Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 1 of 19 PAGEID #: 100272
1
1
2
3
4
5
6
7
8
9
10

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
IN RE: E. I. du PONT de NEMOURS AND . CASE NO. 2:13-md-2433
COMPANY C-8 PERSONAL LITIGATION
.
. COLUMBUS, OHIO
. JULY 20, 2016
. 1:30 P.M.
.
. . . . . . . . . . . . . . . . . . .
TRANSCRIPT OF THE PROCEEDINGS OF THE TELEPHONIC STATUS CONFERENCE
BEFORE THE HONORABLE EDMUND A. SARGUS, JR., UNITED STATES DISTRICT
CHIEF JUDGE.
APPEARANCES FOR THE PLAINTIFFS:

11

MICHAEL A. LONDON, ESQ.; ROBERT A. BILOTT, ESQ.; JON C. CONLIN, ESQ.;
DAVID J. BUTLER, ESQ.

12

FOR THE DEFENDANT E. I. du PONT de NEMOURS AND COMPANY:

13

JOHN BURLINGAME, ESQ.; C. CRAIG WOODS, ESQ.

14

-

-

-

15
16
17
18
19
20
21
22
23
24
25

LAURA L. SAMUELS, OFFICIAL FEDERAL COURT REPORTER
(614) 719-3245

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 2 of 19 PAGEID #: 100273
2
1

Wednesday Afternoon Session

2

July 20, 2016

3

-

4

THE COURT:

-

-

-

-

Good afternoon to all of you.

I thought all

5

of you were pretty sick of me now, yet you still want to do

6

another phone call.

7

MR. BUTLER:

8

THE COURT:

9

Not at all, judge.
Yeah, yeah.

We're on the record.

You have

to say that.

10

MR. BUTLER:

11

THE COURT:

Sorry about that.
But I understand that -- The plaintiffs asked

12

for this call to do with the issue of some discovery regarding

13

the, I think not yet completed but maybe about to be completed,

14

motion.

15

So who would like to speak?
MR. BUTLER:

Your Honor, this is David Butler.

I can

16

start things off.

17

call-in number -- He misplaced it -- so he might be chiming in

18

here at any moment, but I can go ahead and kick things off.

19

And then Mike London, I just sent him the

Just by way of background, this kind of whole wave of the

20

motion to compel started when in December of -- Oh, there he is.

21

Okay.

22

MR. LONDON:

Sorry, sorry.

23

MR. BUTLER:

That's okay.

24

THE COURT:

25

MR. BUTLER:

We're good.

Go ahead.

Your Honor, this wave started back in

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 3 of 19 PAGEID #: 100274
3
1

December of 2015 when both Dow and DuPont announced their intent

2

to merge with each other and then do -- they announced then intent

3

then to subsequently, after the merger, to spin off into three new

4

separate, independent companies.

5

When -- After that announcement in December, the

6

plaintiffs already had a pending motion to compel related to

7

Chemours, the Chemours spinoff, and so we supplemented that motion

8

to compel in January of 2016.

9

Basically, in a nutshell, paragraph 10 of that January

10

supplement what we asked for was the schedules that were attached

11

to the merger -- or the spinoff agreement between DuPont and

12

Chemours that we had been asking for for some time.

13

for DuPont -- the DuPont-Dow merger documents that would show

14

where the liabilities were going to go after the merger and the

15

subsequent three-way split.

16

discovery on the merger and three-way split once we got that

17

information.

18

We also asked

We also asked for additional limited

This issue came up at the next status conference, which

19

was on March 23 of 2016.

20

-- The Court asked DuPont's counsel to take a look at this and see

21

what information was available and then basically report back to

22

everyone at the next status conference.

23

As reflected in PTO 44, what the Court

In the meantime, what DuPont produced was a new

24

declaration of Julie Mazza, who is an in-house attorney with

25

DuPont, to kind of take the place of the prior declarations that

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 4 of 19 PAGEID #: 100275
4
1

had been supplied by an in-house attorney that was no longer with

2

DuPont.

3

In April then of 2016, we supplemented our motion to

4

compel.

5

basically in our view just parroted some public information that

6

was on the file with the SEC, was not responsive and did not allay

7

our concerns about where -- what was going on with both the

8

schedules from the DuPont-Chemours and what was going to go on

9

with the merger.

10

Plaintiffs believe that the Mazza declaration, which

Specifically, on page 2 of that third supplement, we

11

incorporated the prior paragraph 10 what we had asked for in

12

January, asking for documents related to the Dow-DuPont merger and

13

then additional limited discovery on the merger and the three-way

14

split.

15

As the Court will recall, this came to a head somewhat

16

during the Freeman trial on about day 4 or 5; and on -- during the

17

June 3 morning conference in response to some press reports in the

18

financial press, this issue kind of came to a head; and Your Honor

19

verbally stated that you would be ordering that the items in that

20

April 2 supplement, which had incorporated paragraph 10 of the

21

January motion, would be ordered to be produced, which included

22

the Chemours-Dow-DuPont merger documents and the schedules.

23

This issue also came up on a Sunday telephone conference

24

call where the Court again reiterated what would be produced.

And

25

then in that discussion, basically everyone decided we would just

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 5 of 19 PAGEID #: 100276
5
1

go ahead and self execute the Court's prior verbal order rather

2

than have the Court put something on the docket ordering the

3

productions.

4

So that brings us to kind of where we are.

Since that

5

telephone call and the Court's verbal order, the only things that

6

have been produced by DuPont in response is a Form S-4 that was on

7

file, which is a public-filing document related to the announced

8

plans that was filed with the SEC, there was also a new

9

declaration from, again, from Julie Mazza which authenticated a

10

public proxy statement that has also been filed with the SEC.

11

then in that declaration, Ms. Mazza further sort of just

12

summarizes what is contained within the proxy statement.

13

all that DuPont has given us.

And

That's

14

What we do not have is we do not have the schedules from

15

the Chemours-DuPont spinoff that we have been asking for and what

16

we believe the Court ordered.

17

underlying Dow-DuPont merger documents that have been properly

18

authenticated by a DuPont person.

19

additional discovery that we would like on this issue, and we have

20

been told basically that we're not going to get anything else.

21

We also do not have any of the

We have also provided a list of

And in the meantime -- and Mike London can speak more to

22

this -- but in the meantime, the Court will recall during the

23

conference when the Court gave the verbal order, the Court

24

mentioned that there would only be one attorney, who could review

25

the information, and also a CPA.

Mr. London endeavored to go out

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 6 of 19 PAGEID #: 100277
6
1

and retain a securities attorney to have the right -- someone who

2

had the right, you know, background and knowledge to review

3

intelligently that information once we got it.

4

We do have somebody engaged now in that regard.

5

folks have looked at what was given to us, this S-4 and the proxy

6

statement, and we have -- you know, they have confirmed with us

7

that the schedules that have not been provided in the merger

8

documents are what we really need to verify what is going on with

9

this liability.

10

Those

And, obviously, the concern is that if these stated

11

plans, the simultaneous shareholder meetings for both Dow and

12

DuPont to vote on this merger are today, and the announced plans

13

then would be to spin off within a period of time to three

14

separate entities that basically are, if everything goes as

15

announced, DuPont would some day no longer exist within the

16

foreseeable, you know --

17

THE COURT:

Before I hear from the plaintiffs, let me ask

18

you a simple question.

19

already public information?

20
21

MR. BUTLER:

Have you received anything that was not

Your Honor, the only thing we received that

was not public was this additional Julie Mazza declaration --

22

THE COURT:

23

or how not detailed is that?

24

MR. BUTLER:

25

How -- I don't -- Explain that.

How detailed

It's not detailed, in our opinion, at all.

It basically -- What it does is summarizes the proxy statement.

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 7 of 19 PAGEID #: 100278
7
1

It authenticates the proxy statement and says, here's a true and

2

accurate copy of the proxy statement, and then proceeds to

3

summarize what that says.

4

THE COURT:

5

MR. BUTLER:

6

THE COURT:

7

MR. BUTLER:

8

THE COURT:

9

Is the proxy statement -And -Is the proxy statement a public document?
Yes, it is.
So it's summarizing a public document?

