Free Notice (Other) - District Court of Delaware - Delaware

Case 1:04-cv-01559-JFC

Document 55-2

Filed 10/04/2005

Page 1 of 36

EXHIBIT A

Case 1:04-cv-01559-JFC

Document 55-2

Filed 10/04/2005

Page 2 of 36

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

: : USG CORPORATION, : a Delaware corporation, et al., : : Debtors. : ___________________________________ : USG CORPORATION, et al., : : Movant : : v. : : OFFICIAL COMMITTEE OF ASBESTOS PERSONAL : INJURY CLAIMANTS, OFFICIAL COMMITTEE OF : UNSECURED CREDITORS, OFFICIAL : COMMITTEE OF ASBESTOS PROPERTY : DAMAGE CLAIMANTS AND LEGAL : REPRESENTATIVE FOR FUTURE CLAIMANTS, : : Respondents. :

In re:

Chapter 11 Jointly Administered Case No. 01-2094 (JKF)

Civil Action No. 04-1559 (JFC) Civil Action No. 04-1560 (JFC)

DEBTORS' STANDARD QUESTIONNAIRE TO SELECT PERSONAL INJURY ASBESTOS CLAIMANTS
COOLEY GODWARD LLP Stephen C. Neal (CA 170085) Scott D. Devereaux (CA 146050) 3000 El Camino Real Five Palo Alto Square Palo Alto, CA 94306 Tel: (650) 843-5000 RICHARDS, LAYTON, & FINGER, P.A. Daniel J. DeFranceschi (DE No. 2732) Paul N. Heath (DE No. 3704) P.O. Box 551 One Rodney Square Wilmington, Delaware 19899 Tel: (302) 651-7700 JONES DAY David G. Heiman (OH 0038271) Brad B. Erens (IL 6206864) North Point 901 Lakeside Avenue Cleveland, Ohio 44114-1190 Tel: (216) 586-3939

Counsel for Debtors

Answer separately and truthfully in writing each of the questions in this Questionnaire in accordance with the Questionnaire's Definitions and Instructions. Read the entire Questionnaire carefully before completing it. Your completed Questionnaire and all attachments must be received by Rust Consulting, Inc. by January 9, 2006. Make sure that you and your attorney, if you have one, sign the last page of the Questionnaire under oath. Completion of this Questionnaire is mandatory under Federal Rules of Civil Procedure, Rules 26 and 33, made applicable to this proceeding by Federal Rules of Bankruptcy Procedure 7026 and 7033.

Case 1:04-cv-01559-JFC

Document 55-2 DEFINITIONS

Filed 10/04/2005

Page 3 of 36

The words in CAPITALS in the Questionnaire are defined as follows: 1. The INJURED PARTY is the person who allegedly has or had a medical condition caused by asbestos exposure, including but not limited to MESOTHELIOMA, LUNG CANCER, OTHER CANCER, PLEURAL PLAQUES, DIFFUSE PLEURAL THICKENING, ASBESTOSIS, or other non-malignant asbestos-related condition. The PERSONAL REPRESENTATIVE OF THE INJURED PARTY is the person or entity that is filing the claim on behalf of the INJURED PARTY if the INJURED PARTY is legally incompetent or deceased. This person or entity may be, for example, the INJURED PARTY's legal guardian, executor, or administrator. This person or entity is not the attorney representing the INJURED PARTY or the attorney representing the PERSONAL REPRESENTATIVE OF THE INJURED PARTY. The CLAIMANT is either the INJURED PARTY or, if the INJURED PARTY is legally incompetent or deceased, the PERSONAL REPRESENTATIVE OF THE INJURED PARTY. DEBTORS are any or all of the following corporations: USG Corporation, United States Gypsum Company, USG Interiors, Inc., USG Interiors International, Inc., L&W Supply Corporation, Beadex Manufacturing, LLC, B-R Pipeline Company, La Mirada Products Co., Inc., USG Industries, Inc., USG Pipeline Company, and Stocking Specialists, Inc. US GYPSUM is United States Gypsum Company. For a description of the businesses of US GYPSUM and other DEBTORS and a listing of the types of products they manufactured or sold that may have contained asbestos, see Appendix B to this Questionnaire. PLEURAL PLAQUES is a non-malignant, circumscribed or localized area of fibrous material appearing in the lining of the lung or the chest wall. DIFFUSE PLEURAL THICKENING is a diffuse (as opposed to circumscribed or localized) area of fibrosis appearing in the lining of the lung or the chest wall. ASBESTOSIS is diffuse fibrosis (or scarring) on both lungs caused by the inhalation of asbestos fibers. LUNG CANCER is a malignant tumor of the lungs.

2.

3. 4.

5.

6. 7. 8. 9.

10. MESOTHELIOMA is a malignant tumor of the pleura, which is the thin membrane or lining surrounding the lung (pleural mesothelioma). It may also be a malignant tumor of the lining of the abdominal cavity (peritoneal mesothelioma). 11. OTHER CANCER is any cancer other than LUNG CANCER or MESOTHELIOMA and includes but is not limited to colon cancer, laryngeal (voicebox) cancer, esophageal cancer, pharyngeal (throat) cancer, stomach cancer, breast cancer, ovarian cancer, liver cancer, brain cancer, lymphoma (cancer of the lymph nodes (or tissues)), and prostate cancer. 12. FORCED VITAL CAPACITY (FVC) describes the total amount of air that can be forcibly and quickly exhaled after inhaling as much air as possible. 13. FORCED EXPIRATORY VOLUME (FEV1) describes the volume of air that can be forced from the lungs in one second of effort. 14. TOTAL LUNG CAPACITY (TLC) represents the total amount of air that can be taken into the lungs, including the air that cannot be exhaled. 15. DIFFUSION CAPACITY (DLCO or DCO) measures the exchange of oxygen from the air to the blood stream.

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Case 1:04-cv-01559-JFC

Document 55-2 INSTRUCTIONS

Filed 10/04/2005

Page 4 of 36

1.

