09/29/2020

Case Number: AC 17-0694 IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA

IN RE ASBESTOS LITIGATION, Cause No. AC 17-0694 Consolidated Cases JUDGMENT AND ORDER APPROVING SETTLEMENT(Robinson Insulation Receivership)

Receiver Nancy Gibson and Allan McGarvey and Mark Kovacich on behalf of certain Libby Plaintiffs have jointly filed a motion (the "Motion") asking this Court to authorize the Receiver's settlement of the insurance coverage claims by Robinson Insulation Company ("Robinson") against ACE Fire Underwriters Insurance Company and ACE Property & Casualty Insurance Company (collectively,"Chubb"), American States Insurance Company ("American States"), and Motorists Commercial Mutual Insurance Company ("Motorists" and, collectively with Chubb and American States, the "Settling Insurers"). A copy of the "Settlement Agreernent and Release"(the "Agreement") between the Receiver and the Settling Insurers is attached to the joint motion ofthe Receiver and certain Libby Plaintiffs, and has been reviewed by this Court. I The court has reviewed the following documentation attached to the Motion and makes these findings based thereon: (a) Exhibit A is a discovery response filed on behalf of Grogan Robinson Lumber Cornpany ("Grogan"). It establishes, and the court finds,(i) that Grogan was the successor to Lurnber Yard Supply and Grogan-Robinson Lumber Cornpany;(ii) ownership and related management of Robinson and Grogan and its predecessors overlapped; and (iii) that, following the winding up of its assets and affairs, Grogan was dissolved in 2018.

(b) Exhibit B is a copy of the Agreement which the Court finds to exhaust the limits of liability coverages in the policies settled thereby.

(c) Exhibit C is an affidavit of Allan McGarvey, attorney for hundreds of Libby asbestos claimants including those with and without claims of exposures during the insurance coverage period. It establishes, and the court finds, that (i) the Agreernent was reached following extensive efforts to identify insurance policies potentially providing coverage for claims against Robinson;(ii) despite reasonable efforts, a Unless defined separately herein, all capitalized terms in this Order have the meanings ascribed to them in the Agreement.

EXHIBIT I 001 nurnber of policies and /or declaration sheets, endorsernents, and forrns for several policies could not be located; (iii) secondary evidence of coverages provided by certain policies was located but was also incomplete;(iv) pleadings in a declaratory judgment action filed in U.S. District Court in Montana were filed setting forth the coverage contentions and defenses of the parties to the Agreement;(v) extensive analysis and negotiation was pursued to reach agreernent on the coverages provable and the rneanings thereof; and (vi) counsel for all known individuals with clairns against Robinson are satisfied that the Agreement exhausts the maximum available coverage under the settled policies.

(d) Exhibit D is a Qualified Settlement Fund Trust which the court finds (i) will receive and hold proceeds of the settlement of the settled insurance; (ii) upon further application to and approval of this court, would distribute such proceeds to resolve claims of those with claims against the Receivership estate which constitute occurrences under the coverages of the settled insurance; and (iii) is the appropriate and necessary and customary rnechanisrn to manage those proceeds, as they must be, for the purpose of resolving corresponding clairns.

(e) The affidavits of Allan McGarvey and Receiver Nancy Gibsonestablish, and the court finds, that (i) lawsuits have been filed against both Robinson and Grogan alleging claims for strict product liability for the sarne asbestos injuries with the difference being that Robinson was primarily a manufacturer of the product while Grogan and its predecessor entities were distributors of the product,(ii) the Settling Insurers have been providing a defense of all such claims under reservation of rights, (iii) plaintiffs' counsel have apprised defense counsel that rnany lawsuits may be brought against Grogan alleging strict product liability for darnages for which Robinson is alleged to also be liable, and (iv) the resolution of the clairns against Robinson will therefore not elirninate lawsuits against Grogan for the same injuries or types of injuries.

The court concludes as follows: (A) This Court's March 23, 2018 Order (the "Order") creating the receivership granted authority for the Receiver to rnake dernands that the insurers settle clairns against Robinson (Order 111(c)). The Order, at Order112 (a),(b) requires that the Receiver obtain this Court's approval of"specific proposals" for settlernent.

(B) The proposed settlement entered into by the Receiver and its insurers is appropriately rnade subject to this Court's approval.

(C) The settlernent is in the best interests of the Robinson and Grogan receivership estates because it is a fair and reasonable compromise of disputed insurance coverage issues. The settlement was negotiated in good faith and at arm's length

EXHIBIT I 002 between the Receiver and Mr. McGarvey, on the one hand, and each ofthe Settling Insurers, on the other hand.

(D) The compromise embodied in the Agreement allows the Receiver to liquidate Robinson's and Grogan's insurance coverage for distribution to persons asserting claims against Robinson and/or Grogan, subject to the establishment of a Trust that would, once approved by this court, fairly and equitably distribute the insurance settlement proceeds to those claimants against Robinson and/or Grogan who satisfy the Trust's requir6ments.

(E) The Agreement provides, at paragraph 3.3, that each Settling Insurer shall pay its respective settlement amount into a Qualified Settlernent Fund ("QSF"), and that the Receiver shall not distribute any funds from the QSF except as authorized by this court.

(F) The Receiver has provided due and adequate notice of the Motion, the deadline to object to the Motion, the Agreernent, and the subject matter thereofto all persons known to have asserted Asbestos Claims(as defined in the Agreement)against either Robinson or Grogan and to all of its other insurers, including Home Insurance Company (in liquidation) and Mission Insurance Company (in liquidation). In addition, to ensure the broadest notice possible, the Receiver and the Settling Insurers have published notice ofthe (i) Motion,(ii) the hearing on the Motion, and (iii) the Agreement in USA Today, The Western News, Kalispell Daily Interlake, Missoulian, Great Falls Tribune, and Helena Independent Record on [May 26], 2020, in the Billings Gazette on [May 27], 2020, and in the Sanders County Ledger on [May 28], 2020. Such notice, including the aforesaid notice by publication, was good and sufficient under the particular circumstances to provide adequate and appropriate notice to both known and unknown Asbestos Claimants, and no other or further notice is or shall be required. Accordingly, a reasonable opportunity to object or be heard with respect to the Motion and relief requested herein has been properly afforded to all persons and entities potentially affected by the Agreement.

(G) The relief sought in the Motion is in the best interests of the Robinson and Grogan receivership estates and the Asbestos Claimants. The Receiver has demonstrated good, sufficient, and sound business purposes and justifications for the relief requested in the Motion. The compromise and settlement with the Settling Insurers embodied in the Agreement is consistent with and within the reasonable range of litigation outcomes if the Receiver were to litigate the matters resolved pursuant to this Order.

EXHIBIT I 003 (H) The compromises contained in the Agreement are a valid and proper exercise of the reasonable business judgment of the Receiver and represent an exchange for reasonably equivalent value. The releases to be given by the Receiver pursuant to Section 5 of the Agreement are appropriate and should be approved. The Settling Insurers would not have entered into the Agreement or any of the compromises and settlements contained therein, or agreed to pay their respective Settlement Amounts, without the benefit of obtaining the releases contained in the Settlement Agreement and the Injunctions contained in this Order.

(I) This court has inherent equitable authority sufficient to permit it to enter the injunctions contained in Sections 4 and 5 of this Order (the "Injunctions"). The Injunctions are essential to give effect to the settlements and compromises set forth in the Agreement and to fulfill the purposes of both the Robinson and Grogan receiverships. The Settling Insurers have asserted that the Injunctions are a necessary prerequisite for entry into the Settlement Agreement, and the Settling Insurers have informed the Receiver that they will not consummate the settlements and cornprornises set forth in the Agreement, or pay their respective Settlement Amounts in the absence of the Injunction.

Wherefore, IT IS HEREBY ORDERED and ADJUDGED: (1) The Motion is granted.

(2) The Agreernent settling and releasing the insurance coverage clairns of Nancy Gibson, as court-appointed Receiver for Robinson and Grogan, against the Settling Insurers is hereby fully and finally approved.

(3) Settlement proceeds shall be paid to the Receiver, Nancy Gibson, to be held by the Receiver in a QSF, until such tirne as this court approves the establishrnent of a Trust and appropriate procedures for the Trust to distribute the settlernent proceeds to Asbestos Clairnants.

(4) Pursuant to the Court's inherent equitable authority,(a) all Persons who hold or assert, or rnay in the future hold or assert, any Claim against Robinson, Grogan, or the Receiver arising in connection with the activities covered by the Policies, or in connection with the activities of Robinson or Grogan giving rise to the Clairns that have been rnade or that could be made under the Policies, and (b) all Persons who rnay claim to be an insured, additional insured, or otherwise entitled to any benefit under the Policies, are permanently stayed, barred, restrained, and enjoined from asserting any such Claim or right to entitlement, from comrnencing a proceeding, or taking any other action against ACE Fire Underwriters Insurance Cornpany, ACE Property & Casualty Insurance Company, Motorists Commercial

EXHIBIT I 004 Mutual Insurance Cornpany, or Arnerican States Insurance Company (collectively,the "Settling Insurers") or the persons and entities defined in the Agreernent as "Insurer Parties" for the purpose of obtaining any recovery or other relieffrom the Settling Insurers or the Insurer Parties based on, under, arising out of, related or attributable to, and/or in connection with the Policies.

(5) A11 clairns for contribution, allocation, subrogation, and equitable indernnity, or sirnilar claims, against any of the Settling Insurers (collectively,"Contribution Claims"), whether by parties appearing before the Asbestos Clairns Court or not, are hereby BARRED pursuant to the Court's inherent equitable authority. All Contribution Claims against any ofthe Settling Insurers shall be channeled to the QSF established to hold the Settlement Arnounts paid by the Settling Insurers or to any Trust to which the funds in the QSF are transferred following an order by this Court authorizing such transfer.

(6) This is a final order and judgment for purposes of appeal under Rule 4(1)(a) ofthe Montana Rules of Appellate Procedure.

/ / /7) // fAff//ad / / / If

EXHIBIT I 005 Nancy M.:Effie(MT Biár #4883) ' Nathan A.Huey(MT Bar # 27181867) ' GORDON REES SCULLY MANSPKHANI,LLP W. Main Street, Suite 101 Missoula,MT 59802 Telephone:(406)203-5808 [email protected] [email protected] '6 Attornäy f- or Third‘Party Defendant, 7. GROGAN ROBINSON LUMBER COMPANY D/B/A LUMBER YARD SUPPLY 8 • • : MONTANA ELEYENTH JUDICIAL DISTRICT COURT,l 9 FLATHEAD COUNTY , 10 •

JEREMIAH HARTLE and KAREN HARTLE, • , -Cause No.DWI8-!53.2A • husband and wife, individually and on behalf of th6if Minor childien, Plaintiffs, , • CÓNAGRA'BRANDS;INC:, a belaWare for profit. corporation; WESTERN BUILDING CENTER,INC., a Montana for prOfit corporation; and DOES A-4, .,; .

Defendants. TIIIRD PARTY DEFENDANT OROGAN 18 gotThlgoN'JAMMER COMPANY WESTERN BUILDING CENTER,INC., a P/B/A.Liming YARD surnrs Montana torporation,, - • • AtsFONSt8 ANt).OWkerKiris TO PLAINTIFFS'ERST • 20 • .‘ Third Party Plaintiff, INTERROGATORIES ANI)REQUESTS FOR PROpUcTION NNETH HARTLEi,and individual; WITTIG BUILDING PRODUCTS,INC., a Washington ,5,25 • torporatioh, individually and succo.§sbr to PALMER.G. LEWIS COMPANY,a Montana corpOration; PALMEItG.LEWIS COMPANY, • a Montana corporation; ACE HARDWARE ' 25 CORPORATION,a Delaware norporation; ROBINSON INSULATION COMPANY,a •

26 Montana dorporatilon; MINOT BUILDERS SUPPLY ASSOCIATION,a Minnesota entity; INDEPgNDENT,LUMBERAND SUPPLY INC.,a Montana corporation; EMPIRE -1- . •• THW FARTYDEPI3NpANT LpMBER YARD SUPPLY'SRESPONSES TO PLAINTIFFS' FIRST • ' i110131tROGAIDRIE§ ANti RtOutsts FoR PRODUCTION Exhibit 01 1 5. All responses are basecl on Lumber Yard Supply's current knowleclge ancl reasonable belief, ancl Lumber Yard Supply reserves the right to amend or supplement these Objections and Responses.

4 6. Lumber Yarcl Supply has made reasonable efforts to respond to Plaintiffs' First Discovery Requests and has not objected to certain of these, inteipreting them in such a fashion as to avoid objections when possible and to facilitate the discovery process. If Plaintiff subsequently asserts an interpretation of any Discovery Request that differs from that of Lumber Yard Supply, Lumber Yard Supply reserves the right to supplement its responses ancl objections.

9 RESPONSES TO INTERROGATORIES 10 INTERROGATORY NO. 1: Please provide a summary of your corporate or business history, 11 including date of incorporation, mergers, consoliclations, re-incorporations, and reorganizations.

12 ANSWER: Lumber Yard Supply objects to this Interrogatory on the grounds that the phrase "corporate or business history" is vague and ambiguous. Lumber Yard Supply also objects to 14 this hilerrogatory on the grounds that it is not appropriately limited in time or scope. Subject to ancl without waiving any of its general or specific objections, Lumber Yard Supply states, upon 16 information and belief, that it was incoiporated in Montana in 1929 as Twin City Finance Co., at which time it was in the business of financing homes. Twin City Finance Co. ceased operating in the early 1930s, becoming inactive, but was not dissolved. In 1948, the name of the company 19 was changed to Lumber Yard Supply Co., and it began business as a lumber wholesaler. In or 20 about 1993, Lumber Yard Supply Co. merged with Grogan-Robinson Lumber Company, a North 21 Dakota company that had been in the retail lumber business since 1906 (originally incorporated 22 as Mahon-Robinson Lumber Co.). When Lumber Yard Supply Co. and Grogan-Robinson 23 Lumber Conipany merged in or about 1993, the combined company became known as Lumber 24 Yard Supply Co. and left the retail lumber business, focusing instead on the wholesale lumber 25 business. In January 2002, a fire at Lumber Yard Supply Co. in Great Falls, Montana destroyed 26 nearly all of its records in existence at that time. In approxiniately March 2015, the assets of 27 Lumber Yard Supply Co., including its name, were sold to Wausau Supply Co. On or about the -4- THIRD PARTY DEFENDANT LUMBER YARD SUPPLY'S RESPONSES TO PLAINTIFFS' FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION Exhibit 02 date of sale, the name of Lumber Yard Supply Co. was changed to Grogan Robinson Lumber Company for put22.se-s-of winding down the company's business. Grogan Robinson Lumber' Cornpany dissolved inilate 2018. Because of the fire in January 2002, the sale of Lumber Yard Supply Co. ausau Supply Co. in 2015, and the dissolution of Grogan Robinson in 2018, access to responsive company recorcls is limited or non-existent. Lumber Yard Supply's investigation is ongoing, and Lumber Yard Supply will supplement its responses to the extent additional responsive information becomes available.

8 INTERROGATORY NO. 2: For each colporation or business entity described above, please clescribe their activities relatecl to placing vermiculite and/or asbestos-containing products into 10 the stream of commerce. The description shoulcl include the name of the corporation or business 11 entity involved; the nianner in which asbestos-containing products were placed into the stream of 12 commerce; the specific products involved, detailed year by year and by brand or trade name; and 13 the amount or volume of all such products placed in the stream of commerce.

14 ANSWER: Lumber Yarcl Supply objects to this Intenogatory on the grouncls that it is not 15 appropriately limited in time or scope. Subject to and without waiver of any of its general or 16 specific objections, Lumber Yard Supply states, upon information and belief and without 17 admitting that any of the products to which Plaintiff Jeremiah Hartle rnay be been exposed 18 contained asbestos, that Lumber Yard Supply Co. sold and clistributed Zonolite (an insulation 19 product produced through heat-treatment of vermiculite) to retailers that it purchased on a per- 20 order basis from Robinson Insulation Company. Upon information and belief, Lumber Yard 21 Supply Co. may also have sold cement board (otherwise known as "asbestos board")to retailers, 22 but states that it does not believe it ever was the primary supplier of any product to Western 23 Building Center. Because of the fue in January 2002, the sale of Lumber Yard Supply Co. to 24 Wausau Supply Co. in 2015, and the dissolution of Grogan Robinson in 2018, access to 25 responsive company records is limited or non-existent. Lumber Yard Supply's investigation is 26 ongoing, and Lumber Yard Supply will supplement its responses to the extent additional 27 responsive information becomes available.

-5- THIRD PARTY DEFENDANT LUMBER YARD SUPPLY'S RESPONSES TO PLAINTIFFS' FIRST INTERROGATORIES AND REQUESTS FOR PRODUCTION Exhibit 03 Exhibit A004 SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release is made as of the Execution Date by all of the Parties: ACE Fire Underwriters Insurance Company; ACE Property & Casualty Insurance Company; Motorists Commercial Mutual Insurance Company; American States Insurance Coinpany; and Nancy Gibson, as Receiver for Robinson Insulation Company.'

