Preview
1 } LISA L. OBERG (BAR NO. 120139)
CAMILLE K. FONG (BAR NO. 113123)
2 | REBECCA L. WOODSON (BAR NO. 194191) ELECTRONICALLY
McKENNA LONG & ALDRIDGE LLP FILED
3 4 101 California Strect Superior Court of California,
41" Bloor County of San Francisco
4 | San Francisco, CA 94111
Telephone: (415) 267-4000 MAR 28 2007
st GORDON PARK-LI, Clerk
5 | Facsimile: (415) 267-4198 BY: RAYMOND K. WONG
Deputy Clerk
6 | Attorneys for Defendant
METALCLAD INSULATION CORPORATION
7
8 SUPERIOR COURT GF THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
0
1 | NANCY MARIE SCOTT, et al., ; CASENO, 443236
2 Plaintiffs, EXHIBITS G M IN SUPPORT OF THE
DECLARATION OF REBECCA L.
3 Vv. WOODSON IN SUPPORT OF
DEFENDANT METALCLAD
[4 | AC and S, INC., et al., INSULATION COGRPORATION’S
MOTION FOR SUMMARY JUDGMENT
5 Defendants. OR IN THE ALTERNATIVE, SUMMARY
ADJUDICATION OF ISSUES
16
[Filed concurrently with Notice of Motion,
17 Memorandum of Points and Authorities,
Separate Statement of Undisputed Facts.,
18 Exhibits and [Proposed] Order]
19 DATE: June 15, 2007
TIME: 9:30 am.
21) Dept.: 302
JUDGE: Honorable Patrick J. Mahoney
21
TRIAL DATE: July 16, 2007
22
23
24
25
26
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MeReNNA rong & EXHIBITS G M IN SUPPORT OF THE DECLARATION OF REBECCA L. WOODSON IN SUPPORT OF DEFENDANT METALCLAD
ATTORNEYS AT LAW INSULATION CORPORATION'S MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
SAN FRAKCISCO
SF:2723 8526.1EXHIBIT Got
STEVEN M. HAROWITZ (Bar No. 71117)
STEPHEN M. TIGERMAN (Bar No. 112127)
MI
AFR PERUZZI (Bar No. 199659)
HAROWITZ & TIGERMAN, LLP
450 Sansome Street, 3° Floor
San Francisco, California 94111
Telephone (415) 788-1588
Facsimile (415) 788-1598
Attorneys for PLAINTIFFS.
SUPFRIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
NANCY MARIE SCOTT, Indivi
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST
DOE through TENTH DOE, inclusive,
Plaintiffs,
vs
AC AND S, INC., etal.,
Defendants.
No. 05-443236
PLAINTIFF NANCY SCOTT’S ANSWERS:
TO DEFENDANTS’ STANDARD
INTERROGATORIES TO HEIR OF
DECEDENT
(Wrongful Death)
Comes now plaintiff NANCY SCOTT and responds as follows to Defendants! Standard
Interrogatories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only
just begun discovery in this case and that discovery is continuing with respect to each interrogatory
and sub-interrogatory. In addition, plaintiff respectfully objects to each interrogatory and
sub-interrogatory insofar as it calls for privileged work product or privileged atlomey-client
communication. Without waiving these objections, plaintiff responds as follows:
i. A. Nancy Matie Scott,
B. Daughter.
c
1/goL23.wa heir. azacy
383 Wintergreen Drive, Brentwood, CA 94513.20
D, Not applicable.
Not applicable.
Not applicable.
‘Not applicable,
No.
Yes. Decedent was previously married to Mary Scott. Decedent, Denzil Scott and Mary
Scott were married on August 4, 1943, Their martiage was terminated as a result of
Mary’s death on May 23, 1991. Denzil Scott and Mary Scott had seven natural children:
Joanne Marie Wolfarth, 61 years of age; Michael Gerald Scott, 59 years of age; Robert
David Scott, 58 years of age; Thomas Cary Scott, 54 years of age; Nancy Marie Scott, 48
yours of age: Mary Denise Soboli, 41 years of age; Stephon Dennis Soot ~ deceased since
Not applicable.
No.
Not applicable.
No.
Not applicable.
Duggan’s Serra Mortuary, 500 Westlake Avenue, Daly City, CA 94014
Decedent was buried on January 26, 2005 at Holy Cross Cemetary, in Colma, California.
No.
Please sce attached.
Not applicable.
No.
(1) Employer's Name: Fred Harvey, Ine.
ss: 1380 Bayshore Highway, Burlingame, CA.
He: Sales Clerk
Date Started: May 1975; May 1976.
Date Ended: September 1975: September 1976.
(2) Employer's Name: Michael A. Maddalena, M.D.
Address: 1750 E] Camino Real, Burlingame, CA.
Job title: Receptionist.
1 /go129.wd heir nancy@)
@)
6)
©
”
(8)
9)
(10)
21. Yes.
A
Date Started: January 197,
Date Ended: May 1977
Employer's Name: Richard F, Moedt, DDS.
Address: 450 Sutter Street, #704, San Francisco, CA.
Job title: Office Manager/Dental Assistant.
Date Started: February 1981.
Date Ended: December 1989.
Employer's Name: Douglas W. Crawford, DDS.
Address: 841 San Brano Avenue, San Bruno, CA.
Job title: Front Office Manager.
Date Started: December 1992.
Date Ended: June 1993,
Employcr's Name: Robert Stieg, DDS.
Addiess: 450 Sutter Street, #1414, San Francisco, CA.
Job title: Back Office Assistant.
Date Started: September 1993.
Date Ended: May 1994
Employer’s Name: Douglas Morrison, DDS.
Address: 1300 University Drive, #3, Menlo Park, CA.
Job title: Front Office Manager
Date Started: September 1994.
Date Ended: September 1994.
Employer's Name: Poplar Recare.
Address: 1764 Marco Polo Way, Burlingame, CA.
Job title: Case Manager/Special Service Manager.
Date Started: February 1995.
Date Ended: September 1997.
ancy M, Scott, MP.T.
Mateo Dr., Ste. G, San Mateo, CA.
Employer's Nam
Date Started “antary 1998,
Date Ended; May 2600.
Employer’s Name: Maltin/Plack Group,
Address: 810 Stanton Road, Burlingame, CA.
Job title: Data Entry Clerk
Date Started: 1999.
Date Ended: February 2000.
Employer’s Name: Regional Center of the East Bay.
Address: 2151 Salvio Street, #368, Concord, CA.
Job title: Case Manager.
Date Started: Febraary 2000.
Date Linded: Presently employed,
No.
1/go128.wd- heir. nancy26
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22.
23.
24.
25.
26.
27.
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29.
30.
31.
B, The trustee of the trust i
CA 94513.
©. Not applicabie.
D. Not applicable.
ancy Marie Scott, 383 Wintergreen Drive, Brentwood,
No.
Decedent’s daughter, Nancy Scott, resided with him during the last twelve months of his
life, Nancy Scott continues to reside at this residence.
During the last five years of decedent’s life, his children provided a significant amount of
emotional support and, as he did not drive, they accompanied him to his doctor
appointments and other errands as needed.
During the last ten years of decedem’s fife, decedent continually contributed financial
support to his grandchildren and great grandchildren’ s college funds.
During his lifetime, decedent was very generous in his support of various charities. In
2004 alone, decedent contributed to many charities in the amount of approximately
$2,500.00. In addition, decedent contributed money on a regular basis to his church.
No.
Prior to decedent’s death, decedent enjoyed assisting in the care of his grandchildren
Yes.
A. The reasonable value of one’s loss of the care, guidance, advice, counsel, training,
protection, society, comfort and companionship of a very close and loving father.
B. Not applicable.
C. My father’s love, care, guidance, advice, counsel, training, protection, society,
comfort, and companionship is invaluable and cannot be replaced, My father
enjoyed life and was a very productive citizen and much to sharc in thic way of
wisdom and knowledge. My father was a Pear! Harbor survivor, and was a veleran
of World War Il and the Kotean War. fle lived through the great depression, grew
up on a farm, and dedicated twenty years of his life to the U.S. Navy. He helped
my mom raise us seven children and helped care for his grandchildren, He was
intelligent and interested in so much of life. His wisdom, life experience, love of
life and his family is priceless, 1 truly miss my father
My father and I enjoyed spending time together and enjoyed various interests together.
We enjoyed traveling; photography; genealogy; coin collecting; gardening; watching sports
together; listening to music together; going to museums; watching television and movies
together. We both shared a love of E’gyptian art, culture, and life. We enjoyed having long
discussions about health issues, envizonmental issues, nature, and science. We liked
tinkering with small fix-it jobs around the house together. My Sather and I spent a lot of
time together, sharing many different hobbies and interests. I miss not being able to share
this time with may father anymore
32. I lived with my father during the last five years of his life. With the exception of time I
spent at work (32 hours per week), and being away to run errands and/or while attending
social events, my father and I shared a lot of time together.
4.20
38.
Dated: Petey 2006
No.
Not applicable.
Yes.
No.
No one other than my attorneys al Harowitz & Tigerman, LLP.
Not applicable.
HAROWITZ & TIG
‘MAN, LLP
7 /gol28.wd.-heir. nancy0
7 /go128.wa heir, zancy
VERIFICATION TO FOLLOWVERIFICATION
I, NANCY SCOTT, declare that:
1am the plaintii' named in the foregoing action; that [have read the foregoing
PLAINTIEE’S ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIR
OF DECENT (‘Wrongful Death), and know the contents thereof, the same is true of my own
knowledge, except as to those matters therein stated on information and belief, and as to those
matters I believe it to be tue.
I declare under penalty of perjury under the faws of the State of California that the
foregoing is true and correct and that this verification was executed jn Brentwood, CA on this
23_ day of _ MAX ___, 2006
Naaty(Sco}
2067/verif-go129.heir.wd.nancyEXHIBIT H26
28
20)
STEVEN M. HAROWITZ (Bar No, 71117)
STEPHEN M. TIGERMAN (Bar No. 112127)
MIA MATTIS (Bar No. 191027)
JENNIFER PERUZZI (Bar No. 199659)
HAROWITZ & TIGERMAN, LLP
450 Sansome Street, 3" Floor
San Francisco, California 94111
Telephone (415) 788-1588
Facsimile (415) 788-1598
Atiomeys for PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
NANCY MARIE SCOT, Individually and | No, 05-443236
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH; | PLAINTIFF MICHAEL SCOTT’S
MICHAEL GERALD SCOTT; ROBERT ANSWERS TO DEFENDANTS"
DAVID SCOTT; THOMAS CARY SCOTT; | STANDARD INTERROGATORIES TO
MARY DENISE SOBOLIK; and FIRST HEIR OF DECEDENT
DOE through TENTH DOE, inclusive,
(Wrongful Death)
Plaintiffs,
vs.
AC AND S, INC, etal,
Defendants,
Comes now plaintiff MICHAEL SCOTT and responds as follows to Defendants! Standard
Interrogatories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only
Just begun discovery in this case and that discovery is continuing with respect to cach interrogatory
and sub-interrogatory. In addition, plaintiff respectfully objects to cach
sub-interrogatory insofar as it calls for privileged work p
communication. Without waiving these objections, plain!
responds as follows:
1 A. Michael Gerald Scott,
B. Son.
C. 2860 Evergreen Drive, San Bruao, CA 94066.1/90
Dz Yes.
Not appticable.
‘Not applicable.
‘Not applicable.
Yes, Plaintiff was previously married to Kathleen Louise Allen from 1969-1991. During
the course of this marriage, they had three children: Jennifer Anne Scott, 33 years of age;
Dianna Denise Scott, 31 years of age; Laura Carey Scott, 30 years of age,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this sct of responses, and thus equally available to defendants.
‘Not applicable.
No.
Not applicable.
No.
Not applicable.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendant
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Deecdent (\Wzongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintiff refers defeadants (o Plaintiff Naney Maric Scott’s Answers to Deferslant’s
Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concustontly with
this set of responses, and thus equally available to defendants,
‘Not applicable,
No.
(1) Employer's Name: Lucky Chances Casino.
‘Aduress: 1700 Hillside Blvd., Colma, CA 94014,
Job title: Security and Facility Operations Manager,
Date Stated: Octoher 13, 2003
Date Bnded: Currently cmployed,
-2-
29.wd-heir.michael20
24.
26.
36,
31
(2) Employer's Name: City of Daly City.
Address: Daly City, CA.
Job fitle: Police Officer.
Date Started: November 16, 1971.
Date Ended: October 10, 2003
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
No,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concurrently with
this sct of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this sot of responses, and thus equally available to defendants
No.
Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
this sot of responses, and thus equally available to defendants.
Yes,
A. The reasonable value of one's loss of the care, guidance, advice, counsel, training,
protection, society, comfort and companionship of a very close and loving father.
B. Not applicable.
C. My father’s love, care, guidance, advice, counsel, training, protection, society,
comfort, and companionship is invaluable and cannot be replaced. 1 truly miss my
father.
My father was an avid hunter and fisherman and taught me how to hunt and fish. We
belonged to a duck club together and enjoyed duck hunting and fishing together every year
until he was unable to walk without oxygen. This time we shared together was very
special, My dad was a wealth of infonination. Whenever | had a question about anything,
my dad would give advice and help and assist where he was able. My dad was a wonderful
role mode]. His knowledge was a vonderful learning tool. We loved sharing time together
asa family. My dad was-very involved in his grandchildren’s life. Ie attended all of their
school activities, sporting events, auc truly enjoyed being a Grandpa, My children miss
71/90129 wa heir michae)32.
33.
34.
35.
36.
37.
38.
Dated: very 0
him dearly as well. My father was an exceptional person,
When my father lived in Daly City, I visited with him daily, When my father moved to
Brentwood, I spent time with him on the weekends, epproximately every other month, |
also spoke with him on the telephone every couple of days. Asa family, we also spent
lime together during hotidays and birthday cclebrations.
No.
Not applicable.
No.
My dad worked around various asbestos-containing products while working in the
shipyards. 1 also recall ry dad performed some home remodel work, sometime between
1956-1958, on our family home that was located at 672 Orange Street, Daly City, CA. 1
recall my dad transforming the downstairs basement into a bedroom forme. | recall ay
dad did alf the work associated with this remodel including, but not limited ta, the framing,
sheetrock, and electrical work. Plaintif!’s investigation and discovery are continuing,
No one other than my attorneys at Harowitz & Tigerman, LLP.
‘Not applicable,
HAROWIIZ & TIGERMAN, LLP
F IZZ1
Attorneys for, PAINT IFF}
7 /go129. wd heir michael7/go129.wd. heir-pichael
VERIFICATION TO FOLLOWEXHIBIT I26
28
2d
STEVEN M. HAROWITZ (Bar No. 71117)
STEPHEN M. TIGERMAN (Bar No. 112127)
MIA MATTIS Gar No, 191027)
JENNIFER PERUZZI (Bar No, 199659}
HAROWTIZ & TEGERMAN, LLP
450 Sansome Steet, 3” Fluor
San Francisco, California 94211
Telephone (415) 788-1588
Facsimile (415) 788-1598
Attorneys for PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA.
COUNTY OF SAN PRANCISCO,
NANCY MARIE SCOTT, Individually and
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;,
MICHAEL GERALD SCOTT: ROBERT.
DAVID SCOTT: THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST
DOE through TENTH DOE, inchusive,
Plaintifis,
vs.
AC AND S, INC, et al.,
Defendants,
Comes now plaintiff ROBERT SCOTT and responds as follows to Defendants’ Standard
Interrogatories to Heir and/or Legal Representative of Decedent, Please not
ery is continuing with respect to each interrogatory
tion, plaintiff respectfully objects to cach interrogatory and
case and that discov
just begun discovery in
and sub-interrogatory. In ad
No. 05-443236
PLAINTIFF ROBERT SCOTT'S
ANSWERS TO DEFENDANTS’
STANDARD INTERROGATORIES TO.
HEIR OF DECEDENT
(Wrongful Death)
sub-interrogatory insofar as itealls for privileged work product or privileged attorney-client
communication. Without waiving these objections, plaintiff responds as follows:
1. A. Robert David Scott.
B. Son.
C, 518 Joaquin Avenue, San Tcandre, CA 94877,
11/go128 .wd.heir. robert
fe that plaintiff has only26
28
20
D. —_Notapplicable.
Not applicable.
‘Not applicable.
Not applicable,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of sesponses, and thus equally available to defendants.
Not applicable.
No.
Not applicable,
No.
Not applicable.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
this set of responses, and (hus equally available to defendants.
No.
Plaintiff refers defendants to Plainti{T Nancy Maciv Scott’s Answers to Defendant's
Standard Interrogatories to Iicirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
Not applicable.
(1) Employer's Name: Livermore Valley Joint Unified School District.
Address: 685 East Jack London Boulevard, Livermore, CA 94550.
Job title: Science Teacher.
Date Started: August 1974
Date Ended: Currently employed.
1/g0129.d heir. xobert20
21
22.
23.
24.
25.
26.
27.
28.
29.
30.
31
32.
33,
Plaintiffrefers defendants (0 Plaintiff Nancy Marie Scott’s Answers 10 Defendant's
Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concurrently with
‘his sct of responses, and thus equally available to defendants.
No.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
{his set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Jnterrogatories to Heirs of Devedent (Wrongtiul Death) served concurrently with
this sct of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Ilcirs of Deeedent (Wrongful Death) served concurently with
this set of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Seolt’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Yes.
A. The reasonable value of one's loss of the care, guidance, advice, counsel, training,
protection, society, comfort and companionship of a very close and loving father.
B. —_Notapplicable.
C. The loss of my father’s care, guidance, advice, counsel, iraining, protection, soviety,
comfort, and companionship is priccless. The last years of my father’s life were not
what he or his family wanted. His decreasing hcalih resulted in a slowing down
and eventual cessation of most oF his hobbies and household chores, He could not
go on family vacations or when he did, during this period, they were cut short due
to his failing health. Much to his frustration, during the last six ycars of his life, he
couldn't participate in the physical work of gardening. This was something we
enjoyed very much and this was very difficult. I really miss my dad,
My dad and I raised several breeds of pheasants and ducks when I lived at home in Daly
City. We spent time together trout fishing and Lake Merced and in the Sierras. Dad and I
shared a love of gardening, especially vegetable gardening. 1 would prunc his ituit trees
and help him procure and plant vatious vegetable seedlings. My father was a parent,
mentor, and companion.
During the last five years of his life, | spent several hours with him on the weekends and
during summer vacations.
No.
7 /gol29.wd heir. robert34. Not applicable.
35. No.
36. recall my dad performed some constuction work on our family home, located at 672
‘Orange Street, Daly City, California. My dad also worked with ashestos-containing
materials during his employment. Plaintiff's investigation and discovery are continuing,
37. Noone other than my attorneys at Harowitz & Tigerman, LLP.
38. Not applicable.
Dated: Februapg/ 7, 2004
7 HAROWITZ & TIGERMAN, LLP
by,
me
FER PERI
Attorneys for PLAINTIFFS:
aol
67 /go129. wd, hoix robert7 /40129.Wd- heir. robert
VERIFICATION TO FOLLOWYE 101
3, ROBERT SCOTT, declare that;
Iam the plaintiff named in the foregoing action; that I have read the foregoing
PLAINTIFFS ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIK
OF DECENT (Wrongful Death), and know the contents thereof; the same is truc of my own
knowledge, except as to those matters therein stated on information and belief, and as to those
matters I believe it to be true.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is trne and correct and that this ver!
Tsay ot Lerch _, 2006.
tion was executed in San Leandro, CA on this
Gee Lhe.
Robert Scott
206 Hiverif 0129 heir wi sobertEXHIBIT J=N M. HAROWITZ. (Bar No. 71117)
BPUEN M. GERMAN (Bar No. 112127}
MIA MATTIS (Bar No. 191027),
JENNIFER PERUZZI (Bar No. 199659)
3. | HAROWITZ & TIGERMAN, LLP
450 Sansome Street, 3 Floor
4 | San Francisco, Calizornia 94113
Telephone (415) 788-1588
5 | Facsimile (415) 788-1598
6
Attorneys for PLAINTIFFS
>
8
9
10 SUPERIOR COURT OF CALIFORNIA
an COUNTY OF SAN FRANCISCO
2
22 | NANCY MARIE SCOTT, Individually and | No. 05-443236
aa | asSucei Interest to DENZIL.
Decedent; JOANNE MARIE WOLFARTH;
ig | MICHAEL GERALD SCOTT; ROBERT
DAVID SCO1 THOMAS CA RY SCOTT; | 5
16 MARY DENISE SOBOLIK; and FIRST HEIR OF DECE)
DOE through TENTH DOE, inclusive,
1 | (Wrongful Death)
Plaintiffs,
16
vs.
19 .
AC AND S, INC. et al.,
20 Defendants.
at _
22
Comes now plaintiff TEOMAS SCO1T and responds as follows 10 Defendants Standard
23. | Interrogatories to Heir and/or Legal Repre: te that plainsiff has only
° and that discovery is continuing with respect fo each interrogatory
plaintiff respectfully o'
sub-interrogatory ingofar as it calis for pri
a5 | communication. Without waiving these ol
a6 | 1 A Thomas Caty Scott
28 C. 1241 W. Ghost Piace, Tucson, Arizona 85737,
2061/go129.wd.heir. thomas6.
20!
Dd. Yes.
Not applicable,
‘Not applicable.
Not applicable.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available te defendants.
Not applicable.
No.
‘Not applicable,
No,
Not applicable.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
ihis set of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Naney Marie Scott's Answers fo Defenda
Standard interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
this set of responses, and thus equally available to defendants,
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendant's
Standard Interrogatories t) Heirs of Decedent (Wrongful Death) served concusreatly with
this set of responses, and thus equally available te defendants,
Not applicable.
No.
No.
Yes,
(1) Employer's Name: Sam Levit Furniture.
Address: 3750 West Orange Grove, Marana, Arizona 85741,
Job title: Manage:.
Date Started: 1993.
Date Ended: Currently employ
‘ture,
Q) Employer's Name: Levitz Fun
26
B1/g0l29.wd.hoix. Ehoaasad
a
25.
26.
27.
Hh /goi29.wd-beie
Address: Nevada.
Job ttle: Manager.
Date Started: 1999,
Date Ended: 1992.
(3) Employer's Name: Furnishings 2000.
céress: San Diego, California.
Job title: Manag
Date Started: 1985.
Date Ended: 1990.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equal!y available to defendants.
s
tly with
Plaintiff refers defendants to Plaintiff’ Nancy Marie Scott’s Answers to Defend:
Standard foterrogatories to Heirs of Decedent (Wrongful Death) served concur
this set of responses, and thus equally available to defendants.
Plaintiff re‘ers defendants to Plaintiff Naney Mat
Standard Interrogatories to Heirs of Decedent (W.
this set of responses, and thus equally available to
Scott's Answers to Defendant's
ved concurrently with
Plaintiff refers defendants to Plaintiff’ Nancy Marie Scolt’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrong Death) served concurrently with
s set of responses, and hus equally available to defendants.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Ioterrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Yes.
A. The reasonable vaiue of one's loss of the care, guidance, advice, counsel, trainin:
protection, society, comfort and companionship of a very close and lovi
B, _Notapplicable.
C, My father’s love, care, guidance, advice, counsel, training, protection, society,
comfort, and companionship is invaluable and cannot be replaced. I really miss my
father,
My father and | enjoyed spending time logether hunting and fishing. We also toved
‘watching football and baseball pames. We shared an enjoyment for watching war movies
together as well. We all eejoyed spending our family time together.20
1) qok2S.ud.heir. the
‘As my father and I resided in different states, I would visit with my
two times per year, for three to four days each visti.
father on average about
No,
Not applicable.
No,
No.
No one other than my attorneys Harowitz & Tigerman, LLP.
Not applicable.
f
2006
HAROWIFZ & TIGERMAN, LLP1/qei29.wd. heir
oma
VERIFICATION TO FOLLOW1, THOMAS SCOTT, declare Laat:
named in the foregoing action; that I have read the foregoing
DANTS’ STANDARD INTERROGATORIES TO HEIR
ENT (Wrongfial Death), and know the contents thereof; the same is érue of my own
knowledge, except as to those matters therein stated on information and belief, and as to those
matters { believe it to be true.
i declare under penalty of perjury under he laws of the State of California that the
foregoing is true and correct and that this verification was executed in Tucson, AZ on this_“7 “x
day of MARCH _, 2006
‘206 veri g0129-heit-wd thomasEXHIBIT kKSTEVEN M. HAROWITZ (Bar No. 71117)
STEPHEN M. TIGERMAN (Bar No. 112127)
MIA MATTIS (Bar No. 191027)
JENNIFER PERUZZI (Bar No, 199659}
HAROWITZ & TIGERMAN, LLP
450 Sansome Street, 3" Floor.
San Francisco, California 94411
Telephone (415) 788-1588
Facsimile (415) 788-1598
Attorneys for PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
NANCY MARIE SCOTT, Individually and
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT.
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST
DOE through ‘TENTH DOE, inclusive,
Plaintiffs,
vs.
AC AND S, INC, etal.,
Defendants.
No, 05-443236
PLAINTIFF MARY SOBOLIK’S
ANSWERS TO DEFENDANT
STANDARD INTERROGATORIES TO
HEIR OF DECEDENT
(Wrongful Death)
Comes now plaintiff MARY SOBOLIK and responds as follows to Defendants’ Standard
20
Interrogatories to Heir and/or Legal Representative of Decedent, Please note that plaintiff has only
just begun discovery in this case and that discovery is continuing with respect to cach interrogator
and sub-interrogatory. In addition, plaintiff respectfully objects to cach interrogatory and
sub-interrogatory insofar as it calfs for privileged work product or privileged attorney-client
communication. Without waiving these objections, plaintiff responds as follows:
1, A. Mary Denise Sobolik.
8. Danghter.
C. 369 Wintergreen Drive, Brentwood, CA,
11/9029 we heir mary1
242
3 13.
ada
5 ps.
6 | 6.
7
a | 7.
oF &
ao | 9.
12 | 10.
12 fil
13 | 12.
14
1s | 13.
16
ay p14.
1g | 1S.
19
20 | 16.
au | 17.
22 | 18.
23 | 19.
24 | 20.
as | ai.
26
28 | 22.
20)
D. Yes.
Not applicable.
Not applicable,
Not applicable.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this sot of responses, and thus equally available to defendants.
Not applicable.
No.
Not applicable,
No.
Not applicable
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No,
Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendant’
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concunently with
this set of responses, and thus equally available to delendants.
Not applicable,
No.
Not applicable.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
wd.heizemary0
26.
27.
28.
29.
30.
31
32.
No
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heits of Decedent (Wrongful Death) served concurently with
this sct of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintif’ Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories (o Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
No,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent {Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Yes.
A. ‘The reasonable value of one’s loss of the care, guidance, advice, counsel, training,
protection, society, comfort and companionship of a very close and Joving father,
B. Not applicable.
C. The loss of my father's care, guidance, advice, counsel, training, protection, society,
comfort, and companionship is invaluable and can not be replaced. If'my father had
not been exposed to asbestos in his younger years, he would have had a longer and
more fulfilling life. The quality and length of his life was greatly affected by his
ness. My family and I could have shared more quality time with him instead of
witnessing him experience his decline. My father was an integral part of our lives
ona daily besis. Words cannot adcquately describe the void that has been left and
the hurt knowing my children, will not get the opportunity to know and experience a
further relationship with their grandfather. Unfortunately, my daughter Lauren,
never got to experience any relationship with him before his death.
My father and I enjoyed spending time together doing many different types of things
including, but not limited to, gardening; stamp collecting; picking fresh fruit at local farms;
feeding quail; listening to music; reading books and magazines and having discussions
about what we read; watching baseball and football; fishing; and boating. We enjoyed
“friday Family Fun Night” where we all played games together. We enjoyed watching
lrish dancing and videos of different countries and cultures. We enjoyed sharing meals
together, grocery shopping, baking pics, taking car rides together, spending time with the
entire family, watching historical and educational programming together. Hc loved
spending time with his grandchildren, playing with thom and teaching them new things. He
taught my daughter Emily fo write the alphabet. My dad and T were happy to sit and just
talk with each other. Treadly miss my dad.
‘On average, I spent approxitnately two hours per day with my Gaher.
7 /g0129.wd.heir.ma=)20)
33. No.
34. Not applicable.
33. No.
36. No
37. No one other than my attorneys at Harowitz & Tigerman, LLP.
Not applicable.
