On July 20, 2005 a Motion-Secondary 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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w SSF “A A SF WS NH = PRINDLE DECKER & AMARO LLP William M. Hake (State Bar No. 110956) ELECTRONICALLY James V. Joyce (State Bar No. 111632) FILED 369 Pine Street, Suite 800 Superior Court of California, San Francisco, California 94104 County of San Francisco Telephone: (415) 788-8354 . Facsimile: (415) 788-3625 APR 02 2007 GORDON PARK-LI, Cler Attorneys for Defendant BY: RAYMOND K. WONG A.W. CHESTERTON COMPANY Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION NANCY SCOTT, et al., CASE NO. CGC-05-443236 DECLARATION OF E. JANE WELLS, ESQ. IN SUPPORT OF DEFENDANT A.W. CHESTERTON COMPANY'S MOTION FOR SUMMARY JUDGMENT Date: June 15, 2007 Time: 9:30 a.m. Dept: 302 Judge: Hon. Patrick J. Mahoney Plaintifi(s), ACandS, INC., et al, Defendants. New” "Segue Seg! sage” ge” eget! get” mse” gate! sip!” mage agape eat Complaint Filed: July 20, 2005 Trial Date: July 16, 2007 I, E. JANE WELLS, ESQ. HEREBY STATE AND DECLARE: 1. lam over 18 years of age, a resident of Clayton, California, and a legal citizen of the United States of America. 2. jum employed as a contract attorney m the San Francisco office of the law firm of Prindle, Decker & Amaro, LLP, 3, All matters stated and declared hereinafter are based upon my direct knowledge from my customary work in my position as a contract attorney for A.W. Chesterton Company.SoS SF Sw we = 4 On December 18, 2006,I attended the deposition of Plaintiff, Nancy Scott in the case ‘of Naney Scott, et al vs. ACandS, Inc., (Case No. SFSC'443236) on behalf of A.W. ‘Chesterton Company. The deposition was held at the Offices of Aiken & Welch Court Reporters located at 1 Kaiser Plaza, Suite 505, Oakland, California 94612. $. On December 18, 2006, daring my cross-examnination of Plaintiff, Nancy Scott, she testified that she was not familiar with the name A.W. Chesterton. She further testified that she hadno no knowledge of whether, her father, Denzil Scott had ever worked with or around any products or materials manufactured or eupplied by A.W. Chesterton : 6 ‘On December 18, 2006, Plaintiff, Nancy Scott testified she had no knowledge that her father, Denzil Scott worked with or around thermal insulation, gaskets, packing ‘or outside contractors at any time, 7. On December 21, 2006, I attended the deposition of Plaintiff, Thomas Scott in the case of Nancy Scott, et al vs. ACandS, Inc., (Case No. SFSC 443236) on behalf of A.W, Chesterton Company. The deposition was held at the Offices of Aiken & ‘Welch Court Reporters located at 1 Kaiser Plaza, Suite 505, Oakland, California 94612. 8. ‘On December:21, 2006, during my cross-examtination of Plaintiff, Thomas Soott, he testified that he was not familiar with the name A.W. Chesterton, 9. On December 19, 2006, Plaintiff, Thomas Scott testified he had no knowledge that hia father, Denzil Scott worked with or around thermal insulation, gaskets, packing or outside contractors at any time. ‘declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge and belief, and that this Declaration was executed on March 29, 2007 in Clayton, California, : Dated: “Z 25/07 €. sO i DECLARATION OF KE. JANE WELLS, E3Q,