Levy Konigsberg, L.L.P. JOSEPH ANTHONY JACONIA, Individually

Levy Konigsberg, L.L.P. Moshe Maimon, Esq. (ID: 04269.1 9 8 6) Daniel LaTerra, Esq. (ID: 033702007) 800 3`d Avenue, 11' floor New York, NY 10022 (212) 605 -6200 Attorneys for Plaintiffs

JOSEPH ANTHONY JACONIA, individually SUPERIOR COURT OF NEW JERSEY and as Executor and Executor ad LAW DIVISION-MIDDLESEX Prosequendum of the Estate of LAMONA COUNTY JACONIA, DOCKET NO. MID -L- 2995- 17(AS) Plaintiff,

v. CIVIL ACTION ASBESTOS LITIGATION 3M COMPANY, f/k/a Minnesota Mining and Manufacturing Co., et al. AMENDED Defendants. CROSS -NOTICE OF DEPOSITION

To: Jacqueline Bushwack RIVKIN RADLER, LLO 926 RXR Plaza Uniondale, NY 11566

PLEASE TAKE NOTICE that in accordance with Rule 4:14-2 and 4:14-9 of the New

Jersey Court Rules, Plaintiff by his attorneys, Levy Konigsberg LLP, will take the testimony upon

oral and videotaped examination of Defendant AVON PRODUCTS, INC. ( "AVON "). The

deposition will take place before a person authorized to administer oaths on Wednesday, October 4,

2017 at 9:30AM EST, continuing day -to -day thereafter as needed, at the Doubletree I-Tilton

Nanuet, 425 NY -59, Nanuet, NY 10954. The deponent shall produce all documents responsive to the requests set forth in in the attached Schedule A no later than ten (10) business days before the beginning of the deposition.

{00399195.DOCX) For purposes of this deposition notice and the requests made herein, the following definition; shall apply:

A. "Avon" shall mean Avon Products, Inc., including all past and current employees, officer and directors, and all predecessor and/or successor companies, as well as all companies fro whom Avon acquired the assets and/or liabilities of a talcum powder product. B. "Talcum powder product(s)" shall mean any powder or aerosol product composed wholly o substantially of talc. C. "Avon talcum powder products" shall mean talcum powder products manufactured and /o sold and/or distributed by Avon. D. Asbestos shall mean all asbestos minerals and all asbestos fiber types, including, but no limited to chrysotile, tremolite, amosite, crocidolite, anthophyllite, and actinolite, and shal include all asbestos minerals in any form including but not limited to asbestiform, non asbestiform and `cleavage fragments ".

The deposition shall be taken of the, person or' persons designated by Avon as having the mos knowledge of:

1) Corporate history of Avon, including but not limited to its predecessors and successorship;

2) The corporate liability and/or ownership for all Avon talcum powder products;

3) The suppliers of the talc used to make all Avon talcum powder products;

4) The talc mines from which talc was used to make all Avon talcum powder products;

5) With respect to all Avon talcum powder products, the manufacturing location, th manufacturing process, as well as the sales, distribution and marketing of all such products; 6) Testing for the presence of asbestos in the talc used to make all Avon talcum powde products;

7) Avon's knowledge of the presence of asbestos in any talc used to make any Avon talcu powder products;

8) Testing for the presence of asbestos in all Avon talcum powder products;

9) Avon's policies and procedures regarding the potential presence of asbestos in its talcum powder products;

l0)Avon's specifications, instructions and/or customs and practices with respect to its suppliers of talc in regards to the potential presence of asbestos in talc supplied to Avon;

11) Avon's policies and procedures regarding pre- market product testing and analysis of Avon talcum powder products;

{00399195.DOCXl -2- 12) Avon's policies and procedures regarding post- market product testing and analysis;

1 3) Any recalls issued by Avon with respect to any Avon talcum powder products;

14) Avon's knowledge of the presence of asbestos in any Avon talcum powder products;

15) Avon's knowledge about the scientific methods available to test talc and talcum powder products for the presence of asbestos during all the years in. which Avon sold its talcutr powder products;

16) All testing known to Avon for the presence of asbestos in any talc or talcum powder product: made by any company at any time;

17) Avon's past and current knowledge of the hazards of asbestos;

18) Avon's past and current knowledge about the hazards of talc;

19) Any warnings provided to Avon regarding the presence of asbestos in talc;

20) Any warnings provided by Avon to consumers regarding any Avon talcum powder products;

21) The product names, and years of sale, for all Avon talcum powder products

22) The product formulas for all Avon talcum powder products;

23)11e date on which Avon stopped using talc in any of its products and the reasons for this decision;

24) The roles, responsibilities, activities, and/or participation by Avon in any trade or industry groups, including, but not limited to, the Cosmetic Toiletries and Fragrances Association ( "CTFA ") and the Personal Care Products Council ( "PCPC "); 25) Avon's scientific research and/or interaction and/or correspondence with any scientists of government agency regarding asbestos or talc and/or the potential presence of asbestos in talc;

26) All financial and business interests that Avon has ever had in any talc mine, talc business or talcum powder products other than Avon talcum powder products;

27) All communications that Avon had with any person or entity at any time about presence o absence of asbestos in talc;

28) The existence of any samples or exemplars of Avon talcum powder products;

29) The existence of any samples or exemplars of any talc used to make Avon talcum powder products;

30) Any Industrial hygiene measures at Avon plants and facilities (including air monitoring /sampling for asbestos);

t00399195.DOCX}-3- 31) Asbestosis, talcosis, lung cancer, and /or mesothelioma suffered by or claimed to be suffered by - Avon's current and former employees, including but not limited workers making Avon talcum powder products and salespersons selling Avon talcum powder products;

32) Any studies that Avon has undertaken and/or discussed to determine the incidents o mesothelioma in users of Avon talcum powder products;

33) Animal studies that Avon has undertaken and /or discussed to determine the safety or danger of Avon's talcum powder products;

34)Any report's, incidents or claims of mesothelioma in, any users of Avon talcum powde products;

35) Avon's affirmative defenses and cross-claims, including but not limited to Plaintiff's use o and exposure to asbestos -containing products for which AVON is not responsible

36) Avon's position on Plaintiffs' identification of, use of, and exposure to Avon's talcun powder products in these cases;

37) Avon's profits and financial: condition;

38) The location and process undertaken to search for documents and emails in Avon possession, custody or control relating to the above topics.

PLEASE TAKE FURTHER NOTICE that pursuant to Rule 4:14 -2(d) and Rule 4:18 -1 of the New Jersey Court Rules as well as the June 18, 2014 Order of the Honorable Ana Viscomi,

J.S.C., Defendant Avon shall produce all documents responsive to the following Schedule A at least ten (10) days in advance of the scheduled deposition date.

SCHEDULE A: DOCUMENTS TO BE PRODUCED

As used herein, the term "documents" shall refer to any written, printed, typed or other graphi matter of any nature whatsoever, whether copies or originals, including, but not limited to invoices, delivery tickets, information stored in electronic form, such as word processing files and compute databases, books, papers, memoranda, correspondence, non -identical copies, work papers, ledgers, diar

{ 0 0 3 99 1 95 . DOCX} -4- entries, articles, drafts, materials, records, tapes, notes, drawings, photographs, charts, telegrams telexes, telecopies and emails. All documents or things responsive to these requests that are in the possession, custody or control of Avon and /or Avon's representatives, agents, consultants and/or expert are expressly requested to be produced. Any documents withheld on the basis of privilege shall b: identified in a privilege log with sufficient information upon which the assertion of privilege can b assessed by the parties and, if necessary, the Court.

DOCUMENTS TO BE PRODUCED

1) All documents relating to the corporate history of AVON, including but not limited to its . predecessors and successorship;.

