In the Asbestos Claims Court of the State of Montana In

06/11/2020

IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA Case Number: AC 17-0694 Cause No. AC 17-0694 IN RE ASBESTOS LITIGATION, Consolidated Cases SUBMISSION OF AFFIDAVITS OF PUBLICATION OF NOTICE OF MOTION TO APPROVE INSURANCE SETTLEMENT AGREEMENTS AND POLICY BUY-BACK AND ENTERING INJUNCTIONS (Robinson Insulation Receivership)

Attached as Exhibits A through H hereto are affidavits of publication of notice of the motion by Receiver Nancy Gibson and Allan McGarvey and Mark Kovacich on behalf of certain Libby Plaintiffs (the “Motion”) asking this Court to authorize the Receiver’s settlement of the insurance coverage claims by Robinson Insulation Company against ACE Fire Underwriters Company, ACE Property & Casualty Insurance Company, American States Insurance Company, and Motorists Commercial Mutual Insurance Company and to issue an injunction and contribution bar order.

The affidavits show that notice of the Motion and the deadline to object to the Motion was published in USA Today, the Western News (Libby), the Kalispell Daily Inter Lake, the Missoulian, and the Great Falls Tribune, and the Helena Independent Record on May 26, 2020, in the Billings Gazette on May 27, 2020, and in the Sanders County Ledger on May 28, 2020.

Respectfully submitted this 11th day of June, 2020

By: __/s/ Allan M. McGarvey______Allan M. McGarvey McGARVEY, HEBERLING, SULLIVAN & LACEY, P.C.

By: /s/ Mark Kovacich______Mark Kovacich ODEGAARD KOVACICH SNIPES, P.C.

Attorneys for Libby Plaintiffs

__/s/ Nancy Gibson__ Nancy Gibson GIBSON LAW OFFICES, P.C. Receiver for Robinson Insulation Company

SFACTIVE-905667042.1

EXHIBIT A

2C ❚ TUESDAY, MAY 26, 2020 ❚ USA TODAY SPORTS Grading Tiger-Manning vs. Phil-Brady Tim Schmitt might expect him to hit (al- many highlights in the round, theme — Manning’s iron shots Golfweek though not many). One thing not to mention the one that coming out crisp. that jumped out was Tiger’s made it feel as if it might be- Sunday’s “The Match: poor speeds on the greens. come a match. Golf: B- Champions for Charity” had a Sure, they were wet. But Tiger And while we thought Brady little bit of everything. Uncer- plays these greens all the time; might be able to recover from It was sloppy, especially tainty over whether the rains you’d think he’d know which his early failing grade to man- through the first eight or so would allow the match to start. putts needed a few extra rolls age a B, he had a few big fails holes, although that’s probably Instant and incessant banter. considering the conditions. down the stretch — including a to be expected in those condi- Horrible golf shots. Amazing missed putt on No. 17 and es- tions. Most important, it golf shots. Phil Mickelson: A- sentially becoming a non-fac- seemed to matter. Both teams And in the end, it produced tor on 18. were awfully chatty through some genuine drama. After dig- While we’re weighting Ti- Still, finishing with this the front nine, but the only dis- ging a big hole, the duo of Phil ger’s grade a bit because it’s his Phil Mickelson plays his shot grade after where we stood six cussion through the last few Mickelson and Tom Brady home track and we expected from the first tee as Tiger holes in was pretty impressive. holes was Mickelson’s attempt staged an impressive come- better putting, we’d be lying if Woods looks on Sunday during to coach Brady to the finish line. back to make the 18th hole rele- we said Phil’s grade wasn’t The Match. USA TODAY SPORTS Peyton Manning: B vant. slightly influenced by his TBS/TNT: A- Here are the grades: amazing dialogue. Phil talked. Everything you need to And talked. And talked. As only Tom Brady: C+ know about Manning’s com- Charles Barkley came Tiger Woods: B+ Phil can. But of course, without petitive fire shined through on through as large, no pun in- the mics, we rarely get to know He really is the master of the 212-yard 16th hole. The tended, as the legendary ath- We’re weighting Tiger’s exactly what he keeps rambling second-half comebacks, isn’t team of Phil and Tom was letes he was chatting with, and grade a little because this is his about. he? Tom Brady was awful clearly gaining momentum, Brady’s calling out Barkley af- home course. He looked strong And Phil was, well, Phil, as through the first six holes. To and Brady stuck a beauty to ter holing out on No. 7 was one — an encouraging sign for golf he sprayed the ball a bit, but the point where buddies across eight feet. At this point, Man- of the day’s best moments. fans — and put himself in great then made some memories. His the country were texting each ning was starting to show signs We’d give Turner Sports an A, position most of the round. In tee shot on No. 11, for example, other and suggesting there was of collapse after messing up a although side chats with A-Rod fact, while the others were made it look as if he were the something they can finally do bunker shot on No. 13 and miss- and Russell Wilson did little but fighting to find fairways member, and was the kind of better than the GOAT. ing an easy par putt on No. 14. distract us from the amazing through a heavy rain on the shot you brag about for weeks. But on No. 7, you could sense But that’s when Peyton on-course chatter. front nine, Tiger routinely On 14 he added a stiff shot and he had been picked on enough. came back with one of the best And we’d be remiss if we placed his ball exactly where a then he buried a huge 12-foot He caught his iron so clean off shots of the day, a perfectly didn’t mention Justin Thomas’ knowledgeable club member par putt on No. 15 to keep his the fairway, it pulled his micro- placed bullet that dropped in- debut in a TV booth. JT was would. squad in the match. phone off and ripped his pants. side two feet from the cup. smooth, funny and another He did miss a few shots we The holed-out birdie was one of It was part of a recurring bright spot. Keselowski ‘tickled to death’ to win iconic race

