Bestwall - Debtor's Motion To Set Date For Substantial Completion of Document Production, Which Includes Discovery Responses by Bestwall

Case 17-31795 Doc 1841 Filed 06/28/21 Entered 06/28/21 22:12:50 Desc Main
Document Page 1 of 88
UNITED STATES BANKRUPTCY COURT

WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
IN RE:
Case No. 17-BK-31795 (LTB)
1
BESTWALL,
Chapter 11
Debtor.
DEBTOR’S MOTION TO SET DATE

FOR SUBSTANTIAL COMPLETION OF DOCUMENT PRODUCTION
Bestwall LLC (“Bestwall” or the “Debtor”), the debtor and debtor in possession in the
above-captioned chapter 11 case (the “Chapter 11 Case”), moves this Court to set the date on or
before which the Debtor shall substantially complete its production of documents in response to
the First Set of Requests for Production of Documents (the “Requests”) served by the official
committee of asbestos personal injury claimants (the “Committee”) and Sander L. Esserman,
the legal representative for future asbestos claimants (the “FCR” and, together with the
Committee, the “Claimants’ Representatives”).
Paragraph 2 of the Joint Discovery Plan and Report (ESI Protocol) (the “Discovery
Plan”), which is Exhibit 1 to the Case Management Order for Estimation of the Debtor’s
Liability for Mesothelioma Claims [Dkt. 1685], sets a default date for substantial completion of
production, calls for the parties to meet and confer regarding the practicality of that date, and,
failing agreement about any adjustment thereof, authorizes the responding party to move the
Court to set the date.
The Debtor has met and conferred with the Claimants’ Representatives no fewer than
seven times regarding the breadth of the Requests, the effort and resources that the Debtor has
1
The last four digits of the Debtor’s taxpayer identification number are 5815. The Debtor’s address is 133 Peachtree
Street, N.E., Atlanta, Georgia 30303.
deployed to review and produce responsive documents, and the Debtor’s best estimates of the
time required to do so. Despite this, no agreement was reached to reset the date from the default
date of June 29, 2021. The Claimants’ Representatives today declined to confirm their
agreement to the Debtor’s proposed substantial completion dates.
The Debtor now moves this Court to set these dates for substantial completion of
production: July 12, 2021, for electronically stored information (“ESI”) of identified custodians;
and July 29, 2021, for hardcopy documents collected from those custodians.
The Requests
1. On April 15, 2021, the Claimants’ Representatives served their Requests. See
Requests (attached as Exhibit A). They numbered 45. They broadly seek document in the files
of any “agents, employees, officers, directors, representatives,” and other individuals associated
with the Debtor or with the former Georgia-Pacific LLC (“Old GP”), see Ex. A at Definition 5,
which documents, dated from January 1, 2011 to present, relate to the defense and resolution of
asbestos claims pursued against Bestwall and Old GP. Ex. A at Instruction 1; see also, e.g.,
Requests 7 (“All Documents concerning or related to the GP Entities’ use of verdict history of
GP Entities and/or non-GP Entities in the decisions to litigate each Resolved Mesothelioma
Claim that it tried to verdict or settled.”); 8 (“All Documents constituting, referring to, relating
to, or concerning any analysis or valuation of the nature, extent and/or value of the GP Entities’
liabilities on Gypsum Asbestos PI Claims.”); 11 (“All Documents constituting, referring to,
relating to, or concerning whether exposure to GP Joint Compound Products does or does not
contribute to the development of mesothelioma.”). They also seek every document in thousands
of litigation claims files maintained by any number of some 190 outside defense firms. See
Request 1 (“All Documents concerning the identified Sample Resolved Mesothelioma Claims,
-2-
including, but not limited to claims files, litigation files, or similar files.”); see also Requests 3,
4, 5, 6, 14, 15, 16.
2. The 15 custodians from whom ESI and hardcopy documents are to be collected
and produced are 11 lawyers, 3 paralegals, and 1 litigation support assistant; all are current or
former members of Old GP’s and/or Bestwall’s legal staff; one (now deceased) most recently
served as an outside defense attorney. See Debtor’s Initial Disclosures in Connection with
Estimation Proceeding, attached as Exhibit B, at ¶¶ a.1–15. The identity and roles of the
custodians and the privilege and work product protections afforded to the bulk of their
communications, of necessity, calls for the dedication of additional effort and resources to
privilege review and, therefore, additional time to identify and produce that which is not
privileged and to log that which is.
3. From the date the Claimants’ Representatives served these Requests through the
date of this filing, the Debtor has taken steps to collect, review, and produce responsive
documents as swiftly and efficiently as practicable. The Debtor has engaged capable vendors,
fielded and deployed a team of initially 20 and now 43 contract lawyers and multi-firm second-
level/privilege reviewers, and harnessed available computer-assisted review software and other
technological assistance.
4. The Debtor repeatedly has updated the Claimants’ Representatives of the status of
review, collection, and production efforts and has addressed their questions and concerns in real
time. Those updates confirm that the Debtor is working as efficiently and as expeditiously as is
practicable. The Debtor now requests a modest move of the substantial completion date by no
more than roughly 30 days.
-3-
The Discovery Plan
5. The Discovery Plan provides that productions of documents in response to the
Requests “shall commence within 30 days of service of the Requests to the Party responding to
the Requests . . . and, subject to the following sentence, be substantially completed within 75
days of service of the Requests.” Discovery Plan at ¶ 2. This default date for substantial
completion of production of documents in response to the Requests served on April 15, 2021,
therefore, would be June 29, 2021.
6. The following sentence in the Discovery Plan, however, starts the explanation of
the method by which an alternative substantial completion date would be set: “Within 14 days of
service of Requests, the Parties shall meet and confer regarding the propriety of the 75-day
deadline for substantial completion of production in response to such Requests. If the Parties
agree to a modification of the deadline, the deadline shall be changed in accordance with the
Parties’ agreement.”
7. The paragraph then prescribes the method of setting the substantial completion
date in the absence of agreement: “If the Parties are unable to reach an agreement, the Party
requesting a change may ask the Court, by motion, to set the substantial completion deadline.”
8. The parties met and conferred within 14 days of the service of the Requests; as
noted below, the Debtor informed the Claimants’ Representatives then and thereafter that the
breadth of the Requests meant that substantial completion within 75 days was unlikely; and
the Debtor provided estimated alternative substantial completion dates as promptly as collection,
review, and production facts would permit.
-4-
The Debtor’s Diligence
9. After initial review and assessment of the 45 Requests, the Debtor met and
conferred with the Claimants’ Representatives on April 29, 2021. See April 30, 2021 Email from
J. Jones to S. Zieg, et al. (attached as Exhibit C). The Debtor informed the Claimants’
Representatives that “the breadth of the requests and our current read of the data to be reviewed
will make substantial completion of production within 75 days of service of the requests more
than materially challenging.” Id.
10. The Debtor’s messaging on substantial completion remained consistent: “[W]e
do not anticipate currently that substantial completion of our collection, review and production of
documents responsive to the [Requests] can be accomplished practicably within 75 days of the
service[.]” See May 6, 2021 Email from J. Jones to S. Zieg et al. (attached as Exhibit D).
11. The Debtor, nonetheless, served its written responses and objections to the
Requests and made its first rolling production of documents on May 17, 2021, as called for by
the Discovery Plan. See Bestwall’s Responses and Objections to ACC and FCR’s First Requests
for Production of Documents (attached as Exhibit E); May 17, 2021 Production Cover Email
from D. Schneider to S. Zieg, et al. (attached as Exhibit F).
12. As noted, the parties have met and conferred on the status of, developments in,
and timeline for the Debtor’s document collection, review, and production no fewer than six
more times after April 29, 2021. Included in those sessions, the Debtor has shared data that
substantiates the breadth and burden of the project and, therefore, the implausibility of
completion on or before June 29, 2021.
13. Some of the relevant numbers are as follows: the Debtor has collected over
580,000 custodial ESI documents; after application of search terms, that corpus of documents
-5-
totaled approximately 200,000;2 the Debtor has collected over 200 boxes of hard-copy
documents, which require scanning and processing before commencing review; the first-level
review team of 43 contract attorneys has tagged approximately 90% of responsive documents as
privileged attorney-client communications or attorney work product, at least in part, which
tagging requires increased scrutiny to assess and confirm privilege determinations and
necessarily requires additional review time. See May 27, 2021 Email from J. Jones to S. Zieg, et
al. (attached as Exhibit G); see also June 24, 2021 Email from J. Jones to S. Zieg, D. Wright, et
al. (attached as Exhibit H).
14. The Debtor provided to the Claimants’ Representatives estimated dates for
substantial completion of production on June 16, 2021, and reiterated/updated its estimates on
June 23, 2021, during the most recent meeting between the parties. See June 17, 2021 Email
from J. Jones to S. Zieg, et al. (attached as Exhibit I) (estimating July 11, 2021, and July 29,
2021, respectively, as substantial completion dates for custodial ESI and hardcopy); Ex. H
(estimating “on or before July 12 and July 29, respectively, or no more than 30 days after the
default substantial completion date set out in our Discovery Plan”).
15. The Debtor excluded from its estimates (a) the custodial ESI of the
aforementioned deceased outside counsel the collection of which from her former law firm
initially met with technical complications that the Debtor now has nearly overcome; and (b)
documents from the approximately 2,700 claims identified to be a part of the Claimants’
Representatives’ definition of “Sample Resolved Mesothelioma Claims” on May 27, 2021. The
Debtor is hopeful that the custodial ESI of its former outside counsel will be fully collected and
2
As the Debtor has shared with the Claimants’ Representatives, it continues to assess the extent to which a shared
drive used by the legal department does or does not contain responsive, non-privileged, and non-duplicative
documents but currently does not anticipate that this assessment will affect its ability to meet the proposed
substantial completion dates.
-6-
available for review yet this week and will work to complete that review as promptly as
practicable. The 2,700 claims files were only identified to the Debtor on May 27, 2021. The
requests for documents from these files are the subject of ongoing meet-and-confer negotiations
and are not the subject of this Motion.3
16. Despite the extensive collection, review, and production efforts described above
and the equally extensive meet-and-confer program detailed in the attached correspondence, the
Claimants’ Representatives have declined to agree that July 12, 2021, and July 29, 2021, are
appropriate dates for the substantial completion of production.
17. The Debtor, therefore, moves this Court to set those dates and attaches as
Exhibit K a proposed order granting this relief.
3
Requests 1, 3, 4, 5, 6, 14, 15, and 16 seek the claims file documentation for “Sample Resolved Mesothelioma
Claims,” which term was undefined when the Claimants’ Representatives served their Requests. On May 27, 2021,
42 days after service of the Requests, they defined the term to include claims from 2,907 claimants. Approximately
200 of those claimants’ files are known to be unavailable, and the Debtor already produced to the Claimants’
Representatives those documents from 2,200 of those files that were provided to the Debtor’s estimation expert
Charles Bates, Ph.D. See March 31, 2021 Letter from S. Pratt (attached as Exhibit J). The default substantial
completion date for production of the balance of the claim file documents sought in these Requests, determined from
adding 75 days to the date the Claimants’ Representatives informed the Debtor of the meaning of the term, is August
10, 2021. As the attached correspondence reflects, the Debtor already has engaged the Claimants’ Representatives
on the disproportionate burden imposed by these Requests, ways that burden might be addressed and mitigated, and
substantial completion of any production in response.
-7-
Dated: June 28, 2021 Respectfully submitted,