2) All documents relating to the corporate liability and/or ownership for all Avon talcum powde products;

3) All documents relating to the suppliers of the talc used to make all Avon talcum powde products;

4) Al] documents relating to the talc mines from which talc was used to make all Avon talcu powder products originated;

5) All documents relating to the manufacturing location, the manufacturing process, as well as thr sales, distribution and marketing of all Avon talcum powder products; 6) All documents, relating to the testing for the presence of asbestos in the talc used to make al Avon talcum powder products;

7) All documents relating to any knowledge of the presence of asbestos in any talc used to mak- any Avon talcum powder products;

8) All documents relating to the testing for the presence of asbestos in all Avon talcum powder products;

9) All documents relating to Avon's policies and procedures regarding the potential presence of asbestos in its talcum powder products;

10) All documents relating to Avon's specifications, instructions and/or customs and practices with respect to its suppliers of talc in regards to the potential presence of asbestos in talc supplied to Avon;.

11)All documents relating to Avon's policies and procedures regarding pre -market product testing and analysis of Avon talcum powder products;

{00399195.DOCX1-5- 12) All documents relating to Avon's policies and procedures regarding post - market product testing and analysis;

13)All documents relating to any recalls issued by Avon with respect to any Avon talcum powder products;

14) All documents relating to Avon's knowledge of the presence of asbestos in any Avon talc powder. products;

15) All documents relating to Avon's knowledge about the scientific methods available to test tal and talcum powder products for the presence of asbestos during all the years in which Avon sol s its talcum powder products;

16) All documents relating to all testing known to Avon for the presence of asbestos in any talc o talcum powder products made by any company at any time;

17) All documents relating to Avon's past and current knowledge of the hazards of asbesto possessed by Avon;

18) All documents relating to Avon's past and current knowledge about the hazards of talc possesse by Avon;

19) All documents relating to any warnings provided to Avon regarding the presence of asbestos talc;

20) All documents relating to any warnings provided, by Avon to consumers regarding any Avo talcum powder products;

21)A11 documents relating to the product names, and years of sale, for all Avon talcum powdei products;

22) All documents relating to the product formulas for all Avon talcum powder products;

23) All documents relating to the date on which Avon stopped using talc in any of its products an . the reasons for this decision;

24) All documents relating to the roles, responsibilities, activities, and/or participation by Avon i any trade or industry groups, including, but not limited to, the Cosmetic Toiletries an Fragrances Association ( "CTFA ") and the Personal Care Products Council ( "PCPC ");

25) All documents relating to Avon's scientific research and/or interaction and /or correspondent with any scientists or government agency regarding asbestos or talc and /or the potential presenc of asbestos in talc;

26) All documents relating to all financial and business interests that Avon has ever had in any talc mine, talc business or talcum powder products other than Avon talcum powder products;

(00399195.DOCX} -6- 27) All documents relating to all communications that Avon had with any person or entity at an time about presence or absence of asbestos in talc;

28) All documents, and photographs relating to any samples or exemplars of Avon talcum powdet products and such samples or exemplars themselves (i.e. these physical items are requested);

29) All documents and photographs relating to any samples or exemplars of any talc used to mak Avon talcum powder products and such samples or exemplars themselves (i.e. these physica items are requested);

30) All documents and photographs relating to any samples or exemplars of any talc or talcu powder products and such samples or exemplars themselves (ix. these physical items ar requested);

31)A1Ì documents relating to any industrial hygiene measures at Avon plants: and facilitie (including but not limited to air monitoring/sampling for asbestos);

32) All documents relating to any incidents or claims of asbestosis, talcosis, lung cancer, and/or mesothelioma suffered by - or claimed to be suffered by - Avon's current and former employees, including but not limited workers making Avon talcum powder products and salesperson selling Avon talcum powder products;

33) All documents relating to any studies that Avon has undertaken and /or discussed to determin the incidents of mesothelioma in users of Avon talcum powder products;