Read carefully the entire Questionnaire and the Definitions and Instructions before completing the Questionnaire. It is important to read the entire Questionnaire at least once before completing it because you may need to photocopy some sections prior to filling them out so that you can submit multiple copies of the sections. See Instruction No. 4, below. Type or print your answers to each question neatly and legibly using black or blue ink. Use capital letters and avoid contact with the edge of the character boxes. Mark check boxes with an "X" (example at right). Do not use a felt-tip pen, do not write outside the boxes or blocks, and do not bend or fold the pages of the Questionnaire. Do not distribute this Questionnaire to others for their completion because each Questionnaire has a unique identifying number for each CLAIMANT. Be complete, accurate, and truthful in your answers to the questions asked. This Questionnaire is an official court document that may be used as evidence in any legal proceeding regarding your claim. The penalty for knowingly and fraudulently making a false statement under penalty of perjury is a fine of up to $500,000 or imprisonment for up to five years, or both. If you cannot fit all information in any particular section or page, make a copy of that page before filling it out and add the necessary information to the copied page(s). Attach as many additional pages as needed. If the INJURED PARTY is deceased, submit a copy of the death certificate with the Questionnaire. If this Questionnaire is being filed by the PERSONAL REPRESENTATIVE OF THE INJURED PARTY, submit with the Questionnaire written evidence of your authority to act on behalf of the INJURED PARTY. Submit with the Questionnaire copies of the following medical documents: A. B. If in Part 2 you state that the INJURED PARTY has been diagnosed with MESOTHELIOMA, submit a copy of a narrative statement from a diagnosing physician that shows the alleged diagnosis. If in Part 2 you state that the INJURED PARTY has been diagnosed with LUNG CANCER or OTHER CANCER, submit copies of any and all physical exam results, pathology reports, and diagnostic tests or reports that support or conflict with the alleged diagnosis. In addition, submit copies of any and all written statements by a doctor or medical clinic regarding the cause or potential cause of the alleged diagnosis. If in Part 2 you state that the INJURED PARTY has been diagnosed with PLEURAL PLAQUES, DIFFUSE PLEURAL THICKENING, ASBESTOSIS, or another non-malignant asbestos-related condition, submit copies of any and all medical reports and records that support, conflict with, or otherwise relate to the alleged diagnosis, including but not limited to: · Physical exam results; · Pathology reports; · Diagnostic tests or reports; · Laboratory tests; · Letters or other written statements from a doctor or medical clinic; · Radiographic evaluations, such as x-rays or CT Scans; · Pulmonary function test (PFT) reports, including: · Spirogram tracings; · FORCED VITAL CAPACITY (FVC); · FORCED EXPIRATORY VOLUME (FEV1); · TOTAL LUNG CAPACITY (TLC); · DIFFUSION CAPACITY (DLCO or Dco); · Written statements by a doctor or medical clinic regarding the cause or potential cause of the alleged diagnosis.

2.

3.

4. 5. 6.

C.

If in Part 2 you allege multiple diagnoses, submit copies of all medical documents required for each and every diagnosis that you allege. 7. If the INJURED PARTY or the PERSONAL REPRESENTATIVE OF THE INJURED PARTY responded to interrogatories or was deposed in a lawsuit filed by or on behalf of the INJURED PARTY for asbestos-related personal injury, submit with the Questionnaire copies of any and all such interrogatory responses and depositions. If a written claim, including but not limited to a proof of claim form, was submitted by or on behalf of the INJURED PARTY for asbestos-related personal injury in another bankruptcy case or against a trust established pursuant to a plan of reorganization or liquidation in another bankruptcy case, submit with the Questionnaire copies of any and all such written claims. See Part 8 of the Questionnaire. If in Part 4 you identify a co-worker or other person upon whom you rely for your belief that the INJURED PARTY was exposed to an asbestos-containing product of US GYPSUM or another DEBTOR, and if that co-worker or other person was deposed in any asbestos-related personal injury action, submit with the Questionnaire copies of any and all such depositions. See Part 4 of the Questionnaire.
Page 2

8.

Case 1:04-cv-01559-JFC
9.

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In Parts 4-7 of the Questionnaire, you are asked to provide Standard Occupational Classification Codes and Standard Industrial Classification Codes. For a list of these codes, refer to Appendices C and D, respectively, to the Questionnaire.

10. Instead of originals, you may submit photocopies of any and all documents that the Questionnaire requires. DEBTORS will reimburse your reasonable expenses incurred in copying documents that you submit. In Part 10, indicate the documents for which you seek reimbursement and the total amount of the reimbursement you seek. Attach to this Questionnaire a receipt that shows the copy costs you incurred. Upon request, DEBTORS may have access to the original of any document that you submit. Original documents provided to DEBTORS will be returned within a reasonable time after their professionals and experts have reviewed the documents. 11. Make sure that the INJURED PARTY or the PERSONAL REPRESENTATIVE OF THE INJURED PARTY completes and signs the Authorization for Release of Earnings Information and Employment Records From the Social Security Administration contained in Appendix A. You do not need to complete the Request for Social Security Earnings Information Form (Form SSA-7050-F4) that is included in Appendix A with the Authorization. This form is only for your reference. You need only complete and return the Authorization on the first page of Appendix A. 12. Make sure that the CLAIMANT and the attorney of the CLAIMANT, if any, signs the Questionnaire. Make a copy of your completed Questionnaire for your records and submit the original Questionnaire and all supporting documentation to the following address: If by mail: Rust Consulting, Inc. Return Address P.O. Box XXXX Faribault, MN 55021-XXXX If by hand or overnight delivery: Rust Consulting, Inc. 201 S. Lyndale Ave. Faribault, MN 55021

Your completed Questionnaire and all supporting documentation must be received by Rust Consulting, Inc. by January 9, 2006. Do not submit your Questionnaire by facsimile, telecopy, or other electronic transmission. Do not send your Questionnaire to DEBTORS or DEBTORS' counsel.

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PART 1: IDENTIFYING INFORMATION

Provide identifying information regarding the INJURED PARTY, the PERSONAL REPRESENTATIVE CLAIMANT'S attorney, if any.

OF THE INJURED

PARTY, and the

A. INJURED PARTY ­ the person who allegedly has or had a medical condition caused by asbestos exposure. 1. Full Name:
Last

First

MI

2.

Other Names Used: (including maiden name)
Last

First

MI

3. 4. 5.

Social Security Number: Gender: Date of Birth:
Month

Male Female

-

/
Day

/
Year

6.

The Injured Party is:

Living

Deceased

(If deceased, enclose the death certificate.)

a.

If deceased, date of death:
Month

/
Day

/
Year

b. 7.

If deceased, was death asbestos-related?

Yes

No

If the INJURED PARTY is living, provide that person's mailing address:

Street/P.O. Box

City

State

Zip

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PART 1: IDENTIFYING INFORMATION (Continued)

B.

PERSONAL REPRESENTATIVE OF THE INJURED PARTY (not filing attorney) ­ If the INJURED PARTY is legally incompetent or deceased, and has a PERSONAL REPRESENTATIVE other than, or in addition to, his/her attorney, provide the following information for the PERSONAL REPRESENTATIVE submitting the claim. (Enclose written evidence of your authority to act on behalf of the INJURED PARTY.)
1. Name of PERSONAL REPRESENTATIVE:

Last

First

MI

2.

Relationship to INJURED PARTY: The PERSONAL REPRESENTATIVE is the INJURED PARTY's:
(Guardian, Administrator, Brother, etc.)

3.

PERSONAL REPRESENTATIVE'S mailing address:

Street/P.O. Box

City

State

Zip

C. Attorney ­ If the CLAIMANT is represented by an attorney, provide the following information. 1. Attorney Name:
Last

First

MI

2.

Email Contact Information:

3.

Name of Law Firm:

(Print full name)

4.

Firm Address:

Street/P.O. Box

City

State

Zip

5.

Phone Number: Fax Number:

( (

) )

-

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PART 2: ASBESTOS-RELATED AND OTHER INJURIES

Provide information about the INJURED PARTY's asbestos-related personal injury. 1. Has the INJURED PARTY been diagnosed with cancer? Yes No

2.

If "Yes," identify the type of cancer that was diagnosed for the INJURED PARTY and the date of diagnosis. Refer to the definitions of LUNG CANCER, MESOTHELIOMA, and OTHER CANCER on page 1 of this Questionnaire. LUNG CANCER Date of Diagnosis: Month MESOTHELIOMA Date of Diagnosis: Month OTHER CANCER If OTHER CANCER, identify what type. Date of Diagnosis: Month

/
Year

/
Year

/
Year

3.

a. b.