Charlotte, North Carolina
/s/ Garland S. Cassada
Garland S. Cassada (NC Bar No. 12352)
Richard C. Worf, Jr. (NC Bar No. 37143)
ROBINSON, BRADSHAW & HINSON, P.A.
101 North Tryon Street, Suite 1900
Charlotte, North Carolina 28246
Telephone: (704) 377-2536
Facsimile: (704) 378-4000
E-mail: gcassada@robinsonbradshaw.com
rworf@robinsonbradshaw.com
Gregory M. Gordon (TX Bar No. 08435300)

JONES DAY
2727 North Harwood Street, Suite 500
Dallas, Texas 75201
Telephone: (214) 220-3939
Facsimile: (214) 969-5100
E-mail: gmgordon@jonesday.com
(Admitted pro hac vice)
Jeffrey B. Ellman (GA Bar No. 141828)

JONES DAY
1221 Peachtree Street, N.E., Suite 400
Atlanta, Georgia 30361
Telephone: (404) 581-3939
Facsimile: (404) 581-8330
E-mail: jbellman@jonesday.com
ATTORNEYS FOR DEBTOR AND DEBTOR

IN POSSESSION
-8-
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EXHIBIT B

CHARLOTTE DIVISION
In re Chapter 11
BESTWALL LLC,1 Case No. 17-31795

Debtor.
DEBTOR’S INITIAL DISCLOSURES

IN CONNECTION WITH ESTIMATION PROCEEDING
Bestwall LLC (“Bestwall” or the “Debtor”) makes the following initial disclosures
(“Initial Disclosures”) pursuant to paragraph 3 of the Case Management Order for Estimation of
the Debtor’s Liability for Mesothelioma Claims (Dkt. 1685) (the “CMO”) concerning the
Estimation Proceeding (as defined in the CMO).
These Initial Disclosures reflect the Debtor’s good faith effort to respond to the items
described in paragraphs 3(a) through 3(d) of the CMO based on the Debtor’s investigation of
information reasonably available to it as of this date. The Debtor expressly reserves the right to
amend or supplement these Initial Disclosures in accordance with Rule 26(e) of the Federal
Rules of Civil Procedure (the “Civil Rules”), as made applicable by Rule 9014 of the Federal
Rules of Bankruptcy Procedure, to include information obtained through the course of further
investigation.
The Debtor’s disclosure of the individuals and other potential document sources
identified below does not constitute a waiver of its right to assert that collection and production
of documents from such individuals and sources is not proportional to the needs of the case
1
The last four digits of the Debtor’s taxpayer identification number are 5815. The Debtor’s
address is 133 Peachtree Street, N.W., Atlanta, Georgia 30303.
under Civil Rule 26(b)(1) and therefore not proper under the Civil Rules. The Debtor also
provides these Initial Disclosures without waiver of or prejudice to (i) any claim of privilege or
immunity, including, but not limited to, the attorney-client privilege, work product protection, or
any other basis for non-disclosure, or (ii) any objection to the use or admissibility of any
evidence on the grounds of relevance, competency, privilege, work product, hearsay, or any
other proper ground. The Debtor further reserves the right to object to any discovery request,
even if directed to the subject matters described herein.
a. Custodians
Pursuant to paragraph 3(a) of the CMO, the Debtor identifies below the 15 custodians
most likely to have, or have had, discoverable information in their possession, custody, or control
and provides their names, titles, and roles related to the Debtor’s asbestos-related personal injury
claims and the nature and types of information that is or was in their possession, custody, or
control. Since the commencement of the Debtor’s bankruptcy case on November 2, 2017 (the
“Petition Date”), some of the individuals identified below have retired, no longer work for the
Debtor or its affiliates, including Georgia-Pacific, LLC (“New GP”), or have different roles than
they did before the Petition Date. For the individuals listed below (in alphabetical order), the
information provided concerns their roles related to the Debtor’s asbestos-related personal injury
claims before the restructuring of Old GP in 2017.2
1. Melissa Baugher – Senior Counsel; member of Old GP asbestos litigation group.
Hard copy documents and electronically stored information (“ESI”) regarding: the management,
defense, and settlement of asbestos-related personal injury claims; asbestos exposures
attributable to other defendants, including bankrupt defendants and related trusts, and various
2
“Old GP” refers to the former Georgia-Pacific LLC that ceased to exist on July 31, 2017.
2
legal issues associated with such exposures; analysis or valuation of Old GP’s aggregate future
costs for asbestos claims; sales of asbestos-containing joint compound; and allegations of
asbestos contamination in talc.
2. Melissa Brown – Chief Counsel Legislative Legal Affairs; member of Old GP
litigation group. Hard copy documents and ESI regarding: asbestos exposures attributable to
other defendants, including bankrupt defendants and related trusts, and various legal issues
associated with such exposures.
3. John Childs – Assistant General Counsel, Litigation; head of Old GP litigation
group, including asbestos litigation group. Hard copy documents and ESI regarding: the
management, defense, and settlement of asbestos-related personal injury claims; asbestos
exposures attributable to other defendants, including bankrupt defendants and related trusts, and
various legal issues associated with such exposures; analysis or valuation of Old GP’s aggregate
future costs for asbestos claims; sales of asbestos-containing joint compound; and allegations of
asbestos contamination in talc.
4. Tye Darland – Senior Vice President - General Counsel and Secretary; head of
Old GP law department with managerial oversight and responsibility for litigation group,
including asbestos group. Hard copy documents and ESI regarding: the management, defense,
and settlement of asbestos-related personal injury claims; asbestos exposures attributable to other
defendants, including bankrupt defendants and related trusts, and various legal issues associated
with such exposures; and analysis or valuation of Old GP’s aggregate future costs for asbestos
claims.
5. Karl Eichelberger – Senior Counsel; member of Old GP asbestos litigation group.
Hard copy documents and ESI regarding: the management, defense, and settlement of asbestos-
related personal injury claims; asbestos exposures attributable to other defendants, including
3
bankrupt defendants and related trusts, and various legal issues associated with such exposures;
sales of asbestos-containing joint compound; and allegations of asbestos contamination in talc.
6. Brenda Godfrey – Senior Counsel; member of Old GP asbestos litigation group.
7. Shannon Harris – Senior Counsel; member of Old GP asbestos litigation group.
8. Terence Hatcher – Litigation Support Assistant; member of Old GP asbestos
litigation group. Hard copy documents and ESI regarding: reports, procedures, and processes
supporting the management, defense, and settlement of asbestos-related personal injury claims.
9. Wade Marionneaux – Senior Counsel; member of Old GP asbestos litigation
group. Hard copy documents and ESI regarding: the management, defense, and settlement of
asbestos-related personal injury claims; asbestos exposures attributable to other defendants,
including bankrupt defendants and related trusts, and various legal issues associated with such
exposures; sales of asbestos-containing joint compound; and allegations of asbestos
contamination in talc.
10. Kristine Meeks – Paralegal; member of Old GP asbestos litigation group. Hard
copy documents and ESI regarding: reports, procedures, and processes supporting the
management, defense, and settlement of asbestos-related personal injury claims.
4
11. Joel Mercer – Chief Counsel; head of Old GP asbestos litigation group. Hard copy
documents and ESI regarding: the management, defense, and settlement of asbestos-related
personal injury claims; asbestos exposures attributable to other defendants, including bankrupt
defendants and related trusts, and various legal issues associated with such exposures; analysis or
valuation of Old GP’s aggregate future costs for asbestos claims; sales of asbestos-containing
joint compound; and allegations of asbestos contamination in talc.
12. Stacy Norris – Paralegal; member of Old GP asbestos litigation group. Hard copy
documents and ESI regarding: reports, procedures, and processes supporting the management,
defense, and settlement of asbestos-related personal injury claims.
13. Rob Stonebraker – Senior Counsel; member of Old GP asbestos litigation group.
14. Sara Turnipseed (deceased) – in-house counsel at Old GP (1983-1996), with
responsibility for asbestos litigation; partner at Nelson Mullins working on Old GP asbestos
litigation matters (1996-2013), including as National Coordinating Counsel (1996-2005). Hard
copy documents and ESI regarding: the management, defense, and settlement of asbestos-related
personal injury claims; asbestos exposures attributable to other defendants, including bankrupt
defendants and related trusts, and various legal issues associated with such exposures; analysis or
valuation of Old GP’s aggregate future costs for asbestos claims; sales of asbestos-containing
joint compound; and allegations of asbestos contamination in talc.
15. Debbie Young – Paralegal; member of Old GP asbestos litigation group. Hard
copy documents and ESI regarding: reports, procedures, and processes supporting the
5
management, defense, and settlement of asbestos-related personal injury claims; and the analysis
or valuation of Old GP’s aggregate future costs for asbestos claims.
b. Non-Custodial Data Sources
Pursuant to paragraph 3(b) of the CMO, the Debtor identifies below the non-custodial data
sources that are most likely to contain non-duplicative discoverable information:
1. Relativity database of historic sales records housed at Troutman Pepper eMerge.
2. Claims management system housed at and maintained by PACE.
3. E-billing database housed at and maintained by Mitratech/Acuity.
4. Matter management database housed at and maintained by Mitratech/Acuity.
5. Repository containing limited and selected litigation-related documents housed at
and maintained by Mitratech/Acuity.
c. Shared Repositories and Drives
Pursuant to paragraph 3(c) of the CMO, the Debtor identifies below the shared repositories,
shared databases, and shared drives reasonably likely to contain discoverable documents or
communications:
1. Two shared drives (G and Q) at New GP that have sub-folders containing
historical asbestos litigation management materials and correspondence created and compiled by
counsel and paralegals for Old GP and the Debtor in the course of litigation.
2. Concordance database containing facts and analysis pertaining to some asbestos
claims submitted to Old GP under administrative settlement agreements.
d. Asbestos Containing Products
Pursuant to paragraph 3(d) of the CMO, the Debtor provides the information below about
the asbestos-containing joint compound products manufactured and sold on or before
6
December 31, 1977 by Old GP or Old Bestwall,3 which products are the subject of the
Estimation Proceeding. For the sake of clarity, the Debtor states that beginning in 1973, some of
the products listed below were manufactured and sold with an asbestos-free formulation during
the same years that such products were manufactured and sold with an asbestos-containing
formulation.
Year First Year Last

Years
Manufacturing Sold by Sold by
Other Product Manufactured Type and Use of
Product Facilities Old GP or Old GP
Name(s) Containing Product
Locations Old Before
Asbestos
Bestwall 1/1/78
All Purpose N/A 1957-1977 Dry powder Acme, TX 1957 1977
Joint mixed with water Akron, NY
Compound and used to cover Chicago, IL
seams and nail Marietta, GA
holes and to
finish wallboard
walls/ceilings
Bedding N/A 1956-1977 Dry powder Acme, TX 1956 1977
Compound mixed with water Akron, NY
and used to cover Chicago, IL
holes and to
finish wallboard
walls/ceilings
Central Mix N/A 1970-1973 Dry powder Acme, TX 1970 1973
mixed with water Marietta, GA
and used to cover
seams and nail
holes and to
finish wallboard
walls/ceilings
Ready Mix N/A 1963-1977 Ready to use Acme, TX 1963 1977
paste used to Akron, NY
cover seams and Brunswick, GA
nail holes and to Chicago, IL
finish wallboard Ft. Dodge, IA
walls/ceilings Marietta, GA
Milford, VA
Sigurd, UT
3
“Old Bestwall” refers to the former Bestwall Gypsum Company, which was incorporated July
1, 1956.
7
Year First Year Last

Years
Manufacturing Sold by Sold by
Other Product Manufactured Type and Use of
Product Facilities Old GP or Old GP
Name(s) Containing Product
Locations Old Before
Asbestos
Bestwall 1/1/78
Joint Joint System 1956-1975 Dry powder Acme, TX 1956 1975
Joint System and used to cover Chicago, IL
Cement seams and nail Marietta, GA
holes and to
Joint System finish wallboard
Compound walls/ceilings
Speed One Day 1963-1973 Dry powder Acme, TX 1963 1973
Set/One (1963-Jan. mixed with water Blue Rapids,
Day 1970) and used to cover KS
seams and nail
Speed Set holes and to
(beginning Jan. finish wallboard
1970) walls/ceilings
Topping N/A 1956-1977 Dry powder Acme, TX 1956 1977
and used to cover Chicago, IL
holes and to
finish wallboard
walls/ceilings
Triple Duty Triple Duty 1965-1977 Dry powder Acme, TX 1965 1977
Joint Wallboard mixed with water Akron, NY
Compound Joint and used to cover Chicago, IL
Compound seams and nail Marietta, GA
holes and to
Triple Duty finish wallboard
Joint walls/ceilings
Compound-
Vinyl Based
Adhesive
8
Dated: April 15, 2021 Respectfully submitted,

Stuart L. Pratt (NC Bar No. 43139)
Telephone: (704) 377-2536
Facsimile: (704) 378-4000

JONES DAY
Dallas, Texas 75201
Telephone: (214) 220-3939
Facsimile: (214) 969-5100

JONES DAY
Telephone: (404) 581-3939
Facsimile: (404) 581-8330
Cary Ira Schachter (TX 17719900)

Raymond P. Harris, Jr. (TX 09088050)
Erin A. Therrian (TX 24072524)
SCHACHTER HARRIS, LLP
909 Lake Carolyn Parkway, Suite 1775
Irving, Texas 75039
Telephone: (214) 999-5700
E-mail: cschachter@shtriallaw.com
rharris@shtriallaw.com
etherrian@shtriallaw.com

IN POSSESSION
9
EXHIBIT C
From: Jones, James M.

Sent: Friday, April 30, 2021 5:16 PM
To: Ramsey, Natalie D.; Sharon Zieg; Gordon, Gregory M.; Ellman, Jeffrey B.; Blake, Rebekah
E.; Garland Cassada (GCassada@rbh.com); Wright, Davis L.; Edwin J. Harron; Edwards,
Erin; Bradley, Elisabeth; Del Medico, Jennifer L.; Kaplan, Jeff A.; Schneider Richard (King
& Spalding - Atlanta, GA)
Subject: Bestwall: Follow-Up on Meet-and-Confer Concerning Document
Collection/Review/Production
Attachments: 1517996480_2_Bestwall -- Search Terms.DOCX
All: Good to speak with you during our meet-and-confer yesterday.
As promised, I have attached a chart showing search terms we propose to use to identify documents for
review and the requests that we read as amenable to search-term application. As I mentioned, we plan to run
these search terms against the custodial data of the 15 custodians identified in Debtor’s Initial Disclosures in
Connection With Estimation Proceeding, for the period January 1, 2011 through November 1, 2017.
We currently plan to address the other requests through targeted searches for responsive documents that
may be aggregated or maintained in identifiable collections or otherwise gathered through targeted search
efforts. As may be appropriate, we also may use such targeted searches to identify for review additional
documents potentially responsive to the requests set out on the attachment that we have identified as
amenable to search-term application.
As I also mentioned, we do plan to serve our written responses and objections and to start rolling productions
on or before May 15, 2021. We plan to report again next week, but, as I shared with you on the call, the
breadth of the requests and our current read of the data to be reviewed will make substantial completion of
production within 75 days of service of the requests more than materially challenging.
Please let us know if you have any questions or comments on the search terms or would like to discuss
further. And we look forward to hearing from you regarding the requests that refer to a proposed sample of
files or claims but do not define that sample.
Have a good weekend, everyone.
James M. Jones (bio)

Partner
JONES DAY® - One Firm Worldwide℠
250 Vesey Street
New York, NY 10281-1047
Office +1.212.326.7838
EXHIBIT D

Sent: Thursday, May 6, 2021 4:33 PM
To: Del Medico, Jennifer L.; Zieg, Sharon; Ramsey, Natalie D.; Gordon, Gregory M.; Ellman,
Jeffrey B.; Garland Cassada (GCassada@rbh.com); Wright, Davis L.; Harron, Edwin;
Edwards, Erin; Bradley, Elisabeth; Kaplan, Jeff A.; Schneider Richard (King & Spalding -
Atlanta, GA)
Subject: RE: Bestwall: Follow-Up on Meet-and-Confer Concerning Document
Collection/Review/Production
Sharon et al.: Consistent with my note of April 30, 2021, and after additional collection efforts and additional
search‐term application to custodial data, we do not anticipate currently that substantial completion of our
collection, review, and production of documents responsive to the ACC/FCR’s 45 requests can be
accomplished practicably within 75 days of the service of those requests. Our collection and review efforts are
ongoing, and we may have a better estimate of when substantial completion can be achieved in the near
term.
We, however, have not received any comments from the ACC/FCR on our search terms. Nor have we received
the proposed definition of “Sample Resolved Mesothelioma Claims” as that term is used in your
requests. Concluding our estimate will require receipt and assessment of these two sets of information.
We continue to work apace, can be available next week to discuss these matters, and that may be an
appropriate next step. Please let us know if you agree and a convenient time to convene. Thank you.

Partner
250 Vesey Street
New York, NY 10281-1047
Office +1.212.326.7838
From: Del Medico, Jennifer L. <jdelmedico@JonesDay.com>
Sent: Monday, May 3, 2021 5:13 PM
To: Zieg, Sharon <SZIEG@ycst.com>; Jones, James M. <jmjones@JonesDay.com>; Ramsey, Natalie D.
<NRamsey@rc.com>; Gordon, Gregory M. <gmgordon@JonesDay.com>; Ellman, Jeffrey B. <jbellman@JonesDay.com>;
Blake, Rebekah E. <reblake@jonesday.com>; Garland Cassada (GCassada@rbh.com) <GCassada@rbh.com>; Wright,
Davis L. <DWright@rc.com>; Harron, Edwin <eharron@ycst.com>; Edwards, Erin <eedwards@ycst.com>; Bradley,
Elisabeth <EBradley@ycst.com>; Kaplan, Jeff A. <jkaplan@jonesday.com>; Schneider Richard (King & Spalding ‐ Atlanta,
GA) <dschneider@kslaw.com>
Subject: RE: Bestwall: Follow‐Up on Meet‐and‐Confer Concerning Document Collection/Review/Production
Sharon:
We are running the search terms through the custodians’ ESI for the time period of January 1, 2011 through Nov. 1,
2017. All of the hits from those searches will be reviewed to determine if they are responsive to any of the
1
Requests. For example, the documents that hit on the search terms for Request 7 will be reviewed for responsiveness to
any of the Requests.

Jenn

Jennifer L. Del Medico (bio)
Partner
JONES DAY® ‐ One Firm Worldwide℠
250 Vesey Street
New York, New York 10281‐1047
Office +1.212.326.3658
Fax +1.212.755.7306
Mobile +1.908.229.5129

From: Zieg, Sharon <SZIEG@ycst.com>
To: Jones, James M. <jmjones@JonesDay.com>; Ramsey, Natalie D. <NRamsey@rc.com>; Gordon, Gregory M.
<gmgordon@JonesDay.com>; Ellman, Jeffrey B. <jbellman@JonesDay.com>; Blake, Rebekah E.
<reblake@jonesday.com>; Garland Cassada (GCassada@rbh.com) <GCassada@rbh.com>; Wright, Davis L.
<DWright@rc.com>; Harron, Edwin <eharron@ycst.com>; Edwards, Erin <eedwards@ycst.com>; Bradley, Elisabeth
<EBradley@ycst.com>; Del Medico, Jennifer L. <jdelmedico@JonesDay.com>; Kaplan, Jeff A. <jkaplan@jonesday.com>;
Schneider Richard (King & Spalding ‐ Atlanta, GA) <dschneider@kslaw.com>
Subject: RE: Bestwall: Follow‐Up on Meet‐and‐Confer Concerning Document Collection/Review/Production
** External mail **
Thanks Jim. We are reviewing and will respond soon. In the meantime, can you please confirm that you are not running
the searches and reviewing by Request No., but rather running all of the searches across all harvested documents and
reviewing each document for responsiveness to any of the 40 Requests.
Regards,
Sharon
Sharon M. Zieg, Partner
Young Conaway Stargatt & Taylor, LLP
Rodney Square, 1000 North King Street
Wilmington, DE 19801
P: 302.571.6655 | F: 302.576.3350
SZIEG@ycst.com | www.youngconaway.com | vCard
This message may contain confidential attorney‐client communications or other protected information. If you believe you
are not an intended recipient (even if this message was sent to your e‐mail address), you may not use, copy, or retransmit
it. If you believe you received this message by mistake, please notify us by return e‐mail, and then delete this message.
Thank you for your cooperation.
From: Jones, James M. <jmjones@JonesDay.com>
Sent: Friday, April 30, 2021 5:16 PM
To: Ramsey, Natalie D. <NRamsey@rc.com>; Zieg, Sharon <SZIEG@ycst.com>; Gordon, Gregory M.
<gmgordon@JonesDay.com>; Ellman, Jeffrey B. <jbellman@JonesDay.com>; Blake, Rebekah E.
<reblake@jonesday.com>; Garland Cassada (GCassada@rbh.com) <GCassada@rbh.com>; Wright, Davis L.
2
<DWright@rc.com>; Harron, Edwin <eharron@ycst.com>; Edwards, Erin <eedwards@ycst.com>; Bradley, Elisabeth
<EBradley@ycst.com>; Del Medico, Jennifer L. <jdelmedico@JonesDay.com>; Kaplan, Jeff A. <jkaplan@jonesday.com>;
Schneider Richard (King & Spalding ‐ Atlanta, GA) <dschneider@kslaw.com>
Subject: Bestwall: Follow‐Up on Meet‐and‐Confer Concerning Document Collection/Review/Production
All: Good to speak with you during our meet‐and‐confer yesterday.

As promised, I have attached a chart showing search terms we propose to use to identify documents for
review and the requests that we read as amenable to search‐term application. As I mentioned, we plan to run
these search terms against the custodial data of the 15 custodians identified in Debtor’s Initial Disclosures in
Connection With Estimation Proceeding, for the period January 1, 2011 through November 1, 2017.

We currently plan to address the other requests through targeted searches for responsive documents that
may be aggregated or maintained in identifiable collections or otherwise gathered through targeted search
efforts. As may be appropriate, we also may use such targeted searches to identify for review additional
documents potentially responsive to the requests set out on the attachment that we have identified as
amenable to search‐term application.

As I also mentioned, we do plan to serve our written responses and objections and to start rolling productions
on or before May 15, 2021. We plan to report again next week, but, as I shared with you on the call, the
breadth of the requests and our current read of the data to be reviewed will make substantial completion of
production within 75 days of service of the requests more than materially challenging.

Please let us know if you have any questions or comments on the search terms or would like to discuss
further. And we look forward to hearing from you regarding the requests that refer to a proposed sample of
files or claims but do not define that sample.

Have a good weekend, everyone.

