**APR 12 2022 5:49 PM FR MONDAY**

**COMPLAINT FOR DAMAGES, PERSONAL INJURY AND WRONGFUL DEATH**

**MM 006957**

1. At all relevant times, Defendant EM SCIENCE, 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.
2. At all relevant times, Defendant EM CHEMICALS, 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.
3. At all relevant times, Defendant EPOXYLITE 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.
4. At all relevant times, Defendant HENKEL 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 and alodine.
5. At all relevant times, Defendant HOECHST CELANES-AMERICAN HOECHST'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, photo resist.
6. At all relevant times, Defendant KEYSTONE ANILINE 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, soluble red dye.
7. At all relevant times, Defendant LOCTITE 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, super bonding agents and adhesives.
8. At all relevant times, Defendant PACIFIC PAC INTERNATIONAL, 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 isopropyl alcohol, ethoxylated alcohol surfactants, methylene chloride, trichloroethylene and 1,1,1-trichloroethane.
9. At all relevant times, Defendant SPACIFIC PAC, 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 isopropyl alcohol, ethoxylated alcohol
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