Exhibit,Appendix: CHARLES BOUDREAUX et al VS. ADVOCATE MINES, LTD et al

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John Langdoc, Esq. (SBN 235509)
BARON & BUDD, P.C.

3102 Oak Lawn Avenue, Suile 1100
Dallas. Texas 75219

Telephone: 214/521-3605
Facsimile: 214/520-1181

Carolin K. Shining, Esq. (SBN 201140)
Eric Brown, Esq. (SBN229622}

Roger Gold, Esq. (SBN 214802)
BARON & BUDD, P.C.

8501 Wilshire Blyd., Suite 305

Beverly Hills, CA 90211

Telephone: 310/289-7821

Facsimile: 310/289-7895

Attorneys for Plaintiffs

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

JUL 16 2007
GORDON PARK-LI, Clerk
BY: EDNALEEN JAVIER-LACSON
Deputy Cler

SUPERIOR COURT GF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO- UNLIMITED JURISDICTION

CHARLES BOUDREAUX, et al.

Plaintifiis),

V8,

ADVOCATE MINES, LTD., et al.

Delendants.

_l]-

CASE NO: CGC-07-274029

DECLARATION OF ROGER GOLD
AND EXHIBITS A-D

Hearing Date: July 26, 2007

Time: 9:30 am.
Dept.: 206
Complaint Filed: January 12, 2007

Tnal Date: n/a

[Filed concurrently with Plaintiffs’ Notice of
Motion and Motion For Preferential Trial
Setting; Memorandum of Points and
Authorities, Declaration of Roger Gold,
Declaration of Dr. Robert Fallat; Proposed
Order; Exhibits A-D filed in support of
Declaration of Roger Gold]

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EXHIBITSDECLARATION OF ROGER GOLD

1, ROGER GOLD, declare:

1. am an attorney licensed to practice law before all the courts of the State of California.
‘Those matters stated herein are true to my own personal knowledge, except for those matters stated
upon information and belief, and as to those matters, I believe them to be true.

2. Lam an associate at BARON & BUDD. P.C., a law firm based in Dallas, Texas and
Beverly Hills, California, retained by Plaintiff Charles Boudreaux to prosecute the instant action.
Plaintiff filed this action on January 12, 2007, by reason of Plaintiff Charles Boudreaux’s diagnosis
of malignant mesothelioma.

3. Mr. Boudreaux is 55 years old and is in fragile health as a result of his mesothelioma.
Thelieve that his interests in the instant lawsuil will be substantially prejudiced if he does not receive
apreferential trial date because he is likely to die soon or become otherwise incapable of participating
in legal proceedings due to physical and mental limitations.

4 On January 18, 2007, Plaintiffs served alf Defendants with Plaintifis’ responses to

Standard Interrogatorics. ‘These responses included but were not limited to the following:

a. Detailed work history sheets

b. A list of Mr. Boudreaux’s physicians

¢.  Allist of Mr. Boudreaux’s hospitalizations

d. __Plaintiff'smedical expert report diagnosing Mr. Boudreaux with mesothelioma.
5. All medical records in Plaintifis’ possession were directly served on Defense Liaison

Counsel, Berry & Berry, P.C., on April 11, 2007 and again on July 10, 2007.

6. Plaintiff's deposition was completed on May 3, 2007. Plaintiff's wife’s deposition will
be scheduled and should be completed before August 30, 2007.

% As shown by the concurrently filed Declaration of Robert Fallat, M.D., there is
substantial medical doubt that Mr. Charles Boudreaux will survive beyond the next four months.

Declaration of Robert Fallat, M.D., is attached as Exhibit “A.”

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NOLICE OF MOTION FOR PRET

ENTIAL. TRIAL. SETTINGJul 13 07 1210p

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8, Attached as Exhibit “B” is Plaintiffs’ Responses to Standard Interrogatories, served on
all parties on January 18, 2007. These responses include Plaintiffs’ list of Physicians, Hospitals, Work
and History Sheets.

9. Attached as Exhibit “C” is Plaintiffs’ GO140 Correspondence, sorved on all parties on
July 11, 2007

10. Plaintiffs appeared ex parte on July 13,2007 and obtained an Order shoriening time to
have this motion heard. Attached hereto as Exhibit “

”” is a tue and correct copy of the Order
granting Plaintiffs’ ex parte application and setting 2 July 26, 2007 hearing date and associated briefing
schedute for the motion.

{ declare under penalty of perjury under the laws of the State of California that the foregoing
is tue and correct.
Dated: July /2 2007.

BG cee

foger Gold, Declare

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NOTICE OF MOTION FOR PREFERENTIAL TRIAL SETTING

RECEIVES TIME tU.. 23. 9: 57MEXHIBIT A

[Filed in support of Declaration of Roger
Gold]SONORA eR wWH a

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John Langdoc, Esq. (SBN 235509)
BARON & BUDD, P.

3102 Oak Lawn ‘Aven, Suite 1100
Dallas, Texas 75219

Telephone: 214/521.3605
Facsimile: 214/520.1181

Carolin K. Shining, Esq. (SBN 201140)
Eric Brown, Esq. (SBN229622)

Roger Gold, Esq. (SBN 214802)
BARON & BUDD, P.!

8501 Wilshire Blvd., Suite 305
Beverly Hills, CA 96211

Telephone: 310/289-7821

Facsimile: 310/289-7895

Attorneys for Plaintiffs,
SUPERIOR COURT OF THE STATE OF CALIFORNIA
OR THE COUNTY OF SAN FRANCISCO,

CHARLES BOUDREAUX, ef al. ) Case No.: CGC-07-274029
)
Plaintiffs, } DECLARATION OF
} ROBERT FALLAT, M.D. IN SUPPORT
vs, } OF PLAINTIFF'S MOTION FOR
) ‘TRIAL PREFERENCE
ADVOCATE MINES, LTD.. et al. )
) Dept:
Defendants. } Complsint Filed: 1/12/2007
} Trial Date:
2

J, Robert Fallat, M.D., declare as follows:

1. Tam a physician duly licensed to practice in the State of California. My
office address is $9 Wildomar St., Mill Valley, California. I have personal knowledge of
the below facts. As to those facts based on information and belief, I believe them to be
true.

