Cyprus /Imerys /Luzenac/RTM

Corporate history

1873

Rio Tinto is incorporated in London. - Spanish company

1880s

Imerys founded to perform mining and metallurgy. 1905

Talc de Luzenac (French) is founded.

1907

Talco e Grafite Val Chisone (The Val Chisone Talc and Graphite Co) is founded and gradually absorbs smaller mining companies in the region like "Anglo Italian Talc and Plumbago Mines Company.

1964

Cyprus Mines Corporation acquires Sierra Talc Company and begins :nining talc in the US.

1964-1966

Cyprus sold asbestos fiber. 84 1965

Cyprus purchased the Southwestern Talc Co 1967

THAN markets Cyprus talc. 85

History of J&J's history with Luzenac/Imerys:86

84 CAM-6 NY Times CAM-1 Question 7 85 CAM-112 86 CONFIDENTIAL. IMERYS089960 • -1968 : Ea:51:em Magnesisocmtrsctsto build adedioatedfl.oat plant inWinds01, VTte> male baby powder tsl cfor Johnson and Johnson

• '1988: Eastern l\.t'sgnesiafsilsto oompletethe plant.J sndJtales over ownership, finishes plant. operates facility as Windsor Minerals

• '1988: J&J sellsWindS01 Minerals to Cyprus: signs 10 year oontractto purchase talctrorn Windsor plant

• '1992: Cyp1ussells talc business to Luzen,ac(Rio Tinto)

• '1995: Tai c Purchase Contract 1enegotiated and extend'edto 200 3

• 2003: J&J qualifiesChinesetalcin NA at IO\ver price; Luzenscooukf ne>t-ope-ateWindsar plant profitably; Luz en scsuppl ies J&-J Chinese based product from Houston: Windsor ci osed

• 2005: Escalation of high quali1'/ Chinese ore prices begins

• 200-9: LuzenachelpsJ-t,Jtodefenditself inChinaancf develop a n,ewgloba.lrtand'.Sld tP dMERYS

Cyprus operated or sold talc from the following mines and mills in the 1990:87

Cyprus Industrial Minerals Resources, Products & Technology-

Active Mines -

* Montana - Yellowstone, Beaverhead, Antler

* Vermont-Troy, Chester, Ludlow

* Alabama - Winterboro

* California - Toyon

* Spain- Malaga

*Australia-Mt Seabrook (mine not owned by Cyprus)

*Italy-Val Chisone (mine not owned by Cyprus)

US Mills-

87 CAM-120 Three Forks, MT; Grand Island, NE; Houston, TX; Alpine, AL; Johnson, VT; Windsor, VT; Chester, VT; Columbia, VT; Toyon, CA

Mills processing talc used in cosmetic powders -Alpine, AL; Johnson, VT; Windsor, VT; Grand Island, NE DECLARA TION OF MARGARET J. BAUMGARD NER

I, Margaret J. Baumgardner, declare: 1. I am not a party to this action. I have personal lmowledge of the facts set forth in this declaration, and if called as a witness, I could and would competently testify as to the truth of the matters set forth herein. 2. I am the Research Coordinator for the Claims Resolution Management Corporation ("CRMC"), a wholly owned subsidiary of the Manville Personal Injury Settlement Trust ("Trust"). The CRMC was created in December 1998 and is staffed by former Trust employees. On January 1, 1999, CRMC began providing claims resolution facility services to the Trust. 3. In this position, I manage the Asbestos Claims Research Facility ("Facility"), a document and records repository located at 3390 Peoria Street, Suite 304, Aurora, Colorado. The Facility contains the business records including but not limited to correspondence, memoranda, reports, records and data compilations ("record") of Manville Corporation or related entities ("Manville"), generally, as well as Manville records relevant to litigation of asbestos liability. The Trust has managed and operated the Facility from November 28, 1988, the date on which the Manville bankruptcy plan was consummated. 4. My experience and familiarity with the documents at the Facility began in 1983 while working for Manville. In my work as a paralegal for Manville, I assisted in locating, indexing and packing many of the records which became the foundation documents for the Facility. I continued to work for Manville until September 1987. From March 1988 to September 1988, I was hired to supervise and assist in the indexing of the first 20,000 boxes which were turned over to the Trust in November 1988. From September 1988 to January 1989, I assisted in the privilege review of documents to be given to the Trust. From November 1988 to April 1994, I worked for Freeborn & Peters and was put in charge of the Facility, managing all productions and "new" acquisitions. In September 1995, I was hired by the Trust to manage the Facility. In December 1998, I was hired by the CRMC to manage the Facility for the Trust. Accordingly, I am

PLAINT•FF'S EXHIBIT Declaration of Margaret J. Baumgardner CAM-6 Page 1 personally familiar with many of the records stored at the Facility, as well as how the records have been gathered. 5. To the best of my knowledge, information and belief, I certify that these records were made at or near the time by, or from information transmitted by, a person with knowledge, were kept in the course of the regularly conducted business activity of Manville, and it was the regular practice and the business activity of Manville to make the records. 6. Attached is a document found among the files and microfilm at the Facility and are bates labeled CRMC-HT-TALC-000001 through CRMC-HT-TALC- 000400 and these documents are true and correct copies of documents found at the Facility.

I declare under penalty of perjury under the laws of the State of California and the State of Colorado that the foregoing is true and correct.

rd Executed on August 3 , 2010 in Aurora, Colorado.

Subscribed and sworn to before rd me thi 3 day of August, 2010. AMVWBENHAM NOTARY PUBLIC STATE OF COLORADO My comm1se1on Expires May 1e. 2012

Declaration of Margaret J. Baumgardner Page2 DRAFT

PRIVILEGED & CONFIDENTIAL

Attorney-Client Communication

Attorney Work Product

MEMO: To Helen Marsh, Esq.

FROM: Robert L. Goodb i nder, Esq.

REGARDING: Interview of April 7, 1989 with Earl B. Smith.

DATE: April 12, 1989

On April 7, 1989 I met with Earl B. Smith in Long Beach, California. We spent the entire day discussing his background and his involvement with the business activities of Desert Minerals Inc. and American Mineral Company. This memorandum is a ~ummary of that interview from my personal notes. This memorandum and notes are being incorporated into the Factual Outline of the history and business of these two companies.

CRMC-HT- T ALC-000002 EBS BACKGROUND: EBS has a chemical engineering background. From 1953-1958 he was a Technical Representative for Spencer­ Kellogg. During that time he met Joe Ellsworth who subsequently taught him the talc business. Because EBS's background was in the paint and organic chemicals business it was natural for him to go to work for Desert Minerals in 1961. In 1963 he was promoted to sales manager and remained in that position until leaving Desert on June 4, 1973 after it was acquired by JM. He left Desert/JM only because he saw a move to Denver coming and did not want to leave Southern California. He also perceived there was no future for him with JM because it was such a large corporation. Upon leaving Desert/JM he went to work again for Spencer-Kellogg as Western Region sales representative specifically in the area of paints and resins. He retired from their employ approximately three years ago and is currently 64 years of age. He contemplates not working again but is extremely knowledgeable about Desert/JM and because of his position with them and the fact that it was so small a company he has vast knowledge particularly about the ~roduct line, sales and their distribution system. He has expressed a sincere desire to help with regard to any information we need to gather or confirm and says he has boxes of documents and memorabilia from his tenure with Desert and Desert/JM.

EBS ON DOCUMENTS: He confirms that to the best of his

CRMC-HT-TAL C-000003 knowledge all Desert and American documents regarding sales and distribution systems are stored at the Lompoc, California facility. Additionally he has a number of documents and other materials stored in his garage. He is willing to have us pick those up or review them in California. He has expressed his willingness to help with the interpretation and review of those materials. He cursorily reviewed the Desertalc Handbock and attachments provided to me. He indicates that they are incomplete and that there is at least one other and maybe two additional volumes which would complete the set. Apparently the materials contained in these additional volumes would be comprised of information regarding distribution, sales and marketing efforts. Tom Remmers or Harry Keefe of JM-Celite Division should have information regarding these. He says that Herb Kranich is the individual who originally assembled the materials for the Desertalc Handbook.

EBS ON SALES, MARKETING AND DISTRIBUTION: Desert's primary markets for talc products were: 1. paint, 2. ceramics, 3. cosmetics, 4. plastics, and 5. rubber which was a very small part of sales, never more than 1% of total sales.

From 1961-1969 were years of tremendous growth in sales volume: $500,000 in 1961 to $3,500,000 in 1972 the last year for which EBS had recall without the benefit of sales records. However in approximately 1970-71 the spEcter of

CRMC-HT-T ALC-000004 tremolite reared its head and it was seen as a developing problem which scared Bill Grantham as CEO. Becaus~ eastern talcs were far more tremolitlc than California talcs in general the "scare" affected them more directly and did not greatly affect the marketing of Desertalc products. Growth in sales had been ~teady because the ore bodies owned by the Grantham's was consistent in its high whiteness and extremely large. These properties, including a relatively consistent tremolite content of either approximately 5% or 30% depending on the mine from which it came, made the product more marketable than other competitor's talc, part.icularly those from the west. As a result of these consistent properties the Grantham talc was sold in crude form to many other talc processors. A particularly large consumer of Grantham crude talc was Sierra. Other processors which purchased crude were Western Talc, which became Vanderbilt, and Kennedy Minerals, which became C. K. Williams. After the acquisition by JM there were still sales of crude to other processors. They all could have sold to rubber manufacturers, but EBS could express no thoughts about that.

An important fact is that here was no steam operated micronizing equipment in California except theirs. From this he indicates that no other processor would have bought crude talc for compounding into rubber products because no one in California could process it properly for use as a compounding agent. This is not true for dusting talc as any processor

CRMC-HT-T ALC-000005 TABLE OF CONTENTS

FOREWORD - Our Competition Is II UNITED SIERRA DIVISION OF CYPRUS MINES CORPORATION I. HISTORY 1 II. GEOGRAPHY 1 Ill. M_INING 1 IV. MANUFACTURING 1 V. MARKETING 2 PFIZER, INC. I. HISTORY 2 11. GEOGRAPHY 3 Ill. MINING 3 IV. MANUFACTURING 3 V. MARKETING 3 INTERNATIONAL TALC COMPANY I. HISTORY 4 11. GEOGRAPHY 4 Ill. MINING 4 IV. MANUFACTURING 4 V. MARKETING 4 R. T. VANDERBILT COMPANY, INC. I. HISTORY 5 II. GEOGRAPHY 5 Ill. MINING 5 IV. MANUFACTURING 5 V. MARKETING 5 ENGELHARD MINERALS & CHEMICALS CORPORATION 6 WHITTAKER, CLARK & DANIELS (W,C&D) 6 OTHER COMPETITION I. DOMESTIC TALC 6 A. Southern Talc Company, Chatsworth, Georgia 6 B. American Talc Company, Alpine, Alabama 6 C. Pioneer Talc Company, Allamore, Texas 6 D. Metropolitan Talc Company, Plainfield, New Jersey 7 II. IMPORTED TALC 7 A. Canadian 7 B. Italian 7 C. French .7 CONCLUSION 8 TABLE I 9 TABLE II 10 TABLE Ill 11 TABLE IV 12

CRMC-HT-TALC-000027 DESERT ALC® COMPETIT·ION

FOREWORD OUR COMPETITION IS -

- talc originating from our region and other regions in the world, Other than California, the major deposits of talc In the United States are in New York and Montana, with lesser deposits In Vermont, the Southeastern States, and In Texas. The largest source of white or high-brightness talc Is Grantham Mlnesl In general, the other sources are specialized or limited because of purity, color, hardness or abrasiveness, or Just piain a11c1italJijiiy. Other ccmestlc non-metallic minerals such as clay, silica, diatomite, limestone, barytes, gypsum, etc., are not directly competitive to talc because of, in each case, a different function as to chemical and physical properties.