Dated: February 7, 2006
HAROWIIZ & TIGERMAN, LLP
by.
fENNIFER PERU
Attorneys for PLAINTIFFS
1/go129.wd heir mazyot
VERIFICATION TO FOLLOW
1/g0229.wd-beir maryEXHIBIT LSTEVEN M. HAROWITZ (Bar No. 71117)
STEPHEN M. TIGERMAN (Bar No, 112127)
MIA MATTIS Bar No. 191027)
JENNIFER PERUZZI (Bar No. 199659)
HAROWITZ & TIGERMAN, LLP
450 Sansome Steet, 3° Floor
San Francisco, California 94111
Telephone (415) 788-1588
Facsimile (415) 788-1598
Attorneys for PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA,
COUNTY OF SAN FRANCISCO,
NANCY MARIE SCOTT, Individually and | No. 05-443236
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH; | PLAINTIFF JOANNE WOLFARTH’S
MICHAEL GERALD SCOTT; ROBERT "| ANSWERS TO DEFENDANTS’
DAVID SCOTT; THOMAS CARY SCOTT:
MARY DENISE SOBOLKK; and FIRST
DOE through TENTH DOE, inclusive,
(Wrongful Death)
Plaintiffs,
vs.
AC AND §, INC., etal,
Defendants.
Comes now plaintiff JOANNE WOLFARTH and responds as follows to Defendants!
Standard Interrogutories to Heir and/or Legal Representative of Decedent. Please note that
plaintiff has only just begun discovery in this case and that discovery is continuing with te
cach interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to each
interrogatory and sub-interrogatory insofar as it calls for privileged work product or privileged
attomey-client communication. Without waiving these objections, plaintiff responds as follows:
1. A, Joanne Marie Wolfarth.
B. Daughter.
C. 2639 Sivererest Stecet, Pinole,
7 /goL29.wd.hesx. joanne2d
D. Yes.
Not applicable,
‘Not applicable,
‘Not applicable.
Plaintiff refers defendants to Plaintiff Naney Marie Soott’s Answers to Defendant's
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Nancy Marie Soott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with
this set of responses, and thus equally available to defendants.
Not applicable.
Ne.
Not applicable.
No.
Not applicable.
Plaintiff refers defendants to Plaintiff’ Nancy Marie Scott's Answers to Defendant’s
Standard Interrogatorics to Heirs of Devedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintif{ Nancy Marie Scott's Answers to Defendant’s
Standard interrogatories to Heizs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendaut’s
Standard Interrogatories to ileirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equaily available to defendants,
Not applicable.
No.
(1) Eigployer’s Nawye: Pewoo Consulting.
: 2639 Silvercrest Street, Pinole, CA,
fob tue Sole Proprietor.
Date Started: January 1, 2003.
Date Ended: Presently employed,
:1/g0129.wd.hesz. joanne21.
23
24
26.
27.
28.
29.
30.
31
Plaintiff refers defendants {o Plaintiff Nancy Marie Soott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
No.
No,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defondant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Deatl)} served concmrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Yes.
A. The reasonable value of one's ioss of the care, guidance, advice, counsel, training,
protection, soviety, comfort and companionship of a very close and loving father.
B. Not applicabic.
C. ‘The loss of my father’s care, guidance, advice, counsel, (raining, protection, society,
comfort, and companionship is invaluable and can not be replaced, My father took
very good care of himself. He wanted to five. He loved his family and wanted fo
be with us for as fong as possible. 1 truly miss sharing all of the special time I
shared with my father. 1 miss him dearly.
My father and I collected stamps together for years. His earlier years in the Navy really
encouraged our collecting stamps from all over the world and our love of history and
geography. I started a stamp collecting club in my school and he supported thei by
writing letters from his overseas ports. We loved to talk about history, and geography,
World War ll, and I continued to lear ftom his expansive knowledge until he died. We
loved to disouss genealogy and his family who lived in the midwest. My father loved every
type of music. We shared CD's and listened to the music together. We loved to watch old
movies and videos, especially “I Love Lucy” and “Dean Martin Roasts.” I remember that
we would laugh and erp, but mostly laughed until we couldn’t laugh anymore, My father
loved to garden and we would “admire” his produce and share recipies and ideas on how to
put them fo the best use possible. My dad would cook and loved to cook pics. In his
earlier years, he hunted, fished, and went abalone diving. We loved the way te prepared
and cooked the abalone. My dad foved to sign and when I told hitn he sounded like Bing
7/g0129.wd-haix. joanneaol
32.
38.
Dated: reorancf 2006
Crosby, he wouldn't stop. Since my father has died, I can not believe the questi
want fo ask him about history and its relation to current events; there are special recipes
that I have just made and how I want himn to cover over and share them; family questions
that | have Forgotten; and just plain talking and laughing about life. I truly miss my dad.
I visited with my dad on a weekly basis until my husband and J started our home busines
‘Thereafier, I visited with my dad as often as possible and spoke with him on the telepho
every other day. When he was ill, I spoke to him daily on the telephone.
No.
Not applicable
No,
No.
‘No one other than my attorneys at Harowitz & Tigessian, LLP
Not applicable,
HAROWITZ & TIGERMAN, LLP
JENNIFER PERUZZI
Attorneys fo PLAINTIFFS
7/go129.wa.heix. joanne20!
7 /g0129.wd.heiy. joanne
VERIFICATION TO FOLLOWEXHIBIT MSTEVEN M. HAROWITZ, (Bar No. 71117)
STEPHEN M. TIGERMAN (Bar No. 112127)
MIA MATTIS (Bar No. 191027)
JENNIFER PERUZZI (Bar No. 199659)
HAROWIIZ & TIGERMAN, LLP
450 Sansome Street, 3" Floor
San Francisco, California 94111
Telephone (415) 788-1588
Facsimile (415) 788-1598
Attorneys for PLAINTIFFS
SUPERIOR COURT OF CALIFORNIA.
COUNTY OF SAN FRANCISCO
“
NANCY MARIE SCOTT, Individually and
as Successor-in-Interest to DENZIL SCOTT,
Decedent; JOANNE MARIE WOLFARTH;
MICHAEL GERALD SCOTT; ROBERT
DAVID SCOTT; THOMAS CARY SCOTT;
MARY DENISE SOBOLIK; and FIRST
DOE through TENTH DOE, inclusive,
No. 05-443236
PLAINTIFF JOANNE WOLFARTH’S
VERIFIED AMENDED AND
SUPPLEMENTAL ANSWERS TO.
DEFENDANTS' STANDARD
INTERROGATORIES TO HEIR OF
DECEDENT
20
Plaintifis,
(Wrongful Death)
¥s.
AC AND S, INC., etal.,
Defendants.
Comes now plaintiff JOANNE WOLFARTH and responds as follows to Defendants’
Standard Interrogatories to Heir and/or Legal Representative of Decedent. Please note that
plaintiff has only just begun discovery in this case and that discovery-is continuing with respect to
each interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to each
interrogatory and sub-interrogatory insofar as it calls for privileged work product or privileged
attomey-client communication. Without waiving these objections, plaintiff responds as follows:
1. A. Joanne Marie Wolfarth..
B. Daughter,
C. 2639 Sivercrest Street, Pinole, CA 94564.
7/g0129.wd. heir. joanne20
D. Yes.
Not applicabic.
Not applicable.
Not applicable.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
‘Not applicable.
No.
Not applicable.
No.
Not applicable,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintigf refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Not applicable.
No.
Name: Paweo Consulting.
2639 Silvercrest Street, Pinole, CA.
Sole Proprietor.
Date Started: January 1, 2003.
Date Ended: Presently employed.26
28
2a
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants,
No.
No.
Plaintiff refers defendants fo Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongfiil Death) served concurrently with
this set of responses, and thus equally available to defendants,
Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiftrefers defendants to Plaintiff Nancy Maric Scolt’s Answers to Defondant’s
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant’s
Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
No.
Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's
Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with
this set of responses, and thus equally available to defendants.
Yes,
A, The reasonable value of one's loss of the care, guidance, advice, counsel, training,
protection, society, comfort and companionship of a very close and loving father,
B. Not applicable,
C. The loss of my father’s care, guidance, advice, counsel, training, protection, society,
comfort, and companionship is invaluable and can not be replaced. My father took
very good care of himself. He wanted to live. [le loved his family and wanted to
be with us for as long as possible. [ truly miss sharing all of the special time I
shared with my father. I miss him dearly.
My father and I collected stamps together for years. His earlier years in the Navy really
encouraged our collecting stamps from all over the world and our love of history and
geography. 1 started a stamp collecting club in my school and he supported them by
waiting letters from his overseas ports, We loved to talk about history, and geography,
World War II, and I continued to learn from his expansive knowledge until he died. We
loved to discuss genealogy and his family who lived in the midwest. My father loved every
type of music, We shared CWD’s and listened to the music together. We loved to watch old
movies and videos, especially “I Love Lucy” and “Dean Martin Roasls.” I remember that
we would laugh and cry, but mostly Jaughed unti} we coulds’t laugh anymore. My father
loved to garden and we would “admire” his produce and share recipies and ideas on how to
put them to the best use possible. My dad would cook and loved to bake pies, In his
earlier years, he hunted, fished, and went abalone diving. We loved the way he prepared
and cooked the abalone. My dad loved to sing and when I told him he sounded like Bing
~3-
1/go123.wa. heir. soanneal
32.
33,
34.
35.
36.
37.
38.
Crosby, he wouldn't stop. Since my father hes died, I can not believe the questions that I
want to ask him about history and its relation to current events; there are special recipes
that I have just made and miss not being able to share them with him; family questions
that I have forgotten; and just plain talking and laughing about life. Twuly miss my dad.
I visited with my dad on a weekly basis until my husband and I started our home business
Thereafter, I visited with my dad as often as possible, sometimes staying days at a time
care for him, and spoke with him on the telephone every other day. When he was ill, I
spoke to him daily on the telephone, Watching my dad die from cancer was horrible,
but I treasured any time we were able to share together.
No.
Not applicable.
No.
No.
No one other than my attorneys at Harowitz & Tigerman, LLP.
Not applicable.
