On July 20, 2005 a AMENDED DECLARATION OF VINCE CILIA (TRANSACTION ID # 15217888) FILED BY PLAINTIFF SCOTT, NANCY MARIE INDIVIDUALLY AND AS SUCCESSOR-IN-INTEREST TO DENZIL SCOTT, DECEDENT WOLFARTH, JOANNE MARIE SCOTT, MICHAEL GERALD SCOTT, ROBERT DAVID SCOTT, THOMAS CARY SOBOLIK, MARY DENISE FIRST DOE THROUGH TENTH DOE, INCLUSIVE was filed involving a dispute between First Doe Through Tenth Doe, Inclusive, Scott, Michael Gerald, Scott, Nancy Marie, Scott, Robert David, Scott, Thomas Cary, Sobolik, Mary Denise, Wolfarth, Joanne Marie, and 3M Company (Formerly Named Minnesota Mining And, Abb, Inc., Abb, Inc. Which Will Do Business In California As, Ac And S, Inc., Allied Packing & Supply, Inc., Amchem Products, Inc., Asbestos Corporation Ltd., A.W. Chesterton Company, Babcock Borsig Power, Inc.,As The Parent Alter Ego, Cbs Corporation, A Delaware Corporation,, Coltec Industries, Inc.,, Crane Co., Darcoid Company Of California, Db Riley, Inc., Dee Engineering Co., Douglass Insulation Company, Eaton Electrical Inc., Eleventh Doe Through Three Hundredth Doe,, Enpro Anchor Packaging, Foster Wheeler Llc, Foster Wheeler Llc, Survivor To A Merger With, Garlock, Inc., General Electric Company, Graybar Electric Co., Graybar Electric Company, Inc., Hill Brothers Chemical Company, Hopeman Brothers, Inc., Imo Industries Inc., Ingersoll-Rand Company, J.T. Thorpe And Son, Inc., Leslie Controls, Inc., Lucent Technologies, Inc., Lucent Technologies, Inc. As A Successor In, Metalclad Insulation Corporation, Metropolitan Life Insurance Company, Minnesota Mining Corporation, Aka 3M Company, M. Slayen And Associates, Inc., M.Slayen & Associates, Inc., New Iem, Llc, The, Quintec Industries, Inc., Rapid-American Corporation, Sb Decking, Inc., Sb Decking, Inc., Formerly Known As Selby,, Soco-Lynch Corporation, Soco West, Inc., Square D Company, Sterling Fluid Systems, Inc., Sterling Fluid Systems, Syd Carpenter Marine Contractor, Inc., Syd Carpenter Marine Engineering, T H Agriculture & Nutrition Llc, The Darcoid Company Of California, The New Iem, Llc,, Thomas Dee Engineering Company, Thorpe Insulation Company, Triple A Machine Shop, Inc., Union Carbide Corporation, Viacom Inc., As Sbm To Cbs Corp., Fka Westinghouse, for civil in the District Court of San Francisco County.
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dun-13-07 08:33am From= “ _— SS Oo ME Om tn fe OU OS Stephen M, Fishback {State Bar No. 191646) Daniel L. Keller (State Bar No. 191738) Rett D.B. Bergmark State Bar No. 169401) KELLER, FISHBACK & JACKSON LLP 28720 Roadside Drive, Suite 20] Agoura Hills, CA 91301 T-496 «= P.DI/0 = F048 ELECTRONICALL FILED Superior Court of California, County of San Francisco JUN 13 2007 GORDON PARK-LI, Clerk BY: VANESSA WU Deputy Clerk Telephone: 818.879.8033 Facsimile: 818.292.8891 Atromeys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO (CNLIMITED JURISDICTION) NANCY MARIE SCOTT, Individually and | Case No. 443236 as Sueccessor-in-Interest to DENZIL SCOTT, Decedent, JOANNE MARIE WOLFARTH: | AMENDED DECLARATION OF VINCE MICHAEL GERALD SCOTT; ROBERT CILIA DAVID SCOTT; THOMAS CARY SCOTT; MARY DENISE SOBOLIK; and FIRST DOE through TENTH DOE, inclusive, Plaintiffs, AC AND §, INC., et al., Defendants. I, VINCE CILIA, declare: 1. I am over the age of eighteen and not a party to the above captioned action. The information stated in this declaration is based on my personal knowledge. If called upon as a witness to testify, I could and would testify to the following facts. 2. [ worked with DENZIL SCOTT during the 1960s and early 1970s at Hunters Point Naval Shipyard in San Francisco, California. I knew DENZIL SCOTT personally and professionally. I would see him during his working hours at Hunter’s Pott Naval Shipyard where he was performing tlectrical and instrumentation work aboard numerous ships at Hunters Point AMENDED DECLARATION OF VINCE CILIAJun=18-07 09:88 From Tae P.02/02 F048 I ‘Naval Shipyard in San Francisco, California, just as I was at the time. 3. During his tenure, [ recall DENZIL SCOTT worked aboard vessels and shops at ‘Hunter’s Point Naval Shipyard. While aboard these vessels and in the shops he performed numerous job responsibilities including the stripping of and otherwise working with old asbestos insulated wire made by ROME CABLE and SIMPLEX. | also recall that while working in the shops and aboard ship that DENZIL SCOTT worked with BAKELITE phenolic molding compounds and insulating boards, drilling, cutting and filing them at times during installation and replacement. These activities invariably caused dust to be generated. These materials were associated with motors, motor controls, witches, terminal boards, power panels and switch gear made by CUTLER HAMMER and WESTINGHOUSE which DENZIL S(2OTT and | worked on and changed out during our respective tenures at Hunter's Point Naval Shipyard as electricians. 4 Irecalt that PARKER HANNIFAN seals and packing were: used at HUNTERS POINT during DENZIL SCOTT’s tenure by those machinists and trades that worked near and around bim and other similarly situated electricians, like myself, I also revall DENZIL SCOTT would form and used insulating paper for some of his electrical work on armatures and motor stators. I declare under the penalty of perjury that the above is true and covrect to the best of my memory, Executed on 13 JOE _, 2007 in J3-¥7g Nnsiwi_ GT, Kailua-Kona, HE VINCY CILIA [AMENDED DECLARATION OF VINCE CILIA