On January 22, 2019 a
Trial Materials
was filed
involving a dispute between
Chulick, Carol,
Hagen, Deborah,
Hagler, Joleen,
and
Anheuser-Busch, Llc,
Anheuserbusch, Llc,
Associated Insulation Of California,
Buttner Corp.,
Columbia Mechanical Contractors, Inc.,
Cooper Brothers, Inc.,
Cosco Fire Protection, Inc.,
Does 1 Through 800, Inclusive, As Required By,
D. Zelinksy & Sons, Inc.,
D. Zelinsky & Sons, Incorporated,
Fdcc California, Inc.,
Frank Bonetti Plumbing, Inc.,
George H. Wilson, Inc.,
George Wilson Company, Inc.,
Grinnell Llc,
Grinnell Llc (Fka Grinnell Corporation, Aka,
Johnson Controls, Inc.,
Kelly-Moore Paint Company, Inc.,
Kellymoore Paint Company, Inc.,
Marconi Plastering Company, Inc.,
Metropolitan Life Insurance Company,
Monterey Mechanical Co.,
Riley Power Inc.,
Rosendin Electric, Inc.,
Rudolph And Sletten, Inc.,
Scott Co. Of California,
Texaco Inc.,
W.L. Hickey Sons, Inc.,
Chulick, Carol,
Hagen, Deborah,
Hagler, Joleen,
for ASBESTOS
in the District Court of San Francisco County.
Preview
1 GABRIEL A. JACKSON (SBN 98119)
gjackson@goldbergsegalla.com
2 PETER K. RENSTROM (SBN 148459)
ELECTRONICALLY
prenstrom@goldbergsegalla.com
3 TODD M. THACKER (SBN 199506) F I L E D
tthacker@goldbergsegalla.com Superior Court of California,
County of San Francisco
4 STEPHEN L. JENKINS (SBN 235601)
sjenkins@goldbergsagalla.com 12/29/2021
5 GOLDBERG SEGALLA LLP Clerk of the Court
BY: YOLANDA TABO-RAMIREZ
611 Gateway Blvd., Suite 120 Deputy Clerk
6 South San Francisco, CA 94080
Telephone: 415-432-6613
7 Facsimile: 415-432-6601
8 Attorneys for Defendant
COSCO FIRE PROTECTION, INC.
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SAN FRANCISCO
12 CAROL CHULICK, as Successor-in-Interest Case No. CGC-19-276757
to and as Wrongful Death Heir of JOHN
13 CHULICK, Deceased; and DEBORAH DEFENDANT COSCO FIRE
HAGEN and JOLEEN HAGLER, as Wrongful PROTECTION, INC.’S TRIAL WITNESS
14 Death Heirs of JOHN CHULICK, Deceased, LIST
15 Plaintiffs, Dept.: 502
Judge: The Honorable Jeffrey S. Ross
16 v.
Action Filed: January 22, 2019
17 RILEY POWER, INC., et al., Trial Date: December 27, 2021
18 Defendants.
19
TO ALL PARTIES AND THEIR COUNSEL OF RECORD HEREIN:
20
Defendant COSCO FIRE PROTECTION, INC. (“COSCO”) hereby submits the following list of
21
trial witnesses:
22
23 Witness Brief Description of Length
Testimony
24
Ted Hanson Mr. Hanson is the president of 1.5 hours
25 Cosco who will testify about
Cosco’s services, the work
26 they performed, the products
with which they worked,
27 types and geographical
locations of jobsites at which
28 they performed work, and the
30 1
DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST
31 31683252.v1
1 scope of available
information concerning
2 Cosco’s corporate history.
Jim Crossley Mr. Crossley is a former 1 hour
3 employee of Cosco who will
testify about Cosco’s services,
4 the work they performed, the
products with which they
5 worked, types and
geographical locations of
6 jobsites at which they
performed work, and the
7 scope of available
information concerning
8 Cosco’s corporate history.
9 C. Alan Brown, MD Dr. Brown is a cardiologist 1.5 hours
who will testify regarding his
10 knowledge of cardiovascular
organ functions, decedent's
11 medical condition and
prognosis, issues of
12 alternative causation and life
shortening problems not
13 related to alleged asbestos
exposure.
14
Kevin Conner, CPA Kevin Conner is an economist 2 hours
15 who will testify regarding
economic damages and losses
16 and related matters as alleged
by plaintiffs.