There are other sources of talc in the world market that pose regional competition from the economic factors but the world market potential consumption for our products is substantial because of the unique and ample supplies of the basic crude Grantham resources. Importation df European (notably French and Italian talc) and Canadian talcs has been described In the DESERTALC business portion of this handbook. Imports of talc Into the United States have remained relatively constant where Canadian Imports have Increased and the European imports have decreased.

Keenest competition to our products is at the lower price (and profit margin) ·products. Our real value and growth potential rests in the properties developed In the mlcronlzed CYCLONIZED ®, or ultra-fine grades where specialized usage commands a higher price and profit. In consideration of all of our competitors products, It Is in these premium grades where efforts should be concentrated.

Ii CRMC-HT-TALC-000028 UNITED SIERRA DIVISI01N OF CYPRUS MINES CORPORATION

I. HISTORY USD is considered one of the largest talc producers in the world having. mining, manufacturing, and distribution facilities In the United States, Europe, Mexico and other areas. Cyprus Mines Corporation acquired the Sierra Talc Company In 1964 and the Southwestern Talc Company in 1965. As an Independent producing company, Sierra Talc was one of the largest domestic suppliers In the industry. Sierra Talc Company was headquartered in South Pasadena, California, and was a leader in the Industry in research and technical development. They developed a broad line of products specialized for industry consumption with emphasis on ultra-fine or mlcronized products. Desert Minerals has been fortunate in acquiring much experience and knowledqe in our association with Individuals such as Joe Ellsworth, Dick Lamar, and Norman Scheffel who all were former employees of the Sierra Talc Company. This experience coupled with the superiority of our basic crude resources has been a fortunate combination which is now even further amplified with the resources of Johns• Manville Corporation.

II. GEOGRAPHY USD has Its headquarters and research facilities at Trenton, New Jersey, from which all activities are directed In talc as well as other non-metallic mineral products. USO mines and mills talc In California, Montana, and Texas. Domestic manufacturing facilities are located at Los Angeles, Keeler and 'Olancha, California; Three Forks, Montana; ana Gra'r'ld 'island, Nebraska. European business Is operated through a subsidiary CMC-Slerra Corporation operatlnq e facility at Ghent, Belgium, based on crude talc shipped from the United States and Australia.

Ill. MINING USO has historically purchased the bulk of their California talc from Grantham Mines, securing from them a uniform source of high-brightness, crude ore. USD has not publicized this fact; rather, they have promoted the image that they mine California talc from several active mines In the Death Valley area of California. The two principal USO mines that have been publicized are the Panamint and Ibex deposits which are somewhat similar to Grantham talcs In be.Ing tr-amolltic, but are not quite as high brightness as Grantham. USD has historically built a rather broad range of products on the Grantham talc utilizing the high-brightness and uniformity features. The Montana operations of USO are open pit from either the Yellowstone or Beaver head Mines. Yellowstone talc must be hand sorted to produce a commercial grade free from impurities of a steatlte type talc. USO Mlstron Vapor Is based on Yellowstone talc from Montana. Texas talc, as supplied, by the Southwestern Talc Corporation, is also open pit. Texas talc is grey to nearly black In color due to organic Impuntles which make the ground products relatively undesirable for paints and coatings, but ceramic products fired at high temperatures are suitable because the talcs are white firing.

IV, MANUFACTURING · USO processing plants are strategically located for the resources. Steatite and cosmetic grade talcs are processed at Keeler, California, on the west side of Death Valley. The Los Angeles operation processes primarily paint talcs shipped from Grantham and th.e Southern Death Valley area, Montana talcs are processed at Three Forks, Montana. A fourth mill located at Grand Island, Nebraska, was located at this point to process talcs from either Montana or California enroute to the ~astern markets. The Grand Island location offers no advantage to processing California talcs other than It being a junction point for processing both California and Montana source matertals. Basl~ processing of crude talc at all USO locations Is the same as our processing With the additional facllltles of fluid energy milling for the production of the ultra-fine Mlstron Vapor and Mlstron Frost products.

CRMC-HT-TALC-000029 V. MARKETING USO products service all the industries with which DESERTALCS and CYCLONIZED products are serviced - ceramics, paint, plastics, paper, rubber, cosmetlcs, etcetera. USO markets their products partially on a direct basis and partially through distributors. The direct sales organization is Industry oriented with specialists traveling nationally out of Trenton and some sales offices in the Northeastern United States. Thompson-Hayward ls the distributor In the Central and Southeastern states. Van Waters and Rogers is the distributor in the West and Northwestern states. Table I Is a data sheet defining the major USO products by Important properties. Due to product and specification changes, all of the known products are not listed. Any old or new product numbers or designations that you encounter competitively that are not listed should be evaluated tor current recommendations. In general, the Flbrene products are Raymond Mill grinds utilized by the paint and plastics industries. The Mlstrons are ultra-fine or mlcronlzed products requiring additional processing after the Raymond Mill production. Our DESERTALC MIKRO and CYCLONIZED product series are comparable to the Mistron series. Other speciality grades are often designated by the crude source or special names definitive for the Industrial consumption. Your DESERTALC Competitron Data Sheet provides our recommendations for general usage.

