On July 20, 2005 a Motion-Secondary was filed involving a dispute between First Doe Through Tenth Doe, Inclusive, Scott, Michael Gerald, Scott, Nancy Marie, Scott, Robert David, Scott, Thomas Cary, Sobolik, Mary Denise, Wolfarth, Joanne Marie, and 3M Company (Formerly Named Minnesota Mining And, Abb, Inc., Abb, Inc. Which Will Do Business In California As, Ac And S, Inc., Allied Packing & Supply, Inc., Amchem Products, Inc., Asbestos Corporation Ltd., A.W. Chesterton Company, Babcock Borsig Power, Inc.,As The Parent Alter Ego, Cbs Corporation, A Delaware Corporation,, Coltec Industries, Inc.,, Crane Co., Darcoid Company Of California, Db Riley, Inc., Dee Engineering Co., Douglass Insulation Company, Eaton Electrical Inc., Eleventh Doe Through Three Hundredth Doe,, Enpro Anchor Packaging, Foster Wheeler Llc, Foster Wheeler Llc, Survivor To A Merger With, Garlock, Inc., General Electric Company, Graybar Electric Co., Graybar Electric Company, Inc., Hill Brothers Chemical Company, Hopeman Brothers, Inc., Imo Industries Inc., Ingersoll-Rand Company, J.T. Thorpe And Son, Inc., Leslie Controls, Inc., Lucent Technologies, Inc., Lucent Technologies, Inc. As A Successor In, Metalclad Insulation Corporation, Metropolitan Life Insurance Company, Minnesota Mining Corporation, Aka 3M Company, M. Slayen And Associates, Inc., M.Slayen & Associates, Inc., New Iem, Llc, The, Quintec Industries, Inc., Rapid-American Corporation, Sb Decking, Inc., Sb Decking, Inc., Formerly Known As Selby,, Soco-Lynch Corporation, Soco West, Inc., Square D Company, Sterling Fluid Systems, Inc., Sterling Fluid Systems, Syd Carpenter Marine Contractor, Inc., Syd Carpenter Marine Engineering, T H Agriculture & Nutrition Llc, The Darcoid Company Of California, The New Iem, Llc,, Thomas Dee Engineering Company, Thorpe Insulation Company, Triple A Machine Shop, Inc., Union Carbide Corporation, Viacom Inc., As Sbm To Cbs Corp., Fka Westinghouse, for civil in the District Court of San Francisco County.
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— I A WwW BF YW BD oo Eugene C. Blackard Jr. (Bar No. 142090) . Cesar A. Alvarado (Bar No. 193973) ELECTRONICALLY ARCHER NORRIS A Professional Law Corporation F ILE D 2033 North Main Street, Suite800 County of San Francisco PO Box 8035 u Walnut Creek, California 94596-3728 . MAR 21 2007 Telephone: 925.930.6600 GORDON PARK-LI, Clerk Facsimile: 925.930.6620 BY: WILLIAM TRUPEK Deputy Clerk Attorneys for Defendant GRAYBAR ELECTRIC COMPANY, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO NANCIE MARIE SCOTT, Individually Case No. 443236 and as Successor-in-Interest to DENZIL SCOTT, Decedent; JOANNE MARIE DECLARATION OF CESAR A. WOLFARTH, MICHAEL GERALD ALVARADO IN SUPPGRT OF MOTION SCOTT, ROBERT DAVID SCOTT, FOR SUMMARY JUDGMENT THOMAS CARY SCOTT, MARY DENISE SOBOLIK, Date: June 15, 2007 Time: 9:30 a.m. Plaintiffs, Dept: 302, Judge: Honorable Patnck J. Mahoney Vv. Trial Date: July 16, 2007 ACandS, INC., et al., Defendants. I, César A. Alvarado, declare: 1. Iam an attorney at law duly licensed te practice before all courts of the state of California, and am an associate with the law firm Archer Norris, attorneys of record for GRAYBAR ELECTRIC COMPANY, INC. (“Graybar”). 2. Ihave personal knowledge of the facts herein and if called as a witness herein I could and would competently testify thereto. 3. Attached to the Index of Exhibits in Support of defendant Graybar’s Motion for Interrogatories Propounded by Defendants (Wrongful Death), Set One. RIC193/549217-1 DECLARATION OF CESAR A. ALVARADO IN SUPPORT OF MOTION FOR SUMMARY JUDGMENTaawan 4, Attached to the Index of Exhibits in Suppart of defendant Graybar’s Motion far Summary Judgment as Exhibit “B” is a true and correct copy of the Declaration of David G. Maxwell. 5. Attached to the Index of Exhibits in Support of defendant Graybar’s Motion for ‘Summary Judgment as Exhibit “C” are true and correct copies of the pertinent portions of Michael Scott’s deposition testimony. 6. Attached to the Index of Exhibits in Support of defendant Graybar’s Motion for Summary Judgment as Exhibit “D” are true and correct copies of the pertinent portions of Nancy Scott’s deposition testimony. 7. Attached to the Index of Exhibits as Exhibit “E” are true and correct copies of the pertinent portions of Robert Scott’s deposition testimony. 8. Attached to the Index of Exhibits as Exhibit “F” are trus and correct copies of the pertinent portions of Mary Sobolik’s deposition testimony. 9. Attached to the Index of Exhibits as Exhibit “G” are trac and cortect copies of the pertinent portions of Joanne Wolfarth's deposition testimony. 10, Attached to the Index of Exhibits as Exhibit “H™ are true and correct copies of the pertinent portions of Thomas Scott’s deposition testimony. 11. Attached to the Index of Exhibits as Exhibit “I” are true and correct copies of Graybar’s Special Interrogatories to Plaintiff, Request for Production of Documents, Request for Admissions, and Form Interrogatories propounded to plaintiff. 12, Attached to the Index of Exhibits as Exhibit “J” is a true and correct copy of Plaintiff's Responses to Graybar Special Interrogatories, Request for Production of Documents, Request for ‘Admissions, and Form Interrogatories. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this_ 25“ day of March, 2007 at Walnut Creek, “™ edo RICIOWS49217-1 2 DECLARATION OF CESAR A. ALVARADO IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT.