Motion-Secondary: HAROLD KOEPKE et al VS. FORD MOTOR COMPANY et al

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                                Garrett Sanderson ITT, Bar No. 131026

sanderson@cbmlaw.com

Peier Ii Crus Bee No. 220850 ELECTRONICALLY

peruz@cbmlaw.com FILED
CARROLL, BURDICK & McDONOUGH Lip Superior Court of California,
Attorneys at Law 00 County of San Francisco
44 Montgomery Street, Suite 4
San Francisco, California 94104 FEB 04 20 14
Telephone: 415.989.5900 BY: VANESSA WU
Facsimile: 415.989.0932 Deputy Clerk

Attorneys for Defendant Volkswagen Group of
America, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217

KOEPKE,
DECLARATION OF PETER H. Cruz IN

Plaintiffs, OPPOSITION TO PLAINTIFFS’ MOTION FOR
PREFERENTIAL TRIAL DATE

Vv.
Date: February 18, 2014
FORD MOTOR COMPANY; et al., Time: 9:00 a.m.

Dept.: 503

Defendants.

Complaint Filed: December 3, 2013
_| Trial Date: None Set

I, Peter H. Cruz, declare as follows:

L. I make this declaration based upon my personal knowledge and, if called
as a witness, could and would testify competently to the matters stated here.

2. Tam a member in good standing of the State Bar of California and am an
associate of Carroll, Burdick & McDonough LLP, attorneys Defendant Volkswagen Group
of America, Inc. (“WWGoA”).

3. Exhibit “A” attached hereto is a true and correct copy of deposition
transcript excerpts from Plaintiff Harold Koepke’s January 23 and 24, 2014, deposition

testiomony in this case.

CBM-SFISF61591 1-1
CRUZ DECLARATION iN OPPOSITION TO PLAINTIFFS’ MOTION FOR PREFERENTIAL TRIAL DATE — NO. CGC-13-2762174, Exhibit “B” attached hereto is a true and correct copy of Plaintiff Harold
Kopeke’s unverified Answers to Defendants’ Standard Interrogatories to Plaintiff and
proof of service regarding same, served on December 26, 2013.

5. Exhibit “B-1” attached hereto is a true and correct copy of Plaintiff
Harold Koepke’s executed verification in support of his Answers to Defendants’ Standard
Interrogatories to dated January 2, 2014.

6. Exhibit “C” attached hereto is a true and correct copy of Plaintiffs’
Preliminary Fact Sheet that accompanied the Complaint filed on December 3, 2013.

7. Exhibit “D” attached hereto is a true and correct copy of Plaintiff Harold
Koepke’s unverified Answers to Defendants’ Standard Request for Production and
Identification of Documents and Things to Plaintiff(s) Set One that was served
electronically on January 14, 2014.

8. Exhibit “D-1” attached hereto is a true and correct copy of Plaintiff
Harold Koepke’s executed verification in support of his Answers to Defendants’ Standard
Request for Production and Identification of Documents and Things to Plaintiff(s) Set One,
dated January 17, 2014.

9. Exhibit “E” attached hereto is a true and correct copy of Plaintiff Harold
Koepke’s unverified Supplemental Answer to Defendants’ Standard Request for
Production and Identification of Documents and Things to Plaintiff(s) Set One No. 8 and
proof of service regarding same, served on January 17, 2014.

10. Exhibit “E-1” attached hereto is a true and correct copy of Plaintiff
Harold Koepke’s executed verification in support of his Answers to Defendants’ Standard
Request for Production and Identification of Documents and Things to Plaintiff(s) Set One
No. 8, dated January 26, 2014.

11. Exhibit “F” attached hereto is a true and correct copy of Plaintiff Harold

Koepke’s unverified Answers to Defendants’ Standard Request for Production and

CBM-SFISFO1S91 1-1 -2-
CRUZ DECLARATION IN OPPOSITION TO PLAINTIFFS’ MOTION FOR PREFERENTIAL TRIAL DATE — NO, CGC-13-276217Identification of Documents and Things to Plaintiff{s) Set One and proof of service
regarding same, served on January 14, 2014.

12. Exhibit “G” attached hereto is a irue and correct copy of Plaintiff Harold
Koepke’s Stanford Hospital medical records bate-stamped HK SH 00001 — HK SH 0020
that contain a November 26, 2013, “Printed On” time stamp on the bottom left-hand corner
of each page.

13. Exhibit “H” attached hereto is a true and correct copy of Plaintiff Harold
Koepke’s medical records bate-stamped HK RRMC 0029, HK RRMC 0151, HK RRMC
0153, HK RRMC 0318, HK RRMC 0326, HK RRMC 0328, HK RRMC 0331, and HK
RRMC 0332 containing references to Mr. Koepke’s Germany and Australia work history.

14. Exhibit “I” attached hereto is a true and correct copy of Plaintiff Harold
Kopeke’s unverified Answers to Defendants’ Standard Interrogatories to Plaintiff, Friction
Set One and proof of service regarding same, served on January 13, 2014.

15. Exhibit “J” attached hereto is a true and correct copy of Plaintiff Harold
Kopeke’s unverified Amended Answers to Defendants’ Standard Interrogatories to
Plaintiff and proof of service regarding same, served on January 13, 2014.

16. Exhibit “KK” attached hereto is a true and correct copy of Plaintiff Harold

Kopeke’s unverified First Amended Responses to Defendants’ Standard Interrogatories to
Plaintiff, Friction Set One and proof of service regarding same, served on January 17,
2014.

17, Exhibit “K-1” attached hereto is a true and correct copy of Plaintiff
Harold Koepke’s executed verification in support of his First Amended Responses to
Defendants’ Standard Interrogatories to Plaintiff, Friction Set One, dated January 26, 2014.

18. Exhibit “L” attached hereto is a true and correct copy of the first three
pages from Defendants’ Standard Interrogatories to Plaintiff (Friction).

19. Exhibit “M” attached hereto are true and correct copies of Notice of
Taking Deposition and Notice of Videotaping Deposition for Wayne Brotze, Bob Segale,

CBM-SFSF6) 5911-1 -3-
CRUZ DECLARATION EN OPPOSITION TO PLAINTIFFS’ MOTION FOR PREFERENTIAL TRIAL DATE = NO. CGC-13-276217oO Om MD HA RY

N
3

Grant Tovey, Lawrence Krasnow, and Jim Nash and the corresponding Deposition
Subpoena and January 21, 2014, proof of service for each respective witness.