Partner
250 Vesey Street
New York, NY 10281-1047
Office +1.212.326.7838
***This e-mail (including any attachments) may contain information that is private, confidential, or protected
by attorney-client or other privilege. If you received this e-mail in error, please delete it from your system
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3
EXHIBIT E

CHARLOTTE DIVISION
In re Chapter 11
BESTWALL LLC,1 Case No. 17-31795 (LTB)

Debtor.
BESTWALL LLC’S RESPONSES AND OBJECTIONS

TO THE OFFICIAL COMMITTEE OF ASBESTOS CLAIMANTS’
AND THE FUTURE CLAIMANTS’ REPRESENTATIVE’S
FIRST SET OF DOCUMENT REQUESTS TO THE DEBTOR
Pursuant to Rules 7026 and 7034 of the Federal Rules of Bankruptcy Procedure
(the “Bankruptcy Rules”), Rules 26 and 34 of the Federal Rules of Civil Procedure (the “Civil
Rules”) incorporated therein, and the Local Rules of this Court (the “Local Rules”), Bestwall LLC
(the “Debtor” or “Bestwall”) responds and objects to the Official Committee of Asbestos
Claimants’ and the Future Claimants’ Representative’s First Set of Document Requests Directed
to the Debtor Pursuant to Fed. Bankr. R. 7026, 7034, and 9014 (the “Requests”) as follows:
GENERAL OBJECTIONS
The following General Objections are incorporated into each of Bestwall’s individual
responses to the Requests (the “Responses”) as if fully set forth therein.
1. Bestwall objects to the Requests to the extent that they seek information that is
neither relevant nor proportional to the needs of the case.
2. Bestwall objects to the Requests on the grounds that they are overly broad, unduly
burdensome, and seek to impose obligations on Bestwall that exceed those imposed upon a party
1
The last four digits of the Debtor's taxpayer identification number are 5815. The Debtor’s address is 133 Peachtree
Street, N.E., Atlanta, Georgia 30303.
by the Civil Rules, the Bankruptcy Rules, the Local Rules, the Agreed Protective Order Governing
Confidential Information [Dkt. 337] (the “Protective Order”), or the Joint Discovery Plan and
Report (ESI Protocol) [Ex. 1 to Dkt. 1685] (the “ESI Protocol”).
3. In responding to these Requests, where noted below, Bestwall will conduct a
diligent search, reasonable in scope, of those files in its possession, custody, or control believed to
be the most likely to contain documents responsive to the Requests, primarily consisting of those
custodial and non-custodial data sources listed in the Debtor’s Initial Disclosures in Connection
with Estimation Proceeding, served on April 15, 2021 (the “Debtor’s Initial Disclosures”).
4. Bestwall objects to the Requests to the extent that they are overlapping and
duplicative.
5. Bestwall objects to the Requests to the extent that they call for information or
documents that are privileged or exempt from discovery under the attorney-client privilege, work
product doctrine, joint-defense or common-interest doctrine, or other applicable protection,
restriction, exemption, or immunity from discovery under applicable law. In the event that any
privileged or protected information or document is disclosed by Bestwall, the disclosure is
inadvertent and is not intended to waive any privilege or protection. See Protective Order, § M.
To the extent that Bestwall specifically objects to certain Requests on the ground of privilege but
not specifically to other Requests on that ground, this indicates only that certain Requests may be
read more clearly to elicit privileged information and should not be taken as an indication that
Bestwall waives its privilege objection in any instance.
6. Bestwall objects to the Requests to the extent that responding to the Requests would
cause unreasonable annoyance, embarrassment, oppression, burden, or expense.
2
7. Bestwall’s objections and Responses are based upon information presently known
to Bestwall and are set forth herein without prejudice to Bestwall’s right to assert additional
objections or to amend or supplement these Responses should Bestwall learn or discover additional
information.
8. Each and every Response to a Request that states that non-privileged documents
will be produced should not be construed as an affirmation that such documents exist or as an
admission of any legal or factual contention contained in any individual Request. Rather, it is an
indication that a reasonable search and inquiry will be undertaken to locate and produce non-
privileged responsive documents. Further, Bestwall’s production of documents in response to any
Request does not constitute an admission by Bestwall that such documents are either relevant or
admissible.
9. Bestwall reserves the right to challenge the competency, relevance, materiality, and
admissibility of and to object on any grounds to the use at any subsequent proceeding in this or
any other action of any information, documents, or other materials produced in response to the
Requests.
10. Bestwall objects to the Requests to the extent that they seek proprietary or other
confidential business information. Subject to and without waiver of the objections set forth in this
document, Bestwall will produce responsive non-privileged information and documents
containing any such information subject to the Protective Order and the ESI Protocol.
11. Bestwall objects to the Requests and their Instructions and Definitions to the extent
that they seek the production of “all” information, documents, or communications relating to
a given subject matter. Bestwall will conduct a reasonable, good-faith search for information and
3
documents responsive to the Requests within the requirements of the applicable Civil Rules and
law and consistent with the terms of the ESI Protocol.
12. Bestwall objects to the Requests to the extent that they call for the production of
information or documents that would violate any law, rule, or regulation.
13. Bestwall objects to the Requests to the extent that they call for legal interpretation
and/or legal conclusions.
14. Bestwall objects to the “Definitions” in the Requests to the extent that they define
terms more broadly than the uniform definitions set forth in the Civil Rules, the Bankruptcy Rules,
and the Local Rules.
15. Bestwall objects to the definitions of “Communication,” “concerning,” “relate to,”
“related to,” “relating to,” “refer to,” “referring to,” “pertain to,” “pertaining to,” and “Document”
in paragraphs 6, 7, and 10 as overly broad.
16. Bestwall objects to the definitions of “Bestwall,” “Debtor,” “You,” “your,” and “GP
Entities” in paragraphs 5, 9, 12, and 29 as overly broad. In these Responses, Bestwall shall mean
Bestwall LLC. Through the Plan of Divisional Merger, dated July 31, 2017, the books and records
related to the asbestos liabilities of the former Georgia-Pacific LLC, which ceased to exist on July
31, 2017 (“Old GP”), were allocated to Bestwall. Except as otherwise noted in connection with a
production of documents, these Responses are made on behalf of and are premised upon
information and documents in the possession, custody, or control of Bestwall, including the
asbestos-related records allocated to Bestwall by Old GP and including the files of the custodians
listed by Bestwall in its Initial Disclosures, and Bestwall objects on grounds of undue burden and
proportionality to any request to search the files of any entity other than Bestwall LLC, whether
or not a corporate affiliate of Bestwall LLC.
4
17. Bestwall objects to the definitions of “GP Joint Compound Products” and “Gypsum
Asbestos PI Claim” in paragraphs 13 and 14 as overly broad and unduly burdensome and because
they seek information that is neither relevant nor proportional to the needs of the case, including
the “Gypsum Asbestos PI Claim” definition’s inclusion of workers’ compensation claims, which
claims are not at issue in this chapter 11 case. Consistent with paragraph 1 of the Court’s Order
Authorizing Estimation of Current and Future Mesothelioma Claims [Dkt. 1577] (the “Estimation
Order”), Bestwall, in these responses, provides information and refers to the production of
documents relating to “mesothelioma claims that (a) arose, in whole or part, from alleged exposure
to joint compound products that contained asbestos either as a constituent ingredient or an alleged
contaminant and (b) were manufactured and sold by the Debtor or its predecessors on or before
December 31, 1977” (the “Bestwall Mesothelioma Claims”), which products are listed both in
footnote 3 of the Motion of the Debtor for Estimation of Current and Future Mesothelioma Claims
[Dkt. 875] and again in section “d” of Debtor’s Initial Disclosures (the “Pre-1978 Asbestos-
Containing Joint Compound Products”).
18. Bestwall objects to the definition of “Gypsum Asbestos PI Claim” in paragraph 14
as vague, ambiguous, overly broad, and disproportionate to the needs of this case because
the definition itself includes the undefined term “GP Gypsum Products.” Bestwall will provide
information pertaining to the Bestwall Mesothelioma Claims and the Pre-1978 Asbestos-
Containing Joint Compound Products.
19. Bestwall objects to the definition of “Sample Resolved Mesothelioma Claims” in
paragraph 27 as vague and ambiguous since the term has yet to be defined by the Official
Committee of Asbestos Personal Injury Claimants (the “Committee”) or Sander Esserman, the
5
legal representative for future claimants (the “Future Claimants’ Representative” or the “FCR”
and, together with the Committee, the “Claimants’ Representatives”).
20. Bestwall objects to the “Instructions” to the extent they seek to impose obligations
on Bestwall that exceed those imposed on a party by the Civil Rules, the Bankruptcy Rules, and
the Local Rules.
21. Bestwall adopts for purposes of these Responses Claimants’ Representatives’
starting date of January 1, 2011, for the period within which to provide responsive information or
documents but objects to providing information or documents for any time after November 1, 2017
(i.e., on or after Bestwall filed its chapter 11 petition on November 2, 2017). Bestwall’s Responses,
therefore, contain responsive information and will produce responsive non-privileged documents
for the period January 1, 2011, through November 1, 2017 (the “Relevant Time Period”).
22. Bestwall objects to Instruction No. 2 on the ground that it is vague and ambiguous
regarding “the information” to be provided. Bestwall further objects to Instruction No. 2 of
the Requests to the extent that it seeks information beyond that required by the ESI Protocol.
Bestwall will produce a privilege log consistent with Attachment B to the ESI Protocol at the time
called for therein and in the Case Management Order for Estimation of the Debtor’s Liability for
Mesothelioma Claims [Dkt. 1685] (the “Case Management Order”).
23. Bestwall objects to Instruction No. 3 on the grounds that it would impose undue
burden disproportionate to the needs of the case and that it seeks information beyond what is
required by Bankruptcy Rule 7034 and Civil Rule 34.
24. Bestwall objects to Instructions No. 5 through 9 on the ground that they each seek
information beyond what is required by Bankruptcy Rule 7034 and Civil Rule 34.
6
25. Bestwall objects to Instruction No. 10 on the grounds that it may seek information
subject to the attorney-client privilege, work product doctrine, joint-defense or common-interest
doctrine, or other applicable protection, restriction, exemption, or immunity from discovery under
applicable law.
26. Bestwall objects to Instruction No. 11 on the ground that it calls for documents that
are not required to be produced pursuant to the ESI Protocol. Bestwall will produce documents in
accordance with the ESI Protocol.
27. The objections set forth in these General Objections apply to each of the Requests
and are not necessarily repeated in response to each individual Request. The assertion of the same,
similar, or additional Specific Objections in response to a Request does not waive any of Bestwall’s
General Objections to that Request or to any other Request.
RESPONSES AND SPECIFIC OBJECTIONS TO

REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: All Documents concerning the identified Sample Resolved Mesothelioma
Claims, including, but not limited to claims files, litigation files, or similar files.
RESPONSE TO REQUEST NO. 1: Bestwall objects to this Request as overly broad and unduly
burdensome and disproportionate to the needs of the case. Bestwall also objects because the term
“Sample Resolved Mesothelioma Claims” has yet to be defined by Claimants’ Representatives.
Bestwall objects to this Request on the ground that it seeks information subject to the attorney-
client privilege, work product doctrine, and/or other applicable protections from disclosure.
Bestwall further objects because certain responsive information has already been produced to
Claimants’ Representative from the PACE Claims Services database and potentially within
materials related to approximately 2,200 resolved mesothelioma claims that were produced
pursuant to paragraph 3(e) of the Case Management Order.
7
Subject to and without waiving its objections, Bestwall will continue to meet and confer
with the Claimants’ Representatives regarding their contemplated sample to assess the extent to
which additional non-privileged documents responsive to this Request may be collected and
produced.
REQUEST NO. 2: All Documents referring to, related to, or concerning Resolved
Mesothelioma Claims that were reviewed, considered or relied upon with respect to
the Informational Briefs or the Trust Discovery Motion.
RESPONSE TO REQUEST NO. 2: Bestwall objects to this Request on the ground that it is
overly broad and seeks information that is protected by the attorney-client privilege, the work
product doctrine, and/or other applicable protections from disclosure.
Subject to and without waiving its objections, Bestwall states that it previously produced
non-privileged documents concerning the exemplar cases described in its Informational Brief and
Trust Discovery Motion at Bates numbers BW-CH11-00046650–BW-CH11-00056210; BW-
CH11-00056211_PEO–BW-CH11-00056305_PEO; BW-CH11-00056306–BW-CH11-00077025;
BW-CH11-00077026_PEO–BW-CH11-00077167_PEO; BW-CH11-00077248–BW-CH11-
00120673; BW-CH11-00120674–BW-CH11-00121552; BW-CH11-00121553_PEO–BW-CH11-
00121585_PEO; BW-CH11-00142788–BW-CH11-00217121; BW-CH11-00217122_PEO–BW-
CH11-00217149_PEO; BW-CH11-00217150–BW-CH11-00221218; BW-CH11-
00221219_PEO–BW-CH11-00221225_PEO; BW-CH11-00221226–BW-CH11-00281172; BW-
CH11-00281173–BW-CH11-00281214; and BW-CH11-00282142–BW-CH11-00287926.
REQUEST NO. 3: All Documents exchanged with counsel for the holder of a Sample
Resolved Mesothelioma Claim that refer to, related to or concern the negotiation of a
settlement of that Resolved Mesothelioma Claim.
RESPONSE TO REQUEST NO. 3: Bestwall incorporates as if fully set forth herein its Response
to Request No. 1.
8
REQUEST NO. 4: All Documents concerning or related to the GP Entities’ decisions to settle
each Sample Resolved Mesothelioma Claim it settled prior to trial or verdict.
RESPONSE TO REQUEST NO. 4: Bestwall objects to this Request as vague and ambiguous,
overly broad, and disproportionate to the needs of the case for, among other reasons, its use of
the term “GP Entities.” Bestwall incorporates as if fully set forth herein its Response to Request
No. 1.
REQUEST NO. 5: All Documents concerning or related to the GP Entities’ decisions to litigate
each Sample Resolved Mesothelioma Claim that it tried to verdict.
overly broad, and disproportionate to the needs of the case for, among other reasons, its use of the
term “GP Entities.” Bestwall incorporates as if fully set forth herein its Response to Request No.
1.
REQUEST NO. 6: All Documents concerning or related to the GP Entities’ decisions to settle
a Sample Resolved Mesothelioma Claim after a trial verdict.
1.
REQUEST NO. 7: All Documents concerning or related to the GP Entities’ use of verdict
history of GP Entities and/or non-GP Entities in the decisions to litigate each Resolved
Mesothelioma Claim that it tried to verdict or settled.
term “GP Entities.” Bestwall objects to this Request on the ground that it seeks information subject
to the attorney-client privilege, work product doctrine, and/or other applicable protections from
disclosure.
9
Subject to and without waiving its objections, Bestwall states that it already has produced
certain non-privileged documents concerning verdict history at Bates numbers BW-Ch11-
00077227_PEO–BW-Ch11-00077230_PEO and BW-Ch11-00121698–BW-Ch11-00121761.
Bestwall will conduct a reasonable search for and will produce, if located, additional non-
privileged documents that reflect Bestwall’s use of verdict history to evaluate the Bestwall
Mesothelioma Claims during the Relevant Time Period.
REQUEST NO. 8: All Documents constituting, referring to, relating to, or concerning any
analysis or valuation of the nature, extent and/or value of the GP Entities’ liabilities on
Gypsum Asbestos PI Claims.
terms “GP Entities” and “Gypsum Asbestos PI Claims.” Bestwall objects to this Request on the
ground that it seeks information subject to the attorney-client privilege, accountant-client privilege,
work product doctrine, and/or other applicable protections from disclosure.
certain non-privileged documents concerning estimates or forecasts of defense and indemnity costs
for Bestwall Mesothelioma Claims at Bates numbers BW-Ch11-00012860–BW-Ch11-
00012899; BW-Ch11-00012860_PEO-BW-Ch11-00012899_PEO; BW-Ch11-00121586–BW-
Ch11-00121697; and BW-Ch11-00141384_PEO–BW-Ch11-00141713_PEO. Bestwall will
conduct a reasonable search for and will produce, if located, additional non-privileged estimates
or forecasts of the referenced costs during the Relevant Time Period.
REQUEST NO. 9: All Documents referring to, relating to, or concerning, asbestos exposure
attributable to other defendants who filed for bankruptcy prior to November 1, 2017.
overly broad, and disproportionate to the needs of the case. Bestwall also objects to this Request
10
on the ground that it seeks information subject to the attorney-client privilege, work product
doctrine, and/or other applicable protections from disclosure.
Subject to and without waiving its objections, Bestwall will conduct a reasonable search
for and will produce, if located, non-privileged documents responsive to this Request.
REQUEST NO. 10: All Documents constituting, referring to, relating to, or concerning the
usage, market share, sales and/or product reach of the GP Joint Compound Products.
term “GP Joint Compound Products” and the undefined term “product reach.”
certain non-privileged documents concerning sales and market share responsive to this Request at
Bates numbers BW-SR-00000001–BW-SR-07152525; BW‐Ch11‐00077231–BW‐Ch11‐
00077247; and BW‐Ch11‐00121763–BW-Ch11-00141269. Bestwall will conduct a reasonable
search for and will produce, if located, additional non-privileged documents concerning market
share attributable to the Pre-1978 Asbestos-Containing Joint Compound Products during the
Relevant Time Period.
REQUEST NO. 11: All documents constituting, referring to, relating to, or concerning whether
exposure to GP Joint Compound Products does or does not contribute to the development of
mesothelioma.
term “GP Joint Compound Products.” Bestwall objects to this Request on the ground that it seeks
information subject to the attorney-client privilege, work product doctrine, and/or other applicable
protections from disclosure.
11
Subject to and without waiving the its objections, Bestwall states that it already has
produced certain non-privileged documents responsive to this Request, including expert reports
within case files, at Bates numbers BW-CH11-00046650–BW-CH11-00056210; BW-CH11-
BW-CH11-00120674–BW-CH11-00121552; BW-CH11-00121553_PEO–BW-CH11-
privileged documents responsive to this Request concerning the Pre-1978 Asbestos-Containing
Joint Compound Products.
REQUEST NO. 12: All Documents constituting, referring to, relating to, or concerning
the Debtor’s usual course of conduct of asbestos-related litigation, the mechanics of asbestos-
related litigation, and any guidelines or procedures related to litigating or settling such
litigation.
overly broad, and disproportionate to the needs of the case. Bestwall objects to this Request on
the ground that it seeks information subject to the attorney-client privilege, work product doctrine,
and/or other applicable protections from disclosure.
certain non-privileged documents responsive to this Request, including sample answers to
interrogatories and requests for admission, motions in limine, and verdict forms, at Bates numbers
12
BW-Ch11-00015095–BW-Ch11-00015893. Bestwall will conduct a reasonable search for and will
produce, if located, additional non-privileged documents responsive to this Request.
the extent and/or value of asbestos liabilities of any entities other than the GP Entities.
term “GP Entities.” Bestwall further objects to this Request on the ground that it seeks information
subject to the attorney-client privilege, work product doctrine, and/or any other applicable
protection from disclosure.
REQUEST NO. 14: All Documents constituting, referring to, or concerning the extent and/or
value of any third-party’s joint and/or several liability for any Sample Resolved Mesothelioma
Claim.
RESPONSE TO REQUEST NO. 14: Bestwall incorporates as if fully set forth herein its
Response to Request No. 1.
Debtor’s attempt to pursue, or decision not to pursue, any indemnification and/or contribution
claim from any other entity for any Sample Resolved Mesothelioma Claim.
Response to Request No. 1 and refers Claimants’ Representatives to Bestwall’s Answer to
Interrogatory No. 3.
REQUEST NO. 16: All Communications between You, or anyone acting on Your behalf, and
any third party that You believed was joint and/or severally liable with the GP Entities for any
Sample Resolved Mesothelioma Claims.
13
1.
the GP Entities knowledge of purported inappropriate conduct by plaintiffs in the tort system,
as identified in the Informational Briefs and the Trust Discovery Motion.
term “GP Entities” and the undefined term “inappropriate conduct.” Bestwall objects to this
Request on the ground that it seeks information subject to the attorney-client privilege, work
product doctrine, and/or any other applicable protections from disclosure.
non-privileged documents concerning the exemplar cases described in its Informational Brief and
Trust Discovery Motion at Bates numbers BW-CH11-00046650–BW-CH11-00056210; BW-
BW-CH11-00077026_PEO–BW-CH11-00077167_PEO; BW-CH11-00077248–BW-CH11-
00120673; BW-CH11-00120674–BW-CH11-00121552; BW-CH11-00121553_PEO–BW-CH11-
privileged documents responsive to this Request.
14
REQUEST NO. 18: All Documents evidencing alleged inappropriate conduct by the holder
of a Resolved Mesothelioma Claim.
REQUEST NO. 19: All Communications, reports, memoranda, or data compilations relating
to the nature, extent and/or value of the Gypsum Asbestos PI Claims that You received from
any expert engaged, employed or otherwise retained by the GP Entities or on the GP Entities’
behalf prior to the Petition Date.
terms “Gypsum Asbestos PI Claims” and “GP Entities.” Bestwall objects to this Request on the
ground that it seeks information subject to the attorney-client privilege, work product doctrine,
joint-defense doctrine, and/or other applicable protections from disclosure.
Subject to and without waiving its objections, Bestwall already has produced certain non-
privileged documents concerning estimates or forecasts of defense and indemnity costs for
Bestwall Mesothelioma Claims at Bates numbers BW-Ch11-00012860–BW-Ch11-
00012899; BW-Ch11-00012860_PEO-BW-Ch11-00012899_PEO; and BW-Ch11-00121586–
BW-Ch11-00121697. Bestwall will conduct a reasonable search for and will produce, if located,
additional non-privileged estimates and forecasts of the referenced costs during the Relevant Time
Period.
REQUEST NO. 20: All Communications, reports, memoranda, or data compilations relating
to the usage, market share, sales and/or product reach of GP Joint Compound Products
containing asbestos as either an ingredient or contaminant, that the GP Entities received from
any expert engaged, employed or otherwise retained by GP Entities (or on the GP Entities
behalf) prior to the Petition Date.
15
terms “GP Joint Compound Products,” “GP Entities,” and the undefined term “product reach.”
Bestwall incorporates as if fully set forth herein its Response to Request No. 10.
REQUEST NO. 21: All Communications, reports, memoranda, or data compilations relating to
the risks and likelihood of cause of various diseases from the GP Joint Compound Products
containing asbestos as either an ingredient or contaminant that the GP Entities received from
any Expert engaged, employed or otherwise retained by the GP Entities (or on the GP Entities
behalf) prior to the Petition Date.
terms “GP Joint Compound Products” and “GP Entities.” Bestwall objects to this Request to the
extent it calls for documents that relate to risk and likelihood of cause of diseases other than
mesothelioma. Bestwall further objects to this Request on the ground that it seeks information
subject to the attorney-client privilege, work product doctrine, and/or other applicable protections
from disclosure.
certain non-privileged documents, including expert reports within case files, at Bates numbers
BW-CH11-00046650–BW-CH11-00056210; BW-CH11-00056306–BW-CH11-00077025; BW-
CH11-00077026_PEO–BW-CH11-00077167_PEO; BW-CH11-00077248–BW-CH11-
00120673; BW-CH11-00142788–BW-CH11-00217121; BW-CH11-00217150–BW-CH11-
00221218; BW-CH11-00221226–BW-CH11-00281172; and BW-CH11-00282142–BW-CH11-
00287926. Bestwall will conduct a reasonable search for and will produce, if located, additional
non-privileged documents concerning the Pre-1978 Asbestos-Containing Joint Compound
Products in response to this Request.
16
REQUEST NO. 22: All Documents relating to the eight published research studies funded by
Old GP in 2005 concerning the health effects of its joint compound that were the subject of the
