# Imerys proposed-trust record — sources and claim mapping

**WO-TRUSTS-20261014-IMERYS · Version 1.0-draft · Checked October 14, 2026 · Prepared by Manus.** Tier 2 draft only; no publication or qualified legal review completed. This register accompanies **imerys-proposed-trust-record.md** and **imerys-status-note.md**.

## Evidence and date rules

**A — filed/court:** A retrieved court-filed document or court opinion. A filing supports what was filed, not the truth of every allegation or completion of a proposed transaction. **A — official administrative:** Official case-agent material supports its dated procedural narrative, but is not a substitute for the underlying signed order. **A — reproduced court document:** The original court text on an identified mirror; hosting is disclosed. **B — reliable secondary:** Context or date correction only. **C — unverified lead:** Not used as factual or numeric evidence.

All sources were checked **October 14, 2026**. The record’s **October 9, 2026 status baseline comes from the supplied work order**, not from a retrieved certification of the complete bankruptcy docket. Negative retrieval findings mean **not obtained/verified**, never proof of nonexistence or a zero value. The latest primary event independently verified is the **October 9 appellate opinion**. The latest plan located is **January 20, 2026**, not an asserted full docket cut-off.

Page references below use **docket-stamped “Page X of Y”**, rather than the internal printed page number. The combined download can contain a main document and exhibits with separate pagination. During consolidation, several research-memo references were found to point to the preceding page footer; the final locators below were corrected against the next docket footer enclosing the relevant clause.

For proposed monetary fields, **scope is the proposed Ivory America / Cyprus Personal Injury Trust**, except the explicitly excluded XL non-trust payment. **Unit is USD**; source date is the January 20, 2026 filing date; value basis is the filed proposal/contract, not a present asset measurement. Effective/trigger dates are conditional and **not independently established as achieved**. Funding pools, account allocations, and insurance recoveries are never aggregated in this package.

## Claim map and primary source register

### [1] Petition: debtor identity, chapter, court and filing date

**Source:** Imerys Talc America, Inc., *Voluntary Petition*, Case 19-10289-LSS, **D.I. 1, filed February 13, 2019**, pp. **1–4 of 26**; affiliate-petition Schedule 2, p. **6 of 26**. **Grade: A — filed.** [1]

**Mapped claims:** Record snapshot’s debtor identity, Chapter 11, February 13 petition date and Delaware court; February 2019 timeline event. Schedule 2 identifies the three contemporaneously filing debtors. Separate case numbers and joint administration are corroborated by [9]. The petition’s consolidated creditor/asset estimates are **not used** as trust assets, current claim counts, or payments.

### [2] Imerys plan: proposed name, structure, scope and funding fields

**Source:** *Second Joint Plan of Reorganization of Imerys Talc America, Inc. and Its Debtor Affiliates*, **D.I. 8070, filed January 20, 2026**, main document **122 pages**. **Grade: A — filed proposal.** [2]

**Mapped identity and status claims:** Title/front matter and introduction, pp. **1–7**, support plan identity and its proposed character. §1.1.283, p. **40**, defines the proposed **Ivory America / Cyprus Personal Injury Trust**. §§1.1.281–282, p. **40**, define Talc Personal Injury Claims and future Demands. §4.6.1, p. **54**, provides the proposed assumption of liabilities on the Effective Date and expressly distinguishes Foreign Claims. Introduction, p. **7**, states the non-admission limitation. These support the proposed-structure and claimant-scope paragraphs, not individual legal conclusions.

**Mapped effectiveness claims:** §1.1.101, p. **18**, defines Effective Date by reference to conditions satisfied or waived. §§9.2.1–9.2.3, p. **74**, describe district-court affirmation/final-order conditions, coordinated Cyprus confirmation and affirmation, and trust-asset transfer conditions. These clauses do not prove the conditions occurred. The page therefore leaves established/effective and operational fields null.