RECITALS A. Robinson has been sued in numerous Asbestos Claims,including in the AC Court, and may be subject to additional such Asbestos Claims in the future.

B. Grogan was sued in the Hartle Claims, which was an Asbestos Claim, and may be subject to additional such Asbestos Claims in the future.

C. Both Robinson and Grogan are dissolved corporations. Robinson is the subject of receivership proceedings in the AC Court.

D. Each ofthe Insurers issued or is alleged to have issued to Robinson and/or Grogan the respective Policies identified on Exhibits A,B,and C to this Agreement. The Receiver alleges that each of the Policies provides coverage for Asbestos Claims. The Insurers have conducted a diligent search for additional liability policies issued or allegedly issued by each of them or their affiliates to Robinson and/or Grogan that inight provide coverage for Asbestos Claims, but have not located policies other than those identified in Exhibits A,B, and C.

E. A dispute exists between the Receiver and Motorists regarding the existence,terms, and/or conditions of some of the Policies listed on Exhibit C, as noted on Exhibit C.

F. The Receiver tendered the Asbestos Claims and the Hartle Claims to the Insurers.

The Insurers settled the Hartle Claims pursuant to a settlement agreeinent approved by the AC Court on April 20,2020.

G. Each Insurer has agreed to defend Robinson against the Asbestos Claims, subject to reservations of rights.

H. ACE Fire and ACE P&C filed the Coverage Case against the Receiver, American States, and Motorists on November 12, 2019. Each of the defendants filed counterclaims against ACE Fire and ACE P&C and cross-claims against one another. The Coverage Case remains pending.

I. The Parties desire to avoid future disputes concerning the existence and scope of each Insurer's obligation, if any, to provide coverage under the Policies for current and future Claims, including Asbestos Claims, and regarding allocation and payment of Asbestos Claims.

All capitalized terms, wherever they appear in this Agreement or in any attachments hereto (including the prefatory paragraph, the recitals, and in the Sections below) have the meanings ascribed to them in Section 1.

Exhibit B001 J. By this Agreement, therefore, the Parties by way of compromise and release (i) except as set forth herein, without prejudice to or waiver of their respective positions in matters with persons or entities who are not Parties, (ii) except as set forth herein, without further adjudication of any issues of fact or law, and (iii) without any admission of liability or responsibility, enter into this full and final settlement that releases all rights, obligations, and liabilities of the Insurers under the Policies pursuant to the terms and conditions set forth in this Agreement.

K. This Agreement is entered into by the Parties in good faith and as the result of(i) an exchange of historical claims data and other information and (ii) arm's-length negotiations among the Parties.

L. These recitals are incorporated in full into the Agreement.

AGREEMENT 1. Definitions.

The following definitions apply to this Agreement and any attachrnents hereto. They do not apply to any other agreement, including any policy of insurance, nor are they to be used as evidence, except with respect to this Agreement. Each defined term stated in a singular form includes the plural form, each defined term stated in plural form includes the singular forrn, and each defined term stated in the masculine, feminine, or neuter form includes each of the masculine, ferninine, and neuter forrns. The word "includine means "including but not limited to."

1.1 "AC Court" means the Asbestos Claims Court of the State of Montana,including in its supervisory role over the Receiver.

1.2 "ACE Fire means ACE Fire Underwriters Insurance Company, formerly known as CIGNA Fire Underwriters Insurance Company, formerly known as Aetna Fire Underwriters Insurance Company.

1.3 "ACE P&C" means ACE Property & Casualty Insurance Cornpany, formerly known as CIGNA Property and Casualty Insurance Company,formerly known as Aetna Insurance Cornpany, (1) in its own capacity and right and (2) as assuming reinsurer for Oakwood Insurance Company, successor by merger to Central National Insurance Cornpany of Omaha, but only with respect to those policies issued through Cravens, Dargan & Company,Pacific Coast.

1.4 "Agreement" rneans this Settlement Agreement and Release.

1.5 "Amended Receivership Order" means Order Granting Receiver Litigation and Settlement Authority (Robinson Insulation Company) entered on or aboutJanuary 23, 2020 by the AC Court.

1.6 "American States" rneans American States Insurance Company.

- 2- Exhibit B002 1.7 "American States Settlement Amount" means the total sum of $425,000.00, which amount is in addition to payments to resolve the Hartle Claims.

1.8 "ASI Releasees" means American States, those entities listed on Exhibit D hereto, and each of their direct and indirect parents, joint ventures, subsidiaries, affiliates, officers, directors, employees, agents, representatives, rnembers, and attorneys (including each of their respective predecessors, successors, assigns, heirs, administrators, or executors), all in their capacities as such and as they exist on the Execution Date.

1.9 "Asbestos Claim" tneans any and all Claims against Robinson or Grogan for bodily injury, personal injuiy, property damage, damages, wrongful death, or other harm relating in whole or in part, in fact or by allegation, to the presence of, or exposure to, direcdy or indirectly and in any manner, asbestos or asbestos-containing materials or products, either alone or in combination with any other substance, that were alleged to have been rnanufactured,installed, removed,fabricated, purchased, sold, supplied, transported, labeled, produced, designed, disturbed, released, used, or in any way at any tinie held, handled,distributed,installed, marketed, or disposed of by Robinson or Grogan, or for which Robinson or Grogan is otherwise alleged to be responsible.

1.10 "Asbestos Claimant" means any person, in any capacity, asserting an Asbestos Claim.

1.11 "Coverage Case ineans the declaratory judgment action pending in the U.S. District Court for the District of Montana captioned ACE Fire Undenvriters Co., et al. o. Nang Gibson, as Receiverfor Robinson Insul. Co., et al., Case No. 9:19-cv-00181-DLC-KLD.

1.12 "Chubb" means, collectively, (a) ACE Fire, (b) ACE P&C, and (c) Oakwood Insurance Coinpany as successor by merger to Central National Insurance Coinpany of Omaha, but only with respect to those policies issued through Cravens, Dargan & Company,Pacific Coast.

1.13 "Chubb Releasees" means ACE Fire, ACE P&C,those entities listed on Exhibit E hereto, and each of their direct and indirect parents, joint ventures, subsidiaries, affiliates, officers, directors, employees, agents, representatives, members, and attorneys (including each of their respective predecessors, successors, assigns, heirs, administrators, or executors), all in their capacides as such and as they exist on the Execudon Date.

1.14 "Chubb Settlement Amount" means the total sum of$5,000,000.00, which amount is in addition to payments to resolve the Harde Claims.

1.15 "Claim" means any claim, assertion of right, complaint, cross-complaint, counterclaim, affirmative defense, writ, demand, inquiry, request, directive, obligation, suit, lawsuit, action, cause of action, administrative proceeding, -3- Exhibit B003 governmental claim or action, order, judgment, settlement, mediation, arbitration, lien, and any other assertion ofliability of any kind, whether past, present,or future, known or unknown, asserted or unasserted, foreseen or unforeseen, fixed or contingent, direct or indirect, matured or unmatured, liquidated or unliquidated, direct or consequential, and whether in law, equity, admiralty, or otherwise.

Without limiting the foregoing, Claim includes any matter that would, absent this Agreement, be covered by one or rnore of the Policies. For the avoidance of doubt,"Claim" does not include the Hartle Claims.

1.16 "Contribution Claim" means any Claim by any insurer of Robinson or Grogan (or guaranty corporation or liquidator authorized to pay claims on behalf, or in lieu, of an insurer of Robinson or Grogan) against any of the Insurers seeking contribution, equitable contribution, indemnity, equitable indemnity, subrogation, equitable subrogation, or recovery pursuant to any other theory under law or in equity, arising out of or relating to the payrnent or defense by such insurer of all or any part of any Claim against Robinson or Grogan, including without limitation any Asbestos Claim.

1.17 "Execution Date means the last date upon which this Agreement was signed by all of the Parties, as evidenced by the last date on the signature pages hereto. If a signature is not dated by one of the Parties, then the date that Party transmitted the document to the other Parties will be deemed the date of signature for purposes of determining the Execution Date.

1.18 "Final Order" means any judgrnent or order (a) as to which the time to appeal, petition for certiorari, or move for re-argument or rehearing has expired, and as to which no appeal, petition for certiorari, or other proceedings for re-argument or rehearing will then be pending, or as to which any right to appeal, petition for certiorari, or request re-argument or rehearing will have been waived in writing, in form and substance satisfactoiy to the Parties, or (b) in the event that an appeal, writ of certiorari, or request for re-argurnent or rehearing thereof has been sought, such order or judgment will have been determined by the highest court to which such order was appealed, or certiorari, re-argument, or rehearing will have been denied, and the time to take any further appeal, petition for certiorari, or move for re-argument or rehearing will have expired.

1.19 "Grogan" means Grogan Robinson Lumber Company, a dissolved corporation.

1.20 "Grogan Entities" means (a) Grogan and its employees, agents or officers,(b) each ofits present and future, direct and indirect, parents, joint venture, subsidiaries, partners, and affiliates, solely in their capacities as such,(c) each of its past, direct and indirect, parents,joi.nt ventures, subsidiaries, partners, and affiliates, but only if a person or entity described in (a) or (b) above has the power or authority to act on such entitys or person's behalf,(d) any person or entity asserting entidement to insurance, rights, or benefits under any of the Policies, including any insured, additional insured, named insured, additional named insured, or protected person,

Exhibit B004 but only if an entity or person described in (a) or (b) above has the power or authority to act on such entity or person's behalf,(e) the past, present, and future trustees, adrninistrators, officers, directors, employees, agents, representatives, members, principals, and attorneys of any of the foregoing, but only in their capacities as such, and (f) the predecessors, successors, assigns, heirs, administrators, or executors of any of the foregoing, but solely in their capacities as such.

1.21 "Hartle Claims" means all claims by Jeremiah Hartle and Karen Hartle, husband and wife, individually and on behalf of their minor children, that were released pursuant to the Confidential Release and Settlement Agreement among Jeremiah and Karen Hartle, individually and on behalf of their minor children, and the Receiver, effective on or about March 6, 2020, which Confidential Release and Settlement Agreement was approved by the AC Court on April 20, 2020 pursuant to the Order Approving Settlement (Robinson Insulation Receivership).

1.22 "Injunctions" means the injunction and the bar order set forth in Sections 8.1 and 8.2 of this Agreement.

1.23 "Insurers" means, collectively, ACE Fire, ACE P&C, Arnerican States, and Motorists.

1.24 "Insurer's Settlement Share" means each Insurer's share as specified in the definitions of American States Settlement Arnount, Chubb Settlement Amount, and Motorists Settlement Amount.

1.25 "Insurer Parties" means, collectively, the ASI Releasees, the Chubb Releasees, and the Motorists Releasees.

1.26 "Motorists" means Motorists Commercial Mutual Insurance Company.

1.27 "Motorists Releasees" means Motorists, those entities listed on Exhibit F hereto, and each of their direct and indirect parents, joint ventures, subsidiaiies, affiliates, officers, directors, employees, agents, representatives, members, and attorneys (including each of their respective predecessors, successors, assigns, heirs, administrators, or executors), all in their capacities as such and as they exist on the Execution Date.

1.28 "Motorists Settlement Amount" means the total sum of $6.2 million, which amount is in addition to payments to resolve the Hartle Claims.

1.29 "Parties" means each of the Insurers and the Receiver, collectively. "Party" means each Insurer and the Receiver, individually.

1.30 "Policies" means all policies of liability insurance, including the respective Policies identified in Exhibits A,B,and C to this Agreement, whether known or unknown, whether issued or allegedly issued, whether primary, umbrella,excess, or otherwise,

Exhibit B005 issued or allegedly issued prior to the Execution Date by any entity with the definition of Insurer Parties: (a) to any entity or person within the definition of Robinson or Grogan; or (b) under which any entity or person within the definition of Robinson Entities or Grogan Entities, or any of their respective successors or assigns, contends that Robinson, Grogan, or the Receiver are entitled to insurance, rights, benefits, or otherwise; providcd, however, that (x) any policy of insurance issued to any entity that is not a Robinson Entity or a Grogan Entity is a Policy only to the extent of coverage for the Robinson Entities or Grogan Entities, and (y) any policy ofinsurance issued to the Receiver is a Policy solely to the extent of coverage for Asbestos Claims and any other Claims arising from the operations, products, or activities of Robinson or Grogan.

1.31 "QSF" means a Qualified Settlement' Fund under section 468B of the Internal Revenue Code, to be established by the Receiver, subject to approval by the AC Court, pursuant to Paragraph 2(c) of the Receivership Order and decretal Paragraph 5 of the Arnended Receivership Order.

1.32 "Receive?' means Nancy Gibson, Esq., as the court-appointed receiver for Robinson and not individually, during such time that she is authorized to act in such capacity by order of the AC Court. In the event that the AC Court appoints a successor receiver, "Receiver" shall include such successor receiver during such time as he or she is acting in such capacity.

1.33 "Receivership Order" means the Order Creating Receivership for Robinson Insulation Cornpany entered on or about March 23, 2018 by the AC Court.

1.34 "Robinson" means Robinson Insulation Company, a dissolved corporation.

1.35 "Robinson Entities" means (a) Robinson and its employees, agents, or officers,(b) each of its present and future, direct and indirect, parents, joint ventures, subsidiaries, partners, and affiliates, solely in their capacities as such,(c) each of its past, direct and indirect, parents, joint ventures, subsidiaries, partners, and affiliates, but only if a person or entity described in (a) or (b) above has the power or authority to act on such entity's or person's behalf,(d) any person or entity asserting entitlement to insurance, rights, or benefits under any of the Policies, including any insured, additional insured, named insured, additional named insured, or protected person, but only if an entity or person described in (a) or (b) above has the power or authority to act on such entity or person's behalf,(e) the past, present, and future trustees, administrators, officers, directors, employees, agents, representatives, members,principals, and attorneys of any of the foregoing, but only in their capacities as such, and (f) the predecessors, successors, assigns, heirs, administrators, or executors of any of the foregoing, but solely in their capacities as such.

1.36 "Settlement Amount" means the total of the American States Settlement Amount, the Chubb Settlement Arnount, and the Motorists Settlement Amount. Each

Exhibit B006 Insurer is severally and not jointly liable for the amounts described as that Insurer's Settlement Amount.

1.37 "Settlement Approval Motion" means a motion, to be filed by the Receiver in the AC Court, seeking approval of the Agreement, establishment of a QSF, and entry of the Injunctions.

1.38 "Settlement Approval Order" ineans a judgment and order entered by the Receivership Court granting the Settlement Approval Motion, approving the Agreement, establishing the QSF,and entering the Injunctions. The Settlement Approval Order shall be substantially in the form attached as Exhibit H hereto,and in all respects shall be subject to the approval of the Insurers, such approval not to be unreasonably withheld or delayed.

1.39 "Trust" ineans a trust, created pursuant to a trust agreement approved by the AC Court,into which the Setdement Arnount held in the QSF will be deposited by the Receiver after the Trust Order has become a Final Order.

1.40 "Trust Order" means an order of the AC Court, on motion of the Receiver, approving establishment of the Trust. The Trust Order shall be in a form reasonably acceptable to all the Parties.

1.41 "Trustee means the person appointed by the AC Court to serve as trustee of the Trust, including any successor trustees.

2. Setdement Approval Motion 2.1 Within fifteen business days after the Execution Date, the Receiver shall file the Settlement Approval Motion.

2.2 The Receiver shall provide notice of this Agreement and the Settlement Approval Motion and the deadline for the filing of any objections to the Settlement Approval Motion, and the terms of the proposed Settlement Approval Order, to all known Asbestos Claimants in a form and manner deemed reasonable by the Parties, the goal being to provide comprehensive notice to all Claimants and other persons who might reasonably be expected to be affected by this Agreement so that they have an opportunity to appear and be heard by the AC Court before the Setdernent Approval Order is entered.

2.3 The Insurers may, at their own expense, cause notice of the Settlement Approval Motion,including the date, time, and place of the hearing on the Setdement Approval Motion and the deadline for the filing of any objections to the Setdement Approval Motion, to be published in The Western News, Kaliipell Dai# Interlake, Sanders Couno Ledger, Missoulian, Great Fall.r Tribune, Helena Independent Record,Billings Ga:zette, and/or USA Today no less than thirty days before the scheduled hearing.

-7- Exhibit B007 3. Payments.

3.1 Each Insurer shall pay its respective Settlement Amount by not later than sixty days after satisfaction ofall conditions precedent,including the conditions precedent set forth in Section 4.1 below. None of the Insurers shall be responsible for the payment of any other Insurer's Settlement Amount.

3.2 Each Insurer may pay its respective Settlement Amount by check(s) or wire transfer(s), pursuant to the instructions to be provided by the Receiver at least thirty days before payments of the Insurers' Settlement Amounts are due.