opinion by in Weitz & Luxenberg P.C. v. Georgia-Pacific LLC (In re N.Y.C. Asbestos Litig.),
966 N.Y.S.2d 420, 423 (N.Y. App. Div. 2013) including but not limited to, the data, protocols,
process, conduct, discussion, and analyses underlying these studies.
RESPONSE TO REQUEST NO. 22: Bestwall objects to this Request because it seeks
information that is neither relevant nor proportional to the needs of the case. Bestwall also objects
to this Request on the ground that it seeks information subject to the attorney-client privilege, work
Subject to and without waiving its objections, Bestwall will produce non-privileged
documents responsive to this Request.
REQUEST NO. 23: All Documents that evidence Old GP’s employment relationship with
Stewart Holm as an expert consultant with respect to the eight published research studies funded
by Old GP in 2005 concerning the health effects of its joint compound.
RESPONSE TO REQUEST NO. 23: Bestwall objects to this Request because it seeks
information that is neither relevant nor proportional to the needs of the case. Bestwall also objects
to this Request on the ground that it seeks information subject to the attorney-client privilege, work
Subject to and without waiving its objections, Bestwall will produce non-privileged
documents responsive to this Request.
REQUEST NO. 24: All Documents constituting, referring to, relating to, or concerning any
analysis or valuation of the nature, extent and/or value of all Claims (as such term is defined in
Section 101(5) of the Bankruptcy Code) against the Debtor, including, without limitation,
Gypsum Asbestos PI Claims, arising prior to the Petition Date.
term “Gypsum Asbestos PI Claims.” Bestwall incorporates as if fully set forth herein its Response
to Request No. 8.
17
REQUEST NO. 25: All Documents provided to any GP Entities’ boards of managers
regarding Gypsum Asbestos PI Claims, including, without limitation, all presentations,
business plans, memoranda, analyses, reports and materials prepared for or made during any
meeting of the board of managers prior to the 2017 Restructuring.
for and will produce, if located, non-privileged documents provided to Bestwall’s or Old GP’s
Board of Managers regarding the Bestwall Mesothelioma Claims during the Relevant Time Period.
REQUEST NO. 26: All Documents provided to the Bestwall’s boards of managers regarding
Gypsum Asbestos PI Claims, including, without limitation, all presentations, business plans,
memoranda, analyses, reports and materials prepared for or made during any meeting of the
board of directors since the 2017 Restructuring.
term “Gypsum Asbestos PI Claims.” Bestwall further objects to this Request on the ground that it
seeks information subject to the attorney-client privilege, work product doctrine, and/or other
applicable protections from disclosure.
for and will produce, if located, non-privileged documents that were provided to Bestwall’s Board
of Managers regarding the Bestwall Mesothelioma Claims during the Relevant Time Period.
18
REQUEST NO. 27: All minutes, transcripts, written consents, and resolutions of or resulting
from meetings of the Old GP’s boards of managers during which Gypsum Asbestos PI Claims
were discussed or otherwise addressed prior to the 2017 Restructuring.
term “Gypsum Asbestos PI Claims.” Bestwall also objects to this Request on the ground that it
seeks information subject to the attorney-client privilege, work product doctrine, and/or other
privileged documents concerning the 2017 corporate restructuring and the allocation of asbestos-
related liabilities resulting therefrom at Bates numbers BW-Ch11-00000001–BW-Ch11-00011582
and BW-Ch11-00045618–BW-Ch11-00046564. Bestwall will conduct a reasonable search for and
will produce, if located, additional responsive non-privileged documents that memorialize
discussions of Bestwall Mesothelioma Claims during the meetings of Old GP’s Board of Managers
within the Relevant Time Period.
REQUEST NO. 28: All minutes, transcripts, written consents and resolutions of or resulting
from meetings of the GP Entities’ boards of managers during which Gypsum Asbestos PI
Claims were discussed or otherwise addressed since the 2017 Restructuring.
terms “GP Entities” and “Gypsum Asbestos PI Claims.” Bestwall further objects to this Request
for and will produce, if located, additional responsive non-privileged documents that memorialize
19
discussions of Bestwall Mesothelioma Claims during the meetings of Old GP’s Board of Managers
within the Relevant Time Period. See also Response to Request No. 27.
REQUEST NO. 29: All Documents constituting internal procedures handbooks or similar
manuals for the process, protocols or means by which the GP Entities address or handle
Gypsum Asbestos PI Claims.
for and will produce, if located non-privileged documents reflecting any protocol used by Old GP
or Bestwall for handling the Bestwall Mesothelioma Claims during the Relevant Time Period.
REQUEST NO. 30: All Documents related to or considered by the Debtor to determine the
appropriate settlement amounts to provide to Resolved Mesothelioma Claims as part of a group
of five (5) or more plaintiffs.
RESPONSE TO REQUEST NO. 30: Bestwall objects to this as overly broad, disproportionate
to the needs of the case and duplicative of Request No. 7. Bestwall objects to this Request on the
privileged documents responsive to this Request in the form of group settlement agreements at
Bates numbers BW-Ch11-00142061–BW-Ch11-00142787. Bestwall will conduct a reasonable
search for and will produce, if located, additional non-privileged documents responsive to this
Request.
20
REQUEST NO. 31: All Documents evidencing factors the Debtor considered or evaluated in
connection with settling the Resolved Mesothelioma Claims, including, but not limited to,
settlement offers made by the Debtor or settlement offers rejected by the Debtor.
RESPONSE TO REQUEST NO. 31: Bestwall objects to this Request as overly broad, unduly
burdensome, and disproportionate to the needs of this case. Bestwall also objects to this Request
for and will produce, if located, non-privileged documents concerning the Bestwall Mesothelioma
Claims responsive to this Request.
Debtor’s knowledge of or participation with any state and/or federal legislation designed to
limit tort related liabilities.
RESPONSE TO REQUEST NO. 32: Bestwall objects to this Request as vague, ambiguous,
overly broad, and unduly burdensome and because it seeks information that is neither relevant nor
proportional to the needs of the case. Bestwall further objects to this Request on the ground that
it seeks information subject to the attorney-client privilege, work product doctrine, and/or other
for and will produce, if located, non-privileged documents concerning Old GP’s or Bestwall’s
involvement in state or federal legislative efforts to address tort reform during the Relevant Time
Period.
REQUEST NO. 33: All Documents or Communications evidencing the Debtor’s knowledge
of alleged issues of asbestos plaintiffs withholding information regarding exposure to other
products manufactured by bankrupt asbestos defendants.
RESPONSE TO REQUEST NO. 33: Bestwall objects to this request as overly broad, vague,
and ambiguous, and disproportionate to the needs of the case. Bestwall objects to this Request as
21
duplicative of Request Nos. 17 and 18. Bestwall incorporates as if fully set forth herein its
Responses to Request Nos. 17 and 18.
REQUEST NO. 34: All Documents concerning or related to any appraisal of GP Industrial
Plasters LLC.
RESPONSE TO REQUEST NO. 34: Bestwall objects to this Request to the extent it is
duplicative of Request No. 8.
Subject to and without waiving its objections, Bestwall already has produced non-
privileged documents concerning this appraisal at Bates numbers BW-Ch11-00141384_PEO–BW-
Ch11-00141713_PEO. Bestwall will conduct a reasonable search for and will produce, if located,
additional non-privileged documents responsive to Request No. 34.
REQUEST NO. 35: All Documents relating to costs incurred by the Debtor including, without
limitation, fees for attorneys and various experts and consultants, to defend or otherwise litigate
Resolved Mesothelioma Claims.
RESPONSE TO REQUEST NO. 35: Bestwall objects to this Request as overly broad and
unduly burdensome and because it seeks information that is neither relevant nor proportional to
the needs of the case. Bestwall further objects to this Request on the ground that it seeks
Subject to and without waiving its objections, Bestwall directs the Claimants’
Representatives to the previously produced fields in the PACE Extract from the PACE Claims
Services database concerning defense costs. Bestwall also refers the Claimants’ Representatives
to Bestwall’s Answer to Interrogatory No. 1. If not already produced, Bestwall will produce
documents sufficient to show aggregate defense costs paid to defend and resolve the Bestwall
Mesothelioma Claims during the Relevant Time Period.
22
cost of defense for each Resolved Mesothelioma Claim and/or the total defense costs for all
Resolved Mesothelioma Claims.
asbestos- contaminated talc in the GP Joint Compound Products.
term “GP Joint Compound Products.” Bestwall objects to this Request on the ground that it seeks
privileged documents concerning asbestos-containing or allegedly asbestos-containing products,
including information regarding the use of talc, at Bates numbers BW‐Ch11‐00121763–BW-Ch11-
00141269. Bestwall will conduct a reasonable search for and will produce, if located, additional
non-privileged documents concerning asbestos-contaminated talc in the Pre-1978 Asbestos-
Containing Joint Compound Products.
source of talc used in GP Joint Compound Products.
term “GP Joint Compound Products.” Bestwall incorporates as if fully set forth herein its
23
REQUEST NO. 39: All Documents or Communications with trade organizations, including
but not limited to Gypsum Association Safety Committee, regarding health risks associated
with products containing or contaminated with asbestos.
the needs of the case. Bestwall objects to this Request on the ground that it seeks information
from disclosure.
privileged documents concerning the Gypsum Association at Bates numbers BW-Ch11-
00141311–BW-Ch11-00141312. Bestwall will conduct a reasonable search for and will produce,
if located, additional non-privileged documents responsive to this Request.
REQUEST NO. 40: All Documents or Communications related to the amounts necessary to
fund a 524(g) trust to finally and fairly resolve current and future Gypsum Asbestos PI Claims.
term “Gypsum Asbestos PI Claims.” Bestwall objects to this Request on the ground that it seeks
protections from disclosure. Because this Request appears to be directed to attorney-client
communications or attorney work product in this estimation proceeding or framed as an overly
broad catch-all request for anything relevant to the proceeding, Bestwall will not produce
documents responsive to Request No. 40 other than those produced in response to other of the
Requests in connection with the Bestwall Mesothelioma Claims.
24
REQUEST NO. 41: All Documents or Communications related to the negotiation and
funding for the North Carolina trust established in December 2020.
proportional to the needs of the case. Bestwall objects to this Request on the ground that it seeks
protections from disclosure. Bestwall will not produce documents responsive to Request No. 41.
REQUEST NO. 42: All Documents constituting, referring to, relating to, or concerning Old
GP’s identified change in legal strategy in 2005 and 2006 which NERA Economic Consulting
referenced in the report dated February 4, 2014, and produced as Bates Number BW-Ch11-
00012860 PEO to BW-Ch11-00012885 PEO, and relied upon to estimate the fixed-cost defense
investment in the updated forecast of Old GP’s asbestos liabilities for the ten-year period from
January 2014 through December 2023.
proportional to the needs of the case. Bestwall further objects to this Request on the ground that
it seeks information subject to the attorney-client privilege, work product doctrine, and/or other
REQUEST NO. 43: All Documents or Communications regarding any deposition noticed
pursuant to (i) paragraph 6 of any of the agreed orders (original, Second, Third, Fourth, Fifth,
Sixth, Seventh, Eighth, Ninth, Tenth, Eleventh, Twelfth, and Thirteenth) Regarding Debtor’s
Request For Extension Or Application Of The Automatic Stay To Certain Actions Against Non-
Debtors [D.I. 30, 32, 33, 46, 41, 91, 125, 136, 141, 152, 157, 160, 162] or (ii) paragraph 5 of the
Memorandum Opinion and Order Granting the Debtor’s Request For Preliminary Injunctive
Relief [D.I. 164].
the needs of the case. Bestwall objects to this Request on the ground that it seeks information
25
from disclosure. Bestwall will not produce documents responsive to Request No. 43.
REQUEST NO. 44: All Documents necessary to replicate or reproduce the estimation of
aggregate “Legal Liability,” as set forth in the Report of Charles E. Bates, PhD, dated
February 15, 2013, and adopted by the United States Bankruptcy Court for the Western
District of North Carolina in the case of In re Garlock Sealing Technologies, LLC. See 504
B.R. 71 (Bankr. W.D.N.C., Jan. 10, 2014).
the needs of the case. Bestwall objects to this Request because it calls for the production of
documents that are not in Bestwall’s possession, custody, or control. Bestwall, however, will
produce all documents the production of which is called for in Civil Rule 26 concerning disclosures
to be made by or on behalf of testifying experts.
REQUEST NO. 45: All Documents related to services Bates White has ever performed for
Old GT2 or any of its Affiliates since 2003.
the needs of the case. Bestwall further objects to this Request on the ground that it seeks
protections from disclosure. Any work performed by Bates White for Old GP was undertaken in
anticipation of or in connection with the ongoing defense of litigation.
2
Bestwall interprets the Claimants’ Representatives’ use of “Old GT” instead of “Old GP” in this Request as a
typographical error.
26
Dated: May 17, 2021 Respectfully submitted,

/s/ Garland S. Cassada______________
Stuart L. Pratt (NC Bar No. 43139)
Telephone: (704) 377-2536
Facsimile: (704) 378-4000
spratt@robinsonbradshaw.com

JONES DAY
Dallas, Texas 75201
Telephone: (214) 220-3939
Facsimile: (214) 969-5100

JONES DAY
Telephone: (404) 581-3939
Facsimile: (404) 581-8330

IN POSSESSION
27
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was served via electronic mail to the following:
Mark P. Goodman, Esq. (mpgoodman@debevoise.com)

M. Natasha Labovitz, Esq. (nlabovitz@debevoise.com)
Debevoise & Plimpton LLC
919 Third Avenue
New York, NY 10022
Natalie Ramsey, Esq. (nramsey@rc.com)

Davis Lee Wright, Esq. (dwright@rc.com)
Robinson & Cole LLP
1201 North Market Street, Suite 1406
Glenn Thompson, Esq. (gthompson@lawhssm.com)

Hamilton Stephens Steele + Martin, PLLC
Charlotte, NC 28202
Edwin J. Harron, Esq. (eharron@ycst.com)

Sharon M. Zieg, Esq. (szieg@ycst.com)
Rodney Square
Young Conaway Stargatt & Taylor, LLP
1000 North King Street
Felton E. Parrish, Esq. (felton.parrish@alexanderricks.com)

Alexander Ricks PLLC
1420 East 7th Street, Suite 100
Charlotte, NC 28204
This 17th day of May, 2021.

Garland S. Cassada
28
EXHIBIT F
From: Schneider, Doc <DSchneider@KSLAW.com>

To: Jones, James M.; Zieg, Sharon
Cc: Del Medico, Jennifer L.; 'Ramsey, Natalie D.'; Bradley, Elisabeth; Kaplan, Jeff A.; Rohrer,
Nicholas J.; Loughman, Paul; Gordon, Gregory M.; Ellman, Jeffrey B.; Cassada, Garland;
'Wright, Davis L.'; Edwards, Erin; Harron, Edwin; Tucker John (King & Spalding - Atlanta,
GA); Antine, Greg; Clements, Ernest; Schneider Richard (King & Spalding - Atlanta, GA)
Subject: Bestwall: Debtor's Initial Rolling Production
Sharon and Team:
Jim Jones has just sent you the Debtor’s responses and objections to the ACC/FCR requests for production and
interrogatories.
The Debtor is also making an initial rolling production as described in this email.
First, I set forth below a link to an FTP site with two dat. files and one zip file. The zip file contains certain non‐privileged
documents responsive to Requests No. 22 and 23. The dat. files contain available metadata for certain previously
produced documents to which Bestwall refers in its Answers and Responses.
I am sending the link for you, Sharon, with your credentials, in a separate email immediately following this one. When
you login, you will get an email to your email address with a code to enter ‐‐ after you have entered your email address
and the password below.
SFTP Address: https://kingspalding.ftptoday.com
Workspace: /Bestwall_Productions/
Everyone on this email will be sent his or her own credentials in case they want to review the materials on the FTP site.
I was reminded today that the files on the FTP site open with 7‐Zip or similar file extracting applications. You should
right click to open in 7‐Zip and then select Extract Data to view the files and images.
Second, we are sending a set of 15 discs and 2 hard drives today for overnight delivery to your office as follows:
Sharon M. Zieg
Young Conway Stargatt & Taylor, LLP
Rodney Square
1000 North King Street
Wilmington, Delaware 19801
The discs and hard drives are accompanied by a series of prior production cover letters that describe what the discs and
hard drives contain.
Have a good evening and I send my best regards,
Doc Schneider
1
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2
EXHIBIT G

Sent: Thursday, May 27, 2021 2:33 PM
To: Zieg, Sharon; Del Medico, Jennifer L.
Cc: Edwards, Erin; Ramsey, Natalie D.; Gordon, Gregory M.; Ellman, Jeffrey B.; Garland
Cassada (GCassada@rbh.com); Wright, Davis L.; Harron, Edwin; Bradley, Elisabeth;
Kaplan, Jeff A.; Schneider Richard (King & Spalding - Atlanta, GA); Pratt, Stuart;
Loughman, Paul
Subject: Bestwall: Yesterday Afternoon's Meet-and-Confer regarding Document Review, Bates
White Reliance Materials, and Rule 502
Attachments: Bestwall Searches Iteration 4_05.26.2021.xlsx
Sharon and team: Thank you for the time we spent yesterday talking about Bestwall’s ongoing collection and review
effort, the Bates White reliance materials and your request for logging related thereto, and Rule 502 matters. I set out
here just a few notes in follow‐up:
1. As I said we would, we have run the search terms set forth on the attached report against the ESI of the 14 custodians
for whom we have collected data to date. The terms are the product of our effort to accommodate Sharon’s proposed
edits of Tuesday evening. (Jennifer will send a redline shortly.) These terms hit upon roughly 240,000 unique
documents with families. We are assessing the practicality of reviewing this expanded corpus with the aid of Continuous
Active Learning the deployment of which we initiated this week as I also mentioned yesterday. We will report back after
the holiday weekend.
2. Yesterday’s conversations concerning privilege logging in respect of the Bates White reliance materials ended with
our commitment to provide a log for those documents within the production that were either redacted for privilege or
appear as a "slip sheet" or the like in the production for the same reason. The redacted text and slip‐sheeted
documents were not dispatched to Bates White and were not produced to you thereafter. We have tabled temporarily
the issue of logging other documents that may have been a part of the case files from which the Bates White reliance
materials were extracted and agreed to revisit that after we receive your proposed case file sample and then discuss
sampling and related logging issues together.
3. Our discussions of a potential Rule 502 agreement and order included exchanges of recollections concerning the
extent to which the parties proceeded under some Rule 502 undertaking in Bondex, the fact that they did not so
proceed in Garlock but rather complied with an order from Judge Hodges, and concluded with your team agreeing to
formalize its proposal in this regard with a proposed agreement and order. We confirmed Bestwall's position that no
privilege waiver has occurred and expressed concern about the potential breadth of any agreement and order you might
propose but will consider the proposal that you tender. Both sides agreed to review their files to find the order that may
have been entered in Bondex. Yesterday, Natalie provided some correspondence and pleadings from Bondex although
the order included in those materials does not appear to relate to the production of settlement information. We are in
the process of reviewing files that our firm may still maintain to find the order that may have been entered in Bondex.
Thanks to all. Have a nice holiday weekend.
Partner
JONES DAY® ‐ One Firm Worldwide℠
250 Vesey Street
New York, NY 10281‐1047
Office +1.212.326.7838
EXHIBIT H

Sent: Thursday, June 24, 2021 11:53 AM
To: Zieg, Sharon; Ramsey, Natalie D.
Cc: Del Medico, Jennifer L.; Edwards, Erin; Gordon, Gregory M.; Ellman, Jeffrey B.; Garland
Loughman, Paul
Subject: RE: Bestwall/Document Discovery: Meet-and-Confer on Wednesday
Sharon, Davis, and team: Thanks for virtually gathering with us yesterday afternoon. Here is a note of follow‐
up.
1. I updated you on our review and production efforts, including that (i) we had upped our first‐level review
team to 43 lawyers who had completed first‐level review of more than 50% of collected custodial ESI and
roughly 50% of collected custodial hardcopy documents, which ESI and digitized hardcopy hit on search terms;
(ii) pace of second‐level review and, therefore, rolling production is slowed, however, because approximately
90% of those documents identified as responsive are also flagged as privileged, which requires additional time
for second‐level assessment. I shared that we hoped to make our second rolling production yet this week.
2. We now anticipate that we will substantially complete production of responsive documents from these two
caches on or before July 12 and July 29, respectively, or no more than roughly 30 days after the default
substantial completion date set out in our Discovery Plan. After sharing this, I asked that the ACC/FCR let us
know in the next day or so if we have their agreement to these substantial completion dates so that we might
avoid approaching the Court in this regard. Sharon and Davis said they would confer and get back to me, and I
appreciate it.
3. As I mentioned (and have before), excluded from these figures and dates are (i) the custodial ESI of the late
Ms. Turnipseed collection and “reviewability” of which has taken more time than we had hoped (her hard
copy documents, however, are included in the review figures set forth in item 1 above) and (ii) previously
unproduced documents within the 2,200 case files from which the Bates White reliance materials were drawn
and documents to be collected from the 500 case files you identified for the first time on May 27. I shared
with you that we estimated the volume of this material to be on the order of 500,000 or more documents the
review and/or production of which would impose severe burden and take material additional time. We
discussed how that might be addressed through search terms or otherwise and we look forward to any
proposals you might have.
4. We did receive from you shortly before our call a draft Rule 502 Order and accompanying “Protocol.” On
quick scan and in response to our inquiry during the call, you shared that you intended the order and protocol,
at least in part, to ease some of the burden just mentioned though you and Davis were uncertain of precisely
from what corpus of files the “sample” described in the protocol would be drawn. We, of course, will review
the order and protocol and respond promptly. In the interim, however, please explain to us precisely what
your new sample is intended to include. You indicated it was a “subset” of other samples under discussion but
could not tell us more. For example, we cannot discern whether it is a subset of the 2,200 files, a subset of the
2,200 files plus the 500 files, or something other.
5. Stuart Pratt shared that he estimates that the privilege review for those documents within the Bates White
reliance materials that were redacted or slipsheeted for privilege (and, therefore, produced neither to Bates
White nor the ACC/FCR) will be complete by July 16.
6. Doc Schneider said that in response to your inquiries regarding Requests 22 and 23, Bestwall already had
produced the Holm letter and would produce gathered pleadings files for the NYCAL dispute, the Holm
deposition and exhibits, the Nelson production mentioned in Doc’s NYCAL cover letter, and the related
privilege logs served in the NYCAL matter, which we would adjust and serve in this proceeding, as well.
7. I also noted that we anticipated sharing with you shortly a draft template categorical log that may ease
logging efforts, which, without easing, will be decidedly burdensome.

