Chapter 11 ) HONX, INC.,1 - Stretto

IN THE UNITED STATES BANKRUPTCY COURTFOR THE SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

)In re: ) Chapter 11

)HONX, INC.,1 ) Case No. 22-90035 (MI)

)Debtor. )

)

DEBTOR’S APPLICATION FOR ENTRYOF AN ORDER (A) AUTHORIZING RETENTION

AND EMPLOYMENT OF BATES WHITE, LLC AS ASBESTOS CONSULTANTS EFFECTIVE AS OF THE PETITION DATE AND (B) GRANTING RELATED RELIEF

This application seeks an order that may adversely affect you. If you oppose the application, you should immediately contact the moving party to resolve the dispute. If you and the moving party cannot agree, you must file a response and send a copy to the moving party. You must file and serve your response within 21 days of the date this was served on you. Your response must state why the application should not be granted. If you do not file a timely response, the relief may be granted without further notice to you. If you oppose the application and have not reached an agreement, you must attend the hearing. Unless the parties agree otherwise, the court may consider evidence at the hearing and may decide the application at the hearing.

Represented parties should act through their attorney.

The above-captioned debtor and debtor in possession (the “Debtor”) states as follows in

support of this application:

Relief Requested

1. The Debtor seeks entry of an order, substantially in the form attached hereto

(the “Order”): (a) authorizing the Debtor to retain and employ Bates White, LLC (“Bates White”)

as asbestos consultants in the Debtor’s chapter 11 case effective as of the Petition Date (as defined

below); and (b) granting related relief.

1 The Debtor in this chapter 11 case, along with the last four digits of the Debtor’s federal tax identification number, is HONX, Inc. (2163). The location of the Debtor’s service address in this chapter 11 case is: 1501 McKinney Street, Houston, Texas, 77010.

Case 22-90035 Document 100 Filed in TXSB on 05/16/22 of 12

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Jurisdiction and Venue

2. The United States Bankruptcy Court for the Southern District of Texas

(the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This is a core

proceeding pursuant to 28 U.S.C. § 157(b). The Debtor confirms its consent to the entry of a final

order by the Court.

3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

4. The bases for the relief requested herein are sections 327, 1107(a) and 1108 of title

11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), rule(s) 2014(a)

and 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and rule 9013-1

of the Bankruptcy Local Rules for the Southern District of Texas (the “Bankruptcy Local Rules”).

Background

5. The Debtor is a wholly owned subsidiary of Hess Corporation (“Hess”), a global

energy company, and the corporate successor of Hess Oil Virgin Islands Corporation (“HOVIC”).

The Debtor constructed, owned, and operated an oil refinery in St. Croix, U.S. Virgin Islands

(the “Refinery”) from the beginning of its creation in 1965 until 1998. In 1998, the Debtor entered

a joint venture with the national oil company of Venezuela, Petróleos de Venezuela, S.A., in which

each held 50% ownership in a company called HOVENSA L.L.C. (“HOVENSA”). HOVENSA

acquired the Refinery through the joint venture transaction and operated the Refinery from

October 1998 until February 2012. From February 2012 through March 2015, HOVENSA

operated the Refinery as an oil storage and distribution center until the Refinery was ultimately

shut down. The Debtor is a non-operating entity without any employees whose primary activity

is defending against asbestos and other litigation related to its prior ownership and operation of

the Refinery.


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6. The first asbestos claim was filed in 1987 against HOVIC and, since that time, more

than 1,500 plaintiffs have filed suit against HOVIC, Hess, and/or the Debtor as HOVIC’s successor

in interest. The Debtor is currently facing approximately 580 asbestos and toxic tort claims in the

Superior Court of the Virgin Islands, and could face an additional 500, or more, claims in the next

several years based on discussions with current plaintiffs’ counsel. The Debtor anticipates that,

absent the filing of this chapter 11 case, litigation of asbestos-related claims could consume an

enormous amount of its and Hess’s time and resources for decades to come.

7. On April 28, 2022 (the “Petition Date”), the Debtor filed a voluntary petition for

relief under chapter 11 of the Bankruptcy Code. A detailed description of the facts and

circumstances giving rise to the Debtor’s chapter 11 case is set forth in the Declaration of Todd R.

Snyder, Chief Administrative Officer of HONX, Inc., in Support of Chapter 11 Petition and First

Day Motions (the “First Day Declaration”).2 The Debtor is operating its business and managing

its properties as a debtor in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy

Code. No request for the appointment of a trustee or examiner has been made in this chapter 11

case. On May 13, 2022, the United States Trustee for the Southern District of Texas (the “U.S.

Trustee”) appointed an official committee of unsecured creditors pursuant to section 1102 of the

Bankruptcy Code (the “Committee”) [Docket No. 91].

Basis for Relief

8. The Debtor requests entry of the Order (a) authorizing the Debtor to retain and

employ Bates White as asbestos consultants in this chapter 11 case to provide expert and consulting

services relating to the evaluation and estimation of the Debtor’s asbestos liability and any other

2 Capitalized terms used but not otherwise defined in this application shall have the meaning ascribed to them in the First Day Declaration or the Engagement Letter, as applicable.


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potential contingent liabilities, effective as of the Petition Date, in accordance with the terms of

the engagement letter between Bates White and Kirkland & Ellis LLP (“Kirkland”) (on behalf of

the Debtor HONX, Inc., then known as HONYC), effective as of April 15, 2022, a copy of which

is attached hereto as Exhibit 1 to the Order and incorporated herein by reference

(the “Engagement Letter”).3

9. In support of this Application, the Debtor submits the Declaration of Andrew R.

Evans CFA in Support of Debtor’s Application for Entry of an Order (A) Authorizing Retention

and Employment of Bates White, LLC as Asbestos Consultants Effective as of the Petition Date

and (B) Granting Related Relief (the “Evans Declaration”), a copy of which is attached hereto as

Exhibit A and incorporated by reference herein.

Bates White’s Qualifications

10. Bates White is an economic consulting firm that provides, among other things,

services relating to the economic analysis and estimation of mass tort claims. The Debtor has

selected Bates White to serve as its asbestos consultant in this chapter 11 case based on Bates

White’s considerable experience with, and knowledge regarding, asbestos claims and valuation.

In addition, this engagement is expected to be led by highly experienced experts.

11. As indicated in the Evans Declaration and in Mr. Evans’ resume attached thereto,

Mr. Evans is a CFA Charterholder and has more than nineteen years of experience in providing

expert testimony and guidance on asbestos claims in bankruptcy, litigation, and business matters.

Included among the matters in which Mr. Evans has provided, or is currently providing,

asbestos-related expert testimony or related services are the bankruptcy cases of In re Aldrich

3 Any references to or summaries of the Engagement Letter herein are qualified by the express terms of the Engagement Letter.


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Pump, In re Owens Corning, In re Paddock Enterprises, In re Specialty Products Holding Corp.,

and In re The Fairbanks Company.4 In addition, Mr. Evans has testified in numerous insurance

and reinsurance coverage disputes dealing with asbestos and other mass torts and has also provided

valuations in non-asbestos mass tort bankruptcies.

12. As indicated in Dr. Charles H. Mullin’s resume attached to the Evans Declaration,

Dr. Mullin has more than twenty years of experience in providing expert testimony and guidance

on litigation and business matters and has authored more than seventy‑five expert reports.

Included among the matters in which Dr. Mullin has provided, or is currently providing,

asbestos-related expert testimony or related services are the bankruptcy cases of In re DBMP LLC,

In re Leslie Controls Inc., In re Motors Liquidation Company, In re Owens Corning, In re Plant

Insulation Company, In re Specialty Products Holding Corp. (Bondex), and In re Thorpe

Insulation Company.5 In addition, Dr. Mullin has testified in numerous asbestos-related insurance

and reinsurance coverage disputes and has provided valuations in non-asbestos mass tort

bankruptcies.

Services to Be Provided

13. The Debtor anticipates that Bates White will render economic consulting, claims

valuation, and related services to the Debtor as needed in connection with asbestos and other toxic

4 In re Aldrich Pump LLC, Case No. 20-30608 (JCW) (Bankr. W.D.N.C. June 17, 2020); In re Owens Corning, Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re Paddock Enterprises, LLC, Case No. 20-10028 (LSS) (Bankr. D. Del. Jan. 6, 2020); In re Specialty Products Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del. May 31, 2010); In re The Fairbanks Company, Case No. 18-41768 (PWB) (Bankr. N.D. Ga. July 31, 2018).

5 In re DBMP LLC, Case No. 20-30080 (JCW) (Bankr. W.D.N.C. Jan. 23, 2020); In re Leslie Controls, Inc., Case No. 10-12199 (Bankr. D. Del. Jul. 12, 2010); In re Motors Liquidation Company, Case No. 09-50026 (REG) (Bankr. S.D.N.Y. June 1, 2009); In re Owens Corning, Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re Plant Insulation Company, Case No. 09-31347 (TEC) (Bankr. N.D. Cal. May 20, 2009); In re Specialty Products Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del. May 31, 2010); In re Thorpe Insulation Company, Case No. 07-19271 (SB) (Bankr. C.D. Cal. Oct. 15, 2007).


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personal injury and any other alleged lung impairment claims against the Debtor, and related

potential costs and liabilities. These services may include, but are not limited to:

(a) performing due diligence and analysis regarding the Debtor’s current, potential, and overall asbestos liability (both defense costs and indemnity), including with respect to historical and projected trends, econometric evaluations, market analysis, and evaluations using other established methodologies;

(b) estimating the number and value of, and producing analysis with respect to, present and future asbestos personal injury claims against the Debtor;

(c) assisting the Debtor in negotiations with various parties regarding the Debtor’s asbestos liability, including by evaluating proposals or potential proposals and providing analysis, information, and support in connection therewith;

(d) advising the Debtor regarding the funding of any asbestos trust that may be created pursuant to the Bankruptcy Code;

(e) advising the Debtor regarding financial issues that may impact the valuation of asbestos claims;

(f) providing expert testimony and reports related to the foregoing and assisting the Debtor in preparing and evaluating reports and testimony by other experts and consultants; and

(g) providing such other consulting services as may be requested by the Debtor.

14. The Debtor requires knowledgeable consultants to render these essential

professional services. As noted above, Bates White has substantial expertise in all of these areas.

Accordingly, the Debtor respectfully submits that Bates White is well qualified to perform these

services for the Debtor.

Compensation and Fee Applications

15. Bates White has indicated its willingness to serve as asbestos consultants and

experts for the Debtor and to receive compensation and reimbursement in accordance with its

standard billing practices, the provisions of the Engagement Letter, sections 330 and 331 of the


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Bankruptcy Code, the Compensation Guidelines, the Interim Compensation Order (as defined

below), and any applicable orders of this Court. The Engagement Letter specifies that the Bates

White retention is through Kirkland, as counsel to the Debtor; however, the Debtor is solely

responsible for the payment of fees for services rendered by Bates White, along with payment of

any related costs under the terms of the Engagement Letter. See Engagement Letter ¶¶ 4, 7.

16. Bates White has agreed to accept as compensation such sums as may be allowed by

the Court. Bates White understands that interim and final fee awards are subject to approval by

this Court.

17. Prior to the Petition Date, on or about April 27, 2022, the Debtor provided Bates

White with a retainer totaling $50,000.00 for services rendered or to be rendered, and for

reimbursement of expenses (the “Retainer”). Fees applied against the Retainer as of the Petition

Date totaled approximately $16,000, representing Bates White’s estimate of fees for April 1, 2022

through April 27, 2022 (just before the Petition Date). Thus, as of the Petition Date, and subject

to reconciliation, approximately $34,000 of the Retainer remained unapplied.6

18. The rates charged by Bates White are fair and reasonable. Bates White has

provided its hourly rates below for work in this case, as follows:

Billing Category RangePartner (Andrew R. Evans) $825

Partner (Dr. Charles Mullin) $1,150Partner $700 - $1,600

6 Bates White will (a) complete its reconciliation of prepetition fees and expenses actually incurred for the period up to the Petition Date no later than the filing of its first interim fee application in this chapter 11 case; (b) make a corresponding adjustment to the amount of the Retainer on or about that date; and (c) disclose such adjustment in its first interim fee application. Subject to the foregoing adjustment, Bates White requests authorization from the Court to hold any remaining amount of the Retainer following such reconciliation as security for the payment of postpetition fees and expenses, subject to the terms of any order establishing procedures for interim compensation and reimbursement of expenses of retained professionals (any such order, the “Interim Compensation Order”). Bates White will not apply any portion of the Retainer to fees and expenses incurred from and after the Petition Date unless and until authorized to do so by a further order of this Court, including the Interim Compensation Order.


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Billing Category RangePrincipal $575 - $750

Managing Economist $545 - $650Managing Consultant $500 - $625

Senior Economist $475 - $550Senior Consultant $450 - $500

Economist $460Consultant II $390 - $425Consultant $365

Research Analyst $365 - $460Project Coordinator $255Research Assistant $210

Bates White’s hourly billing rates are subject to periodic adjustments to reflect economic and other

conditions and promotions. Under the terms of the Engagement Letter, if the invoiced fees that

are not subject to any bankruptcy holdback are paid within 30 days of the date they are due under

the Interim Compensation Order or other applicable rules in this Chapter 11 Case, the Debtor will

receive a 5% prompt-pay discount for the entire invoiced amount. See Engagement Letter ¶ 9.

19. Bates White’s hourly billing rates are not intended to cover out-of-pocket expenses

and certain elements of other expenses that are typically billed separately. Accordingly, Bates

White regularly charges its clients for the expenses and disbursements incurred in connection with

the client’s case, including, among other things, postage and package delivery charges, court fees,

transcript costs, travel expenses, expenses for “working meals,” and research. Bates White has

agreed that it will only seek reimbursement of expenses in accordance with sections 330 and 331

of the Bankruptcy Code, Bankruptcy Rule 2016, the Compensation Guidelines, the Interim

Compensation Order, and any other applicable orders of this Court.

20. The Engagement Letter specifies that any dispute arising between Bates White and

Kirkland or the Debtor will be determined by binding arbitration in Washington, DC.

See Engagement Letter ¶¶ 13, 14. Notwithstanding this provision, Bates White has agreed that the


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Bankruptcy Court shall hear and adjudicate any such dispute during the pendency of this chapter

11 case.

21. The Engagement Letter contains the following provision:

The parties shall not be liable to one another for any claim, whether sounding in contract, tort, (including but not limited to malpractice), or otherwise, including a claim arising out of the breach, termination, enforcement, interpretation, or validity of this agreement, for indirect, special, consequential, or exemplary damages. Bates White shall not be liable for direct damages in excess of the lesser of two times the fees paid or $250,000 with respect to services performed under this letter, except to the extent of Bates White’s gross negligence, willful misconduct, or fraud.

Engagement Letter ¶ 15 (the “Limitation of Liability Provision”). Upon entry of the Order, the

Limitation of Liability Provision will be stricken.

22. The Engagement Letter also permits the Debtor, Kirkland, or Bates White to

terminate the agreement upon seven days written notice. See Engagement Letter ¶ 17.

Disinterestedness

23. In reliance on the Evans Declaration and except as set forth therein, the Debtor

believes that (a) the members and professionals of Bates White do not have any connections with

the Debtor, its affiliates, its creditors, the U.S. Trustee for Southern District of Texas, any person

employed in the office of the U.S. Trustee, or any other party with an actual or potential interest

in this chapter 11 case or their respective attorneys or accountants; (b) Bates White is not a creditor,

equity security holder, or insider of the Debtor; (c) none of Bates White’s professionals is, or was

within two years of the Petition Date, a director, officer, or employee of the Debtor; and (d) Bates

White neither holds nor represents an interest materially adverse to the Debtor or its estate.

Accordingly, the Debtor believes that Bates White is a “disinterested person,” as defined in section

101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code.


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24. To the extent that, during the period of its retention, Bates White discovers any new

relevant facts or relationships bearing on the matters described herein, Bates White will

supplement the Evans Declaration.

Notice

25. The Debtor will provide notice of this application to: (a) the U.S. Trustee; (b) the

Top Asbestos Counsel List;7 (c) counsel to Hess Corporation, Haynes and Boone, LLP, Attn:

Charles Beckham (1221 McKinney Street #4000, Houston, Texas 77010) and Martha Wyrick

(2323 Victory Ave., Suite 700, Dallas, Texas 75219); (d) Burns Charest LLP, as counsel in the

majority of pending asbestos cases, 900 Jackson Street, Suite 500, Dallas, Texas 75202, Attn:

Warren Burns; (e) the United States Attorney’s Office for the Southern District of Texas; (f) the

Internal Revenue Service; (g) the United States Securities and Exchange Commission; (h) the

United States Environmental Protection Agency; (i) the office of the attorney general in the states

where the Debtor conducts its operations; and (j) any party that has requested notice pursuant to

Bankruptcy Rule 2002. In light of the nature of the relief requested, no other or further notice need

be given.

7 As defined in the creditor matrix motion filed at Docket No. 12.


The Debtor requests entry of the Order, granting the relief requested herein and granting such other relief as the Court deems appropriate.

Houston, Texas May 16, 2022

/s/ Matthew D. CavenaughJACKSON WALKER LLP KIRKLAND & ELLIS LLPMatthew D. Cavenaugh (TX Bar No. 24062656) KIRKLAND & ELLIS INTERNATIONAL LLPJennifer F. Wertz (TX Bar No. 24072822) Christopher T. Greco, P.C. (admitted pro hac vice)Veronica A. Polnick (TX Bar No. 24079148) Matthew C. Fagen (admitted pro hac vice)1401 McKinney Street, Suite 1900 601 Lexington AvenueHouston, TX 77010 New York, New York 10022Telephone: (713) 752-4200 Telephone: (212) 446-4800Facsimile: (713) 752-4221 Facsimile: (212) 446-4900Email: [email protected] Email: [email protected] [email protected] [email protected] [email protected]

- and -Proposed Co-Counsel to the Debtorand Debtor in Possession KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS INTERNATIONAL LLPWhitney C. Fogelberg (admitted pro hac vice)Jaimie Fedell (TX Bar No. 24093423) (admitted pro hac vice) 300 North LaSalleChicago, Illinois 60654Telephone: (312) 862-2000Facsimile: (312) 862-2200Email: [email protected]

[email protected]

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KIRKLAND & ELLIS LLPKIRKLAND & ELLIS INTERNATIONAL LLPMichael F. Williams, P.C. (admitted pro hac vice)Daniel T. Donovan, P.C. (admitted pro hac vice)Alexandra I. Russell (admitted pro hac vice)1301 Pennsylvania Ave., N.W.Washington, D.C. 20004Telephone: (202) 389-5000Facsimile: (202) 389-5200Email: [email protected]

[email protected]@kirkland.com

Proposed Co-Counsel to the Debtorand Debtor in Possession


Certificate of Service

I certify that on May 16, 2022, I caused a copy of the foregoing document to be served by the Electronic Case Filing System for the United States Bankruptcy Court for the Southern District of Texas.

/s/ Matthew D. CavenaughMatthew D. Cavenaugh


Exhibit A

Evans Declaration

Case 22-90035 Document 100-1 Filed in TXSB on 05/16/22 Page 1 of 56


HOUSTON DIVISION



)Debtor. )

)

DECLARATION OF ANDREW R. EVANS CFA IN SUPPORT OF DEBTOR’S APPLICATION FOR ENTRY OF AN ORDER (A) AUTHORIZING RETENTION AND EMPLOYMENT OF BATES WHITE, LLC AS ASBESTOS CONSULTANTS

EFFECTIVE AS OF THE PETITION DATE AND (B) GRANTING RELATED RELIEF

I, Andrew R. Evans, under penalty of perjury, declare as follows:

1. I am the Practice Chair of the Environmental and Product Liability Practice at Bates

White, LLC (“Bates White”), which maintains offices at 2001 K Street NW, North Building, Suite

500, Washington, DC 20006. A copy of my curriculum vitae is attached hereto as Exhibit 1.

2. I am duly authorized to make this Declaration on behalf of Bates White. I make

this Declaration in support of the Debtor’s Application for Entry of an Order (A) Authorizing

Retention and Employment of Bates White, LLC as Asbestos Consultants Effective as of the

Petition Date and (B) Granting Related Relief filed contemporaneously herewith

(the ”Application”).2 The facts set forth in this Declaration are personally known to me and, if

called as a witness, I could and would testify thereto.


2 Capitalized terms not otherwise defined herein have the meanings given to them in the Application.


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Qualifications


services relating to the economic analysis and estimation of mass tort claims. Bates White has

considerable experience with, and knowledge regarding, asbestos claims and valuation. In

addition, this engagement is expected to be led by highly experienced experts, myself and

Dr. Charles. H. Mullin. Dr. Mullin’s curriculum vitae is attached hereto as Exhibit 2.

4. I am a CFA Charterholder and have more than 19 years of experience in providing


Included among the matters in which I have provided or am currently providing asbestos-related

expert testimony or related services are the bankruptcy cases of In re Aldrich Pump, In re Owens

Corning, In re Paddock Enterprises, In re Specialty Products Holding Corp., and In re The

Fairbanks Company.3 In addition, I have testified in numerous insurance and reinsurance

coverage disputes dealing with asbestos and other mass torts and provided valuations in

bankruptcies involving mass torts other than asbestos, such as in In re Boy Scouts of America and

In re USA Gymnastics (both of which relate to sexual abuse claims), In re Blitz U.S.A., Inc.

(relating to allegedly defective gas cans), and In re TK Holdings Inc. (relating to defective

airbags).4

5. Dr. Mullin has more than twenty years of experience in providing expert testimony

and guidance on litigation and business matters and has authored more than seventy‑five expert

3 In re Aldrich Pump LLC, Case No. 20-30608 (JCW) (Bankr. W.D.N.C. June 17, 2020); In re Owens Corning, Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re Paddock Enterprises, LLC, Case No. 20-10028 (LSS) (Bankr. D. Del. Jan. 6, 2020); In re Specialty Products Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del. May 31, 2010); In re The Fairbanks Company, Case No. 18-41768 (PWB) (Bankr. N.D. Ga. July 31, 2018).

4 In re Boy Scouts of America and Delaware BSA, LLC, Case No. 20-10343 (LSS) (Bankr. D. Del. Feb. 18, 2022); In re USA Gymnastics, Case No. 18-09108 (RLM) (Bankr. S.D. Ind. Dec. 5, 2018); In re Blitz U.S.A., Inc., Case No. 11-13603 (PJW) (Bankr. D. Del Nov. 9, 2011); In re TK Holdings Inc., Case No. 17-11375 (BLS) (Bankr. D. Del. June 25, 2017).


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reports. Included among the matters in which Dr. Mullin has provided or is currently providing





and reinsurance coverage disputes and provided valuations in bankruptcies involving mass torts

other than asbestos, such as In re Blitz U.S.A., Inc. (relating to allegedly defective gas cans) and In

re TK Holdings Inc. (relating to defective airbags).6


6. Bates White will render economic consulting, claims valuation, and related services

to the Debtor as needed in connection with asbestos personal injury claims against the Debtor and

related potential costs and liabilities. These services may include, but are not limited to:

(a) performing due diligence and analysis regarding the Debtor’s current, potential, and overall asbestos liability (both defense costs and indemnity), including with respect to historical and projected trends, econometric evaluations, market analysis, and evaluations using other established methodologies;

(b) estimating the number and value of, and producing analysis with respect to, present and future asbestos personal injury claims against the Debtor;

(c) assisting the Debtor in negotiations with various parties regarding the Debtor’s asbestos liability, including by evaluating proposals or

5 In re DBMP LLC, Case No. 20-30080 (JCW) (Bankr. W.D.N.C. Jan. 23, 2020); In re Leslie Controls, Inc., Case No. 10-12199 (Bankr. D. Del. Jul. 12, 2010); In re Motors Liquidation Company, Case No. 09-50026 (REG) (Bankr. S.D.N.Y. June 1, 2009); In re Owens Corning, Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re Plant Insulation Company, Case No. 09-31347 (TEC) (Bankr. N.D. Cal. May 20, 2009); In re Specialty Products Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del. May 31, 2010); In re Thorpe Insulation Company, Case No. 07-19271 (SB) (Bankr. C.D. Cal. Oct. 15, 2007).

6 In re Blitz U.S.A., Inc., Case No. 11-13603 (PJW) (Bankr. D. Del Nov. 9, 2011); In re TK Holdings Inc., Case No. 17-11375 (BLS) (Bankr. D. Del. June 25, 2017).


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potential proposals and providing analysis, information, and support in connection therewith;

(d) advising the Debtor regarding the funding of any asbestos trust that may be created pursuant to the Bankruptcy Code;

(e) advising the Debtor regarding financial issues that may impact the valuation of asbestos claims;

(f) providing expert testimony and reports related to the foregoing and assisting the Debtor in preparing and evaluating reports and testimony by other experts and consultants; and

(g) providing such other advisory services as may be requested by the Debtor.


7. Bates White is willing to serve as asbestos consultants and experts for the Debtor

and to receive compensation and reimbursement in accordance with its standard billing practices,

the provisions of the Engagement Letter, sections 330 and 331 of the Bankruptcy Code, the

Compensation Guidelines, the Interim Compensation Order, and any other applicable orders of

this Court. The Engagement Letter, a copy of which is attached as Exhibit 1 to the Order, specifies

that the Bates White retention is through Kirkland, who will provide direction as to the scope and

type of services Bates White is to provide. In any event, however, the Debtor is solely responsible

for the payment of services rendered by Bates White, along with payment of any related costs

under the terms of the Engagement Letter. See Engagement Letter ¶¶ 4, 7.



this Court.


White with a retainer totaling $50,000 for services rendered or to be rendered, and for



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Billing Category RangePartner (Andrew R. Evans) $825

Partner (Dr. Charles Mullin) $1,150Partner $700 - $1,600

Principal $575 - $750Managing Economist $545 - $650Managing Consultant $500 - $625

Senior Economist $475 - $550Senior Consultant $450 - $500

Economist $460Consultant II $390 - $425Consultant $365

Research Analyst $365 - $460Project Coordinator $255Research Assistant $210



are not subject to any bankruptcy holdback are paid within thirty days of the date they are due

7 Bates White will (a) complete its reconciliation of prepetition fees and expenses actually incurred for the period up to the Petition Date no later than the filing of its first interim fee application in this chapter 11 case; (b) make a corresponding adjustment to the amount of the Retainer on or about that date; and (c) disclose such adjustment in its first interim fee application. Subject to the foregoing adjustment, Bates White requests authorization from the Court to hold any remaining amount of the Retainer following such reconciliation as security for the payment of postpetition fees and expenses, subject to the terms of any order establishing procedures for interim compensation and reimbursement of expenses of retained professionals (any such order, the “Interim Compensation Order”). Bates White will not apply any portion of the Retainer to fees and expenses incurred from and after the Petition Date unless and until authorized to do so by a further order of this Court, including the Interim Compensation Order.


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under the Interim Compensation Order or other applicable rules in this chapter 11 case, the Debtor

will receive a 5% prompt-pay discount for the entire invoiced amount. See Engagement Letter ¶ 9.

11. In addition, also subject to approval by this Court, Bates White shall submit for

reimbursement all of its reasonable out-of-pocket expenses in connection with this chapter 11 case.

12. No promises have been received by Bates White as to compensation in connection

with this chapter 11 case other than as outlined in this Declaration and the Application in

accordance with the provisions of the Bankruptcy Code. Bates White has no agreement with any

other entity to share any compensation received.

13. The terms of Bates White’s employment and compensation as described in this

Declaration, the Engagement Letter, and the Application are consistent with employment and

compensation arrangements typically entered into by Bates White when providing such advisory

services and, to the best of our knowledge, are competitive with those arrangements entered into

by other economic consulting firms when rendering comparable services.





11 case.


The parties shall not be liable to one another for any claim, whether sounding in contract, tort, (including but not limited to malpractice), or otherwise, including a claim arising out of the breach, termination, enforcement, interpretation, or validity of this agreement, for indirect, special, consequential, or exemplary damages. Bates White shall not be liable for direct damages in excess of the lesser of two times the fees paid or $250,000 with respect to services performed under this letter, except to the extent of Bates White’s gross negligence, willful misconduct, or fraud.


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Disinterestedness

17. Through Kirkland, the Debtor has provided us a listing of potentially interested

parties in this chapter 11 case (the “Potential Parties in Interest”), and such parties are listed on

Schedule 1 hereto. To the extent that information was available, we undertook a detailed, good

faith search to determine and to disclose, as set forth herein, whether we have provided or currently

provide consulting services to any significant creditors, insiders, or other parties-in-interest

identified by such list in any substantively unrelated matters.

18. In preparing this Declaration, Bates White staff, under my direction and control,

searched our database containing the names and matter descriptions of current and previous

engagements handled by our firm. To the extent the information is available, the search request

identified parties to whom Bates White has provided or currently provides services that also are

Potential Parties in Interest, which included significant creditors of the Debtor, significant

professional advisors to the Debtor, and other potential parties-in-interest in this chapter 11 case.

19. To the best of my knowledge and belief, Bates White has provided, or is currently

providing, consulting services to certain creditors of the Debtor (or affiliates of creditors of the

Debtor), equity security holders, or other parties-in-interest in matters unrelated to the Debtor or

this chapter 11 case, as described on Schedule 2 to this Declaration.

20. If Bates White discovers additional information that requires disclosure, we will

promptly file a supplemental disclosure with the Court.


-8-

21. Bates White is not a creditor, equity security holder, or an insider of any of the

Debtor.

22. Neither Bates White nor any of Bates White’s professionals is, or was within two

years of the Petition Date, a director, officer, or employee of the Debtor.

23. Accordingly, to the best of my knowledge, information and belief, Bates White is

a “disinterested person” as such term is defined by section 101(14) of the Bankruptcy Code.


Pursuant to 28 U.S.C. § 1746, declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge, and belief.

Dated: May 16, 2022 /s/ Andrew R. Evans Andrew R. Evans CFA. Practice Chair of the Environmental and Product Liability PracticeBates White, LLC2001 K Street NWNorth Building, Suite 500Washington, DC 20006


Exhibit 1

Andrew R. Evans, CFA Curriculum Vitae


2001 K Street NW North Building, Suite 500 Washington, DC 20006

Main 202. 408. 6110

ANDREW R. EVANS, CFA

Partner

AREAS OF EXPERTISE

• Contingency valuation

• Insurance allocation

• Financial forecasting

• Liability valuation and hedging

• Reorganizations

• Economic analysis

SUMMARY OF EXPERIENCE

Andrew R. Evans chairs Bates White’s Environmental and Product Liability Practice. He is a CFA charter holder

and a recognized expert on legacy liability valuation, financial risk assessment, and insurance allocation. He has

more than 18 years of experience providing advice and expert analysis on issues involving mass torts,

(re)insurance coverage, alternative risk transactions, mergers and acquisitions, and financial valuation matters

related to distressed operations and restructurings. Mr. Evans is currently the Practice Chair of the Environmental

and Product Liability Practice at Bates White, LLC.

Mr. Evans has authored expert reports and declarations as part of contract disputes, state insurance proceedings,

federal bankruptcy reorganizations, Alternative Dispute Resolutions (ADRs), mediations, and in support of

corporate valuations, mergers and acquisitions, and divestitures. He has facilitated settlements in coverage

disputes related to asbestos, environmental losses, and other toxic tort litigation that involved the retirement of

several billion dollars in total available coverage limits. Mr. Evans also advises insurers, investors, and corporate

strategists in litigation funding, and has particular expertise in risk management through the use of “ring-fencing”

and hedging structures.

EDUCATION

• Chartered Financial Analyst (CFA) charter holder

• AB, Woodrow Wilson School of Public Policy and Foreign Affairs, Princeton University

• Co-recipient of the R.W. van de Velde Prize for outstanding policy work

• Worked with the US Department of State as a Political Military Junior Officer and assisted with

negotiations involving nuclear weapons reductions and crisis intervention for the Kosovo Peace Plan

• Chief Administrator for a campus advertising business

SELECTED EXPERIENCE

• Retained as abuse claims valuation and insurance allocation expert by an insurance company in a set of

class action cases dealing with hazing and sexual abuse claims: 2022–present.


ANDREW R. EVANS, CFA Page 2 of 7

• Served as consulting advisor on talc valuation related issue to the Debtor in In re LTL Management LLC, No.

21-30589 (MBK) (Bankr. D.N.J.): 2021–present.

• Retained as valuation consultant to advise corporate board of foreign based company on US-based liability

management options: 2021–present.

• Retained as abuse claims valuation expert by an insurance company in a dispute related to the valuation of a

group of sexual abuse claims resulting in settlement: 2021-2022.

• Authored expert report and testified at a binding arbitration subject to American Arbitration Association rules

on behalf of an insurance joint defense group in a defense fee dispute for coverage of sexual abuse-related

defense fees: 2021–2022.

• Retained by Debtors and participated in successful mediation regarding the value of pending and future

asbestos-related personal-injury claims on behalf of the Debtors in In re Paddock Enterprises, LLC, No. 20-

10028 (LSS) (Bankr. D. Del.): 2020–present.

• Served as lead consulting advisor to Debtors regarding the value of pending and future asbestos-related

personal-injury claims in In re Aldrich Pump LLC, et al., No. 20-30608 (Bankr. W.D.N.C.): 2020–present.

• Authored letters regarding the range of potential valuations associated with a Fortune 500 company’s

asbestos-related reserves. 2020–present.

• Authored expert reports and testified at a Bermuda arbitration hearing on behalf of an insurer regarding the

portion of set of auto defect claims potentially subject to coverage: 2019–2020.

• Retained as abuse claims valuation consultant by the Debtors and lead mediation valuation efforts in the

matter of In re: Boy Scouts of America and Delaware BSA, LLC No. 20-10343-LSS (United States Bankruptcy

Court for the District of Delaware): 2019–present.

• Retained as consulting expert and participated in pre-bankruptcy mediation related to the valuation of losses

stemming from sexual abuse claims: 2019–2020.

• Retained as consulting expert by an insurance company and participated in court-ordered mediation in the

matter In re: USA Gymnastics No. 18-09108-RLM-11 (United States Bankruptcy Court for the Southern

District of Indiana Indianapolis Division): 2019–2022.

• Authored expert report and declarations, and provided deposition and trial testimony, regarding the sufficiency

of document and settlement data productions for asbestos-related claims in the matter of Keyes Law Firm,

LLC v. Napoli Bern Ripka Shkolnik, LLP et al., No.: 1:17-cv-02972 (United States District Court for the District

of Maryland, Northern Division): 2019–2020.

• Authored presentation for investor group and provided model of potential losses related to bodily injury claims

alleged related to agricultural pollutant: 2019.

• Retained as allocation consultant and advised an insurer on settlement mediation in Wellington coverage

dispute: 2019.

• Authored expert report and provided deposition testimony regarding projected future asbestos-related losses

and the portion potentially subject to reimbursement under an indemnity agreement In re Midwest Generation,

LLC, et al., No. 12-49218 (United States Bankruptcy Court Northern District of Illinois (Chicago): 2018–2019.

• Authored report on the value of insurance potentially available to offset future asbestos-related expenditures

for corporate entity assessing strategic alternatives: 2018.



• Authored legacy liability valuation report for a regional supply company to a firm considering a potential

strategic acquisition: 2018.

• Retained to provide contingent liability valuation on behalf of insurance company evaluating strategic

alternatives: 2018.

• Submitted declaration as custodian of records for asbestos-related insurance coverage dispute: 2018.

• Retained as part of consulting team advising, and participated in settlement mediations on behalf of, a group

of automobile manufacturers regarding the scope of potential future personal injury and wrongful death claims

related to allegedly defective airbags in the matter of In re: TK Holdings Inc., et al., No. 17-11375 (BLS)

(United States Bankruptcy Court for the District of Delaware) and related proceedings: 2017–2018.

• Retained by insurer and authored settlement report analyzing outcomes related to potential policy exposure

associated with allegedly faulty medical implants as part of a coverage mediation: 2017–2018.

• Advised parties on a possible corporate transaction involving potentially significant asbestos-related liabilities:

2017–2018.

• Retained by insurer to analyze probable policy exposure associated with future asbestos claims in the tort

system and under a potential 524(g) bankruptcy trust and participated in related mediation and settlement

discussions in In re: The Fairbanks Company, No. 18-41768 (United States District Court for the Northern

District of Georgia): 2017–present.

• Led consulting team through arbitration hearing for an asbestos-related reinsurance dispute involving a nearly

$50 million claim: 2017.

• Retained as consulting expert and advised Fortune 500 companies assessing strategic alternatives for

addressing their asbestos-related expenditures: 2016–present.

• Authored expert reports and provided deposition testimony addressing inconsistent treatment of conceptually

related insurance allocation issues as part of a dispute regarding MTBE ground water pollution: 2015–2017.

• Co-authored expert report addressing the legacy asbestos liability and related insurance offsets for a set of

industrial companies as part of a corporate acquisition: 2016.

• Provided legacy liability valuation for a national construction materials company, including related potential

insurance offsets, to a strategic buyer considering a potential acquisition: 2016.

• Retained as sampling and insurance allocation expert for a multi-million-dollar insurance claim related to

asbestos: 2016.

• Authored expert reports and provided deposition testimony addressing the allocation of a multi-million-dollar

insurance claim related to an agricultural ground water pollutant: 2015–2017.

• Provided legacy liability valuation of a regional construction company, including related potential insurance

offsets, to a private equity firm considering a potential acquisition: 2015.

• Coauthored letters supporting the approximately $700m international legacy asbestos liability and related

insurance valuations for the newly combined AMEC Foster Wheeler across different accounting frameworks,

namely US GAAP and IFRS, as of their 2014 acquisition dates, and defended the analysis through a multi-

firm audit; providing ongoing periodic analytical updates and reports: 2014–present.

• Served as consulting expert to a pair of reinsurers in arbitration regarding allocation issues related to multi-

million-dollar asbestos cessation: 2014–2016.



• Provided settlement support and served as consulting expert on behalf of five-member insurance joint

defense group in a case taken through jury trial related to primary policy exhaustion and alternative available

coverage lines under a variety of potential choice of law and occurrence rulings: 2013–present.

• Led analytical team and served as consulting expert for insurer involved in a coverage dispute with a large

asbestos defendant: 2014–2016.

• Provided legacy liability valuation report of an energy sector services company to a private equity firm

considering a potential acquisition: 2014.

• Led team and served as consulting expert on analysis of the potential impact of alternative occupancy rates

and leverage ratios on the value of a large assisted living property over time: 2014.

• Led separate settlement support analytical team that worked on simplified valuation framework that leveraged

existing valuations tools, and accounted for various shortcomings within those tools, to value dozens of large

RMBS securitizations: 2014.

• Provided legacy liability valuation report that parsed liability for a large-scale energy generator across specific

facilities and over time: 2014.

• Co-authored expert report, provided deposition testimony, and testified regarding the sufficiency of the

proposed aggregate product liability claim settlement on behalf of the settling insurers in In re Blitz USA Inc.,

No. 1:11-bk-13603 (United States Bankruptcy Court for the District of Delaware): 2013–2014.

• Provided consulting expertise in support of Dr. Charles E. Bates’ liability estimation, and led team working on

Dr. Karl N. Snow’s financial valuation work on behalf of the Debtors in In re Garlock Sealing Technologies,

LLC, No. 10-BK-31607 (United States Bankruptcy Court for the Western District of North Carolina): 2010–

present.

• Authored declaration and served as lead consulting expert on behalf of the Debtors in In re Specialty

Products Holding Corp., et al., No. 10-11780 (JKF) (United States Bankruptcy Court for the District of

Delaware): 2010–present.

• Presented to the board of a Fortune 500 company regarding the potential economic risks associated with the

assumption of legacy liabilities tied to US manufacturing firms: 2014.

• Retained as the allocation and valuation expert for an excess insurer involved in Wellington ADR proceedings

related to an asbestos products manufacturer joint defense group: 2013–2014.

• Co-authored asbestos due diligence report for a corporate client evaluating restructuring opportunities: 2013.

• Advised numerous clients contemplating acquisitions that involve companies with potential legacy liability

issues. Work involved assessing potential future tort expenditures and associated risk drivers, as well as

evaluating insurance assets that may provide offsetting coverage: 2005–present.

• Authored expert report and served as the allocation expert for an insurance company dealing with

remediation costs across multiple environmental sites that could be subject to numerous potential legal

rulings and estimated future loss scenarios: 2012–2013.

• Advised insurers in reinsurance ADR proceedings on issues related to asbestos products’ usage that could

impact performance of reinsurance treaties: 2011–2013.

• Provided due diligence evaluation and report for a client engaged in a bidding war for an acquisition target

with potential long-tail liability risks: 2012.



• Provided consulting and settlement support to an excess insurer in asbestos-related Wellington ADR

proceedings for an insulation contracting and sales company: 2011–2012.

• Advised an insurer in litigation on issues related to the availability of various types of asbestos insurance

products: 2011.

• Assisted a Fortune 500 company with the acquisition of after-the-fact insurance, similar to a liability portfolio

transfer, covering the financial risk arising from thousands of asbestos claims: 2010–2011.

• Provided consulting support and analysis for multiple insurance companies in In re Leslie Controls, Inc., No.

10-12199 (CSS) (United States Bankruptcy Court for the District of Delaware): 2010–2011.

• Provided tort defendants with information required for them to file contribution claims with various 524(g)

trusts: 2010–2011.

• Provided a report to a large reinsurance group about issues impacting asbestos claiming trends and

insurance recoveries: 2010.

• Evaluated potential damages and investment returns for several third-party litigation funders on numerous

cases dealing with issues including: mass environmental loss, qui tam tax claims, fraudulent conveyance,

international contract arbitration, price-fixing, patents, and mortgage-backed securities and other CDOs:

2009–2011.

• Supported experts assessing the value of pending and future asbestos-related personal-injury claims on

behalf of the Official Committee of Unsecured Creditors in In re Motors Liquidation Company, et al. f/k/a

General Motors Corp., et al., No. 09-50026 (REG) (United States Bankruptcy Court for the Southern District of

New York): 2010–2011.

• Provided extensive claiming population analysis for a defendant corporation facing a mass of black lung

claims: 2010.

• Developed an alternative risk transfer product to help companies minimize overhang costs associated with

asbestos and other legacy liabilities. Shaped customized transactions for several clients that would have

involved nine- and ten-figure loss transfers: 2007–2009.

• Advised a joint defense group of more than a dozen insurers throughout their litigation and settlement

negotiations in the matter Foster Wheeler L.L.C. v. Affiliated FM Insurance Co., Index No. 600777/01 (N.Y.S.,

New York City): 2006–2010.

• Provided supporting analysis on the economic viability of the Trust Fund proposed under S.852, the Fairness

in Asbestos Injury Resolution (FAIR) Act of 2005, which highlights how compensation criteria specified for the

proposed Fund would change the number and composition of claims relative to the current tort environment:

2005.

• Coauthored a report on company-specific asbestos litigation risk in support of a successful corporate

divestiture: 2005–2006.

• Managed the litigation support team responsible for addressing the fraction of expenditures associated with a

company’s asbestos installation operations on behalf of defendants in Owens Corning v. Birmingham Fire

Insurance Company of Pennsylvania, No. C10200104929 (Ohio Court of Common Pleas, Lucas County).

Assessed data quality, reviewed the opposing expert’s analytical methods, and developed an independent

method for predicting “non-products” liability: 2003–2005.



• Managed the litigation support team that addressed the fraction of expenditures associated with a company’s

asbestos installation operations on behalf of Liberty Mutual Insurance Company in Armstrong World

Industries Inc. v. Liberty Mutual Insurance Co., No. 02 cv 4360 (Eastern District of Pennsylvania). Assessed

data quality, reviewed the opposing expert’s analytical methods, and developed an independent method for

predicting “non-products” liability in insurance policies: 2003–2009.

• Developed plaintiff law firm-specific future asbestos liability forecasts for a multimillion-dollar London Market

insurance policy buy-back negotiation: 2004–2005.

• Assisted in the development of cross-project asbestos site identification procedures, tools, and applications:

2003–2005.

• Assisted in the development of future claim value projection techniques to analyze the effects of bankruptcies

on claim values in joint and several tort environments: 2003–2005.

• Assisted in the development of a new proprietary insurance allocation application: 2003–2006.

• Conducted exposure analyses and predicted future claims involving asbestos manufacturers and contractors

in bankruptcy and insurance coverage disputes: 2003–2005.

• Played a key role in the development of new methodologies for disaggregating and identifying the drivers of

legacy liability losses used to determine the impact of punitive damage awards as well as the portion of

settlements driven by liability, as opposed to other considerations.

PROFESSIONAL EXPERIENCE

• Bates White Economic Consulting

• Partner, 2019–present

• Principal, 2009–2018

• Manager, 2003–2008

• Critical member of the team that developed the first generation of Bates White proprietary insurance

allocation software.

• Principal and founding member, Litigation Resolution Group LLC, 2007–2009

• Litigation Resolution Group (LRG) was a third-party litigation funder originally founded to provide

economic finality to companies facing substantial asbestos and other long-tailed tort claims. LRG was the

first company that worked to serve the US market with a focus on assuming defense-side litigation risks.

Worked with senior hedge fund managers, insurance and reinsurance executives, lawyers, and corporate

executives to help them understand the value of their litigation derivative assets and liabilities.

PRESENTATIONS AND PANELS

• “Cutting Edge Trends and Developments in Allocation Issues,” Panel presentation at Perrin Conferences

Emerging Insurance Coverage & Allocation Issues Conference, May 11, 2017 (Philadelphia)

• “Recent Developments in Coverage Litigation and the Practical and Real Life Implications,” Panel discussion

at Perrin Conferences Asbestos Litigation Conference: A National Overview & Outlook, September 2016 (San

Francisco)

• “US Asbestos: Current and Emerging Trends,” IntAP Spring Technical Meeting, May 2012 (Cologne, DE)



• “US Asbestos: Current and Emerging Trends,” IntAP Spring Technical Meeting, June 2010 (Norwich, UK)

• “A Conversation About Litigation Risk Sharing by Major Law Firms,” RAND Institute Alternative Litigation

Finance in the US Conference, May 2010 (Arlington, VA)

• “Investing in Litigation,” Butterworths’ International Asbestos, September 2009 (London)

PROFESSIONAL ASSOCIATIONS

• CFA

• CFA Society of Washington, DC

• American Bar Association

• American Bankruptcy Institute


Exhibit 2

Charles H. Mullin, Ph.D. Curriculum Vitae



Main 202. 408. 6110

CHARLES H. MULLIN, PHD

Partner

AREAS OF EXPERTISE

• Data analysis

• Econometrics

• Economic modeling


• Microsimulation modeling

• Statistical analysis


Charles H. Mullin is the Bates White Managing Partner. He provides advice and expert analysis on issues

involving mass torts, class actions, bankruptcies, insurance coverage, and due diligence for mergers,

acquisitions, and spin-offs. He is a recognized expert on statistical and data analysis, econometrics, economic

and microsimulation modeling, sample design, insurance allocation, and the valuation of mass torts. Who’s Who

Legal has named him Insurance Expert of the Year (2018-2020), and he has been a Who’s Who Legal Insurance

and Reinsurance Expert Witness Thought Leader since 2016 and Global Elite Thought Leader since 2020. Dr.

Mullin has authored more than 75 expert reports and provided expert testimony in more than 50 matters, as well

as provided due diligence reports for corporate transactions. He has more than 20 years of experience providing

this expertise in both the private and public sectors.

He taught courses in statistics, econometrics, and labor economics while on the faculty in the Department of

Economics at Vanderbilt University and at the University of California at Los Angeles. Dr. Mullin has published

papers on applied and theoretical econometrics and labor economics in peer-reviewed journals, and he is

frequently invited to speak at industry conferences.

EDUCATION

• PhD, Economics, University of Chicago

• BA, Mathematics and Economics, University of California at Berkeley

SELECTED EXPERIENCE

• Authored expert report, provided deposition testimony, and provided hearing testimony on behalf of the

Debtor in In re LTL Management LLC, No. 21-30589 (JCW) (Bankr. W.D.N.C.): 2021–present.

• Authored expert report, provided deposition testimony, and provided hearing testimony in In re: Mallinckrodt

PLC, et al. No. 20-12522-JTD (Bankr. D. Del.): 2021–present.

• Authored expert report and provided deposition testimony in Kevin Brown et al. v. Saint-Gobain Performance

Plastics Corporation and Gwenael Busnel, No. 1:16-cv-00242-JL (U.S. Dist. Ct. D. N.H.): 2020–present.


CHARLES H. MULLIN, PHD Page 2 of 10

• Authored expert report, provided deposition testimony, provided hearing testimony, and assessed the value of

pending and future asbestos-related personal-injury claims on behalf of the Debtors in In re Aldrich Pump

LLC, et al., No. 20-30608 (Bankr. W.D.N.C.): 2020–present.

• Assessed the value of pending and future abuse claims on behalf of the Debtors in In re: Boy Scouts of

America and Delaware BSA, LLC No. 20-10343-LSS (Bankr. D. Del.): 2020–present.

• Assessed the value of pending and future asbestos-related personal-injury claims on behalf of the Debtors in

In re DBMP, LLC, No. 20-30080 (Bankr. W.D.N.C.): 2020–present.


In re Paddock Enterprises, LLC, No. 20-10028 (LSS) (Bankr. D. Del.): 2020–present.

• Authored expert report and provided deposition testimony on behalf of the Johnson & Johnson in In re: Imerys

Talc America, Inc., et al. No. 19-10289-LSS (Bankr. D. Del.): 2019–present.

• Authored presentation for investor group and provided model of potential losses related to bodily-injury claims


• Retained on behalf of the Debtors in In re Purdue Pharma L.P., et al., No. 19-23649 (Bankr. S.D.N.Y.): 2019–

present.

• Authored expert report in In re Midwest Generation, LLC, et al., No. 12-49218 (Bankr. N.D. Ill.): 2019.

• Provided testimony in PERB Interest Arbitration between PBA and the City of New York: 2019–present.

• Authored expert report and provided deposition testimony on behalf of excess insurers in In re Kaiser

Gypsum Company, Inc., et al., No. 16-31602 (Bankr. W.D.N.C.): 2018–present.

• Authored expert report in Consumer Financial Protection Bureau v. Navient Corporation and Navient

Solutions, Inc., No. 3:17-cv-00101 (M.D. Pa., Jan. 18, 2017). 2018–present.

• Authored expert report and provided deposition testimony in Keyes Law Firm v. Napoli Bern Ripka Shkolnik,

LLP, et al., No. 1:17-cv-02972 (U.S. Dist. Ct. D. Md.): 2018–2020.

• Authored expert report and provided deposition testimony in St. Paul Surplus Lines Insurance Company v.

Wright Medical Group, Inc., et al., No. CH-14-0927 (Tn. Ch. Ct. 13th Jud. Dist. Memphis): 2018–2019.

• Authored expert report, provided deposition testimony, and testified in Cannon Electric, Inc., now known as

ITT Cannon, Inc., et al. v. ACE Property and Casualty Company, et al., No. BC 290354 (Super. Ct. Cal. L.A.

Cnty. Ct.): 2018.


In re Bestwall, LLC, No. 17-31795 (Bankr. W.D.N.C.): 2017–present.

• Assessed the value of pending and future airbag-related personal-injury claims on behalf of automobile

manufacturers in the matter of In re: TK Holdings Inc., et al., No. 17-11375 (BLS) (Bankr. D. Del.) and related

proceedings: 2017–2018.

• Authored expert reports and testified in James D. Sullivan et al. v. Saint-Gobain Performance Plastics

Corporation, No. 5:16-cv-00125 (U.S. Dist. Ct. D. Vt.): 2017–2019.

• Authored expert report, provided deposition testimony, and testified in In re the Receivership of Fraser’s

Boiler Service, Inc., No. 15-2-01791-8 SEA (Wash. Super. Ct., King Cnty.): 2017.

• Authored expert report in Gerrit H. Brouwer et al. v. Wyndham Vacation Resorts, Inc. et al., No. 2014-CA-

008533 (Fl. Cir. Ct. 9th Jud. Cir. Orange Ct.): 2017–present.



• Authored expert report in Ernest Yaeger, Jr. et al. v. Wyndham Vacation Resorts, Inc. et al., No. 2014-CA-


• Authored declarations and testified in a reinsurance arbitration: 2017–present.

• Authored declaration and reports, provided deposition testimony, and testified in a reinsurance arbitration:

2016–present.

• Analyzed coverage issues on behalf of Columbia Casualty Co. regarding pharmaceutical-based losses: 2016.

• Authored expert reports on behalf of HDI-Gerling Industrial Insurance Co. regarding pharmaceutical-based

losses: 2015–2016.

• Authored expert report and declaration and provided deposition testimony in Appleton Papers Inc. & NCR

Corp. v. George A. Whiting paper Co. et al., No. 08-C-16 (U.S. Dist. Ct. E.D.WI): 2015–2017.

• Authored expert reports on behalf of ACE Bermuda insurance Ltd. regarding an arbitration claim by 3M

Company regarding allegedly defective masks and respirators against Bermuda-Form policies: 2015–2016.

• Authored expert report on behalf of Allstate Insurance Company regarding an insurance contribution claim in

Certain Underwriters at Lloyd’s London v. Allstate et al., No. C101-1674 (Ohio Ct. Com. Pl., Lucas Cnty.):

2015–2016.

• Analyzed coverage issues stemming from agricultural-related water contamination claims: 2015–2018.

• Analyzed coverage issues stemming from MTBE-related claims filed: 2015–2018.

• Authored expert report and provided deposition testimony in Direct General Ins. Co. v. Indian Harbor Ins. Co.,

No. 1:14-CV-20050-MGC (S.D. Fla.): 2015.

• Authored expert report, provided deposition testimony, and testified during arbitration on behalf of General Re

Corporation and SCOR SE in a reinsurance matter: 2014–2017, 2018–2021.

• Analyzed coverage issues stemming from Benzene claims filed in Radiator Specialty Company vs. Arrowood

Indemnity Company et al., No. 13 CVS 2271 (NC Super. Ct. Mecklenburg Cnty.): 2014–2015.

• Coauthored letters supporting the approximately $700 million international legacy asbestos liability and

related insurance valuations for the newly combined AMEC Foster Wheeler across US GAAP and IFRS

accounting frameworks, as well as periodic updates to said analyses: 2014–present.

• Authored declaration on behalf of insurance companies in AIU Ins. Co. v. Philips Elecs. N. Am. Corp., No.

9852-VCN (Del. Ch.): 2014–2015.

• Authored declaration on behalf of insurance companies in In re T.H. Agric. & Nutrition, LLC, No. 08-14692

(Bankr. S.D.N.Y.): 2014.

• Analyzed coverage issues stemming from environmental loss in Olin Corporation v. Insurance Company of

North America et al., No. 84 CIV. 1968 (TPG) (U.S. Dist. Ct. S.D.N.Y.): 2014–2015.



• Authored expert report, provided deposition testimony, and testified during arbitration on behalf of Allstate

Insurance Company in a reinsurance matter: 2013–2015.

• Provided deposition testimony on behalf of National Indemnity Company in Nat’l Indem. Co. v. State, No.

XDDV 2012-140 (Mont. Dist. Ct., Lewis & Clark Cnty.): 2013–2018.



• Authored expert report, provided deposition testimony, and testified on behalf of insurance companies in

Nooter Corp. v. Allianz Underwriters Ins. Co., No. 1022-CC01145-01 (Mo. Cir. Ct. 22nd Jud. Cir. St. Louis

City): 2013–present.

• Coauthored expert report, provided deposition testimony, and testified on behalf of multiple insurance

companies in In re Blitz U.S.A., No. 11-13603 (PJW) (Bankr. D. Del.): 2013–2014.

• Provided deposition testimony on behalf of The Hartford Accident and Indemnity Company in the matter Fluor

Corp. v. Hartford Accident & Indem. Co., No. 06CC00016 (Cal. Super. Ct., Orange Cnty.): 2013.