PFIZER, INC. I. HISTORY The talc operations are assigned to the MPM (Minerals, Pigments and Metals Division) and consist of the consolidated operations from several acquisitions. The basic ~o.:.l~iun i,, ·t&·l.:: was Initiated PY the .acqulsltlon of C. K. Willia.ms & Company In 1963. Prior to that, C. K. Williams had acquired the Kennedy Minerals Company of Los Angeles. Kennedy Minerals had operated a mineral processing plant In Los Angeles for several years and was Involved with Louise Grantham as described In the DESERTALC Business section of this Handbook by mining at Warm Springs under contract starting in 1943. Kennedy Minerals marketed talcs under the name of Kentalc, Fibre M, and Warm Springs Talc. Kennedy. Minerals operation in Los Angeles consisted essentially of Raymond Mill production from which he supplied his products at 200 mesh to the ceramic Industry and at 325 mesh to the paint Industry. The acquisition by C. K. Williams and subsequently by Pfizer of course did not Include the Grantham Mine at Warm Springs Canyon, but It did include two other smaller operating mines in Death Valley called the Eclipse and the Death Valley Mines. Pfizer operated these mines on a small scale and initiated the conversion of the Kennedy Minerals' names to a number system with the coined names Talcron. Then In 1966, Pfizer made an additional acquisition which implanted the MPM Division more firmly Into the talc business. This acquisition was that of Southern Callfornla Minerals Company with a mill in Los Angeles and a mill at Dunn, California. It Is this Dunn MIii that was placed into operation In 1963 by SCMC that Is now owned by Johns-Manville for expansion of the Desert Minerals product line. This acquisition also included the purchase of the Tri-State Minerals Company and the Fine Pigments Corporation with plants and mines at Barretts and Dillon, Montana. These Montana operations constituted a joint venture between Southern California Minerals Company and Whittaker, Clark & Daniels. SCMC operated the mines and production facilities and WCD exclusively marketed the finished products east of the Rocky Mountain states. It was through WCD's efforts that WCD 399 SF (Super Fine) became established in the Eastern paint Industry as the preferred mfcrontzed talc. Many other grades of Montana and California talcs were marketed by WCD under-a complex nurnberlnq system. WCD has continued to market selected products under a contract with Pfizer since the acquisition - notably WCD 399 SF. Pfizer, thus, supplemented their initial acquisition with additional California mines In the Death Valley area under such names as Apex, Acme, Monarch and Superior. In Montana, the Treasure and Regal Mines continue to supply. Pfizer has amplified the product line accordingly with additional trad,emarks Cercron (ceramic talcs) and Microtalc (micronlzed) along with a complex numbering system. Pfizer's activities in the non• metallic mineral business are supplemented with Eastern and Western sources of calcium carbonates, barytes, and others.

2 CRMC-HT-T ALC-000030 ~· • PLAINTIFF'S ... EXHIBIT ... CAM-112 .. . ~-· , \ 1967 -

SUBJECT:

We have entered into an agreement with United erra Division to again market their talc and diatomite products. .

After approximate~lne year of selling Pf er Talc products;. we have decided that it woul be to ow: best over l interest to again sell . United Sierra prod~cts Some branches e done a commendable job in retaining and buildtiut- talc busines this past year, while others have not been successful~ We realize e difficulty invoived in ·first converting customers" and then -converting them. However, considering this factor, w~:elieve at the majority of the br~ucbes will profit greater from. th\ new rangement. Attached is a copy of the aP,eeme t with United Sierra. Note t.'1at it bec:omes effective July l .. \ In ddition to the states lis:=e~ we will also sell in tha~ portio~of Illinois regularly covered bys~. Louis and Davenport. We will d11 United Sierra label p:oducts in LCL quantities, as well as spl t carloads providing the split is with a T-H warehouse. It is n t intended that we sell full ~z.zloacs of United Sierra label product· to third parties. I \ Additionally the agreement.prov,des for us to sell LCl. lots u~ce: T•H label outside the territory $_pecified and c&::-load T·=i ls'b.al w:.:::h• in the territory if mutually agrx· ed upon. All such ca:::oad s.~cou.:-.~s should be referred to me for han ling• .. Note further that the agreement i for 5 years, can..:el;.ai:iie on one years notice waich will profaect our selling efforts.

United Sierra has maintained wareliouse stocks for LCL cus~v.~ar s i~ Sr:. Louis, Dallas, Houston, Oklahoma City and Kansas City. We :.&va agreed to take over this stock by!July l, providir.g tha s~oc~ is marketable in the area invo~ved. ·:United Sierra wa.nts to closa a:i warehouses by this time, sotleast cooperate to this e~d. ~f yv~ cannot meet this camnittmen , ple se let me kpow. We will be i:.-.• voiced for this stock deliv ed t our warehouses at the ca:lo&d p:ica, less 51., plus· the minimum ra'fel freight. Issue your confirming ?.;.:chaiie orders after inbounding this ltc:Q.c'It,

Attached is the current United Sierra ~rice list. 0-.ir p=ice s~a~:s have been issued, As you establish your local LCL price s~:-..al~:es, please keep in mind that price i~ not a prime sales factc: o~ ~~le to many of our customers. This has been amply dei:lonst:rated by o~ in· ability to conver,tdily frau one_ product to another. P&ge l·-- NAP 70128468 SERIES •o• ...

A United Sierra representative will supply you with a list of t~a~= present LCL customers including the grades and quantities they e:e purchasing. They will also supply you current technical litara.tu::-a. I have copies of the United Sierra LCL price schedule covering ws:e­ house sales from Dallas. Houston, Kansas City and Cklaho=a City, These are being sent separately to branches previously served by these war ehousea.