2. Lama physician (ret.) specializing in pulmonary medicine with the
California Pacific Medical Center (the “Center”) in San Francisco, California. I serve as a

Consultant in Pulmonary Diseases. I am an Associate Clinical Professor of Medicine at the

Ni CUIENSBIBOUDREALX.CFnee: Deserain wt
DECLARATION OF ROBERT FALLAT 19.University of California, San Francisco School of Medicine and Associate Rescarch
Member at the California Pacific Medical Center Research Institute. | was Medical
Director of Pulmonary Physiclogy and Research at the Center from 1969 to 1997. I was
Medical Director of Pulmonary Fellowship at the Center from 1976 to 1991. I was Chief
of the Division of Pulmonary and Critical Care Medicine at the Center from 1969 to 1993.
obtained my medical degree from the University of California, San Francisco in 1960. I

completed my internship at Upstate New York Medical Center, NY, a Division of
Syracuse, in 1961. I performed my initial residency at N.E, Deaconers Hospital, Boston,
in 1962, I then served in the U.S. Air Force as a Flight Surgeon ftom 1962 to 1964. I then
completed my residency at Bellvue Hospital, Columbia Med Svc NY, from 1964 to 1966.
Finally, 1 undertook a Pulmonary Fellowship at C-U Research Institute of University of
California, San Francisco, from 1966 to 1969_

3. Thave spoken to Charles Boudreaux, and have reviewed the medical
records relating to his recent diagnosis and treatment. My opinions and observations
below are stated within a reasonable degree of medical probability or certainty.

4. Mr. Boudreaux is a 55- year old man who first complained to his general
physician in June 2006, of shortness of breath and tightness of the chest. Mr. Boudreaux
also developed a cough, and his symptoms progressively worsened. A CT of the chest
performed June 20, 2006 showed a right pleural effusion. A thoracentesis was performed
the same day removing one liter of bloody fluid. Cytology was negative for malignant
cells.

5. On August 08, 2006, there was a re-accumulation of fluid. Accordingly,
another thoracentesis was performed removing another liter of yellowish pleural fluid.
Cytology was negative for malignant cells. Mr. Boudreaux also underwent a bronchoscopy
on August 11, 2006 and pathology revealed benign fibrosis.

6. Mr. Boudreaux went to the emergency room September 03, 2006 secondary

to severe shortness of breath and pleuritic chest pain not relieved with Percocet. The

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possibility of mesothelioma was discussed due to his asbestos oxposure. A chest CT
revealed a loculated pleural effusion with a thickened pccl on the pleura of the lung.

7. On September 07, 2006, Mr, Boudreaux underwent a right thoracotomy
with decortication of the right pleural cavity as well as wedge resections of right upper and
right middle lobes.

8. Pathology was positive for poorly differentiated epithelioid tumor.
Genzyme Immunohistochemistry analysis results were positive for CK5-6 and WT-1 and
negative for CD15. Findings supportive of mesothelial origin.

9. Mr. Boudreaux returned to the operating room for an exploratory
thoracotomy with biopsies where an extra pleural intrapericardial pneumonectomy was
performed September 12, 2006. A partial pericardectomy with reconstruction and total
resection of the diaphragm with reconstruction was also performed.

10. Immunostains were positive for Calretinin and on September 27, 2006 a
diagnosis of mesothelioma of right lung and diaphragm and pleural fibrosis was made.

11, Mr. Boudreaux was discharged September 26, 2006 with Home Health
sorvices and 5/325 mg Percocet and 75 meg Fentanyl patch for pain.

12. During a surgical follow up visit September 29, 2006, Mr. Boudreaux was
found to have a low heart rate, and O2 sats in the 80's. Mr. Boudreaux was placed on
continuous oxygen at 2 liters / min.

13. Mr. Boudreaux came to the emergency room October 07, 2006 with chest
wall pain and lower extremity edema. He was admitted and treated for atrial fibrillation
and respiratory decompensation. He was evaluated overnight in MICU October 14, 2006
for possible respiration pneumonitis and again October 17, 2006 for A-fib. Mr. Boudreaux
was eventually discharged home November 03, 2006.

14. Mr. Boudreaux continued to suffer from shortness of breath and edema. He

also developed localized cellulitis with drainage at surgical site.

1p CLIENTSIS:DOUDREADE CF atal Dethroned
DECLARATION OF ROBERT FAIVAr. ALD.ONOM RYH A

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15, On January 31, 2007, Mr. Boudreaux consulted with an oncologist and it
was decided at that time not to pursue chemotherapy.

16. ‘On March 22, 2007, Mr, Boudreaux once again came to UC Davis Hospital
complaining of extreme right-sided pressure, weight loss, and nausea and vomiting. He
was discharged on March 27, 2007, and prescribed morphine and oxycontin.

17. Mr. Boudreaux continues o struggle with a staff infection at thoracotomy
invision site and is now required to see an infectious disease doctor.

18. Mesothelioma is a tumor thet typically originates in the pleura, but also
may affect the abdominal lining or peritoneum. Malignant mesothelioma is a terminal
disease with no known cure. Treatment options are limited and are generally accepted as
only able to extend life fora short period of time with a low rate of success.