17
J. David Godwin, MD J. David Godwin, MD is a 1.5 hours
18 radiologist who will provide
testimony regarding his
19 interpretation of decedent’s x-
rays, CT-scans, and medical
20 records of decedent. His
testimony may also include a
21 review of the ILO
classification system for chest
22 films and its role and function
in evaluation. He may also
23 testify on lung physiology,
lung function, lung defense
24 mechanisms, mechanisms by
which asbestos fibers do or do
25 not cause a particular disease,
the effects of smoking, the
26 relationship between smoking
and alleged asbestos-related
27 diseases, and other issues
within his scope of expertise
28
30 2
DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST
31 31683252.v1
1 as the circumstances in this
case require.
2
Christopher Dunn, MD Dr. Dunn is a pulmonologist 2 hours
3 who will testify regarding his
knowledge of lungs and
4 thoracic organ functions,
decedent’s medical
5 conditions, the development
and treatment of and
6 prognosis for plaintiff’s
medical condition, issues of
7 alternative causation and life
shortening problems not
8 related to alleged asbestos
exposure.
9
Eric Rasmuson, CIH Mr. Rasmuson is a certified 2 hours
10 industrial hygienist and
toxicologist who will testify
11 concerning the areas of
retrospective exposure
12 assessment, health risk
assessment, product
13 apportionment with respect to
asbestos exposures,
14 substantial exposure factors,
the relative and absolute
15 potentials of various asbestos
products to product dust,
16 industrial hygiene and
environmental standards and
17 their basis, control technology
and process specific aspects
18 of exposure, analytical
chemistry, chemistry,
19 asbestos-related measurement
techniques, general industrial
20 hygiene issues including the
effects of ventilation and
21 distance on exposure, and
related subjects. Mr.
22 Rasmuson will also testify
regarding “state-of-the-art”
23 and the evolution of
knowledge concerning
24 asbestos.
25 Khalil Sheibani, MD Dr. Sheibani is a pathologist 1.5 hours
who will testify to the
26 pathological aspects of the
case, decedent’s medical
27 condition, issues of
alternative causation and life
28
30 3
DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST
31 31683252.v1
1 shortening problems not
related to asbestos exposure.
2
3 COSCO hereby incorporates by reference all expert witnesses designated by Plaintiffs as
4 set forth in their designation of expert witnesses and/or Plaintiffs’ Trial Witness List. COSCO
5 expressly reserves the right to call any such witness designated by Plaintiffs in this action.
6 COSCO hereby incorporates by reference all expert witnesses designated by other
7 Defendants as set forth in their designations of expert witnesses and/or the Defendants’ respective
8 Trial Witness Lists. COSCO expressly reserves the right to call any such witness designated by
9 others in this action.
10 COSCO reserves the right to seek leave to call other expert witnesses as substitutes for
11 expert witnesses listed herein who become unavailable. Moreover, COSCO reserves the right to
12 amend and/or supplement this list as trial proceeds in this case. COSCO also reserves the right to
13 call any and/or all physicians or other medical experts who have treated the decedent, or reviewed
14 medical records or facts relevant to Plaintiffs’ claims, including physicians/doctors.
15 Cosco further reserves the right to call any witnesses, including expert witnesses, named on
16 any other party's witness list as well as any other witnesses required to rebut testimony presented
17 by other parties during trial or as needed to impeach other witnesses presented at trial.
18 Dated: December 29, 2021 GOLDBERG SEGALLA LLP
19
20 By:
GABRIEL A. JACKSON
21 PETER K. RENSTROM
TODD M. THACKER
22 STEPHEN L. JENKINS
Attorneys for Defendant
23 COSCO FIRE PROTECTION, INC.
24
25
26
27
28
30 4
DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST
31 31683252.v1
1 PROOF OF SERVICE
Carol Chulick (WD John), et al. v. Riley Power, Inc.
2 San Francisco County Superior Court Case No. CGC-19-276757
Our Client: Defendant Cosco Fire Protection, Inc.
3
STATE OF CALIFORNIA
4
I declare that I am employed in the County of San Mateo, State of California. I am over the
5 age of eighteen and not a party to the within action; my business address is 611 Gateway Blvd., Suite
120, South San Francisco, California 94080.
6
On December 29, 2021, I served the foregoing document described as DEFENDANT
7 COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST on the interested parties in this
action:
8
David Donadio **See File & ServeXpress website**
9 DDonadio@braytonlaw.com
Brayton Purcell LLP
10 222 Rush Landing Road
P.O. Box 6169
11 Novato, California 94948-6169
T: (415) 898-1555
12 Attorneys for Plaintiffs
13 BY ELECTRONIC SERVICE: I electronically served the document(s) described above
via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the File
14 & ServeXpress website (https://secure.fileandservexpress.com) pursuant to the Court Order
establishing the case website and authorizing service of documents.
15
I declare under penalty of perjury under the laws of the State of California that the
16 foregoing is true and correct.
17 Executed on December 29, 2021, at San Francisco, California.
18
19
20
Eva Luna
21
22
23
24
25
26
27
28
30 5
DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST
31 31683252.v1
Preview
1 GABRIEL A. JACKSON (SBN 98119) gjackson@goldbergsegalla.com 2 PETER K. RENSTROM (SBN 148459) ELECTRONICALLY prenstrom@goldbergsegalla.com 3 TODD M. THACKER (SBN 199506) F I L E D tthacker@goldbergsegalla.com Superior Court of California, County of San Francisco 4 STEPHEN L. JENKINS (SBN 235601) sjenkins@goldbergsagalla.com 12/29/2021 5 GOLDBERG SEGALLA LLP Clerk of the Court BY: YOLANDA TABO-RAMIREZ 611 Gateway Blvd., Suite 120 Deputy Clerk 6 South San Francisco, CA 94080 Telephone: 415-432-6613 7 Facsimile: 415-432-6601 8 Attorneys for Defendant COSCO FIRE PROTECTION, INC. 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN FRANCISCO 12 CAROL CHULICK, as Successor-in-Interest Case No. CGC-19-276757 to and as Wrongful Death Heir of JOHN 13 CHULICK, Deceased; and DEBORAH DEFENDANT COSCO FIRE HAGEN and JOLEEN HAGLER, as Wrongful PROTECTION, INC.’S TRIAL WITNESS 14 Death Heirs of JOHN CHULICK, Deceased, LIST 15 Plaintiffs, Dept.: 502 Judge: The Honorable Jeffrey S. Ross 16 v. Action Filed: January 22, 2019 17 RILEY POWER, INC., et al., Trial Date: December 27, 2021 18 Defendants. 19 TO ALL PARTIES AND THEIR COUNSEL OF RECORD HEREIN: 20 Defendant COSCO FIRE PROTECTION, INC. (“COSCO”) hereby submits the following list of 21 trial witnesses: 22 23 Witness Brief Description of Length Testimony 24 Ted Hanson Mr. Hanson is the president of 1.5 hours 25 Cosco who will testify about Cosco’s services, the work 26 they performed, the products with which they worked, 27 types and geographical locations of jobsites at which 28 they performed work, and the 30 1 DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST 31 31683252.v1 1 scope of available information concerning 2 Cosco’s corporate history. Jim Crossley Mr. Crossley is a former 1 hour 3 employee of Cosco who will testify about Cosco’s services, 4 the work they performed, the products with which they 5 worked, types and geographical locations of 6 jobsites at which they performed work, and the 7 scope of available information concerning 8 Cosco’s corporate history. 9 C. Alan Brown, MD Dr. Brown is a cardiologist 1.5 hours who will testify regarding his 10 knowledge of cardiovascular organ functions, decedent's 11 medical condition and prognosis, issues of 12 alternative causation and life shortening problems not 13 related to alleged asbestos exposure. 14 Kevin Conner, CPA Kevin Conner is an economist 2 hours 15 who will testify regarding economic damages and losses 16 and related matters as alleged by plaintiffs. 17 J. David Godwin, MD J. David Godwin, MD is a 1.5 hours 18 radiologist who will provide testimony regarding his 19 interpretation of decedent’s x- rays, CT-scans, and medical 20 records of decedent. His testimony may also include a 21 review of the ILO classification system for chest 22 films and its role and function in evaluation. He may also 23 testify on lung physiology, lung function, lung defense 24 mechanisms, mechanisms by which asbestos fibers do or do 25 not cause a particular disease, the effects of smoking, the 26 relationship between smoking and alleged asbestos-related 27 diseases, and other issues within his scope of expertise 28 30 2 DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST 31 31683252.v1 1 as the circumstances in this case require. 2 Christopher Dunn, MD Dr. Dunn is a pulmonologist 2 hours 3 who will testify regarding his knowledge of lungs and 4 thoracic organ functions, decedent’s medical 5 conditions, the development and treatment of and 6 prognosis for plaintiff’s medical condition, issues of 7 alternative causation and life shortening problems not 8 related to alleged asbestos exposure. 9 Eric Rasmuson, CIH Mr. Rasmuson is a certified 2 hours 10 industrial hygienist and toxicologist who will testify 11 concerning the areas of retrospective exposure 12 assessment, health risk assessment, product 13 apportionment with respect to asbestos exposures, 14 substantial exposure factors, the relative and absolute 15 potentials of various asbestos products to product dust, 16 industrial hygiene and environmental standards and 17 their basis, control technology and process specific aspects 18 of exposure, analytical chemistry, chemistry, 19 asbestos-related measurement techniques, general industrial 20 hygiene issues including the effects of ventilation and 21 distance on exposure, and related subjects. Mr. 22 Rasmuson will also testify regarding “state-of-the-art” 23 and the evolution of knowledge concerning 24 asbestos. 25 Khalil Sheibani, MD Dr. Sheibani is a pathologist 1.5 hours who will testify to the 26 pathological aspects of the case, decedent’s medical 27 condition, issues of alternative causation and life 28 30 3 DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST 31 31683252.v1 1 shortening problems not related to asbestos exposure. 2 3 COSCO hereby incorporates by reference all expert witnesses designated by Plaintiffs as 4 set forth in their designation of expert witnesses and/or Plaintiffs’ Trial Witness List. COSCO 5 expressly reserves the right to call any such witness designated by Plaintiffs in this action. 6 COSCO hereby incorporates by reference all expert witnesses designated by other 7 Defendants as set forth in their designations of expert witnesses and/or the Defendants’ respective 8 Trial Witness Lists. COSCO expressly reserves the right to call any such witness designated by 9 others in this action. 10 COSCO reserves the right to seek leave to call other expert witnesses as substitutes for 11 expert witnesses listed herein who become unavailable. Moreover, COSCO reserves the right to 12 amend and/or supplement this list as trial proceeds in this case. COSCO also reserves the right to 13 call any and/or all physicians or other medical experts who have treated the decedent, or reviewed 14 medical records or facts relevant to Plaintiffs’ claims, including physicians/doctors. 15 Cosco further reserves the right to call any witnesses, including expert witnesses, named on 16 any other party's witness list as well as any other witnesses required to rebut testimony presented 17 by other parties during trial or as needed to impeach other witnesses presented at trial. 18 Dated: December 29, 2021 GOLDBERG SEGALLA LLP 19 20 By: GABRIEL A. JACKSON 21 PETER K. RENSTROM TODD M. THACKER 22 STEPHEN L. JENKINS Attorneys for Defendant 23 COSCO FIRE PROTECTION, INC. 24 25 26 27 28 30 4 DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST 31 31683252.v1 1 PROOF OF SERVICE Carol Chulick (WD John), et al. v. Riley Power, Inc. 2 San Francisco County Superior Court Case No. CGC-19-276757 Our Client: Defendant Cosco Fire Protection, Inc. 3 STATE OF CALIFORNIA 4 I declare that I am employed in the County of San Mateo, State of California. I am over the 5 age of eighteen and not a party to the within action; my business address is 611 Gateway Blvd., Suite 120, South San Francisco, California 94080. 6 On December 29, 2021, I served the foregoing document described as DEFENDANT 7 COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST on the interested parties in this action: 8 David Donadio **See File & ServeXpress website** 9 DDonadio@braytonlaw.com Brayton Purcell LLP 10 222 Rush Landing Road P.O. Box 6169 11 Novato, California 94948-6169 T: (415) 898-1555 12 Attorneys for Plaintiffs 13 BY ELECTRONIC SERVICE: I electronically served the document(s) described above via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the File 14 & ServeXpress website (https://secure.fileandservexpress.com) pursuant to the Court Order establishing the case website and authorizing service of documents. 15 I declare under penalty of perjury under the laws of the State of California that the 16 foregoing is true and correct. 17 Executed on December 29, 2021, at San Francisco, California. 18 19 20 Eva Luna 21 22 23 24 25 26 27 28 30 5 DEFENDANT COSCO FIRE PROTECTION, INC.’S TRIAL WITNESS LIST 31 31683252.v1