10 HEAT AND ARC RESISTANT ELECTRICAL INSULATION BOARDS There is only one manufacturer of heat and arc resistant electrical insulation board in South Africa.

THE BENDIX CORPORATION FRICTION MATERIALS DIVISION TROY, NEW YORK FORD MTR FIELD ACT DEP P 0 BOX 2005 LIVONIA MI 46151 SHIPPED TO FORD MTR BOSTON DEP WOftC TPK AT SPEEH KD NATICK MA CLEVELAND, TENN.

f*.t r THE BENDIX CORPORATION FRICTION MATERIALS DIVISION TROY, NEW YORK POHt* MU' FlilLO J.CT OE.P P <i DOT 2005 LIVONaJ.

THE BENDSX CORPORATION FRICTION MATERIALS DIVISION TROY, NEW YORK CLEVELAND, 16NN.

Mr 7J THE BpNDIX CORPORATION FRICTION MATERIALS DIVISION TROY, NEW YORK | ; i. * CLEVELAND, TERN SOLD FOHO MTfii'FlELO ACT VO P 0 nox jfcOGS 1.IV0N1A M SHIPPED TO FORD MTp CO H Y PTS !

within the subject policies' coverage As noted above, the instant policies provided that " 'occurrence' means an accident, including continuous or repeated exposure to conditions, which results in bodily injury or property damage neither expected nor intended from the standpoint of the insured " An accident has been interpreted to mean" 'an unforeseen occurrence * * * of untoward or disastrous character' or 'an undesigned sudden or unexpected event' " Bituminous Casualty Com v Gust K Newborn Construction Co. 218 IU Add 3d 956. 965-66. 161 IU Dec 357. 578 N E 2d 1003 0991). quoting Aetna Casualty & Surety Co v Frever. 89 111 Add 3d 617, 619. 44 111 Dec 791, 411 N E 2d 1157 (19801 Our review therefore requires us to compare the allegations of the complaint with the policies and determine whether the allegations of the counterclaim allege or potentially allege an "occurrence" as that term is defined in the policy We now compare the allegations of the counterclaim and the relevant policy provisions Paragraph 71 ofthe counterclaim states that "BFG's counterclaims arise out of the transactions or occurrences, relating to the parties' actions and obligations to each other under the Agreement with respect to covered environmental matters, which are the subject matter of [Pneumo Abex's] complaint * * * " In paragraph 72 of the counterclaim, BFG sought a declaration of Pneumo Abex's obligation to reimburse BFG for environmental remediation **305***111 expenses provided for under "the Agreement" In paragraph 74 ofthe counterclaim, BFG claimed that Pnuemo Abex agreed to indemnify it for environmental liabilities relating to purchased assets or business under the agreement Paragraph 79 indicated that "Hazardous Substances," as defined m the agreement, had been identified at the various sites owned by BFG Paragraphs 80,82, and 84 indicated the presence of contamination at the Cleveland New Main, Cleveland Plating, and Tullahoma facilities exceeding human health and environmental protection *869 standards established under "Environmental Laws," as that term was defined in the agreement Paragraphs 81, 83, and 85 alleged that the contamination, if left unremediated, threatened human health and environmental concerns Those same paragraphs also alleged that the contamination occurred before BFG maintained "stewardship" over the property Paragraph 86 alleged "To date, BFG has incurred over $400,000 to identify and characterize the presence at the properties of 'Hazardous Substances' within the meaning of the Agreement, at or above levels of regulatory concern, to evaluate the risks posed by those substances to site Page 6 occupants, ground water resources and neighboring properties, and to implement appropriate response actions " Paragraph 88 further provided "These expenditures all constitute 'Environmental Liabilities' for which Pneumo Abex has agreed to indemnify BFG under the terms of Article 13 5 ofthe Agreement" Considering all ofthe allegations above, we do not find that they alleged "an accident, including continuous or repeated exposure to conditions, which [resulted] m bodily injury or property damage neither expected nor intended from the standpoint of the insured " We also find that the counterclaim did not seek relief for property damage Instead, the counterclaim sought indemnification for expenses incurred for remediating the environmental contamination contemplated by the parties in the asset purchase agreement Because the contamination and the expenses for remediating the contamination were contemplated by the parties, the damages complained of could not have arisen from an unforeseen occurrence On appeal, plaintiffs rely primarily upon Outboard Marine. 154 111 2d at 111,180 111 Dec 691.607NE2d 1204. and United States Fidelity & Guaranty Co v Specialty Coatings Co. 180 111 App 3d 378. 382. 129 111 Dec. 306. 535 N E 2d 1071 fl989f They state that broad insuring language in Outboard Marine and Specialty Coatings is similar if not identical to the policy language in this case Plaintiffs also suggest that the allegations of environmental property damage caused by the insured m the BFG suit are similar to the allegations in the third-party actions in Outboard Marine and Specialty Coatings Because the third party actions m those cases triggered the duty to defend, plaintiffs claim that the BFG suit triggered the duty to defend in this case In Outboard Marine, several complaints were filed against Outboard Marine Corporation (OMC) by the state and federal environmental protection agencies for the discharge of polychlorinated byphenyls into the North Ditch, Waukegan Harbor, and Lake Michigan *870 The underlying suits also included a third-party complaint filed by OMC against the Monsanto Corporation The Environmental Protection Agency (EPA) then joined Monsanto as a party defendant in an amended complaint Monsanto filed a cross-claim for indemnification against OMC m the event it was **306 ***112 found liable as a result of the EPA action OMC tendered the defense of the underlying actions to its insurers under comprehensive general liability insurance policies The policy language stated. " '[The insurer] will pay on behalf of the insured all Copr West 2003 No Claim to Orig U S Govt Works \

