Document for NANCY MARIE SCOTT et al VS. AC AND S, INC. et al

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                                | || Stephen M. Fishback (State Bar No. 191646) |

Daniel L, Keller (Slate Bar No. 191738) — ELECTRONICA
2 |) Katherine Y. Wang (State Bar No. 215663) FILED |
. KELLER, FISHBACK & JACKSON LLP Superior Court of Catifornia,
° 28720 Roadside Drive, Suite 201 County of San Franciscp
‘ \
4 Agoura Hills, CA 91301 JUN 04 2007 |
clephone: 818.879.8033 GORDON PARK-LI. Clerk
5 || Facsimile: 818.292.8891 BY: LUGIARAMOS 7} |”
. : Deputy ger
6 || Attorneys for Plaintiffs |
7 |
Q SUPERIOR COURT OF THE STATE OF CALIFORNIA |
CITY AND COUNTY OF SAN FRANCISCO |
9 |
10 :

NANCY MARIE SCOTT, Individually and | Case No. 443236 |
11 || as Successor-in-Interest to DENZIL SCOTT, |
Decedent; JOANNE MARTE WOLFARTH; i
MICHAEL GERALD SCOTT; ROBERT EXHIBITS A-C OF DECLARATION OF |
13 DAVID SCOTT; THOMAS CARY SCOTT; | KATHERINE Y. WANG IN SUPPORT OF

MARY DENISE SOBOLIK; and FIRST PLAINTIFFS’ OPPOSITION TO |
14 DOE through TENTH DOE, inclusive, DEFENDANT STERLING FLUID SYSTEMS |
: (USA), LLC’S MOTION FOR SUMMARY
15 Plaintitts, JUDGMENT |
16 YS. |
17 |
AC AND 8, ING., et al., Date: June 15, 2007
18 Time: 9:30 a.m. |
Defendants, Dept.: 302, Hon. Patrick Mahoney
14 !
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EAHIBITS At PAGE |EXHIBIT AStephen M, Fishback (State Bar No. 191646)
Daniel L. Keller (State Bar No. 191738)
KELLER, FISHBACK & JACKSON LLP
28720 Roadside Drive, Suite 201

‘Agoura Hills, CA 91301

Telephone: 818.879.8033

Facsimile: 818.292.8891

‘Attorneys for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

(UNLIMITED JURISDICTION)
NANCY MARIE SCOTT, Individually and as
Suocessor-in-Interest to DENZIL SCOTT, Case No. 443236
Decedent; JOANNE MARIE WOLFARTH; ,
MICHAEL GERALD SCOTT; ROBERT PLAINTIFFS’ RESPONSES TO GENERAL

DAVID SCOTT; THOMAS CARY SCOTT; | ORDER INTERROGATORIES, SET TWO
MARY DENISE SOBOLIK; and FIRST DOE FUL
through TENTH DOE, inclusive, (WRONG) DEATH)

Plaintiffs,
vs.

AC AND §, INC., et al.,

Defendants. ?

PROPOUNDING PARTY: Defendants

RESPONDING PARTY: _ Plaintiffs NANCY MARIE SCOTT, JOANNE MARIE WOLFARTH,
MICHAEL GERALD SCOTT, ROBERT DAVID SCOTT, THOMAS
CARY SCOTT, MARY DENISE SOBOLIK

SET NUMBER: TWO

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SETTWO (WRONGFUL DEATH)
Page 1yaw

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PRELIMINARY STATEMENT

Plaintif{s’ responses are based upon information in plaintiffs” possession at the time of
answering these interrogatories. Plaintiffs have consulted all sources reasonably available in
preparing these responses. However, plaintiff and plaintiffs’ attorneys have not fully completed
their investigation of the facts related to this case, have not completed their discovery in this action
and have not completed their preparation for trial. Plaintif(s’ discovery and investigation will
continue to and throughout the trial of the above-captioned action. Plaintiffs reserve the right to
supplement and amend these responses if plaintiffs discover any responsive information.

The following responses are based upon plaintiffs’ understanding of the meaning of each of
the interrogatories. If propounding party asserts an interpretation of any request which differs
from plaintiffs” understanding of the meaning of such interrogatory, then any response contained
herein is without prejudice to plaintiffs” right to further object or respond thereto,

Any response by plaintiffs to these interrogatories over objection does not concede the
relevancy, materiality, or admissibility of any information sought by the discovery requests or any
responses thereto. These responses are made subject to and without waiver of any questions or
‘objections as to the competency, relevancy, materiality, privilege, or admissibility of evidence,
documents, or information referred to herein, or the subject matter thereof, in any proceeding,
including trial.

GENERAL OB. [ONS

The following objections are incorporated by reference into plaintiff’ responses to
discovery requests:

1, Plaintiffs object to the extent that the information requested is equally or more
available to the propounding party than responding party (dipine Mut. Water Company v. Superior
Court (1968) 259 Cal.App.2d 45);

2, Plaintiffs object to the extent that the discovery requests are overly broad, vague,
ambiguous, unduly burdensome and oppressive, and speculative due to the unlimited scope of the
request regarding time and location;

3. Plaintiffs object to the extent that the discovery requests can only produce information

irrelevant to the subject matter of the above-captioned action, and are not reasonably calculated to

PLAINTIFFS” RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO {WRONGFUL DEATH)
Page 2lead to discovery of admissible evidence, and are therefore burdensome, oppressive, and harassing;

4, Plaintiffs object to the discovery requests to the extent they conflict with the general
order interrogatories such discovery purports to rely upon and in the event of a conflict, plaintiffs
follow the applicable general order;

5. Plaintiffs object to the extent that the discovery requests information protected by
attorney work product and attorney-client privilege. By disclosure of any information arguably
covered by any privilege, plaintiffs do not intend a broader waiver of the privilege;

6. Plaintiffs object to the discovery requests to the extent that they are vague, ambiguous,
speculative, and overly broad so as to be oppressive and unduly burdensome;

7. Plaintiffs object to the discovery requests to the extent that they call for expert opinion
testimony in violation of California Code of Civil Procedure section 2034.210, and/or call for a
legal conclusion, which is not the proper subject of discovery;