**F01 — Imerys Settlement Funds:** §1.1.144, p. **22**: **$75,000,000**, plus Sale Proceeds, less **$376,630.14** of specified parent DIP-document costs; remaining Sale Proceeds only after case funding and amounts payable/reserved under the plan. These are separately transcribed components of one source definition, not a calculated net contribution. Net Sale Proceeds unknown.

**F02 — Rio Tinto cash:** §1.1.245, p. **33**: **$80,000,000** proposed trust cash contribution. Separate trigger timing and assigned credits are supported by [5].

**F03 — Zurich cash:** §1.1.315, p. **44**: **$260,000,000** proposed trust cash contribution. Not merged with Rio Tinto or valued insurance interests.

**F05 — XL cash / F06 — separate fire-claim trust amount:** §§1.1.304–306, p. **43**: **$28,250,000** XL Cash Contribution; distinct **$1,000,000** California Fire Claim contribution to the trust. The same definition separately specifies **$1,250,000** payable to **Imerys Filtration Minerals, Inc.**, a non-debtor. The latter is expressly excluded from trust funding. Source exhibit [6] corroborates this distinction.

**F09 — Home Proceeds:** §1.1.179, p. **26**, includes Home Proceeds and J&J Payment Obligations in the defined J&J Settlement Proceeds, subject to designated-account/effective-date provisions. No dollar value inferred.

**F10 — qualified-settlement-fund amounts:** §§1.1.226–228, p. **31**, define QSF Funds at transfer and identify QSF Orders **D.I. 6788 and 7898**. Neither is treated as an already operating Section 524(g) trust. No QSF balance is supplied by these definitions.

**F11 — other listed assets:** §1.1.285, pp. **40–41**, lists proposed funding, debtor cash, non-cash rights, insurance assets, stock, causes of action, reserve residues, J&J proceeds and QSF funds. It is an asset taxonomy, not a funded-total valuation. Account/reserve transfers can overlap with these categories; none is assigned a guessed value or counted twice.

### [3] Cyprus plan: separate case, coordinated proposal and note principal

**Source:** Cyprus Mines Corporation, *Fourth Modified First Amended Plan*, **Cyprus D.I. 3676, filed January 20, 2026**, **96 pages**. **Grade: A — filed proposal.** [3]

**Mapped claims:** Coordinated plan identity is also named in [8]. §1.1.45, p. **13**, defines Cyprus Contributions as the Plan Note, pledge agreement, Freeport guarantee and Assignment. **F04 — Plan Note:** §1.1.160, p. **25**, defines an **unsecured seven-year note**, issued by CAMC and the Reorganized Debtor jointly and severally in favor of the trust, with **$195,000,000 outstanding principal as of the Effective Date**, payable under §10.7.2.1. §4.7.1, p. **43**, addresses proposed issuance and transfer. No actual issuance or repayment is established by those proposal clauses.

**Gap reconciliation:** The supplied package’s “Cyprus-pool documents not found” is narrowed: this filed plan and its note definition were recovered. That does not close the remaining note-form, guarantee, assignment, implementation and payment-performance gaps. The historical **$130 million** reporting lead is not substituted for the current note and is not compared as a like-for-like cash increase.

### [4] Proposed Trust Distribution Procedures: separate funds, not live rates

**Source:** Imerys **D.I. 8070-1**, Exhibit A, proposed TDP, **filed January 20, 2026**, **101 pages**. **Grade: A — filed proposal.** [4]

**Mapped claims:** §2.2, pp. **33–35**, describes Fund A and Fund B. Fund A covers specified ovarian-cancer categories; Fund B covers mesothelioma, secondary mesothelioma and lung-cancer categories. The TDP excludes Foreign Claims from those funds.

**Audit-only allocation transcription:** pp. **34–35**: Fund A receives **60% of Trust Fund; 45% of Cyprus Contributions; 52.5% of Cyprus talc-insurance proceeds; 52.5% of J&J Settlement Proceeds**. Fund B receives **40%; 55%; 47.5%; 47.5%**, respectively. These are **source-specific internal allocations**, not payment percentages or amounts received. They are retained here to substantiate the record’s separate-funds description, not displayed as headline trust rates. No scheduled claim values, filing instructions or operational TDP are adopted in the draft.

