`
`EDWIN J. RACHUBA,
`
`CIVIL DIVISION - ASBESTOS
`
`Plaintiff (s),
`
`No. GD 98-7398
`
`v.
`
`NOTICE OF BANKRUPTCY FILING
`
`AND IMPOSITION OF AUTOMATIC
`
`QUIGLEY COMPANY, INC, et a1.,
`
`STAY
`
`Defendants.
`
`Filed on Behalf of Quigley Company, Inc.
`
`Counsel of Record for this Party:
`
`C. James Zeszutek, Esq.
`Pa. ID. No. 22071
`
`Michael R. Bucci, Jr., Esq.
`Pa. ID. No. 33394
`
`THORP REED & ARMSTRONG, LLP
`Firm No. 282
`
`One Oxford Centre
`301 Grant Street, 14th Floor
`Pittsburgh, PA 15219
`412/394—7711
`
`2:
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`
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`
`00560496.DOC
`
`
`
`NOTICE OF BANKRUPTCY FILING AND
`
`IMPOSITION OF AUTOMATIC STAY
`
`PLEASE TAKE NOTICE that on September 3, 2004, Quigley Company, Inc. (the
`
`"Debtor") filed a voluntary petition for relief under Chapter 11 of Title 11 of the United States
`
`Code (the "Bankruptcy Code") in the United States Bankruptcy Court for the Southern District of
`
`New York (the "Court"). The Chapter 11 case is pending before Bankruptcy Court Judge
`
`Prudence C. Beatty under the case name In re Quigley Company, Inc. and Case No. 04-15739.
`
`Pursuant to the provisions of section 362(a) of the Bankruptcy Code, this lawsuit is stayed as to
`
`Quigley Company, Inc. All actions taken in violation of the stay are null and void.
`
`Dated: September 21, 2004
`
`Respectfully submitted,
`
` C. J
`es Zeszu
`
`Michael R. Bucci, Jr.
`
`THORP REED & ARMSTRONG, LLP
`
`One Oxford Centre,
`301 Grant Street, 14th Floor
`Pittsburgh, PA 15219
`412/394-7711
`
`Attorneys for Quigley Company, Inc.
`
`00560496.DOC
`
`
`
`UNITED STATES BANKRUPTCY COURT
`SOUTHERN DISTRICT OF NEW YORK
`——————————————————————————————————————————————————————x
`
`In re
`
`QUIGLEY COMPANY, INC,
`
`Chapter 11
`
`Case No. 04- 15739 (PCB)
`
`__--—--——-___-__-_-___—________-_----_.._---.‘. —————————— x
`
`.
`
`QUIGLEY COMPANY, INC,
`
`:
`
`Adv. Proc. No. . 04-04262 (PCB)
`
`Plaintifl;
`
`v.
`
`A. C. Coleman, THE OTHER PARTIES
`LISTED ON EXHIBIT A
`
`TO THE COMPLAINT, JOHN DOES
`
`1-1000 AND JANE DOES 1-1000,
`
`ORDER (A) ISSUING TEMPORARY RESTRAINING ORDER
`PURSUANT TO BANKRUPTCY CODE SECTIONS 105(a) AND 362(a)
`AND FEDERAL RULE OF BANKRUPTCY PROCEDURE 7065, AND (B)
`SCHEDULING HEARING ON PRELIMINARY INJUNCTION
`
`Upon the motion (the “Motion”) of Quigley Company,
`
`Inc.
`
`(“Quigley”), debtor
`
`and debtor in possession, pursuant to sections 105(a) and 362(a) of title 11, United States Code
`
`(the “Bankruptcy Code”), and Rule 65 of the Federal Rules of Civil Procedure made applicable
`
`hereto by Rule 7065 of the Federal Rules of Bankruptcy Procedure, for a preliminary injunction
`
`staying, restraining and enjoining the commencement or continuation of any and all actions or
`
`other proceedings against Pfizer Inc.