Has the doctor who made the diagnosis of cancer stated that the cancer in question was caused by asbestos exposure? Has any doctor stated that the cancer in question was caused by asbestos exposure or that asbestos exposure was a substantial contributing factor in the cause of the disease?

Yes

No

Yes Yes

No No

4. 5.

HAS the INJURED PARTY been diagnosed with a non-malignant asbestos-related condition?

If "Yes," identify the type of non-malignant asbestos-related condition that was diagnosed for the INJURED PARTY and the date of diagnosis. Refer to the definitions of PLEURAL PLAQUES, DIFFUSE PLEURAL THICKENING, and ASBESTOSIS on page 1 of this Questionnaire. PLEURAL PLAQUES Date of Diagnosis: Month DIFFUSE PLEURAL THICKENING Date of Diagnosis: Month ASBESTOSIS Other Non-Malignant Asbestos-Related Condition Date of Diagnosis: Month If Other Non-Malignant Asbestos-Related Condition, identify what type. Date of Diagnosis: Month

/
Year

/
Year

/
Year

/
Year

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PART 2: ASBESTOS-RELATED AND OTHER INJURIES (Continued)

6.

a.

Has the doctor who made the diagnosis of non-malignant asbestosrelated condition stated that the condition in question was caused by asbestos exposure? Has any doctor stated that the non-maglignant asbestos-related condition in question was caused by asbestos exposure or that asbestos exposure was a substantial contributing factor in the cause of the condition? Has the INJURED PARTY taken a pulmonary function test (PFT)?

Yes

No

b.

Yes Yes

No No Do Not Know

7.

a. b.

If "Yes," provide all of the following information regarding the INJURED PARTY's most recent pulmonary function test (PFT) results. FORCED VITAL CAPACITY (FVC):

TestDat e:
Month Test Date: Month Test Date: Month Test Date: Month 8. a. b.

/
Day

/
Year

Result:

. . . .
Yes

L L L L

% of Predicted:

% % % %

FORCED EXPIRATORY VOLUME (FEV1):

/
Day

/
Year

Result:

% of Predicted:

TOTAL LUNG CAPACITY (TLC):

/
Day
CO

/
Year

Result:

% of Predicted:

DIFFUSION CAPACITY (DLCO or D ):

/
Day

/
Year

Result:

% of Predicted: No Do Not Know

Has the INJURED PARTY had an ILO reading of a chest x-ray?

If "Yes," provide information regarding the INJURED PARTY's most recent ILO x-ray reading. Reading Date: Month

/
Day

/
Year

Results:

/

9.

a.

Has the INJURED PARTY been diagnosed with any other lung condition? Yes No Another lung condition includes but is not limited to: (i) chronic obstructive pulmonary disease (including emphysema and chronic bronchitis), (ii) asthma, (iii) pneumonia, (iv) interstitial lung disease (idiopathic pulmonary fibrosis), (v) silicosis, (vi) effusion (fluid around the lung (pleural cavity)), and (vii) congestive heart failure (fluid in the lung) (lung edema). If "Yes," identify the other lung condition.

b.

10. If in Part 2, Question 2, you allege that the INJURED PARTY has been diagnosed with MESOTHELIOMA, complete this question. Otherwise, continue to Question 11. Attach to this Questionnaire a copy of a narrative statement from a diagnosing physician that shows the alleged MESOTHELIOMA diagnosis, and provide the following information regarding the diagnosing physician. a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box

City Page 7

State

Zip

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PART 2: ASBESTOS-RELATED AND OTHER INJURIES (Continued) 11. If in Part 2, Question 2, you allege that the INJURED PARTY has been diagnosed with LUNG CANCER or OTHER CANCER, complete this question. Otherwise, continue to Question 12. Attach to this Questionnaire copies of all medical documents identified in Instruction 6, subsection B. See page 2 of the Questionnaire. Provide the following information regarding the INJURED PARTY'S doctor(s). If you allege that the INJURED PARTY has been diagnosed with both LUNG CANCER and OTHER CANCER, or with more than one type of OTHER CANCER, photocopy this section and complete it for each alleged diagnosis. A. For the doctor who made the alleged diagnosis of LUNG CANCER or OTHER CANCER: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

c.

Doctor's Diagnosis:

LUNG CANCER

OTHER CANCER, Identify what type:

B. For the doctor, if any, who issued the most recent pathology report regarding the alleged diagnosis: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

12. If in Part 2, Question 2, you allege that the Injured Party has been diagnosed with PLEURAL PLAQUES, DIFFUSE PLEURAL THICKENING, ASBESTOSIS, or another non-malignant asbestos-related condition, complete this question. Otherwise, continue to the Part 3. Attach to this Questionnaire copies of all medical documents identified in Instruction 6, subsection C. See page 2 of the Questionnaire. Provide the following information regarding the INJURED PARTY'S doctor(s). If you allege that the INJURED PARTY has been diagnosed with more than one non-malignant asbestos-related condition, photocopy this section and complete it for each alleged diagnosis. A. For the doctor who made the alleged diagnosis of PLEURAL PLAQUES, DIFFUSE PLEURAL THICKENING, ASBESTOSIS , or another non-malignant asbestos-related condition: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

c.

Doctor's Diagnosis: PLEURAL PLAQUES DIFFUSE PLEURAL THICKENING ASBESTOSIS

Other Non-Malignant Asbestos-Related Condition, Specify:

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PART 2: ASBESTOS-RELATED AND OTHER INJURIES (Continued)

B.

Fort doct ,i any he or f ,who i ssued t most recent pathology report regarding the alleged diagnosis: he
a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

C. For the doctor, if any, who issued the most recent ILO x-ray reading of the INJURED PARTY: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

D. For the doctor, if any, who took the most recent pulmonary function test (PFT) of the INJURED PARTY: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

E.

For the doctor, if any, who most recently treated the INJURED PARTY for the alleged diagnosis: a. Doctor's Name:
Last First MI

b.

Doctor's Address:
Street/P.O. Box City State Zip

Page 9

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PART 3: SMOKING HISTORY OF THE INJURED PARTY

If in Part 2, you allege that the INJURED PARTY has been diagnosed with MESOTHELIOMA, continue to Part 4. Otherwise, complete this Part. 1. Has the INJURED PARTY ever smoked cigarettes, cigars, or pipes? Yes No

Mark the box(es) that apply and provide the information requested. Age When First Started Smoking Cigarettes: Age Started Cigars: Age Started Pipes: Age Started Month Month / Year Month / Year Pipes per Day: (#) Yes No Date, If Any, When Completely Stopped Smoking / Year Cigars per Day: (#) Average Daily Usage

Packs per Day: (#)

. . .

* * *

2.

Has the INJURED PARTY ever used chewing tobacco or snuff?

Mark the box(es) that apply and provide the information requested. Age When First Started Using Chewing Tobacco: Age Started Snuff: Age Started * Month Month Date, If Any, When Completely Stopped Using Average Daily Usage Number of

/
Year

Times per Day: (#) Number of Times per Day: Year (#)

. .

