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  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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                                Brybox
Hueo & PARKER
139 MAIN STREET
20" FLOcR
Sun Franisea, CA 94105

Edward R. Hugo [Bar No. 124839]
Gregory S. Rosse [Bar No. 157965]
Ken L. Hoang [Bar No. 207645]
BRYDON HUGO & PARKER

135 Main Street, 20'" Floor

San Francisco, CA 94105
Telephone: (415) 808-0300
Facsimile: (415) 808-0333

Attorneys for Defendant
NIBCO INC.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

JUL 21 2010

Clerk of the Court
BY: CHRISTLE ARRIOLA
Deputy Clerk

SUPERIOR COURT - STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION

LOUIS CASTAGNA,

Plaintiff(s),
vs.

ASBESTOS DEFENDANTS (B*P), ET AL.,

Defendants.

(ASBESTOS)
Case No. CGC-07-274230

DISCOVERY

DEFENDANT NIBCO INC’S NOTICE OF
MOTION AND MOTION TO COMPEL
VERIFIED RESPONSES TO WRITTEN
DISCOVERY AND FOR SANCTIONS

(Filed concurrently with Memorandum of
Points and Authorities; and Declaration of
Ken L. Hoang)

Date: August 17, 2010
Time: 9:00 a.m.
Dept.: 220

Judge: Harold E. Kahn

Action filed: June 6, 2007
Trial Date: October 12, 2010

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on August 17, 2010 at 9:00 a.m., or as soon thereafter

as this matter may be heard, in Department 220 of this Court, Defendant NIBCO INC.

(“NIBCO”) will move the Court, for an Order that Plaintiff LOUIS CASTAGNA

(“Plaintiff”) provide complete verified responses without objections to NIBCO’s First

Supplemental Interrogatory and First Supplemental Request for Production to Plaintiff.

NIBCO will also move for an Order that Plaintiff LOUIS CASTAGNA and opposing

1

DEFENDANT NIBCO INC.'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED
RESPONSES TO WRITTEN DISCOVERY AND FOR SANCTIONS1 || counsel, BRAYTON PURCELL pay a monetary sanction to NIBCO in the sum of

2 || $1,538.50 as the reasonable cost and attorney’s fees incurred by the moving party in
connection with this proceeding.

4 Said motion will be made on the grounds that the Interrogatory, and Request for

5 || Production are relevant to the subject matter of this action, and do not relate to privileged
6 || matters, and that Plaintiff's refusal to provide same is without substantial justification.

7 || (See Code Civ. Proc. §§ 2030.290, and 2031.300.)

8 Said motion to compel is based on this Notice, the Memorandum of Points and

9 || Authorities, the attached Declaration of Ken L. Hoang, and the complete files and records

10 |) in this action.

12 || Dated: July 21, 2010 BRYDON HUGO & PARKER

13

14 By: /sf Ken L. Hoang
Edward R. Hugo

15 Greg 5. Rosse
Ken L. Hoang,

16 Attorneys for Defendant
NIBCO INC.

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BryDoN 2
Huco & PARKER,
“hon DEFENDANT NIBCO INC'S NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED

San Franeiceo, CA 24108 RESPONSES TO WRITTEN DISCOVERY AND FOR SANCTIONSCastagna, Louis (Brayton 536)
San Francisco County Superior Court Case No. CGC-07-274230
LexisNexis Transaction No. 32260396

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@bhplaw.com and my business address is 135 Main Street, 20" Floor, San
Francisco, ¢ alifornia 94105. On the date below, I served the following:
Defendant Nibco Inc's Notice of Motion and Motion to Compel Verified Responses

to Written Discovery and for Sanctions; Supporting Memorandum of Points and
Authorities; and Supporting Declaration of Ken L. Hoang

on the following:

David Donadio AND LEXIS NEXIS SERVICE LIST
BRAYTON PURCELL LLP

222 Rush Landing Road

Novato, CA 94945

Fax: (415) 898-1247

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

o By transmitting via facsimile the document(s) listed above to the fax
number(s) set forth above on this date before 5:00 p.m.

o By placing the document(s) listed above in a sealed envelope and placing
the envelope for collection and mailing on the date below following the
firm’s ordinary business practices. I am readily familiar with the firm’s
practice of collection and processing correspondence for mailing. Under
that practice it would be deposited with U.S. Postal service on the same
day with postage thereon fully prepaid at San Francisco, California in the
ordinary course of business. I am aware that on motion of party served,
service is presumed invalid if postal cancellation date or postage meter
date is more than one day after date of deposit for mailing in affidavit.

I declare under penalty of perjury that the above is true and correct.
Executed on July 21, 2010, at San Francisco, California. .

Adrena Williams

PROOF OF SERVICE