Document o9gvD0E4QogRQxGM39bR7MeO3

COMMONWEALTH OF PENNSYLVANIA ) Coum-Y OF PHILADELPHIA 3 ss# ) AFFIDAVIT RICHARD KRZYZANOWSKI, being duly sworn, deposes and pays: 1. am the General Counsel ofdefendant Crown Code &Seal Co., Inc. ("Crown"). I have been employed by Grown since 1967. 2. Ciown is a wett-known producer ofbottle crowns and closures and metal and plastic containers. Many ofthe aerosol cans and the beverage and food cans and bottles in (he 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 industry. 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-HiU 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 materials, and business records, and a transferofexecutives and personnel ofthe division to the employ of Baldwin-Ehret-Hill. Accordingly, Mundei's records pertaining to its t* insulation division were not kept by Mundet and Crown has no such records today. Sworn to before me this NOTARIALSEAL H THERESARAUSCH, Notaryft&c ! CtvofPh0^9t^PWa.Catf<V L_MyCoattteflMfeflwt ItoyS, 20to 1