19, Mr. Boudreaux’s health is expected to continue to decline due to his
terminal cancer and within a reasonable degree of medical probability, a cure cannot be
expected, His health is likely to continue to deteriorate and his symptoms will continye to
‘worsen end he will require pain management and oxygen for symptoms related to his
mesothelioma,

20. In my medical opinion, Mr. Boudreaux suffers from asbestos-related
malignant mesothelioma with a poor prognosis. It has been approximately six months
since Mr. Boudreaux was diagnosed with toesothelioma, and based on his current health,
there is a substantial medical doubt that he will survive more than four months from the
date of this declaration.

Tdeclare under penalty of perjury under the laws of the State of Califomia that the
foregoing is true and correct as reviewed and Signed on the date below in Mill Valley, CA.

Date: July 72, 2007

‘DECLARATION OF ROBERT FLAT. 0.EXHIBIT B

[Filed in support of Declaration of Roger
Gold]| [John Langdoc, Esq. (SBN 235509)
BARON & BUDD. P.-C.

213102 Oak Lawn Avenue, Suite 1100

Dallas, Texas 75219

~ | Telephone: 214/521-3605

Facsimile: 214/520-1181

5|Carolin K, Shining, Esq. (SBN 201140)
Eric Brown, Esq. (SBN229622)
6|BARON & BUDD, PC.

9465 Wilshire Blvd., Suite 460

Beverly Hills, CA 90212

Telephone: 310/860-0476

Facsimile: 310/830-0480

~

° Attomey for Plaintiffs, CHARLES BOUDREAUX AND DEBORAH BOUDREAUX
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
CHARLES BOUDREAUX and Case No.: CGC-07-274029

"3 DEBORAH BOUDREAUX,
PLAINTIFF CHARLES BOUDREAUX’

ANSWERS TO DEFENDANTS’
STANDARD INTERROGATORIES
TO PLAINTIFF

Plaintiffs,
vs

ADVOCATE MINES, LTD., et al, (Personal Injury), Set 1

Defendants.
PROPOUNDING PARTY: Defendants
20) RESPONDING PARTY. CHARLES BOUDREAUX

21)SET NUMBER: One

22
23
24
I
25,
26
|. zi- S_CURSTSIrMeHnREACNE
2 PLAINTIFF CHARLES BOUDREAUX” ANSWERS TO DEFENDANTS: STANDARD|

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1y

26
7

RESPONSES

STANDARD INTERROGATORY NO. t.
Please state YOUR

A. Full name including first, middle and last names:
Date of birth;

Age,

Place of birth;

Address;

Height and weight;

Social Security number;

Kajser number,

Government Serial number;

Military Serial number;

Driver's license number and state;

All of the names by which YOU have been known:
Highest grade level of school completed:

Current spouse’s name;

Spouse's date of birth,

Date of current marriage;

Spouse's current address;

Spouse's occupation/employer;

Name(s) of any former spouse(s);

Date(s) of any former marviage(s); and

Place, date and circumstances under which any marriage(s) was (were) dissolved or
terminated

CHP ROVOZEOAOH- ZOUMOAS

RESPONSE TO STANDARD INTERROGATORY NO. 1.
Charles Joseph Boudreaux

January 17, 1952

35

New Orleans, Louisiana

13323 Gina Drive, Lockeford, California 95237
614", 195 Ibs.

437-286-7738

Not applicable

Not applicable

437-86-7738

CA N9366572

Charles Joseph Boudreaux, Charlie

Completed one (1) year of college in California
Deborah Boudreaux

October 24, 1954

August 30, 1980

SOLZET RSH roONmoaaE

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PLAINTIFF CHARLES BOUDREAUX” ANSWERS TO DEFENDANTS" STANDARD
INTERROGATORIFS TO PLAINTIFF (PERSONAI, INJURY). SEF 126

27

Q 13323 Gina Drive, Lockeford, California 95237
R— Office Manager in Stockton, California

S. Victoria Bourg,

T. Approximately late 1960s to early 1970s

U, Divorced in Louisiana

STANDARD INTERROGATORY NO. 2. For each child (cither natural or adopted) of any
marriage, state:

Name,

Date of birth:

Whether natural or adopted,

Address;

Occupation; and

Whether the child is living or dead.

mmMOADS

RESPONSE TO STANDARD INTERROGATORY NO. 2.
Theresa Boudreaux Baldwin

June 14, 1975

Natural

105 Maplewood, Covington, Louisiana 70433
Homemaker

=r OORS

SUAD ‘Ave either of YOUR natural parents alive? If
YOUR answer is "yes. please state for each parent:

A. Name of parent;

B. Current age;

C. Any history of cancer or respiratory disease; and

D. Occupation.

RESPONSE TO STANDARD INTERROGATORY NO. 3.
A. Geraldine Boudreaux, Mother

B. Age early 70s

CC. Asbestos-related disease

D. Not applicable

STANDARD INTERROGATORY NO. 4. For each of YOUR blood relatives (for example:

parent, grandparent, sibling, child, aunt, uncle) whom YOU believe died of either a malignancy
(cancer) or pulmonary (lung) disease other than pneumonia, please state, separately for each
person:

A. Fullname,

-3- sot

PLAINTIFF CHARIES BOUDREAUX: ANSWERS TO DEFENDANTS: STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1Blood relation to YOU (for example: parent, grandparent, sibling. aunt, uncle);
‘Age at death;

Date of death.

City, county and state where the person died; and

The cause of death, as specifically described as possible,

Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to YOUR answers to these interrogatories or (2) attach disks
containing such data or (3) describe such DOCUMENTS with sufficient particularity that they
may be made the subject of a request for production of documents.

Quroon

RESPONSE TO STANDARD INTERROGATORY NO. 4.
Charles Joseph Boudreaux, Sr.
Father

Louisiana
Lung cancer
Plaintiff does not have any documents responsive to this request.

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STANDARD INTERROGATORY NO. 5. State as completely as possible the address of each
of YOUR residences during YOUR lifetime and the inclusive dates of each period of such
residence.

RESPONSE TO STANDARD INTERROGATORY NO. 5.