* *

/

Indicate fractional amounts as appropriate, e.g., three and one-half would be entered as 3.5.

Page 10

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PART 4: OCCUPATIONAL EXPOSURE TO PRODUCTS OF UNITED STATES GYPSUM COMPANY OR ANY OTHER DEBTOR

Provide information about the INJURED PARTY's occupational exposure to asbestos-containing products that were manufactured or sold by US GYPSUM or any other DEBTOR. In Appendix B to the Questionnaire, you will find a description of the businesses of US GYPSUM and other DEBTORS and a listing of the types of products they manufactured or sold that may have contained asbestos. 1. Did the INJURED PARTY have occupational exposure to an asbestoscontaining product manufactured or sold by US GYPSUM or another DEBTOR? If "Yes," complete the remainder of this Part as instructed. If "No," continue to Part 5. 2. Did the INJURED PARTY have occupational exposure to more than one asbestos-containing product manufactured or sold by US GYPSUM or another DEBTOR? If "Yes," photocopy this Part and complete the Part for each product. 3. Product Exposed To: (one product per page) Brand Name: Yes No Yes No

Manufacturer of Product: What is the basis for your belief that the exposure was to a DEBTOR'S product and not to another manufacturer's? Personal Recollection Other, Specify:

If you rely on a co-worker of the INJURED PARTY or on another person for your belief that the INJURED PARTY was exposed to a DEBTOR'S product, provide that person's name:

Last

First

MI

If you rely on a co-worker or other person, has this person been deposed in any asbestos-related personal injury action?

Yes

No

If the co-worker or other person has been deposed, attach to this Questionnaire a copy of any and all such depositions. 4. Was the INJURED PARTY exposed to the product in more than one occupation? (Use the Standard Occupational Classification Codes listed in Appendix C.) If "Yes," photocopy this Part and complete the Part for each occupation. 5. Occupation during exposure: (Use the Standard Occupational Classification Codes listed in Appendix C.) Industry during exposure: (Use the Standard Industrial Classification Codes listed in Appendix D.)

Yes

No

Specify if "Other":

6.

Specify if "Other":

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PART 4: OCCUPATIONAL EXPOSURE TO PRODUCTS OF UNITED STATES GYPSUM COMPANY OR ANY OF THE DEBTORS (Continued)

7.

Provide the date range and frequency of product exposure in the listed occupation and industry. If exposure was not continuous in the listed occupation and industry, provide all separate date ranges and frequencies of exposure. Start with the first date range of exposure and finish with the last date range of exposure. If there are more than four date ranges of exposure, photocopy this section before completing it and attach additional pages. For each date range of exposure, describe the exposure type as A, B, C, or D as follows: The INJURED PARTY was: (A) a worker who personally worked with the product identified in Question 3 of this Part; (B) a worker in a room where other workers were personally working with the product identified in Question 3 of this Part; (C) a worker on a floor where other workers were personally working with the product identified in Question 3 of this Part; or (D) a worker at a site where other workers were personally working with the product identified in Question 3 of this Part. Choose the category that best describes the INJURED PARTY'S type of exposure and choose only one category. The best category is the INJURED PARTY'S most typical or most usual form of exposure during the date range at issue. Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

8.

Description of the INJURED PARTY'S job duties:

9.

Description of how the product identified in Question 3 of this Part was used at the site(s):

10. If the exposure(s) listed in response to the above questions was/were at a construction site, state the percentage of time such exposure(s) occurred at residential and commercial sites: Residential:
Page 12

%

Commercial:

%

= 100 %

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PART 5: OCCUPATIONAL EXPOSURE TO OTHER ASBESTOS-CONTAINING PRODUCTS

Provide information about the INJURED PARTY's occupational exposure to asbestos-containing products that were not manufactured or sold by US GYPSUM or another DEBTOR. 1. Did the INJURED PARTY have occupational exposure to an asbestoscontaining product that was not manufactured or sold by US GYPSUM or another DEBTOR? If "Yes," complete the remainder of this Part as instructed. If "No," continue to Part 6. 2. Did the INJURED PARTY have occupational exposure to more than one asbestos-containing product that was not manufactured or sold by US GYPSUM or another DEBTOR? If "Yes," photocopy this Part and complete the Part for each product. 3. Product Exposed To: (one product per page) Brand Name: Yes No Yes No

Manufacturer of Product: 4. Was the INJURED PARTY exposed to the product in more than one occupation? (Use the Standard Occupational Classification Codes listed in Appendix C.) If "Yes," photocopy this Part and complete the Part for each occupation. 5. Occupation during exposure: (Use the Standard Occupational Classification Codes listed in Appendix C.)

Yes

No

Specify if "Other":

If the INJURED PARTY was exposed to the Product in more than one occupation, photocopy this Part and complete the Part for each occupation. 6. Industry during exposure: (Use the Standard Industrial Classification Codes listed in Appendix D.)

Specify if "Other":

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PART 5: OCCUPATIONAL EXPOSURE TO OTHER ASBESTOS-CONTAINING PRODUCTS (Continued)

7.

Provide the date range and frequency of product exposure in the listed occupation and industry. If exposure was not continuous in the listed occupation and industry, provide all separate date ranges and frequencies of exposure. Start with the first date range of exposure and finish with the last date range of exposure. If there are more than four date ranges of exposure, photocopy this section before completing it and attach additional pages. For each date range of exposure, describe the exposure type as A, B, C, or D as follows:

TheI NJURED PARTY was:
(A) a worker who personally worked with the product identified in Question 3 of this Part; (B) a worker in a room where other workers were personally working with the product identified in Question 3 of this Part; (C) a worker on a floor where other workers were personally working with the product identified in Question 3 of this Part; or (D) a worker at a site where other workers were personally working with the product identified in Question 3 of this Part. Choose the category that best describes the INJURED PARTY'S type of exposure and choose only one category. The best category is the INJURED PARTY'S most typical or most usual form of exposure during the date range at issue. Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

8. Descrpton oft NJURED PARTY'S job duties: ii heI

9.

Description of how the product identified in Question 3 of this Part was used at the site(s):

10. If the exposure(s) listed in response to the above questions was/were at a construction site, state the percentage of time such exposure(s) occurred at residential and commercial sites: Residential:
Page 14

%

Commercial:

%

= 100 %

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PART 6: OCCUPATIONAL HISTORY

Provide the complete occupational history of the INJURED PARTY in chronological order, starting with the INJURED PARTY'S earliest employer. Include all jobs in which the INJURED PARTY worked at least a month, including any summer jobs, and conclude with any current employment. For Occupation Codes, use the Standard Occupational Classification Codes listed in Appendix C. For Industry Codes, use the Standard Industrial Classification Codes listed in Appendix D. If the INJURED PARTY has had more jobs than can fit on this page, photocopy the page before filling it out as many times as needed and complete the additional pages. 1. Employer Name: Employer Address:
Street

City

State

Zip

Dates Worked: From: Month Occupation Code: Industry Code:

/
Year

To: o: Month

/
Year

Specify if "Other": Specify if "Other":

2.

Employer Name: Employer Address:
Street

City

State

Zip

Dates Worked: From: Month Occupation Code: Industry Code:

/
Year

To: o: Month

/
Year

Specify if "Other": Specify if "Other":

3.