All

right.

10

Let me hear from the defendant.

11

MR. BURLINGAME:

Sure, Your Honor.

This is John

12

Burlingame.

13

transcript from, I think it was, a Sunday afternoon telephone call

14

that the Court had, and the Court was very explicit and everybody

15

agreed that there didn't need to be an order.

16

Your Honor, I'm looking at the June 5, 2016,

And you said, and I'm quoting from page 25:

Just to be

17

clear, it was pretty simple, I took the plaintiffs' second

18

supplement, and that's docket no. 4516 -- and on the second page

19

there are two categories of information requested numbered one and

20

two, and that's what I ordered.

21

Number one said, a copy of any existing documentation,

22

paren, authenticated by a current DuPont declaration, closed

23

paren, to clarify where the liabilities and obligations of DuPont

24

will fall if the proposed Dow-DuPont merger and subsequent

25

three-way split occurs.

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 8 of 19 PAGEID #: 100279
8
1

After that, DuPont issued the proxy statement that is

2

very voluminous and, yes, it is a public document, and we, about a

3

month ago, provided a declaration that the Court doesn't have, but

4

I'll read pertinent portions of it, as described in the proxy

5

statement in connection with the proposed merger transaction.

6

Dow and DuPont will each merge with separate wholly-owned

7

subsidiaries of DowDuPont, with Dow and DuPont being the surviving

8

entities in such mergers and, as a result, becoming subsidiaries

9

of DowDuPont.

10

From paragraph 6, upon the consummation of the merger

11

transaction, the alleged liabilities and obligations associated

12

with the litigation will remain with DuPont, and there is no

13

expectation or plan that DuPont will be liquidated or otherwise

14

merged out of existence through the proposed merger transaction.

15

Paragraph 7, Dow and DuPont currently intend that

16

following the consummation of the proposed merger, DowDuPont will

17

pursue in all cases, subject to the receipt of approval by the

18

post-merger DowDuPont board and constituent advisory committee as

19

well as any required regulatory approvals, the separation of

20

DowDuPont into three independent, publicly-traded companies, the

21

so-called spinoff transactions, consisting of the combined

22

agriculture, material and science and specialty products.

23

It goes on -- I'll start paraphrasing to just to try to

24

truncate this, Your Honor -- but the merger transaction is not

25

conditioned on the termination -- on the determination to proceed

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 9 of 19 PAGEID #: 100280
9
1

with the spinoff transactions, and such determination whether to

2

proceed with any or all proposed spinoff transactions will only be

3

made after consumption -- after consummation of the proposed

4

merger.

5

The post-merger DowDuPont board may at any time prior to

6

the consummation of any of their proposed spinoff transactions

7

determine to abandon any or all such transaction, and no assurance

8

can be or have been given to any such transactions will occur.

9

Now in short, Your Honor, it is contemplated that there

10

will be spinoff transactions for three separate, publicly-traded

11

companies.

12

those that will be making recommendations to the board of

13

DowDuPont with respect to allegations of allocation of assets and

14

liabilities.

15

There will be advisory boards constituted for each of

There has been no determination whatsoever in terms of

16

where the liabilities that currently are held by DuPont will go if

17

they ultimately go into any of the three contemplated spinoff

18

transactions.

19

THE COURT:

Well, let me -- I don't have the document in

20

front of me, and there's no reason I should, so that's not a

21

criticism, but it's kind of hard to absorb this without having it.

22

MR. BURLINGAME:

23

THE COURT:

Sure.

But let me go back.

You referenced a

24

transcript from June 5, all accurate, but I have also a transcript

25

from June 3 where when I ordered this, I made it clear that there

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 10 of 19 PAGEID #: 100281
10
1

will be an eyes-only set of people to look at this on the

2

plaintiffs' side, clearly not contemplating that we were only

3

looking at public records.

4

So I start with the idea that I assumed -- and no one

5

contradicted me at the time -- that this was going to be something

6

that was confidential, something that was more detailed than

7

general statements about, well, we'll look at this after the

8

merger and something, frankly, a little more fine tuned as far as

9

accounting aspects.