1982 to 1969: Lived in Marrero, Louisiana
1970 to 1970: Served in the U.S. Air Force:
1970 to present: California

STANDARD INTERROGATORY NO. 6, State YOUR educational background and identify

all institutions attended, including any apprenticeship courses, or formal on the job training and
identify all institutions attended, the date graduated from each institution, and YOUR major
course of study and any special scholastic honors or degrees received.

RESPONSE TO STANDARD INTERROGATORY NO. 6. Plaintiff completed his GED
while serving in the U. S. Air Force and later completed one {1) year of college in California.

STANDARD INTERROGATORY NO. 7. State the earliest date that service of the summons
and complaint was effected on any defendant in this case.

RESPONSE TO STANDARD INTERROGATORY NO. 7. Plaintiff will supplement.

26

-4- SHES MRUAEE CHIC NFP

27

PLAINTIFF CHARLES BOLDREAUX* ANSWERS TO DEFENDANTS’ STANDARD
INTERROGATORIFS TO PJ.AINTIFE (PERSONAL. INJURY). SET 11| STANDARD INTERROGATORY NO. 8. Have YOU ever been convicted of a felony? If
"yes", please state fully and in detail the date, place and nature of each such felony conviction.

2| Either (1) attach all DOCUMENTS evidencing the information sought in this interrogatory and
its subparts to YOUR answers to these interrogatories or (2) attach disks containing such data or
34(3) describe such DOCUMENTS with sufficient particularity that they may be made the subject
of a request for production of documents

5|RESPONSE TO STANDARD INTERROGATORY NO. 8 No

6|STANDARD INTERROGATORY NO. 9, Have YOU ever been a member of the Armed

Forces? If "yes", please state: each branch of service in which YOU served; the inclusive dates of

TIYOUR service; the date of YOUR discharge from active duty, YOUR service number; each

g [Place (e.g. Fort, base, station, etc.) at which YOU served, and YOUR duties at each place. If
‘YOU have not ever been a member of the Armed Forces due to health reasons, please state the

9 {health reasons.

10| RESPONSE TO STANDARD INTERROGATORY NO.9. Yes

Branch of service U.S. Air Foree
11 Inclusive dates service: 197 to 1979
Date of discharge from active duty: 1979
2 Service number: 437-86-7738

Place (e.¢., fort, base, station, etc.) at which Plaintiff served: Please see Plaintiff's Work
History Sheets, attached, as well as any and all supplements and/or amendments thereto.
Plaintiff's duties at each place: Please see Plaintiff's Work History Sheets, attached, as
well as any and all supplements and/or amendments thereto.

16 STANDARD INTERROGATORY NO. 10. For every doctor who has ever treated or
examined YOU during the last 10 years for any condition, and beyond [0 years for cancer and/or
'7| conditions related to the lungs, respiratory system, and/or ribs and any additional complaints or
conditions stated in response to Interrogatory No. 16, please state for each treatment or
examination

19 fA. Doctor's name;
B. Doctor's address;
20/C. Treatment or examination received,
D. Date(s) of treatment or examination;
2. Reason for treatment or examination:
F,__Bither (1) attach all DOCUMENTS evidencing the information sought in this

22 interrogatory and its subparts to YOUR answers to these interrogatories ar (2) attach
disks containing such data or (3) describe such DOCUMENTS with sufficient
particularity that they may be made the subject of a request for production of documents,

| RESPONSE TO STANDARD INTERROGATORY NO. 10. (A-F) Plaintiff has provided,
25|or shortly will provide. authorizations necessary for Defendant to obtain Plaintiff's medical

5 ctu Sos RAL ANT EHH Hm

27 PLAINTIFF CHARLES BOUDREAUX” ANSWERS TO DEFENDANTS: STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL, INJURY). SET 1v

records. See also Plaintiff's Physician List and Hospitalization [ist attached, as well as any and
all supplements and/or amendments thereto,

STANDARD INTERROGATORY NO. 11. For every hospital in which YOU have ever been
treated, tested, or examined whether as an "inpatient" or as an "outpatient" during the last 10
years for any condition and beyond 10 years for cancer and/or conditions related to the lungs,
respiratory system, and/or ribs and any additional complaints or conditions stated in response to
Interrogatory No. 16, please state for each hospital visit:

Name of hospital,

Address of hospital,

Test, treatment, examination or hospitalization received,

Date of test, treatment, examination or hospitalization received; and

Reason for hospital visit;

Bither (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparis to YOUR answers to these interrogatories or (2) attach
disks containing such data or (3) describe such DOCUMENTS with sufficient

particularity that they may be made the subject of a request for production of documents

SmMOOp>

RESPONSE TO STANDARD INTERROGATORY NO. 11. (A-F) Please see Plaintiff's
medical reports, attached, as well as any and all supplements and/or amendments thereto
Additionally, Plaintiff has provided, or shortly will provide, authorizations necessary for
Defendant to obtain Plaintiff's medical records. See also Plaintiff's Physician List and
Hospitalization List attached, as well as any and all supplements and/or amendments thereto.

STANDARD INTERROGATORY NO. 12. [lave YOU had taken an Xray, CT scan or high-

resolution CT scan of YOUR “trunk”? If "yes", please state for each
JA. Name and address where taken;

B. Date(s) and number taken of each,

IC. Part(s) of body xrayed or scanned,

D. Results, conclusions and/or diagnosis from each, except those prepared by consultants;
E. Either (1) attach all DOCUMENTS evidencing the information sought in this

interrogatory and its subparts to YOUR answers to these interrogatories or (2) attach
disks containing such data or (3) describe such DOCUMENTS with sufficient
particularity that they may be made the subject of a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 12. (A-E) Plaintiff has provided,
or shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's medical
records. See also Plaintiffs Physician List and Hospitalization List attached, as well as any and
all supplements and/or amendments thereto

-6- Se enusustnncinnt ase ns eMsoYe wed

PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS: STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY}. SET 11 [STANDARD INTERROGATORY NO. 13. Have YOU ever undergone a pulmonary function
test? If "yes", please state

2

‘A. Name and address where test was performed,
B. Date of test.