34) All documents relating to any animal studies that Avon has undertaken and/or discussed t determine the safety or dangers of Avon's talcum powder products;

35) All documents relating to any reports, incidents or claims of mesothelioma in any users of Avo talcum powder products;

36) Any summaries, charts, databases or data compilations in existence that relate to Avon's talc powder products, including not limited to such materials that compile information about brand of Avon's talcum powder products, talc used in particular Avon talcum powder products, testin of Avon talcum powder products and /or years in which various Avon entities sold. particula Avon talcum powder products;

37) All photographs or other images of all Avon talcum powder products;

38) All notes or other writings of Avon's corporate representative relating to this litigation and /o case;

39) All Material Safety Data Sheets for all talc obtained, purchased, and /or received by Avon for us in all Avon talcum powder products;

40) All documents related to Avon's market share regarding talcum powder product sales in the United States for each year beginning with the first year Avon sold talcum powder products until Avon ceased selling talcum powder products in the United States;

{00399195.DOCX} -7- 41)All documents that Avon has produced in any insurance litigation or personal injury litigation relating to Avon's talcum powder products;

42) All depositions, interrogatories, statements, certifications, and/or affidavits that will be used to prove Avon's cross claims, if any, against any other defendant in the above captioned lawsuit;

43) All documents that will be used to assert a claim of exposure and /or causation from a product/premise for which Avon is not responsible, if any, against any party /entity not named in the above captioned lawsuit;

44) All depositions, interrogatories, statements, certifications, and/or affidavits that will be used to prove Avon's claim of exposure and /or causation from a product/premise for which Avon is not responsible, if any, against any party/entity not named in the above captioned lawsuit; 45) All documents that will be used to prove Avon's cross claims or allegations, if any, against any company or entity;

46) All depositions, interrogatories, statements, certifications, and /or affidavits that will be used to prove Avon's cross claims or allegations, if any, against any company or entity; 47) All documents to support Avon's contention, if any, that Plaintiff's mesothelioma was caused by exposure to asbestos from something other than Avon talcum powder products;

48) All documents relating to AVON's profits and financial condition;

49) All documents relating to the location of, process undertaken to search for, and organization o documents and emails in Avon's possession, custody or control relating to any and all of th above topics.

Dated: October 2, 2017 New York, New York

By: DA Levy Konig; Attorneys for

{00399195.DOCX } -8- Levy Konigsberg,.L.L.P. Moshe Mainion, Esq. (ID: 042691986) Daniel LaTerra, Esq. (ID: 033702007) 800 3`e Avenue, 11 th floor New York, NY 10022. (212) 60576200 .Attorneys for Plaintiffs

JOSEPH ANTHONY JACONIA, individually SUPERIOR COURT OF NEW JERSEY and. as Executor and Executor ad LAW DIVISION-MIDDLESEX Prosequendum of the Estate of LAMONA COUNTY JACONIA, DOCKET NO. MID -L- 2995- 17(AS) Plaintiff,

v. CIVIL ACTION ASBESTOS LITIGATION 3M COMPANY, f/k/a Minnesota Mining and Manufacturing Co., et al. CROSS-NOTICE OF DEPOSITION Defendants.

To: Jacqueline Bushwack RIVKINRADLER, LLO 926 RXR Plaza Uniondale, NY 11566

PLEASE TAKE NOTICE that in accordance with Rule 4 :14 -2 and 4 :14 -9 of the New

Jersey Court Rules, Plaintiff by his attorneys, Levy Konigsberg LLP, will take the testimony upon

oral and videotaped examination of Defendant AVON PRODUCTS, INC. ( "AVON "). The

deposition will take place before a person authorized to administer oaths on Wednesday, October 4,

2017 at 9 :30AM EST at the Doubletree Hilton Nanuet, 425 NY -59, Nanuet, NY 10954. The deponent shall produce all documents responsive to the requests set forth in in the attached. Schedule

A no later than ten (10) business days before the beginning of the deposition.

(00399195.DOCX} For purposes of this deposition notice and the requests made herein, the following definition

shall apply:

A. "Avon" shall mean Avon Products, Inc., including all past and current employees, officer: and directors, and all predecessor and/or successor companies, as well as all companies fro whom Avon acquired the assets and/or liabilities of a talcum powder product. B. "Talcum powder product(s)" shall mean any powder or aerosol product composed wholly o substantially of talc. C. "Avon talcum powder products" shall mean talcum powder products manufactured and/o sold and/or distributed by Avon. D. Asbestos shall mean all asbestos minerals and all asbestos fiber types; including, but no limited to chrysotile, tremolite, amosite, crocidolite, anthophyllite, and actinolite, and shal include all asbestos minerals in any form including but not limited to asbestiform, non asbestiform and "cleavage fragments ".

The deposition shall be taken of the person or persons designated by Avon as having the mos knowledge of:

1) Corporate history of Avon, including but not limited to its predecessors and successorship;

2) The corporate liability and/or ownership for all Avon talcum powder products;

3) The suppliers of the talc used to make all Avon talcum powder products;

4) The talc mines from which talc was used to make all Avon talcum powder products;

7) Avon's knowledge of the presence of asbestos in any talc used to make any Avon talcu powder products;

8) Testing for the presence of asbestos in all Avon talcum powder products;

9) Avon's policies and procedures regarding the potential presence of asbestos in its talcum powder products;

1D) Avon's specifications, instructions and/or customs and practices with respect to its suppliers of talc in regards to the potential presence of asbestos in talc supplied to Avon;

11) Avon's policies and procedures regarding pre- market product testing and analysis of Avon talcum powder products;

{00399195.DOCX } -2- 12) Avon's policies and procedures regarding post- market product testing and analysis;

13) Any recalls issued by Avon with respect to any Avon talcum powder products;

14) Avon's knowledge of the presence of asbestos in any Avon talcum powder products;

15) Avon's knowledge about the scientific methods available to test talc and talcum powde products for the presence of asbestos during all the years in which Avon sold its talcu powder products;

16) All testing known to Avon for the presence of asbestos in any talc or talcum powder product' made by any company at any time;

17) Avon's past and current knowledge of the hazards of asbestos;

18) Avon's past and current knowledge about the hazards of talc;

19) Any warnings provided to Avon regarding the presence of asbestos in talc;

20) Any warnings provided by Avon to consumers regarding any Avon talcum powder products;

21) The product names, and years of sale, for all Avon talcum powder products;

22) The product formulas for all Avon talcum powder products;

23) The date on which Avon stopped using talc in any of its products and the reasons for thi decision;

24) The roles, responsibilities, activities, and/or participation by Avon in any trade or indus groups, including, but not limited to, the Cosmetic Toiletries and Fragrances Associatio ( "CTFA ") and the Personal Care Products Council ( "PCPC "); 25) Avon's scientific research and/or interaction and/or correspondence with any scientists o government agency regarding asbestos or talc and/or the potential presence of asbestos i talc;

26) All financial and business interests that Avon has ever had in any talc mine, talc business o talcum powder products other than Avon talcum powder products;

27) All communications that Avon had with any person or entity at any time about presence o absence of asbestos in talc;

28) The existence of any samples or exemplars of Avon talcum powder products;

29) The existence of any samples or exemplars of any talc used to make Avon talcum powde products;

30) Any Industrial hygiene measures at Avon plants and facilities (including an monitoring/sampling for asbestos);

{00399195.DOCX } -3- 31) Asbestosis, talcosis, lung cancer, and/or mesothelioma suffered by - or claimed to be suffered by - Avon's current and former employees, including but not limited workers making Avon talcum powder products and salespersons selling Avon talcum powder products;

32) Any studies that Avon has undertaken and/or discussed to determine the incidents o mesothelioma in users of Avon talcum powder products;