• Authored expert report on behalf of The Hartford Accident and Indemnity Company in the matter Hartford

Accident & Indemnity Co. v. Travelers Indem. Co., No. X07-HHD-CV-11-6021732-S (Conn. Super. Ct.,

Hartford Cnty.): 2013–2015.

• Provided deposition and trial testimony on behalf of The Travelers Indemnity Company in US Silica Co. v.

ACE Fire Underwriters Ins. Co., No. 06-C-2 (W. Va. Cir. Ct., Morgan Cnty.): 2013.

• Authored expert report and testified during arbitration proceedings on behalf of the Massachusetts Insurance

Insolvency Fund in In re the Liquidation of Midland Ins. Co., No. 41294/86 (N.Y. Sup. Ct.): 2012–2013.

• Authored expert report, provided deposition testimony, and testified at trial on behalf of Defendant in Cannon

Elec., Inc. v. Affiliated FM Ins. Co., No. BC 290354 (Cal. Super. Ct., L.A. Cnty.): 2012–2013.

• Authored expert report and provided deposition testimony on behalf of multiple insurance companies in

Goodrich Corp. v. A.G. Securitas et al.: 2013–2015.

• Authored expert reports and testified during arbitration proceedings on behalf of Munich Re regarding

pharmaceutical-based losses: 2011–2013.

• Authored expert report on behalf of Zurich International (Bermuda) Ltd. in a Wellington ADR: 2011.

• Authored expert reports, provided deposition testimony, and testified during arbitration on behalf of Liberty

Mutual Insurance Company in a series of related reinsurance arbitration matters: 2011–2013.

• Authored expert reports and declarations, provided deposition testimony, and testified during the confirmation

hearing on behalf of multiple insurance companies in In re Plant Insulation Co., No. 09-31347 TC (Bankr. N.D.

Cal.): 2011–2014.

• Provided consulting services for a coalition of direct action plaintiffs in In re Puerto Rican Cabotage Antitrust

Litigation.

• Analyzed liability and damages resulting from the indirect claim on behalf of a large coalition of direct-action

plaintiffs in the United States, Asia, and Europe in In re TFT-LCD (Flat Panel) Antitrust Litig., MDL No. 1827

(N.D. Cal.): 2011–2015.

• Authored expert reports, provided deposition testimony, and testified assessing the value of pending and

future asbestos-related personal-injury claims on behalf of the Debtors in In re Specialty Prods. Holding

Corp., No. 10-11780 (JKF) (Bankr. D. Del.): 2010–2015.


In re Garlock Sealing Techs., LLC, No. 10-BK-31607 (Bankr. W.D.N.C.): 2010–2018.

• Assisted a Fortune 500 company in the completion of a limited portfolio transfer of thousands of asbestos

claims to a major insurance company: 2010–2011.



• Authored declaration and provided deposition testimony on behalf of multiple insurance companies in In re

Leslie Controls, Inc., No. 10-12199 (CSS) (Bankr. D. Del.): 2010–2011.

• Authored declarations on behalf of Century Indemnity Company in In re Thorpe Insulation Co., No. CV 10-

1493 DSF (Bankr. C.D. Cal.): 2010–2011.

• Assessed the value of pending and future asbestos-related personal-injury claims on behalf of the Official

Committee of Unsecured Creditors in In re Motors Liquidation Co., No. 09-50026 (REG) (Bankr. S.D.N.Y.):

2010–2011.

• Assessed the value of diacetyl claims on behalf of the Official Committee of Equity Security Holders in In re

Chemtura Corp., No. 09-11233 (REG) (Bankr. S.D.N.Y.): 2010.

• Provided deposition and trial testimony in Cannon Electric, Inc., now known as ITT Cannon, Inc., et al. v.

Affiliate FM Insurance Company, et al., No. BC 290354 (Super. Ct. Cal. L.A. Cty. Ct.) Goulds: 2009–2017.

• Authored expert report on behalf of FM Global and Utica in an arbitration matter: 2009–2010.

• Authored expert reports and provided deposition testimony on behalf of Aviva Insurance Company in Flintkote

Co. v. Gen. Accident Assurance Co. of Can., No. C04-01827 MHP (N.D. Cal.): 2009–2010.

• Provided deposition testimony on behalf of NL Industries, Inc., in Brown v. NL Indus., Inc., No. 06-602096-CZ

(Mich. Cir. Ct., Wayne Cnty.): 2009–2010.

• Authored expert report on behalf of taxpayers in Cencast Servs., L.P. v. United States, Nos. 02-1916 T

through 02-1925 T (Fed. Cl.): 2009–2012.

• Authored declaration on behalf of the State of Israel in In re Holocaust Victim Assets Litig., No. 09-160

(ERK)(JO) (E.D.N.Y.): 2009–2010.

• Provided deposition testimony on behalf of multiple insurance companies in the matter State of Minnesota v.

Associated Medical Assurance Ltd., No. 27-CV-08-1912 (Minn. Dist. Ct., Hennepin Cnty.): 2008–2010.

• Authored expert reports, provided deposition testimony, and testified on behalf of multiple insurance

companies in Continental Casualty Co. v. BorgWarner Inc., No. 04 CH 01708 (Ill. Cir. Ct., Cook Cnty.): 2007–

present.


companies in Continental Ins. Co. v. Honeywell Int’l., Inc., No. MRS-L-1523-00 (N.J. Super. Ct., Morris Cnty.):

2007–2018.

• Authored expert report and provided deposition testimony on behalf of insurance company in Nat’l Serv.

Indus., Inc. v. Appalachian Ins. Co., No. E-22807 (Ga. Super. Ct., Fulton City): 2007.

• Authored expert report, provided deposition testimony, and testified on behalf of policyholder in Imo Indus.,

Inc. v. Transamerica Corp., No. L-2140-03 (N.J. Super. Ct., Mercer Cnty.): 2007–2011.

• Authored expert report and provided deposition testimony on behalf of insurance company in Degussa Corp.

v. Century Indem. Co., No. UNN-L-2163-03 (N.J. Super. Ct., Union Cnty.): 2007.

• Authored expert report and provided deposition testimony on behalf of insurance joint defense group in Foster

Wheeler LLC v. Affiliated FM Ins. Co., No. 600777/01 (N.Y. Sup. Ct., N.Y. Cnty.): 2007–2011.

• Authored expert reports, provided deposition testimony, and testified on behalf of Argonaut Insurance

Company in several reinsurance arbitrations: 2006–2007.



• Coauthored a report on the economic viability of the Trust Fund proposed under S.852, the Fairness in

Asbestos Injury Resolution (FAIR) Act of 2005, which highlights how compensation criteria specified for the


2005.

• Authored due diligence reports on asbestos, silica, opioids, and other mass tort matters for corporate

transactions that assessed potential future tort expenditures and evaluated the insurance assets that may

provide coverage for those tort expenditures: 2005–present.

• Authored expert reports and provided deposition testimony assessing the Trust-based liquidated values and

insurance allocation on behalf of Plaintiff in Nat’l Union Fire Ins. Co. of Pittsburgh, Pa. v. Porter Hayden Co.,

No. 1:03-CV-03408-CCB (D. Md.): 2004–2015.

• Authored expert report and provided deposition testimony to address the fraction of expenditures associated

with a company’s asbestos installation operations on behalf of Defendants in Owens Corning v. Birmingham

Fire Ins. Co. of Pa., No. C10200104929 (Ohio Ct. Com. Pl., Lucas Cnty.): 2003–2005.

• Authored expert report focused on the design and implementation of claims file samples in Hercules Inc. v.

OneBeacon Am. Ins. Co., No. 02C-11-237 (Del. Super. Ct., New Castle Cnty.): 2004.

• Assisted with settlement negotiations by analyzing the total value of a national refractory company’s products

and nonproducts coverage associated with claims for both asbestos and potential silica liabilities.

• Evaluated future liabilities and projected insurance recoveries under various scenarios, such as geographic

constraints regarding a regional insulation contractor and supply company.

• Served on behalf of the US Department of Labor in providing statistical analysis for discriminatory hiring

cases and assessing damages.

• Analyzed demand-side management programs for utility companies. Evaluated different contract structures,

software development options, and returns on subsidization programs.

• Investigated potential collusion and redlining by auto-insurance companies on behalf of the Office of the

Chicago Mayor.

OTHER PROFESSIONAL EXPERIENCE

Prior to joining Bates White, Dr. Mullin worked at Chicago Partners, where he provided damages assessments for

antitrust matters. Previously, he worked at Quantum Consulting, where he conducted demand-side management

for utility companies, and at Litigation Resolution Group. In addition to his professional experience, Dr. Mullin was

on the faculty in the Departments of Economics at Vanderbilt University and the University of California at Los

Angeles.

INDUSTRY PRESENTATIONS

• “Update on Talc Litigation.” Perrin Conferences—National Asbestos Litigation Conference, Oct. 1, 2018.

• “Corporate Roundtable: In-House Perspectives on Asbestos Litigation.” Perrin Conferences—Asbestos

Litigation Conference: A National Overview & Outlook, Sept. 13, 2016.

• “Emerging Risks & Insurance Issues in 2016 Coverage Litigation.” Perrin Conferences—Emerging Insurance

Coverage & Allocation Issues Conference, May 18, 2016.



• “Impact of Bankruptcies on Litigation Strategies.” Perrin Conferences—Asbestos Litigation Conference: A

National Overview & Outlook, Sept. 28, 2015.

• “Emerging Issues, Coverage Trends and Key Jurisdictional Updates for 2015.” Perrin Conferences—

Emerging Insurance Coverage & Allocation Issues, May 19, 2015.

• “National Trends Driving Asbestos Litigation.” Perrin Conferences—Asbestos Litigation Conference: A


• “Asbestos Bankruptcy Update.” Perrin Conferences—Asbestos Litigation Conference: A National Overview &

Outlook, Sept. 16, 2013.

• “Charting the Right Course in 2013: A Closer Look at This Year’s Emerging Insurance Coverage Issues.”

Perrin Conferences—Emerging Insurance Coverage & Allocation Issues in 2013, May 14, 2013.



• “Mathematical Estimates of Carrier Exposures.” Perrin Conferences—Emerging Insurance Coverage &

Allocation Issues, Feb. 23, 2012.

• “Quantifying the Exposure: Reinsurance, Reserves, and Practical Considerations.” Perrin Conferences—

Emerging Insurance Coverage & Allocation Issues, Jan. 24, 2011.

• “Adding Up the Parts—Settlement Offsets in All Sums Jurisdictions.” Perrin Conferences—Emerging

Insurance Coverage & Allocation Issues, Jan. 24, 2011.

• “Impact of Current Tort Environment on Asbestos Reserves.” 2010 Casualty Actuary Society Annual Meeting,

Nov. 8, 2010.

• “Litigating Asbestos Cases in 2010: National Trends Driving the Litigation.” Perrin Conferences—Asbestos


• “Trusts On-Line: The Impact of Asbestos Bankruptcies on the Tort System.” Perrin Conferences—Asbestos

Bankruptcy Conference, June 21, 2010.

• “Asbestos Litigation in 2010 & Beyond—Current and Emerging Trends.” Perrin Conferences—Cutting Edge

Issues in Asbestos Litigation, Feb. 25–26, 2010.

• “A National Update on Current Cases & Trends that are Driving Asbestos Bankruptcy Litigation.” Perrin

Teleconference Series, Dec. 1, 2009.

• “Asbestos Bankruptcy: New Filings, Confirmations & Dismissals.” Perrin Conferences—Asbestos Litigation

Mega Conference, Sept. 14–16, 2009.

• “Claims Estimation in Mass Tort Cases.” ABA Section of Business Law Spring Meeting Committee on

Business Bankruptcy, Apr. 16–18, 2009.

• “Role of the Bankruptcy Trusts in Civil Asbestos.” BVR Legal/Mealey’s Emerging Trends in Asbestos

Litigation Conference, Mar. 9–11, 2009.

• “Damages in a Bad Faith Case.” BVR Legal/Mealey’s Bad Faith Litigation Conference, Nov. 6–7, 2008.

• “Emerging Issues and Important Developments.” West Legalworks, Insurance and Reinsurance Allocation

2008: A Comprehensive Workshop, June 12, 2008.



• “Impact of Underlining Litigation Developments.” West Legalworks, Insurance and Reinsurance Allocation,

Nov. 7, 2007.

• “Removing the Asbestos Overhang—Is There an Alternative to Asbestos Bankruptcy?” Mealey’s Publications,

Mealey’s National Asbestos Litigation SuperConference, Sept. 26, 2007.

• “Another Chapter in Asbestos Bankruptcy Litigation: What Does the Future Hold?” Mealey’s Publications,

Asbestos Bankruptcy Conference, June 8, 2007.

• “Impact of Underlining Litigation Developments.” West Legalworks, Insurance and Reinsurance Allocation

Superbowl 2007, Mar. 20, 2007.

• “Quantifying the Risk: The Impact Investigations into Fraudulent Silica/Asbestos Suits Will Have on the Rate

of Filing and Value of Current & Future Claims.” Mealey’s Publications, Silica & Asbestos Claims Conference:

What Effect Will Investigations into Fraudulent Suits Have on the Litigation? Nov. 11, 2006.

• “How State and Federal Tort-Reform Efforts Are Changing the Asbestos Litigation Landscape.” Mealey’s

Teleconference: Asbestos Legislation—Is a Solution to the Crisis around the Corner? July 20, 2006.

• “Asbestos Legislative Initiatives for Federal and State Tort Reform.” American Conference Institute’s (ACI) 7th

Annual Litigating, Settling, and Managing Asbestos Claims, June 15, 2006.

• “The FAIR Act: An Economic Analysis.” American Legislative Exchange Council, 2005 States and Nation

Policy Summit, Dec. 2005.

• “The Impact of Different Approaches to Settlement Credits.” Mealey’s Publications, All Sums: Reallocation &

Settlement Credits Conference, Nov. 7, 2005.

• “Assessing the Merits of Reallocation.” American Enterprise Institute, Industry Roundtable Discussion, Apr.

21, 2005.

• “The Effect of Joint and Several Liability on the Incentive of Defendants to Declare Bankruptcy: Evidence from

Asbestos Litigation.” American Law and Economics Association, Annual Meeting, May 2004.

• “Assessing the Merits of Reallocation.” American Law and Economics Association, 14th Annual Meeting (co-

author Anup Malani), May 3, 2004.

PUBLICATIONS

• Mullin, Charles H., Karl N. Snow, and Noah B. Wallace. “Unresolved Issues in Allocation of Loss to

Insurance.” Coverage 21, no. 1 (2011): 13–23.

• Mullin, Charles H., Karl N. Snow, and Noah B. Wallace. “Proper Settlement Credits in All Sums Jurisdictions.”

Coverage 20, no. 3 (2010): 26–31.

• Mullin, Charles H., Charles E. Bates, and Marc Scarcella. “The Claiming Game.” Mealey’s Litigation Report:

Asbestos 25, no. 1 (2010).

• Mullin, Charles H., Charles E. Bates, and A. Rachel Marquardt. “The Naming Game.” Mealey’s Litigation

Report: Asbestos 24, no. 15 (2009).

• Mullin, Charles H., and Charles E. Bates. “State of the Asbestos Litigation Environment.” Mealey’s Litigation

Report: Asbestos, 23 no. 19 (2008).

• Mullin, Charles H., and Charles E. Bates. “Show Me the Money.” Mealey’s Litigation Report: Asbestos 22, no.

21 (2007).



• Mullin, Charles H., and Charles E. Bates. “The Bankruptcy Wave of 2000—Companies Sunk by an Ocean of

Recruited Asbestos Claims.” Mealey’s Litigation Report: Asbestos 21, no. 24 (2007).

• Mullin, Charles H., and Charles E. Bates. “Having Your Tort and Eating It Too?” Mealey’s Asbestos

Bankruptcy Report 6, no. 4 (2006).

• Mullin, Charles H. “Identification and Estimation with Contaminated Data: When Do Covariate Data Sharpen

Inference?” Journal of Econometrics 130, no. 2 (2006): 253–72.

• Mullin, Charles H., and David H. Reiley. “Recombinant Estimation for Normal-Form Games, with Applications

to Auctions and Bargaining.” Games and Economic Behavior 54, no. 1 (2006): 159–82.

• Mullin, Charles H. “Bounding Treatment Effects with Contaminated and Censored Data: Assessing the Impact

of Early Childbearing on Children.” Advances in Economic Analysis & Policy 5, no. 1, (2005): article 8.

• Mullin, Charles H., Kelly A. Dugan, and John J. Siegfried. “Undergraduate Financial Aid and Subsequent

Alumni Giving Behavior.” Quarterly Review of Economics and Finance 45, no. 1 (2005): 123–43.

• Mullin, Charles H., and Anandi Mani. “Choosing the Right Pond: Social Approval and Occupational Choice.”

Journal of Labor Economics 22, no. 4 (2004): 835–62.

• Mullin, Charles H., V. Joseph Hotz, and John K. Scholz. “Welfare, Employment, and Income: Evidence on the

Effects of Benefit Reductions from California.” American Economic Review 92, no. 2 (2002): 380–84.

• Mullin, Charles H., V. Joseph Hotz, and John K. Scholz. “Welfare Reform, Employment and Advancement.”

Focus 22, no. 1, Special Issue (2002).

• Mullin, Charles H., V. Joseph Hotz, and John K. Scholz. “The Earned Income Tax Credit and Labor Market

Participation of Families on Welfare.” In The Incentives of Government Programs and the Well-Being of

Families, eds. Bruce Meyer and Greg Duncan (Evanston, IL: Joint Center for Poverty Research, 2001).


Participation of Families on Welfare.” Poverty Research News, May/June 2001.

• Mullin, Charles H., and John J. Siegfried. “Grants Today, Gifts Tomorrow.” Currents 27, no. 4 (2001): 9–10.

• Mullin, Charles H., Carolyn J. Hill, V. Joseph Hotz, and John K. Scholz. “EITC Eligibility, Participation, and

Compliance Rates for AFDC Households: Evidence from the California Caseload,” May 1999, prepared for

the State of California.

• Mullin, Charles H., V. Joseph Hotz, and Seth Sanders. “Bounding Causal Effects Using Data from a

Contaminated Natural Experiment: Analyzing the Effects of Teenage Childbearing.” Review of Economic

Studies 64, no. 4 (1997): 575–603.

GRANTS

• 2004–2007: Principal Investigator (with V. J. Hotz and J. K. Scholz), National Science Foundation Grant, “Tax

Policy and Low-Wage Labor Markets: New Work on Employment, Effectiveness and Administration.”

• 2000–2001: Principal Investigator (with V. J. Hotz and J. K. Scholz), Grant to the University of Wisconsin–

Madison from Assistant Secretary of Planning and Evaluation, US Department of Health and Human

Services.

• 1997–1998: National Institutes of Health Predoctoral Training Grant.



PROFESSIONAL ASSOCIATIONS AND HONORS

• Who’s Who Legal: Insurance Expert of the Year, 2018–2020

• Who’s Who Legal Thought Leader: Global Elite list, 2019–present

• Who’s Who Legal: Insurance & Reinsurance Expert Witnesses Thought Leader, 2016–present

• Who’s Who Legal: Insurance & Reinsurance Expert Witnesses Global Elite Thought Leader, 2020–present


• American Economic Association

• American Law and Economics Association

• Econometric Society

• Society of Labor Economists


Schedule 1

Potential Parties in Interest


SCHEDULE 1

List of Schedules

Schedule Category1(a) Parent Affiliates1(b) Current/Former Directors & Officers1(c) Stockholders of Parent1(d) Cash Management Bank 1(e) Bankruptcy Judges & Staff1(f) Governmental/Regulatory Agencies1(g) Insurers1(h) Parties to Significant Actual or Known Potential Litigation with Debtor1(i) Plaintiffs’ Firms1(j) Co-Defendants1(k) Debtor’s Proposed Professionals and Affiliates’ Professionals1(l) U.S. Trustees’ Office


SCHEDULE 1(a)

Parent Affiliates

Hess Capital Services LLCHess CorporationHess Oil & Gas Holdings Inc.Hess Oil St. Lucia Holdings LPHess Oil St. Lucia Terminal HoldingsSt. Croix Petrochemical Corp.


SCHEDULE 1(b)

Current/Former Directors & Officers

Asafu-Adjaye, JacquelineBaker, DJDunagin, Martin C., Jr.Fishman, Eric S.Franzino, RobertGoodell, Timothy B.Hess, John B.Kahn, MatthewMenell, SethMosk, MiltonPrince, Edd D.Rielly, John P.Schachter, BarrySnyder, Todd R.Stapleton, AmyWiley, Jason


SCHEDULE 1(c)

Stockholders of Parent

BlackRock Inc. Brady, NicholasFMR LLCGoodwillie, Eugene, Jr.Hess, John B.Kean, Thomas H.State Street Corp.Vanguard Group Inc., The


SCHEDULE 1(d)

Cash Management Bank

JPMorgan Chase


SCHEDULE 1(e)

Bankruptcy Judges & Staff

Isgur, MarvinJones, David R.Lopez, ChrisNorman, Jeffrey P.Rodriguez, Eduardo V.


SCHEDULE 1(f)

Governmental/Regulatory Agencies

Illinois, State of, Attorney GeneralNew York, State of, Attorney GeneralUnited States, Government of the, Department of the Interior, Environmental Protection Agency


SCHEDULE 1(g)

Insurers

American International Group Inc.Royal Insurance Holdings Ltd.Travelers Cos. Inc., The


SCHEDULE 1(h)

Parties to Significant Actual or Known Potential Litigation with Debtor

Abraham, AlexandrineAbraham, Davidson Abraham, EleanorAbraham, FerdinandAbraham, HaroldAbraham, NarcisseAbraham-Soldiew, BernadetteAcosta, EdelmiroAcosta-Lewis, CandidaAdams, Melvine, Sr.Ahamad, ZulaikaAlamo, JuanAlbert, Felicite PatriciaAlexander, Anselm Alexander, David AdrianAlexander, Gabriel Alexander, Michael K.Alibocas, ShirleyAllen, Richard, Sr.Alphonse, AgnesAmelina, Marc LouisAndrew, AgnesAngol, AugustinAntoine, CatherineAntoine, ChedAntoine, JamfesAntoine, JohannaAquino-De La Rosa, OvidioArchibald, EmikaArno, CarlosArno, ConfesorArno, FeliciaArno, GladysArno, Liz Marie M.Arno, MagdalenaArno, YadielArno-Jimenez, GlerysbethArnold, AnnaArroyo, Ahrianna L.Arroyo, HectorArroyo, KianaArroyo, Petra

Arthurton, DexterAuguste, Keosha MariahAuguste, MarieAugustin, EmmanuelAustin, AllanAyala, EnriqueAyala, HumbertoAyala, JesusAzille, CherylBaez, LuisBallantine-Phillips, YvetteBaltimore, LinkBannis, HeaflineBaptiste, Alwyn JohnBaptiste, AntoineBaptiste, MariaBaptiste, Pricilla JohnBarnes, Dennis, Jr.Barry, JamesBarry, St. RoseBarry, SylviaBatista, JuanBazil, JoannessBeharry, Lawrence J., Sr.Beharry, Pascal W.Belardo, FidelBelardo, Hector C.Benjamin, Alford D.Benjamin, MelvinBenjamin, MorrisBenton, IngridBenwaree, RennieBergan, ArlingtonBerley, Cassilla V.Berley, Noel U.Bernard, AngeloBhola, AnthonyBiggs, Bruce E. P.Blake, Irvine E.Blake, RodneyBodley, CelinaBodley, Elias


Boland, VeronicaBougouneau, FranciscaBougouneau, Francisca AndreaBougouneau, JeremiahBowery, IraBoyce, Clemence, Sr.Boyer, ReginaBraithwaite, LisaBrown, Clarence G.Brown, FrankBrowne, Alexis H.Browne, AlfredBrowne, EdwinBrowne, GladstoneBrowne, Joshua S.Browne, RitaBrowne, StaffordBurke, A’JadaBurke, TyroneCaldena, BlakeCannon, MirandaCarlot, ZuleykaCarmona, DanieCarmona, JoannnaCarpio, LuisCarrasquillo, Victor RuizCarroll, MarioCarter, ArthurCasimir, AvanCastillo, Altagracia JavierCastro, JaimeCastro, PabloCelestin, EzraCepeda, Kelvin D.Cepeda, Nashali E.Cepin, Alfredo Marquez, Jr.Cepin, GuillerminaChapkanova, RoumenkaCharles, AlexanderCharles, CatherineCharles, Cuthbert R.Charles, ItaCharles, JuliaCharles, Veronica RitaCharles, VynishaChiverton, Onesimus

Christmas, ElfordChristophe, CyrillaCirilo, SoniaClarke, MichaelClaudio, Jorge Luis FontanezClercin, MaryClercin, Skitter VernaClifford, AugustineClinton, HenryClouden, ElvitaClouden-Browne, AbbeyClovis, CelestinClovis, LawrenceClovis, ReginaCoburn, JanelleColeman, JuliettaCollins, PhillipCombie, ElizaCombie, ValerieCompton, Claire J.Consula, MatthewCooke, RichardCooke, WilhelminaCorridon, NeilCoto, PedritoCotto, Jovo, Jr.Cox, DudleyCreighton, TheresaCrispin, PaulaCruz, CristinoCuffy, Gee, Jr.Cuffy, MableCuffy, ShirleyCyrille, PaulDalmau-Estrada, CarlosDalsan, AgnesDaniel, CatherineDaniel, ChristineDaniel, NoelDaniel, Phillip E.Dantes, BarthelmyDariah, TheresaDariah, WrandaDavid, JeanneDavis, RupertDayatra, Emmanuel


De La Cruz, Milciades UbriDe La Cruz, NancyDe Lande, ClefrynDe Rosa, Edelmira RoaDecaille, LildaDecima, John BaptisteDefreitas, Gilbert M.Degrasse, WilliamDelande, PeterDelgado, Gabriel A.Delozier, DarrenDenbow, HelenaDenis, AlexisDenis, AlphonsusDenis, DariahDenis, PlacideDennery, ArthurDennie, IsraelDesbonnes, NathalieDeschamps, MalcolmDesir, JoannaDesir, UriasDesouza, JohnDeterville, CharlesDiaz de Ayala, RosandaDiaz, ElizabethDiaz, RosaDonawa, Clarence EustaceDonawa, IanDonelly, TriciaDoran, GarfieldDoran, JudithDouglas, Charles (Christian)Drayton, CleavelyDrew, LenroyDrigo, DanielDucreay, IsaiahDuncan, TyroneDurgah, ShariaDyett, GeorgeEardley, Howard CharlesEast, EugeniaEastman, FelixEdward, PeterEdwards, Albert, Jr.Elcock, Kendrick

Elderfield, RichardElliot, AltonElliott, AlbertEmanuel, HensonEmmanuel, HyacinthEnglish, AllanErrilienne, CarmelaEstate of Alberto MorlaEstate of Arnold AnthonyEstate of Benjamin FreemenEstate of Eli McKenzieEstate of Emerson GillEstate of Ezekiel FarrellEstate of Felito RijoEstate of Felix ColonEstate of Fitzroy RobertsEstate of Francisco Carrasquillo-AcostaEstate of George GlasgowEstate of Greta ShaltoEstate of James HughesEstate of John JordanEstate of Joseph PlanteEstate of Julian PetersEstate of Kelvin StanislasEstate of Leroy W. TrimminghamEstate of Logan A. PujolsEstate of Luciano SusinoEstate of Luke FrederickEstate of Lunid WalterEstate of Miguel MartinezEstate of Nelson Mena MarteEstate of Nicholas GeorgeEstate of Octave FerdinandEstate of Patricia StewartEstate of Patrick MathurinEstate of Ramona SantosEstate of Roland BodleyEstate of Rosemary NicholasEstate of Scipio MurrenEstate of Teresa FontenelleEstate of Thomas LannaghanEstate of Wilmouth A. HughesEstephan, Americo RodriguezEugene, MaryEugene, SimniaEugene, Veronica


