On June 06, 2007 a Party Discovery was filed involving a dispute between Castagna, Louis, and Advocate Mines Limited, Albay Construction Company, All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, American Conference Of Governmental Industrial, American Conference Of Governmental Industrial Hyg, American Standard, Inc., Ameron International Corporation, A.O. Smith Corporation, Asbestos Defendants, Asbestos Manufacturing Company, Auto Friction Corporation, Auto Specialties Manufacturing Company, Baugh Construction Company, Bechtel Corporation, Bell Asbestos Mines Ltd., Borgwarner Morse Tec, Inc., Brassbestos Brake Lining Company, Bridgestone Firestone North American Tire, Llc, Briggs & Stratton Corporation, Bucyrus International, Inc., Caterpillar Inc., Cbs Corporation, A Delaware Corporation, Chevron Products Company, Chevron U.S.A. Inc., Chicago Bridge & Iron Company,, Chrysler Llc Fka Daimlerchrysler Company Llc,, Conocophillips Company, Consolidated Insulation, Inc., Contra Costa Electric, Inc., Copeland Corporation, Copeland Corporation, Llc Fka Copeland Corporation, Crane Co., Csk Auto, Inc., Daimlerchrysler Company Llc, Formerly Known As, Daimlerchrysler Corporation, Dana Corporation, Dillingham Construction N.A., Inc., Does 1-8500, Douglass Insulation Company, Inc., Durametallic Corporation, Eaton Corporation, Eaton Electrical Inc., Elliott Company,, Elliott Turbomachinery Co., Inc., Emsco Asbestos Company, Fibre & Metal Products Company, Fibre & Metal Products Company, Inc., Fisher Controls International Llc, Fmc Corporation, Fmc Corporation-Chicago Pump, Forcee Manufacturing Corp., Ford Motor Company, Foster Wheeler Llc, Garlock Sealing Technologies, Llc, Gate City Plumbing & Heating, Gatke Corporation, General Electric Company, General Motors Corporation, Genuine Parts Co., Genuine Parts Company, Henry Vogt Machine Co., H. Krasne Manufacturing Company, Honeywell International Inc.,, Hopeman Brothers, Inc., Imo Industries Inc., Ingersoll-Rand Company, Interlake Steamship Co., Johnson Controls, Inc., J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Kelly-Moore Paint Company, Inc., Lamons Gasket Company, Landsea Holding Company, Lasco Brake Products, Lear Siegler Diversified Holdings Corp., Lindstrom & King Co., Inc., L.J. Miley Company, Maremont Corporation, Metropolitan Life Insurance Company, Molded Industrial Friction Corporation, Morton International, Inc., National Automotive Parts Association, National Transport Supply, Inc., Nibco Inc., Oakfabco, Inc., Owens-Illinois, Inc., Paccar Inc., Pacific Gas & Electric Company, Pacific Mechanical Corporation, Parker-Hannifin Corp., Performance Mechanical, Inc., Plant Insulation Company, Pneumo Abex Llc, Quintec Industries, Inc., Rapid-American Corporation, Red-White Valve Corporation, Republic Supply Company, Riley Power Inc., Riley Power, Inc., Erroneously Sued As Babcock, Riteset Manufacturing Company, Rockwell Automation, Inc., Rossendale-Ruboil Company, Santa Fe Braun, Inc., Schlage Lock Company, Scott Co. Of California,, Sequoia Ventures Inc., Shell Oil Company, Silver Line Products, Inc., Southern Friction Materials Company, Special Electric Company, Inc., Special Materials, Inc.-Wisconsin, Standard Motor Products, Inc., Standco, Inc, Sta-Rite Industries, Llc, Stuart-Western, Inc., Swinerton Builders Fka Swinerton & Walberg Co., Taco, Inc., Temporary Plant Cleaners, Inc., Terry Corporation Of Connecticut, Terry Steam Turbine Co., The Budd Company, The Dow Chemical Company, The Industrial Maintenance Engineering Contracting, The William Powell Company, Thomas Dee Engineering Company, Timec Company, Inc., Tosco Refining Company, Inc., Trane Us, Inc., Triple A Machine Shop, Inc., Tyco International, Underwriters Laboratories, Inc., Uniroyal Holding, Inc., Universal Friction Materials Company, Unocal Corporation, U.S. Spring & Bumper Company, Warren Pumps, Llc, Wheeling Brake Block Manufacturing Company, Yarway Corporation, Zurn Industries, Llc, Formerly Known As Zurn, for civil in the District Court of San Francisco County.
