On January 22, 2019 a Order 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.
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1 DAVID R. DONADIO, ESQ., S.B. #154436 NANCY T. WILLIAMS, ESQ., S.B. #201095 2 NWilliams@braytonlaw.com BRAYTONPURCELL LLP ELECTRONICALLY 3 Attorneys at Law 222 Rush Landing Road F I L E D Superior Court of California, 4 P.O. Box 6169 County of San Francisco Novato, California 94948-6169 12/03/2019 5 (415) 898-1555 Clerk of the Court Tentative Ruling Contest Email: contestasbestosTR@braytonlaw.com BY: ERNALYN BURA 6 Deputy Clerk Attorneys for Plaintiffs 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 CAROL CHULICK, as Successor-in- ) ASBESTOS Interest to and as Wrongful Death Heir of ) No. CGC-19-276757 11 JOHN CHULICK, Deceased; and ) DEBORAH HAGEN and JOLEEN ) DECLARATION OF NANCY T. 12 HAGLER, as Wrongful Death Heirs of ) WILLIAMS IN SUPPORT OF EX PARTE JOHN CHULICK, Deceased, ) APPLICATION FOR ORDER GRANTING NOVATO, CALIFORNIA 94948-6169 BRAYTONPURCELL LLP 13 ) LEAVE TO FILE AMENDMENT TO THE 222 RUSH LANDING ROAD Plaintiffs, ) COMPLAINT TO SUBSTITUTE ATTORNEYS AT LAW 14 ) DEFENDANT'S TRUE NAME FOR DOES (415) 898-1555 P O BOX 6169 vs. ) 1 AND 302 15 ) RILEY POWER INC., et al., ) [C.C.P. § 473] 16 ) Defendants. ) Date: December 4, 2019 17 Time: 11:00 a.m. Dept.: 503, Hon. Cynthia Ming-mei Lee 18 Trial Date: N/A Action Filed: January 22, 2019 19 20 I, Nancy T. Williams, declare as follows: 21 1. I am an attorney at law duly licensed to practice before all courts in the State of 22 California; and am an associate in the law firm of BraytonPurcell LLP, attorneys of record for 23 plaintiffs herein. 24 2. Plaintiffs propose to file an Amendment to Complaint to substitute defendant's true 25 names for “Does,” a true and correct copy of which is attached hereto as Exhibit A. 26 3. At the conclusion of percipient witness Monte Manwill’s deposition, taken on 27 October 23, 2019 and October 24, 2019, it was revealed there is an additional 28 entity who may share liability for decedent’s asbestos-related disease. Therefore, the K:\Injured\26244\PLD\decl xpt mta cmp doe 1 & 302.wpd 1 NTW DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER GRANTING LEAVE TO FILE AMENDMENT TO THE COMPLAINT TO SUBSTITUTE DEFENDANT'S TRUE NAME FOR DOES 1 AND 302