On September 29, 2006 a Motion-Secondary was filed involving a dispute between Rodamer, James, Rodamer, Nancy, and All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, Armstrong International, Inc., Asbestos Corporation, Ltd., A.W. Chesterton Company, Buffalo Pumps, Inc., Cleaver Brooks, Cleaver-Brooks, Inc., Crane Co., Crane Co. Individually And As Sii To Chapman Valve, Crown, Cork & Seal, Individually And As, Csr, Ltd., Aka Colonial Sugar Refinery, Does 1-300, Inclusive, Domco Products Texas, L.P, Douglass Insulation Company, Inc., Durabla Manufacturing Company, Elliott Company,, Fairbanks Morse Pump, Fairbanks Morse Pump Corp., Familian Corporation, Familian Corporation Dba Familian Pipe &, Foster Wheeler Llc, Foster Wheeler, Llc, Gardner Denver, Inc., Garlock Sealing Technologies, Llc, Garlock Sealing Technologies, Llc Individually And, General Electric Company, Goulds Pumps, Inc., Grinnell Corporation, Henry Vogt Machine Co., Hill Brothers Chemical Company, Imo Industries Inc.,, Imo Industries, Inc., Ingersoll-Rand Company, International Paper Company, Itt Corporation,, Itt Industries, Individually And As Sii To, J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Kentile Floors, Inc., Leslie Controls, Inc., Lydall, Inc., Lydall, Inc.,, Metex Mfg. Corporation, Owens-Illinois, Inc., Parker Hannifin Corp., Individually And As Sii To, Parker Hannifin Corporation, Plant Insulation Company, Quintec Industries, Inc., Ray L. Hellwig Plumbing, R. F. Macdonald, R.F. Macdonald Co., Soco West, Inc., Sterling Fluid Systems, The Goodyear Tire & Rubber Company, Thomas Dee Engineering Company, Thomas Dee Engineering Company, Inc., Union Carbide Corporation, Uniroyal, Inc., Warren Pumps, Llc, Westburne Supply Inc., Yarway Corporation, for ASBESTOS in the District Court of San Francisco County.
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STEEFEL, LEVITT & WEISS * PRO ?IS2IG NAL CORPORATION » Facsimile: (415) 78a-2015 BR. 3217 FLOOR -SAN FRANCISCO, CA 94111-3714 Telephone: (415) ¥88-G400 ONE EMBARCADERG CENT bo DECLARATION OF VLADISLAV V, LUSKIN IN SUPFOR'T OF MOTION IN LIMINE #6 10 EXCLUDE BARRY W. LLL (State Bar No. 88685} YLADISLAV ¥. LUSKIN (State Bar No. 139759) ELECTRONICALLY STBEFEL, LEVITT & WEISS FILED A Professional Corporation tof Californi One Embarcadero Center, 30th Floor County ce San Francisco” San Franciseo, CA 94111-3719 Telephone: (415) 788-0900 MAY 15 2007 GORDON PARK-LI, Clerk BY: JUANITA D. MURPHY Deputy Clerk. Facsimile: (415) 788-2019 Attorneys for Defendant WESTBURNE SUPPLY INC, SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY O1 SAN FRANCISCO UNLIMITED IL RISDICTION JAMES RODAMER and NANCY Case No, CGC 06 456569 RODAMER, DECLARATION OF VLADISLAV V¥. Plaintiffs, LUSKIN SUPPORT OF MOTION IN LIMINE #6 TO EXCLUDE EVIDENCE v. OFFERED TO SHOW OFPRESSION, FRAUD OR MALICE A.W. CHESTERTON COMPANY, et al., Defendants. TRIAL DATE: April 30, 2007 Date Complaint Filed: September 29, 2006 I, Vladislav V. Luskin , declare: 1. Tam an altorney at law duly acdmitied to practice before all of the courts of | the State of California, I am an attorney of record for defendant WESTBURNE SUPPLY INC. in | this matter. The facts stated herein are based on my own personal knowledge and if called as a witness I could and would testi fy to them. 2. According to the documentation I have reviewed and that has been furnished to plaintiffs, P. E. O’Hair was purchased by Westburne Supply in 1988. I am informed and believe that Westburne Supply did not do business in California before the mid 1980°s. There has been no cvidenes in this case that James Rodamer purchased or used any products from ZCPZLGIBS7HS, l EVIDENCE OFFERED TO} SHOW OPPRESSION, FRAUD OR MALICESTEEFEL, LEVITT & WEISS Westburne Supply. His claims arc that he was exposed to products supplied by P. Li. O° Hair between the years of 1959 to 1973, before Westburne was in California, 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 May 14,2007 at San Francisco, California. Abi f [ La) /s/Vladislav V, Luskin Viadislay V, Luskin’ 20721 SKATER. 2 DECLARATION OF VLADISLAV V. LUSKIN IN SUPPORT OF MOTION IN LIMINE 26 TO EXCLUDE EVIDENCE OFFERED TO SHOW OPPRESSION, FRAUD OR MALICE