IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA ALBERT DiSANTIS, et ux,, Plaintiffs, v.

( (h) all liabilities and obligations of Seller or any Affiliate of Seller under the Guaranties; I (i) all other liabilities and obligations with re spect to which Buyer is obligated to indemnify Seller or the Seller Indemnified Parties under this Agreement as set forth in Article VII, Article VIII and Article XI; < (j) all liabilities and obligations with respect to any return, warranty or similar liabilities relating to prod ucts of the Business which were designed, manufactured, ser viced or sold on or prior to the Closing Date or which were held in the inventory, used or held for use primarily in the Business as of the Closing Date; I (k) all liabilities and obligations for death, personal injury, other injury to persons or property damage relating to, resulting from, caused by or arising out of, di rectly or indirectly, use of or exposure to any of the products of the Business (or any part or component) designed, manufac tured, serviced or sold, or services performed, by the Busi ness, including any such liabilities or obligations for neg ligence, strict liability, design or manufacturing defect, conspiracy, failure to warn, or breach of express or implied warranties of merchantability or fitness for any purpose or use; J (l) all liabilities and obligations relating to, resulting from, caused by or arising out of, directly or in directly, the Business or any assets or property used, manu factured, sold, leased, owned or operated, or services per formed, in connection with the Business at any time including i those which constitute, may constitute or are alleged to con stitute a tort, breach of contract or violation of, or noncompliance with, any Daw or Government Permit, including any relating to workers' compensation, occupational health and safety, occupational disease, occupational injury, toxic tort or Environmental Law (including the removal or remediation of asbestos in buildings or building interiors), subject to the provisions of Article VI and Article VIII; (m) all liabilities and obligations arising out of asbestos-related Actions for death, personal injury or property damage relating to or arising out of the Assets or the Busi < ness; (n) all liabilities and obligations to the extent arising out of Actions relating to or arising out of, directly or indirectly, the Business or the use, manufacture, sale, ownership, lease, operation or disposition of any of the assets or property of the Business; -20- 1

4 employees of the Division and to preserve the goodwill of customers, suppliers, licensors, licensees, and others having 4 business relations with the Division.

i another name and indicates clearly that the Division and the Business are affiliated with Buyer and not with Seller tfor I example, by reference in such trademark, trade name, name, phrase or logo to Buyer or an Affiliate of Buyer).

the fourth anniversary of the closing Date, if no Supple mental Letter of Credit has been delivered by such date or (y) until the tenth day before the fifth anniversary of the Closing Date, if the Supplemental Letter of Credit has been delivered) following the issuance of an arbitration award against Seller pursuant to Section 13.2(c) of this Agreement setting forth the dollar amount owed to Buyer by Seller pursuant to Seller's indemnification obligations under any provision of this Agreement, to pay the full amount required to be so paid as specified in such arbi tration award, which award may include, if the event de scribed in clause (iv)(x) below has occurred, the Present Value of all future indemnification obligations of Seller arising from the claim in such arbitration which would be reasonably esqpected to arise after such award is rendered, upon payment of which the claims covered by such arbitra tion award shall be deemed finally settled; but if such event has not occurred, such Present Value amounts shall be excluded; provided, however, that if any such payment is required to be made by Seller to Buyer after the ninety-fifth day before the fifth anniversary of the Closing Date, then Buyer may, in lieu of requiring such payment to be made by Seller and without regard to any 30-day waiting period, draw down such amount directly under the Letter of Credit; (iii) Abex has failed, within 30 days (or, if fewer, the number of days (x) until the tenth day before the fourth anniversary of the Closing Date, if no Supplemental Letter of Credit has been delivered by such date or (y) until the tenth day before the fifth anniversary of the Closing Date, if the Supplemental Letter of Credit has been delivered) after the issuance of an arbitration award against Abex pursuant to Section of the Mutual Guaranty Agreement setting forth the dollar amount owed to Buyer by Abex pursuant to Abex's obligations under the Mutual Guaranty Agreement with respect to the failure of Seller to satisfy its indemnification obligations under any pro vision of this Agreement, to pay the full amount required to be so paid as specified in such arbitration award, which award may include, if the event described in clause (iv)(x) below has occurred, the Present Value of all fu ture indemnification obligations of Seller arising from the claim in such arbitration which would be reasonably expected to arise after such award is rendered, upon payment of which the claims covered by such arbitration award shall be deemed finally settled; but if such event has not occurred, such Present value amounts shall be excluded; provided. however, that if any such payment is required to be made by Abex to Buyer after the ninetyfifth day before the fifth anniversary of the Closing Date, then Buyer may, in lieu of requiring such payment to -58-

T iiis brings us to o u r real p ro b le m .

Thei serious effects of exposure to excessive radiation are well known and the| established tolerance dose is 200 milliroentgens per week based on forty hour week.- Good maintenance of radiation shielding is essential.

NOTE (H.

Speaking of grievances, we are cognizant of the fact that in.

"Eemember todays labor situation will keep changing over the years, sometimes for better and sometimes for worse."

The founders of industrial nursing got the jump on the founders >f Brake Shoe t>y fourteen years.

LOSS prevention department LIBERTY MUTUAL February 8 1967^* West *'amPbeD Avenue> Roanoke, Virginia 24009 TeL Hr.

Mr.

CANADA The report for the American Brakeblok Division of Lindsay, Ontario will be contained in the annual report of the Dominion Brake Shoe Company, Limited.

li PLAINTIFF'S EXHIBIT AB-72 1 ffovember 20, 1936 LeRoy U.