Dated: May %, 2006
HAROWITZ & TIGERMAN, LLP
7/go129.wd.heic-joanneVERIFICATION
I, JOANNE WOLFARTH, declare that.
1 am the plaintiff named in the foregoing action; that I have read the foregoing
PLAINTIFF'S AMENDED AND SUPPLEMENTAL ANSWERS TO DEFENDANTS’
STANDARD INTERROGATORIES TO HEIR OF DECENT (Wrongful Death), and know the
contents thereof; the same is true of my own knowledge, except as to those matters therein stated
on information an
Preview
1 } LISA L. OBERG (BAR NO. 120139) CAMILLE K. FONG (BAR NO. 113123) 2 | REBECCA L. WOODSON (BAR NO. 194191) ELECTRONICALLY McKENNA LONG & ALDRIDGE LLP FILED 3 4 101 California Strect Superior Court of California, 41" Bloor County of San Francisco 4 | San Francisco, CA 94111 Telephone: (415) 267-4000 MAR 28 2007 st GORDON PARK-LI, Clerk 5 | Facsimile: (415) 267-4198 BY: RAYMOND K. WONG Deputy Clerk 6 | Attorneys for Defendant METALCLAD INSULATION CORPORATION 7 8 SUPERIOR COURT GF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 0 1 | NANCY MARIE SCOTT, et al., ; CASENO, 443236 2 Plaintiffs, EXHIBITS G M IN SUPPORT OF THE DECLARATION OF REBECCA L. 3 Vv. WOODSON IN SUPPORT OF DEFENDANT METALCLAD [4 | AC and S, INC., et al., INSULATION COGRPORATION’S MOTION FOR SUMMARY JUDGMENT 5 Defendants. OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION OF ISSUES 16 [Filed concurrently with Notice of Motion, 17 Memorandum of Points and Authorities, Separate Statement of Undisputed Facts., 18 Exhibits and [Proposed] Order] 19 DATE: June 15, 2007 TIME: 9:30 am. 21) Dept.: 302 JUDGE: Honorable Patrick J. Mahoney 21 TRIAL DATE: July 16, 2007 22 23 24 25 26 27 28 MeReNNA rong & EXHIBITS G M IN SUPPORT OF THE DECLARATION OF REBECCA L. WOODSON IN SUPPORT OF DEFENDANT METALCLAD ATTORNEYS AT LAW INSULATION CORPORATION'S MOTION FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION SAN FRAKCISCO SF:2723 8526.1EXHIBIT Got STEVEN M. HAROWITZ (Bar No. 71117) STEPHEN M. TIGERMAN (Bar No. 112127) MI AFR PERUZZI (Bar No. 199659) HAROWITZ & TIGERMAN, LLP 450 Sansome Street, 3° Floor San Francisco, California 94111 Telephone (415) 788-1588 Facsimile (415) 788-1598 Attorneys for PLAINTIFFS. SUPFRIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO NANCY MARIE SCOTT, Indivi as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH; MICHAEL GERALD SCOTT; ROBERT DAVID SCOTT; THOMAS CARY SCOTT; MARY DENISE SOBOLIK; and FIRST DOE through TENTH DOE, inclusive, Plaintiffs, vs AC AND S, INC., etal., Defendants. No. 05-443236 PLAINTIFF NANCY SCOTT’S ANSWERS: TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIR OF DECEDENT (Wrongful Death) Comes now plaintiff NANCY SCOTT and responds as follows to Defendants! Standard Interrogatories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only just begun discovery in this case and that discovery is continuing with respect to each interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to each interrogatory and sub-interrogatory insofar as it calls for privileged work product or privileged atlomey-client communication. Without waiving these objections, plaintiff responds as follows: i. A. Nancy Matie Scott, B. Daughter. c 1/goL23.wa heir. azacy 383 Wintergreen Drive, Brentwood, CA 94513.20 D, Not applicable. Not applicable. Not applicable. ‘Not applicable, No. Yes. Decedent was previously married to Mary Scott. Decedent, Denzil Scott and Mary Scott were married on August 4, 1943, Their martiage was terminated as a result of Mary’s death on May 23, 1991. Denzil Scott and Mary Scott had seven natural children: Joanne Marie Wolfarth, 61 years of age; Michael Gerald Scott, 59 years of age; Robert David Scott, 58 years of age; Thomas Cary Scott, 54 years of age; Nancy Marie Scott, 48 yours of age: Mary Denise Soboli, 41 years of age; Stephon Dennis Soot ~ deceased since Not applicable. No. Not applicable. No. Not applicable. Duggan’s Serra Mortuary, 500 Westlake Avenue, Daly City, CA 94014 Decedent was buried on January 26, 2005 at Holy Cross Cemetary, in Colma, California. No. Please sce attached. Not applicable. No. (1) Employer's Name: Fred Harvey, Ine. ss: 1380 Bayshore Highway, Burlingame, CA. He: Sales Clerk Date Started: May 1975; May 1976. Date Ended: September 1975: September 1976. (2) Employer's Name: Michael A. Maddalena, M.D. Address: 1750 E] Camino Real, Burlingame, CA. Job title: Receptionist. 1 /go129.wd heir nancy@) @) 6) © ” (8) 9) (10) 21. Yes. A Date Started: January 197, Date Ended: May 1977 Employer's Name: Richard F, Moedt, DDS. Address: 450 Sutter Street, #704, San Francisco, CA. Job title: Office Manager/Dental Assistant. Date Started: February 1981. Date Ended: December 1989. Employer's Name: Douglas W. Crawford, DDS. Address: 841 San Brano Avenue, San Bruno, CA. Job title: Front Office Manager. Date Started: December 1992. Date Ended: June 1993, Employcr's Name: Robert Stieg, DDS. Addiess: 450 Sutter Street, #1414, San Francisco, CA. Job title: Back Office Assistant. Date Started: September 1993. Date Ended: May 1994 Employer’s Name: Douglas Morrison, DDS. Address: 1300 University Drive, #3, Menlo Park, CA. Job title: Front Office Manager Date Started: September 1994. Date Ended: September 1994. Employer's Name: Poplar Recare. Address: 1764 Marco Polo Way, Burlingame, CA. Job title: Case Manager/Special Service Manager. Date Started: February 1995. Date Ended: September 1997. ancy M, Scott, MP.T. Mateo Dr., Ste. G, San Mateo, CA. Employer's Nam Date Started “antary 1998, Date Ended; May 2600. Employer’s Name: Maltin/Plack Group, Address: 810 Stanton Road, Burlingame, CA. Job title: Data Entry Clerk Date Started: 1999. Date Ended: February 2000. Employer’s Name: Regional Center of the East Bay. Address: 2151 Salvio Street, #368, Concord, CA. Job title: Case Manager. Date Started: Febraary 2000. Date Linded: Presently employed, No. 1/go128.wd- heir. nancy26 28 aa 22. 23. 24. 25. 26. 27. 28 29. 30. 31. B, The trustee of the trust i CA 94513. ©. Not applicabie. D. Not applicable. ancy Marie Scott, 383 Wintergreen Drive, Brentwood, No. Decedent’s daughter, Nancy Scott, resided with him during the last twelve months of his life, Nancy Scott continues to reside at this residence. During the last five years of decedent’s life, his children provided a significant amount of emotional support and, as he did not drive, they accompanied him to his doctor appointments and other errands as needed. During the last ten years of decedem’s fife, decedent continually contributed financial support to his grandchildren and great grandchildren’ s college funds. During his lifetime, decedent was very generous in his support of various charities. In 2004 alone, decedent contributed to many charities in the amount of approximately $2,500.00. In addition, decedent contributed money on a regular basis to his church. No. Prior to decedent’s death, decedent enjoyed assisting in the care of his grandchildren Yes. A. The reasonable value of one’s loss of the care, guidance, advice, counsel, training, protection, society, comfort and companionship of a very close and loving father. B. Not applicable. C. My father’s love, care, guidance, advice, counsel, training, protection, society, comfort, and companionship is invaluable and cannot be replaced, My father enjoyed life and was a very productive citizen and much to sharc in thic way of wisdom and knowledge. My father was a Pear! Harbor survivor, and was a veleran of World War Il and the Kotean War. fle lived through the great depression, grew up on a farm, and dedicated twenty years of his life to the U.S. Navy. He helped my mom raise us seven children and helped care for his grandchildren, He was intelligent and interested in so much of life. His wisdom, life experience, love of life and his family is priceless, 1 truly miss my father My father and I enjoyed spending time together and enjoyed various interests together. We enjoyed traveling; photography; genealogy; coin collecting; gardening; watching sports together; listening to music together; going to museums; watching television and movies together. We both shared a love of E’gyptian art, culture, and life. We enjoyed having long discussions about health issues, envizonmental issues, nature, and science. We liked tinkering with small fix-it jobs around the house together. My Sather and I spent a lot of time together, sharing many different hobbies and interests. I miss not being able to share this time with may father anymore 32. I lived with my father during the last five years of his life. With the exception of time I spent at work (32 hours per week), and being away to run errands and/or while attending social events, my father and I shared a lot of time together. 4.20 38. Dated: Petey 2006 No. Not applicable. Yes. No. No one other than my attorneys al Harowitz & Tigerman, LLP. Not applicable. HAROWITZ & TIG ‘MAN, LLP 7 /gol28.wd.-heir. nancy0 7 /go128.wa heir, zancy VERIFICATION TO FOLLOWVERIFICATION I, NANCY SCOTT, declare that: 1am the plaintii' named in the foregoing action; that [have read the foregoing PLAINTIEE’S ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIR OF DECENT (‘Wrongful Death), and know the contents thereof, the same is true of my own knowledge, except as to those matters therein stated on information and belief, and as to those matters I believe it to be tue. I declare under penalty of perjury under the faws of the State of California that the foregoing is true and correct and that this verification was executed jn Brentwood, CA on this 23_ day of _ MAX ___, 2006 Naaty(Sco} 2067/verif-go129.heir.wd.nancyEXHIBIT H26 28 20) STEVEN M. HAROWITZ (Bar No, 71117) STEPHEN M. TIGERMAN (Bar No. 112127) MIA MATTIS (Bar No. 191027) JENNIFER PERUZZI (Bar No. 199659) HAROWITZ & TIGERMAN, LLP 450 Sansome Street, 3" Floor San Francisco, California 94111 Telephone (415) 788-1588 Facsimile (415) 788-1598 Atiomeys for PLAINTIFFS SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO NANCY MARIE SCOT, Individually and | No, 05-443236 as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH; | PLAINTIFF MICHAEL SCOTT’S MICHAEL GERALD SCOTT; ROBERT ANSWERS TO DEFENDANTS" DAVID SCOTT; THOMAS CARY SCOTT; | STANDARD INTERROGATORIES TO MARY DENISE SOBOLIK; and FIRST HEIR OF DECEDENT DOE through TENTH DOE, inclusive, (Wrongful Death) Plaintiffs, vs. AC AND S, INC, etal, Defendants, Comes now plaintiff MICHAEL SCOTT and responds as follows to Defendants! Standard Interrogatories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only Just begun discovery in this case and that discovery is continuing with respect to cach interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to cach sub-interrogatory insofar as it calls for privileged work p communication. Without waiving these objections, plain! responds as follows: 1 A. Michael Gerald Scott, B. Son. C. 2860 Evergreen Drive, San Bruao, CA 94066.1/90 Dz Yes. Not appticable. ‘Not applicable. ‘Not applicable. Yes, Plaintiff was previously married to Kathleen Louise Allen from 1969-1991. During the course of this marriage, they had three children: Jennifer Anne Scott, 33 years of age; Dianna Denise Scott, 31 years of age; Laura Carey Scott, 30 years of age, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this sct of responses, and thus equally available to defendants. ‘Not applicable. No. Not applicable. No. Not applicable. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendant Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Deecdent (\Wzongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintiff refers defeadants (o Plaintiff Naney Maric Scott’s Answers to Deferslant’s Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concustontly with this set of responses, and thus equally available to defendants, ‘Not applicable, No. (1) Employer's Name: Lucky Chances Casino. ‘Aduress: 1700 Hillside Blvd., Colma, CA 94014, Job title: Security and Facility Operations Manager, Date Stated: Octoher 13, 2003 Date Bnded: Currently cmployed, -2- 29.wd-heir.michael20 24. 26. 36, 31 (2) Employer's Name: City of Daly City. Address: Daly City, CA. Job fitle: Police Officer. Date Started: November 16, 1971. Date Ended: October 10, 2003 Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. No, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concurrently with this sct of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this sot of responses, and thus equally available to defendants No. Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with this sot of responses, and thus equally available to defendants. Yes, A. The reasonable value of one's loss of the care, guidance, advice, counsel, training, protection, society, comfort and companionship of a very close and loving father. B. Not applicable. C. My father’s love, care, guidance, advice, counsel, training, protection, society, comfort, and companionship is invaluable and cannot be replaced. 1 truly miss my father. My father was an avid hunter and fisherman and taught me how to hunt and fish. We belonged to a duck club together and enjoyed duck hunting and fishing together every year until he was unable to walk without oxygen. This time we shared together was very special, My dad was a wealth of infonination. Whenever | had a question about anything, my dad would give advice and help and assist where he was able. My dad was a wonderful role mode]. His knowledge was a vonderful learning tool. We loved sharing time together asa family. My dad was-very involved in his grandchildren’s life. Ie attended all of their school activities, sporting events, auc truly enjoyed being a Grandpa, My children miss 71/90129 wa heir michae)32. 33. 34. 35. 36. 37. 38. Dated: very 0 him dearly as well. My father was an exceptional person, When my father lived in Daly City, I visited with him daily, When my father moved to Brentwood, I spent time with him on the weekends, epproximately every other month, | also spoke with him on the telephone every couple of days. Asa family, we also spent lime together during hotidays and birthday cclebrations. No. Not applicable. No. My dad worked around various asbestos-containing products while working in the shipyards. 1 also recall ry dad performed some home remodel work, sometime between 1956-1958, on our family home that was located at 672 Orange Street, Daly City, CA. 1 recall my dad transforming the downstairs basement into a bedroom forme. | recall ay dad did alf the work associated with this remodel including, but not limited ta, the framing, sheetrock, and electrical work. Plaintif!’s investigation and discovery are continuing, No one other than my attorneys at Harowitz & Tigerman, LLP. ‘Not applicable, HAROWIIZ & TIGERMAN, LLP F IZZ1 Attorneys for, PAINT IFF} 7 /go129. wd heir michael7/go129.wd. heir-pichael VERIFICATION TO FOLLOWEXHIBIT I26 28 2d STEVEN M. HAROWITZ (Bar No. 71117) STEPHEN M. TIGERMAN (Bar No. 112127) MIA MATTIS Gar No, 191027) JENNIFER PERUZZI (Bar No, 199659} HAROWTIZ & TEGERMAN, LLP 450 Sansome Steet, 3” Fluor San Francisco, California 94211 Telephone (415) 788-1588 Facsimile (415) 788-1598 Attorneys for PLAINTIFFS SUPERIOR COURT OF CALIFORNIA. COUNTY OF SAN PRANCISCO, NANCY MARIE SCOTT, Individually and as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH;, MICHAEL GERALD SCOTT: ROBERT. DAVID SCOTT: THOMAS CARY SCOTT; MARY DENISE SOBOLIK; and FIRST DOE through TENTH DOE, inchusive, Plaintifis, vs. AC AND S, INC, et al., Defendants, Comes now plaintiff ROBERT SCOTT and responds as follows to Defendants’ Standard Interrogatories to Heir and/or Legal Representative of Decedent, Please not ery is continuing with respect to each interrogatory tion, plaintiff respectfully objects to cach interrogatory and case and that discov just begun discovery in and sub-interrogatory. In ad No. 05-443236 PLAINTIFF ROBERT SCOTT'S ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO. HEIR OF DECEDENT (Wrongful Death) sub-interrogatory insofar as itealls for privileged work product or privileged attorney-client communication. Without waiving these objections, plaintiff responds as follows: 1. A. Robert David Scott. B. Son. C, 518 Joaquin Avenue, San Tcandre, CA 94877, 11/go128 .wd.heir. robert fe that plaintiff has only26 28 20 D. —_Notapplicable. Not applicable. ‘Not applicable. Not applicable, Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of sesponses, and thus equally available to defendants. Not applicable. No. Not applicable, No. Not applicable. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with this set of responses, and (hus equally available to defendants. No. Plaintiff refers defendants to Plainti{T Nancy Maciv Scott’s Answers to Defendant's Standard Interrogatories to Iicirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, Not applicable. (1) Employer's Name: Livermore Valley Joint Unified School District. Address: 685 East Jack London Boulevard, Livermore, CA 94550. Job title: Science Teacher. Date Started: August 1974 Date Ended: Currently employed. 1/g0129.d heir. xobert20 21 22. 23. 24. 25. 26. 27. 28. 29. 30. 31 32. 33, Plaintiffrefers defendants (0 Plaintiff Nancy Marie Scott’s Answers 10 Defendant's Standard Interrogatorics to Heirs of Decedent (Wrongful Death) served concurrently with ‘his sct of responses, and thus equally available to defendants. No. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with {his set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Jnterrogatories to Heirs of Devedent (Wrongtiul Death) served concurrently with this sct of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Ilcirs of Deeedent (Wrongful Death) served concurently with this set of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintiff refers defendants to Plaintiff Nancy Marie Seolt’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Yes. A. The reasonable value of one's loss of the care, guidance, advice, counsel, training, protection, society, comfort and companionship of a very close and loving father. B. —_Notapplicable. C. The loss of my father’s care, guidance, advice, counsel, iraining, protection, soviety, comfort, and companionship is priccless. The last years of my father’s life were not what he or his family wanted. His decreasing hcalih resulted in a slowing down and eventual cessation of most oF his hobbies and household chores, He could not go on family vacations or when he did, during this period, they were cut short due to his failing health. Much to his frustration, during the last six ycars of his life, he couldn't participate in the physical work of gardening. This was something we enjoyed very much and this was very difficult. I really miss my dad, My dad and I raised several breeds of pheasants and ducks when I lived at home in Daly City. We spent time together trout fishing and Lake Merced and in the Sierras. Dad and I shared a love of gardening, especially vegetable gardening. 1 would prunc his ituit trees and help him procure and plant vatious vegetable seedlings. My father was a parent, mentor, and companion. During the last five years of his life, | spent several hours with him on the weekends and during summer vacations. No. 7 /gol29.wd heir. robert34. Not applicable. 35. No. 36. recall my dad performed some constuction work on our family home, located at 672 ‘Orange Street, Daly City, California. My dad also worked with ashestos-containing materials during his employment. Plaintiff's investigation and discovery are continuing, 37. Noone other than my attorneys at Harowitz & Tigerman, LLP. 38. Not applicable. Dated: Februapg/ 7, 2004 7 HAROWITZ & TIGERMAN, LLP by, me FER PERI Attorneys for PLAINTIFFS: aol 67 /go129. wd, hoix robert7 /40129.Wd- heir. robert VERIFICATION TO FOLLOWYE 101 3, ROBERT SCOTT, declare that; Iam the plaintiff named in the foregoing action; that I have read the foregoing PLAINTIFFS ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIK OF DECENT (Wrongful Death), and know the contents thereof; the same is truc of my own knowledge, except as to those matters therein stated on information and belief, and as to those matters I believe it to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is trne and correct and that this ver! Tsay ot Lerch _, 2006. tion was executed in San Leandro, CA on this Gee Lhe. Robert Scott 206 Hiverif 0129 heir wi sobertEXHIBIT J=N M. HAROWITZ. (Bar No. 71117) BPUEN M. GERMAN (Bar No. 112127} MIA MATTIS (Bar No. 191027), JENNIFER PERUZZI (Bar No. 199659) 3. | HAROWITZ & TIGERMAN, LLP 450 Sansome Street, 3 Floor 4 | San Francisco, Calizornia 94113 Telephone (415) 788-1588 5 | Facsimile (415) 788-1598 6 Attorneys for PLAINTIFFS > 8 9 10 SUPERIOR COURT OF CALIFORNIA an COUNTY OF SAN FRANCISCO 2 22 | NANCY MARIE SCOTT, Individually and | No. 05-443236 aa | asSucei Interest to DENZIL. Decedent; JOANNE MARIE WOLFARTH; ig | MICHAEL GERALD SCOTT; ROBERT DAVID SCO1 THOMAS CA RY SCOTT; | 5 16 MARY DENISE SOBOLIK; and FIRST HEIR OF DECE) DOE through TENTH DOE, inclusive, 1 | (Wrongful Death) Plaintiffs, 16 vs. 19 . AC AND S, INC. et al., 20 Defendants. at _ 22 Comes now plaintiff TEOMAS SCO1T and responds as follows 10 Defendants Standard 23. | Interrogatories to Heir and/or Legal Repre: te that plainsiff has only ° and that discovery is continuing with respect fo each interrogatory plaintiff respectfully o' sub-interrogatory ingofar as it calis for pri a5 | communication. Without waiving these ol a6 | 1 A Thomas Caty Scott 28 C. 1241 W. Ghost Piace, Tucson, Arizona 85737, 2061/go129.wd.heir. thomas6. 