EXHIBIT C

EXHIBIT D

EXHIBIT E

EXHIBIT F Page 1 of 1 06/10/2020 14:00:34 Ad Number 11037243 Ad Key 20472255 Order Number 20472255 Salesperson IR02 - Crystal Gray IR02 PO Number Publication Independent Record Customer 60038492 Porte Advertising Section Main Contact Jay H. Heymen Sub Section Main Address1 738 Shadowlawn Drive Category ROP Address2 Dates Run 05/26/2020-05/26/2020 City St Zip Westfield NJ 07090 Days 1 Phone (212) 249-1939 Size 2 x 4.50, 54 lines Fax Words 0 Ad Rate Open Printed By Billie Jo Williams Ad Price Entered By Crystal Gray Amount Paid Amount Due Keywords Legal ad for Porte Advertising Notes approved rate ey Zones

AFFIDAVIT OF PUBLICATION STATE OF MONTANA, County of Lewis & Clark - -- CrystaI Gray IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA Being duly sworn, deposes and says; In re Asbestos litigation, Consolidated Cases Cause No. AC 17--0694 NOTla OF MOTION TO APPROVE INSURANCE SETTLEMENTAGREEMENTS AND POLICY BUY That she is the principal clerk of the Independent Record, a newspaper of BACK AND ENTERING INJUNCTIONS (Robinson Insulation Receivership} general circulation published daily in the City of Helena, in the Countyof Lewis & PLEASE TAKE NOTICE THAT Nancy Gibson, as Receiver for Robinson Insulation Co., has fileda motion with Clark, State of Montana, and has charge of the advertisement therof: the Asbestos Claims Court of the State of Montana (the "Court") asking the Court to approve a Settlement That the Notice of Motion Agreement and Release' between (i) the Receiver and each of (ii) ACE Fire Underwriters Insurance Company, ACE Property & Casualty Insurance Company, Motorists Commercial Mutual Insurance Company, and American States Insurance Company (collectively, the "lhsurers") and to issue an injunction and a contribution bar order. a true copy of which is hearto annexed, was published in said newspaper on the The Settlement Agreement resolves disputes regarding certain historical liability insurance policies following dates: viz.: (the "Policie1') issued or allegedly issued ,by the Insurers to Robinll)n Insulation Co. ("Robinson") and/or Grogan Robinson Lumber Co. ("Grogan"), or under which Robinson and/or Grogan �re insured or Ma 26, 2020 may claim to be insured or entitled to benefits(as more particularly definedin the Settlement Agreement}. Under the terms of the Settlement Agreement, (i) the Insurers agree to pay their respective settlement mak!ng in all_l_ publication(s) amounts to the Receiver to be held in a QualifiedSettlement Fund trust pending further direction from the Court, (ii) the Insurers and their affiliateswill receive a release of all past, present, and future Claims, known and unknown, based upon, arising from, or attributable to the Policies, and (iii) any and all rights and Interests in the Policies will be deemed to have been sold back to each of the Insurers, thus permanently and irrevocably extinguishing all rights, duties, and coverage under the Policies. In addition to asking the court to approve the Settlement Agreements, the Receivers motion also asks the Court to enter orders (collectively, the "Injunctions") that (i) permanently enjoin the prosecution, '=¥ ti});/_, Subscribed and sworn to me this _10_ day of _June 2020. continuation, or commencement of any Claim that any person or entity holds or asserts or may in the future hold or assert against any of the Insurers, based upon, arising from, or attributable to any of the Polides and (ii) bar the assertion of claim/ againstthe Insurers for contribution, subrogation, indemnification,or similar claims related to the.Policies or the matters released in the SettlementAgreement. Copies of the Receivers motion and the Settlement Agreement can be obtained by contacting counsel for the Receiver, Certain Libby Claimants, or the Insurers at the addresses set forth below. Printed Name: Billie Jo Williams YOUR RIGHTS MAY BE AFFECTED BY THE SETTLEMENT AGREEMENT AND THE ORDERS APPROVING THE SETTLEMENT AGREEMENT AND ENTERING THE INJUNCTIONS. If you wish to object to approval Residing at Clancy, Montana 5_9634 of the Settlemeni Agreement or entry of the Injunctions, you must file an objection on or by My commission expires August 31, 2022 June 19, 2020. Any such objection should be filed with the Court: Hon. Amy Eddy, Asbestos Claims Court Judge, Department No. 1, Flathead County Justice Center, 920 South Main Street; Suite 310, Kalispell, Montana 59901, and served on. the following: (i) the Receiver, Nancy Gib�n, Esq., Gibson (Notary Seal) Law Offices PLLC, 4110 Weeping Willow Drive, Missoula, Montana 59803, [email protected], (ii) counsel for Certain Libby Claimants, Allan McGarvey, Esq., McGarvey Heberling Sullivan & · Lacey, r-:::;•�====7.·7":--="'··---'-�.. �- 345 First Avenue East, Kalispell, Montana 59901, [email protected], (iii) and counsel forthe s1LuE JO WlLUAMS Insurers: Mark D. Plevin, Crowell & Moring LLP,Three Embarcadero Center, 26th Floor, San Francisco, CA 94111, mplevin@crowell com:MichaelJ.Cohen,Esq.,MeissnerTierneyFisher&NicholsS.C., 111 East Kilbourn Avenue, NOT.A.RYPUBLIC for the 19th Floor, Milwaukee, Wisconsin 53202, mjc@mtfn com· and Marc Weintraub, Esq., Bailey & Glasser LLP, Stateof Mortana 360 Central Avenue, Suite lSOO, St. Petersburg, Florida 33701, [email protected]. Re.sidingat Clancy, Montana 'The description of the terms of the settlement contained herein is subject to the provisions of the Settlement Agreement. To the extent there is any incon�stency between the description of the terms of My Commission Expires the settlement contained herein and the provisions of the Settlement Agreement, the provisions of the August31, 2022 Settlement Agreement shall control. EXHIBIT G