31 Name of doctor administering and/or interpreting test,

4|D. Reason for test:
B. Results, conclusions and/or diagnosis from each test, except those prepared by

s consultants;
Were YOU informed of the results of the test?

Who informed YOU of the results of the test?

Either (1) attach all DOCUMENTS evidencing the information sought in this

7 interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents

a
=Os

RESPONSE TO STANDARD INTERROGATORY NO. 13. (A-I!) Please sce Plaintiff's
10 | List of Physicians and Plaintiff's List of Hospitals, attached, as well as any and all supplements
and/or amendments thereto. .

121STANDARD. ROGATORY NO. 14. Describe the name and quantity of each type of
drug, tranquilizer, sedative or other medication taken or used by YOU during the last 10 years,
specifying the frequency and purpose of use.

RESPONSE TO STANDARD INTERROGATORY NG. 14. Plaintiffhas provided, or

15 |shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's medical records.
‘See also Plaintiff's Physician Jist and Hospitalization List attached, as well as any and all

16 supplements and/or amendments thereto

STANDARD INTERROGATORY NO. 15. Do YOU or YOUR attorney have any medical
reports except those prepared by consultants from any persons, hospitals, doctors ot medical

19 [practitioners or institutions that have ever treated or examined YOU at any time? If "yes", either
(1) attach all DOCUMENTS evidencing the information sought in this interrogatory and its

20| subparts to YOUR answers to these interrogatories or (2) attach disks containing such data or
(3) describe such DOCUMENTS with sufficient particularity that they may be made the subject
21 Jofa request for production of documents

22) RESPONSE TO STANDARD INTERROGATORY NO. 15. Plaintiff has provided, or

shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's medical records.
See also Plaintiff's Physician List and Hospitalization List attached, as well as any and all
24 supplements and/or amendments thereto

-7- SLES WH HEA CME CF HNL

a7 PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS: STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1STANDARD INTERROGATORY NO. 16, Identify exch and every complaint, symptom,

adverse reaction o other injury which YOU allege is directly or indirectly related to YOUR

alleged exposure to RAW ASBESTOS or ASBESTOS CONTAINING MATERIAL and for

jeach complaint, symptom, adverse reaction or other injury, please state

A. The date on which YOU first became aware of signs of the complaint, symptom, adverse
reaction or injury.

B, The date each such complaint, symptom, adverse reaction or injury ceased to affect
YOU;

Any physical change in YOUR appearance occasioned by such complaint, symptom,
adverse reaction or injury;

D. Each part of YOUR body which YOU contend has been affected;

E, The date upon which the complaint, symptom, adverse reaction or injury was reported to
a doctor or physician;

F. State the name, address and telephone number of each such physician to whom said
complaint, symptom, adverse reaction or injury was reported;

G.— Whether YOU have lost any time from work as a result of YOUR asbestos related injury
or medical condition;

H. — Ifsuch injury has resulted in fost time from work, please state the date on which YOU
first lost work and the amount of time lost from work; and

1 Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that. they may be made the subject of a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 16 (A-I) Piaintiff began
experiencing breathing problems in August 2006. Plaintiff's symptoms included shortness of
breath and tightness of the chest and became progressively worse. On September 9, 2006, a
biopsy of the lung was performed by Dr. James Follett. The biopsy revealed malignant
mesothelioma. See Plaintiff's Physician List and Plaintiff's Hospital List attached, as well as any
and all supplements and/or amendments thereto, Plaintiff's expert report linking the Plaintiff's
malignant mesothelioma with asbestos exposure will be supplemented.

STANDARD INTERROGATORY NO. 17. Have YOU been advised that YOU are suffering
from an asbestos related disease? If "yes", state:

‘A. The nature of the asbestos related disease(s);

B. _ The date and time YOU were first advised;

C. The name, address, and telephone number of the physician and/or other persons who so
informed YOU;

D. The name, address and telephone number of the physician who made the evaluation;

E, The method and information upon which such determination was based:

F, The name, address, and telephone number of any hospital, medical institution, laboratory,

physician, nurse. laboratory technician, etc , involved in any part of such determination;

8. SPURS ISITE URES ISCO HS

RLES BOUDREAUX” ANSWERS TO DEFENDANTS’ STANDARD
INJURY). SET 1

PLAINTH
INTERROGATORIES TO PLAINTIFF (PERSO!The name, address, and telephone number of every person. including YOUR relatives,
‘employer or anyone acting in YOUR behalf who was so advised. Please include the date
when such persons were so advised:

H. IDENTIFY YOUR employer(s) at the time YOU were so advised,

1. The specific course(s) of treatment or therapy, including any medicine prescribed as a
result of such determination and the name, address and telephone number of each
prescribing physician;

J. State whether YOU have followed the medication or therapy regime prescribed by each
of the said physicians for the treatment of said complaint, symptom, adverse reaction or
injury,

K, State the names and addresses of any other physicians or practitioners subsequently
affirming or making the same determination; and

L Either (1) attach all DOCUMENTS evidencing the information sought in this

interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks

containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents

RESPONSE TO STANDARD INTERROGATORY NO. 17. (A-L) On September 9, 2006,
a biopsy of the lung was performed by Dr. James Follette. The biopsy revealed malignant
mesothelioma. Sec Plaintiff's Physician List and Plaintiff's Hospital List attached, as well as any
and all supplements and/or amendments thereto, Plaintiff's expert report linking the Plaintiff's
malignant mesothelioma with asbestos exposure will be supplemented.