`
`(“Pfizer”), which allege personal
`
`injury or wrongful death
`
`based upon purported exposure to asbestos, silica, mixed dust,
`
`talc, or vermiculite,
`
`including
`
`without limitation,
`
`the actions and proceedings listed on Exhibits A and B to the Motion, and
`
`staying, restraining and enjoining all parties from taking any action with respect to any property
`
`97l4ll0.4
`
`1
`
`
`
`in which Pfizer and Quigley have a legal, equitable, beneficial, contractual or other interest,
`
`including, without
`
`limitation, any insurance policies or proceeds thereof in which Pfizer and
`
`Quigley have a shared interest, and for a temporary restraining order pending a hearing on the
`
`Motion for a preliminary injunction; and the Court having considered and reviewed:
`
`(i)
`
`Quigley’s memorandum of law in support of the Motion,
`
`(ii)
`
`the Afiidavit of Paul Street
`
`in
`
`support of the Motion, (iii) the Aflidavit of Steven C. Kany in support of the Motion, and (iv)
`
`Quigley’s complaint
`
`for declaratory and injunctive relief with respect
`
`to the personal
`
`injury
`
`claims asserted against Pfizer“, and the Court having jurisdiction to consider flie Motion and the
`
`relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334; and this matter being a
`
`core proceeding under 28 U.S.C. §157(b)(2)(A),
`
`(G) and (O); and based on the record
`
`established at the hearing on September 7, 2004, the Court finds and concludes as follows:
`
`1.
`
`Quigley and Pfizer are defendants in over one hundred thousand personal
`
`injury claims alleging injury based on alleged exposure to asbestos, silica, 'mixed dust,
`
`talc, or
`
`vermiculite. Quigley and Pfizer have utilized shared insurance policies and the fimds contained
`
`in an insurance trust, under which Quigley and Pfizer are joint beneficiaries,
`
`to satisfy
`
`settlements, judgments and defense costs related to the personal injury claims.
`
`2.
`
`Prior to the commencement of this chapter 11 case, Pfizer engaged in
`
`extensive settlement discussions with Quigley, present holders of personal
`
`injury claims against
`
`Pfizer and Quigley, and a representative representing the interests of holders of future demands
`
`against Pfizer and Quigley.
`
`Those discussions resulted in Quigley filing this chapter 11 case
`
`with a pre-negotiated plan, which contemplates a significant contribution by Pfizer to a trust to
`
`be established under section 524(g) of the Banlo'uptcy Code.
`
`97141104
`
`
`
`3.
`
`Quigley commenced this chapter 11 case to protect
`
`the remaining limits
`
`under the shared insurance policies and the amounts contained in the insurance trust, which Will
`
`be used to fund the pre-negotiated plan of reorganization and a section 524(g) trust
`
`4.
`
`The insurance policies and the amounts contained in the insurance trust
`
`constitute property of Quigley’s estate.
`
`Each of these assets may be utilized by Pfizer and
`
`Quigley to satisfy settlements,
`
`judgments or defense costs related to personal
`
`injury claims
`
`against either of them, on a first billed, first paid basis, irrespective of amounts previously billed
`
`by or paidtoPfizer or Quigley.
`
`5.
`
`Quigley has demonstrated that absent a stay of pending and future
`
`personal
`
`injury claims asserted against Pfizer, plaintifl‘s will continue to prosecute their claims
`
`against Pfizer, which will have the efi‘ect of depleting the shared insurance policies and the fimds
`
`inthe insurance trust.
`
`6.
`
`Quigley has demonstrated that depletion of the shared insurance policies
`
`and the insurance trust assets will cause immediate and irreparable injury to Quigley’s estate and
`
`impair Quigley’s
`
`ability to implement
`
`its pre-negofiated chapter
`
`11 plan and successfirlly
`
`reorganize under chapter 11 of the Bankruptcy Code.
`
`7..
`
`Quigley has demonstrated that
`
`the injunctive relief requested is in the best
`
`interests ofQuigley, its estate, creditors and parties in interest.
