Instruction Letter to Claimants
Existing Asbestos Claims
Re: In the Matter of the Companies' Creditors Arrangement Act, R.S.C., 1985, c. C-36, of Asbestos Corporation Limited – Instruction Letter to Claimants
Dear Sir or Madam,
This letter provides instructions intended to assist you in completing and submitting a Proof of Claim in respect of any Existing Asbestos Claim [1], in accordance with the Asbestos Claims Bar Date Order issued by the Superior Court of Québec (Commercial Division) on January 6, 2026, as rectified on January 7, 2026, (the “Asbestos Claims Bar Date Order”).
Please note that this letter is only a guide. In case of discrepancy between the terms of this letter and those of the Asbestos Claims Bar Date Order, the terms of the Asbestos Claims Bar Date Order shall prevail.
Capitalized terms in this letter have the meanings ascribed to them in the Asbestos Claims Bar Date Order, which can be found on the Monitor’s website, along with summaries of the sales of asbestos by ACL in Canada and the U.S. for the sole purpose of evaluating or advancing your position in the Insolvency Proceedings including for the completion of a proof of claim and all documentation relating to the restructuring process, at the following address: https://www.raymondchabot.com/en/business/public-records/asbestos-corporation/.
Covered by this notice is any person who may have an Existing Asbestos Claim. Any such person should carefully review and comply with the provisions of the Asbestos Claims Bar Date Order. In accordance with the Asbestos Claims Bar Date Order, any person having an Existing Asbestos Claim must submit a Proof of Claim, so as to be received by the Monitor by no later than September 10, 2026 (being the “Claims Bar Date” as established by the Monitor’s Claims Bar Date Certificate)
EXISTING ASBESTOS CLAIMS WHICH ARE NOT RECEIVED BY THE CLAIMS BAR DATE WILL FOREVER BE BARRED AND EXTINGUISHED.
For any additional information on how to complete the Proof of Claim, please refer to the Monitor’s website, or communicate with the Monitor, whose contact information is below.
We invite you to refer to the following documents, copies of which are attached to this letter:
- Notice to Claimants
- Blank Proof of Claim Form
The below guide is designed to assist those willing to submit a Proof of Claim.
Section 1 – Particulars of the Claimant
- Any Claimant who wishes to assert an Existing Asbestos Claim in the CCAA Proceedings, including any Claimant who is already a party to legal proceedings in respect of an Existing Asbestos Claim is required to file a Proof of Claim with the Monitor. You will find the complete definition of “Existing Asbestos Claim” in the Asbestos Claims Bar Date Order, as complemented by the Monitor's Claims Bar Date Certificate.
- The Claimant must indicate its full legal name, address, and contact information.
Section 2 – Proof of Claim
- The Claimant must identify which of the Debtor, General Dynamics, and/or Insurers, and their respective director and officers (if applicable), it wishes to assert an Existing Asbestos Claim against.
Section 3 – Amount and Particulars of Claim
- The Claimant must provide the particulars requested and set out the basis for its Existing Asbestos Claim, including the description of any facts and evidence giving rise to the Existing Asbestos Claim, as specifically listed and requested in the Proof of Claim.
- The Claimant is under a duty to timely supplement his or her responses in the Proof of Claim if he or she learns that prior information is in some material respect incomplete or incorrect, and if the additional or corrective information has not otherwise been made known to the Debtor, General Dynamics, and/or Insurers. The duty to supplement is not limited to providing documents or information that existed at the time of filing an initial or prior Proof of Claim but, rather, includes any additional information without reference to the date of its existence. This would include, for example, new information learned about exposures to asbestos.
- The Claimant may attach additional pages to the Proof of Claim, if necessary, including replicating Part E of the Proof of Claim, if there are several locations of exposure.
Section 4 – Supporting Documentation
Each Claimant must include copies of the following documents with the Proof of Claim:
- All depositions taken in any lawsuits listed that relate in any way to the Claimant’s alleged exposures to asbestos or asbestos-containing products;
- All written discovery (including interrogatories and requests for admission) answered on behalf of the Claimant in any of the lawsuits listed in the Proof of Claim;
- All expert reports produced by any party in a lawsuit listed in the Proof of Claim;
- Social Security printout and copy of union, employment, or work‑history records evidencing the Claimant’s alleged exposure to the Debtor’s asbestos (where available) and any other relevant evidence of exposure to the Debtor’s asbestos. In the case of alleged Secondary or Household exposure, provide the Social Security printout and copy of union or employment of the person who worked with or around asbestos or asbestos-containing products who brought home asbestos fibers on his or her clothes (i.e., the Primary Exposed Person);
- Copy of medical records (or autopsy report) confirming diagnosis and establishing asbestos exposure as a contributing factor in causing the disease;
-
Other medical evidence for the review of the Proof of Claim, including:
For Malignancies:
- Evidence establishing the latency period between the date of first exposure to asbestos or asbestos-containing products and the diagnosis
- Physical examination by the physician providing the diagnosis; and/o
- Diagnosis by a board-certified pathologist; and/o
- Diagnosis by a pathology report prepared at or on behalf of a hospital accredited by JCAHO (Joint Commission on Accreditation of Healthcare Organizations).