Evans, GualbertEvans, HandersonEvans, HughEvans, JuliannaFabian, PatricioFahie, Royce H.Farrelly, ChastidyFarrelly, ChristianFarrelly, ChristineFarrow, OliverFaucher, AngelaFelicien, JeremiahFelix, Angelina M.Felix, AnthonyFelix, BertaFerdinand, Brenda G.Ferdinand, OctaviaFigueroa, Carlos J.Figueroa, Carlos R., Jr.Figueroa, RobertoFinney, AlanaFinney, EmeraldFinney, JacklineFlood, CynthiaFonetenelle, ExiliaFontenelle, GeorgeFontenelle, PiusForde, LinroyFox, Melwyn EliasFrancis, AndreFrancis, SophiaFrancis-Christopher, DaisyFraser, Tamica T.Freeman, Eugene T., Sr.Frontal, JiannaGabriel, JuliaGaliber, Joyce JamesGarcia, FelixGarcia, FredericoGarcia, Glorimar MenaGarcia, JuanGarcia, ReynaldoGaston, SimoneGautier, AngelGeorge, CuthbertGeorge, Eunice

Gervais, RufinusGifford, AlainGilbert, IdoniaGilbert, JosephGill, FondaGlasgow, CatherineGlover, MaryGomez, OscarGonsalves, HyacinthGonsalves, MarieGonsalves, Marie V.Gonzague, AugustaGonzague, Henry, Jr.Gonzales, GlenGonzales, RamonaGonzalez, MarioGonzalez, RaulGordon, AdolphusGordon, AnnaGordon, CelestineGordon, RoderickGranger, StephanieGrant, FeliceGreen, Tony CurtisGreen, WendyGreenaway, DanGreene, AlwynGuadalupe, DomingoGuadalupe, Javier, Jr.Guadalupe, SheraldaGuadalupe-Thomas, Maria R.Gumbs, AlexanderGumbs, AnneGustave, AudreyGuzman, SencionHall, Egbert CarltonHamilton, AmbroseHenry, GeorgeHenry, LucilleHenry, Mary G.Henry, MervynHenry, MichaelHenry, MilesHenry, NicholasHenry, PaulHenry, Yolanda


Hepburn, Maria M.Herelle, JosephHerman-Sadoo, NataliaHernandez-Aquino, XiomaraHill, Joseph VigilantHinkson, FrancillaHippolyte, WaltrudeHospedales, RoderickHughes, StedmanInce, AlbertInglis, DillonIrwin, VeraIsaac-Joseph, SirdrinaIsidore, HelenJackson, MalvinaJacob, CharlesJacobs, GwendolynJagrup, VerdanJames, BrendaJames, FrancisJames, Irwin L.James, JeromeJames, JulieJarvis, GaryJarvis, LeroyJean, AndreJean, LarryJeffers, StephenJeffers, Wilfred Z.Jeffrey, CrystalJeremiah, FrankJimenez, DavidJn-Marie, EugeniaJno-Baptiste, NicholasJno-Finn, MichaelJoaquin, JosephJohn, AgnesJohn, GertrudeJohn, JoanJohn, Michael C.John, SylvesterJohn-Baptiste, ArthurJohn-Baptiste, BernadineJohnson, Juana L.Jonas, WinifredJoseph, Bernett

Joseph, ElwinJoseph, Emil Joseph, GeorgeJoseph, GraceJoseph, JudithJoseph, KennethJoseph, MagiltaJoseph, MargaritaJoseph, PhillipaJoseph, Selwin GeorgeJoseph, St GeorgeJoseph, TheresaKing, ClaudetteKnight, EvertonLanguedoc, ClementLansiquot, EnnoLaurencin, AnthonyLawrence, RosettaLazare, LouiseLazare, MaynardLeblanc, Alex G.Ledesma, FelipeLeon, AybertLeon, JoannaLeon, MaryLeon, MichaelLeonce, HerbertLeonce, PhylisLestrade, RebeccaLiburd, DaveLiburd, HenrekerLinares, AbigailLing, Michael LeeLlanos, VeronicaLongville, MaryLopez, CarmenLopez, MaishaleenLopez, MymaLopez, MyrnaLopez-Acosta, JoseLopez-Quintana, JuanLouis, AgathaLouis, CorneliaLubin, Jonah N.Lucille, MaryMaharaj, Devraj


Malaykhan, EyajieManie, JohnMarcelle, LuciaMarquez, DayanaMarquez, SigfredoMars, AliciaMarsh, Jane M.Marte, Eladia Flaviana MenaMartin, TelbertMartina SimeinaMartinez, EstherMartinez, HectorMassicot, EricMassicott, Jeannoel S.Massicott, MerlynMateo, Joan Manuel MenaMathurin, BernardMathurin, GregoryMathurin, PatriciaMatthew, Fitzroy B.Matthew, Michael ElsworthMaxwell, MaryMaxwell, WeldonMayfield, CarmenMaynard, CarolynMaynard, JamesMaynard, Nadean V.McBean, JanineMcFarlane, CaniceMcIntosh, DanielMcIntosh, LydiaMcKenzie, JennieMcKenzie, VernonMcMahon, VincentMcNamara, JamesMelius-Michaud, VirginiaMenders, Reynard D., Sr.Mendez, LoanmiMerced, EdgarMerced-Green, LucetteMess, JosephMichael, ColettaMicheau, Julian L.Miller, Delroy E., Sr.Miller-Lloyd, WilmaMitchell, Alfred

Mitchell, ClaytonMitchell, CorneliusMitchell, GemmaMitchell, MarianMoe, RussellMohansingh, KadarMondesir, FrancesMondesir, Viviane CharlesMonrose, VictorMontoute-Dumar, ClaritaMoore, Gary A.Moore, StevenMorla, FreddyMoses, GodcliveMoses, JeromeMulrain, Carlos P.Munchez-Nurse, Barbara A.Murray, Anne Marie P.Murray, MichaelNales-Martinez, NormaNandlal, BasilicaNavarro, Guillermo RiveraNelson, ClementNelson, GerardNewton, SharonNicholas, Sandra A.Nieves, JoelNieves, Jose A., IIINieves, SoniaNisbeth, EdricNobbie, AinsleyNoelien, JoycelineNoorhasan, ShaneNorford, DerrickNyack, MarilynO’Bryan, NinaOctalien, Norbert C.Oliver, PedroOrta, YaralizOsorio, Pedro, Jr.Ozoria, VictorPacheco, KarinaParris-Bruce, NormaParris-Delgado, AnnettePaul, AnthonyPaul, John


Paul, PhillipPena-Arrendell, ArelisPeralta, QuermanPerez, SantaPerez-Rivera, AbrahamPeter, MichaelPeterson, LucienPhangyou, Carl PJPhangyou, RobertPhangyou, TabitaPhillip, CatherinePhillip, VaughnPhillips, PatrickPhilogene, BibianaPhilogene, LawrencePilier, AntonioPilier, DemetrioPilier, LeandroPilier, LizandroPilier, LizangelPlante, MarionPoleon, AngelaPoleon, CelinaPoleon, JohnPoleon, YviePowell, CharlesPrescott, JosephPresident, WinifredPrevost, FlorettaPrime, HollisProsper, ElpherRambally, BrianRamdhanny, JohnRamos, BrunildaRamos, JosefinaRandolph-Victor, LauraRaphael, DerekRaphael, MarthaRaphael, ThomasRas, LuisRaymond, ZeniaReid, AvisRene, CoriaRennie, LloydRennie, RonnieReuben, Aaron

Reyes, ConfesorRichardson, CherylRichelieu, GregorRichelieu, Gregory E.Richelieu, MargaritaRichelieu, Verna RitaRijo, MarcoRios, FelipeRivera, JoseRivera, Jose M.Rivera, Luis, Jr.Rivera, Luis, Sr.Rivera, SandroRivera, SantosRivera, TeresaRivera-Lopez, SantosRiviere, AnnabelleRoa, BasilioRoberts, Aldora FlemingRoberts, Cuthbert F.Roberts, DarriyenRoberts, KendallRoberts, Roger A.Robertson, LintonRobles, AngelaRobles, MaicangelRobles, NatashaRodriguez, AngelRodriguez, IsraelRodriguez, LeonardRodriguez, MariaRodriguez, SerafinRodriguez, Serafin, Jr.Romain, AndrewRosa, SoniaRosario, AnaRose, EustaceRoseline, EleanorRussell, HulesterSadoo, RicardoSam, Reginald A.Samuel, Richard A.Samuel, VirginiaSanchez, JoseSanes, MariaSantiago, Bernabe, Jr.


Santiago, CarmenSantiago, ChayanneSantiago, LuisSantiago, MaynalysSantiago, ShanequaSantos-Rios, AngelSargeant, PatronellaSargeant, PetronellaSargeant, VincentScotland, MariskaSealey, RonaldSeecharan, AlvanSerieux, MarieShirley, HelenSilvestre, Juan RiverasSimon, EnochSimon, LesroySmith, AnthonySmith, James A.Solomon, RodneySonny, JosephSonson, AlvinSookoo, RichieSoto, JorgeSoto-Nieves, IrmaSoto-Santos, EfraimSt. Henry, Norris RupertSt. Jean Wong, MeredithSt. Remy, FrancoisSt. Rose, Alexander St. Rose, GerardSt. Rose, GertrudeSt. Rose, MarySt. Rose, SaraphineSt. Rose, VirginiaStanislas, AlbertStanislas, MarinaStanley, EugeniaStephenson, EugeneStevenson, ElsworthStraker, CoraSubniak, DiananSusino, CarmelaSwanston, ArleneSydney, JohnSykes, Eric

Talian, Lucy C.Tann, ReneeTayliam, AlbertTaylor, MacDonaldTheobbles, EstherTheodile, RuthineTheodore, RoselynTheodule, ElizabethTheophilus-Phillipp, Alita V.Thomas Peters, AnitaThomas, ClaudiusThomas, Franklyn M.Thomas, JoycelynThomas, MichaelThomas, Patrick NelsonThomas, SandyThomas, ThomasThomas-Cooke, CheryannThomas-Eastman, JacquelineThorpe, CharlineTitre, CyrilTorgerson, BruceTreasure, FerdinandTreasure, MelroseTrimmingham, DoritaTurnbull-James, LyneTutein, JoelTutein, WilmaVega-Vargas, PercioVelazquez, Ada L.Velazquez, AndresVelazquez, RitaVernage, MatthewVictor, AlbertVictor, CosmosVictor, Fenton CurtisVictor, MarkVictor, MarthaVictor, RubenVigilant, LesterVigilant, TimothyViotty, RollinVitalis, MathurinWallace, EltonWalter, DavonWalters, Shawn


Weekes, ReubenWeeks, Mary AnnaWeston, TheclaWheeler, Joseph C.Wheeler, StephanieWhite, ClydeWickham, Sean IanWilliam, AugustineWilliam, John B.Williams, Albert J.Williams, Anderson LeroyWilliams, AnthonyWilliams, BernardWilliams, BerylWilliams, Carol G.Williams, Ira S.Williams, LennardWilliams, Leonox L.Williams, Lequani L.Williams, MerleWilliams, SpencerWilliams, ThomasWilliams, VincentWilson, AlfredWilton, MargueriteWiltshire, ChristinaWiltshire, Susan GumbsWoodley, VictoriaWoodrupp de Almonte, Andrea C.Woods, BenjaminXavier, RosaYounge, EveretteYounge, Grantley A.


SCHEDULE 1(i)

Plaintiffs’ Firms

Burns Charest LLPEarly Law Firm LLC, TheGori Law Firm PC, TheHarris & Huge LLCLaw Office of Ryan W. GreeneLee J. Rohn & Associates LLCMaune Raichle Hartley French & Mudd LLCMeirowitz & Wasserberg LLPMurray Law FirmPate Law Firm, ThePorter Hedges LLPThomas Alkon PCWaters & Kraus LLP


SCHEDULE 1(j)

Co-Defendants

4520 Corp. Inc.ABB Inc.Abex Corp.AECOM E&C Inc.AECOM Energy & Construction Inc.AERCO International Inc.Air & Liquid Systems Corp.Akzo Nobel Chemicals LLCAkzo Nobel Functional Chemicals LLCAkzo Nobel Inc. Allen-Bradley Co.Alliance Machine Co. Inc., TheAllied Insulation Supply Co. Inc.Alltite Gaskets Co.Alton Box Board Co.American Boiler Tank & Welding Co. Inc.American CyanimidAmeron International Corp.Amphenol Corp.Armstrong International Inc.Armstrong Pumps Inc.ArvinMeritor Inc.AstenJohnson Inc.Atlas Copco Compressors LLCAtlas Copco North America LLCAtwood & Morrill Co.Aurora Pump Co.AWT Air Co. Inc.BASF Corp.BBC Brown BoveriBechtel Corp.Bigelow-Liptak Corp.Blackmer & Roger Pump Co.Blackmer Pump Co.BMCE Inc.BMW Constructors Inc.Borden Chemical Inc.Borg-Warner Morse TEC LLCBrake Parts Inc. LLCBuffalo Pumps Inc.Burnham LLCBWIP Inc.

Carboline Co.Carver Pump Co.Cashco Inc.CBS Corp.CDI Corp.CertainTeed Corp.Chevron USA Inc.Chicago Bridge & Iron Co.Chicago Gasket Co.Chicago Pneumatic Tool Co. LLCChicago Wilcox Manufacturing Co.Clark-Reliance Corp.Cleaver Brooks Co. Inc.Cleaver-Brooks Inc.ClemcoClyde Union Inc.CNA Holdings LLCCoca-Cola Co., TheConocoPhillips Co.Consolidated Edison Co.Continental Automotive Systems Inc.Cooper Industries LLCCorrigan Company Mechanical ContractorsCrane Co.Cutler-Hammer Inc.Cyprus Amax Minerals Co.DAP Products Inc. deVan Sealants Inc.Dow Chemical Co.Dow Chemical Co., TheDurametallic Corp.EagleBurgmann Industries LPEaton Corp. plcEcodyne Corp.Edward Valves Inc.ElectroluxEntergy Corp.Essex Specialty Products LLCExxonMobil Oil Corp.FirstEnergy Corp.FlowserveFlowserve US Inc.


Fluor Corp.Fluor Enterprises Inc.FMC Corp.Ford Motor Co.Formosa Plastics Corp. USAFort Kent HoldingsFoster Wheeler Corp.Foster Wheeler LLCGardner Denver Inc.General Electric Co.General Engineering Corp.Geo P. Reintjes Co. Inc.Glencore Ltd.Goodyear Tire & Rubber Co., TheGorman-Rupp Co., TheGoulds Pumps LLCGreene Tweede & Co.Grinnell LLCGuard-Line Inc.Hauck Manufacturing Co.Hawkins Parnell & Young LLPHercules LLCHexion Inc.Hollingsworth & Vose Co.Honeywell Honeywell International Inc.Howden North America Inc.Huntington Ingalls Industries Inc.Hydro-ChemICI Americas Inc.IMO Industries Inc.Industrial Holdings Corp.Ingersoll Rand Co.Inmont Corp.International Paper Co.ITE Electrical Products Co.ITT Corp.ITT LLCJersey Central Power & Light Co.JM Eagle Inc.JM Manufacturing Co. Inc.John Crane Inc.John Zink Co. LLCJohnson Controls Inc.Kaiser-Gypsum Co. Inc.KC Wall Products Inc.

KCG Inc.Keeler-Dorr Oliver Boiler Co.Kennedy Valve Manufacturing Co.Krogh Pump Co. Inc.La Mirada Products Co. Inc.Linde Engineering North America LLCLitwin Corp.Lockheed Martin Corp.Magnum ProductsMarley Cooling TowerMcCanna Corp.McMaster-Carr Supply Co.Mead Corp., TheMeadWestvaco Corp.Metropolitan Life Insurance Co.Metso Minerals Industries Inc.Milton Roy Co.Minute Maid Co.Monsanto Co.Mount Vernon Mills Inc.Mueller Co. LLCMueller Steam SpecialtyMW Custom Papers LLCMW Kellogg Co., TheNash Engineering Co., TheNooter Corp.Nordstrom Valves Inc.Occidental Chemical Corp.Overseas Shipbuilding GroupPfizer Inc.Phillips 66 Co.Pneumo Abex LLCPNM Resources Inc.PSEG Fossil LLCPublic Service Electric & Gas Co. Resal Inc. Resco Holdings LLCResearch-Cottrell Inc.Reunion Industries Inc.Rew Materials Inc.RIC-WIL Inc.Riggers & Erectors International Inc.Riley Power Inc.Rockwell Automation Inc.Rockwell Manufacturing Co.Ross Operating Valve Co.


Rostone Corp.RUCO EquipmentSaint-Gobain Abrasives Inc.Salem Furnace Co.Schneider Electric SESequoia Ventures Inc.Shaw Group Inc., TheSherwin-Williams Co., TheSiemens Industry Inc.Spence Engineering Co. Inc.Spirax Sarco Inc.Sprinkmann Sons Corp.SPX Cooling Technologies Inc.Sterling Fluid Systems (USA) LLCStubbs OverbeckSulzer Pumps (US) Inc.Swindell-Dressler Corp.Taco Inc.Tenova Core Inc.Tenova SpATexaco Inc. Tnemec Co. Inc.Trane US Inc.Treco Construction Services Inc.Turner Construction Co.Turner St. Croix Maintenance Inc.Union Carbide Corp.Universal Refractories Inc.US Power Generating Co. LLCVelan Valve Corp.Vellumoid Inc.ViacomCBS Inc.Viad Corp.Vickers Inc. Viking Pump Inc.Vimasco Corp.Warren Pumps LLCWarren Rupp Inc.Watts Water Technologies Inc.Welco Manufacturing Co.WestRock RKT Co.William Powell Co., TheWTI Rust Holdings Inc.Wyatt VI Inc.York International Corp.Yuba Heat Transfer LLC

Zinclahoma Inc.Zurn Industries LLC


SCHEDULE 1(k)

Debtor’s Proposed Professionals and Affiliates’ Professionals

Bankruptcy Management Solutions Inc.Beckstedt & Kuczynski LLPHaynes and Boone LLPJackson Walker LLPKirkland & Ellis LLPPiper Sandler & Co.Stretto, Inc.Wilson Elser Moskowitz Edelman & Dicker LLP


SCHEDULE 1(l)

U.S. Trustees’ Office

Boykin, JacquelineDuran, HectorGriffin, BarbaraHobbs, Henry G., Jr.Johnson-Davis, LuciMcCullar, AliciaMotton, LindaOtto, GlennRuff, Jayson B.Schmidt, PatriciaSimmons, ChristySmith, GwenStatham, StephenWaxton, ClarissaWhitworth, Jana


Schedule 2

Bates White Prior or Current Affiliations For Services Provided For or on Behalf of Potential Parties in Interest



Hess CorporationBurns Charest LLPKirkland & Ellis LLPOffice Of The Attorney General for the State of IllinoisKaiser Gypsum Company, Inc.Linde AGOffice Of The Attorney General for the State of New YorkOccidental Chemical CorporationPfizer, Inc.PNM Resources, Inc.RILEY POWER INC., f/k/a RILEY STOKER CORPORATIONRockwell Automation Inc as successor in interest to the Allen Bradley Company incorrectly named Rockwell Automation Inc f/k/a Allen Bradley Company Inc., individually and as successor in interest to Rostone CorporationThe Coca-Cola Company, Individually and as Successor-in-Interest to Minute MaidGoodyear Tire & Rubber Co.John Crane IncSiemens Industry Inc.Velan Valve CorporationViad CorpWarren Pumps LLC3M a/k/a Minnesota Mining & Manufacturing CompanyAIGCarrier CorporationCertainTeed CorporationFoster WheelerGarlock, Inc.Internal Revenue ServiceLockheed Martin Corporation Arrowpoint Capital (Formerly Royal Insurance)Securities and Exchange Commission (SEC)The Travelers Companies Inc.Westinghouse electric Corporation n/ka/ Viacom, Inc.Wilson Elser Moskowitz Edelman & Dicker LLPSaint-GobainViacom, Inc.Koch IndustriesAkzo Nobel Coatings, Inc.American CyanamidGeneral Electric CompanyHawkins Parnell & YoungHercules LLCElectroluxUnion Carbide Corporation (UCC)


2

American Standard IndustriesAurora PumpThe Dow Chemical CompanyEssex Chemical CorporationExxon MobilFirstenergy CorporationFlowserve CorporationFord Motor CompanyHoneywell International Inc.Howden North America, IncIngersoll RandInternational Paper CompanyITT CorporationSherwin-WilliamsTrane Co.Armstrong InternationalBeaconMEdaes, a division of Atlas Copco ABBASF Corporation Blackmer Pump CompanyCashcoCBS CorporationChevron Environmental Management CompanyChevron de Puerto Rico, LLC Cleaver-BrooksCNA Holdings LLCCooper Industries, LLCIMO IndustriesElliott Company, a division of CarrierConsolidated Edison CompanyGrinnellPNEUMO Abex LLC, Successor in Interest to Abex Corporation



HOUSTON DIVISION



)Debtor. )

)) Re: Docket No. __

ORDER (A) AUTHORIZING THE RETENTION AND EMPLOYMENT OF BATES WHITE, LLC AS ASBESTOS CONSULTANTS


Upon the application (the “Application”)2 of the above-captioned debtor and debtor in

possession (the “Debtor”) for entry of an order (this “Order”), (a) authorizing the retention and

employment of Bates White, LLC (“Bates White”) as asbestos consultants in the Debtor’s

chapter 11 case effective as of the Petition Date (as defined below) and (b) granting related relief,

all as more fully set forth in the Application; and upon the First Day Declarations; and this Court

having jurisdiction over this matter pursuant to 28 U.S.C. § 1334; and this Court having found that

this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found that it

may enter a final order consistent with Article III of the United States Constitution; and this Court

having found that venue of this proceeding and the Application in this district is proper pursuant

to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in the

Application is in the best interests of the Debtor’s estate, its creditors, and other parties in interest;

and this Court having found that the Debtor’s notice of the Application and opportunity for a


2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Application.


-14-

hearing on the Application were appropriate and no other notice need be provided; and this Court

having reviewed the Application and having heard the statements in support of the relief requested

therein at a hearing before this Court (the “Hearing”); and this Court having determined that the

legal and factual bases set forth in the Application and at the Hearing establish just cause for the

relief granted herein; and upon all of the proceedings had before this Court; and after due

deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT:

1. The Application is GRANTED.

2. The Debtor is authorized to retain and employ Bates White as asbestos consultants

in this chapter 11 case effective as of the Petition Date, pursuant to section 327(a) of the

Bankruptcy Code and Bankruptcy Rule 2014 on the terms and conditions set forth in the

Application and the Engagement Letter attached hereto as Exhibit 1.

3. Bates White shall be compensated for its services and reimbursed for any related

expenses as set forth in the Application and the exhibits thereto, and in accordance with applicable

provisions of the Bankruptcy Code, the Bankruptcy Rules, the Bankruptcy Local Rules, the Interim

Compensation Order, and any other applicable orders or procedures of this Court.

4. Bates White shall: (a) complete its reconciliation of prepetition fees and expenses

actually incurred for the period prior to the Petition Date no later than the filing of its first interim

fee application in this chapter 11 case; (b) make a corresponding adjustment to the amount of

the Retainers on or about that date, as described in the Application and the exhibits thereto; and

(c) disclose such adjustment in its first interim fee application. Subject to the foregoing adjustment

and the terms of the Interim Compensation Order, Bates White is authorized to hold any remaining

amount of the Retainers following such reconciliation as security for the payment of postpetition

fees and expenses.


-15-

5. Bates White shall not apply any portion of the Retainers to fees and expenses

incurred from and after the Petition Date unless and until authorized to do so by a further order of

this Court, including the Interim Compensation Order.

6. Notwithstanding any contrary provision of the Engagement Letter, the Court shall

have jurisdiction over, hear, and adjudicate any dispute that may arise under the Engagement

Letter among the parties to the Engagement Letter during the pendency of this chapter 11 case.

7. Paragraph 15 of the Engagement Letter (the “Limitation of Liability Provision”) is

hereby stricken.

8. To the extent that this Order is inconsistent with the Engagement Letter, the terms

of this Order shall govern.

9. This Order shall immediately be effective and enforceable upon its entry.

10. Notice of the Application as provide therein shall be deemed good and sufficient

notice of such Application, and the notice requirements of the Bankruptcy Rules and the

Bankruptcy Local Rules are satisfied by such notice.

11. The Debtor is authorized to take all actions necessary to effectuate the relief granted

in this Order.

12. This Court retains exclusive jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Order.

Houston, TexasDated: ___________, 2022

UNITED STATES BANKRUPTCY JUDGE


Exhibit 1

Engagement Letter


2001 K Street, NW, North Building, Suite 500, Washington, DC 20006 main 202.408.6110 fax 202.408.7838

BATESWHITE.COM

April 15, 2022 Via Electronic Mail Michael F. Williams, P.C. Kirkland & Ellis LLP 1301 Pennsylvania Ave., NW Washington, D.C. 20004 T: 202.389.5123 [email protected]

Re: Claims evaluation on behalf of Hess Oil New York Corp.

Dear Mr. Williams: 1. Thank you for selecting Bates White, LLC (“Bates White”) to provide expert services to Kirkland

& Ellis LLP (and its affiliated entity Kirkland & Ellis International LLP (collectively, “Kirkland”)) on behalf of your client, Hess Oil New York Corp. (“HONYC”), in the above-referenced matter. This letter sets forth the terms of this engagement.

2. Bates White understands that its work product under this arrangement is being prepared in

connection with the above matter. Bates White will treat all communications with HONYC and/or its counsel, including Kirkland, and all information provided by HONYC and/or its counsel (including Kirkland) as privileged and confidential, and Bates White will use such information solely for the purpose of performing its obligations under this agreement. Unless otherwise agreed, Bates White will treat any reports, memoranda, or other documents that it prepares in connection with this matter as attorney work product. Such case-specific materials prepared by Bates White for HONYC in connection with this matter (the “Deliverables”) will be the property of HONYC and will be segregated and maintained separate from Bates White’s other work for other clients so that the confidentiality of these matters can be maintained. Bates White shall not disclose to third parties any materials that it prepares in connection with this matter or any communications with or information provided by HONYC and/or its counsel (including Kirkland) unless such disclosure has been authorized by HONYC or Kirkland, or a court or some other lawful process has required disclosure. Information or documents provided by HONYC that are or become publicly available (other than as a result of a disclosure by Bates White in violation of this agreement) shall not be considered confidential.

3. Notwithstanding the foregoing, all methodologies, procedures, management tools, software, data

files, concepts, ideas, inventions, know-how, reports, documents, materials, and other intellectual capital (“Bates White intellectual property”) that Bates White has developed, created, or acquired


Michael F. Williams, P.C. April 15, 2022 Page 2 of 7

prior to performing the above-described services, or such Bates White intellectual property of general purpose and utility that Bates White develops, creates, or acquires during performance of the above-described services, are and shall remain the sole and exclusive property of Bates White, and neither Kirkland nor HONYC shall have or acquire any right, claim, title or interest in or to any such intellectual capital.

4. Bates White shall take direction from Kirkland regarding the scope of work and as to the manner in which its work is presented and its Deliverables are prepared and presented. HONYC agrees that Bates White may take direction from Kirkland without notification to or approval or concurrence from HONYC.

5. The project team at Bates White will be headed by me and will include other professional and

administrative staff resources as appropriate. Our fees are based upon the time actually spent by each assigned Bates White Partner and employee at their hourly billing rate.

6. Our current rates for Bates White personnel range from $210.00 to $1,600.00 per hour. Rates may

be adjusted from time to time, typically annually at the end of a calendar year and upon promotion of staff. Kirkland, on behalf of HONYC, agree in advance to such annual adjustments. Bates White has a wealth of experts, including economists and affiliated academics widely recognized in their fields, who have developed significant expertise in many different fields over many years, and from time to time, those experts may provide strategic consulting advice on this matter. That advice will be billed on an hourly basis, except as otherwise agreed. In addition to professional fees, our bills will include out-of-pocket expenses that Bates White incurs on HONYC’s behalf, such as travel, electronic invoicing charges from third party vendors, and other case-specific charges. Kirkland and HONYC acknowledge that the reputation of Bates White’s experts is important to those experts and to Bates White, and agree to oppose fully, at HONYC’s expense and with Bates White’s involvement, any motion to exclude or limit expert opinions offered by Bates White experts.

