SPRINGFIELD, Ill. - A woman's evidence of parallel conduct falls short of the "clear and convincing" standard needed to prevail on summary judgment motions filed by asbestos conspiracy defendants, an Illinois appeals court held Nov. 15 (Carolyn Garrelts v. Honeywell International Inc., et al., No. 4-12-0997, Ill. App., 4th Dist.; 2013 Ill. App. Unpub. LEXIS 2594).