficiary will be permitted to proceed in any manner against the Trust or Manville in any state or federal court. 1. Litigation between Trust Beneficiaries. (b) Right to introduce evidence. In any litigation between Trust Beneficiaries, all Beneficiaries shall retain their respective rights provided by applicable law to introduce evidence at trial in state or federal court. (e) Discovery and informational issues. The Trust shall comply with the rules of discovery pertaining to non-parties under applicable law. (f) Verification of settlement information. In response to a Co- Defendant request, the Trust and the claimant shall promptly verify, no later than the start of jury selection in the trial of an action by the claimant against the Co- Defendant, the fact of any settlement or any filing by the claimant of a claim with the Trust; and shall provide information regarding the amount and terms of any such settlement at the time and with the detail required by applicable law. 1. Under what circumstances does CRMC disclose claim information? A. Informal inquiry Pursuant to section I.1(f) of the Manville TDP, the Trust will respond to communications requesting the status of claims if the requesting party confirms that it is a Co-Defendant in current and active asbestos-related litigation

18 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. B Page 3 of 7 with the claimant. The Trust will state whether or not a claim has been filed and whether or not a claims has been settled, but will not provide the settlement amount. B. Requests for records Subpoenas The Manville Trust and CRMC generally accept out-of-state subpoenas for Manville claim records that meet certain conditions: i. The subpoena complies with the procedural requirements of the jurisdiction from which it is issued. ii. The requesting party is a Co-Defendant in current and active asbestos-related litigation. iii. The subpoena is accompanied by a cover letter or some other communication that identifies the name of the attorney or law firm that is representing the claimant in the litigation. Written consent of the claimant The Manville Trust will honor any written consent 1 to release claim records that meets the following conditions: i. The document authorizes the Trust to release claim records ii. The document is signed either by the claimant, the claimant s attorney 2 or the claimant s personal representative (the person administering the claimant s estate). If signed by the personal representative, we will also require a copy of the court order or other document establishing that the signatory represent the claimant s estate. Court order CRMC responds as specifically directed by court order. 2. When does CRMC respond to these requests? A. Informal inquiry CRMC aims to respond to all informal inquiries within 24 hours. If you have not received a response within that time, feel free to follow-up. B. Requests for records Subpoenas CRMC promptly notifies claimant s counsel of record (and, if known, the attorney representing the claimant in litigation) of receipt of a subpoena, then will wait out the plaintiff s objection deadline before responding to a subpoena. When the subpoena does not specify an objection 1 There is a written consent template on CRMC s website under Manville Document TAB A 2 Must be the attorney of record for the Manville claim

19 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. B Page 4 of 7 deadline, CRMC presumes a two-week objection period following the issuance date. If counsel for the plaintiff communicates an intent to file a motion to quash the subpoena, CRMC will stay production for an additional two weeks. If a motion is filed within that time, CRMC will stay production until the matter is resolved. If a motion is not timely filed, CRMC will produce the records. Authorizations and court orders CRMC will respond to requests by written consent of the claimant and court orders as soon as possible. 3. What information does CRMC release? Most Manville Trust claims are electronically filed by law firms using CRMC s e- Claims TM processing system. In response to a series of questions or prompts that appear on the e-claims TM screens, trained and certified law firm representatives enter information about a claim. A minority of claims are filed using a paper proof of claim (POC) form, upon receipt of which a CRMC employee enters the information into the e-claims TM system. In response to Third Party discovery requests, CRMC releases information maintained in the e-claims TM system as described below, and documentation and information submitted by the claimant. CRMC does not release correspondence that relates to claim evaluation and negotiation by and between CRMC and claimant/counsel. CRMC also does not release CRMC internal evaluation and operational processing information. Unless a claim is selected for Quality Control (QC) or other audit review, only limited medical and exposure evidence must be submitted to CRMC for claims that are resolved through the categorization process (as most claims are). Relatively few claimants request Individual Evaluation or Arbitration. The letters highlighted below are listed on the e-claims TM screen printouts under the heading Action/View. CRMC provides printouts of the Claimant Information (Injured Party) screen, as well as screens E and I, but does not provide printouts of the remaining screens, all of which relate to internal CRMC claim evaluation processes and negotiation. The following information is captured on these screens: Claimant Information (Injured Party) Claimant Name, Social Security Number (or International ID number if the claim is foreign), date of birth, gender, address and contact information; date of death; whether death was asbestos related and personal representative (if any); and Claim Status, including Claimant and POC numbers, name of trust against which the claim is filed, date filed, disease level, claim type (FIC = first injury claim; SIC = second injury claim); and value. Claim Status descriptions are at Documents tab S, e-claims Status Descriptions

20 Case Doc Filed 05/08/15 Entered 05/08/15 15:48:18 Desc Ex. B Page 5 of 7 E = The Claim screen includes some of the same claimant identification information as the Claimant Information screen and adds the following: Law Firm information, litigation information, smoking information, and exposure information (the occupation and industry codes are at Documents, Tabs O and I ). If claimant is seeking compensation at a disease level for which evidence of SOE is required, and if claimant was exposed by working in close proximity to a co-worker who was directly working with asbestos, the nature of their co-worker s exposure will be indicated by vicinity occupation (Vic Occ), the occupation of the worker through whom they were exposed, and vicinity type (Vic Type), the coworker s exposure type. I = Claim Detail. This is a summary of the key information that affects the processing and payment of a claim. In addition to the Claimant Information and E and I screenshots from the e-claims TM processing system, CRMC provides copies of the medical records, exposure affidavits, death certificates and similar documents submitted in support of the claim. These documents are imaged upon receipt and filed by POC number in a document management system. Except in the case of claims that are audited or claims that are filed in paper form, CRMC does not routinely receive medical documents in support of mesothelioma claims. For claims filed on paper, CRMC will provide copies of the POC form and supporting submissions. Unless specifically ordered by a court, CRMC will not provide correspondence that relates to claim evaluation and negotiation by and between CRMC and claimant/counsel. CRMC does not provide copies of settlement checks, electronic fund transfer (EFT) reports, or releases. In most cases, law firms maintain the releases pursuant to a law firm affidavit/agreement. In all instances, copies of materials sent to Co-Defendants also are sent to claimants counsel. 4. For more information Additional information concerning CRMC and claims against the Manville Trust, including the 2002 Manville TDP, sample claim forms and releases, SOE Occupation and Industry charts, and the CRMC s Asbestos Claims Research Facility in Denver, is available on the CRMC website, See the Documents tab and click on Manville Trust. You also may contact Jared Garelick, CRMC s General Counsel: (703) or Alek Pivec, Paralegal: (703)

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