What Is Plaintiff's Allegationss

Defendant, Union Oil Company of California, d/b/a/ UNOCAL (“Unocal”) responds to Plaintiffs’ allegations as follows. To the extent the allegations of the Amended Complaint are directed to Defendants other than Unocal, Unocal is without sufficient knowledge or information to form a belief as to the truth of the averments and, therefore, denies them.

JURISDICTION AND VENUE

1. Denied. The allegations of Paragraph 1 are legal conclusions to which no response is required. To the extent a response is required, Unocal denies the allegations. By way of further response, for the reasons set forth in Unocal’s Preliminary Objections to Plaintiffs’ Amended Complaint, Unocal specifically denies that it is subject to personal jurisdiction in this
Denied. Plaintiff’s allegations of Paragraph 8 constitute conclusions of law to which no response is required. To the extent a response is required, Unocal denies the allegations.
9. Denied. Plaintiff’s allegations of Paragraph 9 constitute conclusions of law to which no response is required. To the extent a response is required, Unocal denies the allegations. Further, Unocal specifically denies that Plaintiff Paul Simmons was exposed to any Unocal product or that he was exposed to benzene from any Unocal product, and it specifically denies that it is liable to Plaintiffs.
10. Subparts (a) through (r): Denied. The allegations of these subparagraphs are directed to Defendants other than Unocal, and Unocal is without sufficient knowledge or information to form a belief as to the truth of the averments. Therefore, Unocal denies the
Unocal incorporates its answers to all preceding allegations as though fully set forth.
12. Denied. Unocal denies that Plaintiff Paul Simmons was exposed to any Unocal product or that he was exposed to benzene from any Unocal product. Further, the allegations of Paragraph 12 constitute conclusions of law to which no response is required. To the extent a response is required, Unocal denies the allegations.
13. Denied. The allegations of Paragraph 13 constitute conclusions of law to which no response is required. To the extent a response is required, Unocal denies the allegations. Unocal also specifically denies that Plaintiff Paul Simmons was exposed to any Unocal product or that he was exposed to benzene from any Unocal product.
14. Denied. The allegations of Paragraph 14 constitute conclusions of law to which no response is required. To the extent that a response is required, without specifying a relevant time period at issue, the levels of alleged exposure to benzene, or the specific disease at issue, Unocal is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14. Therefore, Unocal denies the allegations in Paragraph