3.3 Each of the Insurers shall pay its respective Settlement Amountinto the QSF. The Receiver or the Trustee, as the case may be, shall not distribute any funds from the QSF except as authorized by the AC Court.

3.4 The Receiver represents, warrants, and agrees that (a) each Insurer's respective Settlement Arnount is the total amount that each Insurer will ever be obligated to pay under or arising out of the Policies to the Receiver, the Robinson Entities, the Grogan Entities, or any other perSOrl or entity and (b) the limits of the Policies shall be deemed and declared exhausted. Consistent with the provisions in Section 5 of this Agreement regarding releases, under no circumstances shall any of the Insurers ever be required to rnake any additional or further payrnents to any Asbestos Claimant under, or related to, Robinson, Grogan,the Receiver, or any other person or entity under the Policies. The Insurers are not obligated to pay any additional costs to any law firm in connection with legal services rendered to the Receiver or to reimburse the Receiver, Robinson, or Grogan, or any other person or entity at any time for the defense of Asbestos Claims, other than fees incurred by Gordon Rees Scully Mansukhani at the request of any of the Insurers in connection with the defense of Robinson or Grogan against Asbestos Claims or to catty out the terms of this Agreement and the Settlement Approval Order.

3.5 Each Party reserves to itself the right to allocate the respective Settlement Arnounts to such claims or policies as it deems appropriate, and no Party shall be bound by the allocation of any other Party.

4. Conditions Precedent To Insurers' Obligation To Pay Their Respective Settlement Amounts.

4.1 This Agreement will not be effective, and the Insurers shall have no obligation to pay their respective Settlement Amounts, until each of the following conditions precedent have been satisfied: 4.1.1 The Settlement Approval Order has been entered and has become a Final Order; 4.1.2 The AC Court has entered an order placing Grogan Robinson in receivership and appointing Nancy Gibson as Receiver for Grogan; -8- Exhibit B008 4.1.3 Counsel at McGarvey, Heberling, Sullivan & Lacey and Odegaard Kovacich Snipes who represent most,if not all, of the Asbestos Claimants must consent in writing to all of the terms of this Agreement.

4.2 If the AC Court, or any other court with jurisdiction, issues a Settlement Approval Order that does not contain all of the provisions described in Sections 8.1 and 8.2 below, this Agreement will, at the option of each Insurer, be voidable, except that the exercise of this option by any Insurer shall not render the Agreement void with . respect to any other Insurer. If any Insurer elects to void this Agreement, the rights, claims, and defenses of all Parties with respect to such electing Insurer are fully preserved as they were immediately prior to the Execution Date.

5. Releases.

5.1 By the Receiver, of the ASI Releasees. Effective immediately upon payment of the American States Settlement Amount,and with no further action being required, the Receiver, on behalf of herself, Robinson, Grogan, and any other entities for whom the Receiver has the power to act, hereby fully, finally, and completely release, settle, and discharge American States and the other ASI Releasees from any and all liability and Clairns, past, present, and future, asserted and unasserted, known or unknown, arising out of or relating to any Asbestos Claims, including (a) any obligation under the American States Policies,(b) Claims for bad faith, failure to act in good faith, interest, violation of any duty of good faith or fair dealing, violation of any unfair claims practices act or similar statute, regulation, or code,or any other similar type of alleged misconduct or omission, including all "Ricllef and "Dubarst-type medical and lost wages expense claims, and (c) any and all Claims which are, have been, or could have been asserted against American States in the Coverage Case.

5.2 By the Receiver, of the Chubb Releasees. Effective immediately upon payment of the Chubb Settlement Amount, and with no further action being required, the Receiver, on behalf of herself, Robinson, Grogan, and any other entities for whom the Receiver has the power to act, hereby fully, finally, and completely release, settle, and discharge ACE Fire, ACE P&C, Oakwood Insurance Company (successor by merger to Central National Insurance Company of Omaha, but only with respect to those policies issued through Cravens, Dargan & Company,Pacific Coast), and the other Chubb Releasees from any and all liability and Claims, past, present, and future, asserted and unasserted, known or unknown, arising out of or relating to any Asbestos Claims, including (a) any obligation under the Chubb Policies,(b) Claims for bad faith, failure to act in good faith, interest, violation of any duty of good faith or fair dealing, violation of any unfair claims practices act or similar statute, regulation, or code, or any other similar type of alleged misconduct or omission, including all "Ridlgi' and "DI/bre-type medical and lost wages expense claims, and (c) any and all Clairns which are, have been, or could have been asserted against ACE Fire or ACE P&C in the Coverage Case.

-9- Exhibit B009 5.3 By the Receiver, of the Motorists Releasees. Effective immediately upon payment of the Motorists Settlement Amount,and with no further action being required, the Receiver, on behalf of herself, Robinson, Grogan, and any other entities for whom the Receiver has the power to act, hereby fully, fmally, and completely release, settle, and discharge Motorists and the other Motorists Releasees from any and all liability and Claims, past, present, and future, asserted and unasserted, known or unknown, arising out of or relating to any Asbestos Claims, including (a) any obligation under the Motorists Policies, (b) Claims for bad faith, failure to act in good faith, interest, violation of any duty of good faith or fair dealing, violation of any unfair clairns practices act or similar statute, regulation, or code, or any other similar type of alleged misconduct or omission, including all "Rid/ey" and "Dubm_t-type medical and lost wages expense claims, and (c) any and all Claims which are, have been, or could have been asserted against Motorists in the Coverage Case.

5.4 By Each Insurer, of the Receiver, the Robinson Entities, and the Grogan Entities.

Effective immediately upon each Insurer's payment of its respective Settlement Amount, and with no further action being required, such Insurer hereby fully, fmally, and completely releases, settles, and discharges the Receiver, the Robinson Entities, and the Grogan Entities froin any and all liability and Clairns, past, present, and future, asserted and unasserted, known or unknown, arising out of or relating to (a) any Claims under the released Insurer's Policies or any associated agreements to pay any chargebacks, deductibles, premiums, retrospective premiums, and/or self-insurance assessments for Released Matters,(b) any Claims for payment of defense costs,(c) Claims for bad faith, failure to act in good faith, interest, violation of any duty of good faith or fair dealing, violation of any unfair claims practices act or similar statute, regulation, ot code, or any other similar type ofalleged misconduct or omission,and (d)any and all Claims which are, have been, or could have been asserted against the Receiver in the Coverage Case.

5.5 By Each Insurer, of the other Insurers. Effective immediately upon each Insurer's payment of its respective Settlement Amount, and with no further action being required, the other Insurers hereby fully, finally, and completely release, settle, and discharge the Insurer paying its respective Settlement Amount from any and all liability and Claims, past, present, and future, asserted and unasserted, known or unknown, arising out of or relating to (a) any obligation under the paying Insurer's respective Policies,(b) Claims for bad faith, failure to act in good faith, interest, violation of any duty of good faith or fair dealing, violation of any unfair claims practices act or similar statute, regulation, or code, or any other similar type of alleged misconduct or omission, including all Contribution Claims and all "Ridley" and "Dubraf-type medical and lost wages expense claims, and (c) any and all Claims which are, have been,or could have been asserted against the paying Insurer in the Coverage Case. Notwithstanding the foregoing, nothing in this Agreement releases any claims by one Insurer against another Insurer in its role as reinsurer or retrocessionaires.

- 10 - Exhibit 13010 5.6 The Releases described in Sections 5.1 through 5.5 above shall not release the Parties' rights to enforce the terms of this Agreement following entry of the Settlement Approval Order by the AC Court, all of which rights shall be expressly reserved by the Parties.

5.7 Immediately upon payment by each Insurer of its respective Settlement Amount, and with no further action being required, such paying Insurer shall be deemed to have bought back all ofits respective Policies free and clear ofinterests, which shall extinguish all obligations that such Insurer has, had, or ever could have to the Receiver, the Robinson Entities, the Grogan Entities, or any other person or entity for insurance coverage under its respective Policies.

5.8 Each Insurer agrees to not pursue any Contribution Claim against any other Insurer or against other insurers of Robinson or Grogan;provided, however,that(a) if an insurer other than one of the Insurers pursues such claims against any Insurer, that Insurer may defend against such claim and may also pursue against such insurer all Contribution Claims such Insurer has against the insurer pursuing such claims; and (b) each Insurer shall retain all rights to pursue reinsurance recoveries with respect to its payment of its respective Setdernent Arnount.

5.9 The Parties expressly represent and warrant that they are familiar with California Civil Code § 1542 and that the effect and irnport of that provision has been fully explained and that, after consultation with their attorneys, the Parties expressly waive the provisions of California Civil Code § 1542, and other state and federal statutes of similar effect. California Civil Code § 1542 provides: A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT,IF KNOWN BY HIM OR HER WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.

5.10 No portion of the Settlement Amount shall be disbursed to an Asbestos Claimant unless that Asbestos Claimant first executes and delivers to the Receiver (or the Trustee, if the Trust has been established), a written release of all Clairns of such Asbestos Claimant arising under or related to the Policies against (a) the Insurer Parties and (b) the Receiver, the Trustee and the Trust, the Robinson Entities, and the Grogan Entities. The Receiver and the Insurers shall agree to the form of the release, or,in the absence of agreement, the release shall be in a form which wholly releases the Insurer Parties and is approved by the AC Court.

6. Cessation of Litigation in the AC Court.

6.1 Each Insurer agrees that, within five business days after being advised by the Receiver that the Settlement Approval Order has becorne a Final Order, it will (a) withdraw any and all motions, briefs, pleadings, and objections it has made in the

Exhibit B011 AC Court and any request for relief from ot against the Receiver will be deemed withdrawn, and (b) not pursue any Claims against the Receiver in the AC Court or that are being released pursuant to this Agreement.

6.2 From the Execution Date until the date the Settlement Approval Order has become a Final Order, each Party shall file no new motions, briefs, pleadings, claims, objections, or other requests for relief against any other Party in the AC Court.

6.3 The Insurers and the Receiver shall bear their own fees and expenses in connection with any proceedings in the AC Court.

7. Cessation of Litigation in the Coverage Case.

7.1 The Parties agree that, within five business days after being advised by the Receiver that the Settleinent Approval Order has become a Final Order, they will file in the Coverage Case a stipulation of dismissal with prejudice of all Claims (including the complaint, all counterclaims, and all cross-clairns) that each Party has asserted against any other Party, with all Parties to bear their own fees and expenses. The stipulation shall be substantially in the form set forth as Exhibit G hereto.

7.2 Froin the Execution Date until the date the Settlement Approval Order has becorne a Final Order, the Parties agree that they shall file no new motions, briefs, pleadings, objections, or other requests for relief against each other in the Coverage Case and will provide open extensions of time for each other, as may be necessaiy to avoid unnecessary litigation expenses.

7.3 The Insurers and the Receiver shall bear their own fees and expenses in connection with any proceedings in the Coverage Case.

8. Injunction Bar Order Judgment Reduction, and Indemnification.

8.1 The Settlement Approval Order must include the entry of an injunction barring all Claims against the Insurers released by the Receiver pursuant to Sections 5.1, 5.2, and 5.3 of this Agreement. The injunction shall state, in substance, as follows: "Pursuant to the Court's inherent equitable authority,(a) all Persons who hold or assert, or may in the future hold or assert, any Claim against Robinson, Grogan, or the Receiver arising in connection with the activities covered by the Policies, or in connection with the activities of Robinson or Grogan giving rise to the Claims that have been made or that could be made under the Policies, and (b) all Persons who may claim to be an insured, additional insured, or otherwise entided to any benefit under the Policies, are permanently stayed, barred, restrained, and enjoined from asserting any such Claim or right to entitlement,from comrnencing a proceeding, or taking any other action against ACE Fire Underwriters Insurance Company, ACE Property & Casualty Insurance Company, Oakwood Insurance Company (successor by merger to Central National Insurance Company of Omaha, but only with respect to those policies issued through Cravens,Dargan & Company,Pacific - 12 - Exhibit B012 Coast), Motorists Commercial Mutual Insurance Company,or American States Insurance Cornpany (collectively, the 'Settling Insurers') or the persons and entities defined in the Agreement as 'Insurer Parties' for the purpose of obtaining any recoveiy or other relief from the Settling Insurers or the Insurer Parties based on, under, arising out of, related or attributable to, and/or in connection with the Policies."

8.2 The Settlement Approval Order must also include a contribution bar order stating, in substance, as follows: "All claims for contribution, allocation, subrogation, and equitable indemnity, or similar claims, against any of the Settling Insurers (collectively,'Contribution Claims'), whether by parties appearing before the Asbestos Clairns Court or not, are hereby BARRED pursuant to the Coutes inherent equitable authority. All Contribution Claims against any of the Settling Insurers shall be channeled to the QSF established to hold the Settlement Amounts paid by the Settling Insurers or to any Trust to Which the funds in the QSF are transferred following an order by this Court authorizing such transfer."

8.3 In the event that any other insurer of Robinson or Grogan or any other Person obtains a judicial determination or binding arbitration award that it is entitled to obtain a sum certain from any of the Insurers as a result of a Contribution Claim against any Insurer for the alleged share or equitable share of such Insurer for defense costs or indemnity costs relating to Claims against the Receiver, Robinson, or Grogan, the Receiver or the Trustee, as the case may be, shall voluntarily reduce such judgment(s) or Claim(s) against, or settleinent with, such other insurer(s) or persons to the extent necessary to eliminate such Contribution Claims against the Insurer. To ensure that such a reduction is accomplished, each Insurer shall be entitled to assert this section as a coinplete defense to any action against it for any such portion of the judgrnent or Claim and shall be entitled to have the court or appropriate tribunal issue such orders as are necessary to effectuate the reduction to protect the Insurer from any liability for the judgment or Claim, the goal being to ensure that the Insurer does not pay anything more than its respective Settlement Amount with respect to matters encoinpassed within the releases set forth in Sections 5.1 through 5.3 of this Agreement.

8.4 The Receiver or the Trustee, as the case rnay be, will attempt to minimize the possibility of Contribution Claims being made against any of the Insurers by any person or entity with respect to insurance coverage for Clairns against Robinson or Grogan by using reasonable best efforts to obtain from each other person or entity settling with the Receiver an agreement to waive or release any and all Contribution Claims it may have against the Insurers and not to otherwise proceed against the Insurers 8.5 The Receiver shall indemnify each of the Insurers against all Claims filed by other insurers, up to the amount of each Insurer's respective Settlement Amount,to the extent necessary given the judgment reduction provision set forth in Section 8.3 of this Agreement. The Receiver may use funds from the QSF for purposes of

- 13 - Exhibit B013 fulfilling her indemnification obligations. The Receiver's indemnification obligations shall be assumed by the Trustee upon the establishment of the Trust, and the Trustee may use funds from the Trust for purposes of fulfilling such indemnification obligations.

8.6 The Receiver or the Trustee, as the case may be, shall cooperate with the Insurers in any litigation against the Insurers asserting any Contribution Claims with respect to any liability under the Policies that is released under this Agreement. Without limiting the foregoing, the Receiver or the Trustee, as the case may be,shall support arguments rnade by the Insurers that their obligations with respect to such claims have been fully released, satisfied, and extinguished by this settlement.

9. Confidentiality 9.1 The Parties may notify the AC Court of the fact of their settlement-in-principle, but shall otherwise maintain the terms of their settlement-in-principle as strictly confidential with respect to third parties until such time as the Receiver files the Settlement Approval Motion. The Parties agree that the Receiver may file this Agreement in the public record with the AC Court in connection with the Settlement Approval Motion.

9.2 Nothing herein shall limit the Insurers' right, prior to or after filing of the Settlement Approval Motion, to fully and completely advise their reinsurers and retrocessionaires as to all matters related to the setdernent-in-principle, including but not limited to the terms and conditions of this Agreement and any related documents.

9.3 Notwithstanding any other provision in this Agreernent, the Parties agree that this Agreement and any related documents, may be disclosed to counsel at McGarvey, Heberling, Sullivan & Lacey and Odegaard Kovacich Snipes who represent most,if not all, of the Asbestos Claimants, for purposes of seeking and obtaining their consent, provided that prior to any such disclosure, such Asbestos Claimants' counsel agree in writing to maintain any information relating to the setdement-in-principle as strictly confidential.

10. Bankruptcy 10.1 In the event that Robinson and/or Grogan becomes the subject of any proceedings pursuant to the United States Bankruptcy Code (a "Restructuring Filing') before all of the Insurers have paid their Setdement Amounts, the Parties agree and acknowledge that: 10.1.1 This Agreement, having been negotiated at arm's length in settlement of bona fide disputes and supported by adequate consideration, is not a preference under section 547 of the Bankruptcy Code, a fraudulent conveyance under sections 546 or 548 of the Bankruptcy Code, or

- 14 - Exhibit B014 avoidable under any other applicable federal bankruptcy or non-bankruptcy law.

10.1.2 The Parties will cooperate to preserve the validity, finality, and enforceability of this Agreement. The Receiver, the Trustee, Robinson,and Grogan shall use their respective best efforts to oppose any and all efforts to challenge this Agreement under any provision of the Bankruptcy Code or state law.

