In the Asbestos Claims Court of the State of Montana In
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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 z TUESDAY, MAY 26, 2020 z 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 Michelle R. Martinelli liott, however, still managed to earned only one point in the race number and a post-race There’s an allowance for that. For The Win finish third. race. number that does give a pretty But if parts break, the number USA TODAY NASCAR’s not done with NASCAR Cup Series manag- tolerance (and) it was outside is the number. There is no real Charlotte Motor Speedway yet. ing director Jay Fabian said the of those post-race numbers.” parameter of that. Brad Keselowski is slowly The Cup Series returns to the car went through the Optical Hendrick Motorsports does “There are parts in the past collecting checkered flags for track Wednesday for its fourth Scanning Station (OSS) and have the option to appeal the that have been designed to fail NASCAR’s biggest races, and in race back following a 10-week failed the post-race alignment penalty. The Cup Series has a or break. Certainly not suggest- the early hours of Memorial hiatus this spring because of numbers. The failure was in the quick turnaround before its ing that’s the case here, but Day at Charlotte Motor Speed- the COVID-19 outbreak. rear alignment. next race at Charlotte on that’s what’s gotten us to this way, the 36-year-old Team Johnson’s No. 48 Chevrolet “It’s the same thing we Wednesday. hardline of this is a post-race Penske driver added another. failed post-race inspection and checked at least a handful of “The 48 ran strong tonight, number, and there is a fair tol- Keselowski in the No. 2 Ford was disqualified. Johnson had cars for post-race after every all night. I hate it for them,” said erance from pre-race numbers held off seven-time champion finished second. With the DQ, event,” said Fabian. “I can’t Fabian. “They had a good car, to post.” Jimmie Johnson to win the Co- Johnson was relegated to a really give specifics on the performed well. The allowance Contributing: Kelly Cran- ca-Cola 600, the longest race last-place finish — 40th — and numbers. Yes, there is a pre- is built-in for parts that move. dall, RACER Magazine on NASCAR’s schedule which actually turned out to be the longest race in Cup Series his- tory, per FOX’s broadcast, be- cause of overtime late Sunday night/early Monday morning. It’s Keselowski’s first Coke 600 win, his first checkered flag of the 2020 season and his 31st career victory. +V)>nX_Rq>V R> qCBVRq)K R"B G_mBF HK (YqV# _ G>X;Y_qVR q) K>O M_VR R> "_NB _ CBHR BLGB;RBC )n>X CqmG"_n#B OVCBn << “I’ve wanted to win the 600 %BHR>nF:Nq_VG_ J>YCqV#m f3:3D>) 4#5 c3f3E3 l <<$<9C79h79:73 e"B H_VZnO;RGK GYBnZom >)(GB XOmR nBGBqNB _ G>X;Y_qVR H$ >09 *A;9A>#A =&*H%A =#8!> #6 >09 A>*>9 #6 %#$>*$* cVqRBC fR_RBm d_VZnO;RGK E>OnR )>n R"B f>OR"BnV %qmRnqGR >) /BM`>nZ _VC _VK nB1OqnBC (YqV# )BB HK R"B )>YY>MqV# CB_CYqVB3 =CKDA[?C -;T +A[?$ N"C GR 1? 8/E?/fO/ 2!f!$Wf!ORA COR/OT!@Wf?@ CW/?/ CWc/? -O; 8C Ni"IhQ& my whole life,” Keselowski said :O#OmR <-DP-P-3 %_RB G_mB (YBC )>n G"_;RBn <<F-'g<-gP-P- E_mB VOXHBnFP-!<<<QQ 92i7 G;@9AK[?NF $#>H=9 #6 %#>H#$ ># *""!#59 H$A8!*$=9 A9>>&9%9$> *3!99%9$>A *$? "#&H=2 ;82C;*=' on a Zoom call with reporters >V (TCD[N;TS 3[N" K -;TC[$? 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