`
`8.
`
`Quigley has demonstrated that notifying over one hundred and sixty
`
`thousand plaintifl‘s, or all of their counsel, who have asserted the personal injury claims against
`
`Pfizer of the hearing on the tempomry restraining order on shortened notice would not be
`
`possible.
`
`In addition to the virtual impossibility of obtaining addresses for and serving all of the
`
`over one hundred and sixty thousand plaintiffs, Quigley's counsel
`
`is
`
`constrained by the
`
`97l4l 10.4
`
`
`
`provisions of the Professional Code of Responsrbility fiom communicating directly wiflr parties
`
`known to be represented by counsel without the consent of their counsel.
`
`9.
`
`_ Quigley cannot provide notice to the holders of future personal
`
`injury
`
`demands because they are not known at this time. Quigley would only be able to provide
`
`publication notice with respect to the holders of firture demands.
`
`10.
`
`Pursuant
`
`to the Court's direction, Quigley's counsel provided limited
`
`notice of the hearing on the Motion to counsel for the top 20 unsecured creditors and three other
`
`counsel representing plaintifis who have not settled their claims with Quigley or Pfizer (a) by
`
`telephone on September 3, 2004, and (b) by, written notice, served togeflier with copies of the
`
`Motion and supporting pleadings, by overnight mail, Saturday delivery.
`
`11.
`
`Quigley will
`
`suffer
`
`immediate and irreparable injury,
`
`loss, or damage
`
`before 'the personal injury defendants or their counsel can be heard in opposition to the Motion.
`
`97l4llO.4
`
`
`
`NOW THEREFORE, IT IS HEREBY
`
`ORDERED,
`
`that
`
`the Motion is granted in part,
`
`insofar as the request
`
`for a
`
`temporary restraining order is granted; and it is further
`
`ORDERED,
`
`that a hearing on Quigley’s motion for a preliminary injunction shall
`
`be held on September 27, 2004 at 10:30am, or as soon thereafter as counsel may be heard,
`
`before The Honorable Prudence C. Beatty, United States Bankruptcy Judge, in Room 701 of the
`
`Alexander Hamilton Custom House, One Bowling Green, New York, New York; and it is fiuther
`
`ORDERED,
`
`that pursuant to sections 105(a) and 362(a)of the Bankruptcy Code
`
`and Rule 7065 of the Bankruptcy Rules, pending a final determination on Quigley’s request for a
`
`preliminary injunction any and all pending or future actions or other proceedings against Pfizer,
`
`which allege personal
`
`injury or wrongful deaflr based upon purported exposure to asbestos,
`
`silica, mixed dust,
`
`talc, or vermiculite,
`
`including without
`
`limitation,
`
`the actions and proceedings
`
`listed on Exhibits A and B to the Motion, and staying, restraining and enjoining all parties from
`
`taking any action with respect
`
`to any property in which Pfizer and Quigley have a legal,
`
`equitable, beneficial, contractual or other
`
`interest,
`
`including, without
`
`limitation, any insurance
`
`policies or proceeds thereof in which Pfizer and Quigley have a shared interest, are enjoined and
`
`restrained; and it is fiuflrer
`
`ORDERED,
`
`that
`
`suflicient cause has been shown for granting Quigley the
`
`temporary restraining order it has requested on the limited notice described above, based on the
`
`virtual
`
`impossrbility of serving all of the over one hundred and sixty thousand personal
`
`injury
`
`defendants or their cOunsel with notice and the immediate and irreparable injury, loss, or damage
`
`that Quigley will suffer absent entry of this Order upon limited notice; and it is further
`
`ORDERED,
`
`that entry of this Order will be without prejudice to any creditor or
`
`party in interest to seek relief from its terms; and it is further
`97l4llO.4
`
`
`
`ORDERED,
`
`that pursuant
`
`to Bankruptcy Rule 7065,
`
`flie security provisions of
`
`Federal Rule 65(c) be, and same hereby are, waived; and it is further
`
`ORDERED, that this Order shall be served together with a compact disk ("CD")
`
`containing Exhibit A to the Motion (list of claims and civil actions against Pfizer and Quigley)
`
`and Exhibit B to the Motion (list of claims and civil actions against Pfizer only):
`
`(a)
`by overnight mail, overnight delivery, postage prepaid, on or before
`September 9, 2004, upon all known parties-in—interest at
`the time of such service who are
`
`directly afi’ected by this Order, or upon counsel for such parties-in—interest, including counsel for
`
`personal injury claimants, as provided in the Order Authorizing Listing of Addresses of Counsel
`
`for Personal Injury Claimants in Creditor Matrix in Lieu of Claimants' Addresses and Approving
`
`Notice Procedures for Claimants; and
`
`(b)
`
`by publication of Notice of Hearing Seeking Preliminary Injunction,
`
`substantially in the form of Exhibit A hereto, which Notice is hereby approved in all respects, to
`
`be published once in The New York Times and The Wall Street Journal (National Edition), on or
`
`before September 14, 2004; and it is further
`
`ORDERED, that service in accordance with this Order shall be deemed good and
`
`sufficient service and adequate notice for all purposes; and it is further
`
`ORDERED, the temporary restraining order shall remain in efl‘ect pursuant to this
`
`Order until September 17, 2004 at midnight (New York Time) and, good cause having been
`
`shown, consistent with section 102(1) of the Bankruptcy Code, Bankruptcy Rule 7065 and Fed.
`
`R. Civ. P. 65(b), may continue in efl‘ect without a hearing until the hearing on Quigley's request
`
`for a preliminary injunction, unless a party directly afi‘ected by such temporary restraining order
`
`moves prior to September 17, 2004 for its dissolution or modification on 2 days' prior written
`
`notice to Quigley and its counsel, Pfizer and its counsel, and the United States Trustee,
`
`in which
`
`97141104
`
`
`
`case the Court will consider such motion and decide if any hearing is necessary to dispose of
`
`such motion, and, if necessary, schedule the time and place for such hearing; and it is further
`
`ORDERED,
`
`that objections,
`
`if any,
`
`to Quigley’s
`
`request
`
`for a preliminary
`
`injunction shall set forth in writing the basis for any such objection and shall be filed with the
`
`Court either (a) by filing electronically in accordance with General Order M-182 (N.B. General
`Order M-182 and the User’s Manual
`for the Electronic Case Filing System can be found at
`
`www.nysb.uscourts.gov,
`
`the official website for the United States Bankruptcy Court for the
`
`Southern District of New York) by registered users of the Court’s electronic filing system and,
`
`by all other parties in interest, on a 3.5 inch disk, preferably in Portable Document Format
`
`(PDF), WordPerfect or any other Windows-based word processing format, or (b) by filing a hard
`
`copy with the Clerk of the Court, One-Bowling Green, New York, NY 10004, and each instance,
`
`with a hard copy delivered directly to Chambers and served on: (i) Schulte, Roth & Zabel LLP,
`
`919 Third Avenue, New York, New York 10022, Tel:
`
`(212) 756—2000, Fax:
`
`(212) 593—5955
`
`(Attention: Michael L. Cook), attorneys for Quigley, (ii) Cadwalader, Wickersham & Tafi LLP,
`
`100 Maiden Lane, New York, New York 10038, Tel:
`
`(212) 504-6000, Fax:
`
`(212) 504-6666
`
`(Attention: Bruce R. Zirinsky, Esq. and John H. Bae, Esq), attorneys for Pfizer, and (iii) the
`
`Office of the United States Trustee, 33 Whitehall Street, Suite 2100, New York, NY 10004, Tel:
`
`(212) 510-0500, Fax: (212) 668—2256, so as to be received on or before September 22, 2004 at
`
`12:00 pm.- (New York time); and it is further
`
`97141104
`
`
`
`ORDERED, that responses, if any, shall be filed and sewed in accordance with
`
`the procedures described above and also shall be served on any objectors, so as to be receiyed on
`
`or before September 24, 2004 at 12:00 pm. (New York time).