Partner
250 Vesey Street
New York, NY 10281-1047
Office +1.212.326.7838
EXHIBIT I

Sent: Thursday, June 17, 2021 5:37 PM
To: Zieg, Sharon; Ramsey, Natalie D.
Cc: Del Medico, Jennifer L.; Edwards, Erin; Gordon, Gregory M.; Ellman, Jeffrey B.; Garland
Loughman, Paul
Subject: Bestwall: Yesterday Afternoon's Meet-and-Confer on Selected Discovery Matters
Sharon and team: Thank you for the time we spent yesterday talking about Bestwall’s ongoing collection and review
effort and related matters. I set out below just a few notes by way of follow‐up:
1. Substantial Completion: I shared that we currently estimate that we will substantially complete collection, review,
and production of custodial ESI for 14 of our 15 custodians by July 11, 2021, if we add the ESI hits generated from the
FCR’s most recent proposed search terms. I then conveyed that we estimate substantially completing collection,
digitization, review, and production of hard‐copy documents by July 29, 2021. Excluded from these estimates are Ms.
Turnipseed’s custodial ESI; documents from the 500 new claims files identified by the ACC/FCR on May 27, 2021; and
documents from the ~2,200 claims files from which the Bates White reliance materials were drawn.
2. I noted that we need to hear from the ACC/FCR on whether they will agree to our proposed substantial completion
dates in the coming days and hopefully early next week. If we do not hear or do not reach agreement, we will approach
the Court to set the substantial completion date(s) as called for in the Discovery Plan. You indicated that you would like
to see our next rolling production before confirming your position; we now are aiming to make that production
tomorrow or early next week.
3. We additionally shared that we do not now intend to run search terms on the sales‐records database; it is already
available to you via the eMerge platform. We also do not intend to produce documents or data from the e‐billing
portion of the Mitratech/Acuity database, as that portion is not responsive, and we are still assessing the extent to
which any Mitratech/Acuity database holds responsive, non‐privileged, non‐duplicative documents. I informed you that
the shared Q Drive no longer exists and was merged into the G Drive documents from which we are collecting (save for
publicly available Garlock documents, which constitute the vast majority of documents on the Drive); we will run search
terms on the documents we do collect from the G Drive.
4. You agreed to send us proposed search terms for Requests 25–29 and 42, and we agreed to send you some
preliminary search terms for Request 42.
5. We informed you that we had not yet received from the ACC or FCR any proposed Rule 502 Order. We took from our
conversation that a draft may be underway but was not yet ready to be shared with us.
6. We confirmed that we could not locate an analogous order from the Bondex case.
7. We also discussed again the undue burden that we believe would be imposed by document‐by‐document logging of
those documents that will be withheld as privileged from the 15 in‐house and outside counsel custodians, not to
mention the privileged documents in the many hundreds of claims files. We will prepare a form or template categorical
log to share with you that might address our concerns, at least in part.
We proposed convening again early next week to discuss these issues. Permit me to propose Wednesday. Is there a
time on that day that might work for your team?
Thank you.

Partner
250 Vesey Street
New York, NY 10281-1047
Office +1.212.326.7838
EXHIBIT J
spratt@robinsonbradshaw.com
704.377.8168: Direct Phone
704.339.3468: Direct Fax
March 31, 2021
VIA EMAIL
Natalie Ramsey, Esq. Edwin J. Harron

Davis Wright, Esq. Sharon M. Zieg
Robinson & Cole LLP Young Conaway Stargatt & Taylor, LLP
1201 North Market Street, Suite 1406 1000 North King Street
Wilmington, DE 19801 Wilmington, DE 19801
nramsey@rc.com eharron@ycst.com
dwright@rc.com szieg@ycst.com
Re: In re Bestwall LLC, Case No. 17-31795 (Bankr. W.D.N.C.)
Dear Counsel:
This letter follows up on our discussions during the estimation CMO meet and confer
process concerning a production of reliance materials that Bates White has requested for 2,238
resolved mesothelioma claims. Bates White will review and use those materials for its initial
analysis of resolved Bestwall claims and its estimation analysis more generally. The 2,238
claims are those among a random sample of 2,407 resolved mesothelioma claims that Bates
White created for which reliance materials, as described below, could be located.
Identification of Claims: In response to your request, and in advance of our production of

the reliance materials, we will be sending via secure link a spreadsheet listing the 2,407 claims in
the sample and certain information about each claim. The spreadsheet is designated as
“Professional Eyes’ Only” under the Agreed Protective Order Governing Confidential
Information (Dkt. 337) because it contains extracts of information in the Asbestos Claims
Database (as defined in that Order).
Reliance Materials: We use the term “reliance materials” to refer to the documents from
the following categories Bates White requested and will receive, to the extent available, for each
claim in the sample. Bates White did not request, and will not receive, any privileged documents.
ROBINSON, BRADSHAW & HINSON, P.A. : robinsonbradshaw.com

Charlotte Office : 101 N. Tryon St., Ste. 1900, Charlotte, NC 28246 : 704.377.2536
March 31, 2021

Page 2
Categories of Reliance Materials

Complaints Settlement & Dismissal Records
Deposition Transcripts Substantive Affidavits
Deposition Exhibits Substantive Correspondence
Employment Records Trial Transcripts
Expert Records Trust Documents
Plaintiff’s Discovery Responses Other1
The reliance materials comprise about 85,000 documents for 2,238 claims in the sample.
Those claims are identified in the spreadsheet we will send. As noted, reliance materials were not
found for the other claims in the sample of 2,407 claims.
We will produce the reliance materials consistent with paragraph 3(e) of the Case
Management Order for Estimation of the Debtor’s Liability for Mesothelioma Claims (Dkt.
1685). All documents will be produced with the same bates-numbering used for productions to
Bates White.
As we discussed, Bates White may in the future request additional documents related to
these or other resolved claims. By the end of April, however, you will have Bates White’s initial
reliance materials related to resolved mesothelioma claims.
Sincerely,
Stuart L. Pratt
cc: Gregory M. Gordon

Jeffrey B. Ellman
Garland S. Cassada
Richard C. Worf, Jr.
Mark P. Goodman
M. Natasha Labovitz
1
Documents that did not fit within one of the defined categories but that may contain claim information similar to
the other categories were classified as “Other.”
EXHIBIT K

CHARLOTTE DIVISION
In re Chapter 11
BESTWALL LLC,1 Case No. 17-31795 (LTB)

Debtor.
ORDER SETTING DATE FOR

SUBSTANTIAL COMPLETION OF DOCUMENT PRODUCTION
This matter came before the Court on Debtor’s Motion to Set Date for Substantial
Completion of Document Production [Dkt. ___] (the “Motion”). Based upon a review of the
Motion, and any response, the Court hereby ORDERS, ADJUDGES, AND DECREES that:
1. The dates by which the Debtor’s production of documents in response to the First
Set of Requests for Production of Documents served by the Official Committee of Asbestos
Personal Injury Claimants and Sander L. Esserman, the legal representative for future asbestos
claimants (together, the “Claimants’ Representatives,” and, together with the Debtor, the
“Parties”), shall be substantially complete are as follows: on or before July 12, 2021, for
electronically stored information of identified custodians; and on or before July 29, 2021, for
hardcopy documents collected from those custodians.
1 The last four digits of the Debtor's taxpayer identification number are 5815. The Debtor's address is
133 Peachtree Street, N.E., Atlanta, Georgia 30303.
2. These deadlines may be extended by consent of the Parties or further order of the
Court.
3. This Court shall retain jurisdiction to hear and determine all matters involving the
interpretation, implementation, or enforcement of this Order.
This Order has been signed electronically. United States Bankruptcy Court
The Judge’s signature and court’s seal
appear at the top of the Order
-2-

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Case 17-31795 Doc 1841 Filed 06/28/21 Entered 06/28/21 22:12:50 Desc Main

UNITED STATES BANKRUPTCY COURT

DEBTOR’S MOTION TO SET DATE

Committee, the “Claimants’ Representatives”).

Court to set the date.

agreement to the Debtor’s proposed substantial completion dates.

liabilities on Gypsum Asbestos PI Claims.”); 11 (“All Documents constituting, referring to,

4, 5, 6, 14, 15, 16.

privileged and to log that which is.

more than roughly 30 days.

The Discovery Plan

5. The Discovery Plan provides that productions of documents in response to the

therefore, would be June 29, 2021.

review, and production facts would permit.

The Debtor’s Diligence

than materially challenging.” Id.

10. The Debtor’s messaging on substantial completion remained consistent: “[W]e

from D. Schneider to S. Zieg, et al. (attached as Exhibit F).

completion on or before June 29, 2021.

privileged attorney-client communications or attorney work product, at least in part, which

al. (attached as Exhibit H).

default substantial completion date set out in our Discovery Plan”).

and are not the subject of this Motion.3

appropriate dates for the substantial completion of production.

Exhibit K a proposed order granting this relief.

Dated: June 28, 2021 Respectfully submitted,

Gregory M. Gordon (TX Bar No. 08435300)

Jeffrey B. Ellman (GA Bar No. 141828)

ATTORNEYS FOR DEBTOR AND DEBTOR

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UNITED STATES BANKRUPTCY COURT

BESTWALL LLC,1 Case No. 17-31795

DEBTOR’S INITIAL DISCLOSURES

Estimation Proceeding (as defined in the CMO).

even if directed to the subject matters described herein.

claims before the restructuring of Old GP in 2017.2

1. Melissa Baugher – Senior Counsel; member of Old GP asbestos litigation group.

defense, and settlement of asbestos-related personal injury claims; asbestos exposures

asbestos contamination in talc.

2. Melissa Brown – Chief Counsel Legislative Legal Affairs; member of Old GP

associated with such exposures.

3. John Childs – Assistant General Counsel, Litigation; head of Old GP litigation

management, defense, and settlement of asbestos-related personal injury claims; asbestos

asbestos contamination in talc.

5. Karl Eichelberger – Senior Counsel; member of Old GP asbestos litigation group.

sales of asbestos-containing joint compound; and allegations of asbestos contamination in talc.

6. Brenda Godfrey – Senior Counsel; member of Old GP asbestos litigation group.

sales of asbestos-containing joint compound; and allegations of asbestos contamination in talc.

7. Shannon Harris – Senior Counsel; member of Old GP asbestos litigation group.

sales of asbestos-containing joint compound; and allegations of asbestos contamination in talc.

8. Terence Hatcher – Litigation Support Assistant; member of Old GP asbestos

9. Wade Marionneaux – Senior Counsel; member of Old GP asbestos litigation

asbestos-related personal injury claims; asbestos exposures attributable to other defendants,

exposures; sales of asbestos-containing joint compound; and allegations of asbestos

management, defense, and settlement of asbestos-related personal injury claims.

joint compound; and allegations of asbestos contamination in talc.

defense, and settlement of asbestos-related personal injury claims.

sales of asbestos-containing joint compound; and allegations of asbestos contamination in talc.

14. Sara Turnipseed (deceased) – in-house counsel at Old GP (1983-1996), with

litigation matters (1996-2013), including as National Coordinating Counsel (1996-2005). Hard

joint compound; and allegations of asbestos contamination in talc.

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