10
11
12

It sounds as though what you have sent is something
purely public and, truthfully, purely general.
MR. BUTLER:

Your Honor, on June 3 also you were very

13

specific that you would -- you included a statement about the

14

schedules --

15

THE COURT:

Yes.

16

MR. BUTLER:

17

THE COURT:

The exact quote is --

18

MR. BUTLER:

-- on the mergers.

19

THE COURT:

20

MR. BUTLER:

-- being ordered to be produced --

Right.
Also the specific reference to document

21

4516, which is the second supplement to the third motion to

22

compel, there's two items there.

23

there is a copy of the documentation.

24

with all due respect, we don't have to take Ms. Mazza's word for

25

what -- We wanted to see the underlying documents that were

And what we -- What it asks for
We don't have -- I mean

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 11 of 19 PAGEID #: 100282
11
1

authenticated by a declaration, not a declaration describing what

2

supposedly the underlying documents say.

3

And then also we can't lose sight that this was all

4

buttressed on the January motion to compel, which is incorporated

5

into what the Court cited, which is, you know, talks about the

6

Chemours spinoff schedules, which we still want, which, again --

7

THE COURT:

One thing I want to be clear on.

8

request, I didn't reduce this to an order.

9

transcript.

10

At DuPont's

That's clear in the

I'm sure everybody agrees with that.

But it was also clear that in the plaintiffs' third

11

motion supplement, I adopted two paragraphs with the addition just

12

mentioned, which includes as well as Chemours schedules in part

13

one.

14

I don't think a proxy statement comes anywhere close to

15

that when the proxy statement just says, we'll look at it in the

16

future.

17

something, Mr. Burlingame, you can tell me.

18

that there aren't schedules, documents, indicating there was due

19

diligence performed, all this occurred, and there had to be

20

something in writing to document it, and I don't hear any of this

21

being disclosed.

22

That's pretty much what I heard.

MR. BURLINGAME:

If I'm missing
But I can't believe

Your Honor, I'm going back to paragraph

23

one, on the second page of the supplement, which you

24

unquestionably ordered, and it talks about clarifying where the

25

liabilities and obligations of DuPont will fall if the merger goes

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 12 of 19 PAGEID #: 100283
12
1

forward.

2

And I can't produce what isn't out there.

The -- There

3

are no documents, and Ms. Mazza in her declaration attested to

4

that fact.

5

more detail, beyond the proxy statement, where the liabilities and

6

obligations of DuPont, including the alleged liabilities and

7

obligations for the litigation, will fall if the proposed merger

8

and three-way split occurs.

9

THE COURT:

DuPont does not have any documents that address in any

Well --

10

MR. BILOTT:

11

THE COURT:

12

You know, I'm not questioning you, Mr. Burlingame,

13

personally.

Your Honor, this is Rob Bilott.
Wait, wait, wait.

I have the floor.

Don't take it that way.

14

MR. BURLINGAME:

15

THE COURT:

I don't, judge.

But this is -- look.

DuPont and Dow didn't

16

just blindly merge or attempt to merge.

There had to be details,

17

due diligence, documents, listings, all these sorts of things.

18

And when there is a proposal that the shareholders already know

19

about, it's public, indicating there's going to be a three-way

20

split, obviously there is some planning for that.

21

happen in a day.

22

for the public documentation, you know, we're not the SEC here.

23

We are not trading on this information.

24

public.

25

CPA selected, who would have to sign a document, verifying he or

That can't

That's what I anticipate this to be.

Waiting

And I assumed it wasn't

That's why we put this whole procedure in place to have a

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 13 of 19 PAGEID #: 100284
13
1

she knew the confidentiality of the documents, wouldn't disclose

2

them to anyone else.

3

were dealing with proxy statements and matters made public through

4

the SEC filings.

5

There would be no reason to do that if you

That just wouldn't make sense.

MR. BURLINGAME:
It was:

Your Honor, again, I go back to the

6

order.

What happens to the liabilities?