20. Had plaintiffs’ initial standard interrogatory responses included the
corresponding contact information for percipient witnesses Wayne Brotze, Bob Seagle,
Grant Tovey, Lawrence Krasnow, and Jim Nash, I would have director an investigator to
make contact with these individuals and served them with deposition subpoenas, including
documents requests, given plaintiffs’ stated intention to file a motion for preferential trial
date.

21. Exhibit “N” attached hereto is a true and correct copy of VWGoA’s
January 14, 2014, meet-and-confer letter regarding plaintiff Harold Koepke’s deficient
responses to VWGoA’s Set One the first three pages from Defendants’ Standard
Interrogatories to Plaintiff (Friction).

22. Exhibit “O” attached hereto is a true and correct copy of Plaintiff Harold
Kopeke’s unverified First Amended Responses to VWGoA’s Set One Special
Interrogatories, proof of service regarding same, served on January 21, 2014.

23. Based on my review of plaintiffs’ responses to standard discovery
requests required by the Case Management Order, none of the requested contact
information for product identification witnesses has been provided concerning Harold
Koepke’s employment in Australia or Germany.

24. Based on my review of plaintiffs’ interrogatory responses and document
production, VWGoA’s investigation, as well as medical records provided in subpoenaed
documents, it is likely that the following treating physicians will be able to testify
concerning plaintiff Harold Koepke’s current condition, prognosis, treatment and ongoing
medical needs:

e Paul Umino, MD, plaintiff's primary care physician at El Rose Medical Group
from 2001;
e A. Lailith Mohan, MD (Cardiologist), who has treated plaintiff since 2009;

CBM-SFISFOIS91H-1 -4-
CRUZ DECLARATION IN OPPOSITION TO PLAINTIFFS’ MOTION FOR PREFERENTIAL TRIAL DATE — NO, CGC-13-276217e Raymond Erny, MD (Cardiologist and Internist), that inserted coronary stents in
plaintiff in 2010;

e {an Anderson, MD (Oncologist), at the Redwood Regional Medical Group has
treated plaintiff for mesothelioma since 2013;

© Michael Bozuk (Oncologist), at Petaluma Valley Hospital and performed a
biopsy on plaintiff in 2013;

e Joel Neal, MD (Oncologist), at Stanford Hospital that examined plaintiff and
referred him to his counsel; and

e Chuong Hoang, MD (Oncologist), at Stanford Hospital that provided a

mesothelioma consultation and developed a treatment plan for plaintiff has

treated him since 2013.

I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct and that this declaration was executed on February 3,

2014, at San Francisco, California.

(Peter H. Cruz

CBM-SP\SF61S9LT-1 5.
CRUZ DECLARATION IN OPPOSITION TO PLAINTIFFS’ MOTION FOR PREFERENTIAL TRIAL DATE — NO. CGC-13-276217Exhibit Aoo Oo FN ODO HW BF WY DB =

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IN. THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
---000---
HAROLD KOEPKE AND NANCY KARIDIS-KOEPKE,
Plaintiffs,
vs. No. CGC13 276217
FORD MOTOR COMPANY, et al.,

Defendants.

VIDEOTAPED
DEPOSITION OF HAROLD KOEPKE

VOLUME I, Pages 1 to 235

Taken before EARLY LANGLEY, CLR, RSA, RMR
CSR No. 3537

January 23, 2014

Aiken Welch Court Reporters
One Kaiser Plaza, Suite 250
Oakland, California 94612
(510) 451-1580/(877) 451-1580
Fax: (510) 451-3797 °

www.aikenwelch.comoO © &O nN DOD oO BF HW YY =

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DEPOSITION OF HAROLD KOEPKE

BE IT REMEMBERED, that pursuant to Notice, and
on January 23, 2014, commencing at the hour. of 10:40
a.m., in the offices of Sheraton Petaluma, 745 Baywood
Drive, Petaluma, California, before me, EARLY LANGLEY,
a Certified Shorthand Reporter, State of California,
personally appeared HAROLD KOEPKE, produced as a
witness in said action, and being by me first duly
sworn, was thereupon examined as a witness in said
cause.
---000~--~-

APPEARANCES
For the Plaintiffs:

JOSEPH D. SATTERLEY

Kazan, McClain, Satterley & Greenwood

55 Harrison Street, Suite 400

Oakland, California 94607
For the Defendant Continental Automotive Systems, Inc.:

EMILY D. BERGSTROM

(Via telephone and in person)

Becherer, Kannett & Schweitzer

1255 Powell Street
Emeryville, California 94608

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23rd, 1962.
MR. SATTERLEY: March --

BY MR. MARKS:

- Q. You're reading from the letter?
A. Yes.
Q. March 27, 1961?
A. 23rd March, 1962.
Q. Does it say from 27th March 19 --
A. Oh, yes, yes, yes.
Q. 27th March 1961 to 23rd --
A. Yes, yes, that's right.
Q. -- March 1962?
A. Yes, yes.
Q. So approximately one year?
A. - Yes.

Q. So your first five months in Australia:
were up in the Snowy Mountains?

A. Uh-huh.

Q. At the hydroelectric project?

A. Yes.

Q. Where did you go for employment after you
finished that work?

A. First when I left the Snowy Mountains I
went on the four weeks trip around Australia.

Q. Okay.

12:43

12:43

12:43

12:44

12:44

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102
A. And then I applied for the job at
Athertons.
Q. Where did you go on your four-week trip
around Australia?
A. We went from Sydney to -- through the -- 12:44
through the bush towards Darvin, through Adelaide,
and then from Adelaide, we went back to the Gold
Coast, traveled along the coast back to Sydney.
Q. Was this by car?
A. Yes. 12:44
Q. And did you camp out?
A. Yes.
Q. And with whom did you make this trip?
A. With two more friends. Actually, three
more friends. 12:44
Q. Did they work with you in the Snowy
Mountains?
A. No.
Q. How did you find them in Australia?
A. One of them I immigrated together with and 12:45
he found the other two.
Q. «I gather that this drive through the bush
was a little different than what you had seen in
Hamburg?

“A. Oh, yes. 12:45

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Q.
you spe!
A.
Q.
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Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.
A.
Q.

A.

Q.
A.
Q.

to work

What are the names of the individuals that
mt the four weeks with?
I only remember one.
What's his name?
Manford Boehnke. 12:45
How do you spell the last name?
B-o-e-h-n-k-e.
Are you still in contact with him?
Yes.
And what was he doing in Australia? 12:45
The same I did.
He was an immigrant there to work?
Yes.
And what was his trade?
Sheet metal worker. . 12:45
Did he also work in the Snowy Mountains?
No.
Where did he work?
He worked in Sydney.
Did you ever work with him? 12:45
Yes.
Where?
At Atherton.
Was he somehow influential in getting you

at Athertons? 12:46

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Q. The supervisor was in charge of other
trades as well?
A. I don't know.
Q. So you wanted to specialize in stainless
steel? 13:04
A. Yes.

Q. And you were looking to emigrate from

Australia?
A. Yes.
Q. Why did you want to leave Australia? 13:05

A. I always wanted to come to the United
States, and this was an opportunity, I thought,
because I spoke enough English -- English, and I
also had saved enough money, which they required
at the time, so I went to the Embassy, the United 13:05
States Embassy, and applied.
Q. For a visa, or for...
A. For a visa.
Q. Work visa?
A. No. For a visa. Immigration visa. 13:05
Q. Were you working at Atherton when you made
this application?
A. No. I was working at Byrnes.
Q. Harry Byrnes?

A. Yes. 13:05

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Q. And Harry Byrnes was another sheet metal
engineer?
A. I don't know if he was an engineer.
Q. What did you do for Harry Byrnes?
A. Sheet metal work. 13:06
Q. What kind of sheet metal work?
A. Pretty much the same again, cabinets.
Q. Where did you fabricate cabinets for Harry
Byrnes?
A. In the sheet metal facility there. 13:06
Q. Did you ever build cabinets for Harry
Byrnes at a location other than its fabrication
shop?
A. No.
Q. And its fabrication shop was on Kent Road 13:06
in Mascot?
A. Yeah --
MR. SATTERLEY: Wait a second. You're
looking at a different document than he's looking
at. He's reading from a document, I think. 13:06
THE WITNESS: Oh.
MR. SATTERLEY: This right here. 0036,
he's reading from that document, Kent Road. If
you know that.

THE WITNESS: Oh, yes. Well, here it says 13:06

120

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STATE OF CALIFORNIA )

) ss.

COUNTY OF ALAMEDA )

I, EARLY LANGLEY, a Certified Shorthand
Reporter, State of California, do hereby certify:

That HAROLD KOEPKE, in the foregoing deposition
named, was present and by me sworn as a witness in the
above-entitied action at the time and place therein
specified;

That said deposition was taken before me at
said time and place, and was taken down in shorthand by

me, a Certified Shorthand Reporter of the State of

California, and was thereafter transcribed into

typewriting, and that the foregoing transcript
constitutes a full, true and correct report of said
deposition and of the proceedings that took place;

IN WITNESS WHEREOF, I have hereunder subscribed my hand

on January 28, 2014.

EARLY L. EY; NO. 3537
State of California

235

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
---000---
HAROLD KOEPKE AND NANCY KARIDIS-KOEPKE,
Plaintiffs,
vs. No. CGC13 276217
FORD MOTOR COMPANY, et al.,

Defendants.

VIDEOTAPED
DEPOSITION OF HAROLD KOEPKE

VOLUME II, Pages 236 to 423

Taken before EARLY LANGLEY, CLR, RSA, RMR
CSR No. 3537

January 24, 2014

Aiken Welch Court Reporters
One Kaiser Plaza, Suite 250
Oakland, California 94612
(510) 451-1580/(877) 451-1580
Fax: (510) 451-3797

www.aikenwelch.com_

oO Oo ON ODO GO BR WwW DN

239

DEPOSITION OF HAROLD KOEPKE

BE IT REMEMBERED, that pursuant to Notice, and
on January 24, 2014, commencing at the hour of 10:34
a.m., in the offices of Sheraton Petaluma, 745 Baywood
Drive, Petaluma, California, before me, EARLY LANGLEY,
a Certified Shorthand Reporter, State of California,
personally appeared HAROLD KOEPKE, produced as a
witness in said action, and being by me previously duly
sworn, was thereupon examined as a witness in said
cause.
~--000---

APPEARANCES
For the Plaintiffs:

CAROLE BOSCH

Kazan, McClain, Satterley & Greenwood

55 Harrison Street, Suite 400

Oakland, California 94607
For the Defendant Continental Automotive Systems, Inc.:

EMILY D. BERGSTROM

Becherer, Kannett & Schweitzer

1255 Powell Street
Emeryville, California 94608

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Did you search for any additional
documents at home after the deposition yesterday
or this morning?

A. No.

Q. Exhibit 9 is a handwritten note with an
address for Mr. James Nash and Manfred Boehnke?

A. Yes.

Q. And Mr. Nash is an individual with whom

you worked in -~ in the automotive gas station and
repair?
A. Yes.

Q. Okay. And Manfred -- and I may have been
saying "Manford" yesterday, but it's Manfred
Boehnke, he was the gentleman with whom you lived
in Newtown?

A. Yes.

Q. And then later in San Francisco?

A. Yes.

Q. And he also was a sheet metal worker; is
that right?

A. Right.

Q. When's the last time you -- I asked you
yesterday when you had spoken last with
Mr. Boehnke.

When have you last seen him?

10:36

10:36

10:36

10:37

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A. In person I've seen him years ago. I
couldn't tell you exactly when.
Q. And, in terms of telephone contact, have
you had just one conversation with him recently,
or has it been more than one? 10:37
A. I usually talk to him once a week.
Q. And how long has that been going on?
A. Maybe for the last ten years.
Q. I think you asked -- you said yesterday
that you had spoken with Mr. Boehnke and asked him 10:37
whether anyone had contacted him; is that right?
A. Yes.
Q. Why did you ask him that?
A. I wanted to make sure that it would be the
right people which contacted him. 10:38
Q. What do you mean by "right people"?
A. Well, maybe that's the wrong phrase. I
wanted to know if it is the lawyers, my lawyers or
it would have been the other party.
Q. I see. Why did you think that someone 10:38
might contact him with respect to your lawsuit?
A. Well.
MS. BOSCH: And don't speak of anything
that is a conversation between you and your

attorneys, so if there's any reason other than 10:38

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Q. You were told in July of last year that
you have a lung problem; is that right?

A. Yes.

Q. When did you first contact an attorney
about that lung condition?

MS. BOSCH: And I'm sorry, can you be more
specific as to what lung condition, Counsel? Are
you asking about his mesothelioma?

MR. MARKS: I'm asking about any condition
related to his lung.

THE WITNESS: I have never contacted any
attorney for this problem.

BY MR. MARKS:

Q. Did you speak to any attorneys other than
the Kazan lawyers about your lung condition?

A. No.

MS. BOSCH: And you don't have to tell him
about any conversation you've had with any
attorney.

THE WITNESS: Okay.

BY MR. MARKS:
Q. I'm not asking for the substance. I'm
asking for the fact of the contact.

Who contacted the Kazan firm if you did

not contact them?

10:58

10:58

10:58

10:58

10:58

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MS. BOSCH: I'm going to object. That
calls for attorney/client-privileged information.
We represent you and your wife, so any
conversation between you and your wife and your
attorneys are privileged, sir, okay? 10:59
MR. MARKS: I'm not asking for the
contents. I'm asking for when the first contact
occurred, and that is discoverable.
MS. BOSCH: You can ask for a date but no
conversations. 10:59
MR. MARKS: That's what I asked. I'm
asking for a date.
THE WITNESS: The date for...
MS. BOSCH: You don't need to raise your
voice, Counsel. 10:59
MR. MARKS: I'm not raising my voice.
THE WITNESS: The date for ~- I'm sorry?
BY MR. MARKS:
Q. When you or someone on your behalf
contacted the Kazan lawyers, the lawyers. that 10:59
represent you?
A. The date, I'd say was about three months
ago.
Q. So that would be November?

A. Yes. 10:59

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Q. Before Thanksgiving?

A. Oh.

Q. Before Halloween?

MS. BOSCH: Asked and answered. Lacks
foundation. Speculation.

THE WITNESS: Somewhere right in between
there.

BY MR. MARKS:

Q. Sometime between October and November,
somebody other than yourself contacted the Kazan
law firm?

A. I --

MS. BOSCH: And, again, please don't
provide any attorney/client-privileged
information. The questions are a little bit
ambiguous as to that.

MR. MARKS: Well, just so we're clear,
Counsel, I'm not going to preface everything.

BY MR. MARKS:

Q. But, Mr. Koepke, I don't want you to
divulge any discussions you've had with your
lawyers, okay?

A. Uh-huh.

Q. None of my questions are designed to get

that.

268

11:00

11:00

11:00

11:00

11:00

Aiken Welch Court Reporters Harold Koepke 01/24/2014oO 86 ON OO oO BR WY HY =

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question to you was designed to give him
information that might help him assist you?
A. No.
Q. What was your understanding as to why
Dr. Neal was asking you about your work history? 11:03
A. He probably wanted to find out where I
caught mesothelioma.
Q. Did you tell Dr. Neal what you had done
for work?
A. Yes. 11:04
Q. And what did you tell him?
A. .I told him that for the 30 -- last 30
years when I worked, I was self-employed in the
service station business and Harold's Automotive
in San Mateo. , 11:04
Q. Did you tell him anything else?
A. I told him also I was employed in Germany
and Australia.
Q. Did you tell him what you did for work in
Germany? 11:04
A. Yes.
Q. And what did you tell him with respect to
that work?
A. I told him I was a sheet metal worker

there. 11:04

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Q. And specifically what did you tell him
about your sheet metal work?
A. Nothing specific.

Q. Did he ask you questions about your sheet

metal work? / a1:

A. Dr. Neal, no.
Q. What did you tell Dr. Neal about your work
in Australia?

A. I don't recall.

Q. Did he ask you details about what you did 11:

in Australia?
A. No.
Q. Did he ask you details about where you

performed your work in Australia?

A. No. Li:

Q. Did he ask you about work with any
particular type of asbestos in Australia?
A. No.

Q. Did he ask you about work around mines?

A. No. 11:

Q. How about openings in the ground like
tunnels, digging?
A. No.

Q. When you were with Dr. Neal, how did the

subject of the Kazan law firm come up? Li:

272

05

05

05

05

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MS. BOSCH: Asked and answered.
THE WITNESS: I'm sorry?
MS. BOSCH: I just said -- I just stated
an objection. I said asked and answered. Sorry.
THE WITNESS: Oh. We talked about the
cancer and the -- he came up with the idea to
pursue this case more by getting in contact with
Kazan law firm.
BY MR. MARKS:
Q. Did he give you their phone number?
A. Yes.
Q. Did he give you any type of written
material?
A. No.
Q. Did he give you a name of a person to
contact?
A. No.
Q. Do you have an understanding as to how
Dr. Neal knew about the Kazan firm?
A. I have no idea.
Q. Did he give you the names of any other
attorneys?
A. No.
Q. Have you spoken with any of your other

doctors about your work history?

273

11:06

11:06

11:06

11:07

11:07

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electrical.

Q. Did he work for you at any other

locations?
A. No.
Q. Who is Jim -- well, you said Jim Nash. 11:43
A. Yes.

Q. He's a former employee?
A. Yes.
Q. You brought Mr. Nash's contact information
today. It's marked as Exhibit 9. 11:43
Is Exhibit 9 your handwriting?
A. Yes.
Q. How long have you had the contact
information for Mr. Nash, the information you gave
me here? 11:44
A. This contact information from him, maybe
six months. It may have changed again. [It
changes quite a few times.
Q. You've had the (530) 229-9149 phone number
for six months? 11:44
A. Yes. That's his cell number.

Q. And his address in Redding, California,

how long --
A. May -- may have changed. I'm not sure.
Q. How long has he lived in Redding? 11:44

Aiken Welch Court Reporters Harold Koepke 01/24/2014i
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MS. BOSCH: Lacks foundation. Calls for

speculation.

THE WITNESS: Eight to ten years.

BY MR. MARKS:

Q. And how long has he lived at the 485 Twin 11:

View Boulevard address?

MS. BOSCH: Lacks foundation. Calls for

speculation.

THE WITNESS: A year.

BY MR. MARKS: ii:

Q. A year?
A. Yes.
Q. And Manfred Boehnke, how long have you had
this contact information for him in Millbrae?
A. 40 years. 11
Q. 40 years?
A. Yes.
Q. Has he been at the Marcello Way address
for the last 40 years?
A. Yes. 11
Q. And you speak with Mr. Boehnke by
telephone; is that right?
A. Yes.

Q. Do you ever call him?

A. Yes. i:

44

44

245

245

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Q. So you have a phone number for him?
A. Yes.
Q. Is there a reason why you did not provide
it on Exhibit 9?
“A. I did. 11:45
MS, BOSCH: It's provided, Counsel. If
you'd read the exhibit, it's right there.
BY MR. MARKS:
Q. Oh, at the bottom?
A. Uh-huh. 11:45
Q. Okay. Is that a home or a cell number?
A. Home.
Q. Lawrence Krasnow, do you have contact
information for him, phone number, address?
A. Yes. But not here. 11:45
Q. How long have you had that information?
A. 30 years.
Q. Do you have contact information for Grant
Tovey?
A. Yes. TI can find it. 11:46
MS. BOSCH: And I just want to state for
the record that we've provided all that
information in the subpoenas that were recently
served.

THE WITNESS: Uh-huh. 11:46

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298
BY MR. MARKS:

Q. How long have you had contact information
for Mr. Tovey, sir?
A. He -- his wife worked for me for 30 years,
so, therefore, 30 years, plus when I retired. 11:46
Q. So approximately 40 years?
A. Yes.

Q. Do you have contact information for Bob

A. Yes. 11:47

Q. Does that include an address and a phone

A. I don't have the address but the phone

number.
Q. And do you know where he lives? 11:47
A. Yes.

Q. Where does he live?
A. In Sebastopol.
Q. How long have you known that he has lived
in Sebastopol? 11:47
A. 25 years. Maybe longer.
Q. How long have you had his phone number?
A. Probably the same time.
Q. 25 years?

A. Yes. 11:47

Aiken Welch Court Reporters Harold Koepke 01/24/2014—

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Q. Do you have contact information for Wayne
Brotze?

A. Only his telephone number.

Q. Do you know which city he lives in?

A. Atascadero.

Q. Do you know what state that's in?

A. California.

Q. And how long have you had his phone

A. Ten years.
Q. Other than Mr. Nash, Mr. Krasnow,
Mr. Tovey, Mr. Segale, Mr. Brotze, and
Mr. Boehnke, are you able to identify the names of
anyone else that has ever worked with you?
A. Yes.
MS. BOSCH: Overbroad.
THE WITNESS: Sorry.
MS. BOSCH: Go ahead.
BY MR. MARKS:
Q. Could you please give me the list of the
names of the people you can identify?
A. The list of the names are all in the
paperwork there. There's dozens and dozens of
names. I don't remember them just like that.

Q. Which paperwork are you referring to?

11:47

11:48

11:48

11:48

11:49

299

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A. I have some names. I could get some

Q. What names would you get?
A. Most of them by first names.
Q. How would you get them? 11:51
A. I have to think about it more and make a
list and give it to you.
Q. Okay. That would be helpful.
A. Fine.
Q. Is there anything you would refer to, to 11:51
help you remember those names?
A. No.
Q. Do you have any books going back to your
school or your apprenticeship?
MS. BOSCH: I'm sorry. Vague and 11:52
ambiguous.
Do you understand?
THE WITNESS: Yes.
MS. BOSCH: What he means by books?
THE WITNESS: Well, there's some in the 11:52
paperwork from Metelmann and...
MS. BOSCH: You mean the paperwork that we
produced --
THE WITNESS: Yes.

BY MR. MARKS: 11:52

Aiken Welch Court Reporters Harold Koepke 01/24/2014= le
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303

Q. There are books in the paperwork from
Metelmann?

A. There are paper -- a paper of the
apprenticeship when I was at Metelmann.

Q. Any other papers, specifically any type of 11:52
books?

A. No.

Q. Do you recognize the name Dillingham
Constructions?

A. No. 11:53

Q. How about Perini?

A. No.

Q. How about John Holland Construction?

A. No.

Q. How about Societe Dumez? 11:53

MS. BOSCH: I'm sorry?
BY MR. MARKS;
Q Societe Dumez?
A. No.
Q. How about Monier-McNamara-Hardeman? 11:53
A No.
Q. How about Thiess Brothers?
A. No.
MS. BOSCH: Can you give us a spelling for

that? 11:53

Aiken Welch Court Reporters Harold Koepke 01/24/2014oO O06 ON DOD OF FF W NY =

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Q. Do you have contact information for
Mr. Branzuela?
A. No.

Q. Do you know where he lives?

Q. Is he listed in your address book?

A. No.

Q. You may put that aside for the moment,
thank you?

A. This?

Q. Yes. Thank you.

MR. MARKS: I want to mark next in order

Exhibit 16 which is the amended notice of
deposition of plaintiff Harold Koepke and request
for production of documents, photographs and
things.

(Whereupon, Exhibit 16 marked

for Identification. }

MS. BOSCH: And do you know if our
objections have been --

MR. MARKS: Your objections, that's No.

Yes.

MS. BOSCH: Thank you, Counsel.
BY MR. MARKS:

Q. I've handed you Exhibit 16.

1.

13:21

13:21

13:22

13:22

13:22

334

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Have you seen that document before today,
just now?
A. This document?
Q. Yes. Please look through it if you could.
A. I don't recall. I don't have a copy of 13:23
it.
MS. BOSCH: That's all right.
BY MR. MARKS:
Q. Do you have any photographs of your family
home in Hamburg? 13:24
A. Yes.
Q. Either home?
A. It's right there.
MS. BOSCH: Counsel, we've produced a
large amount of photographs of Mr. Koepke's family 13:24
home in Hamburg.
BY MR. MARKS:
Q. Other than what you have produced to the
defendants, do you have any photographs of the
family home in Hamburg? 13:24
A. You mean my sister's home?
Q. Your parents’ home?
A. No.
Q. Where you lived.

A. No. 13:24

335

Aiken Welch Court Reporters Harold Koepke 01/24/2014—

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424
STATE OF CALIFORNIA )

) ss.

COUNTY OF ALAMEDA )

I, EARLY LANGLEY, a Certified Shorthand
Reporter, State of California, do hereby certify:

That HAROLD KOEPKE, in the foregoing deposition
named, was present and by me sworn as a witness in the
above-entitled action at the time and place therein
specified;

That said deposition was taken before me at
said time and place, and was taken down in shorthand by
me, a Certified Shorthand Reporter of the State of
California, and was thereafter transcribed into
typewriting, and that the foregoing transcript
constitutes a full, true and correct report of said
deposition and of the proceedings that took place;

IN WITNESS WHEREOF, I have hereunder subscribed my hand

on January 29, 2014.

EARLY LEY; NO. 3537
State of California

Aiken Welch Court Reporters Harold Koepke 01/24/2014Exhibit B©. Oo WD hh BW Ne

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ey’ RPERSRE RSS RSERRBEESH os

Joseph D. Satterley, Esq. (C.S.B. #286890)
Carole Bosch, Esq. (C.S. B. 239790)
KAZAN, McCLAIN, SATTERLEY,
LYONS, GREENWOOD & OBERMAN
A Professional Law Corporation

Jack London Market

55 Harrison Street, Suite 400

Oakland, California 94607

Telephone; (510) 302-1000

Facsimile: (510) 835-4913
cbosch@kazanlaw.com

Attorneys for Plaintiffs

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
-IN AND FOR THE COUNTY OF SAN FRANCISCO

HAROLD KOEPKE AND NANCY KARIDIS-

KOEPKE,
Plaintiffs,
vs.
FORD MOTOR COMPANY, et al.,
_ Defendants.