20! Dd. Yes. Not applicable, ‘Not applicable. Not applicable. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available te defendants. Not applicable. No. ‘Not applicable, No, Not applicable. Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with ihis set of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Naney Marie Scott's Answers fo Defenda Standard interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with this set of responses, and thus equally available to defendants, No. Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendant's Standard Interrogatories t) Heirs of Decedent (Wrongful Death) served concusreatly with this set of responses, and thus equally available te defendants, Not applicable. No. No. Yes, (1) Employer's Name: Sam Levit Furniture. Address: 3750 West Orange Grove, Marana, Arizona 85741, Job title: Manage:. Date Started: 1993. Date Ended: Currently employ ‘ture, Q) Employer's Name: Levitz Fun 26 B1/g0l29.wd.hoix. Ehoaasad a 25. 26. 27. Hh /goi29.wd-beie Address: Nevada. Job ttle: Manager. Date Started: 1999, Date Ended: 1992. (3) Employer's Name: Furnishings 2000. céress: San Diego, California. Job title: Manag Date Started: 1985. Date Ended: 1990. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equal!y available to defendants. s tly with Plaintiff refers defendants to Plaintiff’ Nancy Marie Scott’s Answers to Defend: Standard foterrogatories to Heirs of Decedent (Wrongful Death) served concur this set of responses, and thus equally available to defendants. Plaintiff re‘ers defendants to Plaintiff Naney Mat Standard Interrogatories to Heirs of Decedent (W. this set of responses, and thus equally available to Scott's Answers to Defendant's ved concurrently with Plaintiff refers defendants to Plaintiff’ Nancy Marie Scolt’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrong Death) served concurrently with s set of responses, and hus equally available to defendants. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Ioterrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Yes. A. The reasonable vaiue of one's loss of the care, guidance, advice, counsel, trainin: protection, society, comfort and companionship of a very close and lovi B, _Notapplicable. C, My father’s love, care, guidance, advice, counsel, training, protection, society, comfort, and companionship is invaluable and cannot be replaced. I really miss my father, My father and | enjoyed spending time logether hunting and fishing. We also toved ‘watching football and baseball pames. We shared an enjoyment for watching war movies together as well. We all eejoyed spending our family time together.20 1) qok2S.ud.heir. the ‘As my father and I resided in different states, I would visit with my two times per year, for three to four days each visti. father on average about No, Not applicable. No, No. No one other than my attorneys Harowitz & Tigerman, LLP. Not applicable. f 2006 HAROWIFZ & TIGERMAN, LLP1/qei29.wd. heir oma VERIFICATION TO FOLLOW1, THOMAS SCOTT, declare Laat: named in the foregoing action; that I have read the foregoing DANTS’ STANDARD INTERROGATORIES TO HEIR ENT (Wrongfial Death), and know the contents thereof; the same is érue of my own knowledge, except as to those matters therein stated on information and belief, and as to those matters { believe it to be true. i declare under penalty of perjury under he laws of the State of California that the foregoing is true and correct and that this verification was executed in Tucson, AZ on this_“7 “x day of MARCH _, 2006 ‘206 veri g0129-heit-wd thomasEXHIBIT kKSTEVEN M. HAROWITZ (Bar No. 71117) STEPHEN M. TIGERMAN (Bar No. 112127) MIA MATTIS (Bar No. 191027) JENNIFER PERUZZI (Bar No, 199659} HAROWITZ & TIGERMAN, LLP 450 Sansome Street, 3" Floor. San Francisco, California 94411 Telephone (415) 788-1588 Facsimile (415) 788-1598 Attorneys for PLAINTIFFS SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO NANCY MARIE SCOTT, Individually and as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH; MICHAEL GERALD SCOTT; ROBERT. DAVID SCOTT; THOMAS CARY SCOTT; MARY DENISE SOBOLIK; and FIRST DOE through ‘TENTH DOE, inclusive, Plaintiffs, vs. AC AND S, INC, etal., Defendants. No, 05-443236 PLAINTIFF MARY SOBOLIK’S ANSWERS TO DEFENDANT STANDARD INTERROGATORIES TO HEIR OF DECEDENT (Wrongful Death) Comes now plaintiff MARY SOBOLIK and responds as follows to Defendants’ Standard 20 Interrogatories to Heir and/or Legal Representative of Decedent, Please note that plaintiff has only just begun discovery in this case and that discovery is continuing with respect to cach interrogator and sub-interrogatory. In addition, plaintiff respectfully objects to cach interrogatory and sub-interrogatory insofar as it calfs for privileged work product or privileged attorney-client communication. Without waiving these objections, plaintiff responds as follows: 1, A. Mary Denise Sobolik. 8. Danghter. C. 369 Wintergreen Drive, Brentwood, CA, 11/9029 we heir mary1 242 3 13. ada 5 ps. 6 | 6. 7 a | 7. oF & ao | 9. 12 | 10. 12 fil 13 | 12. 14 1s | 13. 16 ay p14. 1g | 1S. 19 20 | 16. au | 17. 22 | 18. 23 | 19. 24 | 20. as | ai. 26 28 | 22. 20) D. Yes. Not applicable. Not applicable, Not applicable. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this sot of responses, and thus equally available to defendants. Not applicable. No. Not applicable, No. Not applicable Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No, Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendant’ Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concunently with this set of responses, and thus equally available to delendants. Not applicable, No. Not applicable. Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. wd.heizemary0 26. 27. 28. 29. 30. 31 32. No Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heits of Decedent (Wrongful Death) served concurently with this sct of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintif’ Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories (o Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, No, Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant’s Standard Interrogatories to Heirs of Decedent {Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Yes. A. ‘The reasonable value of one’s loss of the care, guidance, advice, counsel, training, protection, society, comfort and companionship of a very close and Joving father, B. Not applicable. C. The loss of my father's care, guidance, advice, counsel, training, protection, society, comfort, and companionship is invaluable and can not be replaced. If'my father had not been exposed to asbestos in his younger years, he would have had a longer and more fulfilling life. The quality and length of his life was greatly affected by his ness. My family and I could have shared more quality time with him instead of witnessing him experience his decline. My father was an integral part of our lives ona daily besis. Words cannot adcquately describe the void that has been left and the hurt knowing my children, will not get the opportunity to know and experience a further relationship with their grandfather. Unfortunately, my daughter Lauren, never got to experience any relationship with him before his death. My father and I enjoyed spending time together doing many different types of things including, but not limited to, gardening; stamp collecting; picking fresh fruit at local farms; feeding quail; listening to music; reading books and magazines and having discussions about what we read; watching baseball and football; fishing; and boating. We enjoyed “friday Family Fun Night” where we all played games together. We enjoyed watching lrish dancing and videos of different countries and cultures. We enjoyed sharing meals together, grocery shopping, baking pics, taking car rides together, spending time with the entire family, watching historical and educational programming together. Hc loved spending time with his grandchildren, playing with thom and teaching them new things. He taught my daughter Emily fo write the alphabet. My dad and T were happy to sit and just talk with each other. Treadly miss my dad. ‘On average, I spent approxitnately two hours per day with my Gaher. 7 /g0129.wd.heir.ma=)20) 33. No. 34. Not applicable. 