Party Discovery: HAROLD KOEPKE et al VS. FORD MOTOR COMPANY et al

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                                1 |] Garrett Sanderson III, Bar No. 131026

gsanderson@cbmlaw.com
2|| Peter H. Cruz, Bar No. 220850 ELECTRONICALLY
peruz@cbmlaw.com.
3 || CARROLL, BURDICK & McDONOUGH LLP sopekr iL ED a
Attorneys at Law County of San Francisco
4 |}44 Montgomery Street, Suite 400
San Francisco, California 94104 DEC 4 19 2013
5}; Telephone: 415.989.5900 BY: EDNALEEN JAVIER
Facsimile: 415.989.0932 Deputy Clerk
6
Attorneys for Defendant Volkswagen Group of
7 || America, Inc.
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
10
11 || HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217
KOEPKE,
12 DECLARATION OF GARRETT SANDERSON IIT
Plaintiffs, IN OPPOSITION TO PLAINTIFFS’ EX PARTE
13 APPLICATION RE: MOTION TO QUASH
ve DEPOSITION NOTICE OF HAROLD KOEPKE
14
FORD MOTOR COMPANY, et al., Date: December 19, 2013
15 Time: 11:00 am.
Defendants. Dept.: 503
16
Action Filed: | December 3, 2013
17 Trial Date: None Set
18
19 I, Garrett Sanderson III, declare as follows:
20 1. Imake this declaration based upon my personal knowledge and, if called as a witness,

21 || could and would testify competently to the matters stated here.

22 2. lam a member in good standing of the State Bar of California and am a partner of

23 || Carroll, Burdick & McDonough LLP, attorneys for Volkswagen Group of America, Inc.

24 || (“VWGoA”).

25 3. Lam scheduled to be on vacation starting at noon on Friday, December 20, 2013, until
26 || the morning of January 2, 2014. I did not take a vacation at all in 2012 because of trials scheduled
27 || that year and in February 2013, and J have not yet had a vacation in 2013 because of multiple trials
28 || and a very active case load. | advised plaintiffs’ counsel of this on December 17, 2013. Exhibit A

CARROLL, BURDICK &

MecDonowos LLP CBM-PRODUCTS'SE61 1513-1

SAN FRANCISCO DECL. OF SANDERSON IN OPP. TO PLTFFS’ EX PARTE APP. RE MOTION TO QUASH DEPO. NOTICE OF HAROLD KOEPKE1 |/ to this declaration is a true and correct copy of my email to plaintiffs’ counsel! that references my
2 || impending vacation.
3 4. Plaintiffs filed this action on December 3, 2013. Plaintiffs served VWGoA with the
4 || summons and complaint on or about December 5, 2013. Code of Civil Procedure section
5 |] 2025.210(a) authorizes a defendant to serve a deposition notice at any time after it is served in the
6 |} case.
7 5. Exhibit B to this declaration is a true and correct copy of an email dated December 7,
8 || 2013, from Carole Bosch of the Kazan firm requesting that Berry & Berry serve the deposition

9 || notice on defendants listed on their service list for this case.
10 6, Exhibit C to this declaration is, what I am informed and believe to be, a true and.
11 || correct copy of the service list that the Kazan firm provided to Berry & Berry for purposes of
12 || serving the deposition notice.
13 7. Exhibit D to this declaration is a true and correct copy of the deposition notice for
14 || Harold Koepke as issued and served by Berry & Berry. The proof of service shows that Berry &
15 || Berry sent a copy of this deposition notice to ali defendants on the service list provided by the
16 |] Kazan firm.
17 8. Exhibit E to this declaration is a true and correct copy of the amended deposition notice
18 || for Harold Koepke as issued and served by Berry & Berry. The proof of service shows that
19 || Berry & Berry sent a copy of this deposition notice to all defendants on the service list provided
20 || by the Kazan firm.
21 I declare under penalty of perjury under the laws of the State of California that the

22 || foregoing is true and correct and that this declaration was executed on December 14 2013, at San

23 |) Francisco, California. a
24 a

Garrett Sandé Ti

28

CARROLL, BURDICK &
McDonouga LLP CBM-PRODUCTSISF61 1513-1 2.

ArTOENEL ATLaa"

Sax PRaweisco DECL, OF SANDERSON IN OPP. TO PLTFFS’ EX PARTE APP. RE MOTION TO QUASH DEPO. NOTICE OF HAROLD KOEPKEEXHIBIT ASanderson, Garrett

From: Sanderson, Garrett

Sent: Tuesday, December 17, 2013 4:02 PM

To: ‘CBosch@kazanlaw.com'

ce: Laura Przetak (LauraP @BerryandBerry.com)

Subject: Koepke v. Ford Motor Co., et al. - Notice of Mr. Koepke's Deposition

Dear Ms. Bosch,

(understand you want to file some as yet-to-be-determined motion relative to your client’s deposition, Please advise
me about the nature of the motion and the relief you intend to seek.

Please also be advised that | will be out of the office starting at noon on December 20, 2013, until January 2, 2014. Asa
result, if you wish to meet and confer prior to filing a motion, please immediately initiate efforts regarding your
intended motion so that meet and confer can be completed by noon on December 20,

| have read your written objections and do not see legitimate grounds for a motion to quash the deposition

notice. Neither the date of service, deposition date, deposition start time, place of the deposition, nor manner of
recording testimony violates Article 2 of the Discovery Act. While | am not willing to stipulate to have any motion heard
on shortened time, filing a motion to quash does have the effect of staying the taking of the deposition until the court
has ruled on the motion (Code of Civil Procedure section 2025.410(c)) — provided you have a legitimate ground for filing
a motion to quash.

If you are considering some other form of motion, please advise me of the nature of the motion and the relief you
intend to seek. | may be willing to agree to a postponement of the start date of Mr. Koepke’s deposition so that your
motion can be heard on regular noticed time.

Sincerely,

Garrett

Garrett Sanderson III

Partner

CARROLL, BURDICK & McDONOUGH LLP
44 Montgomery Street, Suite 400

San Francisco, CA 94104

Phone 415.743.2578

Fax 415.989.6932

Fa «

Attorney-client and work-product privilege — do not forward.