Employer Name: Employer Address:
Street

City

State

Zip

Dates Worked: From: Month Occupation Code: Industry Code:

/
Year

To: o: Month

/
Year

Specify if "Other": Specify if "Other":

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PART 7: OTHER EXPOSURE TO ASBESTOS

1.

a.

Was the INJURED PARTY exposed to asbestos outside the INJURED PARTY's occupation? Yes No

b.

Was the INJURED PARTY exposed to asbestos through another person (the "Source Individual")? Yes No

If you checked "Yes" to either Question 1(a) or Question 1(b), answer Questions 2 through 4. If you checked "Yes" to Question 1(b), additionally answer Questions 5 through 15. 2. Was the INJURED PARTY exposed to more than one asbestoscontaining product outside the INJURED PARTY'S occupation or through a Source Individual? If "Yes," photocopy this Part and complete the Part for each product. 3. Product Exposed To: (either directly or through Source Individual) Brand Name:

Yes

No

Manufacturer of Product: What is the basis for your belief that the exposure was to a DEBTOR'S product and not to another manufacturer's? Personal Recollection Other, Specify:

If you rely on another person for your belief that the INJURED PARTY was exposed to a DEBTOR'S product, provide that person's name:

Last

First

MI

If you rely on another person, has this person been deposed in any asbestos-related personal injury action?

Yes

No

If the other person has been deposed, attach to this Questionnaire a copy of any and all such depositions.

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PART 7: OTHER EXPOSURE TO ASBESTOS (Continued)

4.

Pr de t dat r ovi he e ange and fequency oft NJURED PARTY's product exposure (either direct or through the Source r heI Individual). If exposure was not continuous, provide all separate date ranges and frequencies of exposure. Start with the first date range of exposure and finish with the last date range of exposure. If there are more than four date ranges of exposure, photocopy this section before completing it and attach additional pages.
Date Range of Exposure: From: Month To: Month Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day: Year Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day: Year Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day: Year Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day: Year

/
Year

/
Date Range of Exposure:

From: Month To: Month

/
Year

/
Date Range of Exposure:

From: Month To: Month

/
Year

/
Date Range of Exposure:

From: Month To: Month 5.

/
Year

/

Source Individual's Name (if you checked "Yes" to Question 1(b)):

Last

First

MI

6.

Was the Source Individual exposed to the product in more than one occupation? (Use the Standard Occupational Classification Codes listed in Appendix C.) If "Yes," photocopy this Part and complete the Part for each occupation. Source Individual's occupation during exposure: (Use Standard Occupational Classification Codes listed in Appendix C.) Source Individual's industry during exposure: (Use the Standard Industrial Classification Codes listed in Appendix D.)
Page 17

Yes

No

7.

Specify if "Other":

8.

Specify if "Other":

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PART 7: OTHER EXPOSURE TO ASBESTOS (Continued)

9.

Provide the date range and frequency of the Source Individual's product exposure in the listed occupation and industry. If the Source Individual's exposure was not continuous in the listed occupation and industry, provide all separate date ranges and frequencies of exposure. Start with the first date range of exposure and finish with the last date range of exposure. If there are more than four date ranges of exposure, photocopy this section before completing it and attach additional pages. For each date range of exposure, describe the exposure type as A, B, C, or D as follows: The Source Individual was: (A) a worker who personally worked with the product identified in Question 3 of this Part; (B) a worker in a room where other workers were personally working with the product identified in Question 3 of this Part; (C) a worker on a floor where other workers were personally working with the product identified in Question 3 of this Part; OR (D) a worker at a site where other workers were personally working with the product identified in Question 3 of this Part. Choose the category that best describes the Source Individual's type of exposure and choose only one category. The best category is the Source Individual's most typical or most usual form of exposure during the date range at issue. Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

Date Range of Exposure: From:
Month

Exposure Type:
Indicate A, B, C or D per Instructions above.

/
Year

Frequency of Exposure During this Date Range: (Answer both items below.) Day(s) per Month: Hour(s) per Day:

To:
Month

/
Year

10. Source Individual's Social Security Number: 11. Source Individual's Gender: 12. Source Individual's Date of Birth:
Month

Male Female

-

/
Day

/
Year

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PART 7: OTHER EXPOSURE TO ASBESTOS (Continued)

13. If the Source Individual is living, provide that person's mailing address:

Street/P.O. Box

City

State

Zip

14.

Sour ndi dualsRel i ceI vi ' atonshi t I p o NJURED PARTY:
The INJURED PARTY is the Source Individual's:
(Spouse, Son, Daughter, etc.)

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PART 8: THE INJURED PARTY'S LAWSUITS AND BANKRUPTCY CLAIMS

A. LAWSUITS

1.

Has a lawsuit been filed by or on behalf of the INJURED PARTY for an asbestos-related personal injury? Yes No

If "Yes," complete the remainder of Part 8.A as instructed. If "No," continue to Part 8.B. 2. Has more than one lawsuit been filed by or on behalf of the INJURED PARTY for an asbestos-related personal injury? Yes No

If "Yes," photocopy Part 8.A and complete the Part for each lawsuit filed. 3. Case Caption:

4.

Case Number:

5.

Court Name:

6. 7.

Case Filing Date:
Month

/
Day

/
Year

Did the INJURED PARTY or the PERSONAL REPRESENTATIVE OF THE INJURED PARTY respond to any interrogatories in this lawsuit? Yes No

If "Yes," attach to this Questionnaire a copy of any and all such interrogatory responses. 8. Were the INJURED PARTY or the PERSONAL REPRESENTATIVE Yes No
OF THE INJURED

PARTY deposed in this lawsuit?

If "Yes," attach to this Questionnaire a copy of any and all such depositions. 9. a. b. Was the lawsuit dismissed? If "Yes," the basis for dismissal: Yes No

10. a. b.

Has a judgment or verdict been entered in this lawsuit?

Yes

No

If "Yes," against what defendant(s) and in what amount(s)? If against more than five defendants, photocopy this question before completing it and complete it for all defendants against whom a judgement or verdict was entered.

$
Defendant Amount

. . . . .

$
Defendant Amount

$
Defendant Amount

$
Defendant Amount

$
Defendant
Page 20

Amount

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PART 8: THE INJURED PARTY'S LAWSUITS AND BANKRUPTCY CLAIMS (Continued)

A. LAWSUITS (Continued)

11. a. b.

Was a settlement agreement reached in this lawsuit?

Yes

No

If "Yes," with what defendant(s) and in what amount(s)? If against more than five defendants, photocopy this question before completing it and complete it for all defendants with whom a settlement was reached.

$
Defendant Amount

. . . . .

$
Defendant Amount

$
Defendant Amount

$
Defendant Amount

$
Defendant c. Amount

If a settlement agreement was reached with US GYPSUM or another DEBTOR, have any settlement amounts been paid? Yes No

d.

If "Yes," by what DEBTOR(s) and in what amount(s)? If by more than two DEBTORS, photocopy this question before completing it and complete it for all DEBTORS who paid a settlement amount.

$
DEBTOR Amount

. .

$
DEBTOR Amount

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PART 8: THE INJURED PARTY'S LAWSUITS AND BANKRUPTCY CLAIMS (Continued)

B. BANKRUPTCY CLAIMS

1.

