On December 11, 2019 a Party Discovery was filed involving a dispute between Blake, Victoria, French, Susan, Mcclary, Steven, Niskanen, Valeri, Ortegon, Tamlyn, and 3M Company, A.J. Peters & Son, Aladdin Heating Corporation, Anderson, Rowe & Buckley, Inc., Asbestos Corporation Limited, Brand Insulations, Inc., Individually And As, Chicago Bridge & Iron Company, Consolidated Insulation, Inc., A Dissolved, Contra Costa Electric, Inc., Cooper Bros., Inc., Cooper Brothers, Inc., Cosco Fire Protection, Inc., Dillingham Construction N.A., Inc., Does 1 Through 800, Inclusive, As Required By, Douglass Insulation Company, Inc., Dow Chemical Company, The, D. Zelinsky & Son, Incorporated, D. Zelinsky & Sons, Inc., Fdcc California, Inc., Fluor Corporation, Frank Bonetti Plumbing, Inc., General Electric Company, Golden Gate Drywall, Goulds Pumps Llc, Grinnell Llc, Imo Industries Inc., Ingersoll-Rand Company, International Business Machines Corporation, James A. Nelson Co., Inc., Johnson Controls, Inc., Kelly-Moore Paint Company, Inc., Marconi Plastering Company, Inc., Metalclad Insulation Llc, Metropolitan Life Insurance Company, N.V. Heathorn, Inc., O C Mcdonald Co Inc, O.C. Mcdonald Company, Inc., Oscar E. Erickson, Inc., Pfizer, Inc., Riley Power Inc., Riley Power Inc., (Erroneously Sued As Alternate, Robertshaw Controls Company, Rosendin Electric, Inc., Sam P. Wallace Company, Inc., Scott Co. Of California, Shell Oil Company, S.J. Amoroso Construction Co., Inc., S.J. Amoroso Construction Co., Llc., Therma Corporation, Trane U.S. Inc., Union Oil Company Of California, University Mechanical & Engineering Contractors,, Valley Sheet Metal Co., Veolia Es Industrial Services, Inc., Viacomcbs Inc, Viacomcbs, Inc. F K A Cbs Corporation, A Delaware, W.L. Hickey Sons, Inc., for ASBESTOS in the District Court of San Francisco County.
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1 JULIE A. TORRES (SBN 80752) Julie.Torres@wilsoneelser.com 2 GAYLE L. KETCHIE (SBN 322422) ELECTRONICALLY 3 Gayle.Ketchie@wilsoneelser.com F I L E D WILSON, ELSER, MOSKOWITZ, Superior Court of California, County of San Francisco 4 EDELMAN & DICKER LLP 525 Market Street, 17th Floor 10/22/2021 Clerk of the Court 5 San Francisco, California 94105 BY: YOLANDA TABO-RAMIREZ Telephone: (415) 433-0990 Deputy Clerk 6 Facsimile: (415) 434-1370 7 Attorneys for Defendant 8 ANDERSON, ROWE & BUCKLEY, INC. 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN FRANCISCO 11 12 VALERI NISKANEN, as Successor-in- CASE NO. CGC-19-276813 Interest to and as Wrongful Death Heir of 13 BILLY JOE McCLARY, Deceased; and VICTORIA BLAKE, TAMLYN ORTEGON, DECLARATION OF GAYLE L. 14 SUSAN FRENCH and STEVEN McCLARY, KETCHIE IN SUPPORT OF as Wrongful Death Heirs of BILLY JOE ADDITIONAL REQUEST FOR 15 McCLARY, Deceased; ADMISSIONS PROPOUNDED ON SUSAN FRENCH, SET ONE 16 Plaintiffs, Action Filed: May 11, 2019 17 vs. 18 KELLY-MOORE PAINT COMPANY, INC. et al.; 19 Defendants 20 21 22 23 24 25 26 27 28 1 DECLARATION OF GAYLE L. KETCHIE IN SUPPORT OF ADDITIONAL REQUEST FOR ADMISSIONS TO PLAINTIFF SUSAN FRENCH 202410481v.1 1 I, Gayle L. Ketchie, declare: 2 1. I am an Associate with the law firm of Wilson, Elser, Moskowitz, Edelman & Dicker, 3 LLP, attorneys of record for Defendant, ANDERSON, ROWE & BUCKLEY, INC. in the above- 4 referenced matter. 5 2. ANDERSON, ROWE & BUCKLEY, INC. is propounding to Plaintiff, SUSAN 6 FRENCH, the attached set of Request for Admissions. 7 3. This set of Request for Admissions will cause the total number of Request for 8 Admissions propounded to the party to whom they are directed to exceed the number of Request 9 for Admissions permitted by § 2033.030 of the Cal. Code of Civil Procedure. 10 4. I previously propounded zero Request for Admissions to this party. 11 5. This set of Request for Admissions contains a total of 45 requests. 12 6. I am familiar with the issues and the previous discovery conducted by all of the parties in 13 this case. 14 7. I have personally examined each of the requests in this set of Request for Admissions. 15 8. This number of Request for Admissions is warranted under §2033.040 of the Code of 16 Civil Procedure because of the complexity and the quantity of the existing and potential issues in 17 this particular case, involving multiple causes of action and multiple exposure claims stretching 18 over three decades. 19 9. None of the requests in this set of Request for Admissions is being propounded for any 20 improper purpose, such as to harass the party, or the attorney for the party, to whom it is 21 directed, or to cause unnecessary delay or needless increase in the cost of litigation. 22 I declare under penalty of perjury under the laws of California that the foregoing is true 23 and correct and that this declaration was executed on October 22, 2021 in San Francisco, 24 California. 25 26 Gayle L. Ketchie 27 28 2 DECLARATION OF GAYLE L. KETCHIE IN SUPPORT OF ADDITIONAL REQUEST FOR ADMISSIONS TO PLAINTIFF SUSAN FRENCH 202410481v.1