### [5] Rio Tinto/Zurich agreement: cash timing and unvalued rights

**Source:** Imerys **D.I. 8070-3**, Exhibit C, settlement agreement, **filed January 20, 2026**, **45 pages**. **Grade: A — filed agreement.** [5]

**Mapped claims:** §4.2.1, p. **16**, specifies **$80 million** to the trust within 14 days after the Rio Tinto/Zurich Trigger Date. §4.3.1, pp. **16–17**, concerns assigned Credits/Future Credits. No present valuation or proof of transfer is claimed. Zurich’s separately defined **$260 million** is cited to [2], §1.1.315, rather than collapsed into a combined figure.

### [6] XL agreement: corroboration of distinct payees

**Source:** Imerys **D.I. 8070-4**, Exhibit D, settlement agreement, **filed January 20, 2026**, **37 pages**, §§I.B–I.C, pp. **13–14**. **Grade: A — filed agreement.** [6]

**Mapped claims:** Corroborates F05–F06 and the non-trust payee distinction. The definitive numerical locator used in the draft is [2], §§1.1.304–306, p. **43**. No trigger completion, court confirmation or current received balance is inferred.

### [7] J&J agreement: separate contractual obligations and bankruptcy distinction

**Source:** Imerys **D.I. 8070-5**, Exhibit E, amended/restated settlement agreement, **filed January 20, 2026**, **72 pages**. **Grade: A — filed agreement.** [7]

**F07 — Initial Payment:** §1.39, p. **16**, separately defines **$225,000,000**. §4.1, p. **24**, provides payment mechanics tied to the Trigger Date and applicable recipients. This is not proof of receipt by a funded trust.

**F08 — J&J Insurance Payments:** §1.40, p. **16**, refers to the first **$200 million** of insurance recoveries and **50% of the next $160 million**, with an escrow/backstop requirement. §5.11, p. **29**, expressly states **$280,000,000** as the aggregate obligation for **this component alone**. The draft transcribes that stated obligation, performs no calculation and does not sum it with the Initial Payment. The backstop’s December 31, 2025 date is contractual timing, not evidence that the obligation was fulfilled. Actual payment performance remains unknown.

**Mapped scope claim:** §§4.2–4.3, pp. **24–26**, distinguish J&J-related bankruptcy arrangements and enforcement of the payment obligations. J&J is not identified as an Imerys debtor in [1]. This record does not summarize the separate J&J-related bankruptcy cases.

### [8] Filed evidence notice: plans considered at resumed hearing

**Source:** Imerys **D.I. 8146, filed February 11, 2026**, notice pp. **1–3**; attached evidence list **8146-1, seven pages**. **Grade: A — filed procedural notice.** [8]

**Mapped claims:** Notice p. **1** states the confirmation hearing resumed **February 2, 2026** on **Imerys D.I. 8070 / Cyprus D.I. 3676**. Exhibit p. **5** lists the Imerys disclosure-approval/solicitation order as admitted exhibit JX-237; p. **7** identifies the January 20 Imerys plan as JX-697. Neither the notice nor its evidence list is a signed confirmation order. Confidential exhibit titles are not quoted in the public-facing draft or used as underlying evidence.

### [9] Official Imerys case-agent narrative

**Source:** Kroll official Imerys case page, undated narrative, **checked October 14, 2026**, sections **Case Background** and **Important Information & Dates**. **Grade: A — official administrative, not filed-order text.** [9]

**Mapped claims:** Exact three debtor names/case numbers, joint administration and judge; **November 5, 2024** disclosure approval and authorized solicitation; **December 16, 2024** vote deadline; **January 5, 2025** voting-result certification; **April 22, 2025** confirmation-hearing commencement. These are historical dated events, not proof of current approval or confirmation. Underlying November 2024 approval orders and voting certifications were not independently retrieved in full.

**Known inconsistency:** The page separately says a Second Joint Plan was filed **September 26, 2025**, with a blank docket number, while an earlier paragraph cites **6732/6733**. Those docket numbers belong to the **November 5, 2024** package per [10] and the historical solicitation site. The draft does not attach them to September 2025. It instead cites [2], [8] and [18] for the January 2026 package.