INTERROGATORY No, 3:

Please state YOUR:

Case No, CGC13-276217

PLAINTIFF'S RESPONSES TO
DEFENDANTS’ STANDARD
INTERROGATORIES TO PLAINTIFF
(PERSONAL INJURY) [SET ONE]
Action Files: December 2, 2013
Trial Date: TBD

a. Full name including first, middle and last names;

b. Date of birth;

c, Age;

d, Place of birth;

e, Address;

f. Height and weight;

g. Social Security number;
h, Kaiser number;

i. Government Serial number;

PLAINTIFFS" RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)yb NH NY NY NY NY WH = _ — —
ew Am A OS F SF be UR AR SOR FS

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d. Occupation,

RESPONSE TO INTERROGATORY No, 3.:

No.
INTERROGATORY No. 4:

For each of YOUR blood relatives (for example: parent, grandparent, sibling, child, aunt,
uncle) whom YOU believe died of either a malignancy (cancer) or pulmonary (lung) disease other
than pneumonia, please state, separately for each person:

a. Full name; . ,

b. Blood relation to YOU (for example: parent, grandparent, sibling, aunt, uncle);

c, Age at death;

d. Date of death;

e, City, county and state where the person died; and

f. The cause of death, as specifically described as possible;

g. Either (1) attach all DOCUMENTS evidencing the information sought in this interrogatory

and its subparts to YOUR answers to these interrogatories or (2) attach disks containing such

“data or (3) describe such DOCUMENTS with sufficient particularity that they may be made

the subject of a request for production of documents. ,
RESPONSE TO INTERROGATORY No. 4,:

Plaintiff objects to this interrogatory on the grounds that it calls for information that is neither
relevant nor calculated to lead to the discovery of admissible evidence. (C.C.P, § 201 7.010.) Further,
it is vague and ambiguous as to what constitutes "blood relatives.” Without waiving said objections,
plaintiffresponds: Kurt Bleick; Uncle; unknown; 1912; Hamburg, Germany; Tuberculosis; none.
INTERROGATORY No. 5:

State as completely as possible the address of each of YOUR residences during YOUR
lifetime and the inclusive dates of each period of such residence.

RESPONSE TO INTERROGATORY No. 5.:
Plaintiff objects to this interrogatory on the grounds that it calls for information that is neither '

relevant nor calculated to lead to the discovery of admissible evidence and to the extent it is

PLAINTIFFS' RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)o 2 YN HR HW Bw DY Ye

= S6

overbroad and seeks privileged information in violation of Plaintiff right to privacy. (C.C.P.

§ 2017.010; see also Smith v, Superior Court (1961) 189 Cal.App.2d 6.) “Notwithstanding and
without waiving these objections, plaintiff responds: Plaintiffs has resided at: 121 Round Ct.,
Petaluma,.CA 95952 since 2003; from 1966-1968 plaintiff resided in San Francisco; from 1969-1974
plaintiff resided in Belmont, CA; from 1974-1982 plaintiff resided in Millbrae, CA; from 1983-2001
plaintiff resided in Redding, CA; and from 2001-2003 plaintiff resided in Redding, CA.
INTERROGATORY No, 6:

State YOUR educational background and identify all institutions attended, including any
apprenticeship courses, or formal on-the-job training and identify all institutions attended, the date
graduated from each institution, and YOUR major course of study and any special scholastic honors
or degrees received.

RESPONSE TO INTERROGATORY Noe. 6.:

Plaintiff objects to this interrogatory on the grounds that it calls for information that is neither
relevant nor calculated to lead to the discovery of admissible evidence and to the extent it is
overbroad and vague as to the meaning of "formal on-the-job training" and "safety classes." (C.C.P.
§ 2017.010.) Notwithstanding and without waiving these objections, plaintiff responds:

Volksschule (High School), Telemannstr., Hamburg, Germany, March 1955, completion;

Apprenticeship Schlosser, Metelmann, Engineering courses, English Language Course,
Rosenallee, Hamburg, Germany, 1960, diploma;

English Courses, History Courtses, San Francisco, CA, completed,
INTERROGATORY No. 7:

State the earliest date that service of the summons and complaint was effected on any
defendant in this case.

RESPONSE TO INTERROGATORY No. 7.:

December 5, 2013
INTERROGATORY No. 8:

Have YOU ever been convicted of a felony? If "yes", please state fully and in detail the date,
place and nature of each such felony conviction. Either (1) attach all DOCUMENTS evidencing the

PLAINTIFFS’ RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)o Oe I DH A BR WN wm

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BSRRRRBRSEPRSESEBRDRBRES SAS

INTERROGATORY No. 25:
Describe the extent to which YOU drank alcoholic beverages during YOUR lifetime,

specifying the particular kind of alcoholic beverages and the quantity € consumed per week over the
period of time such beverages were consumed. :
RESPONSE TO INTERROGATORY No. 25.:

Plaintiff objects to this interrogatory on the grounds that it calls for information that is neither
relevant nor calculated to lead to the discovery of admissible evidence. (C.C.P. § 2017.010.)
Notwithstanding and without waiving said objections, plaintiff responds: Plaintiff consumes wine or
beer with evening meal.

INTERROGATORY No. 26:

For every type of employment that you have ever had, whether self-employed or employed by
others, please complete the following: (If more space is needed, please attach additional sheets
containing the requested information.)

RESPONSE TO INTERROGATORY No. 26.:

Plaintiff objects to this interrogatory to the extent that it calls for information that is neither
relevant nor calculated to lead to the discovery of admissible evidence, (C.C.P. § 2017.010,)
Notwithstanding and without waiving said objections, plaintiff responds:

Employer’s Name and Address Dates of Employment
Modern Piating & Polishing 1962 - 1963
1400 Park

. Emeryville, CA 94608

Duties: Sheet metal pattern maker.

Plaintiff does not claim exposure at this employment.

Employer"s Name and Address Dates of Emplo'
Michel & Pefeffer 1965
1386 San Anselmo Ave.

San Anselmo, CA 94960

Duties: Sheet metal worker.
Plaintiff does not claim exposure at this employment.
itt

PLAINTIFFS’ RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)© 2B NH ww BR ww Ye

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Employer’s Name and Address Dates of Employment
Trayer Engineering Corporation 1965 - 1972

898 Pennsylvania Ave.

San Francisco, CA 94107

Duties: Sheet metal worker

Plaintiff does not claim exposure at this employment.

Employer’s Name and Address Dates of Employment

William Hansberg 1972
Folsom Shell Service

3005
San Francisco, CA 94103

St.

Duties: Service station attendant.

Plaintiff claims exposure at this employment.

Employer’s Name and Address Dates of Employment

Nikkhah Ataollah 1972
Nicks Super Shell

1100 Howard St,

San Francisco, CA 94103

"Duties: Service station attendant.

_ Plaintiff claims exposure at this employment.

Employer’s Name and Address Dates of Employment
Self Employed:

Harold’s Shell Service Station 1972 - 1979

1100 Howard St.

San Francisco, CA 94103

Duties: Service station dealer.

Plaintiff claims exposure at this employment.

Employer's Name and Address tes of Emplovment
7" Street Auto Repair 1974 ~ 1975
1100 Howard St.

San Francisco, CA 94103

Duties: Owner.

Plaintiff claims exposure at this employment.

PLAINTIFFS’ RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)Oo eo WA Hh Bw DB om

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Employer's Name and Address Dates of Employment

Harold’s Automotive 1980 - 2000
839 N. San Mateo Dr.

San Mateo, CA 94401

Duties: Owner.

Plaintiff claims exposure at this employment.

Employer's Name and Address Dates of Employment
Veracom Automotive Group LLC 2001-2003

Branzuela Robert Member

790 N. San Mateo Dr.

San Mateo, CA 94401

Duties: Manager.

Plaintiff's investigation is ongoing as to whether plaintiff was exposed to asbestos at this
employment.
INTERROGATORY No. 27:

Are YOU or have YOU been a member of any labor union, including but not limited to the
Heat, Frost, Insulation and Asbestos Workers Union? If YOUR answer is "yes", state for each such
union membership: :

a. The name of each such international union and its number, along with the local number of"

each such union; and

b. The date and time periods during which YOU maintained membership in such union.

RESPONSE TO INTERROGATORY No. 27.:
Yes, Sheetmetal Union #104, 858 Hinckley Rd., Burlingame, CA; 1972-1980,

INTERROGATORY No. 28:
When did YOU first learn that exposure to asbestos was a potential health hazard?

PO. OINT (0. 28,

, Plaintiff objects this Interrogatory is overbroad and calls for information that is neither
relevant nor calculated to lead to the discovery of admissible evidence. C.C.P. § 2017.010.
Notwithstanding and without waiving these objections, Plaintiffs responds: Plaintiff does not recall
the exact date when he first became aware that exposure to asbestos was a potential health hazard.
‘if.

PLAINTIFFS’ RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)Oo eo NDR HW F&F Bw

NPN YN BPN NR KD De ema
ou A HW BR BN & FS Owe I AA Rw HH SB S

¢. Either (1 attach all DOCUMENTS evidencing the information sought in this interrogatory

to your answers to interrogatories, or (2) attach disks containing such data, or

(3) describe such DOCUMENTS with sufficient particularity that ey may be made the

subject of a request for production of documents.
RESPONSE TO INTERROGATORY No. 53.:

Plaintiffs object to the extent this request seeks settlement demands, offers to compromise,
settlement proposals, payment information, and/or statements made in the course of settlement
negotiations as the information is neither relevant nor reasonably calculated to lead to the discovery
of admissible evidence. C.C.P. § 2017.010; Cal. Evid, Code §§ 210 & 350. Further, private financial
information is worthy of protection in discovery, even when the information sought is relevant to the
litigation. Valley Bank of Nevada v. Superior Court (1975) 15 Cal.3d 652, 656-67; Cobb v. Superior
Caurt (1979) 99 Cal.App.3d 543, 550; Doak v. Superior Court (1968) 257 Cal.App.2d 825, 827-28.
The privacy of a settlement is generally understood and accepted in our legal system, which favors
settlement and therefore supports attendant needs for confidentiality. Hinshaw, Winkler, Draa,
March & Still v. Superior Court (1996) 51 Cal.App.4th 233, 241, citing to Cho v. Superior Court
(1995) 39 Cal.App.4th 113, 124 and Philippine Export & Foreign Loan Guarantee Corp. v. Chuidian
(1990) 218 Cal. App.3d 1058, 1976-77. Notwithstanding and without waiving these objections,
plaintiffs respond: No.

DATED: December ws, 2013 KAZAN, McCLAIN, SATTERELY, LYONS,
GREENWOOD & OBERMAN, A Professional Law
Corporation
By
Carole M. Bosch
Attorneys for Plaintiffs

PLAINTIFFS’ RESPONSES TO STANDARD INTERROGATORIES (PERSONAL INJURY)‘e10)sa2-1000
Fax (G70}636-4019 28

‘CBOGGSN272835.1

*** VERIFICATION TO FOLLOW***} PRGOF OF SERVICE
Re: Harald Koepke & Nancy Karidis-Koepke v Ford Motor Company, et al.
San Francisco Superior Court Case No. CGC13-276217

2
3
4
I declare that, I am employed in the County of Alameda, State of California. J am over the
§ || age of 18 years and not a party to the within action. My business address is 55 Harrison Street,
Suite 400, Oakland, California 94607. On the date stated below, I caused the following
6 | document(s) to be served:
7
8
9

PLAINTIFF’S RESPONSES TO DEFENDANTS’ STANDARD
INTERROGATORIES TO PLAINTIFFS 9PERSONAL INJURY [SET ONE]

by transmitting a true copy:

ALL COUNSEL
[SEE ATTACHED LIST]

via the following method:

XX (By File & Serve Xpress Electronic Service) The document(s) was/were
12 transmitted by electronic service through the File & Serve Xpress System

13 (By Personal Service) By causing to be personally delivered a true copy of the
document as listed above.

I declare under penalty of perjury that the foregoing is true and correct. Executed on
15 || December 26, 2013 at Oakland, California.