33) Animal studies that Avon has undertaken and/or discussed to determine the safety or dange of Avon's talcum powder products;

34) Any reports, incidents or claims of mesothelioma in any users of Avon talcum powde products;

35) Avon's affirmative defenses and cross -claims, including but not limited to Plaintiffs use o and exposure to asbestos -containing products for which. AVON is not responsible;

36) Avon's position on Plaintiffs' identification of, use of, and exposure to Avon's talcu powder products in these cases;

37) Avon's profits and financial condition;

38) The location and process undertaken to search for documents and emails in. Avon' possession, custody or control relating to the above topics.

PLEASE TAKE FURTHER NOTICE that pursuant to Rule 4:14 -2(d) and Rule 4:18 -1 of the New Jersey Court Rules as well as the June 18, 2014 Order of the Honorable Ana Vìscomi,

J.S.C., Defendant Avon shall produce all documents responsive to the following Schedule A at least ten (10) days in advance of the scheduled deposition date.

SCHEDULE A: DOCUMENTS TO BE PRODUCED

As used herein, the term "documents" shall refer to any written, printed, typed or other graphi matter of any nature whatsoever, whether copies or originals, including, but not limited to invoices delivery tickets, information stored in electronic form, such as word processing files and compute databases, books, papers, memoranda, correspondence, non -identical copies, work papers, ledgers, dia

(00399195 .DOCX} -4- entries, articles, drafts, materials, records, tapes, notes, drawings, photographs, charts, telegrams

telexes, telecopies and emails. All documents or things responsive to these requests that are in th= possession, custody or control of Avon and/or Avon's representatives, agents, consultants and/or experts are expressly requested to be produced. Any documents withheld on the basis of privilege shall b= identified in a privilege log with sufficient information upon which the assertion of privilege can b assessed by the parties and, if necessary, the Court.

DOCUMENTS TO BE PRODUCED

I) All documents relating to the corporate history of AVON, including, but not limited to its predecessors and successorship;

2) All documents relating to the corporate liability and/or ownership for all Avon talcum powde products;

3) All documents relating to the suppliers of the talc used to make all Avon talcum powde products;

4) All documents relating to the talc mines from which talc was used to make all Avon talcum powder products originated;

5) All documents relating to the manufacturing location, the manufacturing process, as well as th sales, distribution and marketing of all Avon talcum powder products;

6) All documents relating to the testing for the presence of asbestos in the talc used to make al Avon talcum powder products;

7) All documents relating to any knowledge of the presence of asbestos in any talc used to mak any Avon talcum powder products;

8) All documents relating to the testing for the presence of asbestos in all Avon talcum powde products;

9) All documents relating to Avon's policies and procedures regarding the potential presence of asbestos in its talcum powder products;

I O) All documents relating to Avon's specifications, instructions and/or customs and practices with respect to its suppliers of talc in regards to the potential presence of asbestos in talc supplied to Avon;

11) All documents relating to Avon's policies and procedures regarding pre -market product testing and analysis of Avon talcum powder products;

( 00399195 .DOCX) -5- 12) All documents relating to Avon's policies and procedures regarding post -market product testing and analysis;

13) All documents relating to any recalls issued by Avon with respect to any Avon talcum powder products;

14) All documents relating to Avon's knowledge of the presence of asbestos in any Avon talcun powder products;

16) All documents relating to all testing known to Avon for the presence of asbestos in any talc o talcum powder products made by any company at any time;

17)All documents relating to Avon's past and current knowledge of the hazards of asbesto possessed by Avon;

18) All documents relating to Avon's past and current knowledge about the hazards of talc,possesse by Avon;

19) All 'documents relating to any warnings provided to Avon regarding the presence of asbestos i talc;

20) All documents relating to any warnings provided by Avon to consumers regarding any Avo talcum powder products;

21) All documents relating to the product names, and years of sale, for all Avon talcum powde products;

22) All documents relating to the product formulas for all Avon talcum powder products;

23) All documents relating to the date on which Avon stopped using talc in any of its products an the reasons for this decision;

24) AlI documents relating to the roles, responsibilities, activities, and/or participation by Avon i any trade or industry groups, including, but not limited to, the Cosmetic Toiletries an Fragrances Association ("CTFA ").and the Personal Care Products Council ("PCPC ");

25) All documents relating to Avon's scientific research and/or interaction and/or correspondent with any scientists or government agency regarding asbestos or talc and/or the potential present of asbestos in talc;

26) All documents relating to all financial and business interests that Avon has ever had in any tal mine, talc business or talcum powder products other than Avon talcum powder products;

(00399195.DOCX } -6- 27) All documents relating to all communications that Avon had with any person or entity at an time about presence or absence of asbestos in talc;

28) All documents and photographs relating to any samples or exemplars of Avon talcum powde products and such samples or exemplars themselves (i.e. these physical items are requested);

29) All documents and photographs relating to any samples or exemplars of any talc used to mak Avon talcum powder products and such samples or exemplars themselves. (i.e. these physica items are requested);

30) All documents and photographs relating to any samples or exemplars of any talc or talcu powder products and such samples or exemplars themselves (i.e.. these physical items ar requested);

31) All documents relating to any industrial hygiene measures at, Avon plants and 'facilitie (including but not limited to air monitoring/sampling for asbestos);

32) All documents relating to any incidents or claims of asbestosis, talcosis, lung cancer, and /or mesothelioma suffered by or claimed to be suffered by - Avon's current and former employees, including but not limited workers making Avon talcum powder products and salesperson selling Avon talcum powder products;

33) All documents relating to any studies that. Avon has undertaken and/or discussed to determin the incidents of mesothelioma in users of Avon talcum powder products;

34) All documents relating to any animal studies that Avon has undertaken and/or discussed t determine the safety or dangers of Avon's talcum powder products;

35) All documents relating to any reports, incidents or claims of mesothelioma in any users of Avo talcum powder products;

36) Any summaries, charts, databases or data compilations in existence that relate to Avon's talcu powder products, including not limited to such materials that compile information about brand of Avon's talcum powder products, talc used in particular Avon talcum powder products, testin of Avon talcum powder products and /or years in which various Avon entities sold particula Avon talcum powder products;

37) All photographs or other images of all Avon talcum powder products;

38) All notes or other writings of Avon's corporate representative relating to this litigation and/o case;

39) All Material Safety Data Sheets for all talc obtained, purchased, and/or received by Avon for us in all Avon talcum powder products;

{00399195.DOCX } -7- 41)AlI documents that Avon has produced in any insurance litigation or personal injury litigation relating to Avon's talcum powder products;

42) All depositions, interrogatories, statements, certifications, and/or affidavits that will be used to prove Avon's cross claims, if any, against any other defendant in the above captioned lawsuit;

43) All documents that will be used to assert a claim of exposure and/or causation from a product/premise for which Avon is not responsible, if any, against any party /entity not named in the above captioned lawsuit;

44) All depositions, interrogatories, statements, certifications, and/or affidavits that will be used to prove Avon's claim of exposure and/or causation from a product/premise for which Avon is not responsible, if any, against any party/entity not named in the above captioned lawsuit;

45) All documents that will be used to prove Avon's cross claims or allegations, if any, against any company or entity;

46) All depositions, interrogatories, statements; certifications, and/or affidavits that will be used to prove Avon's cross claims or allegations, if any, against any company or entity;

47) All documents to support Avon's contention, if any, that Plaintiff's mesothelioma was caused by exposure to asbestos from something other than Avon talcum powder products;

48) All documents relating. to AVON's profits and financial condition;

Dated: September 19, 2017 New York, New York

By: /si Daniel LoTerra DANIEL LaTERRA Levy Konigsberg, LIP Attorneys for Plaintiff

(0Ò399195.DOCX) -8-