8. Plaintiffs object to the discovery requests to the extent that they seek confidential or
private information, which shall not be disclosed pursuant to the California Constitution, Article I,
and the Constitution of the United States of America;

9. Plaintiffs object to the discovery requests to the extent that they seek to impose greater
obligations than those permitted under the California Code of Civil Procedure;

10. Plaintifffs object to the extent that the discovery requests seek information protected by
plaintiff's federal, state, and common law rights of privacy;

J1. Plaintiffs object to the extent the discovery is duplicative and/or harassing:

12. Plaintiffs object to the extent defendants request information, which has been asked and
answered in previous discovery device, and is thus harassing, oppressive and repetitious
(Cembrook v. Superior Court (1960) 56 Cal.2d 423, 430);

13. Plaintiffs object to the extent that the discovery requests call for the disclosure of expert
information; and

14, Plaintiffs firther object to the extent that much of the information responsive to these
requests is contained within asbestos defendants’ own business records, through depositions taken
of product identification witnesses through the course of asbestos litigation and through the
standard General Order 29 and 129 responses to interrogatories provided by those defendants also

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)
Page3Cwm a

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involved in decedent’s exposure as his employers or coworkers and sub-contractors at numerous of,
decedent’s work sites referred to in Exhibit “A”, attached hereto.

Without waiving said objections, plaintiff responds as follows:
STAND, INTERROGATORY, Set 2, No. 1:

For each and every one of the known job sites at which decedent performed work of any
kind, plaintiffs refer to the following responsive information as well as the more specific and
detailed responsive information contained in Exhibit “A,” attached hereto and fully incorporated
herein by this reference.

Interrogatory 1, Subsections A (work site) and B (address):

For every work site identified in Exhibit “A” attached hereto, plaintiffs have identified both
the site name and the corresponding address. For those sites where an incomplete name and/or
address is provided, or no name or address is provided at all, plaintiffs continue to investigate the
same through the search of public databases such as the intemet and phone listings, and by
contacting identified co-workers and review of records of decedent’s employers to complete the
responses to sub-sections A and B. Plaintiffs reserve the right to supplement these responses with
such information and/or introduce, at trial, such information that is discovered after the service of
these responses.

Interrogatory 1, Subsection C (days worked):

For each and every known job site at which decedent performed work, plaintiffs have
attempted to identify in Exhibit “A” the exact days decedent was present at such site. For those
sites where incomplete time period and/6r days of work is provided, plaintiffs are currently
investigating employment records and corresponding information from decedent's employers and
identified co-workers and/or witnesses to supplement the responses to sub-section C. Plaintiffs

Teserve the right to supplement these responses with such information and/or introduce, at trial,

| such information that is discovered after the service of these responses.

Interrogatory 1, Sul D r)

For each and every known job site identified in Exhibit “A,” plaintiffs have attempted to
identify the employer for whom decedent was performing work at such site.

For those sites where incomplete employer information is provided, plaintiffs continue to

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL, DEATH)
Page 4investigate employment records and identified co-workers and other equally available sources to
supplement their responses to sub-section D. Plaintiffs reserve the right to supplement these
responses with such information and/or introduce, at trial, any information that is discovered after

the service of these responses.

Interro subsections nd F (work performed)

Plaintiffs have attempted to provide the most comprehensive compilation of information
relating these inquiries for each work site, identified in Exhibit “A”, where decedent has worked.
For those sites where decedent's job title or description of work performed appears incomplete,
plaintiffs continue to scarch equally available sources such as employment records, identified co-
workers and witnesses, defendants’ business records, and defendants’ responses to General Order
and case specific interrogatories to supplement the responses to sub-sections E and F. Plaintiffs
reserve the right to supplement these responses with such information and/or introduce, at trial,
such information that is discovered after the service of these responses.

Interrogatory 1, Subsection G (work with or around raw asbestos or asbestos.

mat at th
As listed on Exhibit “A,” plaintiffs believe decedent was exposed, whether directly or

indirectly, to asbestos at each of the identified job sites. Due to the fact that asbestos fibers, once
released into the air, have a very slow settling velocity, drift with the currents of air movement and
are also easily re-entrained once settled, decedent was exposed to asbestos at any site where
asbestos was utilized and/or disturbed in his vicinity.

Interrogatory 1, Subsection G, sub-subsections 1 (area d 2 (das

sure)
Plaintiffs have attempted to identify the specific area within the work site where decedent
worked with or around asbestos or asbestos-containing materials and the length of time of each
such exposure in Exhibit “A,” and their responses to Interrogatories No. 1.B. and 1.C. For those
sites where decedent's work area or duration of exposure appears incomplete, plaintiffs are
currently investigating employment records and corresponding information from decedent's
employers and identified co-workers and/or witnesses to supplement the responses. However,

because of the propensity of asbestos fibers to float, drift and re-entrain, and since even invisible

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)
Poge 5Cea ane wne

Bee ee eee ee
SeSeae ra GR BRS

levels of asbestos concentrations in the air contributed substantially to decedent’s total aggregate
dose of occupational exposure to asbestos, decedent was necessarily exposed to respirable asbestos
fibers generated by other workers or trades in his vicinity and from other sources of which he may
not ever have been personally aware. Consequently, plaintiffs contend decedent was exposed to
asbestos every day he was present at a work site where asbestos was being or had been
manipulated in his general vicinity.

Interrogatory 1, Section G, sub-subsection 3 (control of work/directors):

Plaintiffs respond that the general contractors and sub-contractors for each of decedent’s

work sites predominantly controlled such site, or their work area within that site and, either
directly or indirectly, controlled the placement, timing or manner of decedent’s activities. The
nature and scope of the direction is covered by the general contractors and sub-contractors’
contracts in the exclusive possession of the relevant named defendants in this action. Where more
specific responsive information is known (j.e., names of contractors’ employees responsible for
safety or direction of time, place or manner of work disturbing asbestos), plaintiffs have identified
such contractors’ employees and/or further responsive information currently available regarding
direction of decedent’s work at each site in Exhibit “A.” For those sites where incomplete
information is provided, most of the information regarding "control" issues is in the exclusive
possession of the relevant named "premises" defendants. Thus plaintiffs continue to search
equally available public databases (such as building permits) to supplement the responses to sub-
subsection 3. Information responsive to this sub-section is also in the possession or control of the
relevant named defendants in this action and such information should be available through
defendants" responses to case specific interrogatories from plaintiffs or through General Order
Interrogatory responses. Plaintiffs reserve the right to supplement these responses with such
information and/or introduce, at trial, such information that is discovered after the service of these
responses.