`
`Dated:
`
`New York, New York
`September 7, 2004 (at 5pm.)
`
`/s/ Prudence Carter Beam
`United States Bankruptcy Judge
`
`97141104
`
`
`
`EXHIBIT A
`
`UNITED STATES BANKRUPTCY COURT
`
`SOUTHERN DISTRICT OF NEW YORK
`------------------------------------------------------x
`
`In re
`
`QUIGLEY COMPANY, INC.,
`
`Chapter 11
`
`Case No. 04- 15739 (PCB)
`
`QUIGLEY COMPANY, INC.,
`
`:
`
`Adv. Proc. No. 04-04262 (PCB)
`
`Plaintifl,
`
`v.
`
`A. C. Coleman, THE OTHER PARTIES
`LISTED ON EXHIBIT A
`
`TO THE COMPLAINT, JOHN DOES
`1—1000 AND JANE DOES 1— 1000,
`
`NOTICE OF HEARING SEEKING PRELIMINARY INJUNCTION
`
`PLEASE TAKE NOTICE that on September 3, 2004 (the “Petition Date”),
`
`Quigley Company, Inc. (“Quigley”) filed a petition for relief under chapter 11,
`
`title 11, United
`
`States Code (the “Bankruptcy Code”) in the United States Bankruptcy Court, Southern District
`
`ofNew York (the “Bankruptcy Court”).
`
`.
`
`PLEASE TAKE FURTHER NOTICE that on the Petition Date, the Debtor filed a
`
`motion (the “Motion”) pursuant to sections 105(a) and 362(a) of the Bankruptcy Code and Rule
`
`65 of the Federal Rules of Civil Procedure for a preliminary injunction staying, restraining and
`
`enjoining the commencement or continuation of any and all actions or other proceedings against
`
`
`
`Pfizer ‘Inc.
`
`(“Pfizer”), which allege personal
`
`injury or wrongful death based upon purported
`
`exposure to asbestos, silica, mixed dust,
`talc, or vermiculite,
`including without
`limitation,
`the
`actions and proceedings listed on Exhibits A and B to' the Motion, and staying, restraining and
`
`enjoining all parties fiom taking any action with respect
`
`to any property in which Pfizer and
`
`Quigley have a legal,
`
`equitable, beneficial,
`
`contractual or other
`
`interest,
`
`including, without
`
`limitation, any insurance policies or proceeds thereof in which Pfizer and Quigley have a shared
`
`interest, and for a temporary restraining order pending a hearing on the Motion for a preliminary
`
`injunction
`
`PLEASE TAKE FURTHER NOTICE, that on September 7, 2004, the Bankruptcy
`
`Court granted the Motion,
`
`in part, and entered a temporary restraining order pending a hearing
`
`on Quigley’s Motion seeking a preliminary injunction.
`
`PLEASE TAKE FURTHER NOTICE, that a hearing on Quigley’s motion for a
`
`preliminary injunction shall be held on September 27, 2004 at 1030a.m., or as soon thereafter as
`
`counsel may be heard, before The Honorable Prudence C. Beatty, United States Bankruptcy
`
`Judge,
`
`in Room 701 of the Alexander Hamilton Custom House, One Bowling Green, New York,
`
`New York.
`
`PLEASE TAKE FURTHER NOTICE,
`
`that objections,
`
`if any,
`
`to Quigley’s
`
`request for a preliminary injunction shall set forth in writing the basis for any such objection and
`
`shall be filed with the Court either (a) by filing electronically in accordance with General Order
`M-182 (N.B. General Order M182 and the User’s Manual for the Electronic Case Filing System
`
`can be found at www.nysb.uscourts.gov,
`
`the oflicial website for the United States Bankruptcy
`
`Court for the Southern District of New York) by registered users of the Court’s electronic filing
`
`system and, by all other parties in interest, on a 3.5 inch disk, preferably in Portable Document
`
`Format (PDF), WordPerfect or any other Windows-based word processing format, or (b) by
`
`NYLIBS 766555.8
`
`
`
`filing a hard copy with the Clerk of the Court, One Bowling Green, New York, NY 10004, and
`
`each instance, with a hard copy delivered directly to Chambers and served on: (i) Schulte, Roth
`
`& Zabel LLP, 919 Third Avenue, New York, New York 10022, Tel:
`
`(212) 756-2000, Fax:
`
`(212) 593-5955 (Attention: Michael Cook, Esq.), attorneys
`
`for Quigley,
`
`(ii) Cadwalader,
`
`Wickersham & Tafi LLP, 100 Maiden Lane, New York, New York 10038, Tel: (212) 504-6000,
`
`Fax:
`
`(212) 504-6666 (Attention: Bruce R. Zin'nsky, Esq. and John H. Bae, Esq.), attorneys for
`
`Pfizer, and (iii)
`
`the Office of the United States Trustee, so as to be received on or before
`
`September 22, 2004 at 12:00 pm. (New York time).
`
`If you fail to respond in accordance with
`
`the foregoing procedures, the relief requested may be entered.
`
`Dated:
`
`New York, New York
`September 7, 2004
`
`SCHULTE ROTH & ZABEL LLP
`
`Proposed Attorneys for Quigley Company, Inc.
`
`BY-
`Michael L. Cook (MC 7887)
`(A Member of the Firm)
`919 Third Avenue
`
`New York, New York 10022
`
`NYLIBS 7665558
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the foregoing
`
`NOTICE OF BANKRUPTCY FILING AND IMPOSITION OF AUTOMATIC STAY has
`
`been served upon counsel for Plaintiff(s) via hand delivery.
`
`Theodore Goldberg, Esquire
`Goldberg, Persky & White
`1030 Fifih Avenue, 3rd Floor
`Pittsburgh, Pa 15219
`
`and counsel of record, as reflected on the attached counsel list have been notified by US. Mail,
`
`first class, postage prepaid, on this let day of September, 2004.
`
`091% -Wb/“
`
`00560496DOC
`
`
`
`Andy Adomitis, Esq.
`Leo G. Daly, Esq.
`Grogan, Graffarn, McGinley & Lucchino
`4 Gateway Center, #12
`Pittsburgh, PA 15222
`
`Kenneth F. Kanica, Esq.
`Michael D. Heintzman, Esq.
`Joseph R. Schaper, Esq.
`Heintzman, Warren, Wise & Fomella
`707 Grant Street, 35ul Floor
`Pittsburgh, PA 15219-1913
`
`Ruth A. Antinone, Esq.
`ConCetta A. Silvaggio, Esq.
`Willman & Arnold
`705 McKnight Park Drive
`PO. Box 15276
`Pittsburgh, PA 15237
`
`Richard C. Polley, Esq.
`Edmund L. Olszewslci, Jr., Esq.
`Joseph Christofi”, II, Esq.
`Brian T. Must, Esq.
`Robert W. Hastings, Esq.
`Dickie, McCamey & Chilcote, P.C.,
`No PPG Place, Suite 400
`Pittsburgh, PA 15222
`
`Miles A. Kirshner, Esq.
`Tony D. Skees, Esq.
`William R. Haushalter, Esq.
`Gregory L. Fitzpatrick, Esq.
`Margolis Edelstein
`1500 Grant Building
`Pittsburgh, PA 15219
`
`Neal Glenn, Esq:
`John Kelley, Esq.
`Frank Camberoni, Paralegal
`Kelley, Jasons, McGuire & Spinelli
`Centre Square West, Suite 1500
`Philadelphia, PA 19102
`
`George N. Stewart, Esq.
`Joni M. Mangino, Esq.
`Joseph W. Selep, Esq.
`Alexander P. Bicket, Esq.
`Dan Krouth, Esq.
`Zimmer Kunz, P.C.
`3300 USX Tower
`
`Pittsburgh, PA 15219
`
`John Argento, Esq.
`Norman 1. Base, Esq;
`Stephen R. Mlinac, Esq.
`Swartz, Campbell & Detweiler
`115 North Jackson Street
`Media, PA 19063
`
`Peter B. Skeel, Esq.
`Summers, McDonnel, Walsh & Skeel
`Gulf Tower, Suite 2400
`707 Grant Street
`Pittsburgh, PA 15219
`
`'
`
`Robert W. Wilkinson, Esq.
`Dogan & Wilkinson, PLLC
`726 Box 1618
`
`Pascagoula, MS 39568-1618
`
`Alan Klein
`Duane, Morris & Heckscher, LLP
`One Liberty Place
`Philadelphia, PA 19103-7396
`
`Kathy K. Condo, Esq.
`John Vitsas, Esq.
`Reed, Smith, Shaw & McClay
`P.O. Box 2009
`Pittsburgh, PA 15230
`
`Patrick L. Mechas, Esq.
`Burns, White & Hickton
`120 Fifth Avenue, Suite 2400
`Pittsburgh, PA 15222
`
`Law Offices of Robb & Robb, P.C.
`Kenneth S. Robb, Esq.
`Michael P. Robb, Esq.
`1080 Long Run Road
`McKeesport, PA 15132
`
`Keith Whitson, Esq.
`Schnader Harrison Segal & Lewis, LLP
`2700 Fifih Avenue Place
`Pittsburgh, PA 15222
`
`James S. Ehrman, Esq.
`‘ Tighe, Evan, Ehrman, Schenck & Paras
`Four Gateway Center
`444 Liberty Avenue, Suite 1300
`Pittsburgh, PA 15222-5404
`
`Dennis F. Wolford, Esq.
`Kathryn L. Johnston, Esq.
`Reed, Luce, Tosh, McGregor & Wolford
`804 Turnpike Street
`Beaver, PA 15009
`
`00430733
`
`
`
`Howard K. Hilner, Esq.
`Eric K. Falk, Esq.
`William D. Geiger, Esq.
`Davies, McFarland & Carroll, P.C.
`- One Gateway Center, 100' Floor
`Pittsburgh, PA 15222
`
`Alba Romano, Esq.
`Wilbraham, Lawler & Buba
`Two Gateway Center 17‘h North
`Pittsburgh, PA 15222
`
`Scott Matthews, Esq.
`Dell, Moser, Lane & Loughney
`437 Grant Street
`
`1300 Prick Building
`Pittsburgh, PA 15219-6002
`
`Allen T. Lane, Esq.
`Claudia Wickharn Lane, Esq.
`Lane & Lane
`
`Fort Pitt COmmons Building
`445 Fort Pitt Boulevard, Suite 160
`Pittsburgh, PA 15219
`
`Nora Barry Fischer, Esq.
`Paul K. Vey, Esq.
`Pietragallo, Bosick & Gordon
`One Oxford Centre
`38'h Floor
`Pittsburgh, PA 15219
`
`Arthur Baker, 111, Esq._
`Thomas Michael, Esq.
`Law Offices of Arthur Baker
`225 Ross Street, 2“‘1 Floor
`Pittsburgh, PA 15219
`
`Peter D. Giglione, Esq.
`Marshall, Dennehey, Warner, Coleman & Groggin
`2900 USX Tower
`600 Grant Street
`Pittsburgh, PA 15219
`
`Richard H. Taylor, Esq.
`USX Corporation
`Law Department
`600 Grant Street
`
`Pittsburgh, PA 15219.2749
`
`Cy Goldberg, Esq.
`Cy Goldberg & Associates, PC.
`The North American Building
`121 South Broad Street
`
`Philadelphia, PA 19107
`
`Kevin C. Tierney, Esq.
`Law Offices of Kevin Tierney
`1 125 Land Title Building
`100 S. Broad Street
`Philadelphia, PA 15110
`
`John J. O’Brien, Ill, Esq.
`O’Brien and O’Brien
`257 East Lancaster Avenue
`Wynnewood, PA 19096
`
`Edward Chiodo, Esq.
`McKenna & Chiodo, RC.
`436 Boulevard of the Allies, Suite 500
`Pittsburgh, PA 15219
`
`Pat Hewitt, Esq.
`Riley, McNulty, Hewitt & Sweitzcr, RC.
`650 Washington Road, #300 .
`Pittsburgh, PA 15228
`
`Richard Rush, Esq.
`Thompson, Rhodes & Cowie
`T‘wo Chatham Center
`10‘h Floor
`Pittsburgh, PA 15219-3499
`
`James F. Israel, Esq.
`Israel, Wood & Puntil
`One Gateway Center
`420 Fort Duqusne Blvd, Suite 700
`Pittsburgh, Pa 15222
`
`Peter Neeson, Esq.
`Rawle & Henderson, LLP
`The Widener Building
`One South Penn Square
`Philadelphia, PA 19107
`
`Monica Maghrak, Esq.
`Murphy Taylor, PC.
`326 Third Avenue
`Suite 100
`
`Pittsburgh, PA 15222
`
`00430733
`
`
`
`‘
`
`A
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`John J. Repcheck, Esq.
`Marks, O’Neill, Reilly, O’Brien & Courtney
`3200 Gulf Tovver
`707 Grant Street
`
`Pittsburgh, PA 15219
`
`James F, Ryan, Esq.
`Schwabenland and Ryan, PC.
`995 Old Eagle School Road
`Suite 306
`
`Wayne, PA 19087
`
`Mary M. O’Day, Esq.
`Donald E. Seymour, Esq.
`Kirkpatrick & Lockhart
`1500 Oliver Building
`Pittsburgh, PA 15222
`
`Mary Drake Korsmeyer, Esq.
`Peacock Keller
`'
`70 E. Beau Street
`
`Washington, PA 15301
`
`Matthew R. Wimer, Esq.
`Wimer Law Office
`655 Allegheny Avenue
`Oakmont, PA 15139.2003
`
`Michael E. Lang, Esq.
`M. Kathleen Canty, Esq.
`Malone Larchuk & Middleman
`Northridge Office Plaza
`117 VIP Drive, Suite 310
`Wexford, PA 15090
`
`Gary E. Wieczorek, Esq.
`Tucker Arensberg, RC.
`1500 One PPG Place
`Pittsburgh, PA 15222
`
`Joseph M. O’Neill, Esq.
`William Fynes, Esq.
`Marks, O’Neill, Rielly & O’Brien
`1880 JFK Boulevard, Suite 1200
`Philadelphia, PA 19103 .
`
`David Craig Landin, ESQ.
`John D. Epps, Esq.
`M. Christine Klein, Esq.
`Hunton & Williams LLP
`Riverfront Plaza, East Tower
`951 East Byrd Street
`Richmond, VA 23219
`
`Megan Willoughby, Esq.
`Stradley Ronon Stevens & Young, LLP
`2600 One Commerce Square
`Philadelphia, PA 19103
`
`Jason W. Rubin, Esquire
`GOLDBERG, MILLER & RUBIN, RC.
`121 South Broad Street, Suite 1500
`Philadelphia, PA 19107
`
`James R Schadel
`Weinheimer, Schadel & Haber, RC.
`602 Law & Finance Building
`429 Fourth Avenue
`Pittsburgh, PA 15219
`
`Kenneth Mroz
`
`Swartz Campbell LLC
`1 120 Grant Building
`310 Grant Street
`
`Pittsburgh, PA 15219
`
`Kevin Batik
`MeGuireWoods LLP
`Dominion Tower
`625 Liberty Avenue, 23rd Floor
`Pittsburgh, Pennsylvania 15222
`
`00430733
`
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