### [10] Official joint solicitation narrative

**Source:** Kroll official Imerys/Cyprus joint solicitation page, undated, **checked October 14, 2026**, **Case Backgrounds**, **Plans and Disclosure Statements**, **Debtors**. **Grade: A — official administrative.** [10]

**Mapped claims:** Cyprus **21-10398**, petition **February 11, 2021**; historical disclosure approval, voting deadline and certifications for both cases; plan proponents (debtors, Imerys S.A., respective tort committees and future-claimant representatives; Cyprus Amax for Cyprus). The legacy website’s ballot or case-claim links do not establish a current trust filing process. The draft contains no instructions or expired deadlines presented as actionable.

The parallel historical solicitation website, `https://iandctalc.com/`, explicitly identifies Imerys **6732/6733** and Cyprus **2651/2652**, dated November 5, 2024, and describes a single proposed trust. Its historical projected overall funding figure is **not carried or aggregated** in this record.

### [11] September conference agenda: planned matter only

**Source:** Imerys **D.I. 8462, filed September 11, 2026**, agenda pp. **1–3**. **Grade: A — filed agenda.** [11]

**Mapped claims:** p. **2** schedules **September 15, 2026, 2:00 p.m. ET**, concerning insurer motion **Imerys 8408 / Cyprus 4007**, filed **July 30, 2026**, requesting a conference on an MDL order’s confirmation implications and abeyance of a confirmation ruling. It identifies objections **8424 / 4026** (August 14) and **8453 / 4054** (September 4), and notice **8437 / 4038** (August 25). Its “going forward” language is prospective. No transcript, minute entry or order resolving that motion was retrieved as of October 14. The MDL motion’s characterization is not adopted as a causation finding.

### [12] October 9 appellate decision: sale appeal, not confirmation

**Source:** U.S. Court of Appeals for the Third Circuit, **No. 25-2786**, submitted September 18, **filed October 9, 2026**, **two-page nonprecedential opinion**, by Circuit Judge Bove. **Grade: A — official court opinion.** [12]

**Mapped claims:** p. **1** identifies RMI Insurers’ challenge to a Section 363(b) sale of indemnification rights to J&J and describes talc distribution to J&J. p. **2** explains Section **363(m)** statutory mootness, good-faith purchaser/no stay, and dismissal as moot. p. **1** footnote states nonprecedential status. The subject and disposition do **not** establish plan confirmation, trust funding or operations. This is the latest independently verified primary event in the record, not an October 14 bankruptcy-status certification.

### [13] Related district-court decision — contextual corroboration

**Source:** District of Delaware, **1:24-cv-01232-TLA, D.I. 45, filed August 22, 2025**, **pp. 1–2**; opinion/order dated **August 21, 2025**, signed by Thomas L. Ambro. **Grade: A — government-hosted court document.** [13]

**Mapped claim:** p. **2** affirms the bankruptcy order approving the J&J settlement and sale of rights. The date distinction is retained; this is not a Chapter 11 confirmation order. Used in status research, not as evidence of trust establishment.

### [14] Bloomberg lead — date correction only

**Source:** Alex Wolf, Bloomberg Law, *Imerys Updates Bankruptcy Plan With Asbestos Claims Pay Details*, **January 21, 2021, 22:01 UTC**, visible headline, timestamp and opening paragraphs. **Grade: B — reliable secondary, historical lead.** Source locator (plain text): `https://news.bloomberglaw.com/bankruptcy-law/imerys-updates-bankruptcy-plan-with-asbestos-claims-pay-details`.

**Mapped correction:** The page itself dates the eighth-iteration / **$130 million** Cyprus story to **2021**, contradicting the work order lead’s implied October 5–12, 2026 reporting window. It is not evidence of a fresh 2026 plan or current funding. That amount appears only as rejected/historical lead documentation here, not in the record’s current funding list. No separate new 2026 article matching the lead was verified.