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to be used, and it cannot be used, by you for the purpose of (1) avoiding any penalty that may be imposed by the Internal Revenue Service or (2) promating, +

another party any transaction or matter addressed herein.EXHIBIT BFrom: Carole Bosch 
Date: December 7, 2013 3:11:35 PM PST

To: "laurap @berryandberry.com" 
Cc: "Joseph D. Satterley" 
Subject: Koepke -- Plaintiff's deposition

Dear Laura:

We are in receipt of your letter of December 6, 2013 requesting that we produce Mr.
Koepke for deposition on December 19, 2013 at 10:00 a.m. Mr. Koepke is available on
this day and at this time for deposition, continuing on December 21-23. We request
that the deposition take place in our offices in Oakland and that defense counsel
videotape the proceedings. Further, as we recently filed the case on December 3, 2013
and have not yet had the opportunity to serve all defendants, we ask that you
personally serve all defendants on December 9 so notice is effective and all defendants
appear at deposition. We will provide our service list first thing on Monday morning.

| will be out of the office on Monday December 9, so please call my cel! phone if you
have any questions or concerns.

Carole

Carole M. Bosch

Attorney

Kazan, McClain, Satterley, Lyons, Greenwood & Oberman
Jack London Market

55 Harrison Street, Ste 400

Oakland, CA 94607

cbhosch@kazanlaw.com

Phone: (510) 302-1200

Fax: (510) 835-4913

This email message is for the sole use of the intended recipient(s) and may
contain confidential and privileged information. Any unauthorized review, use,
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message. This Email is covered by the Electronic Communications Privacy Act,
18 U.S.C. Sections 2510-2521 and is legally privileged.

To reply to our email administrator directly, send an email to

postmaster@kazanlaw.com

KAZAN, McCLAIN, SATTERLEY, LYONS, GREENWOOD & OBERMAN
A Professional Law Corporation

http:/Avww.kazanlaw.comEXHIBIT CA.B.C. MOBILE SYSTEMS, indv.
and as sii, parent, ao, and equitable
trustee of ASSOCIATED BRAKE
COMPANY and WESTERN STATES
BRAKE MANUFACTURING c/o
Agent; David B. Slater

45 S, Cottage Rd.

Belmont, MA 02478

AMERICAN HONDA MOTOR CO.,
INC.,

efo Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

BELL INDUSTRIES INC., indy. and
as sli, parent, ac, and equitable trustee
of ROX AUTOMOTIVE, c/o Agent:
The Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

BELNORTEL CORPORATION, dba
A.B.C. MOBILE, BRAKE OF SAN
FRANCISCO,

c/o Agent: Gary R. McArthur

7975 Morningside Dr,

Granite Bay, CA 95746

BORGWARNER MORSE TEC
INC.,, indy, and as sii, pazent, ae and
equitable trustee of BORG-WARNER
CORPORATION, c/o Agent: The
Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

BURLINGAME AUTO SUPPLY,
Agent: TBD

CONTINENTAL AUTOMOTIVE
SYSTEMS, INC., indv. and as sii,
pareni, ae and equitable trustee of
CONTINENTAL TIVES, INC., e/o
Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

COOPER INDUSTRIES, LLC, indy.
and as sii, parent, ac and equitable
trustee of PNEUMO ABEX, LLC and
ABEX CORPORATION, c/o Agent:
The Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

DON L. MORRIS, INC.,
c/o Agent: Michael B. Morris
132 Loch Lomond Rd.
Rancho Mirage, CA 92270

FMC CORPORATION-JOHN BEAN
AUTOMOTIVE EQUIPMENT SERVICE
DIVISION, c/o Agent: CT Corporation
System

818 West Seventh Street

Los Angeles, CA 90917

FMC TECHNOLOGIES, INC,, indy,
and as sii, parent, ae, and equitable trustee
of JOHN BEAN AUTOMOTIVE
EQUIPMENT SERVICE DIVISION of
FMC CORPORATION, c/o Agent: CT
Corporation System

818 West Seventh Street

Los Angeles, CA 90017

FOLSOM AUTO SUPPLY,
c/o Agent: Harry Low

328 + 2nd Avenue, #1

Sau Francisco, CA 94118

FORD MOTOR COMPANY,
c/o Agent: CT Corporation System
818 West Seventh Street

Los Angelos, CA. 90017

GENUINE PARTS COMPANY,
c/o Agent: CT Corporation System
818 West Seventh Street
Los Angeles, CA 90017

ELM, ROYAL, INC,,

cfo Agent: Phillip £, Griffin
Fox Rothschild LLP

997 Lenox Dr., Bidg 3
Lawrenceville, NJ 08648

HONEYWELL INTERNATIONAL,
INC,, tka ALLIED SIGNAL, INC, as
Successor-In-Interest to the BENDIX.
CORPORATION, c/o Agent:
CSC-Lawyers Incorporating Service
2710 Gateway Oaks Drive, Suite 150N
Sacramento, CA 95833

KELSEY-HAYES COMPANY, c/o
Agent; CSC-Lawyers Incorporating
Service

2710 Gateway Oaks Drive, Suite 150N
Sacramento, CA. 95833

LEAR SIEGLER DIVERSIFIED
HOLDINGS CoRP.,, indy. and as sii,
parent, ae and equitable trustee of
ROYAL INDUSTRIES, INC., c/o Agent:
The Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

LES VOGEL CHEVROLET
COMPANY,

clo Agent: Philip O. Vogel
617 Occidental Ave,

San Mateo, CA 94402

METROPOLITAN LIFE
INSURANCE COMPANY, c/o Agent:
CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

MORTON INTERNATIONAL, LLC,
formerly known as MORTON
INTERNATIONAL, INC., indy, and as
sii, parent, ac and equitable trustee of
THIOKOL CORPORATION, c/o
Agent: CT Corporation System

251 E, Ohio St, Suite 1100
Indianapolis, IN 46204

NATIONAL AUTOMOTIVE PARTS
ASSOCIATION, c/o Agent: The
Corporation Company

30600 Telegraph Rd, Bingham Farms,
MI 48025

PARKER-HANNIFIN
CORPORATION, indv. and as sii,
parent, ae and equitable trustee of EIS
BRAKE PARTS, CALI-BLOK,
INDUSTRIAL & AUTOMOTIVE
ASSOCIATES, INC., d.b.a.
CALEBLOCK, c/o Agent: CT
Corporation Systen