Interrogatory 1, Subsection G, sub-subsections 4 (co-workers) and 5 (other

witnesses):
Plaintifis have attempted to identify each and every one of decedent’s co-workers or other
individuals with knowledge of his exposure, for each identified site, in Exhibit “A.” For those

PLAINTIFFS’ RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)
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sites where incomplete co-worker and’or exposure witness information is provided, plaintiffs
‘continue to search public databases (such as contracts, the internet and phone listings) and
investigate other known co-workers to augment co-worker and witness information responsive to
sub-subsections 4 and 5. Much of this information is also in the possession or control of
decedent's employers and other defendants in this action. Plaintiffs reserve the right to
supplement these responses with such information and/or introduce, at trial, such information that
is discovered after the service of these responses.

atory 1, Subsections G, sub-subsections 6 and 7 (contemporaneous and prior
contractors):

Plaintiffs have provided the most responsive, currently available information on contractor
identities in Exhibit “A.” Where incomplete contractor identification is provided, or no contractor
is identified at all, plaintiffs continue to search public databases and research identified co-
workers, construction contracts, building permits and defendants’ responses to standard and case
specific discovery to complete the responses to sub-subsections 6 and 7. Plaintiffs reserve the
right to supplement these responses with such information and/or introduce, at trial, such
information that is discovered after the service of these responses.

In ry 1, Subsections G, sub-sub: s 8a

The majority of any documentation supportive of plaintiffs! responses can be found or
idcatified through equally available sources such as defendants’ business records, defendants’
responses to standard and case-specific discovery, building permits and In Re Complex Litigation
discovery. Plaintiffs will not endeavor to compile a list of all of the documents that are equally
available. Plaintiffs continue to search these and other equally available resources to discover
information more responsive to sub-subsections 8 and 9. Plaintiffs reserve the right to supplement
these responses with such information and/or introduce, at trial, such information that is
discovered after the service of these responses.

Interrogatory 1, Subsections G, sub-subsection 10(a-e) (Decedent’s_ work with

asbestos

Plaintiffs have provided the most responsive, currently available information on the details

regarding decedent’s work with asbestos or asbestos-containing materials in Exhibit “A”.

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SETTWO (WRONGFUL DEATH)
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Decedent did not wear breathing protection against asbestos inhalation. In fact, decedent was not
aware of the possibility of danger from asbestos inhelation until such knowledge became public
throughout the news media. Decedent was not provided any breathing protection by his employer
before such time nor was he ever advised that such protection was available. Additional
information may be found or identified through equally available sources such as defendants’
business records, defendants’ responses to standard and case-specific discovery, building permits,
construction contracts and discovery propounded in specific cases and In Re Complex Litigation.
Plaintiffs continue to search those equally available resources and public databases such as
identified co-workers, construction contracts, building permits and defendants’ responses to
standard and case specific discovery to complete the responses to sub-subsection 10. Plaintiffs
reserve the right to supplement these responses with such information and/or introduce, at trial,
such information that is discovered after the service of these responses.

ection 11(a-h) (others’ work with asbes

Interros Subse

Plaintiffs have provided the most responsive, currently available information on the details
regarding other entities' or individuals' work with asbestos or asbestos-centaining materials, in the
vicinity of decedent, in Exhibit “A.” Decedent did not wear breathing protection against asbestos
genefation caused by other entities or individuals. Moreover, unless specifically indicated to the
contrary in Exhibit “A,” plaintiffs are unaware of any general contractor, sub-contractor or any of
their agents or representatives having taken any safety precautions to protect decedent from
exposure to asbestos. Additional information may be found or identified through equally available
sources such as defendants’ business records, defendants’ responses to standard and case-specific
discovery, building permits, construction contracts and In Re Complex Litigation discovery.
Ptaintif® continue to search those equally available resources and public databases such as
identified co-workers, construction contracts, building permits and defendants’ responses to
standard and case specific discovery to complete the responses to sub-subsection I. Plaintiffs
reserve the right to supplement these responses with such information and/or introduce, at trial,
such information that is discovered after the service of these responses. Plaintiffs” investigation
and discovery are continuing.

Wa

PLAINTIFFS" RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)
Page 8Cera aAneurne

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STANDARD INTERROGATORY. Set 2, No. 2:

Investigation and discovery are continuing as to depositions of any of the individuals
identified in Response to Interrogatory No. 1 and the circumstances surrounding such depositions.
Plaintiffs reserve the right to supplement this response with subsequently discovered information ~
as any such information is discovered, To the extent that such individuals may include witnesses
revealed in other cases, this information is equally available to defendants, Plaintifts*
investigation and discovery are continuing.

STANDARD INTERROGATORY, Set 2, No.

Information responsive to this interrogatory is cumulative of information that already has
been or may be provided by plaintiffs in response to defendants’ standard request for production to
plaintiffs. Additional relevant, non-privileged documents responsive to this request are equally
available to defendants through their own investigation. Plaintiffs’ investigation and discovery are

continuing.

DATED: February 2¢_, 2007 KELLER, FIS) JACKSON LLP

Attorneys for Plaintiffs

PLAINTIFF'S RESPONSES TO GENERAL ORDER INTERROGATORIES, SETTWO (WRONGFUL DEATH) .
Page SEXHIBIT “a”

Decedent, DENZIL SCOTT, died from asbestos-caused diseases, including but not limited
to, mesothelioma, on January 21, 2005.

Plaintiffs allege and believe that DENZIL SCOTT’s exposures to asbestos may have
occurred at job sites including, but not limited to, the following:

Employer:

Job title:
Dates:

Job Duties:

Job Sites:

Employer:

Job title:
Dates:

Job Duties:

Job Sites:

Employer:

Job title:
Dates:

St. Louis & Southwestern Railroad, St. Louis, Missouri.
Ticket seller.

