On July 20, 2005 a Judgment 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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“sO ON lA ELECTRONICALLY Stephen M. Fishback (State Bar No. 191646) FILED Daniel L. Keller (State Bar No. 191738) re Katherine Y. Wang (State Bar No. 215663) County oF or or ealnornia, KELLER, FISHBACK & JACKSON LLP 28720 Roadside Drive, Suite 201 JUN 04 2007 Agoura Hills, CA 91301 GORDON PARK-LI, Clerk Telephone: 818.879.8033 BY: LUCIA RAMOS Facsimile: 818.292.8891 Deputy Clerk Attomeys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SAN FRANCISCO NANCY MARIE SCOTT, Individually and | Case No. 443236 as Successor-in-Interest to DENZIL SCOTT, . Decedent: JOANNE MARIE WOLFARTH; | DECLARATION OF KATHERINE Y, WANG MICHAEL GERALD SCOTT; ROBERT IN SUPPORT OF PLAINTIFFS’ DAVID SCOTT; THOMAS CARY SCOTT; OPPOSITION TQ) DEFENDANT STERLING MARY DENISE SOBOLIK; and FIRST FLUID SYSTEMS (USA), LLC’S MOTION DOE through TENTH DOE, inclusive, FOR SUMMARY JUDGMENT Plaintiffs, VS. Date: June 15, 2007 Time: 9:30 a.m. AC AND §, INC., et al., Dept.: 302, Hon. Patrick Mahoney Defendants. DECLARATION OF KATHERINE Y¥, WANG IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANT STERLING FLUID SYSTEMS (USA), LLC’S MOTION FOR SUMMARY JUDGMENT PAGE 1war Aue ene S I, Katherine Wang, declare: 1. Taman attorney duly admitted to practice before all the courts in the State of California and am an associate of KELLER, FISHBACK & JACKSON LLP. The information stated in this declaration is based on my personal knowledge. [f called upon as a witness to testify, {could and would testify to the following facts. 2. Decedent, Denzil Scott, suffered from asbestos-related diseases culminating in his death on January 21, 2005. 3. An autopsy following Mr, Scott’s death identifies his cause of death as mesothelioma. 4. On July 20, 2005, Mr. Scott’s heirs commenced the instant wrongful death case against Defendant's based on Mr. Scott’s exposure to asbestos from his work with and around Defendant’s asbestos containing products 5. Attached hereto as Exhibit A is a true and correct copy of Plaintiffs’ Responses to Defendants’ Standard Interrogatories, Wrongful Death, Set Two. 6. Attached hereto as Exhibit B are true and correct copies of excerpts from Denzil Scott’s military records. 7. Attached hereto as Exhibit C is a true and correct copy of Plaintiffs’ Responses to Defendants? Special Interrogatories. 8. Attached as Exhibit D is a true and correct copy of Frank Vassallo’s declaration. 9. Attached as Exhibit E is a true and correct copy of Vincent Celia’s unsigned declaration. A signed copy will be submitted to this court on or before the hearing on this motion. 10. Attached as Exhibit F is a true and correct copy of William Chesson’s declaration. I declare under the penalty of perjury under the laws of the State of California that the above is true and correct. Executed on June 1, 2007 in San Francisco, California. DECLARATION OF KATHERINE Y. WANG IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANT STERLING FLUID SYSTEMS (USA), LLC’S MOTION FOR SUMMARY JUDGMENT. PAGE?