Yours truly

MKM:zip

NAP 70128489 SERIES •o• lmerys - J&J Meeting

OlU1n- D~fferentnated Offeirnrr,g

i) IM ERYS

1 • A long history of working together based on mutual trust to achieve common goals.

• lmerys Talc is a world leader in product quality, product aid process innovation, and analytical capabilities managed by dedicated and highly experienced employees with expertise in mineralogy, asbestos identification, and world regulations.

• lmerys operates a one-of-a-kind product stewardship proqrarn that goes beyond compliance with global regulations.

• We are vertically integrated and maintain strict chain of custody at all times for all purchased ores, thereby improving supply and quality consistency.

• We follow strict quality control protocol from mine to market.

• We meet 35 physical, chemical and microbiological specifications. The batch sterilization process in Houston is unique to J&J.

c!) IMERYS

2 • 1966: Eastern Magnesia contracts to build a dedicated float plant in Windsor, VT to make baby powder talc for Johnson and Johnson

• 1968: Eastern Magnesia fails to complete the plant; J and J takes over ownership, finishes

plant, operates facility as Windsor Minerals

• 1988: J & J sells Windsor Minerals to Cyprus; signs 10 year contract to purchase talc from

Windsor plant

• 1992: Cyprus sells talc business to Luzenac (Rio Tinto)

• 1995: Talc Purchase Contract renegotiated and extended to 2003

• 2003: J & J qualifies Chinese talc in NA at lower price; tuzenac could not operate Windsor plant profitably; Luzenac supplies J&J Chinese based product from Houston: Windsor closed

• 2005: Escalation of high quality Chinese ore prices begins

• 2009: Luzenac helps J&J to defend itself in China and develop a new global standard (!) IM ERYS

3 Long term resources under control (US, EU, Asia Pacific) Quality systems • Global Pharmacopeia compliance (EP, US, JP) • Quality systems · ISO 9001:2000 · ISO 14001 • GM P excepient • Certificate of analysis • Product specifications • TDS, MSDS Unique and extensive product stewardship programs i) IM ERYS

4 lmerys offers wide range of products to the Personal Care market

USA France Belgium Italy Luzenac pharma Luzenac pharma M

Imperial 400 USP Imperial 500 USP Luzenac pharma M

Grade 25 f.4istron Flair HT Luzenac oxo Extra 5/0 Dec Olympic H USP Luzenac o Pyrenean Silk HT Imperial 200

Supra H USP Extra 5/0 Dec Supreme H USP Superiore MlO Dec Suprafino H USP Luzenac 00 Luzenac Pharma M

Steasilk 5 CH Steasilk 5 GHT Steasilk 5AH

Steasilk 5 Y Steasilk 5 Cl

Glacier 200 Luzenac OXO Mistron CG Luzenac Pharma Glacier 400 Luzenac 00 Mistron CGHT

Imperial 500 USP Imperial 700 FCC Luzenac Imperial 400Y G20F

Luzenac OXO Luzenac 00 Extra ~~.o ... • Extrat:,/ Imperial 250 USP Luzenac OOC IMERYS

5 ------·---- A wide range of products with a long outstanding history matching the regional requirements

{,, Industries USA France Belgium Italy Cosmetic$: Body powder Grade 25 Luzenac Mistron Flair HT Extra 5/0 Dec \:}iif Olympic H USP oxo Pyrenean Silk HT Imperial 200 Luzenac 0 I

TECH NI.CAL Whiteness Screen Residue Quartz Loose density Compliance 3 DATA SHEET y (Alpine ajrjet} (FT IR•%} (g/cm } status Grade 25 91.0 ~ 75 µm - max 1.5% 10.1 <0.1 0.40 USP, CTFA, CTPA Imperial 200 87 GEB ~ 75 µm - max 2.0% 14 .. 0 <0.1 0.53 USP, CTFA, CTPA Olympic H USP 85GEB ~ 75 µm - max 0.5% 10.5 <0.1 0.42 USP, CTFA, CTPA Extra 5/0 DEC 91.0 ~ 75 µm-max 2% 12.0 <1 0.50 CTFA,CTPA Mistron Flair HT 86.0 ~ 75 µm - max 2% 13.9 <0.5 0.50 CTFA,CTPA Pyrenean Silk 82.0 ~ 75 µm - max 2% 9.6 <1 0.49 CTFA,CTPA HT e) IM ERYS

6 • PCPC/CIR/FDA/USP/IPEC • ANSES, health council of Netherlands • Korean talc issue • China developments • IARC reviews • I MA and Euro-Talc • ASTM and ISO • NIOSH "Roadmap" for asbestos • Judgment against "industrial talc" (2008) - supplier exits from the market • Congressional bills have proposed expanding asbestos "definitions." • Lack of consistent definitions - listed as high priority at ASTM Johnson Asbestos Conference • "Naturally occurring asbestos" (NOA) - leading labs disagree on results

eJ IM ERYS

7 • Microscopy/Spectral Analysis - Optical Microscopy: PLM, Dispersion Staining Scanning electron microscopy (SEM) Transmission electron microscopy (TEM) X-ray diffraction (XRD) Infra-red spectroscopy/microscopy (FT-IR) Thermal gravimetric analysis (TGA) Chemical analysis (EDS, XRF, LECO)

Product • Physical Testing Development - Particle size ,/ • Median (SediGraph, Coulter) • Top size (Hegman, Sieve) - Surface area Operations/ Res.Jurce - Color/Brightness (Minolta, GEB) 3 Dev:llopment 60% Customer - Other Support (!J IMERYS

8 • Quality standards are not necessarily consistent globally. We take the most conservative approach to

keep a// fibers out of products using the most comprehensive and sensitive test methods

• Continue to ensure that talc is safe (has been used in the most sensitive markets for over a century)!

