Document OxJdrkOrzbRkMkdKXOb7bGrv

COMMONWEALTH OF PENNSYLVANIA ) 3 ss.* COUNTY OF PHILADELPHIA ) AFFIDAVIT RICHARD KR2Y21ANOWSKI, being duly sworn, deposes and pays: 1. am the General Counsel ofdefendant Crown Cork & Seal Co., Inc. * ("Crown"). I have been employed by Crown since 1967. 2. Ciown is a well-known producer ofbottle crowns and closures and metal and plastic containers. Many ofthe aerosol cans and the beverage and food cans and bottles in the average American home are made by Crown. Crown got its start in the business through (he invention in 1892 ofthe modem bottle cap. Crown has never manufactured, processed, sold or distributed asbestos-containing products. 3. The following, based on my research and knowledge ofCrown's company history and documents, summarizes the unusual (acts that led to Crown's being named as a defendant in asbestos litigation. In November 1963, Crown became a majority shareholder of Mundet Cork Corporation, a competitor in the bottle crowns and closures industiy. Mundet also had an unprofitable insulation division that, upon information and belief, manufactured and sold insulation and operated an insulation contracting business. Crown had no business interest in Mundet's insulation business. A buyer for the insulation division was found and it was sold in its entirety to Baldwin-Ehret-Hill * effective February 8,1964 - less than three months after Crown became a Mundet shareholder. . A, As part of the sale of its insulation division, Mundet agreed not to compete in the insulation business. The sale of the division included all equipment, inventory, raw j Hi.............. ...... materials, and business records, and a transfer ofexecutives and personnel ofthe division (o (he employ of Bddwift-Ehrel-HHl. Accordingly, Mundefs records pertaining to its it insulation division were not kept by Mundet and Crown has no such records today. iMXiiS " RICHARD Sworn to before me this davofOetohar. Notary Public . NOTARIAL SEAL I THERESARAUSCH NotiyPUbtc C^gfPhnaAajph^PWULCa^y' I ^Mydonated Eyg^Uayq.gO'X? 1