COOPER INDUSTRIES LTD(Form 424B2, Received 10/25/2002 13 39 31) Page 42 of 68 classified as a long-term liability, based on Cooper's current estimate of the most likely amount of losses that it believes will be incurred The product liability accrual consists of $3 2 million of known claims with respect to ongoing operations, $4 9 million of known claims for previously divested operations and $4 9 million which represents an estimate of claims that have been incurred but not yet reported While Cooper is generally self-insured with respect to product liability claims, Cooper has insurance coverage for individual 2001 claims above $3 0 million Environmental remediation costs are accrued based on estimates of known environmental remediation exposures Such accruals are adjusted as information develops or circumstances change The environmental liability accrual includes $7 1 million related to sites owned by Cooper and $39 2 million for retained environmental liabilities related to sites previously owned by Cooper and third-party sites where Cooper was a potentially responsible party Third-party sites usually involve multiple contributors where Cooper's liability will be determined based on an estimate of Cooper's proportionate responsibility for the total cleanup.

BRAKE FRICTION MATERIAL NUMBER EXPIR APPL # 030538 021091 020490 040632 021084 021083 040891 030531 030772 040168 030898 030897 030292 040173 030753 020983 040946 021010 040947 021012 020795 040948 020796 040266 021013 020405 020247 020246 020258 020259 020004 020343 020634 021104 020470 020470 020471 020471 040068 020624 020747 040632 040246 040123 040312 040394 021035 021134 040062 040061 030120 021133 07 06 01 06 07 05 01 08 07 05 07 05 01 08 07 06 01 07 07 07 01 07 01 07 07 06 07 07 01 07 01 06 01 06 01 06 01 06 01 06 01 06 01.06 01 06 07 07 01 06 07 05 07 05 07 05 07 05 07 05 07 05 07 05 07 05 01 06 07 05 07 05 07 05 07 05 07 07 07 05 07 05 01 08 07 07 01 07 07 07 07 07 07 05 01 06 01 07 01 07 07 06 01 06 00950 00950 00950 80025 67620 67620 55300 67850 67900 67900 67900 67900 00950 09215 69110 69110 69110 69110 69110 69110 69110 69110 69110 67900 01100 16900 16900 16900 16900 16900 16900 16900 10700 10700 72625 72625 72625 72625 00950 00950 00950 80025 72425 72425 72425 72425 72425 72425 72425 72425 72425 72425 5/6/2005 MARKINGS PX 1170 EE PX 1180 EE PX 1200 FF QBP ABS EE QTP 500 EE QTP 550 EE RAAF 05 FF RANE AF-45M FF RBB 15300 FF RBB 15300CGG RBB 162001 GF RBL 2550 FF RC 101 FF RMS 121 GG RMSA 150 FF RMSA 841 FF RMSA 852 FF RMSA 852S GF RMSA 857S FF RMSA 875S FF RMSA 876 FF RMSA 882S FF RMSA 903 FF RMX 9500 FF RTX 896 FF SAC L6173P FF SAC L6234A FF SAC L6653H FF SAC L6771AH FF SAC L9161AEE SAC PD17AH FF SAC PD53C EF SAI 153 EE SAI 163 EE SAT SV10FE SAT SV10FE SAT SV40 EE SAT SV40 EE SATB PROS1 FE SATB PROS2A EE SATB PROS3A EE SATB-PRO S6 EE SBI DB903 EE SBI DB903B EE SBI NA20J FE SBI NA25C GF SBI NA34A FF SBI NA35A GG SBIP531 FE SBI SA54B FF SBI SD083 FF SBI SD303 GG SECTION 10-56

Compliance List of Automotive Safety Devices SUPPLEMENT 2, 2005 Section 10--Friction Material JULY 31, 2005 Automotive Manufacturers Equipment Compliance Agency, Inc.

FRICTION MATERIALS STANDARDS INSTITUTE 588 MONROE TURNPIKE, MONROE, CT 06468 AUTOMOTIVE DATA BOOK BULLETIN #2-001 October 20, 2000 FRONT SYSTEM REAR FMSI NO.

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1133 STREET, N.W., WASHINGTON, D C. 2005 202/331-1770 TELEX 69-2673 M EMR ANDM James H.PrMreiHreitrU* Morm'an F.

SECRETAR Y OF STA TE IT IS 1IEREHY CERTIFIED that ItlHIDING MA T ERIALS MANUFACTURING COR1ORATION l ile No. 125433 06 a DEEAWARE corporation, has been issued a Certificate of Authority and the corporation is currently authorized to transact business in Texas.

E/2 Scott Aviation 22S Erie St., Lancaster, NY 14086 CJ.S.

FMC CORPORATION 2000 Market St.