case 14-31848-krh doc 1528-25 filed 12/15/15 entered 12/15

SSA-1826 ITEMIZED STATEMENT OF EARNINGS* * * FOR SSN XXX-XX-9083 * .* *

EMPLOYER NUMBER: 61-0701721LANCE COAL CORPORATIONHC 85 BOX 177WHITESBURG KY 41858-0000

1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1979 $18,635.371980 $13,069.67

EMPLOYER NUMBER: 62-0933838BLUE DIAMOND MINING INCPO BOX 59015KNOXVILLE TN 37950-9015

YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1981 $30,166.471982 $15,957.131984 $18,719.321985- $39,600.001986 $42,000.001987 $42,520.16

EMPLOYER NUMBER: 61-0875443ALLIANCE CORPORATION116 E COLLEGE STGLASGOW KY 42141-2514

YEAR19831984

EMPLOYER NUMBER: 61-1013907COFFEE CUP COAL COMPANY INC•PO BOX 14ISOM KY 41824-0014

YEAR 1ST QTR 21984

EMPLOYER NUMBER: 62-0133200BDCC HOLDING COMPANY INC901 E BYRD ST STE 1600RICHMOND VA 23219-4054

3RD QTR 4TH QTR TOTAL$9,638.00$1,656.00

3RD QTR 4TH QTR TOTAL$6,204.59

YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1988 $43,878.461989 $42,975.601990 $42,547.88

PAGE

Case 14-31848-KRH Doc 1528-25 Filed 12/15/15 Entered 12/15/15 15:08:47 Desc 1199 of 4

SSA-1826 ITEMIZED STATEMENT OF EARNINGS* * * FOR SRN XXX-XX-9083 * * *

1991

EMPLOYER NUMBER: 61-0993751MAGDI FAHMY PSC85 LOYOLA DRORMOND BEACH FL 32176-7829

$20,628.58

YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1992 $1,872.50

EMPLOYER NUMBER: 61-1155722ADENA FUELS INC271 W SHORT ST STE 805LEXINGTON KY 40507-1217

1992.1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL

$1,700.00

EMPLOYER NUMBER: 61-1204007LEATHERWOOD- ENERGY INCPO BOX 11JEFF KY 41751-0011

Y19921993

1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL$27,414.78$14,180.40

EMPLOYER NUMBER: 61-0997055DIXON ELECTRIC INC516 W FOURTH STLEXINGTON KY 40508-1206

YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1993 $1,940.00

EMPLOYER -NUMBER: 61-1148318ARC ENERGIES INCPO BOX 3633PIKEVILLE KY 41502-3633

YEAR 1ST QTR 2ND QTR 3RD QTR 4TH QTR TOTAL1993 $788:25


FILED ENTERED TENDEREDCOSTS PAID SUMMONS DATE IZ 7 ROGER D. COLUNSPERRY CIT CLERK

COMMONWEALTH OF KENTUCKY BY' PERRY CIRCUIT COURT

CIVIL ACTION NO.: U7-Cr-O0753

CONNIE COX, EXECUTRIXOF ESTATE OF MERLE COX

vs.

3 M COMPANY, a foreign corporation, f/k/a MINNESOTAMINING AND MANUFACTURING COMPANY; MINE SAFETYAPPLIANCES COMPANY, a foreign corporation; AMERICANOPTICAL CORPORATION, a foreign corporation; MINESERVICE COMPANY, INC., a Kentucky corporation; KENTUCKYMINE SUPPLY COMPANY_ a Kentucky corporation; ANDJIM ZIMMERMAN, Executive Director, Office of WorkplaceStandards and. Acting Director, Division of Workers CompensationFunds, f/k/a the SPECIAL FUND,

PLAINTIFF

DEFENDANTS

COMPLAINT

Comes the above named Plaintiff and for her cause of action against the above

named Defendants, respectfully states:

INTRODUCTION

1) This Complaint is filed on behalf of the above named Plaintiff who:

a) was married to Merle Cox who worked as a coal miner within the

Commonwealth-of Kentucky, and who died September 30, 2006,

b) whose husband was exposed to coal, rock or sand dust as a result

of such coal mine employment,

whose husband suffered from an occupational lung disease known

as Coal Workers' Pneumoconiosis and/or Silicosis, commonly referred to as Black Lung

Page 1 of 18

0,C.


by virtue of the failure of the respirators/dust masks Plaintiff's husband used to protect

him from exposure to coal rock and sand dust while working as a coal mine employee.

2) Plaintiffs mailing address is 4398 Lotts Creek Road, Hazard, Kentucky

41701. The Plaintiff's husband worked as a coal miner within the Commonwealth of

Kentucky. Plaintiff was duly appointed Executrix of the Estate of her deceased husband

by Order of the Perry District Court-entered on 1211/06. Copy attached as Exhibit A.

PARTIES MADE. DEFENDANTS HEREIN

3) Defendants, 3M Company, formerly known as Minnesota Mining and

Manufacturing Company (3M) and Mine Safety Appliances Company (MSA) are or were

foreign corporations authorizing to do, have done, or are still doing business in the

Commonwealth of Kentucky in various counties, including Perry County, which

represents substantial and not isolated activities in this State and who manufactured the

respirators/dust masks used by one or more of the Plaintiffs. The agent for service of

process for Defendants 3M, and MSA is CT Corporation System, Kentucky Homelife

Building, Room 1102, Louisville, Kentucky 40202.

4) Defendant, American Optical Corporation (AO) is or was a foreign

corporation; authorizing to do, have done, or is still doing business in the

Commonwealth of Kentucky in various counties, including Perry County, vt.thich

represents substantial and not isolated activities in this State and who manufactured the

respirators/dust masks used by the Plaintiff. The agent for service of process for

Defendant, AO, is the Secretary of State.

5) Defendants, 3M, MSA, and AO are collectively referred to as the

Respiratory Protection Defendants. The Respiratory Protection Defendants

Page 2 of 18


case 14-31848-krh doc 1528-25 filed 12/15/15 entered 12/15

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