• Continue to ensure that global government authorities deem our products are safe

• Maintain programs that decrease liability and maintain reputation for lmerys and its customers

• Diligently ensure employees safety

• Continually monitor current issues / trends

• Influence regulations and develop test methods

• Continue to participate in regulatory discussion (IARC, NTP, ASTM, ISO, USP/FDA, etc.)

Beyond the safety of our workers and product end-users, limiting liability to lmerys and our customers is the driver behind our programs eJ IM ERYS

9 ------·---·-----·-----·--·----·-·---- J&J testing protocol developed and instituted in early 90's

lmerys uses a combination of state-of-the-art techniques to test for asbestos Microscopy Methodology TEM = Transmission Electron Microscopy SEM = Scanning Electron Microscopy PLM = Polarizing Light Microscopy PCM = Phase Contrast (light) Microscopy

Non-microscopy Methodology XRD* = X-ray Diffraction

*XRD cannot distinguish asbestiform from non-asbestiform e) varieties of the same mineral. IM ERYS

10 lmerys is committed to ensuring its products meet or exceed product quality standards • We map our talc deposits to avoid impurities including those that occur naturally in some lower quality ore bodies Use only highest quality ore · Can't process asbestos out · Trace level is a concern for regulators • We sample and test ores we mine and purchase to analyze their composition, quality and safety tracking throughout the whole process • We sample and test our finished products to ascertain their composition, quality and safety • We install dust control systems and monitor air quality at cur operations to ensure that employees' dust exposure is below levels determined to be safe. Asbestos has never been detected in dust. • We develop product safety information for people who work with our products at every step in the supply chain • We audit our quality systems on a regular basis to ensure their integrity ct) IMERYS

11 lmerys has a century-long track record of working closely with customers, government officials and other health experts to advance the world's understanding of talc's health effects and benefits • We are acknowledged as world leaders in talc mining and processing and occupational health and safety among our employees. • We continue working closely with government officials to share research, and to ensure that people know the facts that talc is safe.

eJ I ME RYS

12 • Multiple ores with varying mineralogical composition - only the purest pass. • Regulatory requirements vary widely across the globe • Historically regional programs based on market needs • The program is aimed at managing risk • Best in class mine to market mineral management to ensure: • System in place to meet requirements of lmerys Product Stewardship Policy • A consistent definition and interpretation of specification and analyses • A consistent internal and external message • Procedures are statistically and legally credible • We verify global processes are consistent • Chain of custody is readily producible when required

·'11 IM ERYS

13 • A partnership built from a long and steady history of consistent quality

product delivered to your specification each and every order.

• Minimize supply risk through:

• World class fiber management program

• World class and diverse mine selection

• World class laboratories to identify and solve problems

• Highly experienced, well trained, and dedicated workforce

• Our commitment to J&J: Unparalleled quality assurance, analytical testing and technical support each and every day.

• lmerys, with its global footprint, product stewardship focus and long

·~ partnership, is a reliable talc supplier to J&J today and tomorrow. I} IM ERYS How Do We Move Forward Together?

• We will continue to bring in Chinese Guanxi #2 for our customer base.

• Working Capital Implications.

• We will continue to guarantee our quality, compliance, and specifications. If product is rejected in Royston, we accept it back at our expense.

• If we continue as your strong majority supplier, we will continue to defend JnJ and the industry

• PCPC - Personal Care Product Council Membership

• IARC - lnt'I Assoc Research on Carcinogens. • ASTM -American Standard Test Methods ., IM ERYS ~. . .

CYPRUS INDUSTRIAL MINERALS

RESOURCES, PRODUCTS & TECHNOLOGY

E.F, McCARTHY MARCH, 199.0

PLAINTIFF'S EXHIBIT QAM·12Q CYPRUS INDUSTRIAL MINERALS - PHILOSOPHY

* WE SELL FUNCTIONAL MINERAL PIGMENTS - NOT FILLERS OR EXTENDER~

* OUR PRODUCTS ARE MORE EXPENSIVE - BUT WOP.TH IT

* WE CERTIFY THAT OUR PRODUCTS ARE FREE OF AMPHIBOLE (ASBESTIFORM) MINERALS

* OUR PRODUCTS ARE BACKED BY TECHNICAL SERVICE, IN PLANT QUALITY CONTROL AND AN ORGANIZATION THAT HAS BEEN PRODU:ING FINE TALC AND BARYTES FOR OVER 60 YEARS RESOURCES

MINES: * MONTANA YELLOWSTONE TALC BEAVERHEAD TA_C ANTLER CI-LORITE

* VERMONT TROY TALC CHESTER TALC LUDLOW (4) TALC

* ALABAMA WINTERBORO TALC

* CALIFORNIA -. TOYON T.A.LC

* GEORGIA CARTERSVILLE BARYTE3

* SPAIN MALAGA TALC

* AUSTRALIA MT. SEABROOK* TALC

* ITALY VAL CHISONE* TALC

*MINES NOT OWNED BY CYPRUS RESOURCES - U.S. MILLS

LOCATION PROCESSING CAPABILITY MARKETS

Three Forks, MT Milling & Micronizing Paper, Rubber, Ceramics High Purity Talc

Grand Island, NE Milling, Micronizing & Rubber, Plastics, Cosmetics Sterilizing Talc & Chlorite

Houston, TX Milling & Micronizing Talc Plastics and Barytes

Alpine, AL Flotation, Milling & Cosmetics, Pharmaceuticals Sterilizing Talc

Johnson, VT Flotation, Milling, Micronizing Cosmetics, Plastics, Paints and Sterilizing Talc

Windsor, VT Flotation, Delaminating and Cosmetics, Plastics Sterilizing Talc

Chester, VT Milling Talc Construction Products, Plastics

Columbia. VT Milling Talc Construction Products, Plastics

Toyon, CA Milling Talc Construction Products

Cartersville, GA Flotation, Milling, Micronizing Plastics, Coatings Barytes RESOURCES-FORBGN

* EUROPE MILLS IN BELGIUM AND SPAIN

* JAPAN JOINT VENTURE WITH JAPANESE TRADING COMPANY

NIHON MISTRON

MILLS IN SUZUKA ANC -iOKKAIDO

* SOUTH AMERICA LICENSE MILL$ IN MEXICO AND VENEZUEi...A TECHNICAL CAPABILITIES

0 PRODUCT -SAFETY

0 2 PHILLIPS AUTOMATED XRD 0 OPTICAL MICROSCOPY 0 JEOL TEM 0 AMRAY SEM WITH EDAX

0 ANALYTICAL

°຿~ CILAS LASER PARTICLE SIZE ANALYSER 0 SEDIGRAPH, BET SURFACE AREA 0 PYNCNOMETER, WET CHEMISTRY

0 HUNTER, TECHNIDYNE, PHOTOVOLT COLOR

0 COATINGS 0 GLOSS, COLOR, ABRASION, OPACITY WEATHERING, TOP SIZE, RHEOLOGY

0 PAPER

0 IR DEPOSIT ANALYSIS, PITCH D~POSITION HANDSHEET MACHINE, PAPER PROPERTIES LASER ZETA POTENTIAL, EINLEINER ABRASION TECHNICAL CENTER PERSONNEL

* KAREN POERSCH EXT 5562 MESSAGES, LOCATOR

* BILL STEEN 5565 PLASTICS, RUBBER

OSCAR NOEL 5570 PVC, RUBBER

* TOM ZINGE 5571 COATINGS

* MIKE CLARK 5574 MINE~ALOGY

* BILL CAVANAGH 5572 PAPE·~

* ED McCARTHY 5563 ANY PROBLEMS HHAT IS TALC?

TALC IS OiJE OF A GROUP OF NATURALLY OCCURP-HIG ORES "THAT IS USED IN THE SA.'·IE CHE'.·1ICAL FOR!·1 AS IT OCCURS. THESE ARE KNmms ts INDUSiRI.~L Mir/ERALS.

"HYDROUS MAGNESIU~·1 SILICATE"

CHEMICAL FOR~iULA:

ALSO KNO\·m AS: SOAPSTOi-lE

STKUCTURE: BRUCITE LAYER SANDWICHED 6ET,EEil s: LI c.; S:iE::Ts

..... ,,

,... ' T ,-.,, T~LC IS ::> L." 1...:, ' PLATY, AND HYDROPHOBIC. TALC APPLICATIONS

* COATINGS PRIMERS - VAPOR RESISTANCE - CORROSION RESISTANCE - VISCOSITY BUILD - ADHESION CHARACTERISTICS - 325 MESH-VARIABLE COLOR

INTERIOR FLATS - FLATTING - VISCOSITY BUILD - ADHESION CHARACTERISTICS - TITANIUM EFFEICIENCY - 4 - 5 HEGMAN WHITE GEL COATS - VISCOSITY - SANDING PROPERTIES - TITANIUM EFFICIENCY - 5 - 6 HEGMAN WHITE HIBUILD - VISCOSITY - SAG RESISTANCE - CORROSION PROTECTION

MARINE - MILSPEC 24441 - HIGH SOLIDS, Twn?ART EPOXY - MISTRON 400, 500 TALC APPLICATIONS

* WALL JOINT COMPOUNDS - SANDING PROPERT:Es, VISCOSITY - 200/325 MESH 70-80 GEB -

* ADHESIVES & SEALANTS - VISCOSIFIER (SILICA) - REINFORCING AGENT - VAPOR BARRIER - 325 MESH & FINER P~n:.CTS TALC APPLICATIONS

RUBBER REINFORCEMENT - HIGHER MODULUS - HIGHER TENSILE - REDUCED DIE SWELL - EASIER PROCESSING MISTRON VAPOR R - CYPRUBOND

DUSTING

- TIRES VERTAL l~ .. - RUBBERTHREAD VERTAL C-2, -~~~LAR 200

PLASTICS - NUCLEATION OF POLYPROPYLENE, PET, NYLON, PS 5-6 HEGMAN WHITE

REINFORCEMENT OF POLYPROPYLENE 325 MESH WHITE TALC GOOD OVEN AGING FINER PRODUCTS FOR TPE, TPO

ANTIBLOCK OF F·ILM 5 HEGMAN WHITE, STELLAR 500 TALC - APPLICATIONS

* CERAMICS * STEATITE 85% 20 MESH TALC 10% KAOLIN 5% BAC03 * CORDIERITE 16% TALC 4% AL203 80% :LAY & OTHER

* WALL TILE 30-70% T).LC BALANCE ~ L.f; '1 S.