818 West Seventh Street

Los Angeles, CA 90017

PNEUMO ABEX LLC, indy, and as
sti, parent, ac and equitable trustee of
ABEX CORPORATION, c/o Agent:
Corporation Service Company

271) Centerville Road, Suite 400
Wilmington, DE 19808

ROX AUTOMOTIVE, Agent: TBD

SHELL OL COMPANY,

c/o Agent: CT Corporation System
818 West Seventh Street

Los Angeles, CA 90017

SPECIALTY FOREIGN AUTO
PARTS, INC. indv. and as sii, parent,
ae and equitable trustee of
SPECIALITY FOREIGN AUTO
PARTS, c/o Agent: Geraldina
Horak-Costagtio

57646 Sunnysiope Dr,

Yucca Valley, CA 92284THE BUDD COMPANY, c/o Agent:
CSC - LAWYERS INCORPORATING
SERVICE

601 Abbot Road

East Lansing, MI 48823

THE HERTZ CORPORATION, c/o
Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

UNIVERSITY DISTRIBUTORS,
INC. as indy. and as sii, parent, ae and
equitable trustee of Don L, Morris, Inc.,
c/o Agent; Michael B. Morris,

132 Loch Lomond Rd.

Rancho Mirage, CA 92270

VOLKSWAGEN GROUP OF
AMERICA, INC,, c/o Agent:
CSC-Lawyers Incorporating Service
2710 Gateway Oaks Drive, Suite L50N
Sacramento, CA 95833

TOYOTA MOTOR SALES, U.S.A.,
INC., c/o Agent: CT Corporation
System

818 West Seventh Street

Los Angeles, CA 90017

W. BERRY HURLEY
CORPORATION, d.b.2. FEDERAL
AUTO PARTS,

Agent: Linda Marver

933 Redwood Dr.

Danville, CA 94506EXHIBIT DCOU mw ID

Laura Przetak, Esq., CSB No. 118301
BERRY & BERRY

A Professional Corporation

2930 Lakeshore Avenue

Oakland, CA 94610

Telephone: (510) 250-0200
Facsimile: (510) 835-5117
laurap@berryandberry.com

Designated Defense Counsel

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217
KOEPKE,
NOTICE OF DEPOSITION OF PLAINTIFF
Plaintiffs, WAROLD KOEPKE AND REQUEST FOR
PRODUCTION OF DOCUMENTS,
v. PHOTOGRAPHS AND THINGS

FORD MOTOR COMPANY; et al.,

Defendants.

TO PLAINTIFFS AND THEIR. ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT Defendants will take the oral deposition by the
stenographic method of plaintiff Harold Koepke on January 7, 2014, starting at 10:00 a.m., before
a certified court reporter, at Carroll, Burdick & McDonough LLP, 44 Montgomery Street, Suite
400, San Francisco, California 94104, pursuant to Code of Civil Procedure section 2025,010 et
seq. Pursuant to Code of Civil Procedure section 2025,220(a)(5), the instant visual display of
testimony also may be utilized during Mr. Koepke’s deposition.

Pursuant to Code of Civil Procedure section 2025.220(a)(4), plaintiff Harold Koepke is
required to produce the following documents, materials, photographs and things at the
commencement of the deposition:

1. A copy of Mr. Koepke’s Social Security earnings records that identify each

employer or period of self-employment, the years and/or quarters worked, and the amount of any
CBM-PRODUCTSISF610397-1

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSwithholdings for the period covering his first employment that withheld Social Security taxes
through the end of 2005,

2. All MILITARY WRITINGS (the term “MILITARY,” as used in this deposition
notice, means the United States Air Force, Army, Coast Guard, Marines, Merchant Marines, or
Navy; and the term “WRITING” or “WRITINGS,” as used in this deposition notice means a
writing as that term is defined. by Evidence Code section 250) and records pertaining to Mr.
Koepke, including all enlistment records, records showing the bases or ships he was stationed at or
on and the period he was assigned to each, records of any promotions or demotions, records of
discharge including the term of discharge (e.g., honorable), and records pertaining to any service
in the military reserves.

3. All photographs of Mr. Koepke while he served in the MILITARY, of any ship he
served aboard, of any equipment he worked on or around, and of any base he served on or at

which he was stationed for basic training, duty or otherwise,

4, All yearbooks, picture books, photo books, crew books, and any other WRITING
that shows or depicts any ship Mr. Koepke was assigned to or served aboard, or any base to which
he was assigned or was stationed at, and other people who served abcard the ship or at the base at
any period when he did.

5. All WRITINGS that evidence, list, or identify the names and any CONTACT
INFORMATION (the term “CONTACT INFORMATION,” as used in this deposition notice,
means the address, landline telephone number, cellphone telephone number and/or email address)
of anyone Mr. Koepke knew or served with in the MILITARY,

6. All WRITINGS constituting, evidencing or pertaining to any claim to the United
States Veterans’ Administration, United States Government, or the MILITARY concerning,
pertaining or relating to any exposure to asbestos, carcinogenic chemicals, or hazardous materials
of any kind, as well as all WRITINGS constituting, evidencing or pertaining to any response to
such a claim.

7 A copy of Mr. Koepke’s birth certificate.

8. A copy of Mr. Koepke’s marriage certificate to Nancy Karidis-Koepke.
CBM-PRODUCTSISE610397+1 2.

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGS9, All photographs of anyone who was in the wedding party (e.g.. groomsmen or
bridesmaids, best man, and maiden of honor) for your marriage to Nancy Karidis-Koepke.

10. All WRITINGS that identify the name and CONTACT INFORMATION for
anyone who was in the wedding party for your marriage to Nancy Karidis-Koepke, as well as all
WRITINGS that are needed to refresh your recollection concerning their names and CONTACT
INFORMATION.

11. All photographs that depict Mr, and Mrs. Koepke.

12. Acopy of Mr. Koepke’s marriage certificate to anyone he wed prior to Nancy
Karidis-Koepke.

13. All photographs of anyone who was in the wedding party (e.g.. groomsman or
bridesmaids, best man, and maiden of honor) for your marriage to anyone you wed prior to Nancy
Karidis-Koepke,

14, All WRITINGS that identify the name and CONTACT INFORMATION for

anyone who was in the wedding party for your marriage to anyone before you married Nancy
Karidis-Koepke, as well as all WRITINGS that are needed to refresh your recollection concerning
their names and CONTACT INFORMATION.

15. , A copy of all WRITINGS pertaining to a divorce, separation or annulment of any

martiage involving Mr, Koepke prior to his marriage to Nancy Karidis-Koepke.

16. All WRITINGS that are sufficient to provide the name and CONTACT
INFORMATION any former spouse of Mr. Koepke, as well as all WRITINGS that are needed to
refresh his recollection regarding their names and CONTACT INFORMATION.

17, All WRITINGS, including any address books and telephone books, that are
sufficient to provide the address for cach residence that Mr. Koepke resided in from the time of his
birth until the present day, as well as all WRITINGS that are needed to identify the dates he lived
in each residence or to refresh his recollection concerning the dates he resided in each,

18. All photographs that depict Mr. Koepke with any person to whom he was married
prior to his marriage to Nancy Karidis-Koepke.

19. All photographs of each residence that Mr, Koepke ever resided in.

CBM-PRODUCTSISF610397-1 3.

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSI A vw BF ww

20. All WRITINGS that are sufficient to provide the name and CONTACT
INFORMATION for any neighbor you knew when you lived at any of the residences you have
lived in, as well as all WRITINGS needed to refresh your recollection concerning their names and
CONTACT INFORMATION,

21, All WRITINGS - including but not limited to building permits, contracts, plans and
photographs — pertaining to or evidencing any demolition, construction, improvements to, or
renovation of any residence Mr. Koepke has lived in that occurred during the time he lived there;
the persons, firms or companies that performed any such work; and the brand, manufacturer and
supplier of any materials that were used; as well as all WRITINGS that are sufficient to refresh his
recollection regarding any demolition, construction, improvements to, or renovations of any
residence he has lived in that occurred while he lived there including the names and CONTACT
INFORMATION for the persons, firms or companies that performed the work and the brand,
manufacturer and supplier of any materials that were used.

22. All WRITINGS that are sufficient to identify the names of Mr. Koepke’s parents,
the dates of their respective deaths, and the causes of their respective deaths, as well as all
WRITINGS that are sufficient to refresh his recollection concerning this information.

23. All WRITINGS that are sufficient to identify the names and CONTACT
INFORMATION for each of Mr. Koepke’s siblings, as well as all WRITINGS that are sufficient
to refresh his recollection about their names and CONTACT INFORMATION.

24, The most recent photograph that Mr. Koepke has of each of his siblings.

25. All WRITINGS that evidence any degree Mr. Koepke received (e.g., high school
diploma, associate’s degree, undergraduate degree, post-graduate degree), as well as all
WRITINGS that are sufficient to refresh his recollection concerning the name of any high school,
trade school, junior or community college, college or university, and post-graduate institution Mr.
Koepke attended at any time, including the name of it, the address, the dates he attended, his
curriculum of study, the date of any degree or certificate he received, and any major or minor area

of study.

(CBM-PRODUCTSISP610397-1 4.

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGS

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26. Mr. Koepke’s high school yearbook, as well as any yearbook he received, obtained
or purchased from any other school, trade school, community or junior college, college or
university, or post-graduate institution,

27. All WRITINGS that evidence or identify anyone Mr. Koepke attended school with
that he considered a friend at any time and their CONTACT INFORMATION, as well as all
WRITINGS that are sufficient to refresh your recollection about the names and last known address
and telephone number of anyone you went to school with, at any time, with whom you were
friends at school and anytime prior or after attending school.

28. All WRITINGS that sufficient to identify the name and CONTACT
INFORMATION of each doctor Mr, Koepke has had since he was 30 years of age, as well as all
WRITINGS that are sufficient to refresh his recollection about their names and last known

addresses,
29. All WRITINGS pertaining to any diagnoses of lymphoma or cancer made of Mr.
Koepke at any time prior to his diagnosis with mesothelioma, as well as all WRITINGS that are

sufficient to refresh his recollection about any such diagnosis,

30. All WRITINGS pertaining to any treatment Mr. Koepke received at any time for
lymphoma or any form of cancer prior to his diagnosis with mesothclioma, as well as all
WRITINGS that are sufficient to refresh his recollection concerning that treatment.

31. All photographs of Mr. Koepke during any hospitalization that involved the
diagnosis of or treatment for any form of cancer or lymphoma,

32. All photographs of Mr. Koepke during a period he was treated for any form of
cancer or lymphoma.

33. All WRITINGS pertaining to Mr. Koepke’s employment from the time he was 16
years old to the present, including all WRITINGS that identify the name and address of the
employer, his position, his job duties, the sites where he worked, and the names CONTACT
INFORMATION for any of his co-workers, supervisors, employees, company officers, or
business owners, as well as all WRITINGS that are sufficient to refresh his recollection

concerning the name and address of each employer he has had from the time he was 16 years old

(CBM-PRODUCTSISF510397-1 5.

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSto the present, the addresses where he worked for each, his position, his job duties, and the identity
and CONTACT INFORMATION for any of his former employees, co-workers, supervisors or
owners.

34. All photographs of Mr. Koepke at work or performing any job.

35. All photographs of any person Mr, Koepke ever worked with, whether in a civilian
or MILITARY capacity,

36, All WRITINGS pertaining to Mr. Koepke’s employment at a Shel! service station
in San Francisco, as alleged in the complaint, including the address of the service station, his
position, and his job duties, and the names and last known addresses of anyone else who worked
there at any time when he did.

37. All photographs of the Shell service station where Mr. Koepke previously worked,
including all photographs of Mr. Koepke that were taken at that Shell station, and all photographs
of anyone who worked at that Shell service station when he did.

38. All WRITINGS that identify or pertain to any motor vehicle Mr. Koepke worked.
on at any Shell service station, or that was worked on when he worked there, including all work
orders, invoices, receipts and parts orders.

39. All photographs of any motor vehicle Mr. Koepke worked on at any Shell service
station, or that was worked on when he worked there.