10.1.3 In any Restructuring Filing where the Receiver, the Trustee, Robinson, or Grogan seeks to discharge Asbestos Claims, the Receiver, the Trustee, Robinson, and/or Grogan shall request and use their best efforts to obtain, from the Bankruptcy Court and/or the District Court, a permanent injunction pursuant to 11 U.S.C. §§ 524(g) and/or 105(a) that enjoins all persons from commencing or continuing any action, proceeding or Claim, including any Asbestos Claim, against the Insurers, directly or indirectly, to collect, recover, or receive payments, satisfaction, or recovery of any kind under, relating to, or arising out of Asbestos Claims and/or the Policies.

10.1.4 The releases contained herein are fully effective according to their terms and this Agreernent is not an executory contract.

11. Assignment and Authority.

The Receiver and the Insurers each separately represent and warrant that they have not waived, released, assigned, or transferred any right, tide, or interest in the Policies 11.2 Each Party represents and warrants that the individual executing this Agreement on its behalf has the authority to do so and to bind that Party to the obligations set forth herein. Each Party represents and warrants that it has authority to execute this Agreernent as its binding and legal obligation. Each Party represents and warrants that it has read this Agreement in full and that the person signing this Agreement on its behalfis authorized by those they purport to represent to execute this Agreernent and to bind that Party to the obligations set forth in this Agreement in full.

12. Non-Prejudice and Construction of Agreernent.

12.1 This Agreement is a negotiated compromise of disputed issues among the Parties, bargained for and entered into in good faith and as the result of arm's-length negotiations, and at all times material the Parties have been represented by counsel of their own choosing concerning the rights affected by this Agreement, the form and content ofit, and the advisability of executing it. This Agreement shall not be construed as an adrnission relating to or in any way connected with the Policies or the Claims or defenses asserted in the Coverage Case, nor shall this Agreement or any provision hereof be construed as a waiver, modification, or retraction of the - 15 - Exhibit B015 positions of the Parties with respect to the interpretation and application of the Policies. No communications or statements made during the negotiations of this Agreement shall be discoverable or admissible in any dispute between the Parties to enforce the terms of the Agreement.

12.2 This Agreement is the product of informed negotiations and involves compromises of the Parties' previously stated legal positions. Accordingly, this Agreement does not reflect the Parties' views as to their rights and obligations with respect to rnatters or entities outsidc the scope of this Agreement. The Parties specifically disavow any intention to create rights in third parties under or in relation to this Agreement except as expressly set forth herein.

12.3 The Parties have participated jointly in the negotiation, drafting, and preparation of this Agreement, and agree that, in the event an ambiguity or question of intent or interpretation arises related to this Agreement, this Agreeinent shall be construed as if drafted jointly by the Parties hereto. Accordingly, no presumption or burden of proof shall arise favoring or disfavoring any Party by virtue of the authorship of any provisions of this Agreement or by virtue of any Party's status as an insurance company.

12.4 Subject to Section 4.2 of this Agreement, in the event that any portion of this Agreement should for any reason become or be found by a court or other tribunal to be null, void,illegal, invalid, or otherwise unenforceable, the remaining portions of this Agreement shall remain in full force and effect and continue to be binding on the Parties provided that each Party continues to receive substantially the benefit of its bargain hereunder 12.5 This Agreernent is not, nor shall it be construed as, an insurance policy.

13. Governing Law.

13.1 This Agreement shall be governed by and shall be construed in accordance with the law of the State of Montana without regard to its conflict of law principles.

14. Notices.

14.1 Unless another person is designated,in writing, for receipt of notices hereunder, all notices to the respective Parties shall be sent to the following persons: American States: Terri Yahia Assistant Vice President and Associate General Counsel Resolute Management Inc. High Street, 10th Floor Boston, Massachusetts 02110 tvahiaarcsolutemgmt.com

- 16 - Exhibit B016 with a copy to: Michael J. Cohen,Esq.

Meissner Tierney Fisher & Nichols S.C. East Kilbourn Avenue, 19th Floor Milwaukee, Wisconsin 53202 E-mail: [email protected] Chubb: Tarnika Jones Assistant Vice President — Claims Brandywine Group of Insurance & Reinsurance Companies Walnut Street — WB11E Philadelphia, PA 19106 tarnika.jonesabrandywineholdings.corn with a copy to: Mark D. Plevin Crowell & Moring LLP Three Embarcadero Center, 26th Floor San Francisco, CA 94111 E-mail: [email protected] Motorists: H. Toney Stroud, Esq.

Encova Insurance P.O. Box 3922 Charleston, West Virginia 25339 E-mail: [email protected] with a copy to: Marc Weintraub, Esq.

Bailey & Glasser LLP Central Avenue Suite 1500 St. Petersburg, Florida 33701 E-mail: [email protected] Receiver: Nancy Gibson, Esq.

Gibson Law Offices PLLC 4110 Weeping Willow Drive Missoula, Montana 59803 with a copy to: Allan McGarvey, Esq.

McGarvey Heberling Sullivan & Lacey First Avenue East Kalispell, Montana 59901 E-mail: amcgarvevO,rucgarvevlaw.corn

14,2 Any Party may change the address at which communications are to be delivered to - 17 - Exhibit B017 it by giving notice to the others, in the rnanner provided in this Section 14.

15. Medicare and Other Third-Party Claims.

15.1 The Parties agree that, given the buy-back nature of this settlement, to the extent any obligation under 42 USC § 1395y, etseq., commonly referred to as the Medicare, Medicaid, and SCHIP Extension Act of 2007, or any other similar statute or regulation, and any related rules, regulations, or guidance issued in connection therewith or relating thereto (including 42 CFR §§ 411, et seq.), with respect to any Asbestos Claims (collectively, the "MSP") is triggered in connection with the Settlernent Amount, the Receiver agrees that she is the Responsible Reporting Entity ("RRE").

15.1.1 The Patties agree that all duties and obligations of the Receiver under Section 15 of this Agreement may be assigned to and assurned by the Trustee pursuant to the Trust Order after (a) the Trust Order has become a Final Order,(b) the Trustee has agreed in a writing sent to all Parties that he or she will assurne all duties, obligations, and agreements of the Receiver under Section 15 of this Agreernent, and (c) the Settlement Arnount has been transferred by the Receiver frorn the QSF to the Trust.

15.2 The Parties further agree that the Insurers are not subject to any reporting requirements or obligations under the MSP. The Parties nevertheless agree to the reporting provisions set forth in Sections 15.3 through 15.12 of this Agreement to ensure full compliance with the MSP.

15.3 The Receiver and/or the Trust, as the case may be,is the RRE and shall assume the obligations of an RRE for all Claims paid with the proceeds of the Settlement Amount.

15.4 The RRE shall, at its sole expense, timely submit all reports that are required by a Responsible Reporting Entity under the reporting provisions of Section III of the Medicare, Medicaid,and SCHIP Extension Act of2007(P.L. 110-173) or any other similar statute or regulation("MMSEA") on account of Asbestos Claims paid by the RRE. The RRE or its RRE Agent shall follow all applicable guidance published by the Centers for Medicare & Medicaid Services of the United States Department of Health and Human Services and/or any other agent or successor entity charged with responsibility for monitoring, assessing or receiving reports under MMSEA (collectively,"CMS")to determine whether or not and,if so, how to report to CMS pursuant to MMSEA.

15.5 The RRE Agent shall provide a written notification to the Insurers within ten business days following receipt of any notification from CMS that any report by the RRE was rejected or otherwise identified as noncompliant by CMS,along with the basis for such rejection or noncompliance.

- 18 - Exhibit B018 15.5.1 With respect to any reports rejected or otherwise identified as noncompliant by CMS,the RRE Agent shall, at the request of any of the Insurers, promptly provide copies of the original reports subrnitted to CMS,as well as any response received from CMS with respect to such reports. The RRE Agent shall reasonably undertake to remedy any issues of noncompliance that CMS identifies and to resubmit such reports to CMS. Upon request by any of the Insurers, the RRE Agent shall provide the Insurers with copies of such resubmissions. With respect to copies of original reports and resubmissions provided under this Section 15.5.1, the RRE Agent may redact from such copies the names, social security numbers other than the last four digits, health insurance claim nurnbers, taxpayer identification numbers, employer identification nurnbers, mailing addresses, telephone numbers, and dates of birth of the injured parties, claimants, guardians, conservators, and/or other personal representatives, as applicable.

15.5.2. All documentation that the RRE Agent relies upon in making a determination that a payrnent does not have to be reported to CMS shall be maintained for a minimum of six years following such determination.

15.6 The Receiver and/or the Trustee, as the case may be, is not required by this Agreernent to rnake report any that is not required by MMSEA.

15.7 The Parties recognize that, upon the cornpletion of her responsibilities, the AC Court may discharge the Receiver from any further obligations with respect to Robinson or Grogan. Likewise, the Parties recognize that once the Trust's purposes are completed, or upon the appointment of a successor trustee, the AC Court may discharge the Trustee from any further obligations with respect to the Trust. Nothing in this Agreement willimpose any duty on any individual,including Nancy Gibson,in any individual capacity or constitute a basis to extend Ms. Gibson's role as Receiver. To ensure the preservation of any information that the Insurers may need in the event CMS concludes that reporting done by the RRE in accordance with the above provisions within this Section 15 is or may be deficient in any way, and has not been corrected to the satisfaction of CMS in a timely manner, or if CMS communicates to the RRE or the Insurers a concern with respect to the sufficiency or timeliness of such reporting or non-reporting, to satisfy any reporting obligation under any MSP,within thirty calendar days after the Execution Date, any of the Insurers shall provide to the Receiver a list of the information that such Insurer designates as likely to be necessary for that Insurer to respond to any notice by CMS that the RRE's reporting was deficient. Subject to AC Court approval, the Receiver and/or the Trustee, as the case may be, shall collect that inforrnation from Asbestos Claimants as part of any claim submission procedures. Following the end of the Trustees responsibilities, the Insurers, at their own expense, shall be entitled to maintain and access this information exclusively to address any claim of non-cornpliance by the RRE or the RRE Agent with MSP reporting obligations, subject to appropriate confidentiality standards - 19 - Exhibit B019 approved by the AC Court. At the Insurers' reasonable request, the Receiver and/or the Trustee, as the case may be,will meet and confer with the Insurers prior to terminating her duties to ensure a transition of any information per this paragraph.

15.8 The RRE and/or any RRE Agent shall indernnify and hold the Insurers harmless from any and all fines, penalties, claims, demands, liens, subrogated interests, and causes of action of any nature or character that rnay in the future be asserted by Medicare and/or persons or entities acting on behalf of Medicare in respect of Medicare claims reporting and payment obligations in connection with the Asbestos Claims,including any obligations owing or potentially owing under MMSEA or 42 U.S.C. § 1395y(b) or any related rules, regulations, or guidance issued in connection therewith, or relating thereto, and any claims arising from or related to the RRE Agenes obligations under this Section 15.

15.9 The Receiver and/or the Trustee, as the case may be, shall obtain, prior to rernittance of funds to Asbestos Claimants' counsel or the claimant, if pro se, in respect of any Asbestos Claim, a certification from the claimant to be paid that said claimant has or will provide for the payment and/or resolution of any obligations owing or potentially owing under 42 U.S.C. 5 1395y(b), or any related rules, regulations, or guidance, in connection with, or relating to, such Asbestos Claim.

The Receiver and/or the Trustee, as the case rnay be,shall provide a certification of his or her compliance with this Section to the Insurers upon the Insurers' request, but not more often than quarterly. The Receiver and/or the Trustee, as the case may be, shall permit reasonable audits by the Insurers, no more often than quarterly, to confirm compliance with this Section 15. The Insurers shall keep any information and docurnents received from the Receiver or the Trustee pursuant to this Section 16 confidential and shall not use such information for any purpose other than meeting obligations under this Section 15.

15.10 Compliance with the requirements of Sections 15.1 through 15.9 of this Agreement shall be a material obligation of the Receiver and/or the Trustee in favor of the Insurers.

15.11 The Patties agree that Sections 15.2 through 15.10 of this Agreernent are intended to be purely prophylactic in nature, and shall not constitute or be construed as an admission that the Insurers are in fact an "applicable plan" for MSP reporting purposes, or that they have any legal obligation to report any actions undertaken by the Receiver, the Trustee, or other payor of Asbestos Claims under the MSP or any other statute or regulation.

15.12 Assets held by the Receiver, the Trustee, or other entity responsible for paying Asbestos Claims rnay also be used for payment ofindemnity and expenses relating to reimbursing conditional payments made pursuant to the MSP to applicable Medicare beneficiaries. Except for the payment of amounts payable under this Agreement, no Party shall be obligated to make any payments for this purpose.

- 20 - Exhibit B020 16. Dispute Resolution.

16.1 If any dispute should arise concerning the terms, meaning, ot implementation of this Agreement, the Parties agree to use their best efforts to reach a prompt resolution of such dispute. If the Parties are unable to reach an agreement, they shall proceed to mediation within thirty days after either Party delivers a written notice of request for mediation. If the mediation is unsuccessful, either Party may commence a legal action in an appropriate forum, but no Party may initiate litigation until after a mediation has commenced and the mediator has determined that the Parties' mediation has reached an impasse.

17. Miscellaneous Provisions.

17.1 This Agreernent shall be binding upon, and inure to the benefit of, the Parties hereto and to their respective successors.

17.2 This Agreernent is not intended to benefit any person or entity other than the Parties, the ASI Releasees, the Chubb Releasees, and the Motorists Releasees, except as expressly stated herein. Other than as expressly provided herein, this Agreement is not intended to bind any non-Party to any of the compromises, stipulations or agreements rnade herein.

17.3 Each Party warrants and represents that neither it nor any ofits predecessors, affiliates, agencies, departments, organizations, branches, commissions, or divisions has previously assigned or transferred or executed an agreement purporting to assign or transfer (a) any Claim released or waived herein or (b) any rights or obligations under this Agreement.

17.4 This Agreement is not assignable by any Party and any purported assignment shall be void without the express written agreement of the other Parties, except an assigninent by operation of Law which shall be effective.

17.5 In the event that any non-Party to this Agreement takes any action to try to invalidate this Agreement in whole or in part, the Parties will fully cooperate to oppose such action.

17.6 The titles of the sections in this Agreement are for convenience of reference only and are not intended to be part of, or to affect the meaning, construction, or interpretation of, this Agreement.

17.7 This Agreement contains the entire agreement among the Parties with respect to the issues addressed herein. Except as explicitly set forth in this Agreement, there are no representations, warranties, promises, or inducements, whether oral, written, expressed, or implied, that in any way affect or condition the validity of this Agreement or alter or supplement its terms. Any statements, promises, or

- 21 - Exhibit B021 inducements made by either Party or any agent of either Party that are not contained in this Agreement shall not be valid or binding.

17.8 This Agreement may be executed in several counterparts, each of which shall be deerned an original, which together shall constitute one and the same instrument and agreement. Each counterpart rnay be delivered by electronic transrnission (by facsimile or e-mail as a .pdf attachment), and a faxed or e-mailed signature shall be binding with the sarne force and effect as original signatures.

17.9 Each of the Parties represents and warrants that it is authorized to enter into this Agreement; that the execution and delivery of this Agreernent and the consummation of this ttansaction will not conflict with or result in any violation or default under any provision of its articles of incorporation, charter, by-laws, or partnership agreement or of any decree, statute, law, ordinance, rule, or regulation applicable to it; and that no further consent, approval, order, authorization, or filing with any governmental authority is required in connection with the execution and delivery of this Agreement or the consummation of the transactions described in this Agreement.

17.10 Each signatory of this Agreement declares, warrants, and represents that he or she has the general and specific authority to enter into and to execute this Agreernent.

This Agreement may be executed on behalf of any Party by the Party's attorney with the same force and effect as if the Party had personally executed the Agreement.

17.11 Each Party understands, acknowledges, and agrees that if any fact or legal premise now believed to be true is found hereafter to be other than, or different from, that which is now believed, each expressly assumes the risk of such difference in fact or legal premise and agrees that this Agreement shall and will remain effective notwithstanding any such difference.

17.12 This Agreement shall not be modified, altered, or discharged, nor any of its provisions waived, except by a writing signed by each of the Parties hereto. A failure to enforce any provision of this Agreernent in a particular instance shall not be construed as a waiver of any such provision or any other provision of this Agreement.

IN WITNESS WHEREOF,the Parties have executed this Agreement by their duly authorized representatives.

Nancy Gibson, Receiver

By: Dated: May , 2020 Nancy Gibson Receiver of Robinson Insulation Company

- 22 - Exhibit B022 American States Insurance Company, by its authorized claims representative, Resolute Management, Inc.