16 ‘
17 itherine Boggs

Kazan, MECLAN,
‘SATTERLEY,
25

ex ET
5 Hagwusaw STREST, 97

(C80G38N272506.1SERVICE LiST CASE: Koepke, Harold and Nancy [NE 1512] “ ACTION #: CGC13276217 December 26, 2013 4:16 PM

BERRY & BERRY PH: (510) 835-8330
P.O. Box 16070, Oakland, CA 94610 FAX: (516) 835-5117 -
FOR: DESIGNATED DEFENSE COUNSEL

COUNSEL UNKNOWN
FOR: A.B.C, MOBILE SYSTEMS; A.B.C. MOBILE SYSTEMS sii/pae/et ASSOC BRAKE CO & WESTERN
STATES BRARE; AMERICAN HONDA MOTOR CO, INC.; BELL INDUSTRIES INC. sli/pae/et ROX
AUTOMOTIVE; BELL INDUSTRIES, INC.; BELNORTEL CORPORATION dba A.B.C. MOBILE BRAKE OF
SAN FRANCISCO. . :

COUNSEL UNKNOWN
FOR: BORG WARNER MORSE TEC INC,

COUNSEL UNKNOWN
FOR: BORG WARNER MORSE TEC INC sii/pae/et of BORG- WARNER CORPORATION; BURLINGAME
AUTO SUPPLY; CONTINENTAL AUTOMOTIVE SYSTEMS, INC.; CONTINENTAL AUTOMOTIVE,
SYSTEMS, INC. sii/pac/et CONTINTENTAL TEVAS INC; COOPER INDUSTRIES, LLC; COOPER
INDUSTRIES, LLC sii/pacéet of ABEX CORPORATION; COOPER INDUSTRIES, LLC sii/pac/et of PNEUMO
ABBX, LLC; DON L. MORRIS, INC.) FMC CORPORATION-JOHN BEAN AUTOMOTIVE EQUIPMENT
SERVICE DIVISION; FMC TECHNOLOGIES, INC; FMC TECHNOLOGIES, INC.sli/pac/et JOHN BEAN AUTO
EQUIP SERV DIV OF FMC ; FOLSOM AUTO SUPPLY; FORD MOTOR COMPANY; GENUINE PARTS
COMPANY; H.M. ROYAL, INC.; HONEYWELL INTERNATIONAL INC. tka ALLIED SIGNAL,
INC/si/BENDIX CORP; KELSEY-HAYES COMPANY, LEAR SIEGLER DIVERSIFIED HOLDINGS CORP.:
LEAR SIEGLER DIVERSIFIED HOLDINGS CORP. sii/pac/et of ROYAL INDUSTRIES; LES VOGEL
CHEVROLET COMPANY: METROPOLITAN LIFE INSURANCE COMPANY

COUNSEL UNKNOWN
FOR: MORTON INTERNATIONAL, LLC fka MORTON INTERNATIONAL, INC.

COUNSEL UNKNOWN
FOR: MORTON INTL LLC fka MORTAN INTL INC sii pac ef THIOKOL CORPORATION; NATIONAL
AUTOMOTIVE PARTS ASSOCIATION

COUNSEL UNKNOWN
FOR: PNEUMO ABEX LLC

COUNSEL UNKNOWN
FOR: PNEUMO ABEX LLC sii/pac/et ABEX CORPORATION

COUNSEL UNKNOWN
FOR: ROX AUTOMOTIVE

COUNSEL UNKNOWN .
FOR; SHELL OLL COMPANY; SPECIALTY FOREIGN AUTO PARTS, INC; SPECIALTY FOREIGN AUTO
PARTS,INC sii pac ef SPECIALTY FORE AUTO PARTS

COUNSEL UNKNOWN
FOR; THE HERTZ, CORPORATION

COUNSEL UNKNOWN
FOR: TOYOTA MOTOR SALES, U,S.A., INC.; UNIVERSITY DISTRIBUTORS, INC.

COUNSEL UNKNOWN
FOR: UNIVERSITY DISTRIBUTORS, INC., sii/pas/et DON L. MORRIS, INC.

COUNSEL UNKNOWN
FOR: VOLKSWAGEN GROUP OF AMERICA, INC, W. BERRY HURLEY CORPORATION, 4.
AUTO PARTS

DERAL

GORDON & REES LLP . . . PH: 415-986-3900
275 Battery Street, Suite 2000, San Francisco, CA 94411 FAX: 415-986-8054
FOR: THE BUDD COMPANYSERVICE LIST ‘ CASE: Koepke, Harold and Nancy’ (NE 1512] ACTION #: CGC13276217 * December 26, 2013 4:16 PM

Page Two

SEMPER LAW GROUP, LLP PH: 213-437-9700
330 N. Brand Bivd., Suite 650, Glendale, CA 91203 FAX: 213-596-1466
FOR: PARKER HANNIFIN CORPs!i pac ot EIS BRAKE&IND AUTO ASSOC dba CALI-BLOCK;
PARKER-HANNIFIN CORPORATION

End of Service ListExhibit B-12
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11
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13
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7
18
19
20
21
22
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Kazan, MoCeam,
Sarrercey, = 95
Lyons,
GREENWOOD &
arcoren a 26
‘ConPonatION
Re Lanna Marae
‘58 HARRISON StREET, 27
‘SuiTe 400
Onxiano, CA 84807

10) 302-1000
racistoyeseaers 28

CBOGESH236245.1

Re: Harold Koepke & Nancy Karidis-Koepke v Ford Motor Company, et al.
San Francisco Superior Court Case No. CGC13-276217

VERIFICATION

Harold Koepke declares under penalty of perjury under the laws of the State of California
that the following is true and correct:
: That declarant is a plaintiff in the above-entitled action; that declarant has read
PLAINTIFF'S RESPONSES TO DEFENDANTS' STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY) [SET ONE]
and knows the contents thereof; that the same is true of declarant's own knowledge except as to
those matters stated therein upon declarant's information and belief and as to those matters,
declarant believes it to be true. /
Executed at Petaluma, CA, on January 2, 22014

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rold KoepkeExhibit CPedtendie?
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CLERK OF ne CQURT
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SUPERIOR COURT OF THE STATE OF CALIFORNIA

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COUNTY OF SAN FRANCISCO

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12 | KOEPKE, Plaintiff, PRELIMINARY FACT SHEET/
NEW FILING/ASBESTOS LITIGATION
13 vs.
(See Case Management Order,
14 | FORD MIOTOR COMPANY, et al. filed June 29, 2012)
Defendant.
16
17
18 NOTICE

To NEW DEFENDANTS SERVED IN COMPLEX ASBESTOS LITIGATION IN THE Superior Court
IN AND FOR THE STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO

You have been served with process in an action which has been designated by the Court
as complex litigation pursuant to Standard 3.10 of the Judicial Administration Standards. This
litigation oa the caption “In Re: Complex Asbestos Litigation”, [San Francisco Superior Court
No. 828684].

This litigation is governed by the Case Management Order, filed with this Court on
June 29, 2012, some of which affect the judicial management and/or discovery obligations,
including the responsibility to answer interrogatories ied propounded in the case. You
may contact the Court or Designated Defense Counsel, Berry & Berry, P.O.