Document X7qqqmbrDr12R13MJx1BndbYK

TOMPKINS, MCGUIRE & WACHENFELD 550 BROAD STREET NEWARK, N. J. 07102 (2011 622-3000 ATTORNEYS FOR Defendants As Listed On Schedule A SUPERIOR COURT OF NEW JERSEY LAW DIVISION PASSAIC COUNTY DOCKET NO. L-20509-86 LOTTIE MEMICE, Individually and LOTTIE MEMICE, as Executrix of the ESTATE OF JOSEPH MEMICE, Deceased, Plaintiffs, v. PPG INDUSTRIES, INC., et als.. Defendants. CIVIL ACTION - CERTIFICATION OF COUNSEL DATED JUNE 6, 1986 WILLIAM B. McGUIRE does certify as follows: - 1. I am an attorney-at-law of the State of New Jersey, and a member of the firm of Tompkins, McGuire & Wachenfeld, attorneys for thirteen defendants in the above-entitled matter. I make this Certification in support PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" UCC 076870 of an application for complex case management assignment of this mafcter. I am joined in this application by counsel for all of the defendants who have thus far appeared of record in this matter. 2. This matter involves a single plaintiff. Thirty-nine defendants have been named in the Second Amended Complaint. Although there is some duplication of defendants as is evident on the face of the pleading, there are never theless at least 27 individual corporate defendants as of the Second Amended Complaint. 3. This death action allegedly arises from plain tiff's decedent's exposure in the course of his employment to products manufactured by the various defendants. Extensive discovery, including voluminous record production, will be involved in the preparation of this matter for trial. Complex legal issues will be required to. be addressed. 4. It is respectfully suggested and requested that assignment of this matter to a judge for case management would be appropriate and beneficial to all parties. It is this assignment for case management which we seek to accomplish by this application. 5. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. Dated: PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" William B. McGuire -2- UCC 076871