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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 
						
                                
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                                Bryoon

Huco & PARKER
135 MAIN STREET
20"
San Franciseo, CA S4105

Edward R. Hugo [Bar No. 124839]
rego S. Rosse [Bar No. 157965]

Ken oang [Bar No. 207645]
BRYDON HU © & PARKER ELECTRONICALLY
135 Main Street, 20% Floor FILED
San Francisco, CA 94105 Superior Court of California,
Telephone: (415) 808-0300 County of San Francisco
Facsimile: (415) 808-0333 — JUN 22 2010
Clerk of the Court
Attorneys for Defendant BY: RAYMOND K. WO!
NIBCO INC. ° bepuly Clerk

SUPERIOR COURT - STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION _

LOUIS CASTAGNA, ASBESTOS)
ase No, CGC-07-274230
Plaintiff(s),
vs. DECLARATION OF KEN L. HOANG IN

SUPPORT OF DEFENDANT NIBCO INC’S
ASBESTOS DEFENDANTS (B*P), ET AL., | MOTION FOR SUMMARY JUDGMENT
OR, IN THE ALTERNATIVE, SUMMARY
Defendants. : ADJUDICATION

{Filed concurrently with Notice,
Memorandum of Points and Authorities,
and Separate Statement of Undisputed]

Date: September 8, 2010
Time: 9:30 a.m.

Dept.: 220

Judge: Harold E. Kahn

Action filed: February 4, 2008
Trial Date: October 12, 2010

1 KEN L. HOANG, declare as follows:

1. Tam an attorney licensed to practice before all the courts of the State of
California and practice with the law firm of Brydon Hugo & Parker, attorneys of record
for Defendant NIBCO INC, (hereinafter “NIBCO”) in the above-referenced matter. I
have personal knowledge of the facts stated herein, or have gained such knowledge from
my review of the records and documents maintained in our file in the regular course of

1

DECLARATION OF KEN L, HOANG IN SUPPORT OF DEFENDANT NIBCO INC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION28

- Bryer
Hugo & PARKER
EMAC TREE

IFES:
Sev Francs, EX ONE

business and, if called as a witness, I could and would testify competently thereto.

2. Attached as “Exhibit A” is a true and correct copy of Plaintiff Louis
Castagna’s Complaint for Personal Injury-Asbestos.

3. Attached as “Exhibit B “ is a true and correct copy-of Defendant NIBCO
INC’s Special Interrogatories to Plaintiff Louis Castagna, Set one.

4. Attached as “Exhibit C” is a true and correct copy of Plaintiff's Responses
to Defendant NIBCO Inc’s Special Interrogatories, Set One.

5. Attached ag "Exhibit D” is a true and correct copy of Defendant NIBCO
INC’s Request for Production of Documents to Plaintiff Louis Castagna, Set one. ©

6. Attached as “Exhibit E” is a true and correct copy of Plaintiff's Response to
Defendant. NIBCO INC’s Request for Production of Documents, Set one.

7. Attached as “Exhibit F” is a true and correct copy of Plaintiff's
Supplemental/Amended Responses to Interrogatories, Set Nos. One and Two.

8 Attached as "Exhibit G” are true and correct copies of Excerpts from the
Deposition of Louis Castagna, Volumes-10, 17 and 18 taken on April 7, 2009, January 29,
2010, and February 19, 2010, respectively.

9. Attached as “Exhibit H “ is a true and correct copy of an Excerpt from the
Deposition of John Fening taken on November 20, 2009 in the matter of David Prince v.
Aqua Chem, Ine, et al, LASC No. BC389759.

i declare under penalty of perjury that the foregoing is true and correct.

Executed on June 22, 2010, in San Jose, California.

fun Ye

Ken L. Hoang

2

BECLARATION OF KEN L, HOANG IN SUPPORT OF DEFENDANT NIBCO INC’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION