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  • RORY LEWIS VS. ASBESTOS DEFENDANTS (B/P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RORY LEWIS VS. ASBESTOS DEFENDANTS (B/P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RORY LEWIS VS. ASBESTOS DEFENDANTS (B/P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RORY LEWIS VS. ASBESTOS DEFENDANTS (B/P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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                                BRAYTON®&PURCELL LLP
ATTORNEYS AT LAW
222 RUSH LANDING ROAD

PO BOX 6169
NOVATO, CALIFORNIA 94948-6169

(415) 898-1555

DAVID R. DONADIO, ESQ., S.B. #154436
BRAYTON*PURCELL LLP ELECTRONICALLY
Attorneys at Law FILED
222 Rush L anding Road Superior Court of California,
P.O. Box 6169 — . County of San Francisco
Novato, California 94948-6169
(415) 898-1555 AUG 14 2006

- GORDON PARK-LI, Cle
Attorneys for Plaintiff BY: MAURA RAMIREZ

Deputy Cler
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

kK

RORY LEWIS, ) No. 438257
Plaintiff,
OFFER TO COMPROMISE
VS. PURSUANT TO C.C_P. § 998
)
ASBESTOS DEFENDANTS (BP) )

TO DEFENDANT GAYLORD CONTAINER CORPORATION AND TO ITS
ATTORNEYS OF RECORD:

Plaintiff RORY LEWIS hereby offers to have judgment taken against defendant
GAYLORD CONTAINER CORPORATION only for FOUR THOUSAND NINE HUNDRED
NINETY-NINE DOLLARS ($4,999.00) pursuant to C.C.P. Section 998. This offer is made only
to GAYLORD CONTAINER CORPORATION and the payment of said sum shall release only
this plaintiff's personal injury claim against said defendant.

Plaintiff RORY LEWIS hereby offers to compromise in the above amount for your
several liability only, and not for a discharge of any other defendant's liability, and not for a
discharge of any claim which is not included in the above-captioned matter. Acceptance of this

offer constitutes agreement by the accepting party and the plaintiff that the sum paid shall afford

only a deduction from any other defendant's liability only to the extent provided by law and shall

not act as a discharge of any other defendant's liability as provided by law. Acceptance of this

C:\Documents and Scttinesladimuni\My Documents*CanversionWarkDirg412_ 20660811 23000sho04 awpd

OFFER TO COMPROMISE PURSUANT TOC.CP. § 998offer specifically shall constitute agreement that the plaintiff may continue to proceed against
other non-settling tortfeasors, whether currently parties to this action or not, including, but not
limited to, tortfeasors currently involved in proceedings pursuant to either 11 U.S.C. Chapter 7
or LL U.S.C. Chapter 11

PLEASE TAKE NOTICE that if you do not accept the above offer within thirty (30) day:
of receipt or the time of trial, whichever is sooner, and plaintiff recovers a more favorable
judgment, plaintiff will seek pre-judgment interest, costs and expert witness fees as provided in
C.CP Section 998 and Civil Code Section 3291. This offer is deemed withdrawn if not accepted
within thirty (30) days or at the time of trial, whichever date is sooner.

If you choose to accept this offer prior to trial of the above-entitled action or within thirty|
(30) days after it is made, whichever occurs first, you may accept the offer by serving plaintiff
with an original notice of acceptance and by requesting that plaintiff file it with the Court
concurrently with plaintiff's original, individual offer.

Dated: 6/16/2006 BRAYTON®PURCELL LLP.

By: _/s/ David R. Donadio
David R. Donadio
Attorneys for Plaintiff

(enn sti lant Downie oui onnes en seo
‘OFFER TO COMPROMISE PURSUANT TOC.CP. $958