Document rBaZwLB1NZwYMGkmVERDZB3Y0

8TATS or PLCRIOA ) ) COUNTY or H2HS3CMUCH > 88.; amipavit I, VITO F. SA8I0N3, on oath depcae and state as follows; 3 1. Z, V2T0 f. BAA80S8. am vies Prssidsnt-Finanea, Treasurer ir.d Controller of The Celctex Corporation. 2. That as of August 31, 1985, The delete* Corporation was t Defendant in approximately $5,000 aabastos-relatad bodily injur/ lawsuits. 3. That as of August 31, 1988, The Calotax Corporation had dispeaad of approximately 27,000 aabaatos-raiatad bodily injury lawsuits through settlement, dianinal or judgment. 4. That between September 1, 1988 and February 28, 1999, approximately 140 judgments totaling approximately 915.5 million Lr. ooepansatery damages and approximately $10 million in punitive damages ware returned against CalotiX in asbeatos-related bodily injury oases. 5. Thatl to data approximately $250,000,000 has baan paid on bahalf of Calotax for satisfsation of vardlets and/or aettlement of asbestos- relatod bodily injury oases. To data, two punitive damage judgmenta in the amount of approxiattaly $175,000 have been paid on behalf of The Calotax Corporation. "t. for tha fiscal year ending August 31, 1988, The Calotax Corporation continued to be added as a defendant in new lawsuits at the rata of apprexiaetsly 1*800 par senth. Tha majority of these lawsuits contains a claim for punitive daaagaa. 7. According to the financial itatwent! of Celot**, with which I aw familiar^a* of August 31, 19M, the not worth of Colottx was $149 million. 8. That if called to testify to the truthfuinaa* of tha foregoing, 1 could competently and truthfully do to. . yUSTHSl AITIANT SAYXW NAUGHT. vim r. uaaoa Notary Public In and for the County of Hillaborough# State of Plorlda r/jo/nNy cotmiffion eapireat