1. used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include but are not limited to methylene chloride, trichloroethylene, 1,1,1-trichloroethane and other organic solvents.
2. 13. At all relevant times, Defendant J. T. BAKER INC. viva MALLINCKRODT BAKER, INC.'s products were sold to IBM, and used by IBM employees, decedent, causing them to suffer injurious exposure; these products include, but are not limited to: toluene and acetone, metal compounds, including chromium compounds and mercuro chloride; and acids which include but are not limited to ethylenedinitrol, acetic acid, phosphoric acid, sulfuric acid, chromic acid, nitric acid and solvents.
3. 14. At all relevant times, Defendant CONAP's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure. these products include, but are not limited to, epoxy and urethane polymer resins and adhesives.
4. 15. At all relevant times, Defendant DEVCON-PLEXUS CORPORATION's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, adhesives.
5. 16. At all relevant times, Defendant DEXTER CORPORATION's products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure: these products include, but are not limited to, epoxy resins and adhesives.
6. 17. At all relevant times, Defendant ELECTRONIC MATERIALS INC.'s products were sold to IBM, and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, Emcast and related epoxy resins and adhesives.
7. 18. At all relevant times, Defendant EM SCIENCE's products were sold to IBM and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure: these products include, but are not limited to, solvents and specialty chemicals.
8. 19. At all relevant times, Defendant EM SCIENCE INDUSTRIES, INC.'s products were sold to IBM and used by IBM employees, including plaintiffs and plaintiffs' decedent, causing them to suffer injurious exposure; these products include, but are not limited to, solvents and specialty chemicals
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COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH

MM 006956