EXHIBIT H

CERTIFICATE OF SERVICE

I, Allan M. McGarvey, hereby certify that I have served true and accurate copies of the foregoing Other - Other to the following on 06-11-2020:

Amy Poehling Eddy (Attorney) 920 South Main Kalispell MT 59901 Representing: Amy Eddy Service Method: eService

Roger M. Sullivan (Attorney) 345 1st Avenue E MT Kalispell MT 59901 Representing: Adams, et al Service Method: eService

John F. Lacey (Attorney) 345 1st Avenue East Kalispell MT 59901 Representing: Adams, et al Service Method: eService

Ethan Aubrey Welder (Attorney) 345 1st Avenue East Kalispell MT 59901 Representing: Adams, et al Service Method: eService

Dustin Alan Richard Leftridge (Attorney) 345 First Avenue East Montana Kalispell MT 59901 Representing: Adams, et al Service Method: eService

Ben A. Snipes (Attorney) Odegaard Kovacich Snipes, PC P.O. Box 2325 Great Falls MT 59403 Representing: Backen et al, Sue Kukus, et al Service Method: eService

Mark M. Kovacich (Attorney) Odegaard Kovacich Snipes, PC P.O. Box 2325 Great Falls MT 59403 Representing: Backen et al, Sue Kukus, et al Service Method: eService

Ross Thomas Johnson (Attorney) Odegaard Kovacich Snipes, PC P.O. Box 2325 Great Falls MT 59403 Representing: Backen et al, Sue Kukus, et al Service Method: eService

Jinnifer Jeresek Mariman (Attorney) 345 First Avenue East Kalispell MT 59901 Representing: Adams, et al Service Method: eService

Nathan Andrew Huey (Attorney) 201 West Main Street Suite 101 Missoula MT 59802 Representing: Robinson Insulation Company Service Method: eService

Mark S. Williams (Attorney) 235 East Pine PO BOX 9440 Missoula MT 59807-9440 Representing: Ace Fire Underwriters Companyh Service Method: eService

Tammy Peterson (Interested Observer) Asbestos Court Clerk Helena MT 59601 Service Method: E-mail Delivery

Nancy M. Erfle (Attorney) Gordon Rees LLP 121 SW Morrison St., Suite 1575 Portland OR 97204 Representing: Robinson Insulation Company Service Method: E-mail Delivery Mark Plevin Service Method: E-mail Delivery E-mail Address: [email protected]

Marc Weintraub Service Method: E-mail Delivery E-mail Address: [email protected]

Nancy Receiver Gibson Service Method: E-mail Delivery E-mail Address: [email protected]

Michael Cohen Service Method: E-mail Delivery E-mail Address: [email protected]

Electronically Signed By: Allan M. McGarvey Dated: 06-11-2020