Approximately late 1930s. Plaintiff's investigation and discovery are continuing.
Decedent sold tickets for the railroad.

St. Louis & Southwestem Railroad, St. Louis, Missouri.

Plaintiff is currently unaware. Investigation and discovery are continuing.
Farm [aborer.

Late 1930s to approximately 1940. Investigation and discovery are continuing.
Decedent’s duties included planting crops and caring for farm animals.

Farm, located in Missouri. Plaintiff's investigation and discovery are continuing.

US. Navy.
Seaman 1" Class; Chief Gunners Mate; Jr. Officer.
September 24, 1940 ~ April 4, 1960

Job Duties and Job Sites: Decedent was a member of the U.S. Navy from September 24, 1940

to April 4, 1960, as a Gunners’ Mate Chief Senior grade. Decedent attended basic
training at the US, Naval training center in Great Lakes, Illinois. After basic
training, decedent was assigned to the USS MARYLAND (BB 46), from
approximately 1940 - 1943, where he worked as a seaman recruit, in the ordinance
division. Decedent also worked as 2 mess cook, performed maintenance in the
ammunition department, and operation of catapults and guns. Also, while the USS
MARYLAND was being overhauled in Bremecton, Washington, decedent
performed fire watches in compartments where welders were welding, Decedent
worked in close proximity to other trades performing, work as well during the
overhauls. From December 22, 1943 to 1946, decedent served onboard USS
LAVALLETTE (DD448), as a gunner’s mate and also worked in the repair party,
where he assisted in the repair of fire damage and/or flooding. Decedent also
performed various cleaning duties onboard the USS LAVALLETTE. Decedent
‘was onboard this vessel when it underwent repair work at Hunters Point Naval
Shipyard, Thereafter, decedent was assigned to a subgroup in San Diego,
California, from approximately April 1946 to April 1948, where he assisted in
putting various ships out of commission including, but not limited to, USS
HUDSON (DD475), USS FULLAM (DD474). Decedent's specific duties while
putting ships out of commission included, but were not limited to, putting the guns
up, oiling machinery, and insuring various compartments were cleaned out before
the ship was put out of commission. In May 1948, for sixteen weeks, decedent
attended Gunner’s Mate School, in Washington, D.C. In April 1949, decedent was

PLAINTIFFS" RESPONSES TO GENERAL ORDER IVTERROGATORIES, SET TWO (WRONGFUL DEATH)

Page 10n=

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3s

Employer:
Job title:
Dates:

Job Duties:

Job Sites:

Employer:
Job title:

Dates:
Job Duties:

Job Sites:

Employer:
Job title:
Dates:

Job Duties:

stationed onboard the USS ROANOKE (CL145), where he worked as Chief, in
charge of the No. 6 tufret, In September 1949, decedent was stationed onboard the
GENERAL A.E. ANDERSON (AP111) ai a chief gunners mate in charge of
ordinance. After his work onboard the GENERAL A.E. ANDERSON, decedent
performed shore duty as a ceremonial guard at U.S. Naval Receiving Station,
‘Washington, D.C. Following the shore duty, decedent was stationed onboard the
USS WOOSTER, as 2 junior officer, where he stood watch and was in charge of
several turrets. Decedent was onboard the USS WOOSTER for approximately five
months. Thereafter, in 1955, decedent worked onboard the USS BALTIMORE,
(CA 68) as Chief in Charge of No. 3 and 4 ordinance divisions. Decedent attended
Instructor’s School in 1956, in San Diego, California. Decedent also served
‘onboard the USS ORISKANY and also assisted in putting the USS ORISKANY
out of commission, In addition, he served onboard the USS BURTON ISLAND,
where he supervised gunnery for approximately five months; USS WARRICK (AK
68), where he supervised gunnery and was in charge of the ordinance division and
also assisted in putting the USS WARWICK cut of commission; USS
ISHERWOOD (DD 520), where he was in charge of ordnance for three years, from
1957-1960. Decedent was also onboard the USS WORCESTER (CL 144). During
his naval career, decedent also worked onboard the following ships including, but
not limited to: CHICAGO; CORAL SEA; CRAIG; ENTERPRISE; HANCOCK;
HANSON; HUDSON; KANSAS CITY; LONG BEACH; MAUNA KEA; PYRO;
and SPERRY, Plaintiff's investigation and discovery are continuing.

Plaintiff is currently unaware. Investigation and discovery are continuing.
‘Maintenance Man.

1960 (approximately four months)

Decedent’s job duties included the installation of fire pits, cutting tree limbs, and
maintaining the park.

Junipero Serra Park, San Bruno, California.

Hunters Point Naval Shipyard, San Francisco, California,
Apprentice electrician/marine electrician/gyrocompass mechanic/ship’s system
mechanic.

1960 ~ 1973

During the first four years of his employment, decedent worked as an apprentice
electrician. Thereafter, he worked as a marine electrician, gyrocompass mechanic,
and ship’s system mechanic. While at Hunters Point, decedent performed work
onboard various ships and in various shops throughout the shipyard. Decedent
worked in the engine rooms and worked around various trades including, but not
limited to, shipfitters, welders, electricians, bumers, and pipe lagers. Plaintiff's
investigation and discovery are continuing.

Hunters Point Naval Shipyard, San Francisco, California.

Mare Island Naval Shipyard, Vallejo, California.
Gyrocompass mechanic.

1973 (approximately three months)

‘Asa gyrocompass mechanic, decedent performed work in Shop 51, as well as,

PLAINTIFFS’ RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)

Page 11Caran ewenn

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Job Sites:

Employer:
Job title:
Dates:

Job Duties:

Job Sites:

Employer:
Job title:
Dates:

Job Duties:

Job Sites:

Employer:
Job titl
Dates:
Job Duties:

Job Sites:

Job Sites:

onboard various ships. Investigation and discovery are continuing.
Mare Island Naval Shipyard, Vallejo, California.