And I'm

7

certain, as you are, judge, that there was valuation of potential

8

liabilities on -- all over this transaction.

9

question, what happens to those liabilities, is something that

But that the core

10

hasn't been addressed and won't be addressed until these advisory

11

boards are constituted and make recommendations to the DowDuPont

12

board.

13

THE COURT:

Right.

14

MR. BURLINGAME:

15

THE COURT:

So the whole time --

But there is a difference -- There's a

16

difference between deciding and analyzing.

And I can understand

17

that maybe it takes final board actions, and the boards haven't

18

been really constituted.

19

of this somewhere along the way, and that would be existing

20

documentation, in my view, at least oral order in this case.

21

mean I have to assume -- I understand that board action hasn't

22

been taken on this.

23

is.

24

seems to me to be subsumed in the first paragraph of what I

25

ordered.

But there has to have been some analysis

I

You can't tell anybody what the board action

But there have been steps taken and analyses made, and that

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 14 of 19 PAGEID #: 100285
14
1

MR. WOODS:

Your Honor, this is Craig Woods.

I think, at

2

least what we're being told is, there has not been an analysis of

3

this specific question of where the liabilities are likely to go

4

in the event of a three-way split.

5

THE COURT:

Well, I'll tell -- You know, I am -- Again,

6

this has nothing to do with anybody on the phone call -- I'm

7

feeling a bit frustrated.

8

very quickly schedule a hearing and have a principal come in who

9

is involved in this.

I think the only option I can see is to

If it's going to be things that aren't

10

public, we will make it all under seal, and we will do that, and

11

the lawyers will be bound by confidentiality.

12

takes and the more difficult it becomes to get this information,

13

truthfully, the more I'm determined that there is something that

14

needs to be ferreted out here.

15

nothing.

16

more things aren't disclosed, the more suspicious everybody

17

becomes, and I think that's the situation we're in right now.

18

But the longer this

I hope it turns out to be the big

But I can tell you from long experience in this job, the

So I'm going to ask you to consult about schedule, and

19

then I am going to order a very high-level person, someone who is

20

intimately familiar and was at the table in making this deal and

21

is at the table in guiding how the new corporation will be formed,

22

has to come in and give testimony and bring in any related

23

documentation with them.

24

MR. BURLINGAME:

25

Burlingame.

Your Honor, may I make a -- This is John

May I make a suggestion, judge?

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 15 of 19 PAGEID #: 100286
15
1

THE COURT:

I'll listen.

2

MR. BURLINGAME:

Thank you.

This is the first that I

3

have heard -- I know that plaintiffs' counsel has been trying to

4

line up a CPA type.

5

have somebody lined up.

6

touch with us, provide the specifics of whatever it is that he or

7

she thinks is out there provided under this protective order.

8

will get to it promptly and then determine whether that

9

satisfactorily addresses the issue with the PSC.

10

THE COURT:

This is the first that I have heard that they
I would suggest that that person get in

We

I think -- As long as we can do that quickly,

11

and I'm sure you are prepared to do that, I think that might be

12

the course to go.

13

I'm --

How many days do you think this would take?

14

MR. LONDON:

15

THE COURT:

Your Honor -Well, just to be clear, I'm thinking a very

16

short period of time here.

17

doesn't work, you will notify me, and then we will do what I just

18

suggested.

19

MR. LONDON:

I'm not -- and, you know, if that

Your Honor, Michael London here.

And we

20

have been consulting with this law firm who was retained over a

21

month ago.

22

telling us, frankly, just as Your Honor said, and we have lost

23

sight of this, that the schedules for the Chemours spinoff exist.

24

They exist.

25

with a spinoff requires the schedules to be filed with the spinoff

And they have been guiding us in these requests and

They unequivocally exist.

And many times the SEC

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 16 of 19 PAGEID #: 100287
16
1

agreement.

2

filed.

3

critical, and they exist.

4

Sometimes the SEC does not require the schedules to be

But the schedules of the Chemours spinoff are absolutely

THE COURT:

This is -- I -- You know, I don't want to cut

5

you off, but what I want to say is this.