By: Dated: May ,2020 Melissa Arkwell Senior Vice President Direct Claims

ACE Fire Underwriters Insurance Company and ACE Property & Casualty Insurance Company

By: Dated: May , 2020 Shelby L. Mattioli Senior Vice President, Brandywine Direct Claims

Motorists Commercial Mutual Insurance Cornpany

By: Dated: May ,2020 William J. McGee,Jr. Senior Vice President, Chief Risk Officer Encova Insurance (foimerly Motorists Insurance Group and BrickStreet Insurance)

- 23 - Exhibit B023 EXHIBIT A — KNOWN AMERICAN STATES POLICY ISSUED TO ROBINSON ISSUING INSURER POLICY POLICY PERIOD American States Insurance AP 079-570-1 5/28/85-5/28/86 Cornpany

A-1 Exhibit B024 EXHIBIT B — KNOWN CHUBB POLICIES ISSUED TO ROBINSON ISSUING INSURER POLICY POLICY PERIOD Central National Insurance CNU 035051 (umbrella) 4/11/80 to 2/11/81 Company of Ornaha Central National Insurance CNU 004833 (umbrella) 2/11/81 to 2/11/84 Company of Omaha (cancelled effective 2/11/83) Aetna Fire WDP DO 7818105 2/10/83 to 2/10/84 (primary) Aetna Ins. Co. UL 850829 2/10/83 to 2/10/84 (umbrella) Aetna Fire RWP DO 7818105 2/10/84 to 2/10/85 (primaiy)

Exhibit B025 B-1 EXHIBIT C — KNOWN OR ALLEGED MOTORISTS POLICIES ISSUED OR ALLEGEDLY ISSUED BY AMERICAN HARDWARE MUTUAL INSURANCE COMPANY TO ROBINSON Primary Policies POLICY POLICY PERIOD MOTORISTS'DISPUTE 1-2282065 12/20/1971-12/20/1974 Interpretation of aggregate limit of liability; Motorists' position is it is a policy period aggregate 2-2282514 02/10/1972-02/10/1975 Interpretation of aggregate limit of liability; Motorists' position is it is a policy period aggregate 5-2282514 02/10/1975-02/10/1978 Existence of this policy and extent of coverage due to (i) lack of information on coverage and policy terms, and (ii) lack of information regarding claimant exposure during the period 4-2282514 02/10/1978-02/10/1979 Existence of this policy and extent of coverage due to (i) lack of information on coverage and policy terms, and (ii) lack of information regarding claimant exposure during the period 8-2282514 02/10/1978-02/10/1979 Existence of this policy and extent of coverage due to (i) lack of information on coverage and policy terms, and (ii) lack of information regarding clairnant exposure during the period 9-2282514 02/10/1979-02/10/1980 Existence of this policy and extent of coverage due to (i) lack of information on coverage and policy terrns, and (ii) lack of information regarding claimant exposure during the period 5-5573921 03/15/1985-05/10/1985 Existence of this policy and extent of coverage due to (i) lack of information on coverage and policy terms, and (ii) lack of information regarding claimant exposure during the period Unknown 1973-1978 Existence of this policy and extent of coverage due to (i) lack of inforrnation on coverage and policy terrns, and (ii) lack of inforination regarding claimant exposure during the period 5-5572332 Unknown Existence of this policy and extent of coverage due to (i) lack of inforrnation on coverage and policy terrns, and (ii) lack of information regarding claimant exposure during the period

Exhibit B026 C-1 Umbrella Policies POLICY POLICY PERIOD MOTORISTS'DISPUTE 1-2140381 12/20/1971- Existence of this policy and extent of coverage due to (i) 02/10/1972 lack ofinformation on coverage and policy terms, and (ii) lack ofinformation regarding claimant exposure during the period 2-2140381 02/10/1972- Existence of this policy and extent of coverage due to (i) 02/10/1973 lack of inforrnation on coverage and policy terms, and (ii) lack of inforrnation regarding claimant exposure during the period 3-2140381 02/10/1973- Existence of this policy and extent of coverage due to (i) 02/10/1974 lack of inforrnation on coverage and policy terrns, and (ii) lack ofinformation regarding claimant exposure during the period 4-2140381 12/26/1974- Existence of this policy and extent of coverage due to (i) 12/26/1977 lack ofinformation on coverage and policy terms, and (ii) lack of inforrnation regarding claimant exposure during the period 7-2140381 12/26/1977- Existence of this policy and extent of coverage due to (i) 12/26/1978 lack ofinformation on coverage and policy terms, and (ii) lack ofinformation regarding claimant exposure during the period 8-2142864 12/26/1978- Existence of this policy and extent of coverage due to (i) 12/26/1979 lack of information on coverage and policy terrns, and (ii) lack of information regarding claimant exposure during the period 9-2142864 12/26/1979- Existence of this policy and extent of coverage due to (i) 4/11/1980 lack ofinformation on coverage and policy terms, and (ii) lack of inforrnation regarding claimant exposure during the period Unknown 3/15/1985- Existence of this policy and extent of coverage due to (i) 5/10/1985 lack of information on coverage and policy terms, and (ii) lack ofinformation regarding claimant exposure during the period

Except for the policies listed above, Motorists disputes the existence of any other policies of liability insurance, whether known or unknown, whether issued or allegedly issued, whether prirnary, umbrella, excess, or otherwise,issued or allegedly issued prior to the Execution Date by any entity with the defmition of Motorists Releasees:(a) to any entity or person within the definition of Robinson or Grogan; or (b) under which any entity or person within the definition of Robinson Entities or Grogan Entities, or any of their respective successors or assigns, contends that Robinson, Grogan, or the Receiver are entitled to insurance, rights, benefits, or otherwise.

Exhibit B027 C-2 EXHIBIT D — AMERICAN STATES ENTITIES TO BE RELEASED America First Insurance Company America First Lloyd's Insurance Company American Econorny Insurance Company American Fire and Casualty Company American States Insurance Company American States Insurance Cornpany of Texas American States Lloyds Insurance Company American States Preferred Insurance Company Colorado Casualty Insurance Company Consolidated Insurance Company Employers Insurance Company of Wausau Excelsior Insurance Company The First Liberty Insurance Corporation First National Insurance Company of America General Insurance Company of America Golden Eagle Insurance Corporation Hawkeye-Security Insurance Cornpany Indiana Insurance Cornpany Insurance Company of Illinois Ironshore Indemnity Inc. Ironshore Specialty Insurance Cornpany Liberty County Mutual Insurance Company Liberty Insurance Corporation Liberty Insurance Underwriters Inc. Liberty Lloyds of Texas Insurance Company Liberty Mutual Fire Insurance Company Liberty Mutual Insurance Company Liberty Mutual Mid-Atlantic Insurance Cornpany Liberty Mutual Personal Insurance Company Liberty Northwest Insurance Corporation Liberty Personal Insurance Cornpany Liberty Surplus Insurance Corporation LM General Insurance Cornpany LM Insurance Corporation LM Property and Casualty Insurance Mid-American Fire & Casualty Company Company The Midwestern Indemnity Cornpany Montgornery Mutual Insurance Company National Insurance Association The Netherlands Insurance Company North Pacific Insurance Company The Ohio Casualty Insurance Cornpany

Exhibit B028 D-1 Ohio Security Insurance Cornpany Oregon Automobile Insurance Cornpany Peerless Indemnity Insurance Cornpany Peerless Insurance Company Safeco Insurance Cornpany of Arnerica Safeco Insurance Company of Illinois Safeco Insurancc Cornpany of Indiana Safeco Insurance Company of Oregon Safeco Lloyds Insurance Cornpany Safeco National Insurance Cornpany Safeco Surplus Lines Insurance Cornpany San Diego Insurance Cornpany Wausau Business Insurance Company Wausau Underwriters Insurance Company Wausau General Insurance Cornpany West American Insurance Company

Exhibit B029 D-2 EXHIBIT E — CHUBB ENTITIES TO BE RELEASED ACE American Insurance Company, formerly known as CIGNA Insurance Company formerly known as INA Underwriters, formerly known as Allied Insurance Company ACE American Insurance Cornpany,successor to ACE American Lloyds Insurance Cornpany fka ACE American Insurance Company of Texas fka American Lloyds Insurance Cornpany ACE American Insurance Company,successor to ACE Arnerican Lloyds Insurance Company fka ACE American Insurance Company of Texas fka American Lloyds Insurance Company ACE American Reinsurance Company, formerly known as CIGNA Reinsurance Company, forrnerly known as INA Reinsurance Company ACE Employers Insurance Company, formerly known as CIGNA Employers Insurance Company, formerly known as INA Employers Insurance Company ACE Fire Underwriters Insurance Company, formerly known as CIGNA Fire Underwriters Insurance Cornpany, formerly known as Aetna Fire Underwriters Insurance Company Westchester Fire Insurance Company, successor to ACE Indemnity Insurance Company, formerly known as CIGNA Indernnity Insurance Cornpany ACE American Insurance Company, successor to ACE Insurance Company of Illinois, formerly known as CIGNA Insurance Company of Illinois, formerly known as INA Insurance Company of Illinois ACE Arnerican Insurance Company,successor to ACE Insurance Cornpany of Ohio,formerly known as CIGNA Insurance Cornpany of Ohio,formerly known as Aetna Insurance Company of Ohio Chubb Insurance Company of Puerto Rico, formally known as ACE Insurance Company of Puerto Rico, formerly known as CIGNA Insurance Company of Puerto Rico,formerly known as Aetna Insurance Company of Puerto Rico ACE American Insurance Cornpany, successor to ACE Insurance Company of Texas, formerly known as CIGNA Insurance Company of Texas, formerly known as Aetna Insurance Company ' of Texas ACE Insurance Company of the Midwest, successor to CIGNA Insurance Company of the Midwest, formerly known as Aetna Insurance Company of the Midwest ACE Property & Casualty Insurance Company,formerly known as CIGNA Property and Casualty Cornpany, successor to Aetna Insurance Cornpany

Exhibit B030 E-1 ACE Fire Underwriters Insurance Company,formerly known as CIGNA Fire Underwriters Insurance Company, formerly known as Aetna Fire Underwriters Insurance Company ACE Property & Casualty Insurance Company,formerly known as CIGNA Property and Casualty Company, successor to Aetna Insurance Company ACE American Insurance Coinpany, successor to ACE Insurance Coinpany of Ohio, formerly known as CIGNA Insurance Company of Ohio,formerly known as Aetna Insurance Company of Ohio Chubb Insurance Company of Puerto Rico, formerly known as ACE Insurance Company of Puerto Rico, formerly known as CIGNA Insurance Coinpany of Puerto Rico, formerly known as Aetna. Insurance Company of Puerto Rico ACE American Insurance Company,successor to ACE Insurance Company of Texas, formerly known as CIGNA Insurance Company of Texas, formerly known as Aetna Insurance Company of Texas ACE Insurance Company of the Midwest,formerly known as CIGNA Insurance Company of the Midwest, formerly known as Aetna Insurance Company of the Midwest Aetna Insurance Company of Connecticut Allied Insurance Company ACE American Insurance Cornpany, successor to ACE American Lloyds Insurance Company fka ACE Ainerican Insurance Company of Texas fka American Lloyds Insurance Company Atlantic Employers Insurance Company Bankers Standard Insurance Company, successor to Bankers Standard Fire & Marine Company Bankers Standard Insurance Company Central National Insurance Company of Omaha, but only as respects policies issued through Cravens, Dargan & Company,Pacific Coast Century Indemnity Company,including as successor to CIGNA Specialty Insurance Company, formerly known as California Union Insurance Company Century Reinsurance Company Chubb Custom Insurance Company Chubb Indemnity Insurance Company

Exhibit B031 E-9 Chubb Insurance Cornpany of New Jersey Chubb Insurance Company of Puerto Rico, formerly known as ACE Insurance Company of Puerto Rico, formerly known as CIGNA Insurance Company of Puerto Rico, formerly known as Aetna Insurance Company of Puerto Rico Chubb Lloyd's Insurance Company of Texas Chubb National Insurance Company ACE Employers Insurance Company, formerly known as CIGNA Ernployers Insurance Company, formerly known as INA Ernployers Insurance Company ACE Fire Undeiwriters Insurance Company,formerly known as CIGNA Fire Underwriters Insurance Company, formerly known as Aetna Fire Underwriters Insurance Company Westchester Fire Insurance Company,successor to ACE Indemnity Insurance Company, formerly known as CIGNA Indemnity Insurance Company ACE American Insurance Company,formerly known as CIGNA Insurance Company successor to INA Underwriters, formerly known as Allied Insurance Cornpany ACE American Insurance Company, successor to ACE Insurance Company of Illinois, formerly known as CIGNA Insurance Company of Illinois, formerly known as INA Insurance Company of Illinois ACE American Insurance Company, successor to ACE Insurance Company of Ohio, formerly known as CIGNA Insurance Company of Ohio,formerly known as Aetna Insurance Company of Ohio Chubb Insurance Cornpany of Puerto Rico, forinally known as ACE Insurance Company of Puerto Rico, formerly known as CIGNA Insurance Company of Puerto Rico, formerly known as Aetna Insurance Company of Puerto Rico ACE American Insurance Company, successor to ACE Insurance Company of Texas, formerly known as CIGNA Insurance Company of Texas, formerly known as Aetna Insurance Company of Texas ACE Insurance Cornpany of the Midwest,formerly known as CIGNA Insurance Company of the Midwest, formerly known as Aetna Insurance Company of the Midwest ACE Property & Casualty Insurance Company,formerly known as CIGNA Property and Casualty Company,successor to Aetna Insurance Company ACE American Reinsurance Company,formerly known as CIGNA Reinsurance Company,

Exhibit B032 E-3 formerly known as INA Reinsurance Cornpany Chubb Holdings, successor to Chubb Executive Risk Inc., fka Executive Risk Inc., fka Executive Re Indernnity Cornpany, fka ERIC Reinsurance Cornpany, fka Excess Insurance Cornpany,fka Arnerican Excess Insurance Company Executive Risk Specialty Insurance Company, fka Executive Re Specialty Insurance Company Federal Insurance Cornpany Illinois Union Insurance Cornpany, successor to GA IlY Insurance Company Great Northern Insurance Company Highlands Insurance Company,in receivership, by and through its clain handling agent, Cravens, Dargan & Co.,Pacific Coast Horace Mann Insurance Company Illinois Union Insurance Cornpany Imperial Casualty Cornpany but only as respects policies issued through Cravens, Dargan & Cornpany, Pacific Coast or GATX Underwriters Inc. ACE Employers Insurance Cornpany, formerly known as CIGNA Employers Insurance Company, formerly known as INA Employers Insurance Company ACE American Insurance Company, successor to ACE Insurance Company of Illinois, formerly known as CIGNA Insurance Company of Illinois, formerly known as INA Insurance Company of Illinois ACE American Reinsurance Company,formerly known as CIGNA Reinsurance Company, formerly known as INA Reinsurance Company INA Surplus Insurance Coinpany ACE American Insurance Company,formerly known as CIGNA Insurance Company successor to INA Underwriters, successor to Allied Insurance Company Century Indemnity Company,as successor to CCI Insurance Company,as successor to Insurance Company of North, as successor to Indemnity Insurance Company of North America Westchester Fire Insurance Company with respect to policies novated froin Industrial Indemnity Insurance Company

Exhibit B033 E-4 Westchester Fire Insurance Cornpany with respect to policies novated frorn Industrial Underwriting Insurance Company.

Westchester Suiplus Lines Insurance Company,formerly known as Industrial Insurance Company of Hawaii, Inc. Century Indemnity Company,as successor to CCI Insurance Company,as successor to Insurance Company of North Arnerica Westchester Fire Insurance Cornpany with respect to policies novated from International Insurance Company Westchester Fire'Insurance Company with respect to policies novated from International Surplus Lines Insurance Cornpany Motor Vehicle Casualty Cornpany, but only as respects policies issued through Cravens,Dargan & Company,Pacific Coast Westchester Fire Insurance Company with respect to policies novated frorn Mount Airy Insurance Company Westchester Fire Insurance Company with respect to policies novated from North River Insurance Cornpany Northwestern Pacific Insurance Cornpany Pacific Employers Insurance Company Pacific Indernnity Cornpany Service Fire Insurance Cornpany, by and through its claim handling agent, Cravens, Dargan & Co., Pacific Coast Texas Pacific Insurance Company • Westchester Fire Insurance Coinpany with respect to policies novated from U.S. Fire Insurance Cornpany Vigilant Insurance Company Westchester Fire Insurance Company with respect to policies novated from Viking Insurance Company Westchester Fire Insurance Company Westchester Surplus Lines Insurance Company fka Industrial Insurance Company of Hawaii

Exhibit B034 E-5 Oakwood Insurance Company (successor by merger to Central National Insurance Company of Omaha, but only with respect to those policies issued through Cravens, Dargan & Company, Pacific Coast)

Exhibit B035 E-6 EXHIBIT F — MOTORISTS ENTITIES TO BE RELEASED

Motorists Mutual Insurance Company American Hardware Mutual Insurance Company Phenix Mutual Fire Insurance Company Wilson Mutual Insurance Company BrickStreet Mutual Insurance Company PinnaclePoint Insurance Company NorthStone Insurance Coinpany SummitPoint Insurance Company AlleghenyPoint Insurance Company MICO Insurance Company Consurners Insurance USA,Inc. Motorists Commercial Mutual Insurance Company Iowa Mutual Insurance Company Motorists Life Insurance Company Iowa American Insurance Company Broad Street Brokerage Insurance Agency,LLC MCM Insurance Agency, Inc. IMARC,LLC

Exhibit B036 F-1 EXHIBIT G — STIPULATION OF DISMISSAL WILLIAMS LAW FIRM Mark S. Williams E. Pine, P.O. Box 9440 Missoula, Montana 59807-9440 (406) 721-4350 Fax: (406) 721-6037 mark wmslaw.com CROWELL & MORING LLP Mark D. Plevin (admitted pro hac vice) Three Embarcadero Center, 26th Floor San Francisco, California 94111 (415) 986-2800 Fax: (415) 986-2827 [email protected] Attorneys for Plaintiffs: ACE Fire Underwriters Company and ACE Property & Casualty Insurance Company UNITED STATES DISTRICT COURT DISTRICT OF MONTANA,MISSOULA DIVISION

ACE FIRE UNDERWRITERS COMPANY CV 19-181-M-DLC-KLD and ACE PROPERTY & CASUALTY INSURANCE COMPANY, Plaintiffs, STIPULATION OF DISMISSAL WITH PREJUDICE OF ALL CLAIMS BY ALL v. PARTIES NANCY GIBSON,AS RECEIVER FOR ROBINSON INSULATION COMPANY; AMERICAN STATES INSURANCE COMPANY;and MOTORISTS COMMERCIAL MUTUAL INSURANCE COMPANY, Defendants.

STIPULATION OF DISMISSAL WITH PREJUDICE OF ALL CLAIMS BY ALL PARTIES

Exhibit B037 G-1 IT IS HEREBY STIPULATED AND AGREED as follows by plaintiffs and counterclaim defendants ACE Fire Underwriters Company and ACE Property & Casualty Insurance Company (collectively,"Chubb"), defendant, counterclairnant, cross-claimant, and cross-claim defendant Nancy Gibson, as receiver for Robinson Insulation Company (the "Receiver"), defendant, counterclaimant, cross-claimant, and cross-claim defendant American States Insurance Company ("Arnerican States"), and defendant, counterclaimant, cross-claimant, and cross-claim defendant Motorists Commercial Mutual Insurance Company ("Motorists"), as follows: 1. Chubb hereby dismisses its cornplaint as against the Receiver, American States, and Motorists, with prejudice.

2. The Receiver hereby dismisses her counterclaims against Chubb and her cross-claims against American States and Motorists, with prejudice.

3. American States hereby dismisses its counterclairns against Chubb and its cross-claims against the Receiver and Motorists, with prejudice.

4. Motorists hereby dismisses its counterclaims against Chubb and its cross-claims against the Receiver and American States, with prejudice.

5. Any and all other claims asserted in this action by any party against any other party ate disrnissed, with prejudice.

6. Each party shall bear its own fees and costs with respect to this action and this stipulation of dismissal with prejudice.

[signatures begin on next page]

Exhibit B038 G-2 Dated: ,2020 By: /s/Mark S. Williams Mark S. Williams WILLIAMS LAW FIRM Mark D. Plevin (admittedpro hac vice) CROWELL & MORING LLP Attorneys for Plaintiffs and Counterclairn Defendants: ACE Fire Underwriters Company and ACE Property & Casualty Insurance Company

Dated: ,2020 By: /s/ Allan M. McGamg MCGARVEY,HEBERLING,SULLIVAN & LACEY,P.C.

On behalf of: Defendant, Counterclaimant, Cross-Clairnant, and Cross-claim Defendant Nancy Gibson,in her capacity as Court-appointed Receiver for Robinson Insulation Company Dated: , 2020 By: /sl Adam M. Shaw Adam M. Shaw BROWN LAW FIRM,P.C.

Michael J. Cohen (admitted pro hac vice) Garrett A. Soberalski (admitted pro bac vice) Hannah M. Compton (admittedpro bac vice) MEISSNER TIERNEY FISHER & NICHOLS S.C..

Attorneys for Defendant, Counterclaimant, Cross-Clairnant, and Cross-claim Defendant American States Insurance Company

Dated: , 2020 By: /s/ Shane P. Coleman Shane P. Coleman HOLLAND & HART LLP Attorneys for Defendant, Counterclaimant, Cross-Claimant, and Cross-claim Defendant Motorists Commercial Mutual Insurance Company

Exhibit B039 G-3 EXHIBIT H — FORM OF SETTLEMENT APPROVAL ORDER IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA

IN RE ASBESTOS LITIGATION, Cause No. AC 17-0694 Consolidated Cases JUDGMENT AND ORDER APPROVING SETTLEMENT(Robinson Insulation Receivership)

Receiver Nancy Gibson and Allan McGarvey and Mark Kovacich on behalf of certain Libby Plaintiffs have jointly filed a rnotion (the "Motion") asking this Court to authorize the Receiver's settlernent of the insurance coverage claims by Robinson Insulation Company ("Robinson") against ACE Fire Underwriters Insurance Company and ACE Property & Casualty Insurance Company (collectively,"Chubb"), American States Insurance Company ("American States"), and Motorists Commercial Mutual Insurance Company ("Motorists" and, collectively with Chubb and American States, the "Settling Insurers"). A copy of the "Settlement Agreement and Release"(the "Agreement") between the Receiver and the Settling Insurers is attached to the joint motion of the Receiver and certain Libby Plaintiffs, and has been reviewed by this Court.2 The court has reviewed the following documentation attached to the Motion and makes these findings based thereon: (a) Exhibit A is a discovery response filed on behalf of Grogan Robinson Lumber Company ("Grogan"). It establishes, and the court finds,(i) that Grogan was the successor to Lumber Yard Supply and Grogan-Robinson Lumber Cornpany;(ii) ownership and related management of Robinson and Grogan and its predecessors overlapped; and (iii) that, following the winding up of its assets and affairs, Grogan was dissolved in 2018.

(b) Exhibit B is a copy of the Agreement which the Court finds to exhaust the limits of liability coverages in the policies settled thereby.

(c) Exhibit C is an affidavit of Allan McGarvey, attorney for hundreds of Libby asbestos claimants including those with and without claims of exposures during the insurance coverage period. It establishes, and the court finds, that(i) the Agreernent was reached Unless defined separately herein, all capitalized terms in this Order have the meanings ascribed to them in the Agreement.

Exhibit B040 H-1 following extensive efforts to identify insurance policies potentially providing coverage for clairns against Robinson; (ii) despite reasonable efforts, a number of policies and /or declaration sheets, endorsements, and forms for several policies could not be located; (iii) secondary evidence of coverages provided by certain policies was located but was also incornplete;(iv) pleadings in a declaratory judgment action filed in U.S. District Court in Montana were filed setting forth the coverage contentions and defenses of the parties to the Agreement;(v) extensive analysis and negotiation was pursued to reach agreernent on the coverages provable and the meanings thereof; and (vi) counsel for aIl known individuals with claims against Robinson are satisfied that the Agreement exhausts the maximum available coverage under the settled policies.

(d) Exhibit D is a Qualified Settlernent Fund Trust which the court finds (i) will receive and hold proceeds of the settlement of the settled insurance; (ii) upon further application to and approval of this court, would distribute such proceeds to resolve claims of those with clairns against the Receivership estate which constitute occurrences under the coverages ofthe settled insurance; and (iii) is the appropriate and necessary and customary rnechanisrn to manage those proceeds, as they must be, for the purpose of resolving corresponding clairns.

(e) The affidavits of Allan McGarvey and Receiver Nancy Gibsonestablish, and the court finds, that (i) lawsuits have been filed against both Robinson and Grogan alleging claims for strict product liability for the sarne asbestos injuries with the difference being that Robinson was primarily a manufacturer of the product while Grogan and its predecessor entities were distributors of the product,(ii) the Settling Insurers have been providing a defense of all such claims under reservation of rights, (iii) plaintiffs' counsel have apprised defense counsel that many lawsuits may be brought against Grogan alleging strict product liability for damages for which Robinson is alleged to also be liable, and (iv) the resolution of the claims against Robinson will therefore not eliminate lawsuits against Grogan for the sarne injuries or types of injuries.

The court concludes as follows: (A) This Court's March 23, 2018 Order (the "Order') creating the receivership granted authority for the Receiver to make dernands that the insurers settle claims against Robinson (Order¶l(c)). The Order, at Order ¶2 (a),(b) requires that the Receiver obtain this Court's approval of"specific proposals" for settlement.

(B) The proposed settlement entered into by the Receiver and its insurers is appropriately made subject to this Court's approval.

(C) The settlement is in the best interests of the Robinson and Grogan receivership estates because it is a fair and reasonable compromise of disputed insurance

Exhibit B041 H-2 coverage issues. The settlernent was negotiated in good faith and at arm's length between the Receiver and Mr. McGarvey, on the one hand, and each of the Settling Insurers, on the other hand.

(D) The compromise embodied in the Agreement allows the Receiver to liquidate Robinson's and Grogan's insurance coverage for distribution to persons asserting claims against Robinson and/or Grogan, subject to the establishrnent of a Trust that would, once approved by this court, fairly and equitably distribute the insurance settlement proceeds to those claimants against Robinson and/or Grogan who satisfy the Trust's requirements.

(E) The Agreement provides, at paragraph 3.3, that each Settling Insurer shall pay its respective settlement amount into a Qualified Settlement Fund ("QSF"), and that the Receiver shall not distribute any funds from the QSF except as authorized by this court.

(F) The Receiver has provided due and adequate notice of the Motion, the deadline to object to the Motion, the Agreement, and the subject rnatter thereof to all persons known to have asserted Asbestos Clairns (as defined in the Agreement) against either Robinson or Grogan and to all of its other insurers, including Horne Insurance Company (in liquidation) and Mission Insurance Cornpany (in liquidation). ln addition, to ensure the broadest notice possible, the Receiver and the Settling Insurers have published notice of the (i) Motion,(ii) the hearing on the Motion, and (iii) the Agreernent in USA Today, The Western News, Kalispell Daily Interlake, Missoulian, Great Falls Tribune, and Helena Independent Record on [May 26], 2020, in the Billings Gazelte on [May 27], 2020, and in the Sanders County Ledger on [May 28], 2020. Such notice, including the aforesaid notice by publication, was good and sufficient under the particular circumstances to provide adequate and appropriate notice to both known and unknown Asbestos Clairnants, and no other or further notice is or shall be required. Accordingly, a reasonable opportunity to object or be heard with respect to the Motion and relief requested herein has been properly afforded to all persons and entities potentially affected by the Agreement.

(G) The relief sought in the Motion is in the best interests of the Robinson and Grogan receivership estates and the Asbestos Claimants. The Receiver has demonstrated good, sufficient, and sound business purposes and justifications for the relief requested in the Motion. The compromise and settlement with the Settling Insurers embodied in the Agreernent is consistent with and within the reasonable range of litigation outcomes if the Receiver were to litigate the matters resolved pursuant to this Order.

Exhibit B042 H-3 (H) The comprornises contained in the Agreement are a valid and proper exercise of the reasonable business judgment of the Receiver and represent an exchange for reasonably equivalent value. The releases to be given by the Receiver pursuant to Section 5 of the Agreement are appropriate and should be approved. The Settling Insurers would not have entered into the Agreement or any of the compromises and settlements contained therein, or agreed to pay their respective Settlement Amounts, without the benefit of obtaining the releases contained in the Settlement Agreement and the Injunctions contained in this Order.

(I) This court has inherent equitable authority sufficient to permit it to enter the injunctions contained in Sections 4 and 5 of this Order (the "Injunctions"). The Injunctions are essential to give effect to the settlements and compromises set forth in the Agreement and to fulfill the purposes of both the Robinson and Grogan receiverships. The Settling Insurers have asserted that the Injunctions are a necessary prerequisite for entry into the Settlement Agreement, and the Settling Insurers have informed the Receiver that they will not consummate the settlements and compromises set forth in the Agreement, or pay their respective Settlement Amounts in the absence of the Injunction.

Wherefore, IT IS HEREBY ORDERED and ADJUDGED: (1) The Motion is granted.

(2) The Agreement settling and releasing the insurance coverage claims of Nancy Gibson, as court-appointed Receiver for Robinson and Grogan, against the Settling Insurers is hereby fully and finally approved.

(3) Settlement proceeds shall be paid to the Receiver, Nancy Gibson, to be held by the Receiver in a QSF, until such time as this court approves the establishment of a Trust and appropriate procedures for the Trust to distribute the settlement proceeds to Asbestos Claimants.

(4) Pursuant to the Court's inherent equitable authority,(a) all Persons who hold or assert, or may in the future hold or assert, any Claim against Robinson, Grogan, or the Receiver arising in connection with the activities covered by the Policies, or in connection with the activities of Robinson or Grogan giving rise to the Claims that have been made or that could be made under the Policies, and (b) all Persons who may claiin to be an insured, additional insured, or otherwise entitled to any benefit under the Policies, are permanently stayed, barred, restrained, and enjoined frorn asserting any such Claim or right to entitlement, from comrnencing a proceeding, or taking any other action against ACE Fire Underwriters Insurance Company, ACE Property & Casualty Insurance Company, Motorists Commercial Mutual

Exhibit B043 H-4 Insurance Cornpany, or American States Insurance Company (collectively, the "Settling Insurers") or the persons and entities defined in the Agreement as "Insurer Parties" for the purpose of obtaining any recbvery or other relief frorn the Settling Insurers or the Insurer Parties based on, under, arising out of, related or attributable to, and/or in connection with the Policies.

(5) All clairns for contribution, allocation, subrogation, and equitable indemnity, or similar claims, against any ofthe Settling Insurers (collectively, "Contribution Claims"), whether by parties appearing before the Asbestos Claims Court or not, are hereby BARRED pursuant to the Court's inherent equitable authority. All Contribution Claims against any of the Settling Insurers shall be channeled to the QSF established to hold the Settlement Amounts paid by the Settling Insurers or to any Trust to which the funds in the QSF are transferred following an order by this Court authorizing such transfer.

(6) This is a final order and judgment for purposes of appeal under Rule 4(1)(a) of the Montana Rules of Appellate Procedure.

DATED AND ELECTRONICALLY SIGNED AS NOTED BELOW.

/ /2020

Arny Eddy, Asbestos Clairns Court Judge

Exhibit B044 H-5 IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA

IN RE ASBESTOS LITIGATION, Cause No. AC 17-0694 Consolidated Cases AFFIDAVIT OF ALLAN MCGARVEY (Robinson Insulation Receivership)

State of Montana ) )ss County ofFlathead)

Allan M.McGarvey, being first sworn, deposes and states: 1. I am an attorney ofrecord for hundreds of plaintiffs with asbestos claim cases in this Court. I have personal knowledge of the matters herein with respect to the proposed Settlement Agreement between the Receiver for Robinson Insulation Company and the Settling Insurers.'

2. The clients represented by my firm include asbestos claimants with cases in this Court, many of whom claim exposures during the insurance coverage period of the insurance coverages settled by the Receiver, and many of whom do not have

"Settling Insurers" refers to Ace Fire Underwriters Insurance Company and Ace Property & Casualty Insurance Company, Motorists Commercial Mutual Insurance Company and American States Insurance Company and such insurers' affiliated and predecessor insurance entities as defined in the Settlement Agreement.

Exhibit C001 wholesaler, or retailer ofthe same vermiculite products for which my clients assert the liability of manufacturer Robinson Insulation Company.

12.Attached is a transcript of a deposition of Owen Robinson, in which he testified as a Rule 30(b)(6) witness on behalf of Grogan Robinson Lumber Company(Tr p.11, line 24)to the following: p. 10 ,.. Is there any common ownership between the two companies?

7 A: Yes,there was. Yes.

p.14 Lumber Yard Supply was the -- was the wholesale arm of what we considered as our company. Grogan Robinson Lumber Company was the retail arm of what we considered our company.

p.16 ... Did Lumber Yard Supply sell Zonolite on a wholesale basis in the 1977 to 1991 time period?

17 Yes.

p.17 A. It was used as an attic insulation. That was primarily its only use, Zonolite itself. There were other products that were made by Robinson Insulation, but they were never retailed by Lumber Yard Supply.

15 Q Was Zonolite the only vermiculite product that was sold by Lumber Yard Supply in the '77 to '91 time period?

17 A Yes.

13. I have been working with the Receiver and attomeys in the Odegaard Kovacich Snipes firm in drafting of a "Trust Distribution Procedure(TDP)proposal for

Exhibit C002 the distribution ofproceeds ofthe settlement to claimants meeting coverage, exposure, and medical criteria, which drafting is modeled on the type of TDP used in bankruptcies of asbestos manufacturers. It is my expectation and intent to present to the Court by the time the proposed QSF is funded, a proposal for an equitable distribution mechanism and the appropriate procedures for approval thereof.

FURTHER THE AFFIANT SAYETH NOT.

Dated this 21st day of May,2020

SUBSCIUBED AND WO=?Tfo me this day of r14., 2020. c for the State of Montana Residinl ,,,i,,i,,,,,,,,, Et14_1c1.ifT%r(Fifjiii.BEIUCMfMINGS My Commission ex , --„, \‘‘ l'.--3 oz -:* State of Montanoar the ;t-z Residing at ---:.`fl ,,,:: oFmo1.4- Kalispell, Montana iiiiti‘\\` My Commission Expires July 20, 2020

Exhibit C003 HARTLE: OWEN ROBINSON - 30(B)(6) Page 1 1 MONTANA ELEVENTH JUDICIAL DISTRICT FLATHEAD COUNTY JEREMIAH HARTLE and KAREN ) 3 HARTLE, husband and wife, ) individually and on ) 4 behalf of their minor ) children, ) 5 ) Plaintiff, ) 6 ) v. ) Case N . DV-18-532(B) CONAGRA BRANDS, INC., et 8 al., 9 Def.endants.

11 VIDEOTAPED 30(b)(6) DEPOSITION OF OWEN ROBINSON

13 On the 15th of October, 2019, beginning at 14 10:00 a.m., the videotaped 30(b)(6) deposition of OWEN 15 ROBINSON was heard at The Staybridge Suites Great Falls, 16 201 Third Stret Northwest, Great Falls, Montana, before 17 Holly E. Fox, Court Reporter and Notary Public.

hglitigation.com

Exhibit C.1.001 HARTLE: OWEN ROBINSON - 30(B)(6) Page 2 Page 4 1 APPEARANCES 1 INDEX 2 2 APPEARING ON BEHALF OF THE PLAINTIFFS: 3 Page 4 MATTHEW BERGMAN and BRENDAN LITTLE (via videoconference) 4 EXAMINATION 5 Attorneys at Law Hy Mr. Bergman 6 Bergman Draper Oslund 6 821 Second Avenue, Suite 2100 Seattle, Washington 98104 6 matigbergmanlega1.C6M brendangbergmanle.gal.com 7 E X H I B I T S 8 8 ETHAN WELDER (telephoninally) Page No. Description 9 Attorney'ab Law • McGarvey, Heberling, Sullivan & Lacey, P.C. 10 1 Notice of 30(b).(6) deposition 11 10 345 First Aimnue East 11 2 Third Party Defendant Grogan Robinson 13 Kalispell, Montana 59901 11 eweldergmcgarveylaw.com Lumber Company d/b/a Lumber Yard Supply's 12 12 Responses and Objections to Plaintiffs' APPEARING ON BEHALF OF THE THIRD-PARTY First Interrogatories and Requests for DEFENDANTS ROBINSON INSULATION COMPANY AND GROGAN ROBINSON LUMBER COMPANY d/b/a LUMBER YARD 13 Production SUPPLY: 14 3 Transcript of 30(b)(6) deposition of WBC's 27 15 NATHAN A. HUEY, ESQ.

Attorney at Law corporate representatives 16 Gordon Rees Scully Mansukhani 15 West Main Street, Suite 101 31 4 Material Safety Data Sheet, two pages 17 Missoula, Montana 59802 nhueyggrsm.com 16 , 18 17 APPEARING ON BEHALF OF THE THIRD-PARTY DEFENDANTS HUTTIG BUILDING PRODUCTS, INC., 18 PALMER G. LEWIS, and ACE HARDWARE: 19 21 CHRISTY MCCANN and DANIEL AUERBACH 20 (telephonically) 22 Attorneys at Law 21 Browning Kaleczyc Berry & Hoven, P.C. 22 23 201 West Railroad Street, Suite 300 MisSoula, Montana 59802 • 23 24 chriatygbkbh.com 24 danielgbkbh.com

Page 3 Page 5 1 APPEARANCES, continued 1 Ths following proceedings were had aad testimony taken: APPEARING ON BEHALF OF DEFENDANT AND THIRD-PARTY PLAINTIFF WESTERN BUILDING CENTER: 3 *** * ** *** * BENJAMIN J. HAMMER, ESQ. (Telephonically) 5 THE VIDECGRAPHER: Let the record show that this 5 Attorney at Law Hammer, Quinn & Shaw, PLLC 6 is the time and place designated for the videotaped Financial Drive, Suite 100 7 deposition of 30(b)(6) witness Cwen Rdbinson in the matter Kalispell, Montana 59904-0310 7 benhammereattorneysmontana.com of Jeremiah Hartle and Karen Hartle, rdaintiffs, versus e 9 ConAgra Brands, Inc., et al., defendants, in the Montana APPEARING ON BEHALF OF DEFENDANT CONAGRA BRANDS, Eleventh Judicial District Court, Flathead County, Cause INC.: 10 11 Number DV-18-52- -- 532(B).

MAXON DAVIS 12 The date today is October 15, 2019. The tire on the 11 Attorney at Law monitor is -- is 10:04. My namv is Wade Larson. I'll be • Davis, Hatley, Haffeman & Tighe, PC 12 101 River North Drive 14 operating the carrera today. . The oourt reporter is Holly Milwaukee Station, Third Floor 15 Fox, 13 Great Falls, Montana 59401 16 And I now ask counsel to PaPAAP voice-identify [email protected] 14 17 themselves and state wiscrn they represent. is 18 MR. BERGMAN: Matthew Bergran for the plaintiffs.

19 MR. LITTLE: Brendan Little for the plaintiffs. le 20 MR. HUEY: Nathan illy for Lunber Yard Sqoply and 19 21 Robinson Insulation ampany.

22 MR. DAVIS: Ifrox Davis for ConAgra.

22 23 VS. MCCAW: Christy McCann for -- 23 24 KR. HOER: Ben -- go ahead.

25 MS. MCCANN: Caristy McCann for Huttig Building

hglitigation.com

Exhibit C.1.002 HARTLE: OWEN ROBINSON - 30(B)(6) Page 6 Page 8 Products, Palmer G. Lewis, and Axe Hardware. 1 old natie, Grogan Robinson Lumber Company. So =- 2 IC, HAMMER: Ben Hammer for Western Building 2 (By Mr. Bergman) I understand, sir, and -- Center. 3 A Okay.

4 bal. WELDER: Ethan Welder for plaintiffs. 4 I didn't mean to interrupt you, sir, so please -- 5 MR. AUERBACH: Dan Auerbach for Ace Hardware, 5 please -- Huttig, and Palmer G. Lewie. 6 A No, that's fine.

7 THE VIDEOGRAPHER: Is that everyone? 7 Q -- finish.

8 Would the reporter please swear in the witness. 8 Can you trace for us the p ugLess of your career 9 9 from the tirm -- from the time you graduated from high 10 OWEN ROBINSON, 10 sdhool to the time you retired?

11 having been first duly sworn by the Court Reporter, was 11 A Yes. When I graduated from high school, I spent a examined and testified as follows: 12 couple of years when I was in college working for the 13 13 company. I think that would have been '65, '66 and '67, 14 EXAMMATION 14 And then I moved to Loa Angeles. Came back to work for the BY MR. BERMAN: 15 carpany in 1976. And that's when my career as a full-time 16 Q Good morning, sir. 16 employee started, in 1976; 17 A Good morning. 17 I was brought there as -- as the cocluter guy. In 18 Q Could you please introduce yourself. 18 those days, you bought a computer and then hired somebody 19 A Ny name is Owen Robinson, 19 to write the software. Nowadays you buy the software, and 20 Q And, Mr. Robinson, where do you live? 20 the computer comes with it. So I wrote all the software 21 A I live here in Great Falls, Montana. 21 for -- for -- and!at that time it riculd have been GrOgan 22 Q And, sir, what is your relationship to Grogan 22 Rdbinson Umber Olompady. And I wrote it --Viol timber Yard Robinson? 23 Supply would have been the -- would have been astbeidiaiy.

24 A Grogan Robinson? I was -- I ended up my career 24 So I wrote the software for accounts receivable, with Grogan Robinson as president and CEO. 25 Mostly accounts receivable, but also accounts payable and

Page 7 Page 9 1 Q And can you just briefly forward for us the 1 got into the general ledger when they finally decided that progress of your career7 And I guess, before I do that, 2 we would -- we finally decided that it %cull be better to are you currently retired, sir? 3 buy a ocuputer that had software on it. That would have 4 A I am, except for being on the -- except for being 4 been probably -- on the city commission. But I consider that work for the 5 Q And did you work -- community, not -- not a career. I get paid $312 a month, 6 (Sirrultaneous talking.)

7 if that answers the question. 7 A I'm sorry. Excuse me. Go ahead, Mt. Bergman.

8 Q That does, sir. That probably pays for the Maalox 8 Q Did you work for Grogan Robinson continually from you need to ingest to put up with that. So 1 -- I cannend 9 1976 until the time you retired?

10 you for your service. 10 A Yes.

11 MR. HUEY: Mr. Bergman? Mr. Bergman, I'm sorry. 11 Q And you testified that in the '65 to '67 pericd This is Nathan Huey. 12 you worked for -- and you said 'the company.'

13 I wonder if we could just clarify for the record when 13 Was that also Grogan Robinson?

14 we talk about Grcgan Robinson which entity we're actually 14 A Yeah, it was. One of those years I worked for referring to, because it's a little bit of a cuiplicated 15 'Missouri River linter .Ciartaapy; uhich was a Subsidiarya corporate history. 16 Grogan Robinsonat Fort'Behton. They had a little luMber 17 ' MR. BERGMAN: Indeed. We're referring to Grogan 17 yard in Fort Benton. There was a big hailstorm, and I went Robinson as sucoasstrto Lumber Supply (sic]. 18 back -- went and worked there that summer. The other two 19 THE DEFONENC: Right. When'I -- the business that 19 would have been in Great Falls for Grogan Robinson.

20 you're concernedabout is reallylAnter Yard Supply, and it 20 THE CCURT REPORTER: I'm sorry. Is someone on the %as at the time. And we had to ciabge the name When I-aold 21 line7 Could you mute ycur phone -- mute your line?

22 Luker Yard Supp1Y:in 2015'; Toe -capany that bought it, 22 MR. DAVIS: Sounds like they did.

23 WicsAn Supply, also bougat'the naMe. It todk tie arco.14 23 THE COURT REPORTER: Thank you, years to close down the company, so Ihad'to dharlge lt. `1, 24 Q (By Mr. Bergman) Sir, did -- have you ever worked had to find a name for it, and I cboee to go badlc to the 25 for Robinson Insulation Ccnpany?

hglitigation.com

Exhibit C.1.003 HARTLE: OWEN ROBINSON - 30(B)(6) Page 10 Page 12 1 A Never. 1 deposition here today?

2 Q Okay. And is tbere,a. relaicUehip betWeen.GrOgan 2 A Yes.

'RObinsan'ani Rebinson-Insulation Company? 3 Q And you understand that you are the -- you are the 4 A lp",) 4 corporate representative for those entities in this 5 Q Okay. Is there any.-cOmmon.omaer614 between the 5 testimony?

6 two companies? 6 A Yes.

7 A .Yes, there .was. Yes. 7 Q If you could turn to Page 2 of Ekhibit 1.

8 Q And can you describe that for us, please, sir. 8 A (Complies.)

9 A Yes. Robinson Insulation started because my 9 Q You see at the bottom of Page 2 of Exhibit 1 there 10 father, he graduated from Princeton University in 1936. 10 are specific topics, and that they -- there's -- they 11 And it was during the recession. There wasn't enough -- my 11 ccutinue 1 through 3 on Page 2 of Eibibit 1, and then great-grandfather and my grandfather would not hire my dad 12 continue on Page 3 and 4 of Exhibit 1.

13 in the company because it was during the recession, and to 13 Do you see those topics, sir?

14 do that, they would have had to fire somebody. We had some 14 A I do.

15 line yards throughout Montana and North Dakota, 15 Q And are you the witness that has been designated 16 And so he worked in the steel mills. He wasn't a 16 by Grogan Robinson and Luber Yard Supply to testify on very strong man, He just hated it. And so the opportunity 17 behalf of the 12 topics set forth on Exhibit 1?

18 came; my grandfather bought a company and named it Robinson 18 A Well, I -- it's kind of hard to answer since it's Insulation, made my dad a partner in it, but he -- but my 19 no longer a corporation But, yes, I suppose I would be grandfather was the biggest owner in it. And they started 20 the one.

21 a company -- that company, and it sold what ended up being 21 MR. HUEY: And just for the record, xe did serve 22 Zonolite insulation, but it was called Unifill * at the 22 objections to Topics 9, 11, and 12.

23 time. 23 MR. BERGMAN: I understand. Thank you, Counsel.

24 Q And was your father Brooks Robinson, sir? 24 Q (By Mr. Bergman) I would then -- at this point, if 25 A Yes, my father v.as Brooks Robinson. 25 I could ask the court reporter to pull out Envelope 3 and

Page 11 Page 13 1 Later in that corrpany, my -- my uncle, Dave 1 nark it as EXhibit 2.

2 Robinson, who used to work for W.R. Gtace, left that 2 (Exhibit 2 marked for identification,) ccepany and went to work for Robinson Insulation. So at 3 Q (By Mr. Bergman) Mr. Robinson, you've been handed one time there was three owners: My grandfather, Fred 4 Ekhibit 2, and I guess my question is, are these the Robinson; my father, Brooks Robinson; and his brother, my 5 inteuveatory responses that Grogan Rebinson Luther Cbmpany uncle, Dave Robinson. And my grandfather died. Then there 6 d/b/a Umber Yard Supply furnished in this case?

7 were only two owners: Brooks and Dave. 7 A Yes, they appear to be. Yes.

8 Q And when do you recalli4r. Dave Robinson working 8 Q Okay. I'm going to be asking you some questions for W.R. Grace, and when did he come to work for Robinson 9 about the responses that are eet forth in EXhibit 2, but 10 Insulation? 10 before I do that, air, can you describe in general terms 11 A Gee. I'm only guessing. I really don't know. 11 the nature of the business of Grogan luMber company?

12 But I think it wOuld have been about 1978. 12 And for purposes of my examination today, I'm 13 Q Okay. And, again, no one wants you to guess, 13 focusing on the period between 1977 and 1991.

14 Mr. Robinson. 14 MR. HUEY: And you mean LuMber Yard Supply, 15 Would it be your best estimate it was in the 15 Mr. Bergman?

16 mid-'700 16 MR. BERGMAN: I do.

17 A That would be an estimate, yes. 17 TEE DEPONENT: Yeah, I can answer that.

18 Q Okay. Sir, I'd ask tbat the court renorter 18 Actuaily-- actually, theywere-two seperete .00mpa4es 19 provide you with Exhibit 1. 19 'at-thatfime: Giogan Robinson and Wilber Yard 4ply. .And; 20 (Exhibit 1 marked for identification.) 20 believe these areamershere46fertcaumberiardSUpplY, 21 Q (By Mr. Bergman) Mr. Rdbinson, I'm -- you've been 21 ` heOauseluMherlard Stpply.a.thattime Was'e 22 handed Exhibit 1, which is the notice of 30(b)(6) 22 thuildingmuteriels 4isiness. GOole,lan RObinson had al4ne 23 deposition in this ratter. Do you understand, air, that 23 Yards Pg'retai4j#eiY.Ardi.

24 you're testifying an bebalf of -- of Grogan Robinson LuMber 24 And so-these:rPfcr.9 4111Rer yard Supply. It's ribt 25 Carpany and Wilber Yard Supply in the context of this 25 just a d/b/,a. It happens to be a d/b/a because we changed

hglitigation.com

Exhibit C.1.004 HARTLE: OWEN ROBINSON - 30(B)(6) Page 14 Page 16 the name at -- in 2015 again, butat that time Lumber Yard 1 Supply andrany other wholesalers. And Lubber Yard Supply Supply was a -.- was a separate carpanÿ -- madly owned by 2 wbuldhave been a Wholesaler zelling:to Grogan Robinson and Grogan Robinson, by the way -- but it was a separate 3 'other retail yards.

4 .carpany doing business as Lumber Yard Supply Cbbpany. 4 Q And in addition to -- did Lumber Yard Supply 5 And then there was Grogan Robinson Lumber anpany that 5 furnish all of the products that were sold by Grogan also had some -- one of their subsidiaries was linter Yard 6 Robinson? Or did Grogan Rdbinson obtain products frcm Snpplytecause they owned most of it, lout they alsobad 7 other -- other entities?

8 other subsidiaries and also just Grogan Robinson Lurber 8 A '-.Crtgan Robinson prbbablybought 30 to 35 percent Carpany as a retail' lumberyard. 9 of their materials from LUmber Yard Supply. They were 10 Q (py Mr. Bergman) Was Lubber Yard Supply and Grogan 10 the -- Lumber Yard Supply's biggest custarer.

11 Lumber -- so I want to rake sure I'm clear an my 11 Q And did Lumber Yard Supply furniSh wholesale nomenclature. 12 Zonolite?