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1 || PAUL V. LANKFORD (State Bar No. 181506) PAUL LANNUS (State Bar No. 192551) 2 | LANKFORD CRAWFORD MORENO LLP ELECTRONICALLY 3 | 1850 Mt. Diablo Bivd., Suite 600 FILED Walnut Creek CA 94596 Superior Court of California, ty of San Francisco 4 | Telephone: 925.300.3520 Facsimile: 925.300.3386 JAN 12 2011 5 Clerk of the Court Attorneys for Defendant BY: ALISON ae puty Clerk 6 | FORD MOTOR COMPANY 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 i SAMUEL LEAL, ASBESTOS 12 B *Plaintiff, BRAYTON GROUP 536 v. 14 CASE No. CGC-08-274807 ASBESTOS DEFENDANTS (B“P), 15 Defendants. 16 17 | LOUIS CASTAGNA, CasE No. CGC-07-274230 18 Plaintiff, DEFENDANT ForD Motor COMPANY’S 19 v. MotIon IN LiMine For Forty-E1GHT HOUR PRE-DISCLOSURE OF WITNESSES 20 | ASBESTOS DEFENDANTS (BP), AND SEVENTY-TWO HOUR PRE- DISCLOSURE OF DOCUMENTS AND 21 Defendants. FORMER TESTIMONY PRIOR TO » PRESENTATION AT TRIAL [MIL #55] 23 24 25 26 27 |e The use of the term “plaintiff” as used herein refers to the plaintiff in a personal injury action and the decedent in a wrongful death action; and the use of “plaintiff” shall refer to both plaintiff in the singular and plural, as 28 appropriate. LANKFORD -1- CRAWFORD MORENO LLP ATTORWEYSATLAW ALANKFORD CRAWFORD MORENO LLP ATTORNEYS ATLAW GARY COATES, Plaintiff, v. ASBESTOS DEFENDANTS (BP), Defendants. CLEM FITZHUGH, Plaintiff, v. ASBESTOS DEFENDANTS (BP), Defendants. Case No. CGC-08-274784 Case No. CGC-08-274645 DEFENDANT Forp MoTOoR CoMPANY’s MOTION IN LIMINE FOR ForTy-Eicut HOUR PRE-DISCLOSURE OF WITNESSES AND SEVENTY-T WO HOUR PRE-DISCLOSURE OF DOCUMENTS AND FORMER TESTIMONY PRIOR TO PRESENTATION AT TRIAL [MIL #55] 4aa oc 28 LANKFORD CRAWFORD MORENO LLP ATTORNEYS ATLAW TO ALL PARTIES HEREIN AND THEIR ATTORNEYS OF RECORD: The above-named defendant (hereinafter “Defendant”) moves this court in limine for the following orders in conjunction with this trial: 1 That each party advise all other parties, at least forty-eight (48) hours in advance, of each witness that the party will call at trial. 2. That each party designate documents, at least seventy-two (72) hours, prior to seeking to admit the documents into evidence or to elicit testimony from a witness concerning the document. 3. That each party designate, via page-line designations, those portions of former deposition or trial testimony sought to be admitted at trial no less than seventy-two (72) hours prior to seeking to enter such testimony into evidence, and that full transcripts of the former testimony, be provided to the parties against whom the testimony is sought to be admitted at least seventy-two (72) hours before it is sought to be admitted. 4, That no documents or former testimony be specifically referred to, or quoted, by any attorney until the opposing side has had the opportunity to request a hearing on their admissibility, out of the presence of the jury. DEFENDANT'S MOTION IN LIMINE FOR FORTY-HIGHT HOUR PRE-DISCLOSURE OF WITNESSES AND SEVENTY-TWO HOUR PRE-DISCLOSURE. OF DOCUMENTS AND FORMER TESTIMONY PRIOR TO PRESENTATION AT TRIAL [MIL #55]28 LANKFORD CRAWFORD MORENO LLP. ATTORNEYS ATLAW The above orders will allow the parties to adequately prepare for this trial. There are thousands of documents and hundreds of potential witnesses available to all parties. Many documents and some testimony should be excluded. Disputed evidence should not be referred to in the presence of the jury until the Court has issued a ruling. Equal application of the Orders requested would ensure a faster trial and would avoid undue prejudice. Dated: December 2, 2010 LANKFORD CRAWFORD MORENO LLP oe, By: pk fir PAUL V. LANKFORD PAUL LANNUS Attorneys for Defendant FORD MOTOR COMPANY -2- DEFENDANT'S MOTION iN LIMINE FOR FORTY-SIGHT HOUR PRE-DISCLOSURE OF WITNESSES AND SEVENTY-TWO HOUR PRE-DISCLOSURE. OF DOCUMENTS AND FORMER TESTIMONY PRIOR TO PRESENTATION AT TRIAL [MIL #55]