7. HONYC will pay Bates White directly. Invoices will be presented for each month’s efforts and

are due upon presentation. Our invoices will contain the total hourly charges by timekeeper for the period covered by the invoice plus a summary of expenses. Invoices paid within thirty days (30) of receipt will receive a 5% prompt-pay discount. Invoices will be sent to HONYC, with a copy to Kirkland if requested. HONYC agrees to pay interest at a rate of 1.0% per month on all account balances over sixty (60) days past due. In the event you or HONYC dispute an amount due on an invoice, you or HONYC agree to communicate such disagreement to me, in writing,



within thirty (30) days of the invoice date, and for HONYC to pay the undisputed portion within thirty (30) days. Failure by you or HONYC to communicate a disagreement regarding the amount due on an invoice within thirty (30) days of the invoice shall constitute a waiver of any such disagreement. In the event that HONYC’s account becomes overdue in excess of sixty (60) days or HONYC refuses to pay in whole or in part for work performed, Bates White reserves the right to withhold further services. Bates White requires that all invoices more than thirty (30) days outstanding be paid prior to any deposition, hearing appearance or courtroom testimony. Kirkland is not and will not be responsible for the payment of Bates White’s fees and costs absent written agreement to the contrary.

8. If it becomes necessary for HONYC to file a petition under chapter 11 of the Bankruptcy Code,

the ongoing employment of Bates White will be subject to the approval of the bankruptcy court with jurisdiction over the petition. If necessary, Bates White will modify the terms and conditions of employment described above as may be required to comply with the applicable requirements of the bankruptcy process, including any orders of the bankruptcy court.

9. Should this matter become subject to bankruptcy court payment processes, subject to the approval

of the bankruptcy court as described above, then payment terms would be modified as follows. The timing of payment regarding the portion of invoices not subject to any holdback provisions will dictate the prompt-pay discount and interest accrual for the entire balance of the invoice. For example, invoices for which HONYC pays the balance not subject to a holdback provision within thirty (30) days of the payment date included in the bankruptcy court payment process would receive the 5% prompt-pay discount for the entire balance of the invoice, regardless of when the court approves payment of the funds subject to the holdback provision. Interest shall not apply to portions of invoices subject to a holdback provision until after thirty (30) days after the later of the date the court approves payment of the funds subject to the holdback provision and the deadline for making the holdback payment set forth in the bankruptcy court payment process.

10. Upon request, Bates White will provide Kirkland or HONYC with an estimated budget for the services. Any estimate of anticipated fees and costs will be our best estimate of the effort required to complete the work based upon the information available to Bates White at the time it is made. Under no circumstances shall any such estimate be considered a maximum fee or an offer to perform the services on a fixed fee basis.

11. Except as otherwise may be required by law, it is Bates White’s policy to return or destroy documents and data provided by Kirkland or HONYC, or subject to protective orders, at the



conclusion of the engagement. Therefore, Kirkland or HONYC will notify Bates White promptly upon the closing of this matter and provide direction to Bates White with respect to disposition of such documents. If Kirkland or HONYC requests the return or destruction of its documents, Bates White will return or destroy them at HONYC’s expense. If Kirkland or HONYC does not provide such direction within the earlier of thirty days (30) days of the conclusion of the engagement or fourteen (14) days prior to the deadline for compliance with the terms of the applicable protective order, Bates White may return or destroy such documents at HONYC’s expense without further notice or liability.

12. Bates White is not aware of anything that would impair our ability to provide independent and

objective services in this matter. Kirkland and HONYC acknowledge that Bates White is engaged by many different clients, ranging from corporations to other business entities, law firms, and government entities, including those with adverse, competitive or opposing interests. Kirkland and HONYC agree that Bates White may be engaged by parties adverse to HONYC or Kirkland, or with interests adverse to those of HONYC or Kirkland, in matters other than the present one. Kirkland and HONYC further acknowledge that Bates White remains free to perform work in matters other than the present one that is similar, in subject matter or otherwise, to that requested by you in this matter. Bates White is not required to advise Kirkland or HONYC of such engagements. Bates White is committed to protecting the confidential information of clients, and Bates White may establish internal walls if deemed necessary in Bates White’s discretion and at such time as Bates White deems necessary and appropriate.

13. Any dispute, claim or controversy between Bates White on the one hand and Kirkland or

HONYC on the other hand, arising out of or relating to this agreement, whether sounding in contract, tort (including, but not, limited to malpractice) or otherwise, including the breach, termination, enforcement, interpretation or validity thereof, and including the determination of the scope or applicability of this agreement to arbitrate and all issues relating to whether a dispute, claim, controversy, or party is subject to arbitration, shall be determined in binding arbitration. The arbitration shall be before a single arbitrator and shall be administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedure then in place and effect. Such arbitration shall take place in Washington, DC. The substantially prevailing party shall be entitled to fees and costs incurred in the arbitration. Judgment on the award may be entered in any court of competent jurisdiction.

14. This agreement shall be governed by and construed in accordance with the laws of the District of

Columbia without respect to its conflicts of laws principles. Each of the parties hereby consents to



submit itself to the exclusive jurisdiction of the federal and local courts located in Washington, DC in any suit, action, or proceeding arising out of or relating to this agreement that could not be resolved by the parties in accordance with the arbitration process set out above. In any proceedings brought to enforce the terms of this agreement, the substantially prevailing party shall be entitled to fees and costs incurred including, without limitation, reasonable attorneys’ fees.

15. The parties shall not be liable to one another for any claim, whether sounding in contract, tort,

(including but not limited to malpractice), or otherwise, including a claim arising out of the breach, termination, enforcement, interpretation, or validity of this agreement, for indirect, special, consequential, or exemplary damages.Bates White shall not be liable for direct damages in excess of the lesser of two times the fees paid or $250,000 with respect to services performed under this letter, except to the extent of Bates White’s gross negligence, willful misconduct, or fraud.

16. Unless extended in writing (or unless earlier terminated as provided below), this engagement will

terminate upon the earliest of (a) the end of the matter described in this letter, (b) the conclusion of our work on the matter, or (c) written notification by Bates White, Kirkland or HONYC that the agreement is terminated. In any event, unless we agree otherwise in writing, this engagement will be deemed terminated if the matter has been inactive and Bates White has had no occasion to perform any expert services in connection with it for a period of one year.

17. Kirkland, HONYC or Bates White may terminate this agreement upon seven (7) days written

notice. In the event of termination by Kirkland, HONYC, or Bates White, HONYC continues to be responsible for payment for work performed up to and including the date of termination, and such payment shall be due immediately.

18. Kirkland represents and warrants that it has the authority from HONYC to enter this agreement

on HONYC’s behalf and to bind HONYC to all of its terms.

19. The parties agree that paragraphs 2, 3, 7, 11, 12, 13, 14, 15, 17, and 18 survive the termination of

this Agreement.

20. Bates White undertakes that Bates White will not, and will ensure that any person acting on Bates White’s behalf in connection with this retention (including, without limitation employees, affiliates and agents) does not:



• offer, promise or give any financial or other advantage to any person with the intention of influencing a person (who need not be the recipient of the advantage) to perform his or her function improperly, or where the acceptance of such advantage would itself be, or might be seen to be, improper; or

• offer, promise or give any financial or other advantage to a foreign public official (or to any other person at the request of, or with the acquiescence of, a foreign public official) with the intention of influencing that official in the performance of his or her public functions, in either case with a view to obtaining or retaining business or any form of commercial advantage either for Kirkland or for HONYC in connection with this retention.

21. If this letter correctly states our arrangements, please sign below where indicated and return it to our attention.


Michael F. Williams, P.C. April 15, 2022

Sincerely,

Bates White, LLC

Charles H. Mullin, PhD Partner

Kirkland & Ellis LLP on behalf of Hess Oil New York Corp.

By: ____ _________ __ Michael F. Williams, P.C.

Dated: --------- -------

Hess Oil New York Corp.

By:

Dated: 'f- / ff- J 2-

Page 7 of 7

4/19/22


Exhibit A

Evans Declaration


IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

)

In re: ) Chapter 11

)

HONX, INC.,1 ) Case No. 22-90035 (MI)

)

Debtor. )

)

DECLARATION OF ANDREW R. EVANS CFA IN SUPPORT OF DEBTOR’S

APPLICATION FOR ENTRY OF AN ORDER (A) AUTHORIZING RETENTION

AND EMPLOYMENT OF BATES WHITE, LLC AS ASBESTOS CONSULTANTS


I, Andrew R. Evans, under penalty of perjury, declare as follows:

1. I am the Practice Chair of the Environmental and Product Liability Practice at Bates

White, LLC (“Bates White”), which maintains offices at 2001 K Street NW, North Building, Suite

500, Washington, DC 20006. A copy of my curriculum vitae is attached hereto as Exhibit 1.

2. I am duly authorized to make this Declaration on behalf of Bates White. I make

this Declaration in support of the Debtor’s Application for Entry of an Order (A) Authorizing

Retention and Employment of Bates White, LLC as Asbestos Consultants Effective as of the

Petition Date and (B) Granting Related Relief filed contemporaneously herewith

(the ”Application”).2 The facts set forth in this Declaration are personally known to me and, if

called as a witness, I could and would testify thereto.

1 The Debtor in this chapter 11 case, along with the last four digits of the Debtor’s federal tax identification number,

is HONX, Inc. (2163). The location of the Debtor’s service address in this chapter 11 case is: 1501 McKinney

Street, Houston, Texas, 77010.

2 Capitalized terms not otherwise defined herein have the meanings given to them in the Application.


-2-

Qualifications


services relating to the economic analysis and estimation of mass tort claims. Bates White has

considerable experience with, and knowledge regarding, asbestos claims and valuation. In

addition, this engagement is expected to be led by highly experienced experts, myself and

Dr. Charles. H. Mullin. Dr. Mullin’s curriculum vitae is attached hereto as Exhibit 2.

4. I am a CFA Charterholder and have more than 19 years of experience in providing


Included among the matters in which I have provided or am currently providing asbestos-related

expert testimony or related services are the bankruptcy cases of In re Aldrich Pump, In re Owens

Corning, In re Paddock Enterprises, In re Specialty Products Holding Corp., and In re The

Fairbanks Company. 3 In addition, I have testified in numerous insurance and reinsurance

coverage disputes dealing with asbestos and other mass torts and provided valuations in

bankruptcies involving mass torts other than asbestos, such as in In re Boy Scouts of America and

In re USA Gymnastics (both of which relate to sexual abuse claims), In re Blitz U.S.A., Inc.

(relating to allegedly defective gas cans), and In re TK Holdings Inc. (relating to defective

airbags).4

5. Dr. Mullin has more than twenty years of experience in providing expert testimony

and guidance on litigation and business matters and has authored more than seventy‑five expert

3 In re Aldrich Pump LLC, Case No. 20-30608 (JCW) (Bankr. W.D.N.C. June 17, 2020); In re Owens Corning,

Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re Paddock Enterprises, LLC, Case No. 20-10028 (LSS)

(Bankr. D. Del. Jan. 6, 2020); In re Specialty Products Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del.

May 31, 2010); In re The Fairbanks Company, Case No. 18-41768 (PWB) (Bankr. N.D. Ga. July 31, 2018).

4 In re Boy Scouts of America and Delaware BSA, LLC, Case No. 20-10343 (LSS) (Bankr. D. Del. Feb. 18, 2022);

In re USA Gymnastics, Case No. 18-09108 (RLM) (Bankr. S.D. Ind. Dec. 5, 2018); In re Blitz U.S.A., Inc.,

Case No. 11-13603 (PJW) (Bankr. D. Del Nov. 9, 2011); In re TK Holdings Inc., Case No. 17-11375 (BLS)

(Bankr. D. Del. June 25, 2017).


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reports. Included among the matters in which Dr. Mullin has provided or is currently providing





and reinsurance coverage disputes and provided valuations in bankruptcies involving mass torts

other than asbestos, such as In re Blitz U.S.A., Inc. (relating to allegedly defective gas cans) and In

re TK Holdings Inc. (relating to defective airbags).6


6. Bates White will render economic consulting, claims valuation, and related services

to the Debtor as needed in connection with asbestos personal injury claims against the Debtor and

related potential costs and liabilities. These services may include, but are not limited to:

(a) performing due diligence and analysis regarding the Debtor’s

current, potential, and overall asbestos liability (both defense costs

and indemnity), including with respect to historical and projected

trends, econometric evaluations, market analysis, and evaluations

using other established methodologies;

(b) estimating the number and value of, and producing analysis with

respect to, present and future asbestos personal injury claims against

the Debtor;

(c) assisting the Debtor in negotiations with various parties regarding

the Debtor’s asbestos liability, including by evaluating proposals or

5 In re DBMP LLC, Case No. 20-30080 (JCW) (Bankr. W.D.N.C. Jan. 23, 2020); In re Leslie Controls, Inc.,

Case No. 10-12199 (Bankr. D. Del. Jul. 12, 2010); In re Motors Liquidation Company, Case No. 09-50026 (REG)

(Bankr. S.D.N.Y. June 1, 2009); In re Owens Corning, Case No. 00-03837 (Bankr. D. Del Oct. 5, 2000); In re

Plant Insulation Company, Case No. 09-31347 (TEC) (Bankr. N.D. Cal. May 20, 2009); In re Specialty Products

Holding Corp., Case No. 10-11780 (LSS) (Bankr. D. Del. May 31, 2010); In re Thorpe Insulation Company, Case

No. 07-19271 (SB) (Bankr. C.D. Cal. Oct. 15, 2007).

6 In re Blitz U.S.A., Inc., Case No. 11-13603 (PJW) (Bankr. D. Del Nov. 9, 2011); In re TK Holdings Inc., Case

No. 17-11375 (BLS) (Bankr. D. Del. June 25, 2017).


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potential proposals and providing analysis, information, and support

in connection therewith;

(d) advising the Debtor regarding the funding of any asbestos trust that

may be created pursuant to the Bankruptcy Code;

(e) advising the Debtor regarding financial issues that may impact the

valuation of asbestos claims;

(f) providing expert testimony and reports related to the foregoing and

assisting the Debtor in preparing and evaluating reports and

testimony by other experts and consultants; and

(g) providing such other advisory services as may be requested by

the Debtor.


7. Bates White is willing to serve as asbestos consultants and experts for the Debtor

and to receive compensation and reimbursement in accordance with its standard billing practices,

the provisions of the Engagement Letter, sections 330 and 331 of the Bankruptcy Code, the

Compensation Guidelines, the Interim Compensation Order, and any other applicable orders of

this Court. The Engagement Letter, a copy of which is attached as Exhibit 1 to the Order, specifies

that the Bates White retention is through Kirkland, who will provide direction as to the scope and

type of services Bates White is to provide. In any event, however, the Debtor is solely responsible

for the payment of services rendered by Bates White, along with payment of any related costs

under the terms of the Engagement Letter. See Engagement Letter ¶¶ 4, 7.



this Court.


White with a retainer totaling $50,000 for services rendered or to be rendered, and for



-5-






Billing Category Range

Partner (Andrew R. Evans) $825

Partner (Dr. Charles Mullin) $1,150

Partner $700 - $1,600

Principal $575 - $750

Managing Economist $545 - $650

Managing Consultant $500 - $625

Senior Economist $475 - $550

Senior Consultant $450 - $500

Economist $460

Consultant II $390 - $425

Consultant $365

Research Analyst $365 - $460

Project Coordinator $255

Research Assistant $210



are not subject to any bankruptcy holdback are paid within thirty days of the date they are due

7 Bates White will (a) complete its reconciliation of prepetition fees and expenses actually incurred for the period

up to the Petition Date no later than the filing of its first interim fee application in this chapter 11 case; (b) make

a corresponding adjustment to the amount of the Retainer on or about that date; and (c) disclose such adjustment

in its first interim fee application. Subject to the foregoing adjustment, Bates White requests authorization from

the Court to hold any remaining amount of the Retainer following such reconciliation as security for the payment

of postpetition fees and expenses, subject to the terms of any order establishing procedures for interim

compensation and reimbursement of expenses of retained professionals (any such order, the “Interim

Compensation Order”). Bates White will not apply any portion of the Retainer to fees and expenses incurred

from and after the Petition Date unless and until authorized to do so by a further order of this Court, including the

Interim Compensation Order.


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under the Interim Compensation Order or other applicable rules in this chapter 11 case, the Debtor

will receive a 5% prompt-pay discount for the entire invoiced amount. See Engagement Letter ¶ 9.

11. In addition, also subject to approval by this Court, Bates White shall submit for

reimbursement all of its reasonable out-of-pocket expenses in connection with this chapter 11 case.

12. No promises have been received by Bates White as to compensation in connection

with this chapter 11 case other than as outlined in this Declaration and the Application in

accordance with the provisions of the Bankruptcy Code. Bates White has no agreement with any

other entity to share any compensation received.

13. The terms of Bates White’s employment and compensation as described in this

Declaration, the Engagement Letter, and the Application are consistent with employment and

compensation arrangements typically entered into by Bates White when providing such advisory

services and, to the best of our knowledge, are competitive with those arrangements entered into

by other economic consulting firms when rendering comparable services.





11 case.


The parties shall not be liable to one another for any claim, whether sounding in contract,

tort, (including but not limited to malpractice), or otherwise, including a claim arising out

of the breach, termination, enforcement, interpretation, or validity of this agreement, for

indirect, special, consequential, or exemplary damages. Bates White shall not be liable for

direct damages in excess of the lesser of two times the fees paid or $250,000 with respect

to services performed under this letter, except to the extent of Bates White’s gross

negligence, willful misconduct, or fraud.


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Disinterestedness

17. Through Kirkland, the Debtor has provided us a listing of potentially interested

parties in this chapter 11 case (the “Potential Parties in Interest”), and such parties are listed on

Schedule 1 hereto. To the extent that information was available, we undertook a detailed, good

faith search to determine and to disclose, as set forth herein, whether we have provided or currently

provide consulting services to any significant creditors, insiders, or other parties-in-interest

identified by such list in any substantively unrelated matters.

18. In preparing this Declaration, Bates White staff, under my direction and control,

searched our database containing the names and matter descriptions of current and previous

engagements handled by our firm. To the extent the information is available, the search request

identified parties to whom Bates White has provided or currently provides services that also are

Potential Parties in Interest, which included significant creditors of the Debtor, significant

professional advisors to the Debtor, and other potential parties-in-interest in this chapter 11 case.

19. To the best of my knowledge and belief, Bates White has provided, or is currently

providing, consulting services to certain creditors of the Debtor (or affiliates of creditors of the

Debtor), equity security holders, or other parties-in-interest in matters unrelated to the Debtor or

this chapter 11 case, as described on Schedule 2 to this Declaration.

20. If Bates White discovers additional information that requires disclosure, we will

promptly file a supplemental disclosure with the Court.


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21. Bates White is not a creditor, equity security holder, or an insider of any of the

Debtor.

22. Neither Bates White nor any of Bates White’s professionals is, or was within two

years of the Petition Date, a director, officer, or employee of the Debtor.

23. Accordingly, to the best of my knowledge, information and belief, Bates White is

a “disinterested person” as such term is defined by section 101(14) of the Bankruptcy Code.


Pursuant to 28 U.S.C. § 1746, declare under penalty of perjury that the foregoing is true

and correct to the best of my information, knowledge, and belief.

Dated: May 1316, 2022

/s/ Andrew R. Evans

Andrew R. Evans CFA.

Practice Chair of the Environmental and

Product Liability Practice

Bates White, LLC

2001 K Street NW

North Building, Suite 500

Washington, DC 20006


Exhibit 1

Andrew R. Evans, CFA. Curriculum Vitae



Main 202. 408. 6110

ANDREW R. EVANS, CFA

Partner

AREAS OF EXPERTISE

• Contingency valuation


• Financial forecasting

• Liability valuation and hedging

• Reorganizations

• Economic analysis


Andrew R. Evans chairs Bates White’s Environmental and Product Liability Practice. He is a CFA charter holder

and a recognized expert on legacy liability valuation, financial risk assessment, and insurance allocation. He has

more than 18 years of experience providing advice and expert analysis on issues involving mass torts,

(re)insurance coverage, alternative risk transactions, mergers and acquisitions, and financial valuation matters

related to distressed operations and restructurings. Mr. Evans is currently the Practice Chair of the Environmental

and Product Liability Practice at Bates White, LLC.

Mr. Evans has authored expert reports and declarations as part of contract disputes, state insurance proceedings,

federal bankruptcy reorganizations, Alternative Dispute Resolutions (ADRs), mediations, and in support of

corporate valuations, mergers and acquisitions, and divestitures. He has facilitated settlements in coverage

disputes related to asbestos, environmental losses, and other toxic tort litigation that involved the retirement of

several billion dollars in total available coverage limits. Mr. Evans also advises insurers, investors, and corporate

strategists in litigation funding, and has particular expertise in risk management through the use of “ring-fencing”

and hedging structures.

EDUCATION

• Chartered Financial Analyst (CFA) charter holder

• AB, Woodrow Wilson School of Public Policy and Foreign Affairs, Princeton University

• Co-recipient of the R.W. van de Velde Prize for outstanding policy work

• Worked with the US Department of State as a Political Military Junior Officer and assisted with

negotiations involving nuclear weapons reductions and crisis intervention for the Kosovo Peace Plan

• Chief Administrator for a campus advertising business

SELECTED EXPERIENCE

• Retained as abuse claims valuation and insurance allocation expert by an insurance company in a set of

class action cases dealing with hazing and sexual abuse claims: 2022–present.



• Served as consulting advisor on talc valuation related issue to the Debtor in In re LTL Management LLC, No.

21-30589 (MBK) (Bankr. D.N.J.): 2021–present.

• Retained as valuation consultant to advise corporate board of foreign based company on US-based liability

management options: 2021–present.

• Retained as abuse claims valuation expert by an insurance company in a dispute related to the valuation of a

group of sexual abuse claims resulting in settlement: 2021-2022.

• Authored expert report and testified at a binding arbitration subject to American Arbitration Association rules

on behalf of an insurance joint defense group in a defense fee dispute for coverage of sexual abuse-related

defense fees: 2021–2022.

• Retained by Debtors and participated in successful mediation regarding the value of pending and future

asbestos-related personal-injury claims on behalf of the Debtors in In re Paddock Enterprises, LLC, No. 20-

10028 (LSS) (Bankr. D. Del.): 2020–present.

• Served as lead consulting advisor to Debtors regarding the value of pending and future asbestos-related

personal-injury claims in In re Aldrich Pump LLC, et al., No. 20-30608 (Bankr. W.D.N.C.): 2020–present.

• Authored letters regarding the range of potential valuations associated with a Fortune 500 company’s

asbestos-related reserves. 2020–present.

• Authored expert reports and testified at a Bermuda arbitration hearing on behalf of an insurer regarding the

portion of set of auto defect claims potentially subject to coverage: 2019–2020.

• Retained as abuse claims valuation consultant by the Debtors and lead mediation valuation efforts in the

matter of In re: Boy Scouts of America and Delaware BSA, LLC No. 20-10343-LSS (United States Bankruptcy

Court for the District of Delaware): 2019–present.

• Retained as consulting expert and participated in pre-bankruptcy mediation related to the valuation of losses

stemming from sexual abuse claims: 2019–2020.

• Retained as consulting expert by an insurance company and participated in court-ordered mediation in the

matter In re: USA Gymnastics No. 18-09108-RLM-11 (United States Bankruptcy Court for the Southern

District of Indiana Indianapolis Division): 2019–2022.

• Authored expert report and declarations, and provided deposition and trial testimony, regarding the sufficiency

of document and settlement data productions for asbestos-related claims in the matter of Keyes Law Firm,

LLC v. Napoli Bern Ripka Shkolnik, LLP et al., No.: 1:17-cv-02972 (United States District Court for the District

of Maryland, Northern Division): 2019–2020.

• Authored presentation for investor group and provided model of potential losses related to bodily injury claims


• Retained as allocation consultant and advised an insurer on settlement mediation in Wellington coverage

dispute: 2019.

• Authored expert report and provided deposition testimony regarding projected future asbestos-related losses

and the portion potentially subject to reimbursement under an indemnity agreement In re Midwest Generation,

LLC, et al., No. 12-49218 (United States Bankruptcy Court Northern District of Illinois (Chicago): 2018–2019.

• Authored report on the value of insurance potentially available to offset future asbestos-related expenditures

for corporate entity assessing strategic alternatives: 2018.



• Authored legacy liability valuation report for a regional supply company to a firm considering a potential

strategic acquisition: 2018.

• Retained to provide contingent liability valuation on behalf of insurance company evaluating strategic

alternatives: 2018.

• Submitted declaration as custodian of records for asbestos-related insurance coverage dispute: 2018.

• Retained as part of consulting team advising, and participated in settlement mediations on behalf of, a group

of automobile manufacturers regarding the scope of potential future personal injury and wrongful death claims

related to allegedly defective airbags in the matter of In re: TK Holdings Inc., et al., No. 17-11375 (BLS)

(United States Bankruptcy Court for the District of Delaware) and related proceedings: 2017–2018.

• Retained by insurer and authored settlement report analyzing outcomes related to potential policy exposure

associated with allegedly faulty medical implants as part of a coverage mediation: 2017–2018.

• Advised parties on a possible corporate transaction involving potentially significant asbestos-related liabilities:

2017–2018.

• Retained by insurer to analyze probable policy exposure associated with future asbestos claims in the tort

system and under a potential 524(g) bankruptcy trust and participated in related mediation and settlement

discussions in In re: The Fairbanks Company, No. 18-41768 (United States District Court for the Northern

District of Georgia): 2017–present.

• Led consulting team through arbitration hearing for an asbestos-related reinsurance dispute involving a nearly

$50 million claim: 2017.

• Retained as consulting expert and advised Fortune 500 companies assessing strategic alternatives for

addressing their asbestos-related expenditures: 2016–present.

• Authored expert reports and provided deposition testimony addressing inconsistent treatment of conceptually

related insurance allocation issues as part of a dispute regarding MTBE ground water pollution: 2015–2017.

• Co-authored expert report addressing the legacy asbestos liability and related insurance offsets for a set of

industrial companies as part of a corporate acquisition: 2016.

• Provided legacy liability valuation for a national construction materials company, including related potential

insurance offsets, to a strategic buyer considering a potential acquisition: 2016.

• Retained as sampling and insurance allocation expert for a multi-million-dollar insurance claim related to

asbestos: 2016.

• Authored expert reports and provided deposition testimony addressing the allocation of a multi-million-dollar

insurance claim related to an agricultural ground water pollutant: 2015–2017.

• Provided legacy liability valuation of a regional construction company, including related potential insurance

offsets, to a private equity firm considering a potential acquisition: 2015.

• Coauthored letters supporting the approximately $700m international legacy asbestos liability and related

insurance valuations for the newly combined AMEC Foster Wheeler across different accounting frameworks,

namely US GAAP and IFRS, as of their 2014 acquisition dates, and defended the analysis through a multi-

firm audit; providing ongoing periodic analytical updates and reports: 2014–present.

• Served as consulting expert to a pair of reinsurers in arbitration regarding allocation issues related to multi-

million-dollar asbestos cessation: 2014–2016.



• Provided settlement support and served as consulting expert on behalf of five-member insurance joint

defense group in a case taken through jury trial related to primary policy exhaustion and alternative available

coverage lines under a variety of potential choice of law and occurrence rulings: 2013–present.

• Led analytical team and served as consulting expert for insurer involved in a coverage dispute with a large

asbestos defendant: 2014–2016.

• Provided legacy liability valuation report of an energy sector services company to a private equity firm

considering a potential acquisition: 2014.

• Led team and served as consulting expert on analysis of the potential impact of alternative occupancy rates

and leverage ratios on the value of a large assisted living property over time: 2014.

