Hearing: KENNETH MOSES SR. VS. KAISER GYPSUM COMPANY, INC. et al

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HUGO PARKER, LLP
135 Man STREET
20" FLOOR
San Francisco, CA 94105

Edward R. Hugo [Bar No. 124839]

Amber Lee Kelly [Bar No. 117006] ELECTRONICALLY
HUGO PARKER, LLP FILED

135 Main Street, 20th Floor Supertor Court of Callfornia,
San Francisco, California 94105 County of San Francisco
Telephone: (415) 808-0300 10/07/2015
Facsimile: (415) 808-0333 Clerk of the Court
Email: service@HUGOPARKER.com BY:ALISON Depie Cisne

Attorneys for Defendant
CAHILL CONSTRUCTION CO., INC.

SUPERIOR COURT - STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION

KENNETH MOSES, SR., (ASBESTOS)

Case No. CGC-13-276180
Plaintiff,
JOINDER TO CO-DEFENDANTS GOLDEN
vs. GATE DRYWALL AND PACIFIC COAST
BUILDING PRODUCTS, INC.’S MOTION TO
KAISER GYPSUM COMPANY, INC., et EXCLUDE TESTIMONY OR EVIDENCE OF
al., DR. DONALD BEYER AT TRIAL AND
COURT’S CONSIDERATION OF SANCTIONS
Defendants.
Date: October 13, 2015
Time: 9:00 a.m.

Dept: 503

Complaint Filed: August 21, 2013
Trial Date: August 31, 2015

Please be advised that defendant Cahill Construction, Co., Inc., (‘Cahill') hereby
joins in Defendants Pacific Coast Building Products, Inc. and Golden Gate Drywall's
(herein after 'Co-Defendants’) Motion, on shortened time, to Exclude Testimony or
Evidence of Dr. Donald Breyer at Trial and For Consideration of Sanctions, to be heard at
9:00 a.m., on October 13, 2015, in Department 503 of the San Francisco County Superior
Court, located at 400 McAllister Street, San Francisco, CA, before the Hon. Teri L. Jackson.
The Motion seeks an order barring Dr. Breyer from testifying in the above-referenced
matter and precluding the use, publication, or reliance upon any of Dr. Breyer's notes,

letters or reports regarding Mr. Kenneth Moses, Sr.

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JOINDER TO CO-DEFENDANTS GOLDEN GATE DRYWALL AND PACIFIC COAST BUILDING PRODUCTS, INC.’S MOTION TO
EXCLUDE TESTIMONY OR EVIDENCE OF DR. DONALD BEYER AT TRIAL AND COURT'S CONSIDERATION OF SANCTIONS1 Cahill joins Co-Defendants’ Motion in lieu of filing a duplicate or substantially
2 ||similar Motion to that filed by Co-Defendants and incorparates the moving papers and
3 ||supporting documents of Co-Defendants as its own and as though fully set forth.
4 If for any reason Co-Defendants withdraw the above referenced Motion, the Motion
5 || will be argued by counsel for Cahill, and adopted as its own.
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7 ||Dated: October 6, 2015 HUGO PARKER, LLP
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9 By:  /s/ Amber Lee Kelly
Edward R. Hugo
10 Amber Lee Kelly
Attorneys for Defendant
i CAHILL CONSTRUCTION CO,, INC.
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HUGO PARKER, LLP 2
135MAINSIREET
San F Pinedo oat0s JOINDER TO CO-DEFENDANTS GOLDEN GATE DRYWALL AND PACIFIC COAST BUILDING PRODUCTS, INC.’S MOTION TO
EXCLUDE TESTIMONY OR EVIDENCE OF DR. DONALD BEYER AT TRIAL AND COURT'S CONSIDERATION OF SANCTIONSnN

SO em ND FB Ww

Moses, Kenneth Sr. v. Kaiser Gypsum Company, Inc., et al.
San Francisco Superior Court Case No. CGC-13-276180
File & ServeXpress Transaction No.: 57975391

PROOF OF SERVICE

lam a resident of the State of California, over the age of 18 years, and not a
party to the within action. My electronic notification address is
service@HUGOPARKER.com and my business address is 135 Main Street, 20'
Floor, San Francisco, California 94105. On the date below, I served the following:

TO CO-DEFENDANTS GOLDEN GATE DRYWALL AND PACIFIC COAST
BUILDING PRODUCTS, INC.’S MOTION TO EXCLUDE TESTIMONY OR
EVIDENCE OF DR. DONALD BEYER AT TRIAL AND COURT’S CONSIDERATION
OF SANCTIONS

on the following:

Brayton0Purcell
222 Rush Landing Road ALL DEFENSE COUNSEL
Novato, CA 94945 (via File & ServeXpress service list)

Tel: (415) 898-1555
Fax: (415) 898-1247

x By transmitting electronically via LexisNexis the document(s) listed above as
set forth on the electronic service list on this date before 5:00 p.m.

I declare under penalty of perjury under the laws of the State of California
that the above is true and correct. Executed on October 6, 2015, at San Francisco,

California.
Mana hagenadey
Z

Maria Diazgranados

PROOF OF SERVICE