Alameda Naval Air Station, Alameda, California.

Instrument mechanic.

1973 — 1980

Decedent's job duties included calibrating instruments in different buildings
throughout Alameda Naval Air Station, Decedent also performed some calibrating
work at Moffett Field, California, Plaintiff's investigation and discovery are
continuing.

Alameda Naval Air Station, Alameda, California; Moffett Field, California.

Allan Instrument Company, Inc., San Francisco, California.
Gyrocompass mechanic.

1981 ~ 1982 (approximately one year)

Decedent performed gyrocompass mechanic work. Decedent worked onboard the
PYRO, while docked in San Francisco, California, Decedent recalled the PYRO
was being overhauled during the time he was onboard overhauling the
gyrocompass. Plaintiff's investigation and discovery are continuing.

Various including, but not limited to, PYRO. Plaintif?s investigation and
discovery are continuing,

Gyro Marine (nstrument, Ine., San Francisco, California.
Gyrocompass mechanic.

1982 - 1983 and 1985 (approximately two years)

Decedent performed gyrocompass repair work onboard various ships docked in San
Francisco. Plaintiffs investigation and discovery are continuing.

Including, but not limited to, various ships docked in San Francisco, California.
Plaintiff's investigation and discovery are continuing.

Allen Rose Ford Home Sales, Daly City, California,

Handyman.

1983 (approximately one year)

Decedent performed work as a handyman including, but not limited to, painting,
installation of light fixtures and doors, and sheetrock work. Plaintiff's investigation
and discovery are continuing,

Various homes in and around Daly City, California. Plaintiff's investigation and
discovery are continuing.

Decedent, DENZIL SCOTT, also performed home remodel work, sometime between 1956-
1958, on the family home that was located at 672 Orange Street, Daly City, California. Decedent
transformed the downstairs basement into a bedroom, Decedent performed all of the work
associated with this remodel including, but not limited to the framing, sheetrock, and electrical

work.

Plaintiff's investigation and discovery are continuing.

PLAINTIFFS’ RESPONSES TO GENERAL ORDER INTERROGATORIES, SET TWO (WRONGFUL DEATH)

Page 12Ihave read the foregoing PLAINTIFFS’ RESPONSES TO GENERAL ORDER:
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof, The matters stated in the foregoing documents are not knowingly false, are
based upon my own knowledge or are stated on information and belief, and/or the
+ “information and belief of my éttomeys; anc-as to'all matters; believeth to'be true = —~
I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on

feb oF, 2007.

Web hegaade dat:

~ ROBERT DAVID Si

oe coast be

keVERIFICATION

Thave read the foregoing PLAINTIFFS’ RESPONSES TO GENERAL ORDER
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof. The matters stated in the foregoing documents are not knowingly false, are
based upon my own knowledge or are stated on information and belief, and/or the
“information and belief of my attorneys; and as to all matters, believe them to be true.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on

272 2007.VERIFICATION

Ihave read the foregoing PLAINTIFFS’ RESPONSES TO GENERAL ORDER
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof. The matters stated in the foregoing documents are not knowingly false, are
based upon my own knowledge or are stated on information and belief, and/or the

~~ information and belief of my attorneys; and ast all matters, [believe them to be tue.
I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on

Hla / 2007.

4 te vats WOLFA! aVERIFICATION

Thave read the foregoing PLAINTIFFS’ RESPONSES TO GENERAL ORDER
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof, The matters stated in the foregoing documents are not knowingly false, are
based upon my own knowledge or are stated on information and belief, and/or the

” information and belief of my attorneys; and’as to ali matters, I believe them to be true,

1 declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on

Masel ] - , 2007.ERIFICATIOI

Ihave read the foregoing PILAINTIFFS’ RESPONSES TO GENERAL ORDER
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof, ‘The matters stated in the foregoing documents are not knowingly false, are

"> ~ based upoh'my own knowledge or are stated on’inforination-and’beliéf, and/or the’
information and belief of my attomeys; and as to all matters, I believe them to be true.

1 declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct and that this declaration was executed on

Yoatke £2, 2007.

Vv RY DENISE SOBOLIKYE) CA’

Thave read the foregoing PLAINTIFFS" RESPONSES TO, GENERAL ORDER
INTERROGATORIES, SET TWO (WRONGFUL DEATH) and know the contents
thereof. The matters stated in the foregoing documents are not knowingly false, are
based upon my own knowledge or ate stated on information and belief, and/or the __ |
information and belief of my attorneys; and as to all matters, I believe them to be true.

I declare under penalty of perjury under the laws of the State of Califomia that the

foregoing is true and correct and that this declaration was executed on :

aReIY 2007.

oT I

SCOTTEXHIBIT B.Sorry or wre Sees ung rt daneer alten wl ceed

pone mrp fr NEALING EXAMINER peace)

CAE whofe
as of clans Fam Se ec ak oF paltoe
* | een 297. ‘TorRSoMT Too Gyro Compass lee!
lay or oxen Aig | Fe of enforce
seek hs = awe (Cr Vallejo ne
Pot 1 6.71 ze br LO [sue: Quit.
Tatiana pao i Sais Ppa a] SUVS I HAE TT
nt, Dean Alisn Ware Island Yaval Shipyard .
Toa Cote pbs Re SE Vallejo, California

‘awoa fr waren = het To fan to comuba dun ta ib

Desaipin of Stes, mapons nd neopeeont never sist reron Elect moth
requires complete digas: napection of all parts for woar. Check

and

sTectrioal electronic paris such as tubes, power transformers and

-
| oT
from_5-31-70 te 27-7,
Shorea mt
Sanne! 6615 Ot he prot
oats 6.7 pot Vit LO sere:
Vine often aparioe
lie, Phil Warda Mr. Henry Bruner San Francisco Naval Shipyard

Tew Sst Fir We Eso San Francisco, Cslifornia
| [eee erteee Beso Closure 7
[Busine fata, penn i ooniimen Sep attached sheot

SF
Rol) 4.87 oo br 10_|soe cane,
Wie inet pari, ‘Wome of clare Um, weenie) oo ain (cadng Lok Te)
Bruner SFNSY
dies Cn nd pene Ne a
ee fe tarog _ PYOROEI OE
Sy pian eieeapiionms Sop Stale] Gheat

= at ager on (da ml wey

 [it Feal savin, chen

Strom YyelnS0 to 5-550 Sanior Chiat tg tats [“mNTO ics {Rat)
Siew aneer NE] Fae etravermen | Rumi dnote lado wn
‘aunt me Pe oe Gremstoyea. [mem Eee cm
Feu foes

Tae Tinta a [Roars OY cephoyes (ran wgusviatin, Or) and adeas (omledeng 21D Coch Barwa)

| __wow

in Cae pone No

ae fron ath

Deine asin mdacanalibmrat nour wes Usad accrued leave.