• Led separate settlement support analytical team that worked on simplified valuation framework that leveraged

existing valuations tools, and accounted for various shortcomings within those tools, to value dozens of large

RMBS securitizations: 2014.



• Co-authored expert report, provided deposition testimony, and testified regarding the sufficiency of the

proposed aggregate product liability claim settlement on behalf of the settling insurers in In re Blitz USA Inc.,

No. 1:11-bk-13603 (United States Bankruptcy Court for the District of Delaware): 2013–2014.

• Provided consulting expertise in support of Dr. Charles E. Bates’ liability estimation, and led team working on

Dr. Karl N. Snow’s financial valuation work on behalf of the Debtors in In re Garlock Sealing Technologies,

LLC, No. 10-BK-31607 (United States Bankruptcy Court for the Western District of North Carolina): 2010–

present.

• Authored declaration and served as lead consulting expert on behalf of the Debtors in In re Specialty

Products Holding Corp., et al., No. 10-11780 (JKF) (United States Bankruptcy Court for the District of

Delaware): 2010–present.

• Presented to the board of a Fortune 500 company regarding the potential economic risks associated with the

assumption of legacy liabilities tied to US manufacturing firms: 2014.

• Retained as the allocation and valuation expert for an excess insurer involved in Wellington ADR proceedings

related to an asbestos products manufacturer joint defense group: 2013–2014.

• Co-authored asbestos due diligence report for a corporate client evaluating restructuring opportunities: 2013.

• Advised numerous clients contemplating acquisitions that involve companies with potential legacy liability

issues. Work involved assessing potential future tort expenditures and associated risk drivers, as well as

evaluating insurance assets that may provide offsetting coverage: 2005–present.

• Authored expert report and served as the allocation expert for an insurance company dealing with

remediation costs across multiple environmental sites that could be subject to numerous potential legal

rulings and estimated future loss scenarios: 2012–2013.

• Advised insurers in reinsurance ADR proceedings on issues related to asbestos products’ usage that could

impact performance of reinsurance treaties: 2011–2013.

• Provided due diligence evaluation and report for a client engaged in a bidding war for an acquisition target

with potential long-tail liability risks: 2012.



• Provided consulting and settlement support to an excess insurer in asbestos-related Wellington ADR

proceedings for an insulation contracting and sales company: 2011–2012.

• Advised an insurer in litigation on issues related to the availability of various types of asbestos insurance

products: 2011.

• Assisted a Fortune 500 company with the acquisition of after-the-fact insurance, similar to a liability portfolio

transfer, covering the financial risk arising from thousands of asbestos claims: 2010–2011.

• Provided consulting support and analysis for multiple insurance companies in In re Leslie Controls, Inc., No.

10-12199 (CSS) (United States Bankruptcy Court for the District of Delaware): 2010–2011.

• Provided tort defendants with information required for them to file contribution claims with various 524(g)

trusts: 2010–2011.

• Provided a report to a large reinsurance group about issues impacting asbestos claiming trends and

insurance recoveries: 2010.

• Evaluated potential damages and investment returns for several third-party litigation funders on numerous

cases dealing with issues including: mass environmental loss, qui tam tax claims, fraudulent conveyance,

international contract arbitration, price-fixing, patents, and mortgage-backed securities and other CDOs:

2009–2011.

• Supported experts assessing the value of pending and future asbestos-related personal-injury claims on

behalf of the Official Committee of Unsecured Creditors in In re Motors Liquidation Company, et al. f/k/a

General Motors Corp., et al., No. 09-50026 (REG) (United States Bankruptcy Court for the Southern District of

New York): 2010–2011.

• Provided extensive claiming population analysis for a defendant corporation facing a mass of black lung

claims: 2010.

• Developed an alternative risk transfer product to help companies minimize overhang costs associated with

asbestos and other legacy liabilities. Shaped customized transactions for several clients that would have

involved nine- and ten-figure loss transfers: 2007–2009.

• Advised a joint defense group of more than a dozen insurers throughout their litigation and settlement

negotiations in the matter Foster Wheeler L.L.C. v. Affiliated FM Insurance Co., Index No. 600777/01 (N.Y.S.,

New York City): 2006–2010.

• Provided supporting analysis on the economic viability of the Trust Fund proposed under S.852, the Fairness

in Asbestos Injury Resolution (FAIR) Act of 2005, which highlights how compensation criteria specified for the


2005.

• Coauthored a report on company-specific asbestos litigation risk in support of a successful corporate

divestiture: 2005–2006.

• Managed the litigation support team responsible for addressing the fraction of expenditures associated with a

company’s asbestos installation operations on behalf of defendants in Owens Corning v. Birmingham Fire

Insurance Company of Pennsylvania, No. C10200104929 (Ohio Court of Common Pleas, Lucas County).

Assessed data quality, reviewed the opposing expert’s analytical methods, and developed an independent

method for predicting “non-products” liability: 2003–2005.



• Managed the litigation support team that addressed the fraction of expenditures associated with a company’s

asbestos installation operations on behalf of Liberty Mutual Insurance Company in Armstrong World

Industries Inc. v. Liberty Mutual Insurance Co., No. 02 cv 4360 (Eastern District of Pennsylvania). Assessed

data quality, reviewed the opposing expert’s analytical methods, and developed an independent method for

predicting “non-products” liability in insurance policies: 2003–2009.

• Developed plaintiff law firm-specific future asbestos liability forecasts for a multimillion-dollar London Market

insurance policy buy-back negotiation: 2004–2005.

• Assisted in the development of cross-project asbestos site identification procedures, tools, and applications:

2003–2005.

• Assisted in the development of future claim value projection techniques to analyze the effects of bankruptcies

on claim values in joint and several tort environments: 2003–2005.

• Assisted in the development of a new proprietary insurance allocation application: 2003–2006.

• Conducted exposure analyses and predicted future claims involving asbestos manufacturers and contractors

in bankruptcy and insurance coverage disputes: 2003–2005.

• Played a key role in the development of new methodologies for disaggregating and identifying the drivers of

legacy liability losses used to determine the impact of punitive damage awards as well as the portion of

settlements driven by liability, as opposed to other considerations.

PROFESSIONAL EXPERIENCE

• Bates White Economic Consulting

• Partner, 2019–present

• Principal, 2009–2018

• Manager, 2003–2008

• Critical member of the team that developed the first generation of Bates White proprietary insurance

allocation software.

• Principal and founding member, Litigation Resolution Group LLC, 2007–2009

• Litigation Resolution Group (LRG) was a third-party litigation funder originally founded to provide

economic finality to companies facing substantial asbestos and other long-tailed tort claims. LRG was the

first company that worked to serve the US market with a focus on assuming defense-side litigation risks.

Worked with senior hedge fund managers, insurance and reinsurance executives, lawyers, and corporate

executives to help them understand the value of their litigation derivative assets and liabilities.

PRESENTATIONS AND PANELS

• “Cutting Edge Trends and Developments in Allocation Issues,” Panel presentation at Perrin Conferences

Emerging Insurance Coverage & Allocation Issues Conference, May 11, 2017 (Philadelphia)

• “Recent Developments in Coverage Litigation and the Practical and Real Life Implications,” Panel discussion

at Perrin Conferences Asbestos Litigation Conference: A National Overview & Outlook, September 2016 (San

Francisco)

• “US Asbestos: Current and Emerging Trends,” IntAP Spring Technical Meeting, May 2012 (Cologne, DE)



• “US Asbestos: Current and Emerging Trends,” IntAP Spring Technical Meeting, June 2010 (Norwich, UK)

• “A Conversation About Litigation Risk Sharing by Major Law Firms,” RAND Institute Alternative Litigation

Finance in the US Conference, May 2010 (Arlington, VA)

• “Investing in Litigation,” Butterworths’ International Asbestos, September 2009 (London)

PROFESSIONAL ASSOCIATIONS

• CFA

• CFA Society of Washington, DC


• American Bankruptcy Institute


Exhibit 2

Charles H. Mullin, Ph.D. Curriculum Vitae



Main 202. 408. 6110

CHARLES H. MULLIN, PHD

Partner

AREAS OF EXPERTISE

• Data analysis

• Econometrics

• Economic modeling


• Microsimulation modeling

• Statistical analysis


Charles H. Mullin is the Bates White Managing Partner. He provides advice and expert analysis on issues

involving mass torts, class actions, bankruptcies, insurance coverage, and due diligence for mergers,

acquisitions, and spin-offs. He is a recognized expert on statistical and data analysis, econometrics, economic

and microsimulation modeling, sample design, insurance allocation, and the valuation of mass torts. Who’s Who

Legal has named him Insurance Expert of the Year (2018-2020), and he has been a Who’s Who Legal Insurance

and Reinsurance Expert Witness Thought Leader since 2016 and Global Elite Thought Leader since 2020. Dr.

Mullin has authored more than 75 expert reports and provided expert testimony in more than 50 matters, as well

as provided due diligence reports for corporate transactions. He has more than 20 years of experience providing

this expertise in both the private and public sectors.

He taught courses in statistics, econometrics, and labor economics while on the faculty in the Department of

Economics at Vanderbilt University and at the University of California at Los Angeles. Dr. Mullin has published

papers on applied and theoretical econometrics and labor economics in peer-reviewed journals, and he is

frequently invited to speak at industry conferences.

EDUCATION

• PhD, Economics, University of Chicago

• BA, Mathematics and Economics, University of California at Berkeley

SELECTED EXPERIENCE

• Authored expert report, provided deposition testimony, and provided hearing testimony on behalf of the

Debtor in In re LTL Management LLC, No. 21-30589 (JCW) (Bankr. W.D.N.C.): 2021–present.

• Authored expert report, provided deposition testimony, and provided hearing testimony in In re: Mallinckrodt

PLC, et al. No. 20-12522-JTD (Bankr. D. Del.): 2021–present.

• Authored expert report and provided deposition testimony in Kevin Brown et al. v. Saint-Gobain Performance

Plastics Corporation and Gwenael Busnel, No. 1:16-cv-00242-JL (U.S. Dist. Ct. D. N.H.): 2020–present.



• Authored expert report, provided deposition testimony, provided hearing testimony, and assessed the value of

pending and future asbestos-related personal-injury claims on behalf of the Debtors in In re Aldrich Pump

LLC, et al., No. 20-30608 (Bankr. W.D.N.C.): 2020–present.

• Assessed the value of pending and future abuse claims on behalf of the Debtors in In re: Boy Scouts of

America and Delaware BSA, LLC No. 20-10343-LSS (Bankr. D. Del.): 2020–present.


In re DBMP, LLC, No. 20-30080 (Bankr. W.D.N.C.): 2020–present.


In re Paddock Enterprises, LLC, No. 20-10028 (LSS) (Bankr. D. Del.): 2020–present.

• Authored expert report and provided deposition testimony on behalf of the Johnson & Johnson in In re: Imerys

Talc America, Inc., et al. No. 19-10289-LSS (Bankr. D. Del.): 2019–present.

• Authored presentation for investor group and provided model of potential losses related to bodily-injury claims


• Retained on behalf of the Debtors in In re Purdue Pharma L.P., et al., No. 19-23649 (Bankr. S.D.N.Y.): 2019–

present.

• Authored expert report in In re Midwest Generation, LLC, et al., No. 12-49218 (Bankr. N.D. Ill.): 2019.

• Provided testimony in PERB Interest Arbitration between PBA and the City of New York: 2019–present.

• Authored expert report and provided deposition testimony on behalf of excess insurers in In re Kaiser

Gypsum Company, Inc., et al., No. 16-31602 (Bankr. W.D.N.C.): 2018–present.

• Authored expert report in Consumer Financial Protection Bureau v. Navient Corporation and Navient

Solutions, Inc., No. 3:17-cv-00101 (M.D. Pa., Jan. 18, 2017). 2018–present.

• Authored expert report and provided deposition testimony in Keyes Law Firm v. Napoli Bern Ripka Shkolnik,

LLP, et al., No. 1:17-cv-02972 (U.S. Dist. Ct. D. Md.): 2018–2020.

• Authored expert report and provided deposition testimony in St. Paul Surplus Lines Insurance Company v.

Wright Medical Group, Inc., et al., No. CH-14-0927 (Tn. Ch. Ct. 13th Jud. Dist. Memphis): 2018–2019.

• Authored expert report, provided deposition testimony, and testified in Cannon Electric, Inc., now known as

ITT Cannon, Inc., et al. v. ACE Property and Casualty Company, et al., No. BC 290354 (Super. Ct. Cal. L.A.

Cnty. Ct.): 2018.


In re Bestwall, LLC, No. 17-31795 (Bankr. W.D.N.C.): 2017–present.

• Assessed the value of pending and future airbag-related personal-injury claims on behalf of automobile

manufacturers in the matter of In re: TK Holdings Inc., et al., No. 17-11375 (BLS) (Bankr. D. Del.) and related

proceedings: 2017–2018.

• Authored expert reports and testified in James D. Sullivan et al. v. Saint-Gobain Performance Plastics

Corporation, No. 5:16-cv-00125 (U.S. Dist. Ct. D. Vt.): 2017–2019.

• Authored expert report, provided deposition testimony, and testified in In re the Receivership of Fraser’s

Boiler Service, Inc., No. 15-2-01791-8 SEA (Wash. Super. Ct., King Cnty.): 2017.

• Authored expert report in Gerrit H. Brouwer et al. v. Wyndham Vacation Resorts, Inc. et al., No. 2014-CA-




• Authored expert report in Ernest Yaeger, Jr. et al. v. Wyndham Vacation Resorts, Inc. et al., No. 2014-CA-


• Authored declarations and testified in a reinsurance arbitration: 2017–present.

• Authored declaration and reports, provided deposition testimony, and testified in a reinsurance arbitration:

2016–present.

• Analyzed coverage issues on behalf of Columbia Casualty Co. regarding pharmaceutical-based losses: 2016.

• Authored expert reports on behalf of HDI-Gerling Industrial Insurance Co. regarding pharmaceutical-based

losses: 2015–2016.

• Authored expert report and declaration and provided deposition testimony in Appleton Papers Inc. & NCR

Corp. v. George A. Whiting paper Co. et al., No. 08-C-16 (U.S. Dist. Ct. E.D.WI): 2015–2017.

• Authored expert reports on behalf of ACE Bermuda insurance Ltd. regarding an arbitration claim by 3M

Company regarding allegedly defective masks and respirators against Bermuda-Form policies: 2015–2016.

• Authored expert report on behalf of Allstate Insurance Company regarding an insurance contribution claim in

Certain Underwriters at Lloyd’s London v. Allstate et al., No. C101-1674 (Ohio Ct. Com. Pl., Lucas Cnty.):

2015–2016.

• Analyzed coverage issues stemming from agricultural-related water contamination claims: 2015–2018.

• Analyzed coverage issues stemming from MTBE-related claims filed: 2015–2018.

• Authored expert report and provided deposition testimony in Direct General Ins. Co. v. Indian Harbor Ins. Co.,

No. 1:14-CV-20050-MGC (S.D. Fla.): 2015.

• Authored expert report, provided deposition testimony, and testified during arbitration on behalf of General Re

Corporation and SCOR SE in a reinsurance matter: 2014–2017, 2018–2021.

• Analyzed coverage issues stemming from Benzene claims filed in Radiator Specialty Company vs. Arrowood

Indemnity Company et al., No. 13 CVS 2271 (NC Super. Ct. Mecklenburg Cnty.): 2014–2015.

• Coauthored letters supporting the approximately $700 million international legacy asbestos liability and

related insurance valuations for the newly combined AMEC Foster Wheeler across US GAAP and IFRS

accounting frameworks, as well as periodic updates to said analyses: 2014–present.

• Authored declaration on behalf of insurance companies in AIU Ins. Co. v. Philips Elecs. N. Am. Corp., No.

9852-VCN (Del. Ch.): 2014–2015.

• Authored declaration on behalf of insurance companies in In re T.H. Agric. & Nutrition, LLC, No. 08-14692

(Bankr. S.D.N.Y.): 2014.

• Analyzed coverage issues stemming from environmental loss in Olin Corporation v. Insurance Company of

North America et al., No. 84 CIV. 1968 (TPG) (U.S. Dist. Ct. S.D.N.Y.): 2014–2015.



• Authored expert report, provided deposition testimony, and testified during arbitration on behalf of Allstate

Insurance Company in a reinsurance matter: 2013–2015.

• Provided deposition testimony on behalf of National Indemnity Company in Nat’l Indem. Co. v. State, No.

XDDV 2012-140 (Mont. Dist. Ct., Lewis & Clark Cnty.): 2013–2018.



• Authored expert report, provided deposition testimony, and testified on behalf of insurance companies in

Nooter Corp. v. Allianz Underwriters Ins. Co., No. 1022-CC01145-01 (Mo. Cir. Ct. 22nd Jud. Cir. St. Louis

City): 2013–present.

• Coauthored expert report, provided deposition testimony, and testified on behalf of multiple insurance

companies in In re Blitz U.S.A., No. 11-13603 (PJW) (Bankr. D. Del.): 2013–2014.

• Provided deposition testimony on behalf of The Hartford Accident and Indemnity Company in the matter Fluor

Corp. v. Hartford Accident & Indem. Co., No. 06CC00016 (Cal. Super. Ct., Orange Cnty.): 2013.

• Authored expert report on behalf of The Hartford Accident and Indemnity Company in the matter Hartford

Accident & Indemnity Co. v. Travelers Indem. Co., No. X07-HHD-CV-11-6021732-S (Conn. Super. Ct.,

Hartford Cnty.): 2013–2015.

• Provided deposition and trial testimony on behalf of The Travelers Indemnity Company in US Silica Co. v.

ACE Fire Underwriters Ins. Co., No. 06-C-2 (W. Va. Cir. Ct., Morgan Cnty.): 2013.

• Authored expert report and testified during arbitration proceedings on behalf of the Massachusetts Insurance

Insolvency Fund in In re the Liquidation of Midland Ins. Co., No. 41294/86 (N.Y. Sup. Ct.): 2012–2013.

• Authored expert report, provided deposition testimony, and testified at trial on behalf of Defendant in Cannon

Elec., Inc. v. Affiliated FM Ins. Co., No. BC 290354 (Cal. Super. Ct., L.A. Cnty.): 2012–2013.

• Authored expert report and provided deposition testimony on behalf of multiple insurance companies in

Goodrich Corp. v. A.G. Securitas et al.: 2013–2015.

• Authored expert reports and testified during arbitration proceedings on behalf of Munich Re regarding

pharmaceutical-based losses: 2011–2013.

• Authored expert report on behalf of Zurich International (Bermuda) Ltd. in a Wellington ADR: 2011.

• Authored expert reports, provided deposition testimony, and testified during arbitration on behalf of Liberty

Mutual Insurance Company in a series of related reinsurance arbitration matters: 2011–2013.

• Authored expert reports and declarations, provided deposition testimony, and testified during the confirmation

hearing on behalf of multiple insurance companies in In re Plant Insulation Co., No. 09-31347 TC (Bankr. N.D.

Cal.): 2011–2014.

• Provided consulting services for a coalition of direct action plaintiffs in In re Puerto Rican Cabotage Antitrust

Litigation.

• Analyzed liability and damages resulting from the indirect claim on behalf of a large coalition of direct-action

plaintiffs in the United States, Asia, and Europe in In re TFT-LCD (Flat Panel) Antitrust Litig., MDL No. 1827

(N.D. Cal.): 2011–2015.

• Authored expert reports, provided deposition testimony, and testified assessing the value of pending and

future asbestos-related personal-injury claims on behalf of the Debtors in In re Specialty Prods. Holding

Corp., No. 10-11780 (JKF) (Bankr. D. Del.): 2010–2015.


In re Garlock Sealing Techs., LLC, No. 10-BK-31607 (Bankr. W.D.N.C.): 2010–2018.

• Assisted a Fortune 500 company in the completion of a limited portfolio transfer of thousands of asbestos

claims to a major insurance company: 2010–2011.



• Authored declaration and provided deposition testimony on behalf of multiple insurance companies in In re

Leslie Controls, Inc., No. 10-12199 (CSS) (Bankr. D. Del.): 2010–2011.

• Authored declarations on behalf of Century Indemnity Company in In re Thorpe Insulation Co., No. CV 10-

1493 DSF (Bankr. C.D. Cal.): 2010–2011.

• Assessed the value of pending and future asbestos-related personal-injury claims on behalf of the Official

Committee of Unsecured Creditors in In re Motors Liquidation Co., No. 09-50026 (REG) (Bankr. S.D.N.Y.):

2010–2011.

• Assessed the value of diacetyl claims on behalf of the Official Committee of Equity Security Holders in In re

Chemtura Corp., No. 09-11233 (REG) (Bankr. S.D.N.Y.): 2010.

• Provided deposition and trial testimony in Cannon Electric, Inc., now known as ITT Cannon, Inc., et al. v.

Affiliate FM Insurance Company, et al., No. BC 290354 (Super. Ct. Cal. L.A. Cty. Ct.) Goulds: 2009–2017.

• Authored expert report on behalf of FM Global and Utica in an arbitration matter: 2009–2010.

• Authored expert reports and provided deposition testimony on behalf of Aviva Insurance Company in Flintkote

Co. v. Gen. Accident Assurance Co. of Can., No. C04-01827 MHP (N.D. Cal.): 2009–2010.

• Provided deposition testimony on behalf of NL Industries, Inc., in Brown v. NL Indus., Inc., No. 06-602096-CZ

(Mich. Cir. Ct., Wayne Cnty.): 2009–2010.

• Authored expert report on behalf of taxpayers in Cencast Servs., L.P. v. United States, Nos. 02-1916 T

through 02-1925 T (Fed. Cl.): 2009–2012.

• Authored declaration on behalf of the State of Israel in In re Holocaust Victim Assets Litig., No. 09-160

(ERK)(JO) (E.D.N.Y.): 2009–2010.

• Provided deposition testimony on behalf of multiple insurance companies in the matter State of Minnesota v.

Associated Medical Assurance Ltd., No. 27-CV-08-1912 (Minn. Dist. Ct., Hennepin Cnty.): 2008–2010.


companies in Continental Casualty Co. v. BorgWarner Inc., No. 04 CH 01708 (Ill. Cir. Ct., Cook Cnty.): 2007–

present.


companies in Continental Ins. Co. v. Honeywell Int’l., Inc., No. MRS-L-1523-00 (N.J. Super. Ct., Morris Cnty.):

2007–2018.

• Authored expert report and provided deposition testimony on behalf of insurance company in Nat’l Serv.

Indus., Inc. v. Appalachian Ins. Co., No. E-22807 (Ga. Super. Ct., Fulton City): 2007.

• Authored expert report, provided deposition testimony, and testified on behalf of policyholder in Imo Indus.,

Inc. v. Transamerica Corp., No. L-2140-03 (N.J. Super. Ct., Mercer Cnty.): 2007–2011.

• Authored expert report and provided deposition testimony on behalf of insurance company in Degussa Corp.

v. Century Indem. Co., No. UNN-L-2163-03 (N.J. Super. Ct., Union Cnty.): 2007.

• Authored expert report and provided deposition testimony on behalf of insurance joint defense group in Foster

Wheeler LLC v. Affiliated FM Ins. Co., No. 600777/01 (N.Y. Sup. Ct., N.Y. Cnty.): 2007–2011.

• Authored expert reports, provided deposition testimony, and testified on behalf of Argonaut Insurance

Company in several reinsurance arbitrations: 2006–2007.



• Coauthored a report on the economic viability of the Trust Fund proposed under S.852, the Fairness in

Asbestos Injury Resolution (FAIR) Act of 2005, which highlights how compensation criteria specified for the


2005.

• Authored due diligence reports on asbestos, silica, opioids, and other mass tort matters for corporate

transactions that assessed potential future tort expenditures and evaluated the insurance assets that may

provide coverage for those tort expenditures: 2005–present.

• Authored expert reports and provided deposition testimony assessing the Trust-based liquidated values and

insurance allocation on behalf of Plaintiff in Nat’l Union Fire Ins. Co. of Pittsburgh, Pa. v. Porter Hayden Co.,

No. 1:03-CV-03408-CCB (D. Md.): 2004–2015.

• Authored expert report and provided deposition testimony to address the fraction of expenditures associated

with a company’s asbestos installation operations on behalf of Defendants in Owens Corning v. Birmingham

Fire Ins. Co. of Pa., No. C10200104929 (Ohio Ct. Com. Pl., Lucas Cnty.): 2003–2005.

• Authored expert report focused on the design and implementation of claims file samples in Hercules Inc. v.

OneBeacon Am. Ins. Co., No. 02C-11-237 (Del. Super. Ct., New Castle Cnty.): 2004.

• Assisted with settlement negotiations by analyzing the total value of a national refractory company’s products

and nonproducts coverage associated with claims for both asbestos and potential silica liabilities.

• Evaluated future liabilities and projected insurance recoveries under various scenarios, such as geographic

constraints regarding a regional insulation contractor and supply company.

• Served on behalf of the US Department of Labor in providing statistical analysis for discriminatory hiring

cases and assessing damages.

• Analyzed demand-side management programs for utility companies. Evaluated different contract structures,

software development options, and returns on subsidization programs.

• Investigated potential collusion and redlining by auto-insurance companies on behalf of the Office of the

Chicago Mayor.

OTHER PROFESSIONAL EXPERIENCE

Prior to joining Bates White, Dr. Mullin worked at Chicago Partners, where he provided damages assessments for

antitrust matters. Previously, he worked at Quantum Consulting, where he conducted demand-side management

for utility companies, and at Litigation Resolution Group. In addition to his professional experience, Dr. Mullin was

on the faculty in the Departments of Economics at Vanderbilt University and the University of California at Los

Angeles.

INDUSTRY PRESENTATIONS

• “Update on Talc Litigation.” Perrin Conferences—National Asbestos Litigation Conference, Oct. 1, 2018.

• “Corporate Roundtable: In-House Perspectives on Asbestos Litigation.” Perrin Conferences—Asbestos


• “Emerging Risks & Insurance Issues in 2016 Coverage Litigation.” Perrin Conferences—Emerging Insurance

Coverage & Allocation Issues Conference, May 18, 2016.



• “Impact of Bankruptcies on Litigation Strategies.” Perrin Conferences—Asbestos Litigation Conference: A


• “Emerging Issues, Coverage Trends and Key Jurisdictional Updates for 2015.” Perrin Conferences—

Emerging Insurance Coverage & Allocation Issues, May 19, 2015.



• “Asbestos Bankruptcy Update.” Perrin Conferences—Asbestos Litigation Conference: A National Overview &

Outlook, Sept. 16, 2013.

• “Charting the Right Course in 2013: A Closer Look at This Year’s Emerging Insurance Coverage Issues.”

Perrin Conferences—Emerging Insurance Coverage & Allocation Issues in 2013, May 14, 2013.



• “Mathematical Estimates of Carrier Exposures.” Perrin Conferences—Emerging Insurance Coverage &

Allocation Issues, Feb. 23, 2012.

• “Quantifying the Exposure: Reinsurance, Reserves, and Practical Considerations.” Perrin Conferences—

Emerging Insurance Coverage & Allocation Issues, Jan. 24, 2011.

• “Adding Up the Parts—Settlement Offsets in All Sums Jurisdictions.” Perrin Conferences—Emerging

Insurance Coverage & Allocation Issues, Jan. 24, 2011.

• “Impact of Current Tort Environment on Asbestos Reserves.” 2010 Casualty Actuary Society Annual Meeting,

Nov. 8, 2010.

• “Litigating Asbestos Cases in 2010: National Trends Driving the Litigation.” Perrin Conferences—Asbestos


• “Trusts On-Line: The Impact of Asbestos Bankruptcies on the Tort System.” Perrin Conferences—Asbestos

Bankruptcy Conference, June 21, 2010.

• “Asbestos Litigation in 2010 & Beyond—Current and Emerging Trends.” Perrin Conferences—Cutting Edge

Issues in Asbestos Litigation, Feb. 25–26, 2010.

• “A National Update on Current Cases & Trends that are Driving Asbestos Bankruptcy Litigation.” Perrin

Teleconference Series, Dec. 1, 2009.