STANDARD INTERROGATORY NO. 18, tlave any of the said treating physicians informed

'YOU at any time that YOUR complaints, symptoms, adverse reactions or injuries may have been

caused by factor(s) or reason(s) other than exposure to RAW ASBESTOS or ASBESTOS

CONTAINING MATERIAL(S)? Lf "yes", please state:

A. The other factor(s) or reason(s) involved,

B. The names, addresses and telephone numbers of the physicians believing or suspecting
such other factor(s) or reason(s) to be involved;

C. The date(s) that said physicians told YOU that they believed or suspected that other
factor(s) or reason(s) might be involved:

D. The reason that said factor(s) or reason(s) were excluded as possible sources or causes of
the symptoms, and

E, Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 18. _(A-E) None of Plaintiff's
treating physicians have informed Plaintiff at any time that Plaintiff's complaints, symptoms,
adverse reactions and injuries may have been caused by factor(s) or reason(s) other than

-9- clued tekst Ses Sra

PLAINTIFF CHARLES BOUDREAUX" ANSWERS TO DEFENDANTS: STANDARD

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1Jexposure to raw asbestos ot asbestos containing material(s}. ‘The only known cause of
mesothelioma is exposure to asbestos

STANDARD INTERROGATORY NO. 19. Please list all respiratory complaints and/or
symptoms which YOU have suffered during the past 10 years and list the inclusive dates for each
such complaint

RESPONSE TO STANDARD INTERROGATORY NO. 19. _ Plaintiff began experiencing
breathing problems in 2006. Plaintiff's symptoms included shortness of breath, tightness of the
chest and a cough and became progressively worse

STANDARD INTERROGATORY NO. 20. Have YOU ever had any biopsies or tissue

samples taken during the past 10 years? If YOUR answer is "yes", state for each such procedure:

‘A. The name of the doctor performing such procedure;

8. The address where such procedure was performed,

C. The date when such procedure was perfarmed:

1D, The results, conclusions and/or diagnosis from such procedure: and

E. _ Bither (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing suck data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 20, (A-E) Yes; sce Plaintiff's
medical report attached, as well as any and all supplements and amendments thereto. Plaintiff

{has provided. or shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's

medical records. Sce also Plaintiff's Physician 1 ist and Hospitalization List attached, as well as

any and all supplements and/or amendments thereto.

STANDARD INTERROGATORY NO. 21. Do YOU know of any pathology slides that were
made from any of YOUR tissue samples during the past 10 years? If YOUR answer is "yes", for
each set of slides made please state:

The name of the hospital;

‘The name of the doctor;

The current location;

The date said slides were made, and

The accession number(s)

mMOAR>

RESPONSE TO STANDARD INTERROGATORY NO. 21. (A-E) See Plaintiff's medical
Teport attached, as well as any and all supplements and amendments thereto. Plaintiff has
provided, or shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's

-10- 1 SUIRSTS i MIRRALNE DN NSPS
PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS’ STANDARD

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SE 1medical records. See also Plaintiffs Physician List and Hospitalization List attached, as well as
any and all supplements and/or amendments thereto

STANDARD INTERROGATORY NO. 22. Have YOU ever suffered any personal injuries
other than those involved in this lawsuit? If "yes", state for each such injury:

‘A. The date, place, names of persons involved, and circumstances surrounding such injury,

B. The nature and extent of the injuries including any ill effects or disabilities remaining at
the time of the last treatment or examination;

C. The names, addresses and date(s) of last treatment or examination by all persons who
treated or examined YOU in connection with such injury;

D. The nature and source of any disability benefits, pensions or other payments for such

injuries; and

E. Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of'a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 22. (A-E) Plaintiff has provided,
lor shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's records

STANDARD INTERROGATORY NO. 23. Have YOU ever smoked tobacco products of any

type? If "yes", state:
JA. The dates and time periods during which YOU have smoked;
B. The type of tobacco products YOU smoke or have smoked. Please state whether YOU

inhaled the smoke or not;
C. The daily frequency with which YOU smoke or have smoked;

D. If YOU have ever smoked cigarettes, please state the average number of packs per day
YOU smoked:

E, Please state the commercial brand name(s) of any tobacco products that YOU have used;
and

F Has any physician ever advised YOU to stop or curtail smoking tobacco products? If
"yes", state:
1 The name of each such physician; and

2. The date(s) on which YOU were so advised

RESPONSE TO STANDARD INTERROGATORY NO. 23. (A-F) Plaintiff is a lifelong
nonsmoker.

STANDARD INTERROGATORY NO. 24. Has any person with whom YOU have shared a

[household far more than one year been a regular user of cigarettes during the time you shared a
household with the person’ If “yes”. state fully and in detail for each such person:

-l- $F SIRS THORDMEALS CDI HOE HA
PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS’ STANDARD

INTERROGATORIES TO PLAINTIFF (PERSONAL INIURY). SET 1A ‘The name and relationship to YOU of the smoker:

B. The dates during which YOU shared a household with the person;

C. The brand name(s) of cigarettes the person used during the time YOU shared a
household with the person and his/her frequency of use; and

D. The frequency with which the person smoked cigarettes in YOUR presence during the
time YOU shared a household with the person.

RESPONSE TO STANDARD INTERROGATORY NO. 24, (A-D) None.

STANDARD INTERROGATORY NO. 25. Describe the extent to which YOU drank
alcoholic beverages during YOUR lifetime, specifying the particular kind of alcoholic beverages

{and the quantity consumed per week over the period of time such beverages were consumed.

RESPONSE TO STANDARD INTERROGATORY NO. 25. Plaintiff objects to those
portions of this Interrogatory which seek information which is not relevant, nor reasonably
calculated to lead to the discovery of admissible evidence.

RESPONSE TO STANDARD INTERROGATORY NO. 26. For every type of employment
that you have ever had, whether self employed or employed by others, please complete the
following: (IF more space is nceded, please attach additional shects containing the requested
information.)

