On September 29, 2006 a Motion,Ex Parte 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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— - Ww bk Selman Breitman LLP ATTORNEYS AT LAW 28 130863.: 1A6.22997 MARK A. LOVE (SBN 162028) JANICE W. MAN (SBN 209956) ELECTRONICALLY SELMAN BREITMAN LLP 33 New Montgomery, Sixth Floor F ILE D San Francisco, CA 94105 Superior Court of California, Telephone: ( 4] 5) 979-0400 County of San Francisco Facsimile: (415) 979-2099 MAY 16 2007 mlove@selmanbreitman.com GORDON PARK-LI, Clerk jman@selmanbreitman.com BY: JUDITH NUNEZ Deputy Clerk Attorneys for Defendant DOUGLASS INSULATION COMPANY, INC. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION JAMES RODAMER and NANCY CASE NQ.456569 RODAMER, DOUGLASS INSULATION COMPANY, Plaintiffs, INC.’S MOTION IN LIMINE FOR 48 COURT HOUR PRE-DISCLOSURE OF V. : DOCUMENTS AND WITNESSES A.W. CHESTERTON COMPANY, etal., | Date Time Defendants. Dept. : 306 Judge : Hon. Nancy L. Davis Trial Date : April 30, 2007 Complaint Filed: September 29, 2006 Defendant DOUGLASS INSULATION COMPANY, INC. (“DOUGLASS”} hereby moves the Court for an ordcr in limine instructing the plaintiffs to advise all other partics, at Icast 48 court hours in advance, of each witness that it will call at trial and each document that will be referred to, shown to the witness, published to the jury, marked as an exhibit, or moved into evidence. The aforementioned order will advance the interests of judicial economy by allowing the trial to proceed withoui unnecessary interruptions or arguments. Moreover, the parties will be forced to prepare in an orderly manner and thus protect the interests of i DOUGLASS INSULATION COMPANY, INC,.’S MOTION IN LIMINE FOR 48 COURT TIGUR PRE- DISCLOSURE OF DOCUMENTS AND WITNESSESSelman Breitman LLP ATTORNEYS AT LAW uke. 16622997 their clients. The proposed "48 court hours" would be scheduled as follows: Monday- by the end of the court day, counsel must disclose all of Thursday's witnesses and documents. Tuesday- by the end of the court day, counsel must disclose all of Friday's witnesses and documents. Wednesday- by the end of the court day, counsel must disclose all of the following Monday's witnesses and documents; Thursday- by the end of the court day, counsel must disclose all of the following Tuesday's witnesses and documents; Friday- by the end of the court day, counsel must disclose all of the following Wednesday's witness and documents. If counsel wishes to introduce the testimony of the witnesses by the use of prior deposition testimony, counsel is to provide the name of the witness, page and line designations as well as a complete copy of the transcript. DOUGLASS respectfully requests the Court to grant the instant motion in limine to promote judicial economy and expediency, as well as protect the rights of all parties at trial. DATED: May 16, 2007 SELMAN BREIFMAN’LLP / MAN for Defendant ASS INSULATION CO., INC. 2 DOUGLASS INSULATION COMPANY, INC.S MOTION IN LIMINE FOR 48 COURT OUR PRE- DISCLOSURE OF DOCUMENTS AND WITNESSES