• “Asbestos Bankruptcy: New Filings, Confirmations & Dismissals.” Perrin Conferences—Asbestos Litigation

Mega Conference, Sept. 14–16, 2009.

• “Claims Estimation in Mass Tort Cases.” ABA Section of Business Law Spring Meeting Committee on

Business Bankruptcy, Apr. 16–18, 2009.

• “Role of the Bankruptcy Trusts in Civil Asbestos.” BVR Legal/Mealey’s Emerging Trends in Asbestos

Litigation Conference, Mar. 9–11, 2009.

• “Damages in a Bad Faith Case.” BVR Legal/Mealey’s Bad Faith Litigation Conference, Nov. 6–7, 2008.

• “Emerging Issues and Important Developments.” West Legalworks, Insurance and Reinsurance Allocation

2008: A Comprehensive Workshop, June 12, 2008.



• “Impact of Underlining Litigation Developments.” West Legalworks, Insurance and Reinsurance Allocation,

Nov. 7, 2007.

• “Removing the Asbestos Overhang—Is There an Alternative to Asbestos Bankruptcy?” Mealey’s Publications,

Mealey’s National Asbestos Litigation SuperConference, Sept. 26, 2007.

• “Another Chapter in Asbestos Bankruptcy Litigation: What Does the Future Hold?” Mealey’s Publications,

Asbestos Bankruptcy Conference, June 8, 2007.

• “Impact of Underlining Litigation Developments.” West Legalworks, Insurance and Reinsurance Allocation

Superbowl 2007, Mar. 20, 2007.

• “Quantifying the Risk: The Impact Investigations into Fraudulent Silica/Asbestos Suits Will Have on the Rate

of Filing and Value of Current & Future Claims.” Mealey’s Publications, Silica & Asbestos Claims Conference:

What Effect Will Investigations into Fraudulent Suits Have on the Litigation? Nov. 11, 2006.

• “How State and Federal Tort-Reform Efforts Are Changing the Asbestos Litigation Landscape.” Mealey’s

Teleconference: Asbestos Legislation—Is a Solution to the Crisis around the Corner? July 20, 2006.

• “Asbestos Legislative Initiatives for Federal and State Tort Reform.” American Conference Institute’s (ACI) 7th

Annual Litigating, Settling, and Managing Asbestos Claims, June 15, 2006.

• “The FAIR Act: An Economic Analysis.” American Legislative Exchange Council, 2005 States and Nation

Policy Summit, Dec. 2005.

• “The Impact of Different Approaches to Settlement Credits.” Mealey’s Publications, All Sums: Reallocation &

Settlement Credits Conference, Nov. 7, 2005.

• “Assessing the Merits of Reallocation.” American Enterprise Institute, Industry Roundtable Discussion, Apr.

21, 2005.

• “The Effect of Joint and Several Liability on the Incentive of Defendants to Declare Bankruptcy: Evidence from

Asbestos Litigation.” American Law and Economics Association, Annual Meeting, May 2004.

• “Assessing the Merits of Reallocation.” American Law and Economics Association, 14th Annual Meeting (co-

author Anup Malani), May 3, 2004.

PUBLICATIONS

• Mullin, Charles H., Karl N. Snow, and Noah B. Wallace. “Unresolved Issues in Allocation of Loss to

Insurance.” Coverage 21, no. 1 (2011): 13–23.

• Mullin, Charles H., Karl N. Snow, and Noah B. Wallace. “Proper Settlement Credits in All Sums Jurisdictions.”

Coverage 20, no. 3 (2010): 26–31.

• Mullin, Charles H., Charles E. Bates, and Marc Scarcella. “The Claiming Game.” Mealey’s Litigation Report:

Asbestos 25, no. 1 (2010).

• Mullin, Charles H., Charles E. Bates, and A. Rachel Marquardt. “The Naming Game.” Mealey’s Litigation

Report: Asbestos 24, no. 15 (2009).

• Mullin, Charles H., and Charles E. Bates. “State of the Asbestos Litigation Environment.” Mealey’s Litigation

Report: Asbestos, 23 no. 19 (2008).

• Mullin, Charles H., and Charles E. Bates. “Show Me the Money.” Mealey’s Litigation Report: Asbestos 22, no.

21 (2007).



• Mullin, Charles H., and Charles E. Bates. “The Bankruptcy Wave of 2000—Companies Sunk by an Ocean of

Recruited Asbestos Claims.” Mealey’s Litigation Report: Asbestos 21, no. 24 (2007).

• Mullin, Charles H., and Charles E. Bates. “Having Your Tort and Eating It Too?” Mealey’s Asbestos

Bankruptcy Report 6, no. 4 (2006).

• Mullin, Charles H. “Identification and Estimation with Contaminated Data: When Do Covariate Data Sharpen

Inference?” Journal of Econometrics 130, no. 2 (2006): 253–72.

• Mullin, Charles H., and David H. Reiley. “Recombinant Estimation for Normal-Form Games, with Applications

to Auctions and Bargaining.” Games and Economic Behavior 54, no. 1 (2006): 159–82.

• Mullin, Charles H. “Bounding Treatment Effects with Contaminated and Censored Data: Assessing the Impact

of Early Childbearing on Children.” Advances in Economic Analysis & Policy 5, no. 1, (2005): article 8.

• Mullin, Charles H., Kelly A. Dugan, and John J. Siegfried. “Undergraduate Financial Aid and Subsequent

Alumni Giving Behavior.” Quarterly Review of Economics and Finance 45, no. 1 (2005): 123–43.

• Mullin, Charles H., and Anandi Mani. “Choosing the Right Pond: Social Approval and Occupational Choice.”

Journal of Labor Economics 22, no. 4 (2004): 835–62.

• Mullin, Charles H., V. Joseph Hotz, and John K. Scholz. “Welfare, Employment, and Income: Evidence on the

Effects of Benefit Reductions from California.” American Economic Review 92, no. 2 (2002): 380–84.

• Mullin, Charles H., V. Joseph Hotz, and John K. Scholz. “Welfare Reform, Employment and Advancement.”

Focus 22, no. 1, Special Issue (2002).


Participation of Families on Welfare.” In The Incentives of Government Programs and the Well-Being of

Families, eds. Bruce Meyer and Greg Duncan (Evanston, IL: Joint Center for Poverty Research, 2001).


Participation of Families on Welfare.” Poverty Research News, May/June 2001.

• Mullin, Charles H., and John J. Siegfried. “Grants Today, Gifts Tomorrow.” Currents 27, no. 4 (2001): 9–10.

• Mullin, Charles H., Carolyn J. Hill, V. Joseph Hotz, and John K. Scholz. “EITC Eligibility, Participation, and

Compliance Rates for AFDC Households: Evidence from the California Caseload,” May 1999, prepared for

the State of California.

• Mullin, Charles H., V. Joseph Hotz, and Seth Sanders. “Bounding Causal Effects Using Data from a

Contaminated Natural Experiment: Analyzing the Effects of Teenage Childbearing.” Review of Economic

Studies 64, no. 4 (1997): 575–603.

GRANTS

• 2004–2007: Principal Investigator (with V. J. Hotz and J. K. Scholz), National Science Foundation Grant, “Tax

Policy and Low-Wage Labor Markets: New Work on Employment, Effectiveness and Administration.”

• 2000–2001: Principal Investigator (with V. J. Hotz and J. K. Scholz), Grant to the University of Wisconsin–

Madison from Assistant Secretary of Planning and Evaluation, US Department of Health and Human

Services.

• 1997–1998: National Institutes of Health Predoctoral Training Grant.



PROFESSIONAL ASSOCIATIONS AND HONORS

• Who’s Who Legal: Insurance Expert of the Year, 2018–2020

• Who’s Who Legal Thought Leader: Global Elite list, 2019–present

• Who’s Who Legal: Insurance & Reinsurance Expert Witnesses Thought Leader, 2016–present

• Who’s Who Legal: Insurance & Reinsurance Expert Witnesses Global Elite Thought Leader, 2020–present


• American Economic Association

• American Law and Economics Association

• Econometric Society

• Society of Labor Economists


Schedule 1

Potential Parties in Interest


KE 12109128

SCHEDULE 1

List of Schedules

Schedule Category

1(a) Parent Affiliates

1(b) Current/Former Directors & Officers

1(c) Stockholders of Parent

1(d) Cash Management Bank Account

1(e) Bankruptcy Judges & Staff

1(f) Governmental/Regulatory Agencies

1(g) Insurers

1(h) Parties to Significant Actual or Known Potential Litigation with Debtor

1(i) Plaintiffs'’ Firms

1(j) Co-Defendants

1(k) Debtor’s Proposed Debtor Professionals and Affiliates’ Professionals

1(l) U.S. Trustees'’ Office


KE 12109128

SCHEDULE 1(a)

Parent Affiliates

Hess Capital Services LLC

Hess Corp.Corporation

Hess Oil & Gas Holdings Inc.

Hess Oil St. Lucia Holdings LP

Hess Oil St. Lucia Terminal Holdings

St. Croix Petrochemical Corp.


KE 12109128

SCHEDULE 1(b)

Current/Former Directors & Officers

Asafu-Adjaye, Jacqueline

Baker, DJ

Dunagin, Martin C., Jr.

Fishman, Eric S.

Franzino, Robert

Goodell, Timothy B.

Hess, John B.

Kahn, Matthew

Menell, Seth

Mosk, Milton

Prince, Edd D.

Rielly, John P.

Schachter, Barry

Snyder, Todd R.

Stapleton, Amy

Wiley, Jason


KE 12109128

SCHEDULE 1(c)

Stockholders of Parent

BlackRock Inc.

Brady, Nicholas

FMR LLC

Goodwillie, Eugene, Jr.

Hess Corp.

Hess, John B.

Kean, Thomas H.

St. Croix Petrochemical Corp.

State Street Corp.

Vanguard Group Inc., The


KE 12109128

SCHEDULE 1(d)

Cash Management Bank Account

JPMorgan Chase


KE 12109128

SCHEDULE 1(e)

Bankruptcy Judges & Staff

Isgur, Marvin

Jones, David R.

Lopez, Chris

Norman, Jeffrey P.

Rodriguez, Eduardo V.


KE 12109128

SCHEDULE 1(f)

Governmental/Regulatory Agencies

Illinois, State of, Attorney General

New York, State of, Attorney General

United States, Government of the, Department of the Interior, Environmental Protection Agency


KE 12109128

SCHEDULE 1(g)

Insurers

American International Group Inc.

Royal Insurance Holdings Ltd.

Travelers Cos. Inc., The


KE 12109128

SCHEDULE 1(h)

Parties to Significant Actual or Known Potential Litigation with Debtor

Abraham, Alexandrine

Abraham, Davidson

Abraham, Eleanor

Abraham, Ferdinand

Abraham, Harold

Abraham, Narcisse

Abraham-Soldiew, Bernadette

Acosta, Edelmiro

Acosta-Lewis, Candida

Adams, Melvine, Sr.

Ahamad, Zulaika

Alamo, Juan

Albert, Felicite Patricia

Alexander, Anselm

Alexander, David Adrian

Alexander, Gabriel

Alexander, Michael K.

Alibocas, Shirley

Allen, Richard, Sr.

Alphonse, Agnes

Amelina, Marc Louis

Andrew, Agnes

Angol, Augustin

Antoine, Catherine

Antoine, Ched

Antoine, Jamfes

Antoine, Johanna

Aquino-De La Rosa, Ovidio

Archibald, Emika

Arno, Carlos

Arno, Confesor

Arno, Felicia

Arno, Gladys

Arno, Liz Marie M.

Arno, Magdalena

Arno, Yadiel

Arno-Jimenez, Glerysbeth

Arnold, Anna

Arroyo, Ahrianna L.

Arroyo, Hector

Arroyo, Kiana

Arroyo, Petra

Arthurton, Dexter

Auguste, Keosha Mariah

Auguste, Marie

Augustin, Emmanuel

Austin, Allan

Ayala, Enrique

Ayala, Humberto

Ayala, Jesus

Azille, Cheryl

Baez, Luis

Ballantine-Phillips, Yvette

Baltimore, Link

Bannis, Heafline

Baptiste, Alwyn John

Baptiste, Antoine

Baptiste, Maria

Baptiste, Pricilla John

Barnes, Dennis, Jr.

Barry, James

Barry, St. Rose

Barry, Sylvia

Batista, Juan

Bazil, Joanness

Beharry, Lawrence J., Sr.

Beharry, Pascal W.

Belardo, Fidel

Belardo, Hector C.

Benjamin, Alford D.

Benjamin, Melvin

Benjamin, Morris

Benton, Ingrid

Benwaree, Rennie

Bergan, Arlington

Berley, Cassilla V.

Berley, Noel U.

Bernard, Angelo

Bhola, Anthony

Biggs, Bruce E. P.

Blake, Irvine E.

Blake, Rodney

Bodley, Celina

Bodley, Elias


KE 12109128

Boland, Veronica

Bougouneau, Francisca

Bougouneau, Francisca Andrea

Bougouneau, Jeremiah

Bowery, Ira

Boyce, Clemence, Sr.

Boyer, Regina

Braithwaite, Lisa

Brown, Clarence G.

Brown, Frank

Browne, Alexis H.

Browne, Alfred

Browne, Edwin

Browne, Gladstone

Browne, Joshua S.

Browne, Rita

Browne, Stafford

Burke, A'’Jada

Burke, Tyrone

Caldena, Blake

Cannon, Miranda

Carlot, Zuleyka

Carmona, Danie

Carmona, Joannna

Carpio, Luis

Carrasquillo, Victor Ruiz

Carroll, Mario

Carter, Arthur

Casimir, Avan

Castillo, Altagracia Javier

Castro, Jaime

Castro, Pablo

Celestin, Ezra

Cepeda, Kelvin D.

Cepeda, Nashali E.

Cepin, Alfredo Marquez, Jr.

Cepin, Guillermina

Chapkanova, Roumenka

Charles, Alexander

Charles, Catherine

Charles, Cuthbert R.

Charles, Ita

Charles, Julia

Charles, Veronica Rita

Charles, Vynisha

Chiverton, Onesimus

Christmas, Elford

Christophe, Cyrilla

Cirilo, Sonia

Clarke, Michael

Claudio, Jorge Luis Fontanez

Clercin, Mary

Clercin, Skitter Verna

Clifford, Augustine

Clinton, Henry

Clouden, Elvita

Clouden-Browne, Abbey

Clovis, Celestin

Clovis, Lawrence

Clovis, Regina

Coburn, Janelle

Coleman, Julietta

Collins, Phillip

Combie, Eliza

Combie, Valerie

Compton, Claire J.

Consula, Matthew

Cooke, Richard

Cooke, Wilhelmina

Corridon, Neil

Coto, Pedrito

Cotto, Jovo, Jr.

Cox, Dudley

Creighton, Theresa

Crispin, Paula

Cruz, Cristino

Cuffy, Gee, Jr.

Cuffy, Mable

Cuffy, Shirley

Cyrille, Paul

Dalmau-Estrada, Carlos

Dalsan, Agnes

Daniel, Catherine

Daniel, Christine

Daniel, Noel

Daniel, Phillip E.

Dantes, Barthelmy

Dariah, Theresa

Dariah, Wranda

David, Jeanne

Davis, Rupert

Dayatra, Emmanuel


KE 12109128

De La Cruz, Milciades Ubri

De La Cruz, Nancy

De Lande, Clefryn

De Rosa, Edelmira Roa

Decaille, Lilda

Decima, John Baptiste

Defreitas, Gilbert M.

Degrasse, William

Delande, Peter

Delgado, Gabriel A.

Delozier, Darren

Denbow, Helena

Denis, Alexis

Denis, Alphonsus

Denis, Dariah

Denis, Placide

Dennery, Arthur

Dennie, Israel

Desbonnes, Nathalie

Deschamps, Malcolm

Desir, Joanna

Desir, Urias

Desouza, John

Deterville, Charles

Diaz de Ayala, Rosanda

Diaz, Elizabeth

Diaz, Rosa

Donawa, Clarence Eustace

Donawa, Ian

Donelly, Tricia

Doran, Garfield

Doran, Judith

Douglas, Charles (Christian)

Drayton, Cleavely

Drew, Lenroy

Drigo, Daniel

Ducreay, Isaiah

Duncan, Tyrone

Durgah, Sharia

Dyett, George

Eardley, Howard Charles

East, Eugenia

Eastman, Felix

Edward, Peter

Edwards, Albert, Jr.

Elcock, Kendrick

Elderfield, Richard

Elliot, Alton

Elliott, Albert

Emanuel, Henson

Emmanuel, Hyacinth

English, Allan

Errilienne, Carmela

Estate of Alberto Morla

Estate of Arnold Anthony

Estate of Benjamin Freemen

Estate of Eli McKenzie

Estate of Emerson Gill

Estate of Ezekiel Farrell

Estate of Felito Rijo

Estate of Felix Colon

Estate of Fitzroy Roberts

Estate of Francisco Carrasquillo-Acosta

Estate of George Glasgow

Estate of Greta Shalto

Estate of James Hughes

Estate of John Jordan

Estate of Joseph Plante

Estate of Julian Peters

Estate of Kelvin Stanislas

Estate of Leroy W. Trimmingham

Estate of Logan A. Pujols

Estate of Luciano Susino

Estate of Luke Frederick

Estate of Lunid Walter

Estate of Miguel Martinez

Estate of Nelson Mena Marte

Estate of Nicholas George

Estate of Octave Ferdinand

Estate of Patricia Stewart

Estate of Patrick Mathurin

Estate of Ramona Santos

Estate of Roland Bodley

Estate of Rosemary Nicholas

Estate of Scipio Murren

Estate of Teresa Fontenelle

Estate of Thomas Lannaghan

Estate of Wilmouth A. Hughes

Estephan, Americo Rodriguez

Eugene, Mary

Eugene, Simnia

Eugene, Veronica


KE 12109128

Evans, Gualbert

Evans, Handerson

Evans, Hugh

Evans, Julianna

Fabian, Patricio

Fahie, Royce H.

Farrelly, Chastidy

Farrelly, Christian

Farrelly, Christine

Farrow, Oliver

Faucher, Angela

Felicien, Jeremiah

Felix, Angelina M.

Felix, Anthony

Felix, Berta

Ferdinand, Brenda G.

Ferdinand, Octavia

Figueroa, Carlos J.

Figueroa, Carlos R., Jr.

Figueroa, Roberto

Finney, Alana

Finney, Emerald

Finney, Jackline

Flood, Cynthia

Fonetenelle, Exilia

Fontenelle, George

Fontenelle, Pius

Forde, Linroy

Fox, Melwyn Elias

Francis, Andre

Francis, Sophia

Francis-Christopher, Daisy

Fraser, Tamica T.

Freeman, Eugene T., Sr.

Frontal, Jianna

Gabriel, Julia

Galiber, Joyce James

Garcia, Felix

Garcia, Frederico

Garcia, Glorimar Mena

Garcia, Juan

Garcia, Reynaldo

Gaston, Simone

Gautier, Angel

George, Cuthbert

George, Eunice

Gervais, Rufinus

Gifford, Alain

Gilbert, Idonia

Gilbert, Joseph

Gill, Fonda

Glasgow, Catherine

Glover, Mary

Gomez, Oscar

Gonsalves, Hyacinth

Gonsalves, Marie

Gonsalves, Marie V.

Gonzague, Augusta

Gonzague, Henry, Jr.

Gonzales, Glen

Gonzales, Ramona

Gonzalez, Mario

Gonzalez, Raul

Gordon, Adolphus

Gordon, Anna

Gordon, Celestine

Gordon, Roderick

Granger, Stephanie

Grant, Felice

Green, Tony Curtis

Green, Wendy

Greenaway, Dan

Greene, Alwyn

Guadalupe, Domingo

Guadalupe, Javier, Jr.

Guadalupe, Sheralda

Guadalupe-Thomas, Maria R.

Gumbs, Alexander

Gumbs, Anne

Gustave, Audrey

Guzman, Sencion

Gwendolyn Jacobs

Hall, Egbert Carlton

Hamilton, Ambrose

Harold Abraham

Henry, George

Henry, Lucille

Henry, Mary G.

Henry, Mervyn

Henry, Michael

Henry, Miles

Henry, Nicholas


KE 12109128

Henry, Paul

Henry, Yolanda

Hepburn, Maria M.

Herelle, Joseph

Herman-Sadoo, Natalia

Hernandez-Aquino, Xiomara

Hill, Joseph Vigilant

Hinkson, Francilla

Hippolyte, Waltrude

Hospedales, Roderick

Hughes, Stedman

Ince, Albert

Inglis, Dillon

Irwin, Vera

Isaac-Joseph, Sirdrina

Isidore, Helen

Jackson, Malvina

Jacob, Charles

Jacobs, Gwendolyn

Jagrup, Verdan

James, Brenda

James, Francis

James, Irwin L.

James, Jerome

James, Julie

Jarvis, Gary

Jarvis, Leroy

Jean, Andre

Jean, Larry

Jeanne David

Jeffers, Stephen

Jeffers, Wilfred Z.

Jeffrey, Crystal

Jeremiah, Frank

Jimenez, David

Jn-Marie, Eugenia

Jno-Baptiste, Nicholas

Jno-Finn, Michael

Joaquin, Joseph

John, Agnes

John, Gertrude

John, Joan

John, Michael C.

John, Sylvester

John-Baptiste, Arthur

John-Baptiste, Bernadine

Johnson, Juana L.

Jonas, Winifred

Joseph, Bernett

Joseph, Elwin

Joseph, Emil

Joseph, George

Joseph, Grace

Joseph, Judith

Joseph, Kenneth

Joseph, Magilta

Joseph, Margarita

Joseph, Phillipa

Joseph, Selwin George

Joseph, St George

Joseph, Theresa

King, Claudette

Knight, Everton

Languedoc, Clement

Lansiquot, Enno

Laurencin, Anthony

Lawrence, Rosetta

Lazare, Louise

Lazare, Maynard

Leblanc, Alex G.

Ledesma, Felipe

Leon, Aybert

Leon, Joanna

Leon, Mary

Leon, Michael

Leonce, Herbert

Leonce, Phylis

Lestrade, Rebecca

Liburd, Dave

Liburd, Henreker

Linares, Abigail

Ling, Michael Lee

Llanos, Veronica

Longville, Mary

Lopez, Carmen

Lopez, Maishaleen

Lopez, Myma

Lopez, Myrna

Lopez-Acosta, Jose

Lopez-Quintana, Juan

Louis, Agatha

Louis, Cornelia


KE 12109128

Lubin, Jonah N.

Lucille, Mary

Maharaj, Devraj

Malaykhan, Eyajie

Manie, John

Marcelle, Lucia

Marquez, Dayana

Marquez, Sigfredo

Mars, Alicia

Marsh, Jane M.

Marte, Eladia Flaviana Mena

Martin, Telbert

Martina Simeina

Martinez, Esther

Martinez, Hector

Massicot, Eric

Massicott, Jeannoel S.

Massicott, Merlyn

Mateo, Joan Manuel Mena

Mathurin, Bernard

Mathurin, Gregory

Mathurin, Patricia

Matthew, Fitzroy B.

Matthew, Michael Elsworth

Maxwell, Mary

Maxwell, Weldon

Mayfield, Carmen

Maynard, Carolyn

Maynard, James

Maynard, Nadean V.

McBean, Janine

McFarlane, Canice

McIntosh, Daniel

McIntosh, Lydia

McKenzie, Jennie

McKenzie, Vernon

McMahon, Vincent

McNamara, James

Melius-Michaud, Virginia

Menders, Reynard D., Sr.

Mendez, Loanmi

Merced, Edgar

Merced-Green, Lucette

Mess, Joseph

Michael, Coletta

Micheau, Julian L.

Miller, Delroy E., Sr.

Miller-Lloyd, Wilma

Mitchell, Alfred

Mitchell, Clayton

Mitchell, Cornelius

Mitchell, Gemma

Mitchell, Marian

Moe, Russell

Mohansingh, Kadar

Mondesir, Frances

Mondesir, Viviane Charles

Monrose, Victor

Montoute-Dumar, Clarita

Moore, Gary A.

Moore, Steven

Morla, Freddy

Moses, Godclive

Moses, Jerome

Mulrain, Carlos P.

Munchez-Nurse, Barbara A.

Murray, Anne Marie P.

Murray, Michael

Nales-Martinez, Norma

Nandlal, Basilica

Navarro, Guillermo Rivera

Nelson, Clement

Nelson, Gerard

Newton, Sharon

Nicholas, Sandra A.

Nieves, Joel

Nieves, Jose A., III

Nieves, Sonia

Nisbeth, Edric

Nobbie, Ainsley

Noelien, Joyceline

Noorhasan, Shane

Norford, Derrick

Nyack, Marilyn

O’Bryan, Nina

Octalien, Norbert C.

Oliver, Pedro

Orta, Yaraliz

Osorio, Pedro, Jr.

Ozoria, Victor

Pacheco, Karina

Parris-Bruce, Norma


KE 12109128

Parris-Delgado, Annette

Paul, Anthony

Paul, John

Paul, Phillip

Pena-Arrendell, Arelis

Peralta, Querman

Perez, Santa

Perez-Rivera, Abraham

Peter, Michael

Peterson, Lucien

Phangyou, Carl PJ

Phangyou, Robert

Phangyou, Tabita

Phillip, Catherine

Phillip, Vaughn

Phillips, Patrick

Philogene, Bibiana

Philogene, Lawrence

Pilier, Antonio

Pilier, Demetrio

Pilier, Leandro

Pilier, Lizandro

Pilier, Lizangel

Plante, Marion

Poleon, Angela

Poleon, Celina

Poleon, John

Poleon, Yvie

Powell, Charles

Prescott, Joseph

President, Winifred

Prevost, Floretta

Prime, Hollis

Prosper, Elpher

Rambally, Brian

Ramdhanny, John

Ramos, Brunilda

Ramos, Josefina

Randolph-Victor, Laura

Raphael, Derek

Raphael, Martha

Raphael, Thomas

Ras, Luis

Raymond, Zenia

Reid, Avis

Rene, Coria

Rennie, Lloyd

Rennie, Ronnie

Reuben, Aaron

Reyes, Confesor

Richardson, Cheryl

Richelieu, Gregor

Richelieu, Gregory E.

Richelieu, Margarita

Richelieu, Verna Rita

Rijo, Marco

Rios, Felipe

Rivera, Jose

Rivera, Jose M.

Rivera, Luis, Jr.

Rivera, Luis, Sr.

Rivera, Sandro

Rivera, Santos

Rivera, Teresa

Rivera-Lopez, Santos

Riviere, Annabelle

Roa, Basilio

Roberts, Aldora Fleming

Roberts, Cuthbert F.

Roberts, Darriyen

Roberts, Kendall

Roberts, Roger A.

Robertson, Linton

Robles, Angela

Robles, Maicangel

Robles, Natasha

Rodriguez, Angel

Rodriguez, Israel

Rodriguez, Leonard

Rodriguez, Maria

Rodriguez, Serafin

Rodriguez, Serafin, Jr.

Romain, Andrew

Rosa, Sonia

Rosario, Ana

Rose, Eustace

Roseline, Eleanor

Russell, Hulester

Sadoo, Ricardo

Sam, Reginald A.

Samuel, Richard A.

Samuel, Virginia


KE 12109128

Sanchez, Jose

Sanes, Maria

Santiago, Bernabe, Jr.

Santiago, Carmen

Santiago, Chayanne

Santiago, Luis

Santiago, Maynalys

Santiago, Shanequa

Santos-Rios, Angel

Sargeant, Patronella

Sargeant, Petronella

Sargeant, Vincent

Scotland, Mariska

Sealey, Ronald

Seecharan, Alvan

Serieux, Marie

Shirley, Helen

Silvestre, Juan Riveras

Simon, Enoch

Simon, Lesroy

Smith, Anthony

Smith, James A.