6

been direct communication between your retained expert, or

7

whatever you want to call them, professional, and anybody from

8

DuPont.

9
10

I want -- There hasn't

Is that correct?
MR. BURLINGAME:

That's correct, judge.

This is John

Burlingame.

11

THE COURT:

So let's just -- wait.

What I'm talking

12

about is a very short period of time, days, not weeks, days.

13

want that to happen, and I want to see if is some opportunity

14

still to get the information.

15

hearing in about ten days or less.

16

MR. BILOTT:

I

If not, then I'm thinking of a

Your Honor, this is Rob Bilott.

I think one

17

thing that does need to be made clear is this is really another

18

delay by DuPont.

19

information we need, and we have been asked to give it to our new

20

consultants here.

21

nothing new we're going to be asking them for.

22

what they need.

23

point.

24
25

We have already conveyed to DuPont what

We have already conveyed that.

There is

They already know

They're just refusing to turn it over at this

MR. LONDON:

Judge, if I can -- This is Michael London --

the schedule is the first thing that they are going to tell John

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 17 of 19 PAGEID #: 100288
17
1

Burlingame that they need, and John has not sent a schedule.

2

We're happy to have orders to meet and confer with them.

3

THE COURT:

I want everybody to relax for a second.

I'm

4

looking at my calendar, and I realize you're all in front of me

5

next Wednesday and Thursday.

6

hearing date on Thursday.

7

through the exercise Mr. Burlingame has suggested.

I don't want

8

to be doing this if this can be still worked out.

So we're going

9

to be -- come prepared -- Two things:

Right?

So let's talk about a

But what I want you to do is still go

Come prepared on Thursday

10

to argue this; and, Mr. Burlingame, you're going to need, and

11

Mr. Woods you are going to need, a principal on that date unless

12

you can work with the other side and see this problem resolved.

13

And when say a principal I mean someone who doesn't have to call

14

anybody, doesn't have to refer to anybody, who can come in here

15

with the kind of information that will tell us exactly how this

16

has been anticipated if not finalized.

17

seal.

18

Thursday.

And it will be all under

But we will go forward, and we will set that for 1:30 on

19

All right.

And what I would like you to do is report

20

back to me maybe by Friday of this week to let me know where this

21

stands.

22

All right?
MR. BURLINGAME:

Judge, just to be -- just to be clear in

23

my understanding, you're talking about if this isn't resolved,

24

you're expecting a hearing at 1:30 on Thursday with this issue?

25

THE COURT:

With a witness from DuPont with -- with great

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 18 of 19 PAGEID #: 100289
18
1

knowledge about anticipated actions to be taken, analyses, not

2

necessarily decisions but analyses, of assets, liabilities, where

3

they may or may not fall.

4

contemplated, and I want somebody who knows of those

5

contemplations and bring documents that would support whatever the

6

testimony is.

7

all under seal unless something else takes place.

8
9
10

At this point I'm going to assume it's going to be

All right.

And so you'll let Penny know on Friday where

we are on this, and then I will look forward to seeing you next
Wednesday.

Thank all of you.

11

MR. BUTLER:

12

MR. BURLINGAME:

13
14
15
16
17
18
19
20
21
22
23
24
25

I'm sure these have all been

Thank you, Your Honor.
Thank you, Your Honor.
-

-

-

 Case: 2:13-md-02433-EAS-EPD Doc #: 4590 Filed: 07/21/16 Page: 19 of 19 PAGEID #: 100290
19
1

C E R T I F I C A T E

2
3

-

-

-

I, Laura L. Samuels, do hereby certify that the foregoing is

4

a true and correct transcript of the proceedings of the Telephonic

5

Status Conference in the case of:

6

Company C-8 Personal Litigation, case no. 2:13-md-2433, before the

7

Honorable Edmund A. Sargus, Jr., Chief Judge, in the United States

8

District Court, Southern District of Ohio, Eastern Division, on the

9

date indicated, reported by me in shorthand and transcribed by me or

10

E. I. du Pont de Nemours and

under my supervision.

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

/s/ Laura L. Samuels
Laura L. Samuels
Official Federal Court Reporter