Employer's Name and Address Job Title Date Started - Date Ended
(Month, Day, Year)

Description of Job Duties

[Job Sites:

Your Estimate of Total Time (Days, Weeks, etc.) You Worked at That Site:

Do you claim exposure to asbestos at this employment? Yes No

RESPONSE TO STANDARD INTERROGATORY NO. 26, Please sce Plaintiff's Work
History Sheets attached, attached, as well as any and all supptements and/or amendments thereto.

STANDARD INTERROGATORY NO. 27. Are YOU or have YOU been a member of any
labor union, including but not limited to the Heat, Frost, Insulation and Asbestos Workers
Union? If YOUR answer is "yes", state for each such union membership:

PLAINTIFE CHARLES BOUDRFAUX: ANSWERS TO DEFENDANTS: STANDARD
INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1IA. The name of each such international union and its number, along with the local number of

each such union; and
2/B. The date and time periods during which YOU maintained membership in such union.

RESPONSE TO STANDARD INTERROGATORY NO. 27. (A-B} No.

&

STANDARD INTERROGATORY NO. 28. When did YOU first learn that exposure to
asbestos was a potential health hazard?

RESPONSE TO STANDARD INTERROGATORY NO. 28. Plaintiff first learned that
exposure to asbestos is a health hazard in the late 1970s.

8 STANDARD INTERROGATORY NO. 29. Describe how YOU first became aware that
g exposure to asbestos was a potential health hazard.

10 RESPONSE TO STANDARD INTERROGATORY NO. 29. Plaintiff first became aware
that exposure to asbestos is a health hazard when Plaintiff's father was diagnosed with an
1 asbestos-related disease.

;| STANDARD INTERROGATORY NO. 30. When did YOU first observe anyone use any type
of SAFETY PRECAUTION while working around RAW ASBESTOS or ASBESTOS
14] CONTAINING MATERIAL(S)?

15] RESPONSE TO STANDARD INTERROGATORY NO. 30. Please see Plaintiff's Work
History Sheets, attached, as well as any and all supplements and/or amendments thereto.

'7) STANDARD INTERROGATORY NO. 31. When, where and at whose direction did YOU
first use any type of SAFETY PRECAUTION while working around RAW ASBESTOS or
|ASBESTOS CONTAINING MATERIAL(S)?

RESPONSE TO STANDARD INTERROGATORY NO. 31. _ Please see Plaintiff's Work
20 History Sheets, attached, as well as any and ail supplements and/or amendments thereto.

STANDARD INTERROGATORY NO. 32. State whether any of YOUR employers have
either required or made available physical examinations for their employees. If such physical
examinations have either been required or made available to YOU, state for each of YOUR
employers

24]A. IDENTIFY YOUR employer,

B. The nature and extent of examinations:

251C. The frequency of examinations:

-13- ‘etanvnst none aE USANA

27 PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS’ STANDARD
t INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY). SET 1BD. Whether they were required or optional,

E.— Whether xray examination was included.

F. The frequeney. including specific dates and times, with which YOU submitted to such
examinations.

G Whether YOU received the results of any such examinations, the dates that they were
given to YOU and the nature of the results;

H. The name, address and telephone number of the examining physician, nurse or technician;

1 YOUR detailed reasons for failing to submit to such examination when required or made
available, if YOU did so fail to submit; and

J Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents.

RESPONSE TO STANDARD INTERROGATORY NO. 32. (A-J} None of Plaintiff's
employers required or made available physical examinations for their employees

STANDARD INTERROGATORY NO. 33. If YOU are not currently employed, please state
the last date worked und the reason that YOU are not currently employed.

RESPONSE TO STANDARD INTERROGATORY NO. 33. Plaintiff has been unable to
work since October 2006 duc to mesothelioma.

STANDARD INTERROGATORY NO. 34. Are YOU receiving any form of disability
pension? Ifso, state

JA. From whom,

B. The amounts received each month, and

Cc The anticipated duration of the disability.

RESPONSE TO STANDARD INTERROGATORY NO. 34. (A-C) Plaintiff is not
receiving any form of disability pension

RESPONSE TO STANDARD INTERROGATORY NO. 35. Have YOU ever been
discharged from or ever voluntarily left a position due to health problems? If "yes", state in detail
the time, name of employer, place and circumstances. Bither (1) attach all DOCUMENTS
evidencing the information sought in this interrogatory and its subparts to your answers to these
interrogatories, or (2) attach disks containing such data, or (3) describe such DOCUMENTS
with sufficient particularity that they may be made the subject of a request for production of
documents.

aid SS CUS EROEEREAE Insect ee
ANSWERS TO DEFENDANTS: STANDARD

"PLAINTIFF CHARLES BOUDREAU.

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY). SET 1iu ie STANDARD INTERROGATORY NO. 35. Please see Plaintiff's
Response to Standard Interrogatory No. 22. Further, Plaintiff has provided, or shortly will
provide, authorizations necessary for Defendant to obtain Plaintif?'s records

4|STANDARD INTERROGATORY NO. 36. Were YOU ever exposed to RAW ASBESTOS

jor ASBESTOS CONTAINING MATERIALS(S) outside of YOUR work environment? If "yes",
Please state for each such OCCASION:
Circumstances surrounding the exposure,
8 Date(s) and LOCATION:
C. Duration and manner of the exposure; and
D. DESCRIBE the RAW ASBESTOS or ASBESTCGS CONTAINING MATERIAL(S).

RESPONSE TO STANDARD INTERROGATORY NO. 36. (A-D) Please see Plaintiff's
Work History Sheets, attached, as well as any and all supplements and/or amendments thereto.

STANDARD INTERROGATORY NO. 37. State whether you assert a claim for toss of
income and, if so, state fidly and in detail the year and YOUR annual earings for each of the last
ten years in which YOU were employed.

