On June 06, 2007 a Motion-Secondary 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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Joanne Rosendin, SBN: 121025 Christopher J. Dyas, SBN: 104384 SACK ROSENDIN, LLP One Kaiser Plaza, Suite 340 ELECTRONICALLY Oakland, California 94612 FILED Telephone: (510) 286-2200 Superior Court of California, County of San Francisco Attorneys for Defendant, JUN 22 2010 CHICAGO BRIDGE & IRON COMPANY, Clerk of the Court an Illinois corporation BY: WILLIAM TRUPEK Deputy Clerk SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO LOUIS CASTAGNA, NO. CGC - 07 - 274230 Plaintiff, DECLARATION OF ‘CHRISTOPHER J. DYAS IN SUPPORT v. OF DEFENDANT CHICAGO BRIDGE & IRON COMPANY ’S MOTION FOR ASBESTOS DEFENDANTS (BP), et al., SUMMARY JUDGMENT Defendants. Date: September 9, 2010 Time: 9:30 a.m. Dept: 220 Action Filed; June 6, 2007 Trial Date: October 12, 2010 I, Christopher J. Dyas declare as follows: 1, Lam an attorney at law duly admitted to practice before the courts of the State of California and am associated with the law firm of Sack Rosendin LLP, attorneys of record for defendant Chicago Bridge & Iron Company, an Illinois corporation, 2, Attached as Exhibit A is a true and correct copy of plaintiff's Complaint for Personal Injury ~ Asbestos, filed on June 6, 2007. 3. Attached as Exhibit B is a true and correct copy of Brayton%Purcell Master Complaint for Personal Injury [Loss of Consortium] — Asbestos, filed in Jn Re: Asbestos Cases of Brayton & Purcell, Case No. 828684, filed January 2, 2003. 4. Attached as Exhibit C is a true and correct copy of plaintiff's Answers to Interrogatories (Standard Asbestos Case Interrogatories), Set One, dated June 29, 2007. -1- DECLARATION OF CHRISTOPHER J. DYAS IN SUPPORT OF CHICAGO BRIDGE & IRON COMPANY ’S MOTION FOR SUMMARY JUDGMENT5. Attached as Exhibit D is a true and correct copy of Defendants’ Standard Interrogatories to Plaintiff (Personal Injury), Set 1. 6. Attached as Exhibit & is a true and correct copy of plaintiff's Answers to Interrogatories (Standard Asbestos Case Interrogatories), Set Two, dated May 16, 2008, without the 175-page exhibits to the Answers. 7. Attached as Exhibit F is a true and correct copy of Defendants’ Standard Interrogatories to Plaintiff (Personal Injury), Set 2. 8. Attached as Exhibit G is a true and correct copy of Plaintiff's Supplemental/ Amended Responses to Interrogatories (Standard Asbestos Case Interrogatories), Sets One and Two, dated February 9, 2010. 9 Attached as Exhibit H is a true and correct copy of Plaintiff Louis Castagna’s Response to Defendant Chicago Bridge & iron Company’s Special Interrogatories, Set One, dated June 10, 2008. 10. Attached as Exhibit Lis a true and correct copy of Defendant Chicago Bridge & Iron Company’s First Set of Special Interrogatories. 11. Attached as Exhibit J are true and correct copies of pages 985, 1057, 1058, 1059, 1060, and 1061 of the transcript of the Deposition of Louis Castagna, April 7, 2009. 12. Attached as Exhibit K are true and correct copies of pages 1292, 1329, 1330, 1331, 1332, and 1333 of the transcript of the Deposition of Louis Castagna, December 15, 2009. I declare under penalty of perjury under the laws of the State of California that the foregoing] is true and correct of my own knowledge and that if called upon I would testify competently thereto] Executed this 22™ day of June, 2010, at Oakland, California. ‘hristophér J. Dyas GAASBICASTAGNA, Louis - CBNMSI\pld - MS) - DEC - CBLwpd -2- DECLARATION OF CHRISTOPHER J. DYAS IN SUPPORT OF CHICAGO BRIDGE & IRON COMPANY ’S MOTION FOR SUMMARY JUDGMENT