40, All WRITINGS evidencing or identifying the owner of at any Shell service station
Mr. Koepke worked at, including all WRITINGS that identify any CONTACT INFORMATION
for the owner of any Shell service station that employed Mr. Koepke,

41. All WRITINGS evidencing or memorializing any information provided by federal
or Cal OSHA, investigations and citations of or to the Shell service station when Mr. Koepke
worked there,

42, All account ledgers for any Shell service station Mr. Koepke worked at.

43, All WRITINGS evidencing any workers’ compensation claim, or claim to the State
of California, made by or on behalf of Mr. Koepke as a result of working at any Shell service

station.
CBM-PRODUCTSISFSL0397-1, ~6-

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSDw ow

44. All WRITINGS pertaining to Mr. Koepke’s ownership or employment at Harold’s
Automotive, as alleged in the complaint, including the address of the business, the form of
business (¢.g., corporation, sole proprietorship, etc.), his position, and his job duties, and the
names and CONTACT INFORMATION for anyone else who worked there at any time when he
did, as well as all WRITINGS that are necessary to refresh Mr. Koepke’s recollection concerning
the names and CONTACT INFORMATION of anyone who owned or worked at Harold’s
Automotive,

45, All WRITINGS that identify or pertain to any motor vehicle Mr. Koepke worked
on at Harold’s Automotive, or that was worked on when he worked there, including all work
orders, invoices, receipts and parts orders.

46. Ail photographs of any motor vehicle Mr. Koepke worked on at Harold’s
Automotive, or that was worked on when he worked there.

47, All photographs of Mr. Koepke working at Harold’s Automotive.

48. All photographs of any employees, co-workers, or owners of Harold’s Automotive.

49, All formation documents for Harold’s Automotive, including articles of formation
or incorporation, if Mr. Koepke ever had an ownership interest, direct or indirect, in Harold’s
Automotive.

50, All WRITINGS, videos and other information received from federal or Cal OSHA.
by Harold’s Automotive, as well as all WRITINGS evidencing or pertaining to any citation by
OSHA or investigation by OSHA that occurred at Harold’s Automotive while Mr. Koepke owned
it or worked there.

$1. All account ledgers, books and records for Harold’s Automotive during the period
Mr. Koepke had an ownership interest in it or worked there.

52, All WRITINGS sufficient to identify the name and CONTACT INFORMATION
for any person or firm that provided accounting or auditing services at any point in time to
Harold’s Automotive during the period that Mr. Koepke worked there or had an ownership

interest, direct or indirect, in Harold’s Automotive, as well as all WRITINGS sufficient to refresh

(CBM-PRODUCTSIS7610397-1 7.

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSCo DW A HW

Mr. Koepke’s recollection concerning the identity and locations of any person or firm and the
period during which any such person or firm provided such services,

53. All WRITINGS evidencing any workers’ compensation claim, or claim to the State
of California, made by or on behalf of Mr. Koepke as a result of working at Harold’s Automotive,

54, All WRITINGS evidencing or pertaining to any claim that has been submitted by
ot on behalf of either plaintiff to any bankruptcy trust asserting injury from exposure to asbestos,
including all WRITINGS evidencing or pertaining to any response to such claim, any inquiries
about the claim or the grounds for the claim, and any payment on any such claim.

55, All brakes, clutches, and gaskets that Mr. Koepke ever removed from any motor
vehicle that he has or has under his control.

56. All brakes, clutches and gaskets for any motor vehicle that Mr. Koepke has in his
possession,

57. All shop manuals, parts manuals, owner’s manuals that he has ever read, consulted
or used,

58, All WRITINGS evidencing or pertaining to the make, model, and model year of
any motor vehicle Mr. Koepke has ever owned or leased.

59. All photographs of any motor vehicle Mr. Koepke has ever owned or leased.

60. All WRITINGS evidencing any work Mr. Koepke has performed on any motor
vehicle he has ever owned or leased, including work orders, invoices, parts orders and receipts for
parts.

61. All photographs of any parts Mr. Koepke has removed from or installed on or in
any motor vehicle.

62. All WRITINGS pertaining to any motor vehicle Mr. Koepke has ever worked on
(other than at the Shell service station and Harold’s Automotive), including work orders, invoices,
parts orders, and receipts.

63, All photographs of any motor vehicle that Mr, Koepke has ever worked on (other

than at the Shell service station and Harold’s Automotive).

CBM-PRODUCTSSF610397-1 -8-

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSOo me LD AD

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64. All WRITINGS constituting or evidencing any settlement agreement Mr. Koepke
has entered into, or which has been entered into on his behalf, on the alleged basis of exposure to
asbestos, any hazardous chemical, or any hazardous substance of any kind, as well as all
WRITINGS needed for Mr. Koepke to refresh his recollection concerning the identity, terms and
parties to each such agreement.

65. All WRITINGS constituting or evidencing an agreement not to sue a person or
entity of any kind or type, whether made by Mr. Koepke or by his counsel that is used for the
benefit of Mr. Koepke, including ali WRITINGS that identify the name of any such person or
entity, the consideration provided by such person or entity in consideration for Mr. Koepke’s or
his attorneys’ agreement not to sue each such person ar entity.

66, All WRITINGS sufficient to identify the name of any lawyer or law firm, and
his/her/its CONTACT INFORMATION, that has represented Mr, Koepke in any forum, except in
this action, to recover damages or compensation as a result of any exposure to asbestos.

67. All WRITINGS that evidence, identify or relate to any exposure to asbestos by Mr.
Koepke, including exposures to asbestos from sources or products manufactured or supplied by
persons, companies or entities that are not named as defendants in this action, as well as all
WRITINGS that are sufficient to refresh Mr. Koepke’s recollection concerning any such
exposures or products and the identity of the manufacturer or supplier of them.

68. All WRITINGS that evidence any damages Mr. Koepke has sustained as a result of

allegedly being diagnosed with mesothelioma,

| Dated: December4 2013 BERRY & BERRY
‘L

Designated-Defense Counsel

CBM-PRODUCTS\SF610397-1 -9-

NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION OF
DOCUMENTS, PHOTOGRAPHS AND THINGSPROOF OF SERVICE BY MAIL
(CCP SECTION 1013-2015)

Tam employed in the County of Alameda, over the age of 18 years, and not a party to the
within action. My business address is in care of Berry & Berry, 2930 Lakeshore Avenue,
Oakiand, California 94610. I am readily familiar with Berry & Berry’s practice for collection

and processing of documents for mailing with the United States Postal Service.