Fa Gacy wT ae F

“THE PEDRNAL GOVERIUGENT EAN EQUAL GPFORTUNETY EXRLOVER OS mee
‘US ci Semer Commision, November 170

900025Rad
Senior Chief Gamer's vate

[ember sed bind of or

Fa

“Tats ear (Fim wah Finda cag IP Ca man

U.S, Navy a

Descigrin of 0 a meoepidsnees You ma

er'a Wats Chief in chi

Fess ie oT polion

fom ® :
Say a aa a | Pe of tiopact—"Taat anditnd afew Rind af Bags wanna
Seming ” rant | Cie Exiefactg aig me,
re wel

Tae of bern viper Nase a eploer Um opt, Tannen ace BP Ook, W eae)

Fe Cold Pe Re .
Sexe for borg

Fara wn PT a oY

Bete er, eran
ore gree

Wet aed hind ofc | Rind of baciocnt_ oF oemanteation
Poon ered ap hes om es

Was ol appr Com open, a] wed nas (oding BP Gos torn: AT CH SUPPLEMENTAL SHEETS OF “ORMS HERE
“NSWER ALL QUESTIONS’ CORRECT .ND FULLY

"TOA Gpel guia tod Hl ab machin fee Tate rv tpn pina (ae wt
(Pith oad pens mpi np se pf sa me

1, Bleetrickan through apprentices

ip at SPUSY,

eg wal mgt pe

2. Operate shop power tools such as driii presses, saws, grinders and iithes,

0 Kind a Uenges or Caine (fee zap
iment sent, Tsay rads tree, CRA}

May

[eRe oto teeadag my

Ae

Wee nd finn poetic) oo
‘Campbell High School
Gompbel, tssouri

Dabs ocd [Ye Caled

Fou [to | By | Nay | “tows

instruct Trainee. Approx.
Graduation Cartificate,

D. Chk endplate ee eae K Obfgatne alta nie
i —_ WA,
7 ajar id yal ghost eaege wo
ak,
‘BSei elon fr Sangh, ede POT Sal Fe Pa ks ech i ae non [ly ray ed EP GPT lef eh
‘Pol Bee went fas wack oes of dascooe bro ar ac an sao ne plot ee}

Ls Advanced GH School, Washington D.C, $-20-48 to 9-20-h8, 6"/k7 Gun Turret. Approx,
LO urs, por week, Gratiation Certificate. ~

2. Instructer School Class Cl, ¥°C, San Diego, Calif. 2-18-57 to

lo srs. per wegk. Graduation Gsrtificate.

3. Apprentice School, SFHSY, 8-21-60 to 9-2-Gh. Electrical and Electronic ‘theary.

3-1-57. How to

2A HERORS, AWARDS AND FELLOWSOPS -

Bee attached shect

FC ANCUAGES OTT THAN ERSTE —

sea Tale
ae of ent

‘andy [Seating [Uaioe | Wil

Bniog Stage Sioa’ _ [Son abet

E HET

gd ges ave defae ngulelar of yous qeatoos
el geo kee ta Berenrenee

‘ed Wane for Oe pon fr oR

PRESENT BUSINESS OR HOME ADDRESS
(deeb, Dowty bee ed a)

‘BUSINESS 08 OCYATION

Steven R. Walter
Wallace R, Stradley

{ muiatan &. earphy

ih Geison ce,

121 Mariposa Ave.
632 Capistrano Way
Son lhc, Calif

Indust. Eng.

Attorney at Lam

net

0000271. Scott wo 10-28-20

Denwil G. Scot . 40-382

Ttem 20

Block ‘#2

‘A. Make Pre-Arrival Inopection of Ship's Compass, Dead Recononing and Undarvater Log
system,

B, Write deficiency reports and aake recomendations for correction.

G. Requisition through Shop Planner all components and parts that cannot be fabricated
in machine shop,

D, Goupletely disassenble and overhaul conpess and related qquipnent, Related equipment
consists of:
a, Ocnerators for compass - Shipbeard test and adjust: only.
‘, Carbon Pile Speed Regulater
c, Automatic Speed Regulator
d, Relay Transmitter
‘3 Compass Popaaters

Dummy
je Rectro-Magnetic Log
ic, Various other componants

‘Voed Shop'd power tools such as band sam, sander, grinder, drill press, mydraulic
yreno and lathes in fabricating necessary shafts, turning and polishing synchro
armatures and clip rings, renewing revolution disks on shafte and various other
‘things that could be doné in the Shop.”

AL work accomplished by using pertinent pamphlets, schematics and blueprinta to
- overhaul, repair, make modifications.and to trouble shoot.

G, Used Test and Measuring Instrugents required and necessary to complete job ae follows:
a, Voltmeter
+b, Ammeter
c, Megger
d, Tachometer 7
en Strobatac
£1 Balancing Maching with Gathodo Ray Oscillograph 160-8
g. Tryratron Tubes Toster WK 1 Mod 0
hy Fhase Rotation Indicator m
#4. Fig Gages
3. Taickness Gege
E! Wleramsters ~ outoldo, dneide and d
1. Various other clectrical and mechanical msasurirg instruments

H, Gunduct transmission tests and correct inputs to Ship's Peloruses, Coupass Repesters,
NO-2 Plotting system, Dead Reconoming Analyzer, Sonar, Radar and Fire Control.