Has a claim been submitted by or on behalf of the INJURED PARTY for an asbestos-related personal injury in another bankruptcy case ("Other Bankruptcy") or against a trust established pursuant to a plan of reorganization or liquidation in another bankruptcy case ("Bankruptcy Trust")? Yes No

If "Yes," complete the remainder of Part 8.B as instructed. If "No," continue to Part 9. 2. Has more than one bankruptcy claim been filed by or on behalf of the INJURED PARTY for an asbestos-related personal injury? Yes No

If "Yes," photocopy Part 8.B and complete the Part for each bankruptcy claim filed. 3. Other Bankruptcy or Bankruptcy Trust in which the claim was submitted:

4.

Date the claim was submitted:
Month

/
Day

/
Year

5.

Description of the claim:

6.

Did the INJURED PARTY or the PERSONAL REPRESENTATIVE OF THE INJURED PARTY submit any written claim, including but not limited to a proof of claim form, in the Other Bankruptcy or against the Bankruptcy Trust? Yes No

If "Yes," attach to this Questionnaire a copy of any and all such written claims. 7. a. Was the claim paid? Yes b. No

If "Yes," the payment amount:

$
8. a. Yes b. No

.

Was the claim dismissed or otherwise disallowed or not honored?

If "Yes," the basis for disallowance:

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PART 9: THE SOURCE INDIVIDUAL'S LAWSUITS AND BANKRUPTCY CLAIMS

A. LAWSUITS

If you answered "Yes" to Question 1(b) in Part 7 regarding the INJURED PARTY'S exposure to asbestos through a Source Individual, complete this Part as instructed. If you answered "No," continue to Part 10. 1. Has a lawsuit been filed by or on behalf of the Source Individual for an asbestos-related personal injury? Yes No

If "Yes," complete the remainder of Part 9.A as instructed. If "No," continue to Part 9.B. 2. Has more than one lawsuit been filed by or on behalf of the Source Individual for an asbestos-related personal injury? Yes No

If "Yes," photocopy Part 9.A and complete the Part for each lawsuit filed. 3. 4. 5. Case Caption: Case Number: Court Name:

6. 7.

Case Filing Date: Month

/ Day

/ Year Yes No

Did the Source Individual respond to any interrogatories in this lawsuit?

If "Yes," attach to this Questionnaire a copy of any and all such interrogatory responses. 8. Was the Source Individual deposed in this lawsuit? If "Yes," attach to this Questionnaire a copy of any and all such depositions. 9. a. b. Was the lawsuit dismissed? If "Yes," the basis for dismissal: Yes No Yes No

10. a. b.

Has a judgment or verdict been entered in this lawsuit?

Yes

No

If "Yes," against what defendant(s) and in what amount(s)? If against more than five defendants, photocopy this question before completing it and complete it for all defendants against whom a judgement or verdict was entered.

$
Defendant Amount

. . . . .

$
Defendant Amount

$
Defendant Amount

$
Defendant Amount

$
Defendant
Page 23

Amount

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PART 9: THE SOURCE INDIVIDUAL'S LAWSUITS AND BANKRUPTCY CLAIMS (Continued)

A. LAWSUITS (Continued)

11. a. b.

Was a settlement agreement reached in this lawsuit?

Yes

No

If "Yes," with what defendant(s) and in what amount(s)? If against more than five defendants, photocopy this question before completing it and complete it for all defendants with whom a settlement was reached.

$
Defendant Amount

. . . . .

$
Defendant Amount

$
Defendant Amount

$
Defendant Amount

$
Defendant c. Amount Yes d. No

If a settlement agreement was reached with US GYPSUM or another DEBTOR, have any settlement amounts been paid?

If "Yes," by what DEBTOR(s) and in what amount(s)? If by more than two DEBTORS, photocopy this question before completing it and complete it for all DEBTORS who paid a settlement amount.

$
DEBTOR Amount

. .

$
DEBTOR Amount

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PART 9: THE SOURCE INDIVIDUAL'S LAWSUITS AND BANKRUPTCY CLAIMS (Continued)

B. BANKRUPTCY CLAIMS

1.

Has a claim been submitted by or on behalf of the Source Individual for an asbestos-related personal injury in another bankruptcy case ("Other Bankruptcy") or against a trust established pursuant to a plan of reorganization or liquidation in another bankruptcy case ("Bankruptcy Trust")? Yes No

If "Yes," complete the remainder of Part 9.B as instructed. If "No," continue to Part 10. 2. Has more than one bankruptcy claim been filed by or on behalf of the Source Individual for an asbestos-related personal injury? Yes 3. No

Other Bankruptcy or Bankruptcy Trust in which the claim was submitted:

4. 5. 6.

Date the claim was submitted:
Month

/
Day

/
Year

Description of the claim: Did the Source Individual submit any written claim, including but not limited to a proof of claim form, in the Other Bankruptcy or against the Bankruptcy Trust? Yes No

If "Yes," attach to this Questionnaire a copy of any and all such written claims. 7. a. Was the claim paid? Yes b. No

If "Yes," the payment amount:

$
8. a. Yes b. No

.

Was the claim dismissed or otherwise disallowed or not honored?

If "Yes," the basis for disallowance:

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PART 10: CERTIFICATION THAT INFORMATION IS TRUE AND COMPLETE

Make sure that this Questionnaire is certified as true and complete by the CLAIMANT and by any attorney that the CLAIMANT has. Both the CLAIMANT (either the INJURED PARTY or the PERSONAL REPRESENTATIVE OF THE INJURED PARTY) and any attorney for the CLAIMANT must sign below. 1. Use the checklist below to indicate which document(s) you are submitting with this Questionnaire and which you seek reimbursement for. DEBTORS will reimburse your reasonable expenses incurred in copying documents that you submit. Attach to this Questionnaire a receipt that shows the copy costs you incurred. Medical reports or records regarding a diagnosis alleged in Part 2 Responses to interrogatories in lawsuits indicated in Parts 8 or 9 Radiographic evaluations, such as x-rays or CT scans Depositions in lawsuits indicated in Parts 4, 8, or 9 Pulmonary function test (PFT) reports, including spirogram tracings, FORCED VITAL CAPACITY (FVC), FORCED EXPIRATORY VOLUME (FEV1), TOTAL LUNG CAPACITY (TLC), and DIFFUSION CAPACITY (DLCO OR DCO) Written claims, including proof of claim forms, in another bankruptcy or against a bankruptcy trust indicated in Parts 8 or 9 Written evidence of the authority of the PERSONAL REPRESENTATIVE OF THE I NJURED P ARTY to act on behalf of the I NJURED P ARTY (if this Questionnaire is filed by the PERSONAL REPRESENTATIVE) Death certificate (if the INJURED PARTY is deceased) Total amount of copy costs sought: A receipt showing copy costs is attached. 2. Complete and sign the authorization attached as Appendix A to this Questionnaire authorizing the disclosure and use of the INJURED PARTY'S earnings information and employment records from the Social Security Administration. The executed release is attached. 3. I have reviewed the information submitted on this Questionnaire and all supporting documents submitted with it. I declare, under penalty of perjury, that, to the best of my knowledge, the information submitted is accurate and complete. Copy costs sought Copy costs sought Copy costs sought Copy costs sought

Copy costs sought

Copy costs sought

Copy costs sought

Copy costs sought

$

Amount

.