Solomon, Rodney

Sonny, Joseph

Sonson, Alvin

Sookoo, Richie

Soto, Jorge

Soto-Nieves, Irma

Soto-Santos, Efraim

St. Henry, Norris Rupert

St. Jean Wong, Meredith

St. Remy, Francois

St. Rose, Alexander

St. Rose, Gerard

St. Rose, Gertrude

St. Rose, Mary

St. Rose, Saraphine

St. Rose, Virginia

Stanislas, Albert

Stanislas, Marina

Stanley, Eugenia

Stephenson, Eugene

Stevenson, Elsworth

Straker, Cora

Subniak, Dianan

Susino, Carmela

Swanston, Arlene

Sydney, John

Sykes, Eric

Talian, Lucy C.

Tann, Renee

Tayliam, Albert

Taylor, MacDonald

Theobbles, Esther

Theodile, Ruthine

Theodore, Roselyn

Theodule, Elizabeth

Theophilus-Phillipp, Alita V.

Thomas Peters, Anita

Thomas, Claudius

Thomas, Franklyn M.

Thomas, Joycelyn

Thomas, Michael

Thomas, Patrick Nelson

Thomas, Sandy

Thomas, Thomas

Thomas-Cooke, Cheryann

Thomas-Eastman, Jacqueline

Thorpe, Charline

Titre, Cyril

Torgerson, Bruce

Treasure, Ferdinand

Treasure, Melrose

Trimmingham, Dorita

Turnbull-James, Lyne

Tutein, Joel

Tutein, Wilma

Vega-Vargas, Percio

Velazquez, Ada L.

Velazquez, Andres

Velazquez, Rita

Vernage, Matthew

Victor, Albert

Victor, Cosmos

Victor, Fenton Curtis

Victor, Mark

Victor, Martha

Victor, Ruben

Vigilant, Lester

Vigilant, Timothy

Viotty, Rollin

Vitalis, Mathurin


KE 12109128

Wallace, Elton

Walter, Davon

Walters, Shawn

Weekes, Reuben

Weeks, Mary Anna

Weston, Thecla

Wheeler, Joseph C.

Wheeler, Stephanie

White, Clyde

Wickham, Sean Ian

William, Augustine

William, John B.

Williams, Albert J.

Williams, Anderson Leroy

Williams, Anthony

Williams, Bernard

Williams, Beryl

Williams, Carol G.

Williams, Ira S.

Williams, Lennard

Williams, Leonox L.

Williams, Lequani L.

Williams, Merle

Williams, Spencer

Williams, Thomas

Williams, Vincent

Wilson, Alfred

Wilton, Marguerite

Wiltshire, Christina

Wiltshire, Susan Gumbs

Woodley, Victoria

Woodrupp de Almonte, Andrea C.

Woods, Benjamin

Xavier, Rosa

Younge, Everette

Younge, Grantley A.


KE 12109128

SCHEDULE 1(i)

Plaintiffs'’ Firms

Burns Charest LLP

Early Law Firm LLC, The

Gori Law Firm PC, The

Harris & Huge LLC

Law Office of Ryan W. Greene

Lee J. Rohn & Associates LLC

Maune Raichle Hartley French & Mudd LLC

Meirowitz & Wasserberg LLP

Murray Law Firm

Pate Law Firm, The

Porter Hedges LLP

Thomas Alkon PC

Waters & Kraus LLP


KE 12109128

SCHEDULE 1(j)

Co-Defendants

4520 Corp. Inc.

ABB Inc.

Abex Corp.

AECOM E&C Inc.

AECOM Energy & Construction Inc.

AERCO International Inc.

Air & Liquid Systems Corp.

Akzo Nobel Chemicals LLC

Akzo Nobel Functional Chemicals LLC

Akzo Nobel Inc.

Allen-Bradley Co.

Alliance Machine Co. Inc., The

Allied Insulation Supply Co. Inc.

Alltite Gaskets Co.

Alton Box Board Co.

American Boiler Tank & Welding Co. Inc.

American Cyanimid

Ameron International Corp.

Amphenol Corp.

Armstrong International Inc.

Armstrong Pumps Inc.

ArvinMeritor Inc.

AstenJohnson Inc.

Atlas Copco Compressors LLC

Atlas Copco North America LLC

Atwood & Morrill Co.

Aurora Pump Co.

AWT Air Co. Inc.

BASF Corp.

BBC Brown Boveri

Bechtel Corp.

Bigelow-Liptak Corp.

Blackmer & Roger Pump Co.

Blackmer Pump Co.

BMCE Inc.

BMW Constructors Inc.

Borden Chemical Inc.

Borg-Warner Morse TEC LLC

Brake Parts Inc. LLC

Buffalo Pumps Inc.

Burnham LLC

BWIP Inc.

Carboline Co.

Carver Pump Co.

Cashco Inc.

CBS Corp.

CDI Corp.

CertainTeed Corp.

Chevron USA Inc.

Chicago Bridge & Iron Co.

Chicago Gasket Co.

Chicago Pneumatic Tool Co. LLC

Chicago Wilcox Manufacturing Co.

Clark-Reliance Corp.

Cleaver Brooks Co. Inc.

Cleaver-Brooks Inc.

Clemco

Clyde Union Inc.

CNA Holdings LLC

Coca-Cola Co., The

ConocoPhillips Co.

Consolidated Edison Co.

Continental Automotive Systems Inc.

Cooper Industries LLC

Corrigan Company Mechanical Contractors

Crane Co.

Cutler-Hammer Inc.

Cyprus Amax Minerals Co.

DAP Products Inc.

deVan Sealants Inc.

Dow Chemical Co.

Dow Chemical Co., The

Durametallic Corp.

EagleBurgmann Industries LP

Eaton Corp. plc

Ecodyne Corp.

Edward Valves Inc.

Electrolux

Entergy Corp.

Essex Specialty Products LLC

ExxonMobil Oil Corp.

FirstEnergy Corp.

Flowserve

Flowserve US Inc.


KE 12109128

Fluor Corp.

Fluor Enterprises Inc.

FMC Corp.

Ford Motor Co.

Formosa Plastics Corp. USA

Fort Kent Holdings

Foster Wheeler Corp.

Foster Wheeler LLC

Gardner Denver Inc.

General Electric Co.

General Engineering Corp.

Geo P. Reintjes Co. Inc.

Glencore Ltd.

Goodyear Tire & Rubber Co., The

Gorman-Rupp Co., The

Goulds Pumps LLC

Greene Tweede & Co.

Grinnell LLC

Guard-Line Inc.

Hauck Manufacturing Co.

Hawkins Parnell & Young LLP

Hercules LLC

Hexion Inc.

Hollingsworth & Vose Co.

Honeywell

Honeywell International Inc.

Howden North America Inc.

Huntington Ingalls Industries Inc.

Hydro-Chem

ICI Americas Inc.

IMO Industries Inc.

Industrial Holdings Corp.

Ingersoll Rand Co.

Inmont Corp.

International Paper Co.

ITE Electrical Products Co.

ITT Corp.

ITT LLC

Jersey Central Power & Light Co.

JM Eagle Inc.

JM Manufacturing Co. Inc.

John Crane Inc.

John Zink Co. LLC

Johnson Controls Inc.

Kaiser-Gypsum Co. Inc.

KC Wall Products Inc.

KCG Inc.

Keeler-Dorr Oliver Boiler Co.

Kennedy Valve Manufacturing Co.

Krogh Pump Co. Inc.

La Mirada Products Co. Inc.

Linde Engineering North America LLC

Litwin Corp.

Lockheed Martin Corp.

Magnum Products

Marley Cooling Tower

McCanna Corp.

McMaster-Carr Supply Co.

Mead Corp., The

MeadWestvaco Corp.

Metropolitan Life Insurance Co.

Metso Minerals Industries Inc.

Milton Roy Co.

Minute Maid Co.

Monsanto Co.

Mount Vernon Mills Inc.

Mueller Co. LLC

Mueller Steam Specialty

MW Custom Papers LLC

MW Kellogg Co., The

Nash Engineering Co., The

Nooter Corp.

Nordstrom Valves Inc.

Occidental Chemical Corp.

Overseas Shipbuilding Group

Pfizer Inc.

Phillips 66 Co.

Pneumo Abex LLC

PNM Resources Inc.

PSEG Fossil LLC

Public Service Electric & Gas Co.

Resal Inc.

Resco Holdings LLC

Research-Cottrell Inc.

Reunion Industries Inc.

Rew Materials Inc.

RIC-WIL Inc.

Riggers & Erectors International Inc.

Riley Power Inc.

Rockwell Automation Inc.

Rockwell Manufacturing Co.

Ross Operating Valve Co.


KE 12109128

Rostone Corp.

RUCO Equipment

Saint-Gobain Abrasives Inc.

Salem Furnace Co.

Schneider Electric SE

Sequoia Ventures Inc.

Shaw Group Inc., The

Sherwin-Williams Co., The

Siemens Industry Inc.

Spence Engineering Co. Inc.

Spirax Sarco Inc.

Sprinkmann Sons Corp.

SPX Cooling Technologies Inc.

Sterling Fluid Systems (USA) LLC

Stubbs Overbeck

Sulzer Pumps (US) Inc.

Swindell-Dressler Corp.

Taco Inc.

Tenova Core Inc.

Tenova SpA

Texaco Inc.

Tnemec Co. Inc.

Trane US Inc.

Treco Construction Services Inc.

Turner Construction Co.

Turner St. Croix Maintenance Inc.

Union Carbide Corp.

Universal Refractories Inc.

US Power Generating Co. LLC

Velan Valve Corp.

Vellumoid Inc.

ViacomCBS Inc.

Viad Corp.

Vickers Inc.

Viking Pump Inc.

Vimasco Corp.

Warren Pumps LLC

Warren Rupp Inc.

Watts Water Technologies Inc.

Welco Manufacturing Co.

WestRock RKT Co.

William Powell Co., The

WTI Rust Holdings Inc.

Wyatt VI Inc.

York International Corp.

Yuba Heat Transfer LLC

Zinclahoma Inc.

Zurn Industries LLC


KE 12109128

SCHEDULE 1(k)

Debtor’s Proposed DebtorProfessionals and Affiliates’ Professionals

Bankruptcy Management Solutions Inc.

Bates White LLC

Beckstedt & Kuczynski LLP

Burns Charest LLP

Haynes &and Boone LLP

Jackson Walker LLP

Kirkland & Ellis LLP

Piper Sandler & Co.

Porter Hedges LLP

Stretto, Inc.

Wilson Elser Moskowitz Edelman & Dicker LLP


KE 12109128

SCHEDULE 1(l)

U.S. Trustees'’ Office

Boykin, Jacqueline

Duran, Hector

Griffin, Barbara

Hobbs, Henry G., Jr.

Johnson-Davis, Luci

McCullar, Alicia

Motton, Linda

Otto, Glenn

Ruff, Jayson B.

Schmidt, Patricia

Simmons, Christy

Smith, Gwen

Statham, Stephen

Waxton, Clarissa

Whitworth, Jana


KE 12109128

SCHEDULE 2

Name of Entity Searched Name of Entity and/or Affiliate of

Entity, that is a K&E Client Status

4520 Corp. Inc. Blount International, Inc. Current

ABB Inc. ABB Ltd. Current

BBC Brown Boveri

AECOM E&C Inc. AECOM Current

AECOM Energy & Construction

Inc.

AECOM-Canyon Real Estate Fund

Advisors LLC

Closed

Akzo Nobel Chemicals LLC Akzo Nobel Nederland BV Closed

Akzo Nobel Functional Chemicals

LLC

AkzoNobel N.V. Closed

Akzo Nobel Inc.

Atwood & Morrill Co. ESCO Group LLC Current

Aurora Pump Co. Pentair Water Pool and Spa, Inc. Closed

Pentair, Inc. Closed

Bankruptcy Management Solutions

Inc.

Stone Point Capital LLC Current

Stretto Stretto Closed

BASF Corp. BASF Americas Corporation Current

Inmont Corp. BASF Catalysts LLC Current

BASF Corp. Current

BlackRock Inc. BlackRock Investment Management

(UK) Limited

Closed

BlackRock, Inc. Current

Mark B. Florian Current

BMW Constructors Inc. BMW Group Current

Borden Chemical Inc. American Securities LLC Current

Borg-Warner Morse TEC LLC Delphi Technologies PLC Closed

CBS Corp. Simon & Schuster, Inc. Closed

ViacomCBS Inc.

CDI Corp. AE Industrial Partners LP Current

CDI Corp. Current

Charles Compton Current

Gryphon Parent, LLC Current

Jonathan Nemo Former

Michael Greene Former

Redwire Corporation Current


2

KE 1210912886428616



CertainTeed Corp. CertainTeed Current

Saint-Gobain Abrasives Inc. Saint-Gobain Abrasives, Inc. Closed

Saint-Gobain Ceramics and Plastics,

Inc.

Current

Saint-Gobain Corp. Closed

Saint-Gobain Performance Plastics,

Inc.

Closed

Chevron USA Inc. Chevron Corporation Current

Texaco Inc. Chevron USA Inc. Current

Chicago Bridge & Iron Co. Berlian McDermott (L) Limited Closed

Shaw Group Inc., The Berlian McDermott Sdn. Bhd. Closed

CB&I (US) Holdings, Limited Closed

CB&I Brazil Holdings, Inc. Closed

CB&I Cairo LLC Closed

CB&I Canada Ltd. Closed

CB&I Clearfield, Inc. Closed

CB&I Cojafex B.V. Closed

CB&I Connecticut Inc. Closed

CB&I Constructors Limited Closed

CB&I El Dorado, Inc. Closed

CB&I Energy Services, LLC Closed

CB&I Europe B.V. Closed

CB&I Fabrication, LLC Closed

CB&I Finance Company Limited Closed

CB&I Financial Resources LLC Closed

CB&I Global Operations

International, Pte. Ltd.

Closed

CB&I Global Operations US Pte.

Ltd.

Closed

CB&I Global, LLC Closed

CB&I Group Inc. Closed

CB&I Group UK Holdings Closed

CB&I Holdco International, LLC Closed

CB&I Holdco, LLC Closed

CB&I Holdings (UK) Limited Closed

CB&I Holdings B.V. Closed

CB&I Houston 06 LLC Closed



3

KE 1210912886428616









CB&I Houston LLC Closed

CB&I India Private Ltd. Closed

CB&I International One, LLC Closed

CB&I International, Inc. Closed

CB&I International, LLC Closed

CB&I Lake Charles, LLC Closed

CB&I Laurens, Inc. Closed

CB&I LLC Closed

CB&I London Closed

CB&I Matamoros, S. de R. L. de

C.V.

Closed

CB&I Middle East Holding, Inc. Closed

CB&I Nederland B.V. Closed

CB&I North Carolina Inc. Closed

CB&I Offshore Services, Inc. Closed

CB&I Oil & Gas Europe B.V. Closed

CB&I Paddington Limited Closed

CB&I Power Company B.V. Closed

CB&I Power International, Inc. Closed

CB&I Power Limited Closed

CB&I Power, LLC Closed

CB&I Project Services Group, LLC Closed

CB&I Rio Grande Holdings, LLC Closed

CB&I Rio Grande Valley

Fabrication & Manufacturing,

LLC

Closed

CB&I Rusland B.V. Closed

CB&I Singapore Pte. Ltd. Closed

CB&I Storage Tank Solutions LLC Closed

CB&I STS Delaware LLC Closed

CB&I STS Holdings LLC Closed

CB&I Tyler LLC Closed

CB&I UK Limited Closed


4

KE 1210912886428616



CB&I Walker LA, LLC Closed

CBI Americas Ltd. Closed

CBI Company B.V. Closed

CBI Company Ltd. Closed

CBI Company Two B.V. Closed

CBI Constructors Pty. Ltd. Closed

CBI de Nicaragua SA Closed

CBI Eastern Anstalt Closed

CBI HoldCo Two Inc. Closed

CBI Overseas (Far East) Inc. Closed

CBI Overseas, LLC Closed

CBI Panama, S.A. Closed

CBI Services, LLC Closed

CBI UK Cayman Acquisition

Limited

Closed

CBI US Holding Company Inc. Closed

Chicago Bridge & Iron (Antilles)

N.V.

Closed

Chicago Bridge & Iron Company Current

Chicago Bridge & Iron Company

(Delaware)

Closed


(IL)

Closed


B.V.

Closed

David Dickson Closed

Horton CBI, Limited Closed

J. Ray McDermott (Aust.) Holding

Pty. Limited

Closed

J. Ray McDermott (Luxembourg),

S.a r.l.

Closed

J. Ray McDermott (Norway), AS Closed

J. Ray McDermott (Qingdao) Pte.

Ltd.

Closed

J. Ray McDermott Canada Holding,

Ltd.

Closed

J. Ray McDermott de Mexico SA de

CV

Closed

J. Ray McDermott Engineering

Services Private Limited

Closed


5

KE 1210912886428616



J. Ray McDermott Far East, Inc. Closed

J. Ray McDermott Holdings, LLC Closed

J. Ray McDermott International

Vessels, Ltd.

Closed

J. Ray McDermott International,

Inc.

Closed

J. Ray McDermott Investments B.V. Closed

J. Ray McDermott Kazakhstan

Limited Liability Partnership

Closed

J. Ray McDermott Logistic Services

Private Limited

Closed

J. Ray McDermott Solutions, Inc. Closed

J. Ray McDermott Technology, Inc. Closed

J. Ray McDermott Underwater

Services, Inc.

Closed

J. Ray McDermott, S.A. Closed

McDermott (Amazon Chartering),

Inc.

Closed

McDermott (DLV 2000 Chartering),

Inc.

Closed

McDermott Aqua Lift II)

Chartering, Inc.

Closed

McDermott Arabia Company

Limited

Closed

McDermott Arabia Holdings, Inc. Closed

McDermott Asia Pacific Pte. Ltd. Closed

McDermott Asia Pacific Sdn. Bhd. Closed

McDermott Australia Pty. Ltd. Closed

McDermott Azerbaijan Marine

Construction, Inc.

Closed

McDermott Blackbird Holdings,

LLC

Closed

McDermott Capital Malaysia Sdn.

Bhd.

Closed

McDermott Caspian Contractors,

Inc.

Closed

McDermott Cayman Ltd. Closed

McDermott Eastern Hemisphere,

Ltd.

Closed


6

KE 1210912886428616



McDermott Engineering L.L.C. and

Khalid Suhail Al Shoaibi for

Engineering Consultancy

Closed

McDermott Engineering Sdn. Bhd. Closed

McDermott Engineering, LLC Closed

McDermott Far East, Inc. Closed

McDermott Finance LLC Closed

McDermott Gulf Operating

Company, Inc.

Closed

McDermott Holdings (M) Sdn. Bhd. Closed

McDermott Holdings (U.K.)

Limited

Closed

McDermott International B.V. Closed

McDermott International

Investments Co. Inc.

Closed

McDermott International

Management S de RL

Closed

McDermott International Marine

Investments NV

Closed

McDermott International Trading

Co. Inc.

Closed

McDermott International Vessels

Inc.

Closed

McDermott International, Inc. Current

McDermott Investments, LLC Closed

McDermott Italia S.r.l. Closed

McDermott Marine Construction

Ghana Limited

Closed

McDermott Marine Construction

Limited

Closed

McDermott Marine Mexico SA de

CV

Closed

McDermott Middle East, Inc. Closed

McDermott Offshore Services

Company, Inc.

Closed

McDermott Old JV Office Inc. Closed

McDermott Overseas Investment

Co. N.V.

Closed

McDermott Overseas, Inc. Closed


7

KE 1210912886428616



McDermott Project Support FZE Closed

McDermott Serviços Offshore do

Brasil Ltda.

Closed

McDermott Subsea Engineering,

Inc.

Closed

McDermott Subsea, Inc. Closed

McDermott Technology (2), B.V. Closed

McDermott Technology (3), B.V. Closed

McDermott Technology (Americas),

Inc.

Closed

McDermott Technology (US), Inc. Closed

McDermott Technology SUB, LLC Closed

McDermott Technology, B.V. Closed

McDermott Technology, LLC Closed

McDermott Trinidad Ltd. Closed

McDermott, Inc. Current

P. T. McDermott Indonesia Closed

P.T. Chicago Bridge & Iron Closed

PT. J. Ray McDermott Indonesia Closed

CNA Holdings LLC Celanese (China) Holding Co., Ltd. Closed

Celanese Corp. Current

Celanese International Corp. Current

CNA Holdings LLC Current

Crane Co. Crane Co. Current

Dow Chemical Co. Dow Chemical Company Current

Dow Chemical Co., The Dow Europe GmbH Closed

Union Carbide Corp. Union Carbide Corporation Current

Ecodyne Corp. Berkshire Hathaway Energy Co. Closed

BHE Renewables, LLC Current

BNSF Railway Current

Essex Specialty Products LLC DowDuPont Inc. Closed

DuPont Dow Elastomers LLC Current

Dupont Performance Elastomers,

LLC

Current

E. I. DuPont de Nemours & Co. Inc. Current

E.I. Dupont Chemical Corporation Closed

Fluor Corp. Fluor Corporation Current

Fluor Enterprises Inc. Fluor Enterprises Inc. Current


8

KE 1210912886428616



Hauck Manufacturing Co. Honeywell Advanced Composites

Inc.

Closed

Honeywell Honeywell ASASCO 2 LLC Closed

Honeywell International Inc. Honeywell ASASCO LLC Closed

Honeywell Holdings International

Inc.

Closed

Honeywell International Inc. Current

Honeywell Specialty Materials,

LLC

Closed

Hess Capital Services LLC Amerada Hess Corp. Current

Hess Corp. Hess Bakken Investments II, LLC Current

Hess Oil & Gas Holdings Inc. Hess Corporation Current

Hess Oil St. Lucia Holdings LP Hess Oil New York Corp. Current

Hess Oil St. Lucia Terminal

Holdings

Hess Virgin Islands Corp. Current

Illinois, State of, Attorney General Illinois Executive Ethics

Commission

Current

Illinois Torture Inquiry and Relief

Commission

Current

Office of the Governor, State of

Illinois

Closed

Ingersoll Rand Co. Ingersoll-Rand Co. Closed

Milton Roy Co. Trane Technologies PLC Closed

Trane US Inc. Trane U.S. Inc. Closed

JM Eagle Inc. J-M Manufacturing Company, Inc. Current

JM Manufacturing Co. Inc.

John Zink Co. LLC Charles Koch Foundation Current

Charles Koch Foundation Events,

LLC

Current

Charles Koch Institute Current

Charles Koch Institute Events Current

Flint Hills Resources LLC Current

Infor Global Solutions Inc. Current

Koch Cos. Public Sector LLC Current

Koch Industries Inc. Current

Koch Minerals & Trading LLC Current

JPMorgan Chase Chase Bank USA, NA Closed

Chase Paymentech Solutions, LLC Closed

Highbridge Capital Management,

LLC

Current


9

KE 1210912886428616



J.P. Morgan AG Closed

J.P. Morgan Securities (Far East)

Limited

Closed

J.P. Morgan Securities Asia Pacific

Limited

Current

J.P. Morgan Securities LLC Current

JPMorgan Asset Management

(Australia) Limited

Closed

JPMorgan Asset Management

(Europe) SARL

Current

JPMorgan Asset Management (UK)

Ltd.

Current

JPMorgan Chase & Co. Current

JPMorgan Chase Bank NA Current

JPMorgan Funds Limited Current

JPMorgan Infrastructure

Investments Fund

Current

JPMorgan Investment Management

Inc. - Global Special Situations

Current

JPMorgan Investment Management

Inc. - Infrastructure Investment

Group

Current

JPMorgan Ventures Energy

Corporation

Closed

Kerwin Clayton Current

Paymentech, LLC Closed

New York, State of, Attorney

General

Empire State Development Closed

New York State Courts Access to

Justice Program

Current

State of New York Closed

Occidental Chemical Corp. Occidental Exploration &

Production Co.

Current

Occidental Petroleum Corporation Current

Pfizer Inc. Hospira, Inc. Closed

Pfizer, Inc. Current

Phillips 66 Co. CF H33 LLC Current

Pneumo Abex LLC Deluxe Entertainment Services

Group Inc.

Closed


10

KE 1210912886428616



Harland Clarke Corp. Closed

MacAndrews & Forbes Holdings,

Inc.

Current

MAFCO Worldwide LLC Closed

Revlon, Inc. Current

Valassis Communications, Inc. Closed

Vericast Corp. Current

Resco Holdings LLC WM Intermediate LLC Current

WM Parent Holding Company, LLC Current

Schneider Electric SE Schneider Electric SE Current

Sherwin-Williams Co., The The Sherwin-Williams Company Current

Siemens Industry Inc. Marc Buncher Current

Siemens Corporation Closed

Siemens Energy Inc. Current

Siemens Industry Software Inc. Current

Siemens Medical Solutions USA

Inc.

Current

Travelers Cos. Inc., The The Travelers Companies, Inc. Current

Turner Construction Co. Sociedad Ibérica De Construcciones

Eléctricas S.A.

Closed

United States, Government of the,

Department of the Interior,

Environmental Protection

Agency

Chamber of Commerce of the

United States

Current

Konstantina Diamantopoulos Former

Orly Godfrey Former

Robert J. Quigley Former

US Power Generating Co. LLC ArcLight Capital Partners, LLC Current

ArcLight Clean Transition Corp. Current

ArcLight Clean Transition Corp. II Current

ArcLight Energy Partners Fund IV,

L.P.

Closed

ArcLight Energy Partners Fund V

LP

Current

ArcLight Energy Partners Fund VI

LP

Closed

ArcLight Energy Partners Fund VII

LP

Current

Daniel R. Revers Current


11

KE 1210912886428616



Vanguard Group Inc., The The Vanguard Group Current

Viking Pump Inc. IDEX Corporation Current

Viking Pump Inc. Current


Schedule 2

Bates White Prior or Current Affiliations

For Services Provided For or on Behalf of Potential Parties in Interest



Hess CorporationBurns Charest LLPKirkland & Ellis LLPOffice Of The Attorney General for the State of IllinoisKaiser Gypsum Company, Inc.Linde AGOffice Of The Attorney General for the State of New YorkOccidental Chemical CorporationPfizer, Inc.PNM Resources, Inc.RILEY POWER INC., f/k/a RILEY STOKER CORPORATIONRockwell Automation Inc as successor in interest to the Allen Bradley Company incorrectly named Rockwell Automation Inc f/k/a Allen Bradley Company Inc., individually and as successor in interest to Rostone CorporationThe Coca-Cola Company, Individually and as Successor-in-Interest to Minute MaidGoodyear Tire & Rubber Co.John Crane IncSiemens Industry Inc.Velan Valve CorporationViad CorpWarren Pumps LLC3M a/k/a Minnesota Mining & Manufacturing CompanyAIGCarrier CorporationCertainTeed CorporationFoster WheelerGarlock, Inc.Internal Revenue ServiceLockheed Martin Corporation Arrowpoint Capital (Formerly Royal Insurance)Securities and Exchange Commission (SEC)The Travelers Companies Inc.Westinghouse electric Corporation n/ka/ Viacom, Inc.Wilson Elser Moskowitz Edelman & Dicker LLPSaint-GobainViacom, Inc.Koch IndustriesAkzo Nobel Coatings, Inc.American CyanamidGeneral Electric CompanyHawkins Parnell & YoungHercules LLCElectroluxUnion Carbide Corporation (UCC)


2

American Standard IndustriesAurora PumpThe Dow Chemical CompanyEssex Chemical CorporationExxon MobilFirstenergy CorporationFlowserve CorporationFord Motor CompanyHoneywell International Inc.Howden North America, IncIngersoll RandInternational Paper CompanyITT CorporationSherwin-WilliamsTrane Co.Armstrong InternationalBeaconMEdaes, a division of Atlas Copco ABBASF Corporation Blackmer Pump CompanyCashcoCBS CorporationChevron Environmental Management CompanyChevron de Puerto Rico, LLC Cleaver-BrooksCNA Holdings LLCCooper Industries, LLCIMO IndustriesElliott Company, a division of CarrierConsolidated Edison CompanyGrinnellPNEUMO Abex LLC, Successor in Interest to Abex Corporation


Chapter 11 ) HONX, INC.,1 - Stretto

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Transcript of Chapter 11 ) HONX, INC.,1 - Stretto