### [15] May 2025 court letter: confirmation record remained open then

**Source:** Judge Laurie Selber Silverstein, official court letter **May 5, 2025**, **pp. 1–2** of four. **Grade: A — official court communication.** [15]

**Mapped claim:** The parties requested adjournment on April 28; the judge kept hearings and the record open while a foreign-claims resolution was pursued. The letter is historical procedural evidence, not proof of the full October 2026 status.

### [16] 2022 appellate background: thousands of litigation claimants

**Source:** Third Circuit, *In re Imerys Talc America, Inc.*, **No. 20-3486**, filed **June 30, 2022**, opinion archived by Villanova’s law-school repository. **Grade: A — reproduced court opinion; not official-court hosting.** [16]

**Mapped claims:** **Factual and Procedural Background**, p. **6**, describes mining/processing/distribution, over **14,000 litigation claimants by early 2019**, and Chapter 11’s proposed Section 524(g) channeling objective. The public record uses the bounded word **“thousands”** rather than turning that historical litigation statistic into today’s proof-of-claim count. It is not a contamination-science determination or a current trustee claims statistic.

### [17] September omnibus order — excludes an unsupported confirmation date

**Source:** Imerys **D.I. 8508, filed/signed September 29, 2026**, **p. 1 of 1**. **Grade: A — filed order.** [17]

**Mapped research boundary:** Schedules an **omnibus hearing November 10, 2026 at 2 p.m. ET**. It does not identify that date as a confirmation hearing or resolve the September 15 status conference. The draft therefore does not publish it as an upcoming confirmation date.

### [18] January revised proposed order notice — proposal is not judgment

**Source:** Imerys **D.I. 8072, filed January 20, 2026**, notice **pp. 1–3**, especially **p. 2**; attached **8072-1** expressly titled **Revised Proposed Confirmation Order**. **Grade: A — filed notice/proposed order.** [18]

**Mapped claims:** Identifies January 20 plan **8070** as amended and prior amended versions **7451, 7586, 7762, 7785**. Sets resumed confirmation hearing for February 2. The notice describes an order the debtors **intend to seek**, with further revisions reserved. The proposed exhibit’s declarative judicial wording—including its proposed findings on additional disclosure/re-solicitation—is **not adopted as a signed court ruling**.

### [20] REMOVED 2026-10-26 (CLEO #101672 IM1): competitor law-firm host, blocklisted. The product-list sentence it alone supported was struck; [12] and [16] do not carry it (Baby Powder 0 in both). Original entry kept below as history only.

**Source:** Imerys **D.I. 2864, filed January 28, 2021**, TDP definition **63, “J&J Product,” docket p. 132 of 371**, in a historical court-document compilation hosted by Beasley Allen. **Grade: A — reproduced filed document, interested-party hosting.** [20]

**Mapped claim:** Defines J&J products to include **Johnson’s Baby Powder** and Shower to Shower, containing or **allegedly** containing Cyprus Talc or Imerys Talc. Together with [12]’s distribution-to-J&J description, this supports narrowly attributed product background. It does not prove contamination, individual exposure or causation. This historical definition is not used for current trust terms, funding or operations. The compilation’s original authors remain the court/filing parties, not Manus or the host law firm.

## Non-case assertions and unresolved fields

**G01 — October 9 status baseline:** Supplied WO-TRUSTS-20261014-IMERYS, lines 12–15 and 20 of the attached work order. Owner-supplied reference-package assertion; **not independently verified against a complete primary docket in this check**. The page retains the proposed/pending classification and states this limit visibly. Nothing is re-dated into an unconditional October 14 “no confirmation” finding.

**G02 — Unknown operations and figures:** No signed confirmation, affirmation, effective-date notice, operating administrator/portal, current trust assets, payments or live rate were obtained. These are documented retrieval limits, not class-A facts asserting absence. No individualized filing process is offered. Proof-of-claim counts and tonnage remain unresolved.