/
Month Day

/
Year

(Signature of CLAIMANT)

/
Month Day

/
Year

(Signature of CLAIMANT'S attorney, if any)

Review your Questionnaire to ensure that it is true and complete and that you have attached all supporting documentation. This Questionnaire is an official court document that may be used as evidence in any legal proceeding regarding your claim. The penalty for knowingly and fraudulently making a false statement under penalty of perjury is a fine of up to $500,000 or imprisonment for up to five years, or both.
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AUTHORIZATION FOR RELEASE OF EARNINGS INFORMATION AND EMPLOYMENT RECORDS FROM THE SOCIAL SECURITY ADMINISTRATION AUTHORIZATION: I hereby authorize the Social Security Administration to furnish to the law firm of Cooley Godward LLP, its partners, employees and agents ("Cooley Godward"), any and all earnings information and employment records ("SSA Employment Records") pertaining to: Name: Other Name(s) Used (Including Maiden Name):

-

-

/
Date of Birth

/

Social Security Number

I hereby further authorize Cooley Godward to prepare and sign a Request for Social Security Earnings Information (Form SSA-7050-F4) on my behalf in order to permit Cooley Godward to request my SSA Employment Records from the Social Security Administration. I acknowledge that I was provided with a blank copy of a Request for Social Security Earnings Information form (Form SSA-7050-F4) for my reference. AUTHORIZED PERSONS AND ENTITIES: This release authorizes Cooley Godward to obtain, receive and use my SSA Employment Records in connection with the litigation entitled In re USG Corporation, United States District Court for the District of Delaware, Case Nos. 01-02094 (JKF), 04-1559 (JFC) and 04-1560 (JFC) ("USG Litigation"). DURATION: This authorization shall become effective immediately and shall expire upon final resolution of the USG Litigation identified above. SIGNATURE:

/
Signature Date

/

If the Authorization is signed by a Personal Representative of the individual, a description of such representative's authority to act for the individual.

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Do

No tF ill O Fo ut r R or e Re fer tu enc rn e wi O th nly Yo -- ur Q ue st io nn ai re
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Do

No tF ill O Fo ut r R or e Re fer tu enc rn e wi O th nly Yo -- ur Q ue st io nn ai re
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Do

No tF ill O Fo ut r R or e Re fer tu enc rn e wi O th nly Yo -- ur Q ue st io nn ai re
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Do

No tF ill O Fo ut r R or e Re fer tu enc rn e wi O th nly Yo -- ur Q ue st io nn ai re
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APPENDIX B COMPANY HISTORY ABOUT PRODUCTS CONTAINING ASBESTOS
United States Gypsum Company is a subsidiary of USG Corporation. United States Gypsum Company was formed in 1901 and is in the business of manufacturing and selling building products. Some of the building products manufactured and sold by United States Gypsum Company from 1920 through 1978 contained asbestos. Products that may have contained asbestos during this period include some wall and ceiling plasters, spray fireproofing, fire-rated ceiling tiles, decorative textures, joint compound, and industrial insulation. Most of these products did not contain asbestos at all times from 1920 through 1978. No product contained asbestos as part of the product formulation after 1978. A list of trade names of products manufactured by United States Gypsum Company during the period from 1920 through 1978 that may have contained asbestos includes, but may not be limited to, the following:
A-B Tex Texture Paint ACOUSTONE 120 Ceiling Tiles ACOUSTONE 180 Ceiling Tiles AUDICOTE Acoustical Plaster Aggregated Spray Finish, White CHINA GLAZE Siding Column Fire Board Concrete Ceiling Texture DURABOND Joint Compound Exterior Texture Wallboard Finish Fire Door Coreboard Hi-LITE Acoustical Plaster IMPERIAL "QT" (Spray) Texture Finish KEMIDOL Joint Compound K-FAC 19 Block Insulation K-FAC Block Insulation MAYFAIR Shake Siding Multi-Purpose Texture Finish ORIENTAL Exterior Finish Stucco ORIENTAL Interior Finish PAC-TEX Texture Paint PERF-A-TAPE Joint Compound PYROBAR Mortar Mix USG "QT" Simulated Acoustical Spray Texture Ready-Mixed Imperial "QT" Simulated Acoustical Spray Texture RED TOP Acoustical Plaster RED TOP BONDCRETE Plaster-Basecoat RED TOP Cover Coat Finish Plaster RED TOP Firecode D Plaster RED TOP Firecode "V" Plaster RED TOP Gypsum Plaster RED TOP Patching Plaster RED TOP Sanded Wall Plaster RED TOP Strucolite Plaster RED TOP Trowel Finish RED TOP Wood Fiber Plaster REGENCY Shingles SABINITE Acoustical Plaster SHEETROCK Radiant Heat Filler-Machine Application SHEETROCK Radiant Heat Simulated Acoustical Texture Simulated Acoustical Spray Texture/Finish Special Texture Paint SPRAYDON Powercote SPRAYDON Standard A SPRAYDON Standard G STRUCTOLITE Plaster Superhard Spray Texture Finish SUPERTITE Roofing Products TEXOLITE Block Filler TEXOLITE Dry Fill TEXOLITE Drywall Surfacer TEXTONE Texture Finish THERMALUX Radiant Heating Panels USG Joint Compound Wainscoat Trowel Finish Plaster

United States Gypsum Company also manufactured other products in the following generic categories that may have contained asbestos: Adhesives Asbestos Board Asbestos Paper Insulating Cement Joint Compound Pipecovering Roofing Products Cement Siding Shingles

