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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
						
                                

Preview

om YN KD A RB Ww YY = YM BY NY YN KN RD DE He ee ee es oe oa a Ah BF BW YW KF SD Ow HM HD HA B YW HY SE Ss 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 Attomeys 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, DEFENDANT CHICAGO BRIDGE & IRON COMPANY ’S NOTICE OF v. MOTION AND MOTION FOR SUMMARY JUDGMENT ASBESTOS DEFENDANTS (BP), et al., Date: September 9, 2010 Defendants. Time; 9:30 a.m. Dept: 220 Action Filed: June 6, 2007 Trial Date: October 12, 2010 TO PLAINTIFF AND TO YOUR ATTORNEYS OF RECORD; NOTICE IS HEREBY GIVEN that on September 9, 2010, at 9:30 a.m., or as soon thereafter] as the court may conveniently hear the matter, Defendant, CHICAGO BRIDGE & IRON COMPANY, an Illinois corporation, ("CBI") will move this Court, located at 400 McAllister Street, San Francisco, CA, for an order granting summary judgment in its favor and against plaintiff} Louis Castagna. This motion is made on the ground that the undisputed facts establish that plaintiff} does not possess, and cannot reasonably obtain, evidence in support of his claims that Parsons caused or contributed to his alleged personal injuries an essential element of their claims, so that CBI is entitled to judgment as a matter of law. This motion will be based upon this Notice of Motion, the Separate Statement of Undisputed Facts, the Declaration of Christopher J. Dyas, and the Memorandum of Points and Authorities, all o -1- CHICAGO BRIDGE & IRON COMPANY ’S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENTND A BF WN which accompany this Motion, as well as upon such further oral or documentary evidence as may be presented at the hearing on this matter. Dated: June 22, 2010 SACK ROSENDIN, LLP ‘hristopher #” Dyas hao fl elon, Z CHICAGO BRIDGE & IRON COMPANY, an Illinois corporation -2- CHICAGO BRIDGE & IRON COMPANY ’S NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT