TWENTY SECOND JUDICIAL DISTRICT COURTPARISH OF WASHINGTONSTATE OF LOUISIANANO.DIVISIONTERRAL EVANS, DANA EVANS, CHARLES BLANCHARD AND SHANNONWILLIAMSVERSUSTIN, INC. d/b/a TEMPLE INLANDFILED _________________________________________________________________ DEPUTY CLERK CLASS ACTION PETITION FOR PERMANENT INJUNCTIVE RELIEF and CLASSDAMAGES COMMON TO ALL SIMILARLY SITUATED CLAIMANTS

Plaintiffs: Terral Evans, Dana Evans, Charles Blanchard and Shannon Williams, make thefollowing allegations for class action relief for injunctive relief and damages common to all similarlysituated claimants against the Defendant, TIN, Inc. d/b/a Temple Inland for the following clear and present danger caused by the actions of the defendant.

Plaintiffs, all of the full age of majority, appear herein individually and as members of the proposed class and represent those persons similarly situated, who are property owners along the PearlRiver; and who were upon information and belief affected by the black liquor spill into the PearlRiver by the Defendant, affecting the enjoyment of the property of the plaintiffs and others owning property along the waterways and lakes in Louisiana and its borders with Mississippi; and who havesustained physical, mental and/or emotional injuries, fright, inconvenience, personal and medicalexpenses, and interruption of or intrusion into their personal and/or professional lives as a directconsequence of spill(s) occurring at the Bogalusa facility on or about August 9, 2011, and thereafter as the same are also common to similarly situated claimants.

II.

Defendant, TIN, Inc. d/b/a/ Temple Inland, is a foreign corporation, organized under the lawsof the State of Texas, and qualified to do and doing business in the State of Louisiana, Parish of Washington, which, at all times material hereto, owned land along tributaries flowing into the PearlRiver, and which operated, maintained, managed and had custody and control of the facility located

in the Parish of Washington, Louisiana, locally known and sometimes referred to as “the BogalusaPaper Mill”; and at which facility on or about August 9, 2011, and thereafter experienced a spill(s)of a substance hazardous and caused damages as alleged to the plaintiffs and a substantial number of residents located within all areas of the Pearl River, thereby violating the limitations on use of property set out in La. C.C. Arts. 667 and 2315.

III.

Venue is proper within the Parish of Washington, Louisiana under Louisiana Code of CivilProcedure Articles 42 and 74.

IV.

The above Defendant is indebted unto your petitioners and the class jointly and in solido for a sum of money found to be reasonable in the premises, together with legal interest from the date of judicial demand, for all costs of these proceedings, and for all other general and equitable relief asmay be afforded by this Honorable Court, for the following reasons:

This is a class action instituted pursuant to the provisions of Article 591,

et seq.

, of theLouisiana Code of Civil Procedure by the petitioners on their own behalf and as members of the classof all persons and/or other entities affected by the Defendant’s actions and who or which havesustained damages arising or resulting from the spill(s) of the hazardous substance, all of whichoccurred on or about August 9, 2011 and thereafter, and on information and belief continues unabatedthrough the flows of the Pearl River.

VI.

Petitioners are entitled to have this cause maintained as a class action pursuant to LouisianaCode of Civil Procedure Article 591,

et seq.

, for the following reasons:a)The persons or entities constituting the class are so numerous that the individual joinder of all parties is impractical; b)There are common questions and issues of law and fact involved in this matter which predominate over questions affecting individual class members;c)There exists a common character among the rights sought to be enforced on behalf of the classamong the named class representatives of the class, are all members of the class and are so

situated so as to provide adequate representation for the unnamed class members;d)The named plaintiffs or representatives of the class are all members of the class of propertyowners and individuals and are so situated so as to provide adequate representation for theunnamed class members;e)The claims of the representative parties are typical of the claims of the class members theyseek to represent;f)The class may be defined objectively in terms of ascertainable criteria, such that the Courtmay determine the constituency of the class for purposes of the conclusiveness of any judgment that may be rendered in this case;g)The great majority of the unnamed class members have no substantial interest in individuallycontrolling the prosecution of their separate actions;h)The prosecution of separate actions by individual members will create a serious risk of inconsistent or varying adjudications which may prejudicially effect the claims of other classmembers in subsequent litigation;i)The prosecution of separate actions by individual members of the class will create a seriousrisk of inconsistent or varying adjudications with respect to individual members of the classwhich would establish incompatible standards of conduct for the parties opposing the class; j)The prosecution of separate actions by the individual class members poses the risk thatseparate adjudications respecting individual claimants would not be entirely dispositive of theinterests of class members not parties to the litigation or would otherwise substantially impair or impede the ability to the class members to protect their interests;k)Any defenses or theories of resistance to liability propounded by the defendants would beapplicable to all claims presented by the members of the class;l)The class action is a superior procedural vehicle for this litigation because the primaryobjectives of the class action are economies of time, effort and expense, will be achieved principally because:1)Question of law or fact common to the class members predominate over questionsaffecting only individual members;2)Any defenses would be generally applicable to all members of the class;