RESPONSE TO STANDARD INTERROGATORY Plaintiff will supplement this

information in the form of an expert economic report.

STANDARD INTERROGATORY NO. 38. Have YOU incurred any hospital expenses to date
jas a result of the injuries, complaints, etc. which YOU attribute to YOUR alleged exposure to
state the total hospital expenses incurred and itemize each charge if more than

z]one hospital is involved

3} RESPONSE TO STANDARD INTERROGATORY NO. 38. Plaintiff has provided, or

shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's hospital billing
information. See also Plaintiff's Physician List and Plaintiff's Hospitalization List attached, as
well as any and all supplements and/or amendments thereto.

STANDARD INTERROGATORY NO. 39. Have YOU incurred any medical expense (other
than hospitalization) or have any medical expenses been incurred on YOUR behalf to date as a
result of the injuries, complaints, etc. which YOU attribute to YOUR alleged exposure to
asbestos? If "yes", state the total medical expenses incurred, itemizing each such charge

RESPONSE TO STANDARD INTERROGATORY NO. 39. _ Plaintiff has provided, or

shortly will provide, authorizations necessary for Defendant to obtain Plaintiff's hospital billing

=15 SPTISSrS ea EAU SNS
RSWERS TO DEFENDANTS’ STANDARD

PLAINTIFF CHARLES BOUDREAU:

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY), SET 1information. Sec also Plaintiff's Physician [ist and Plaintiff's Hospitalization List attached hereto
as well as any and all supplements and/or amendments thereto

STANDARD INTERROGATORY NO. 40, Has any insurance company, union or any other
person, firm or corporation paid for or reimbursed YOU for, or become obligated to pay for, any
medical or hospital expenses incurred by the alleged exposure to asbestos? If "yes", state the
name and address of the insurance company, union, person, firm or corporation who or which
has paid or is obligated for the payment of or reimbursement for said expenses,

RESPONSE TO STANDARD INTERROGATORY NO. 40, Plaintiff will supplement this
‘information.

STANDARD INTERROGATORY NO. 41. Have YOU ever at any time made a claim for or
received for an asbestos related condition any health or accident insurance benefits, Workers’
Compensation payments, disability benefits, pension, accident compensation payment or veterans
disability compensation’ If"
A. The itlness, injury or injuries for which YOU made the claim,
B. ‘The date when such injury or injuries were sustained, the place of occurrence and the
nature of the accident or incident causing such injury,
©. The names and addresses of YOUR employer(s) at the time of each injury or illness,
1D, The names and addresses of the examining doctors for each injury or illness;
The name of the board, tribunal or superior officer which or to whom the claim or claims

were made oF filed;
FL The date the claim was made or filed;
G.—The claim, file or other number by which YOUR claim was identified,
H. The present status of such claims (pending settlement, dismissal, etc..
1 The amounts of the benefits or awards or payments;
J. The dates covering the times during which YOU received the benefits or awards or
payments;

K. The identity of the agencies or insurance companies from whom YOU received the
awards, benefits or payments, and

L. Either (1) attach all DOCUMENTS evidencing the information sought in this
interrogatory and its subparts to your answers to these interrogatories, or (2) attach disks
containing such data, or (3) describe such DOCUMENTS with sufficient particularity
that they may be made the subject of a request for production of documents

RESPONSE TO STANDARD INTERROGATORY NO. 41. (A-L) Piaintiff has never made
a claim for or received for an asbestos related condition any health or accident insurance benefits,
Workers’ Compensation payments, disability benefits, pension, accident compensation payment
Jor veterans disability compensation

-16- SU EUISSTS HCTREALSU THO EB SEES ep

PLAINTIFF CHARLES BOUDREAUX: ANSWERS TO DEFENDANTS’ STANDARD

INTERROGATORIES TO PLAINTIFF (PERSONAL INJURY). SET 1| RESPON:

STANDARD INTERROGATORY NO. 42. Have YOU lost or do YOU claim any wage or
earning loss as a result of YOUR alleged exposure to asbestos? If so, state

A. How much time was lost from work or employment, listing the dates involved and the
name and address of the employer.

B. The gross amount of salary or earnings which YOU received each pay day, stating the
intervals of such paydays (e.g, weekly, bimonthly, monthly);

C. State the gross amount of salary or earnings actually lost due to the exposure:

D. _Ifselfemployed, state the total time lost from business, listing the dates involved and the

gross financial loss to YOU, stating the nature of such loss and how incurred; and
E. Of the sum stated in YOUR response to subpart D of this interrogatory, state YOUR net
loss.

RESPONSE TO STANDARD INTERROGATORY NO. 42. (A-E) Documentation

regarding lost eamings, if any, will be supplemented

STANDARD INTERROGA TORY NO. 43. Have YOU incurred any expense or financial loss
including property damage, other than as listed above which YOU attribute in any degree to
YOUR exposure to asbestos products? If so, state such financial losses, expenses and property
damage, giving the dates incurred and the amounts involved and the nature of each such expense
or loss.

E TO STANDARD INTERROGATORY NGO. 43. To the best of Plaintiff's
knowledge, Plaintiff has not incurred expense or financial loss, including property damage, other
than as listed above which Plaintiff attributes to exposure to asbestos products

STANDARD INTERROGATORY NO. 44, Has any insurance company, union or other

person, firm or corporation paid for or reimbursed YOU for or become obligated to pay for or

reimburse YOU or anyone on YOUR behalf for any sums of money (excluding medical or

hospital expenses) to provide any of the following: disability or other benefits; loss of earnings,

property damage resulting from the alleged exposure to asbestos? If "yes", state:

A. The nature of the obligation giving rise to the payment or reimbursement, and

B. The name and address of the insurance company, union or other person, firm or
corporation who or which has paid for or is obligated for payment of or reimbursement
for such sums of money.

R