For Non-Malignancies:
- Physical examination by the physician providing the diagnosis; and/o
- ILO (International Labor Office Classification System) report showing either bilateral interstitial fibrosis, bilateral pleural plaques, bilateral pleural thickening, or bilateral pleural calcification; and/or
- Pathology report showing either bilateral interstitial fibrosis, bilateral pleural plaques, bilateral pleural thickening, or bilateral pleural calcification. Pathological proof of asbestosis may be based on the pathological grading system for asbestosis in the Special Issue of the Archives of Pathology and Laboratory Medicine, “Asbestos-associated Diseases,” Vol. 106, No.11, App.3 (October 8, 1982); and/or
- Written report of chest x-rays read by a qualified B reader or other qualified physician showing either bilateral interstitial fibrosis, bilateral pleural plaques, bilateral pleural thickening, or bilateral pleural calcification; and/or
- Written report of CT scans read by a qualified physician showing either bilateral interstitial fibrosis, bilateral pleural plaques, bilateral pleural thickening, or bilateral pleural calcification; and/or
- Pulmonary function testing (PFT) in compliance with the American Thoracic Society (ATS) ; and/or
- Forced vital capacity (FVC) and forced expiratory volume in one second to forced vital capacity ratio (FEV1/FVC) ; and/or
- Total lung capacity (TLC)
-
Other relevant evidence for the review of the Proof of Claim, including :
- Death certificate
- Certificate of official capacity (administrator, executor, guardian, etc.) or other estate documentation
- Power of attorney
- Letters testamentary or letters of administration.
General
Additional Proofs of Claim may be downloaded from the Monitor's website or may be sent to you if you contact the Monitor using the contact information below and provide your name, mailing address, email address, and fax number. Each Proof of Claim must be signed by the Claimant, before a witness, indicating the place and date, or respect the instructions for online submission on the Monitor’s Claims Process Website if the Proof of Claim is filed online.
The completed and signed Proof of Claim may be sent to the Monitor by one of the following means:
- By mail, courier or registered mail – Canada:
- By mail, courier or registered mail – U.S.
- By facsimile:
- By email:
- Online submission:
National Bank Tower
600 De La Gauchetière Street West
Suite 2000
Montreal, Quebec H3B 4L2
757 Third Ave.
9th Floor
New York, NY 10017
800-711-1070
Each completed Proof of Claim and supporting documents must be sent and received by the Monitor no later than September 10, 2026, being the Claims Bar Date as established by the Monitor’s Claims Bar Date Certificate.
If you have any questions regarding the Asbestos Claims Bar Date Order or the attached documents, please consult the Monitor's Claims Process Website at ACLClaims.com or contact the Monitor at: asbestoscorp@rcgt.com
[1] "Existing Asbestos Claim" means any Claim against the Debtor or General Dynamics, and/or any of their respective predecessors, current or former employees, directors, officers, agents, representatives, assigns, or any of their respective Insurers, that (i) has been advanced (including, without limitation, in any outstanding or pending litigation), that could have been advanced or that could be advanced by, on behalf of, or based on actual or alleged harm to, any Person that has been diagnosed with symptoms or injury as of March 6, 2026, and (ii) arises from, is based upon, is related to, or is in any way connected, directly or indirectly to, exposure to asbestos or an asbestos-containing product which was at any time prior to May 6, 2025, distributed, supplied, or sold, or otherwise placed into the stream of commerce, by the Debtor or any of its predecessors or affiliates. For greater certainty, "Existing Asbestos Claim" includes, without limitation, any Claim for personal injury, sickness, disease, death, wrongful death, fear of disease or other injury, medical monitoring, medical expenses, loss of consortium, loss of support, lost wages, lost household service, economic or business loss, indemnity, contribution, reimbursement, subrogation, property damage, punitive or exemplary damages, statutory or regulatory relief, equitable relief, or any other form of damages or remedy whatsoever, provided, however, that an Existing Asbestos Claim shall not include any "Future Asbestos Claim" (being any Claim of a Person that would otherwise qualify as an Existing Asbestos Claim but for the fact that such Person had not been diagnosed with symptoms or injury as of March 6, 2026)