13 There was Lubber Yard Supply, and then was it, in 13 (Clarification by the court reporter.)

14 the '77 to '91 period, referred to as Grogan Lumber 14 Q (py Mr. Bergman)'D'id LUmber Yard Supply sell Company? 15 Zonolite 64 a wholesale basis in the 1977 to 1991 tiine 16 A Nb, not really. There was a -- I'll try and 16 period?

17 re-explain it. I'm not sure I'm being clear. 17 A Yes.

18 But,during that periodcf.time-, Lubber Yard Supply 18 Q And did Lurber Yard SupplY sell or supplylono1ite was the -..- Was the wholesale armiof What we Considered as 19 on a wholesale basis to the GLugan Robinscu entities in the our Cobpany. Grogan RObinson Lubber Company Na5 the retail 20 1977 to 1991 tire period?

21 arb.of what W8 considered bur bobpani. 21 A ; Yes. i 22 Q Okay. I appreciate that clarification, sir. 22 Q What percentage -- roughly speaking, sir -- was 23 Did Grogan Robinsan Lumber Company and Lumber Yard 23 the sale of Zonolite by Lumber Yard Supply relative to Supply operate out of the same location? 24 other products sold by the cavany in the '77 to '91 time 25 A No. 25 period?

Page 15 Page 17 1 Q A11 right. What were the relative locations of 1 A I can't give you an exact percentage, but it vas a the boo entities, sir? 2 very small part of their business. Very small.

3 A Well, Lumber Yatd SUpply I.a location in Great 3 Q Ckay. And, again, sir, I'm not asking you to Falls down near the river -- Missouri River. Grogan 4 guess, No one wants you to guess.

5 'Robinson Umber Company had%a -- at that -- during tho6e 5 Would you say it was 5 percent? Was it more or yearsthat you refeiLed to, had a retail' --1.tWo retail. 6 less than 5 percent?

7 yards in Great Valid: Cne downtownand'the other on the 7 A Less than 5 percent, easily.

8 west side. They had a retail yard in Havre, 14ntana, They 8 Q Okay. And what were the uses of Zonolite, DO far had a retail yard - although under- a different company's 9 as you know, in the '77 to '91 time period for which it was name -- in Fort Benton called Missu7rri RiVet Lumber 10 sold by Lubber Yard Supply?

11 ,- Ctrpany. They had a retail yard in Helena called Peterson 11 A It was used as an attic insulation. That was :Lumber Cobpany, and they had retail yard in Butte Called 12 primarily its only use, Zonolite itself. There were other Pioneer Lpmber Company. 13 products that were made by Robinson Insulation, but they 14 Q All right. Sir, Lumber Yard Supply, what 14 were never retailed by Lumber Yard Supply.

15 wholesale products did it furnish? 15 Q Was Zonolite the only vermiculite product that vas 16 A It -- well, almost -- as many building material 16 sold by Lumber Yard Supply in the '77 to '91 time period?

17 products as we could represent. Biggest products would 17 A Yes.

18 have been lumber and plywood. And we had roofing. We had 18 Q Are you aware of other applications for Zonolite windbws, siding. And -- and that's all that really comes 19 besides attic insulation?

20 to rind right now. But we had a lot of little smaller 20 A No, I -- well, one exception. I think that products too. 21 they -- some people would use it and put it in soil as 22 And Lumber'Yard Supply did sell to Grogan 22 a -- as a moisture reliever, but that's not what we sold it Rdbinson, as well as -- as other Cobpanied. So- Grogan 23 as. But some people would say, Well, I'll put Zonolite and ,Robinson would have been like any other retail lumber 24 mix it with my soil, and it retains moisture a little companyin the state. And they bought from Lubber Yard 25 better. But that vas not what we sold it ad. We sold it

hglitigation.com

Exhibit C.1.005 Exhibit 1

IN THE ASBESTOS CLAIMS COURT OF THE STATE OF MONTANA

IN RE ASBESTOS LITIGATION, Cause No. AC 17-0694

Consolidated Cases INSURED CLAIMS QUALIFIED SETTLEMENT FUND TRUST

1. Name and Purpose of the Trust. The Trust shall be known as the Insured Claims Qualified Settlement Fund Trust (hereafter, the "Trust"). The purpose of the Trust is to create a trust entity to assume and take assignment of all rights and obligations of the Receiver (as defined herein) for Robinson Insulation Company and Grogan Robinson Lumber Company with respect to settled liability insurance coverage of Claims (as defined herein) against those entities, and to fulfill distribution obligations arising from the settlement of insurance claims. The Trustee shall receive and distribute the Contributions referenced in Paragraph 2 below in a manner consistent with the terms and conditions described in the Settlement Agreement(as defined herein and attached hereto as Exhibit 1 and incorporated herein by this reference) to Insured Claimants (as defined herein) so

Exhibit H003 as to resolve the personal injury clairns to the extent of such liability insurance coverage. The Trust is established as a qualified settlement fund ("QSF") in accordance with 26 U.S.C. § 468B and its corresponding regulations, 26 C.F.R. § 1.468B.

2. Contributions to the Trust. The following contributions (the "Contributions") will be made to the Trust: A. Upon fulfillment of the conditions in the Settlement Agreement including Court approval, Settlement Amounts totaling $11,625,000.00 shall be paid to the Trust by Insurers (as defined herein) which have resolved their obligations under Policies (as defined herein) with respect to Claims against the Robinson Entities (as defined herein) and Grogan Entities (as defined herein).

B. Upon any future Court-approved settlement of insurance obligations of other insurers with respect to Claims against the Robinson Entities and Grogan Entities, all resulting payments from such insurers or liquidators of insolvent insurers which have resolved their insurance obligations shall be paid to the Trust.

Contributions made to the Trust shall not be construed as fines, penalties, monetary sanctions, or punitive damages.

3. Assignment and Assumption of Rights and Responsibilities. Subject in all events to the terms of the Settlement Agreement, all rights and responsibilities of the Receiver (as defined herein) with respect to the above described

Exhibit H004 Contributions, and distributions thereof, including all rights and duties of the Receiver arising under the Settlement Agreement, are hereby assigned to and assumed by the Trust, and the Receiver and Receivership estate shall have no further duties with respect thereto. The Trust shall indemnify the Receivership estate and Receiver for any clairn, liability, or defense expense arising from the assignrnents and assumptions of rights and responsibilities under this Trust and the Receivership estate.

4. Dispositive Provisions. Trust funds shall be used as follows: A. Payment ofIncome and Principal. During the terrn of the Trust, the Trustee shall pay or apply such part (or all) of the income and principal of the Trust to resolve Insured Claims against the Robinson Entities and Grogan Entities, which payments are subject to the other terms and provisions of the Trust and requirements of the Settlement Agreement.

B. Trust Distribution Procedures. Payments on Insured Claims shall be made pursuant to the terms of a Court-approved Trust Distribution Procedure created to afford equitable claim resolution of Insured Claims in a manner consistent with claim values in the tort system.

C. Trust Administration. Costs of administration of the Trust, including payment of the Trustee's fees and expenses, such as professional accounting services, shall be paid by the Trust frorn the Trust Funds.

Exhibit H005 5. Activities and termination. The activities of the Trust shall be limited as follows: A. No Authority to Conduct Business. The purpose of the Trust is limited to the matters set forth herein, and the Trust shall not be construed to confer upon the Trustee any authority to carry on any business or activity for profit.

B. Termination of the Trust. The Trust shall terrninate upon distribution of all trust assets and upon order of the Court.

C. Alterations, Amendments, and Revocation. The Trustee's duties may be altered, arnended, or revoked frorn tirne to tirne but only (a) in a rnanner that is consistent with the Settlement Agreement and purposes above described and (b) is ordered by the Court.

6. Trustee A. Initial Trustee. The initial Trustee of the Trust shall be Kent Saxby, lst Avenue East, P.O. Box 3038 Kalispell, MT 59903 (hereinafter referred to as the "Trustee").

B. Management of the Corpus of the Trust. The Trustee shall be empowered to manage the corpus of the Trust as it appears advisable in order to effectuate the purposes of the Trust. This authority shall include, but not be limited to, the investment of the monetary assets of the Trust and earnings thereon, if any, in one or more money market accounts which shall be treated as a single fund

Exhibit H006 without distinction between principal and income. For purposes of this paragraph, "money rnarket accounr shall mean a money fund whose objectives are current incorne consistent with liquidity and low risk, the maintenance of a portfolio of high quality, short-terrn rnoney rnarket instrurnents, and maintenance of a constant $1.00 net asset value per share. All investments shall be rnade so as to at all times provide sufficient liquidity to meet the anticipated cash needs of the Insured Claims Qualified Settlement Fund Trust. Subject to the goal of rnaintaining adequate liquidity, the Trustee may invest some of the rnonetary assets of the Trust, in the sole discretion of the Trustee, in high quality, low risk investments, such as United States Treasury bills and other United State Government-backed securities. Medium risk, high risk, or speculative investrnents are expressly prohibited.

C. Continuing Jurisdiction of Court. The Court shall have continuing jurisdiction of the administration of the Trust and the performance of trust duties by the Trustee. In order to enable the Court to exercise its continuing jurisdiction, the Trustee shall report to the Court once every six rnonths on an accounting of Trust assets and payments, including amounts maintained in order to pay any liens and specifically Medicare and/or Medicaid liens, including arnounts set forth in final demand letters from Medicare and Medicaid. The reports prepared by the

Exhibit H007 Trust for the Court shall also be provided in electronic format to the Insured Claimants' counsel.

7. Express Powers of Trustee. Without in any way limiting the power and discretion conferred upon the Trustee by the other provisions of the Trust or by law, the Trustee is expressly authorized and ernpowered as hereinafter set forth: A. Payment ofExpenses ofAdministration. To incur and pay any and all charges, taxes, and expenses upon or connected with the Trust in the discharge of its fiduciary obligations under the Trust. All such payments shall be made using the assets of the Trust.

B. Retention ofProperty. To hold and retain all or any part of the Trust in the forrn in which the sarne may be at the time of the receipt by the Trustee, as long as it shall deem advisable, and without any liability for any loss of principal or income by reason of such retention.

C. Preservation ofPrincipal. Notwithstanding any other provision in the Trust, to at all times hold, manage, invest, and reinvest the assets of the Trust in a manner designed to preserve the accrued income and principal of the Trust for the purposes of the Trust.

D. Retention of Investment Advisor and Other Consultants. To engage the services of (and pay compensation to) an investment advisor, accountants,

Exhibit H008 agents, managers, counsel, or other consultants with respect to the management of investments ofthe Trust, the management of the Trust, or any other matters.

E. Execution ofDocuments of Transfer. To rnake, execute, acknowledge, and deliver any and all documents of transfer and conveyance and any and all other instruments that may be necessary or appropriate to carry out the powers herein granted.

F. Resolution of Claims. The Trustee is authorized to resolve claims pursuant to the terms of Trust Distribution Procedures that are approved by the Court, and to exercise all decisions, claim acceptance, and discretion described therein, including with respect to proof of claim requirements, exceptional clairn valuation, and setting and adjustment of a payrnent percentage. The Trustee shall assurne and fulfill all requirements of the Settlement Agreement, including provisions for indemnity of insurers and releases by claimants.

G. Resolution of Reimbursement Claims and Liens. The Trustee is authorized to negotiate and compromise Medicare liens or reimbursement claims and Medicaid liens or reimbursement clairns on an individual-by-individual Clairnant basis. No payrnent from the Trust to an individual Claimant shall be made until all Medicare and Medicaid liens or reimbursement claims with respect to that individual Claimant are identified and such liens or reimbursement claims with respect to that individual Insured Clairnant have been satisfied or resolved in

Exhibit H009 writing by the appropriate state or federal agency. The Trustee shall require, as a condition of any payrnent to an Insured Claimant, that such Claimant provide all necessary information to fulfill any Medicare and/or Medicaid reporting obligations.

H. Litigation. Upon obtaining approval of the Court, to institute and defend litigation in the narne of the Trust.

I. Execution of Contracts and Agreements. At the direction of the Court, to make, execute, acknowledge, and deliver any and all contracts or agreements on behalf of the Trust. Such agreernents may include settlement agreements and qualified assignment agreernents to effectuate settlements governed by sections 104(a)(2) and 130 of the Internal Revenue Code of 1986, as amended.

J. Discretion in Exercise of Power. To do any other acts that it deerns proper to effectuate the purpose hereof and to exercise the powers specifically conferred upon it by the Trust.

8. Advice of Counsel. The Trustee rnay from tirne to tirne consult with counsel with respect to any question arising as to compliance with this Trust. The Trustee shall be fully protected, to the extent permitted by law, in acting in reliance upon the advice of counsel.

9. Trustee Compensation & Expenses. The Trustee, and any successor Trustee, shall receive payment for services in accordance with the Trustee's

Exhibit H010 schedule of rates in effect at the time such cornpensations becornes payable, without reduction for any other fees or other cornpensation paid to consultants or others, except to the extent required by applicable law. The Trustee's cornpensation may be paid by the Trust, from the Trust funds, without Court approval. The Trustee shall be reirnbursed for reasonable expenses, including travel expenses reasonably required and incurred by such Trustee in the performance of the Trustee's duties.

10. Successor Trustees.

A. Vacancy Caused by Resignation or Removal. The Trustee rnay resign as Trustee of any trust hereunder at any time by written notice delivered to the Court with continuing jurisdiction over this Trust. Such resignation shall be effective upon the written appointment of a successor Trustee. The Court shall have the power to appoint a successor Trustee. In default of such appointment, the Trustee shall petition the Court to appoint it successor. All of the Trustee's fees and expenses (including reasonable attorneys' fees) attributable to the appointment of a successor Trustee shall be paid by the Trust. No bond or other security shall be required of the Trustee or successor Trustee in any jurisdiction. Any successor Trustee shall have the sarne powers, authorities, and discretion as though originally narned as the Trustee.

Exhibit H011 B. Acceptance of Appointtnent of Successor Trustees. Acceptance of appointment of a successor Trustee shall be in writing and shall become effective upon receipt by the Court of notice of such acceptance. Upon the acceptance of appointment of any successor Trustee, title to the Trust shall thereupon be vested in said successor Trustee without the necessity of any conveyance or instrument.

Each successor Trustee shall have all the rights, powers, duties, authority, and privileges as it initially narned as a Trustee hereunder.

C. Preservation of Record of Changes to Trustees. A copy of each instrument of resignation, rernoval, appointment, and acceptance of appointment shall be attached to an executed counterpart of the Trust in the custody of the Court.

11. Indemnity. Each Trustee, whether initially named or appointed as successor Trustee, acts as a Trustee only in that capacity and not personally. With respect to any contract, obligation, or liability rnade or incurred by the Trustees, or any of them hereunder in good faith, all persons shall look solely to the Trust and not the Trustees personally. The Trustees shall not incur any liability, personal or corporate, of any nature in connection with any act or omission, of the Trustees in the administration of the Trust or otherwise pursuant to the Trust; except for any liability arising from gross negligence or intentional tortious or criminal acts such as fraud or theft. The Trustees initially named, or appointed as successor Trustees

Exhibit H012 by a Court, shall be indemnified and held harrnless by the Trust. This indemnification and hold harmless provision shall cover all expenses reasonably incurred by such Trustee in defense of the aforementioned acts or ornissions of the Trustee, including, but not limited to, reasonable attorney fees and costs. Except for the payment of all expenses reasonably incurred, this indemnification shall not apply to any liability arising frorn a crirninal proceeding or acts where the Trustee had reasonable cause to believe that the conduct was unlawful.

12. Interpretation and Definitions. As used in the Trust, words in the singular include the plural and words in the plural include the singular and rnasculine and neuter genders shall be deerned to include the masculine, feminine, and neuter. The description heading for each Section and Subsection of the Trust shall not affect the interpretation or the legal efficacy of the Trust. It is agreed the neither the act of entering into the Trust nor any contribution to the Trust nor any action taken under the Trust shall be deemed to constitute an admission of any liability or fault on the part of the Trustees, the Grantors, or the State, nor does it continue a commitment or agreement, either expressed or implied, by any or all of thern to undertake any further activities outside the scope of the Trust. The following capitalized terms shall have these meanings: A. "Insured Claimant" shall mean an individual with a personal injuly claim against Robinson Insulation Company and/or Grogan Robinson Lumber

Exhibit H013 Cornpany which claim alleges an occurrence within period of insurance coverages beginning Decernber 20, 1971, and ending May 28, 1986.

B. "Receiver" shall mean the Court-appointed Receiver for the dissolved entities Robinson Insulation Cornpany and Grogan Robinson Lumber Company.

C. "Settlement Agreemear shall mean the attached Exhibit 1.

D. The terms "Robinson Entities," "Grogan Entities," "Claims," "Insurers" and "Policies" shall have the meanings defined in the Settlement Agreement.

13. Choice of Law. This Trust shall be administered, construed, and enforced according to the laws of the State of Montana.

DATED this im day of ,2020

Kent Saxby, Trustee

Exhibit H014