I, Make initial Bay and Sea Trials on final check of Compass Systen performance,. Dems 8. Scott : oe

Item 29
Block #3

A, Assisted Engincering Devigh in Ship's Arrival Inspection of Oompass systen.

B, Bisoonnect Compass from Ship's binnacle: encase cae in special carrging frame and
~" assisted Riggere in recoval of Compass frou Ship to Shop for overhavl.

Corplately disassembled Compass and associated equipment. Inspected all mechanica?
parts for alighment and lost motion. Inspected and tested all motors and generators
for continuity. Inspected all wiring and tested for continuity and flexibility,

D, Roquisitioned through Shop Plamar al parts needed for overhaul of compass system
that cannot be fabricated in machine shop. Parts needed are determined during
disassembly of Goxpass and associated equipment.

Vged machine shop when necessary to fabricate parts, polish amatures and sliprings,
check concentricity af phantom and vertical ring and do various other work needed.

F, Make Static and Dynamic tests of rotors. forrect balanes Jf necessary.

G,. Completely cverhau? all parts and sub-assemblies using proper procedures and sequence
applicable to ansure correct clearances and aligmont necassary for satisfactory
operation of units.

He Make Vertical, Coupound and. Horisontal running balance of compas:

T, Maks swing balaness to removo acceleration and centrifugal error,

J. Make high angle Scorsby runs to ingure Coupass will perform accarding to Burean
specifications,

K, Shop.teated all associated equipment to Compass system prior to re-installation,

L, Asteted Riggers in re-instaliation of Compass aboard ship. Connected up Ompass
in binnacle, phoned wiring to onsure correct hook-up and contimity, mada mechanical
adjustments for proper freedom and balance, lighted off Compass and sot up gonerators
to ensure proper voltages and speed to rotors, settled Compass and had sun azimuths
taken to check if any exror encounteréd in Compass transit fron shop to ship.

¥, Tost and Measuring Instruments used aama ag Block #2, Item G.

flote: Have been 2oad mechanic on Master and Auxiliary Compasses and systen equipuent
~ Of fcLlowing ships and made Bay.and Sea Triala as Shop Compass Representative.Denzil a, Scott 10-26-20

ites 20
Block #7

A, Torked in Instrimont Section of Oyro Shop. Overhauled and tested Auphoux meters,
Forved Draft Blower magnetoes, Salinity Indicators, Reverse Grent Relaya, Over
Durrent Relays, Constant Frenquency units and Hydscgen Joteotors,

3. Lead qverhaul. of UK AVILL vod. 1A Auxiliary Compass.
2, Overhaul prodedure same as Item 20 Block #3, riimttaks ¢ through J.
2, Test and Heasuring instruments used sane ao Item 20, Block #2, lebter0,
3. Completed teats and put Oapass in stand-ty-veadiness,
©, Lead overhaul of KK XL Hod.6 Master Oowpasa.
1. Overhaul procedure, Test oquiywent uxe saws as aluvs ia B,

2. bend ovsshani of Wk iv “Axl. 1 Compass “
1, Gverhaul procedure, Teat equipment used samo as above in Be
2) Gompletéd testa ant gut ecupass in stand-by-readingoo,

“00033”. : . 4
Donuil G. Scott

Ttem 20
Block #8

A, Lead mechanic of inotallstion of ihster Compass UK XIV Mod, 1 outfitting
installation on U.5,5, Procyon,

1. This required layout, requisitioning of materials, intershop planning,
Installation of components, oub in cabling and asdist in systom check out.

3B, Planned and asgisted in installation of Degaussing switchboard and generator
aboard ¥,5.8, Chicago.
1, Layed’out and installed units using applicable plans,
20 ALL units hooked up by using applicable blueprints,
3. Phoned out all wiring.’ -°*"

©, Lead mochanic of installation of EO roon on U.S.S. Hamner.
2, Layed out and hook-up same as item above.

1b. Worked in Gyro machine shop section,
1, Operated lathes, milling machinen, drill presses and all other power and
special tools necessary to fabricate parts such ap shafte, goare, etc,
needed Tor compass repair.
2, Used bineprinte and schonatics in all ware where necessary.ro z
+ xbueo secomenasrion For
Ee eee

YO: Incentive Avards Countttee

J recommend that avard consiceration be given for the mperiar eienmptlshacat beitin descr ibsd which war
parted by the eepleyee, ot free of amplopeee raced befor.

WaOnOne FS weaver [eee ie wigtin ==

EoCorRE Gomes ae, lens Bley ov Pavel Pax) Pasties Step, Be
SCOFT, Douail 6 Apprentice Electician Shop Sl $6555
“tetZzero— +r

(iteah @ Wise Jor 28d onal raplegoo
1. OAS 1S FOR AWARD ReoOMENOATION. a me
(CJ srenton scnserentnr Bevo 0 Bet Sept, 1963 te Sept. 1964
Tier een

A. intanciove sencerts: Clover [Xj ummovroactim — Juomae

i,
vate [are L)ucoeeere De. meer
xen oF arruicarion [J ume [ij voca. Cleon arse [ences

De TANGINE BENEFITS _ (Fn toble Delew compute Cobor vovings at actual cont)
TABOR MATERTAL

‘Labor and
st cetidtay

memo

Yop ebenye

eavi95,
fered

%. aceon eek Feaeaa er Te

Denzil Seott entered the A 4a Electrician program 1 August 1960 ond will
graduate 6 Novenber 1964, Onring this four yeer progrum, be has maintained «
Eosertable 2,5 grade averoge for ll class work weder # 4.0 eystem, Ty addition,
Mey Scott ‘steven outstanding, two S-plus and thirtees 5 grades for the
‘twenty Six shop training courses widertaken, .

the past He, Scott hes been ander the olose supervision of
Leite TL ¥2 Breners who bas roported Ms Superior ocecupl ishoests
oxa's

ee Stott oucconstully overhanted, with the seopexsate, ence of 0 Je
Gyro Compass, & ‘Compass, two Dosa
Reckontog Tables end a SK VII Gyro Coupons. oghaee peat

on_the USS_UDGBER, We__S20tt_potformed inven owtsbandiog-onanet! wisrocentoatfeg
Toa pe ara Tease lsear om? a

ExCtES won JON COPEETANEY? 6. C6 wweneweuent CA BE USED ELSEMERE. INDICATE MERE

S18 2aroe ywresrieatiom ageaieneD em, meet heen

_ oe "RAPT INCENTIVE AMARSS PREG

000063sever bortorueq 10m onrarsn,

ESTE IT BROT TTF TIS

Te Wired 250 26M
Kren te wo Siogorde or ce omaweh

bo nek a

agus Gunceea
hegegin 00" cud ekg

z cyyed
hret tae tom aebx beets
oBeeReges jpocenpe gay brotaae ¢ sninae j

we? [Or PHo
2. gh segyeyou

£1q STE

. Be, sea triole by hinself, showing particalar adeptness in handling the Gyro
yatem,

Mr. Seatt presently is doing Journeyman level work, and perforsing in 9 anpertor
manner on the Dead Reckoning Equipment om the OSS SCARBARDF ISH,

To view of the above performance and the fact that Mey Scott is ay tice
who bes perforved ut 5 Yew Fel te Te recmaeended thet

wR sor Farmance ay.

eer Tes NyCeERTe /nn

pee. enna, poonerEXHIBIT Cawk wn

Stephen M. Fishback (State Bar No. 191646)
KELLER, FISHBACK & JACKSON LLP
28720 Roadside Drive, Suite 201

‘Agoura Hills, CA 91301

Telephone: 818.879.8033

Facsimile: 818.292.8891

Attomeys for Plaintifis

SUPERIOR COURT OF THE STATE OF CALIFORNIA.
CITY AND COUNTY OF SAN FRANCISCO
(UNLIMITED JURISDICTION)

NANCY MARIE SCOTT, Individually and as
Successor-in-Interest to DENZIL SCOTT,

Decedent; JOANNE MARIE WOLFARTH; . .
MICHAEL GERALD SCOTT; ROBERT PLAINTIFFS’ SUPPLEMENTAL

: .._ | RESPONSES TO SPECIAL
DAVID SCOTT; THOMAS CARY SCOTT; P :
MARY DENISE SOBOLIK; and FIRST DOE. | INTERROGATORIES PROPOUNDED BY

through TENTH DOE, inclusive, (USANLLe. T STERLING FLUID SYSTEMS

Case No. 443236

Plaintiffs,
vs.

AC AND §, INC. et al.,

Defendants.

PROPOLNDING PARTY: Defendant STERLING FLUID SYSTEMS (USA), LLC
RESPONDING PARTY: _ Plaintiffs NANCY MARIE SCOTT, JOANNE MARIE
WOLFARTH, MICHAEL GERALD SCOTT, ROBERT DAVID
SCOTT, THOMAS CARY SCOTT, MARY DENISE SOBOLIK
SET NUMBER: ONE

Plaintiffs hereby voluntarily responds in supplement to some of the Special Interrogatories
propounded by defendant STERLING FLUID SYSTEMS (USA), LLC as follows:

PLAINTIFFS? SUPPLEMENTAL RESPONSES TO SPECIAL INTERROGATORIES PROPOUNDED BY DEFENDANT STERLING FLUID
SYSTEMS (USA), LLC
Page |PRELIMINARY STATEMENT.

Plaintiffs” responses are based upon information in plaintiffs’ possession at the time of
answering these interrogatories. Plaintiffs have consulted all sources reasonably available in
preparing these responses. However, discovery and investigation in this action are continuing.
Plaintiff” discovery and investigation will continue to and throughout the trial of the above-
captioned action. Plaintiffs and their attorneys have not fully completed their investigation of the
facts related to this case, have not completed their discovery in this action and have not completed
their preparation for trial. Plaintiffs reserve the right to supplement and amend these responses if
plaintiff discovers any additional responsive information.

The following responscs are based upon plaintiffs’ understanding of the meaning of each of
the interrogatories. If propounding party asserts an interpretation of any interrogatory which
differs from plaintiffs’ understanding of the meaning of such interrogatory, then any response
contained herein as to any such interrogatory is without prejudice to plaintiff's right to further
object o respond thereto.

Any response by plaintiffs to these interrogatories over objection does not concede the
relevancy, materiality, or admissibility of any information sought by the discovery requests or any
responses thereto. ‘These responses are made subject to and without waiver of any questions or
objections as to the competency, relevancy, materiality, privilege, or admissibility of evidence,
documents, or information referred to herein, or the subject matter thereof, in any proceeding,
including trial.

GENERAL OBJECTIONS

The following objections arc incorporated by reference into each interrogatory response:

1. Plaintiffs object to the extent that the information requested is equally or more
available to the propounding party than responding party;

2. Plaintiffs object to the extent these interrogatories posed herein are overly broad,
vague, ambiguous, unduly burdensome and oppressive, and speculative due to the unlimited scope
of the request regarding time and location;

3. Plaintiffs object to the extent that these interrogatories can only produce information
irrelevant to the subject matter of the above-captioned action, and not reasonably calculated to lead
to discovery of admissible evidence, and are therefore burdensome, oppressive, and harassing;

4, Plaintiffs object to the extent these interrogatories request information protected by
attorney work product and attorney-client privilege;

5. Plaintiffs object to these interrogatories to the extent that they are vague, ambiguous,
and overly broad, so as to bc oppressive and unduly burdensome;

6. _ Plaintiffs object to these interrogatories to the extent that they violate Superior Court
General Orders-Asbestos;

7. _ Plaintiffs object to these interrogatories to the extent that they call for expert opinion
testimony in violation of California Code of Civil Procedure section 2034.210, eg seq, and/or call
fora legal conclusion, which is not the proper subject of discovery;

8. Plaintiffs object to these interrogatories to the extent that they seek confidential or
private information, which shall not be disclosed pursuant to the California Constitution, Article 1,
and the Constitution of the United States of America;

PLAINTIFFS" SUPPLEMENTAL RPSPONSES TO SPEC’AL INTERROGATORIES PROPOUNDED BY DEFENDANT STERLING F.UID
SYSTEMS (USA), LLC
Page 29. Plaintiffs object to these interrogatories