On Deemer 4 , 2013, I served the attached NOTICE OF TAKING

DEPOSITION AND REQUEST FOR PRODUCTION OF DOCUMENTS,
PHOTOGRAPHS AND THINGS of HAROLD KOEPKE on the following entities to said
action by placing for collection and mailing on said date, following ordinary business practices,
a true copy thereof in a sealed envelope in the mail room of Berry & Berry for deposit, postage
thereon fully prepaid, with the United States Postal Service at Oakland, California, addressed as

follows:

Kazan McClain Satterley Lyons, See Entities on Attached Service List
Greenwood & Oberman

Jack London Market,

55 Harrison Street, Suite 400

Oakland, CA 94607

Fax No: 510-835-4913

I declare under penalty of perjury that the foregoing is true and correct and that this
declaration was executed on __ Desember 4G, 2013 at Oakland, California.Page 1 oft BERRY AND BERRY SERVICE LIST Asof — 12/09/2013

FAX NUMBER
CASE NAME: KOEPKE, HAROLD/ NANCY V. FORD MCTOR COMP = SFSC CGC-13-276217 KAZAN M45338.ASB
PLTF COUNSEL NAME
KAZAN KAZAN MCCLAIN ABRAMS LYONS ET, AL. :
|
M4538,ASB CARROLL, BURDICK & MCDONOUGH oo
44 MONTGOMERY STREET, SUITE 400 SAN FRANCISCO, CA 94104 (415)989-0932

VOLKSWAGEN OF AMERICA, INC.A.B.C, MOBILE SYSTEMS, indy.
and as sii, parent, ac, and equitable
trustee of ASSOCIATED BRAKE,
COMPANY and WESTERN STATES
BRAKE MANUFACTURING c/o
Agent; David B. Slater

45 S. Coulage Ra.

Belmont, MA 02478

AMERICAN HONDA MOTOR CO.,
INC,

c/o Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

BELL INDUSTRIES INC.,, indy. and
as sil, parent, ac, and equitable trustee
of ROX AUTOMOTIVE, c/o Agent:
‘The Corporation Trust Company

1209 Orange Street

‘Wilmington, DE 19801

BELNORTEL CORPORATION, dba
A.B.C. MOBILE BRAKE OF SAN
FRANCISCO,

cfo Agent: Gary R. McArthur

7975 Morningside Dr.

Granite Bay, CA 95746

BORGWARNER MORSE TEC
INC., indy, and as sii, parent, ae and
equitable trustee of BORG- WARNER
CORPORATION, c/o Agent: The
Corporation Trust Company

1209 Orange Street

‘Wilmington, DE 19801

BURLINGAME AUTO SUPPLY,
Agent: TBD

CONTINENTAL AUTOMOTIVE
SYSTEMS, INC., indy, and as sii,
parent, ae and equitable trustee of
CONTINENTAL TEVES, INC, c/o
Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

COOPER INDUSTRIES, LLC, indv.
and as sii, parent, ac and equitable
trustee of PNEUMO ABEX, LLC and
ABBX CORPORATION, c/o Agent:
The Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

DON L. MORRIS, INC.,
c/o Agent: Michael B, Morris
£32 Loch Lomond Rd.
Rancho Mirage, CA 92270

EMC CORPORATION-JOHN BEAN
AUTOMOTIVE EQUIPMENT SERVICE
DIVISION, c/o Agent: CT Corporation
System

818 West Seventh Street

Los Angeles, CA 90017

FMC TECHNOLOGIES, INC,, indy.
and as sii, parent, ae, and equitable trustee
of JOHN BEAN AUTOMOTIVE
EQUIPMENT SERVICE DIVISION of
FMC CORPORATION, ¢/o Agent: CT
Corporation System

818 West Seventh Street

Los Angeles, CA S0G{7

FOLSOM AUTO SUPPLY,
c/o Agent: Harry Low

328 - 2nd Avenue, #1

San Francisco, CA 94118

FORD MOTOR COMPANY,
c/o Agent: CT Corporation System
818 West Seventh Street

Los Angeles, CA. 90017

GENUINE PARTS COMPANY,
c/o Agent: CT Corporation System
818 West Seventh Street
Los Angeles, CA 90017

HLM, ROYAL, INC.,

c/o Agent: Phillip i. Griffin
Fox Rothschild LLP

997 Lenox Dr., Bldg 3
Lawrenceville, NI 08648

HONEYWELL INTERNATIONAL,
INC, fka ALLIED SIGNAL, INC., as
Successor-In-Interest to the BENDIX
CORPORATION, c/o Agent:
CSC-Lawyers incorporating Service
2710 Gateway Oaks Drive, Suite 150N
Sacramento, CA 95833

KELSEY-HAYES COMPANY, e/o
Agent: CSC-Lawyers Incorporating
Service

2710 Gateway Oaks Drive, Sutte 150N
Sacramento, CA 95833

LEAR SLEGLER DIVERSIFIED
HOLDINGS CORP, indv, and as sii,
parent, ae and equitable trustee of
ROYAL INDUSTRIES, INC., c/o Agent:
The Corporation Trust Company

1209 Orange Street

Wilmington, DE 19801

LES VOGEL CHEVROLET
COMPANY,

c/o Agent: Philip O. Vogel
617 Occidental Ave.

