**PLAINTIFFS,**

-AGAINST-

**UNION CARBIDE CORPORATION, EASTMAN KODAK COMPANY, KTI CHEMICALS, INC. J.T. BAKER, INC., K/N/A MALLINCKRODT BAKER, INC., SHIPLEY COMPANY, INC., INDUSTRI-CHEM LABORATORY, INC., ASHLAND OIL, INC., E.I. DUPTON DE NEMOURS AND COMPANY, AND INTERNATIONAL BUSINESS MACHINES CORPORATION,**

**DEFENDANTS.**

**Plaintiffs, by DURST, APSAN, BERSIN & DEPROSPO, allege the following upon information and belief:**

**A FIRST CAUSE OF ACTION FOR NEGLIGENCE**

1. At all times hereinafter mentioned, the defendant UNION CARBIDE CORPORATION was a domestic corporation, incorporated under the laws of the State of New York.
2. At all times hereinafter mentioned, the defendant UNION CARBIDE CORPORATION was authorized to do business in the State of New York.
3. At all times hereinafter mentioned, the defendant EASTMAN KODAK COMPANY was a foreign corporation, incorporated under the laws of the State of New Jersey.
4. At all times hereinafter mentioned, the defendant EASTMAN KODAK COMPANY was authorized to do business in the State of New York.
5. At all times hereinafter mentioned, the defendant EASTMAN KODAK COMPANY was an unincorporated business association,

**IBM-ZRIND 64217**