**G03 — Implementation context:** Read the live [trust index](https://asbestostrusts.org/trusts), [Paddock detail](https://asbestostrusts.org/trusts/paddock-enterprises-owens-illinois-asbestos-trust) and [sitemap](https://asbestostrusts.org/sitemap.xml) on October 14. These support compatible section conventions and the observation that no Imerys route was listed in the retrieved public index; they do not prove no private draft exists. No repository/source-code or current build-history access was verified. Proposed slug and typed null fields are implementation recommendations, not site edits.

**G04 — Atlas context:** Read [AsbestosAtlas’s homepage](https://asbestosatlas.org/) on October 14; a specific Imerys facility/evidence URL was not located. The work order supplies the scope boundary. No facility or scientific narrative is duplicated; the owner must supply any intended deep link.

**G05 — Authorship, funding and review:** Manus authored this package. Funding disclosure and workflow come from the supplied current project instructions and local editorial/bio-box files. Their sample named reviewers, credentials and dates were not copied as completed review. The local Daily Accomplishment Log is dated September 3, 2026; the October 12 research package and later build/task records were not attached or otherwise obtained.

**Access note:** Browser access to Kroll/iandctalc returned CloudFront 403. Text extraction recovered official narratives and direct filed PDFs; some dynamic docket requests returned empty listings. Another targeted public plan-category retrieval recovered the January plan links. Public DocketBird/PacerMonitor listings showed routine entries through **D.I. 8528, October 13, 2026**; those mirrors were used for discovery, not a complete primary-docket absence check. No PACER purchases or subscription changes were made.

## Draft reconciliations and correction history

**October 14, 2026 — new draft, not a correction to a live record.** The apparent fresh Bloomberg report was reclassified from October 2026 lead to January 21, 2021 historical reporting. The stale/blank September landing-page pointer was replaced by **latest located D.I. 8070, January 20, 2026**. Cyprus “documents not found” was narrowed to “plan/note definition recovered; implementation and payment performance unknown.” The proposed filed name **Ivory America / Cyprus Personal Injury Trust** was retained. Preliminary page references were corrected to enclosing docket-footer pages; numerical amounts were not changed. No nominal funding sum was created or reproduced as assets.

## Accomplishments ledger fallback — for Charles, not public page copy

The GitHub connector is disabled, and repository authentication was blocked in this task environment. No new access was requested or changed. The header format in `manus-vault-bridge/Manus/accomplishments.md` could not be read, so the following is **entry content for the requesting owner to adapt to the actual ledger format**, not a claim that a commit occurred:

> **2026-10-14 — Manus — AsbestosTrusts.org — WO-TRUSTS-20261014-IMERYS.** Completed and source-checked a Tier 2 draft-only Imerys bankruptcy/proposed-trust package: record page, claim-to-source register and status note. Recovered January 20, 2026 Imerys D.I. 8070 and Cyprus D.I. 3676, retained the filed proposed Ivory America / Cyprus trust name, and documented funding components separately without totals or current-asset claims. Verified the October 9 Third Circuit sale-appeal dismissal from the official opinion; rejected the January 21, 2021 eighth-plan/$130M story as fresh 2026 news; recovered September 15 agenda but preserved the missing outcome. No publication, deployment, merge, site commit or new public URL. ANCHOR editing → CLEO QA → Charles publication gate pending; qualified legal review not completed. Outstanding: later plan/status orders, confirmation/affirmation/effectiveness, September conference result, actual funding/payment evidence, claims counts and precise Atlas deep link. Deliverables: imerys-proposed-trust-record.md, imerys-sources.md, imerys-status-note.md. **Ledger not committed: repository access unavailable.**