San Mateo, CA 94402

METROPOLITAN LIFE
INSURANCE COMPANY, c/o Agent:
CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

MORTON INTERNATIONAL, LLC,
formerly known as MORTON
INTERNATIONAL, INC., indy, and as
sii, parent, ae and equitable trustee of
THIOKOL CORPORATION, c/o
Agent: CT Corporation System

231 E, Ohio St, Suite 1100
Indianapolis, IN 46204

NATIONAL AUTOMOTIVE PARTS
ASSOCIATION, c/o Agent: The
Corporation Company

30600 Telegraph Rd. Bingham Farms,
MI 48025

PARKER-HANNIFIN
CORPORATION, indy. and as sii,
parent, ae and equitable trustee of EIS
BRAKE PARTS, CALI-BLOK,
INDUSTRIAL & AUTOMOTIVE
ASSOCIATES, INC,, d.b.a.
CALT-BLOCK, ¢/o Agent: CT
Corporation System

818 West Seventh Street

Los Angeles, CA 90017

PNEUMO ABEX LLC, indy, and as
sii, parent, ac and equitable trustee of
ABEX CORPORATION, c/o Agent:
Corporation Service Company

2711 Centerville Road, Suite 400
Wilmington, DE 19808

ROX AUTOMOTIVE, Agent: TBD

SHELL OIL COMPANY,

c/o Agent: CT Corporation System
818 West Seventh Street

Los Angeles, CA 90017

SPECIALTY FOREIGN AUTO
PARTS, INC. indy. and as sii, parent,
ae and equitable trustee of
SPECIALITY FOREIGN AUTO
PARTS, c/o Agent: Geraldina
Horak-Costagtio

57646 Sunnyslope Dr,

Yuova Valley, CA 92284THE BUDD COMPANY, c/o Agent:
CSC - LAWYERS INCORPORATING
SERVICE

601 Abbot Road

Bast Lansing, MI 48823

THE HERTZ CORPORATION, c/o
‘Agent: CT Corporation System

818 West Seventh Street

Los Angeles, CA 90017

UNIVERSITY DISTRIBUTORS,
ENC. as indy. and as sil, parent, ae and
equitable trustee of Don L, Morris, Inc.,
cfo Agent: Michael B. Morris,

132 Loch Lomond Rd.

Rancho Mirage, CA 92270

VOLKSWAGEN GROUP OF
AMERICA, INC., c/o Agent:
C8C-Lawyers Lacorporating Service
2710 Gateway Oaks Drive, Suite 150N
Sacramento, CA 95833

TOYOTA MOTOR SALES, U.S.A.
INC., c/o Agent: CT Corporation
System

818 West Seventh Street

Los Angeles, CA 90017

W. BERRY HURLEY
CORPORATION, d.b.a, PEDBRAL
AUTO PARTS,

Agent: Linda Marver

933 Redwood Dr.

Danville, CA 94506EXHIBIT ELAURA PRZETAK, ESQ. CSB NO.118301
BERRY & BERRY

A Professional Corporation

2930 Lakeshore Avenue

Oakland, California 94610

Telephone: (510) 250-0200

Designated Defense Counsel

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

HAROLD KOEPKE and NANCY KARIDIS- | Case No. CGC-13-276217
KOEPKE,
AMENDED NOTICE OF DEPOSITION OF

Plaintiffs, PLAINTIFF HAROLD KOEPKE AND REQUEST
FOR PRODUCTION OF DOCUMENTS,
v. PHOTOGRAPHS AND THINGS
FORD MOTOR COMPANY; et al.,
Defendants.

TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE THAT Defendants will take the oral deposition by the
stenographic method of plaintiff Harold Koepke on January 7, 2014, starting at 10:00 a.m., before
a certified court reporter, at Carroll, Burdick & McDonough LLP, 44 Montgomery Street, Suite
400, San Francisco, California 94104, pursuant to Code of Civil Procedure section 2025.010 et
seq. Pursuant io Code of Civil Procedure section 2025.220(a)(5), the instant visual display of
testimony also may be utilized during Mr. Koepke’s deposition. The deposition will continue
from day-to-day until completed, excluding weekends and holidays.

For those parties wishing to participate by telephone, the dial in number is as follows: 888
~ 632 - 5950; passcode: 47758.

Pursuant to Code of Civil Procedure section 2025.220(a)(4), plaintiff Harold Koepke is
required to produce the following documents, materials, photographs and things at the

commencement of the deposition:

CBM-PRODUCTSISF611 175-1

AMENDED NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KORPRE AND REQUEST FOR PRODUCTION
OF DOCUMENTS, PHOTOGRAPHS AND THINGS0 BTA Hw RB WwW He

ne me
N = oS

13

1 A copy of Mr. Koepke’s Social Security earnings records that identify each
employer or period of self-employment, the years and/or quarters worked, and the amount of any
withholdings for the period covering his first employment that withheld Social Security taxes
through the end of 2005.

2. All MILITARY WRITINGS (the term “MILITARY,” as used in this deposition
notice, means the United States Air Force, Anmy, Coast Guard, Marines, Merchant Marines, Navy
or Reserves for any branch of the armed services; and the term “WRITING” or “WRITINGS,” as
used in this deposition notice means a writing as that term is defined by Evidence Code section
250) and records pertaining to Mr. Koepke, including all enlistment records, records showing the
bases or ships he was stationed at or on and the period he was assigned to each, records of any
promotions or demotions, records of discharge including the term of discharge (e.g., honorable),
and records pertaining to any service in the military reserves.

3. All photographs of Mr. Koepke while he served in the MILITARY, of any ship he
served aboard, of any equipment he worked on or around, and of any base he served on or at
which he was stationed for basic training, duty or otherwise.

4, All yearbooks, picture books, photo books, crew books, and any other WRITING
that shows or depicts any ship Mr. Koepke was assigned to or served aboard, or any base to which
he was assigned or was stationed at, and other people who served aboard the ship or at the base at
any period when he did.

5, All WRITINGS that evidence, list, or identify the names and any CONTACT
INFORMATION (the term “CONTACT INFORMATION,” as used in this deposition notice,
means the address, landline telephone number, cellphone telephone number and/or email address)
of anyone Mr, Koepke knew or served with in the MILITARY.

6. All WRITINGS constituting, evidencing or pertaining to any claim to the United
States Veterans’ Administration, United States Government, or the MILITARY concerning,
pertaining or relating to any exposure to asbestos, carcinogenic chemicals, or hazardous materials
of any kind, as well as all WRITINGS constituting, evidencing or pertaining to any response to

such a claim.
CBM-PRODUCTS\SF611175-1 ~2~

AMENDED NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION
OF DOCUMENTS, PHOTOGRAPHS AND THINGS7. A copy of Mr. Koepke’s birth certificate.

8. A copy of Mr. Koepke’s marriage certificate to Nancy Karidis-Koepke.

9. All photographs of anyone who was in the wedding party (e.g.. groomsmen or
bridesmaids, best man, and maiden of honor) for your marriage to Nancy Karidis-Koepke.

10. All WRITINGS that identify the name and CONTACT INFORMATION for
anyone who was in the wedding party for your marriage to Nancy Karidis-Koepke, as well as all
WRITINGS that are needed to refresh your recollection concerning their names and CONTACT
INFORMATION.

11. All photographs that depict Mr. and Mrs. Koepke.

12. Acopy of Mr. Koepke’s marriage certificate to anyone he wed prior to Nancy
Karidis-Koepke.

13. All photographs of anyone who was in the wedding party (e.g.. groomsman or
bridesmaids, best man, and maiden of honor) for your marriage to anyone you wed prior to Nancy
Karidis-Koepke.

14. All WRITINGS that identify the name and CONTACT INFORMATION for
anyone who was in the wedding party for your marriage to anyone before you married Nancy
Karidis-Koepke, as well as all WRITINGS that are needed to refresh your recollection concerning
their names and CONTACT INFORMATION.

15. A copy of all WRITINGS pertaining to a divorce, separation or annulment of any
marriage involving Mr. Koepke prior to his marriage to Nancy Karidis-Koepke.

16. All WRITINGS that are sufficient to provide the name and CONTACT
INFORMATION any former spouse of Mr. Koepke, as well as all WRITINGS that are needed to
refresh his recollection regarding their names and CONTACT INFORMATION.

17. All WRITINGS, including any address books and telephone books, that are
sufficient to provide the address for each residence that Mr. Koepke resided in from the time of his
birth until the present day, as well as all WRITINGS that are needed to identify the dates he lived

in each residence or to refresh his recollection concerning the dates he resided in each.

CBM-PRODUCTSISF6!1175-1 3

AMENDED NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION
OF DOCUMENTS, PHOTOGRAPHS AND THINGSeo OW YU DA FW NY KB

VN Nb N YN RN Nw eB Re Re Re
eS yr AM SB YW YH |&F Soe IAA A REO HAS

18. All photographs that depict Mr. Koepke with any person to whom he was married
prior to his marriage to Nancy Karidis-Koepke.

19. All photographs of each residence that Mr. Koepke ever resided in.

20. All WRITINGS that are sufficient to provide the name and CONTACT
INFORMATION for any neighbor you knew when you lived at any of the residences you have
lived in, as well as all WRITINGS needed to refresh your recollection concerning their names and
CONTACT INFORMATION.

21. All WRITINGS - including but not limited to building permits, contracts, plans and
photographs ~ pertaining to or evidencing any demolition, construction, improvements to, or
renovation of any residence Mr. Koepke has lived in that occurred during the time he lived there;
the persons, firms or companies that performed any such work; and the brand, manufacturer and
supplier of any materials that were used; as well as all WRITINGS that are sufficient to refresh his
recollection regarding any demolition, construction, improvements to, or renovations of any
residence he has lived in that occurred while he lived there including the names and CONTACT
INFORMATION for the persons, firms or companies that performed the work and the brand,
manufacturer and supplier of any materials that were used.

22. All WRITINGS that are sufficient to identify the names of Mr. Koepke’s parents,
the dates of their respective deaths, and the causes of their respective deaths, as well as all
WRITINGS that are sufficient to refresh his recollection concerning this information,

23. All WRITINGS that are sufficient to identify the names and CONTACT
INFORMATION for each of Mr. Koepke’s siblings, as well as all WRITINGS that are sufficient
to refresh bis recollection about their names and CONTACT INFORMATION.

24. The most recent photograph that Mr. Koepke has of each of his siblings.

25. All WRITINGS that evidence any degree Mr. Koepke received (e.g., high school
diploma, associate’s degree, undergraduate degree, post-graduate degree), as well as all
WRITINGS that are sufficient to refresh his recollection concerning the name of any high school,
trade school, junior or community college, college or university, and post-graduate institution Mr.

Koepke attended at any time, including the name of it, the address, the dates he attended, his
CBM-PRODUCTSISF611 175-1 -4.

AMENDED NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION
OF DOCUMENTS, PHOTOGRAPHS AND THINGSa

Oo om IY A

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curriculum of study, the date of any degree or certificate he received, and any major or minor area
of study.

26, Mr. Koepke’s high school yearbook, as well as any yearbook he received, obtained
or purchased from any other school, trade school, community or junior college, college or
university, or post-graduate institution.

27. All WRITINGS that evidence or identify anyone Mr. Koepke attended school with
that he considered a friend at any time and their CONTACT INFORMATION, as well as all
WRITINGS that are sufficient to refresh your recollection about the names and last known address
and telephone number of anyone you went to schoo! with, at any time, with whom you were
friends at school and anytime prior or after attending school.

28. All WRITINGS that sufficient to identify the name and CONTACT
INFORMATION of each doctor Mr. Koepke has had since he was 30 years of age, as well as all
WRITINGS that are sufficient to refresh his recollection about their names and last known
addresses.

29. All WRITINGS pertaining to any diagnoses of lymphoma or cancer made of Mr.
Koepke at any time prior to his diagnosis with mesothelioma, as well as all WRITINGS that are
sufficient to refresh his recollection about any such diagnosis.

30. All WRITINGS pertaining to any treatment Mr. Koepke received at any time for
lymphoma or any form of cancer prior to his diagnosis with mesothelioma, as well as all
WRITINGS that are sufficient to refresh his recollection concerning that treatment.

31. All photographs of Mr. Koepke during any hospitalization that involved the
diagnosis of or treatment for any form of cancer or lymphoma.

32. All photographs of Mr. Koepke during a period he was treated for any form of
cancer or lymphoma.

33. All WRITINGS pertaining to Mr. Koepke’s employment from the time he was 16
years old to the present, including all WRITINGS that identify the name and address of the
employer, his position, his job duties, the sites where he worked, and the names CONTACT

INFORMATION for any of his co-workers, supervisors, employees, company officers, or
CBM-PRODUCTS\SFE11175«1 -5~

AMENDED NOTICE OF DEPOSITION OF PLAINTIFF HAROLD KOEPKE AND REQUEST FOR PRODUCTION
OF DOCUMENTS, PHOTOGRAPHS AND THINGSbusiness owners, as well as all WRITINGS that are sufficient to refresh his recol