USG Corporation was formed in 1985 and is the parent company of various debtors in this chapter 11 proceeding. USG Corporation has never manufactured or sold any building products. Various subsidiaries of USG Corporation manufactured or sold building products that contained asbestos at various times in the past. L&W Supply Company, a subsidiary of USG Corporation, is a distributor of building materials manufactured by United States Gypsum Company and other companies. L&W Supply Company was created in 1971 as a subsidiary of United States Gypsum Company and, since 1985, has been a subsidiary of USG Corporation. In the 1970s, some of the products distributed by L&W Supply Corporation, primarily joint compound and roofing materials, contained asbestos. Since its formation in 1971, L&W Supply Company distribution centers have operated under different business names in different locations. A list of these business names is available on the USG claims website at http://www.usgclaims.com/ LandWbusiness_names.asp. Beadex Manufacturing, LLC, a subsidiary of United States Gypsum Company, manufactured and sold joint compound containing asbestos from 1963 through 1978. Distribution of products that contained asbestos is believed to have been limited to Washington, Oregon, Idaho, Alaska, and possibly Colorado. USG Interiors, Inc., a subsidiary of USG Corporation, was formed in 1986. USG Interiors has manufactured mineral fiber ceiling tiles and suspension systems, mineral fiber insulation, access floors, and wall partition systems. None of the products manufactured or sold by USG Interiors contained asbestos as part of the product formulation.
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APPENDIX C STANDARD OCCUPATIONAL CLASSIFICATION CODES1
Healthcare Practitioners and Technical Occupations 1. Dentists, General Protective Service Occupations 2. Fire Fighters Building and Grounds Cleaning and Maintenance Occupations 3. Janitors and Cleaners, Except Maids and Housekeeping Cleaners Construction and Extraction Occupations 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. 44. 45. 46. Asbestos Removal Workers2 Boilermakers Brickmasons and Blockmasons Carpenters Carpet Installers Cement Masons and Concrete Finishers Construction and Building Inspectors Construction Laborers Continuous Mining Machine Operators Drywall and Ceiling Tile Installers Drywall Finishers (Tapers) Electricians Elevator Installer & Repairers First-Line Supervisors/Managers of Construction Trades and Extraction Workers Floor Layers, Except Carpet, Wood, and Hard Tiles Floor Sanders and Finishers Glaziers Hazardous Materials Removal Workers Helpers ­ Brickmasons, Blockmasons, Stonemasons, and Tile and Marble Setters Helpers ­ Electricians Helpers ­ Extraction Workers Helpers ­ Painters, Paperhangers, Plasterers, and Stucco Masons Helpers ­ Pipelayers, Plumbers, Pipefitters, and Steamfitters Insulation Workers Mine Cutting and Channeling Machine Operators Miner 12 Operating Engineers and Other Construction Equipment Operators Painters, Construction and Maintenance Paperhangers Pipelayers Plasterers and Stucco Masons Plumbers, Pipefitters, and Steamfitters Rail-Track Laying and Maintenance Equipment Operators Reinforcing Iron and Rebar Workers Rock Splitters, Quarry Roof Bolters, Mining Roofers Service Unit Operators, Oil, Gas, and Mining Sheet Metal Workers Stonemasons Structural Iron and Steel Workers Terazzo Workers and Finishers Tile and Marble Setters Installation, Maintenance, and Repair Occupations 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. Automotive Service Technicians and Mechanics Boiler House Mechanics2 Bus and Truck Mechanics and Diesel Engine Specialists Control Valve Installers and Repairers, Except Mechanical Door Electrical and Electronics Repairers, Powerhouse, Substation, and Relay Fabric Menders, Except Garment Heating, Air Conditioning, and Refrigeration Mechanics and Installers Industrial Machinery Mechanics Maintenance and Repair Workers, General Maintenance Workers, Machinery 64. 65. 66. 67. 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. 78. 79. 80. 81. 82. 83. 84. 85. 86. 87. 88. 89. 90. 91. 92. 93. 94. 57. 58. 59. 60. 61. 62. 63. Millwrights Mobile Heavy Equipment Mechanics, Except Engines Motorcycle Mechanics Rail Car Repairers Refractory Materials Repairers, Except Brickmasons Riggers Valve Repairers2 Production Occupations Cabinetmakers and Bench Carpenters Chemical Equipment Operators and Tenders Coating, Painting, and Spraying Machine Setters, Operators, and Tenders Crushing, Grinding and Polishing Machine Setters, Operators and Tenders Cutters and Trimmers, Hand Cutting, Punching, and Press Machine Setters, Operators, and Tenders, Metal and Plastic Dental Laboratory Technician Engine and Other Machine Assemblers Foundry Mold and Coremakers Gas Plant Operators Lay-Out Workers, Metal and Plastic Machinists Metal-Refining Furnace Operators and Tenders Mixing and Blending Machine Setters, Operators, and Tenders Molders, Shapers, and Casters, Except Metal and Plastic Painting, Coating and Decorative Worker Petroleum Pump System Operators, Refinery Operators, and Gaugers Pourers and Casters, Metal Power Plant Operators Prepress Technicians and Workers Printing Machine Operators Sawing Machine Setters, Operators, and Tenders, Wood Stationary Engineers and Boiler Operators Structural Metal Fabricators and Fitters Textile Cutting Machine Setters, Operators and Tenders Textile Knitting and Weaving Machine Setters, Operators and Tenders Textile Winding, Twisting, and Drawing Out Machine Setters, Operators, and Tenders Tool and Die Makers Welders, Cutters, Solderers, and Brazers Welder, Production Line2 Welding, Soldering, and Brazing Machine Setters, Operators and Tenders Transportation and Material Moving Occupations 95. 96. 97. 98. 99. 100. 101. 102. 103. 104. 105. 106. 107. 108. 109. 110. 111. 112. 113. 114. Cleaners of Vehicles and Equipment Conveyor Operators and Tenders Crane and Tower Operators Excavating and Loading Machine and Dragline Operators Industrial Truck and Tractor Operators Laborers and Freight, Stock, and Material Movers, Hand Loading Machine Operators, Underground Mining Locomotive Engineers Locomotive Firers Pump Operators, Except Wellhead Pumpers Rail Yard Engineers, Dinkey Operators, and Hostlers Railroad Conductors and Yardmasters Railroad Car Inspectors2 Sailors and Marine Oilers Ship Engineers Shuttle Car Operators Tank Car, Truck, and Ship Loaders Transportation Inspectors Truck Drivers, Heavy and Tractor Trailer Truck, Drivers, Light or Delivery Service

115. Other (please specify)

Codes are based on U.S. Department of Labor, Bureau of Labor Statistics, List of Standard Occupation Classifieds, found at http://stats.bls.gov/oes/1999/oes_stru.htm unless otherwise indicated. 2 Codes are based on U.S. Department of Labor, Dictionary of Occupational Titles, Fourth Edition, Revised 1991 found at http://www.oalj.dol.gov/public/dot/refrnc/dotalpha.htm with definitions at http://www.oalj.dol.gov/libdot.htm#definitions. Page 33
1

Case 1:04-cv-01559-JFC

Document 55-2

Filed 10/04/2005

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APPENDIX D STANDARD INDUSTRY CLASSIFICATION CODES3
A. B.1 B.2 C. D.1 D.2 D.3 D.4 D.5 D.6 D.7 D.8 D.9 D.10 D.11 D.12 D.13 E.1 E.2 E.3 E.4 F. G. H. I.1 I.2 I.3 J. K. L. M. Agriculture, Forestry & Fishing Mining & Milling (asbestos) Mining & Milling (non-asbestos) Construction Manufacturing ­ Asbestos Containing Products Manufacturing ­ Boilers Manufacturing ­ Chemicals Manufacturing ­ Insulation (asbestos containing) Manufacturing ­ Insulation (non-asbestos containing) Manufacturing ­ Petroleum Refining and Related Industries Manufacturing ­ Plastic Products Manufacturing ­ Rubber Manufacturing ­ Textiles (asbestos containing) Manufacturing ­ Textiles (non-asbestos containing) Manufacturing ­ Transportation Equipment (other than shipbuilding or shipbreaking) Manufacturing ­ Transportation Equipment (shipbuilding or shipbreaking) Manufacturing ­ Other (please specify product) Transportation ­ Electric, Gas, and Sanitary Services Transportation ­ Railroad Transportation ­ Water Transportation ­ Other (please specify) Wholesale Trade Retail Trade Finance, Insurance, and Real Estate Services ­ Automotive Repair Services ­ Miscellaneous Repair Services ­ Other (please specify) Public Administration Military (Non-Navy) Navy Other (please specify)

3

Codes are based on OSHA, U.S. Department of Labor, Standard Industry Classifications, Division Structure, at http://www.osha.gov/oshstats/sicser.html.
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