33. No. 36. No 37. No one other than my attorneys at Harowitz & Tigerman, LLP. Not applicable. Dated: February 7, 2006 HAROWIIZ & TIGERMAN, LLP by. fENNIFER PERU Attorneys for PLAINTIFFS 1/go129.wd heir mazyot VERIFICATION TO FOLLOW 1/g0229.wd-beir maryEXHIBIT LSTEVEN M. HAROWITZ (Bar No. 71117) STEPHEN M. TIGERMAN (Bar No, 112127) MIA MATTIS Bar No. 191027) JENNIFER PERUZZI (Bar No. 199659) HAROWITZ & TIGERMAN, LLP 450 Sansome Steet, 3° Floor San Francisco, California 94111 Telephone (415) 788-1588 Facsimile (415) 788-1598 Attorneys for PLAINTIFFS SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO, NANCY MARIE SCOTT, Individually and | No. 05-443236 as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH; | PLAINTIFF JOANNE WOLFARTH’S MICHAEL GERALD SCOTT; ROBERT "| ANSWERS TO DEFENDANTS’ DAVID SCOTT; THOMAS CARY SCOTT: MARY DENISE SOBOLKK; and FIRST DOE through TENTH DOE, inclusive, (Wrongful Death) Plaintiffs, vs. AC AND §, INC., etal, Defendants. Comes now plaintiff JOANNE WOLFARTH and responds as follows to Defendants! Standard Interrogutories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only just begun discovery in this case and that discovery is continuing with te cach interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to each interrogatory and sub-interrogatory insofar as it calls for privileged work product or privileged attomey-client communication. Without waiving these objections, plaintiff responds as follows: 1. A, Joanne Marie Wolfarth. B. Daughter. C. 2639 Sivererest Stecet, Pinole, 7 /goL29.wd.hesx. joanne2d D. Yes. Not applicable, ‘Not applicable, ‘Not applicable. Plaintiff refers defendants to Plaintiff Naney Marie Soott’s Answers to Defendant's Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Nancy Marie Soott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death} served concurrently with this set of responses, and thus equally available to defendants. Not applicable. Ne. Not applicable. No. Not applicable. Plaintiff refers defendants to Plaintiff’ Nancy Marie Scott's Answers to Defendant’s Standard Interrogatorics to Heirs of Devedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintif{ Nancy Marie Scott's Answers to Defendant’s Standard interrogatories to Heizs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintiff refers defendants to Plaintiff Nancy Marie Seott’s Answers to Defendaut’s Standard Interrogatories to ileirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equaily available to defendants, Not applicable. No. (1) Eigployer’s Nawye: Pewoo Consulting. : 2639 Silvercrest Street, Pinole, CA, fob tue Sole Proprietor. Date Started: January 1, 2003. Date Ended: Presently employed, :1/g0129.wd.hesz. joanne21. 23 24 26. 27. 28. 29. 30. 31 Plaintiff refers defendants {o Plaintiff Nancy Marie Soott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, No. No, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Maric Scott’s Answers to Defondant’s Standard Interrogatories to Heirs of Decedent (Wrongful Deatl)} served concmrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Yes. A. The reasonable value of one's ioss of the care, guidance, advice, counsel, training, protection, soviety, comfort and companionship of a very close and loving father. B. Not applicabic. C. ‘The loss of my father’s care, guidance, advice, counsel, (raining, protection, society, comfort, and companionship is invaluable and can not be replaced, My father took very good care of himself. He wanted to five. He loved his family and wanted fo be with us for as fong as possible. 1 truly miss sharing all of the special time I shared with my father. 1 miss him dearly. My father and I collected stamps together for years. His earlier years in the Navy really encouraged our collecting stamps from all over the world and our love of history and geography. I started a stamp collecting club in my school and he supported thei by writing letters from his overseas ports. We loved to talk about history, and geography, World War ll, and I continued to lear ftom his expansive knowledge until he died. We loved to disouss genealogy and his family who lived in the midwest. My father loved every type of music. We shared CD's and listened to the music together. We loved to watch old movies and videos, especially “I Love Lucy” and “Dean Martin Roasts.” I remember that we would laugh and erp, but mostly laughed until we couldn’t laugh anymore, My father loved to garden and we would “admire” his produce and share recipies and ideas on how to put them fo the best use possible. My dad would cook and loved to cook pics. In his earlier years, he hunted, fished, and went abalone diving. We loved the way te prepared and cooked the abalone. My dad foved to sign and when I told hitn he sounded like Bing 7/g0129.wd-haix. joanneaol 32. 38. Dated: reorancf 2006 Crosby, he wouldn't stop. Since my father has died, I can not believe the questi want fo ask him about history and its relation to current events; there are special recipes that I have just made and how I want himn to cover over and share them; family questions that | have Forgotten; and just plain talking and laughing about life. I truly miss my dad. I visited with my dad on a weekly basis until my husband and J started our home busines ‘Thereafier, I visited with my dad as often as possible and spoke with him on the telepho every other day. When he was ill, I spoke to him daily on the telephone. No. Not applicable No, No. ‘No one other than my attorneys at Harowitz & Tigessian, LLP Not applicable, HAROWITZ & TIGERMAN, LLP JENNIFER PERUZZI Attorneys fo PLAINTIFFS 7/go129.wa.heix. joanne20! 7 /g0129.wd.heiy. joanne VERIFICATION TO FOLLOWEXHIBIT MSTEVEN M. HAROWITZ, (Bar No. 71117) STEPHEN M. TIGERMAN (Bar No. 112127) MIA MATTIS (Bar No. 191027) JENNIFER PERUZZI (Bar No. 199659) HAROWIIZ & TIGERMAN, LLP 450 Sansome Street, 3" Floor San Francisco, California 94111 Telephone (415) 788-1588 Facsimile (415) 788-1598 Attorneys for PLAINTIFFS SUPERIOR COURT OF CALIFORNIA. COUNTY OF SAN FRANCISCO “ NANCY MARIE SCOTT, Individually and as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE WOLFARTH; MICHAEL GERALD SCOTT; ROBERT DAVID SCOTT; THOMAS CARY SCOTT; MARY DENISE SOBOLIK; and FIRST DOE through TENTH DOE, inclusive, No. 05-443236 PLAINTIFF JOANNE WOLFARTH’S VERIFIED AMENDED AND SUPPLEMENTAL ANSWERS TO. DEFENDANTS' STANDARD INTERROGATORIES TO HEIR OF DECEDENT 20 Plaintifis, (Wrongful Death) ¥s. AC AND S, INC., etal., Defendants. Comes now plaintiff JOANNE WOLFARTH and responds as follows to Defendants’ Standard Interrogatories to Heir and/or Legal Representative of Decedent. Please note that plaintiff has only just begun discovery in this case and that discovery-is continuing with respect to each interrogatory and sub-interrogatory. In addition, plaintiff respectfully objects to each interrogatory and sub-interrogatory insofar as it calls for privileged work product or privileged attomey-client communication. Without waiving these objections, plaintiff responds as follows: 1. A. Joanne Marie Wolfarth.. B. Daughter, C. 2639 Sivercrest Street, Pinole, CA 94564. 7/g0129.wd. heir. joanne20 D. Yes. Not applicabic. Not applicable. Not applicable. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, ‘Not applicable. No. Not applicable. No. Not applicable, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintigf refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Not applicable. No. Name: Paweo Consulting. 2639 Silvercrest Street, Pinole, CA. Sole Proprietor. Date Started: January 1, 2003. Date Ended: Presently employed.26 28 2a 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31 Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants, No. No. Plaintiff refers defendants fo Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongfiil Death) served concurrently with this set of responses, and thus equally available to defendants, Plaintiff refers defendants to Plaintiff Nancy Marie Scott’s Answers to Defendant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiftrefers defendants to Plaintiff Nancy Maric Scolt’s Answers to Defondant’s Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant’s Standard interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. No. Plaintiff refers defendants to Plaintiff Nancy Marie Scott's Answers to Defendant's Standard Interrogatories to Heirs of Decedent (Wrongful Death) served concurrently with this set of responses, and thus equally available to defendants. Yes, A, The reasonable value of one's loss of the care, guidance, advice, counsel, training, protection, society, comfort and companionship of a very close and loving father, B. Not applicable, C. The loss of my father’s care, guidance, advice, counsel, training, protection, society, comfort, and companionship is invaluable and can not be replaced. My father took very good care of himself. He wanted to live. [le loved his family and wanted to be with us for as long as possible. [ truly miss sharing all of the special time I shared with my father. I miss him dearly. My father and I collected stamps together for years. His earlier years in the Navy really encouraged our collecting stamps from all over the world and our love of history and geography. 1 started a stamp collecting club in my school and he supported them by waiting letters from his overseas ports, We loved to talk about history, and geography, World War II, and I continued to learn from his expansive knowledge until he died. We loved to discuss genealogy and his family who lived in the midwest. My father loved every type of music, We shared CWD’s and listened to the music together. We loved to watch old movies and videos, especially “I Love Lucy” and “Dean Martin Roasls.” I remember that we would laugh and cry, but mostly Jaughed unti} we coulds’t laugh anymore. My father loved to garden and we would “admire” his produce and share recipies and ideas on how to put them to the best use possible. My dad would cook and loved to bake pies, In his earlier years, he hunted, fished, and went abalone diving. We loved the way he prepared and cooked the abalone. My dad loved to sing and when I told him he sounded like Bing ~3- 1/go123.wa. heir. soanneal 32. 33, 34. 35. 36. 37. 38. Crosby, he wouldn't stop. Since my father hes died, I can not believe the questions that I want to ask him about history and its relation to current events; there are special recipes that I have just made and miss not being able to share them with him; family questions that I have forgotten; and just plain talking and laughing about life. Twuly miss my dad. I visited with my dad on a weekly basis until my husband and I started our home business Thereafter, I visited with my dad as often as possible, sometimes staying days at a time care for him, and spoke with him on the telephone every other day. When he was ill, I spoke to him daily on the telephone, Watching my dad die from cancer was horrible, but I treasured any time we were able to share together. No. Not applicable. No. No. No one other than my attorneys at Harowitz & Tigerman, LLP. Not applicable. Dated: May %, 2006 HAROWITZ & TIGERMAN, LLP 7/go129.wd.heic-joanneVERIFICATION I, JOANNE WOLFARTH, declare that. 1 am the plaintiff named in the foregoing action; that I have read the foregoing PLAINTIFF'S AMENDED AND SUPPLEMENTAL ANSWERS TO DEFENDANTS’ STANDARD INTERROGATORIES TO HEIR OF DECENT (Wrongful Death), and know the contents thereof; the same is true of my own knowledge, except as to those matters therein stated on information an