'I;: .:. ~::. ·- * FLUX (PLASTICIZER) & Du NT I I,..., I I • _,'

* TEXTILES SIZE FOR STIFFENED FABRICS * 50/50 STARCH/325 MESH TALC

* AGRICULTURAL CHEMICALS * CARRIER 200 MESH Lo COLOR * PRILL DUSTING AGENT 200/325 MESH Lo COLOR CYPRUS PRODUCTS - MONTANA TALC

PRODUCT MEAN PARTICLE SIZE HEGMAN COLOR APPLICATIONS

GLACIER 200 8 2 76 AG CARRIER, WALL JOIN. SEALANTS GLACIER 325 6 3.5 78 AG CARRIER, TRAFFIC PAINT, SEALANTS BEAVERWHITE 200 8 2 83 SEALANTS, DUSTING BEAVERWHITE 325 6 3,5 85 WORKHORSE PAINT PRODUI MISTRON 400 4,5 4 86 MILSPEC, LATEX FLAT MISTRON 500 3,5 5 87 MILSPEC, LATEX FLAT MISTRON RCS 3.5 5 87 Low VISCOSITY SEALANT INTERIOR FLATS MISTRON MIST 3 5.5 87 INTERIOR FLATS MISTRON 600 2.5 6 88 Low VISCOS,ITY, HIGH HEGMAN MISTRON MONOMIX 1. 5 6.5 89 FLATTING, HIDING GEL COATS MISTRON ULTRAMIX 1. 3 6.0 90 HIDING, GEL COATS MISTRON VAPOR-R 1. 7 5.5 86 RUBBER REINFORCEMENT CYPRUBOND 1. 7 5.5 86 SILANE TREATED FOR RUBBER REINFORCEMENT MISTRON ZSC 1. 7 5.5 86 STEARATE TREATED FOR DISPERSION & MOLD RELEASE CYPRUS PRODUCTS - VERMONT TALC

PRODUCT MEAN PARTICLE SIZE HEGMAN COLO~ APPLICATIONS

VERTAL 15 15 1 70 BODYPATCH, RUBBE DUSTING, AG CARR ER, WALL JOINT VERTAL 10 10 2 72 WALL JOINT, ADHE IVES PLASi"ICS

VERTAL 6 6 3.5 76 PP. H·!~RS I PLASTIC VERTAL 1500 15 1 76 Ru:;:::~ DUSTING, ADHE~!YES & SEAL NTS VERTAL 1000 10 2 77 RUBE:":~ DUSTING, ADHESIVES & SEAL NTS VERTAL 700 7 3,5 78 COATINGS, PLASTI s VERTAL 300 3 4.5 82 COATINGS, PLASTI s VERTAL 200 2 5.5 85 RUBBER VERTAL zsc 2 5.5 85 RUBBER, PLASTICS CYPRUS PRODUCTS - AUSTRALIAN & CHINESE

PRODU~T MEAN PARTICLE SIZE HEGMAN COLOR APPLICATIONS (MICRON)

STELLAR 200 11 2 86 PLASTICS, PAINT

STELLAR 400 7 3,5 88 PLASTICS

STELLAR 500 3.5 5 90 ANTI BLOCK, PLASTICS

STELLAR 600 2.2 6 92 GEL COATS, PLASTICS

STELLAR 410 8.5 3.5 87 PLA::-:cs

AF - 200 11 2 80 TR~-::!c PAINT

AF - 400 7 3.5 83 PAINT

ALL OF THESE PRODUCTS ARE SOURCED OUT OF HOUSTON EXCEPT FOR STELLAR 400, STELLAR 500,. AND STELLAR 600 WHICH ARE ALSO AVA I LAB LE AT GRAND l SLAND CHLORITE

* HYDROUS MAGNESIUM ALUMINUM SILICATE

* APPRoxrMATE CoMPosITioN: s MGO . AL2o3 . 3 SI02 . 8<0H)

* PLATY PIGMENT WITH MINIMAL FINES

* CYPRUS Is ONLY U.S. PRODUCER CHLORITE - APPLICATIONS

* CERAMIC CORDIERITE 25% CHLORITE No AL203 BALANCE CLAY & FELDSPAR FIRES AT CONE 5 VS CONE 11 FOR TALC

COATINGS Low Voe CHLORITES CAN BE LOADED AT 5 - 6#/GAL FLAT WELL AT HIGHER LOADINGS GOOD DISPERSION PROPERTIES

CORROSION RESISTANCE Goon CORROSION RESISTANCE BELOW 30 PVC

TIOz OPTIMIZATION BARYTES

BAS04 * DOES Nor THERMALLY DEGRADE UNTIL 1540°C * COMPLETELY INERT To ACID OR ALKALI * SPECIFIC GRAVITY OF 4,5 Glee * VERY Low OIL ADSORPTION (LESS THAN 12 GM/100GM) * ABSORBS SOUND, X-RAYS (Nor MICROWAVES) CYPRUS BARIMITE, BARIMITE XF AND BARYTES #22 ARE ONE OF ONLY Two FLOATED PRODUCTS AVAILABLE IN THE U.S. BARYTES - APPLICATIONS

* AUTOMOTIVE PRIMERS * INERTNESS * Low OIL ADSORPTION * SOUND DEADENING * BARIMITE XF

* AUTOMOTIVE SOUND DEADENING * HIGHER DENSITY * PLASTICOLS 200-500 PHR * TPE 250-350 PHR * FOAMS * CARPET BACKING

* AUTOMOTIVE BRAKES * THERMAL STABILITY * CONSISTENCY * 25% OF FORMULATION * BARYTES #22

SPECIALTY * APPLIANCES (DENSITY) * MEDICAL X-RAY SHIELDS * SOUND PANELS * PRIMARILY POLYESTER THERMOSETS CYPRUS PRODUCTS - BARYTES

PRODUCT MEAN PARTICLE SIZE HEGMAN COLOR APPLICATIONS (MICRON)

G-50 30 0 lAN CONSTRUCTION PRODUCTS

BARYTES #22 10 2 TAN BRAKES, PLASTIC RUBBER

BARIMITE 4 3 TAN RU36ER, PLASTIC I P~r :n

BARIMITE XF 2 5 TAN COATINGS, TPO

CIMBAR 325 10 3 88 COATINGS, PLAST CS

CIMBAR XF 2 5 90 COATINGS PRODUCT AND APPLICATIONS LITERATURE

DATA SHEETS

APPLICATIONS BULLETINS

TECHNICAL BULLETINS

TECHNICAL REPORTS

PUBLISHED PAPERS