## References

[1]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MTA2MjcyMQ==&id2=0 "Imerys D.I. 1 — petition, filed February 13, 2019"
[2]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzM5NQ==&id2=-1 "Imerys D.I. 8070 — Second Joint Plan, filed January 20, 2026"
[3]: https://cases.ra.kroll.com/cyprusmines/Home-DownloadPDF?id1=MjgwMzQxMA==&id2=-1 "Cyprus D.I. 3676 — Fourth Modified First Amended Plan, filed January 20, 2026"
[4]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzM4OQ==&id2=0 "Imerys D.I. 8070-1 — proposed TDP, filed January 20, 2026"
[5]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzM5MQ==&id2=0 "Imerys D.I. 8070-3 — Rio Tinto/Zurich agreement, filed January 20, 2026"
[6]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzM5Mg==&id2=0 "Imerys D.I. 8070-4 — XL agreement, filed January 20, 2026"
[7]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzM5Mw==&id2=0 "Imerys D.I. 8070-5 — J&J agreement, filed January 20, 2026"
[8]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwNjAyMw==&id2=-1 "Imerys D.I. 8146 — evidence notice, filed February 11, 2026"
[9]: https://cases.ra.kroll.com/IMERYSTALC/ "Official Imerys case-agent narrative, checked October 14, 2026"
[10]: https://cases.ra.kroll.com/iandctalc/ "Official joint solicitation narrative, checked October 14, 2026"
[11]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgyODE4Mw==&id2=0 "Imerys D.I. 8462 — September conference agenda, filed September 11, 2026"
[12]: https://www2.ca3.uscourts.gov/opinarch/252786np.pdf "Third Circuit No. 25-2786 — opinion filed October 9, 2026"
[13]: https://www.govinfo.gov/content/pkg/USCOURTS-ded-1_24-cv-01232/pdf/USCOURTS-ded-1_24-cv-01232-1.pdf "District court D.I. 45 — filed August 22, 2025; opinion dated August 21"
[15]: https://www.deb.uscourts.gov/sites/deb/files/opinions//Imerys%20-%20Cyprus%20Letter.pdf "Judge Silverstein letter, May 5, 2025"
[16]: https://digitalcommons.law.villanova.edu/cgi/viewcontent.cgi?article=1475&context=thirdcircuit_2022 "Third Circuit No. 20-3486 — June 30, 2022 opinion, university archive"
[17]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgyOTI1Mw==&id2=0 "Imerys D.I. 8508 — omnibus-hearing order, filed September 29, 2026"
[18]: https://cases.ra.kroll.com/IMERYSTALC/Home-DownloadPDF?id1=MjgwMzQwMw==&id2=-1 "Imerys D.I. 8072 — revised proposed order notice, filed January 20, 2026"
[20]: REMOVED (blocklisted host; see entry above)

## ANCHOR docket refresh and link check — October 26, 2026

- **Plan category (case agent, Plan & Disclosure Statement filter):** newest entry is D.I. 8116 (February 11, 2026, notice continuing the confirmation hearing). No plan, disclosure or confirmation filing after it. D.I. 8070 remains the latest plan located. [22]
- **Main docket, D.I. 8462 to 8559 (through October 20, 2026):** CourtListener RECAP and the case agent's newest-entries page. Fee applications and CNOs; removal-deadline orders (Kroll lists the Twenty-Fourth Order under 28 U.S.C. § 1452 among the October 19 entries); agendas 8501/8502 (September 25); 8506 agenda marked HEARING CANCELLED (September 28); omnibus hearing dates 8508 (September 29) and 8539 (October 15); supplemental mailing affidavit for the September 15 agenda (8545, October 19). [21]
- **Unidentified orders:** D.I. 8480 (September 15, 2026) and D.I. 8505 (September 28, 2026). RECAP shows "Order" only (PACER-only); the case agent's docket search returns a reCAPTCHA. Not characterized.
- **Lead, not read:** D.I. 7895 (November 18, 2025), order approving the form and manner of notice of (A) continued confirmation hearing and (B) plan modifications. Bears on the re-solicitation question. [23]
- **Link check, October 26:** [1]-[6] 200 (PDF); [12] 200; [15] 200; [21] 200. ([20] removed: blocklisted competitor-firm host, CLEO #101672.) [7]-[11], [18], [22], [23] (cases.ra.kroll.com) returned 202 with an empty body after six successful requests, which is the case agent's bot throttle; they were read through firecrawl earlier in this session and are unconfirmed, not dead. [16] (Villanova digital commons) returns 403 to curl and 200 through firecrawl, so the host blocks bots.