Party Discovery: WINCO WINDOW COMPANY INC., A CORPORATION VS. PROGRESS GLASS CO. INC., A CALIFORNIA CORPORATION et al

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                                1 |} Mark I. Schickman (CSB #62653)
Cathleen S. Yonahara (CSB #203802)
2 || FREELAND COOPER & FOREMAN LLP

150 Spear Street, Suite 1800 ELECTRONICALLY
3 || San Francisco, California 94105
Telephone: (415) 541-0200 a a ta,
4) Facsimile: (415) 495-4332 County of San Francisco
Email: schickman@freelandlaw.com
5 yonahara@freelandlaw.com 02/17/2016
BY:VANESSA WU
6 || Attorneys for Defendant and Cross-Complainant Deputy Clerk
PROGRESS GLASS COMPANY, INC.
7 {| and Defendant NIBBI BROS., INC.
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
10] WINCO WINDOW COMPANY, INC., a CASE NO.: CGC 14-537120
Corporation,
i DEFENDANT AND CROSS-
a v. COMPLAINANT PROGRESS GLASS
3 12 COMPANY, INC.'S AND DEFENDANT
Zz PROGRESS GLASS CO., INC., a California NIBBI BROS. ASSOCIATES, INC.'S
S _ 913] Corporation; NIBBI BROS, INC. a California DESIGNATION OF JOHN CAMPBELL
aes Corporation; LIBERTY MUTUAL DEPOSITION TESTIMONY RE: TRIAL
& % 3!4|| INSURANCE CO. a Surety Company; and EXHIBIT 398
&@ BE DOES | to 100, inclusive,
a 7 S15
ago Defendants.
& 816
° 2
gis
aenll Complaint filed: January 31, 2014
Zs Trial date: January 19, 2016
Ss 718
3 19 AND RELATED CROSS-ACTION.
fe
20
21 DEFENDANT AND CROSS-COMPLAINANT PROGRESS GLASS COMPANY, INC.

22 || ("Progress") and DEFENDANT NIBBI BROS. ASSOCIATES, INC. ("Nibbi") submit their
23 || designation of deposition testimony of deponent John Campbell, taken on August 25, 2015 and
24 || December 16, 2015, re: Trial Exhibit 398, to be used at trial, as detailed below, pursuant to San
25 || Francisco Superior Court Local Rule 6.2.

26 Progress and Nibbi specifically reserve the right to use all or any portion of the deposition
7 || testimony designated by any other party. Progress and Nibbi further reserve the right to use any

2g || portion of any deposition testimony for impeachment or rebuttal herein.

NIBBI BROS. ASSOCIATES, INC.'S DESIGNATION OF JOHN CAMPBELL DEPOSITION TESTIMONY
RE: TRIAL EXHIBIT 398; Case No, CGC-14-537120
400237754}FREELAND COOPER & FOREMAN LLP.

150 Spear Street, Suite 1800

nN a

San Francisco, California 94105

a

19

Deposition of John Campbell, Taken August 25, 2015

Excerpts:

103:6-113:21

Deposition of John Campbell Taken December 16, 2015

Excerpts:

8:25-14:3

17:3-32:7

61:20-74:23

76:11-77:3

78:19:82:10

93:13-101:15

Dated: February (, 2016 FREE AND COOPER & FOREMAN LLP

“” MARK I. SCHICKMAN

Attorneys for Defendant and Cross-Complainant
PROGRESS GLASS COMPANY, INC.

and Defendant NIBBI BROS., INC.

By:

DEFENDANT AND CROSS-COMPLAINANT PROGRESS GLASS COMPANY, INC.'S AND DEFENDANT
NIBBI BROS. ASSOCIATES, INC.'S DESIGNATION OF JOHN CAMPBELL DEPOSITION TESTIMONY
RE: TRIAL EXHIBIT 398; Case No. CGC-14-537120

{00237754}1 CERTIFICATE OF SERVICE

Iam employed in the City and County of San Francisco, State of California. I am over the age
3 of eighteen and not a party to the within action; my business address is 150 Spear Street, Suite 1800,
San Francisco, California 94105.

On February 17, 2016 I served the foregoing document described as follows:
DEFENDANT AND CROSS-COMPLAINANT PROGRESS GLASS COMPANY, INC.'S

6 AND DEFENDANT NIBBI BROS. ASSOCIATES, INC.'S DESIGNATION OF JOHN
CAMPBELL DEPOSITION TESTIMONY RE: TRIAL EXHIBIT 398

7
8 by placing a true and correct copy thereof enclosed in a sealed envelope addressed to the party(ies) of
record whose name(s) and address(es) appear below:
9
10 David F. Myers
Wolkin Curran, LLP
ll 555 Montgomery Street, Suite 1100
D San Francisco, CA 94111

7 Attorney for Plaintiff, Winco Window Company,
Ine.

(4 BY HAND-DELIVERY IN OPEN COURT

(J [BY E-MAIL or ELECTRONIC TRANSMISSION] Based on a court order or agreement of the
parties to accept service by e-mail or electronic transmission, I caused the documents to be sent
to the persons at the email addresses listed above. I did not receive within a reasonable time after
the transmission, any electronic message or other indication that the transmission was
unsuccessful.

19 >] [BY MAIL - CCP § 1013a] I caused such sealed envelope with postage thereon fully prepaid to

be placed in the United States mail at San Francisco, California, for collection and mailing to the

20 office of addressee(s) on the date shown herein following ordinary business practice.

San Francisco, Cal

FREELAND COOPER & FOREMAN LLP

21 [X] [STATE] I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.

23 Executed on February 17, 2016 at San Francisco, California, <--->

24 lene Cae

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