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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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                                Eugene C, Blackard Jr, (Bar No. 142090)
Jasun C. Molineili (Bar No. 204456)

Kime H. Smith (Bar No, 230740) ELECTRONICALLY

ARCHER NORRIS

A Professional Law Corporation

2033 North Main Street, Suite 800 opel bold ED
Walnut Creek, Sea 596-3759 County of San Francisco
Telephone; — 925.930. JUN 24 2010
Facsimile: 925.930.6620 Clerk of the Court
Attorneys for Defendant BY: ALISON ae puty Clerk

ALBAY CONSTRUCTION COMPANY

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA, Case No, CGC-07-274230

Plaintiff, ALBAY CONSTRUCTION COMPANY’S
NOTICE OF MOTION AND MOTION
v. FOR SUMMARY JUDGMENT

ASBESTOS DEFENDANTS (BP), Date: September 9, 2010
Time: 9:30 a.m.

Defendant. Dept: 220

Judge: Hon. Harold E, Kahn

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

TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on September 9, 2010, at 9:30 a.m., or as soon thereafter as
this matter may be heard in Department 220 of this Court, located at 400 McAllister Street, San
Francisco, California, ALBAY CONSTRUCTION COMPANY will and does hereby move this
court to grant summary judgment pursuant to Code of Civil Procedure § 437.

This motion is made and based on the grounds that no triable issues of fact exist, in that
ALBAY CONSTRUCTION COMPANY did not cause or contribute to plaintiff LOUIS
CASTANGNA’s exposure to asbestos or asbestos-containing products.

This motion is further made and based upon this Notice, the Memorandum of Points and

Authorities, the Separate Statement of Undisputed Material Facts, the Declaration of Kime H.

ALBAY CONSTRUCTION COMPANY’S NOTICE OF MOTION AND MOTION FOR SUMMARY
JUDGMENTSmith, the Index of Exhibits and Exhibits attached thereto, the records and files in this action, and

upon such other oral, and documentary evidence as may be presented at the hearing of this

motion.

Dated: June 22, 2010

ALBO03974333-1

ARCHER NORRIS

diyst>

Kime H. Smith
Attorneys for Defendant
ALBAY CONSTRUCTION COMPANY

2

ALBAY CONSTRUCTION COMPANY'S NOTICE OF MOTION AND MOTION FOR SUMMARY

JUDGMENTPROOF OF SERVICE

Name of Action; Castagna v. Asbestos Defendants (BP), et al.
Court and Action No: San Francisco Superior No. CGC-07-274230

I, the undersigned, declare that J am over the age of eighteen years and not a party to this
action or proceeding. My business address is 2033 North Main Street, Suite 800, PO Box 8035,
Walnut Creek, California 94596-3728. On this date, I caused the following document(s) to be
served:

ALBAY CONSTRUCTION COMPANY’S NOTICE OF MOTION
AND MOTION FOR SUMMARY JUDGMENT; SEPARATE
STATEMENT OF UNDISPUTED FACTS; POINTS AND
AUTHORITIES IN SUPPORT OF ITS MOTION FOR
SUMMARY JUDGMENT; DECLARATION OF KIME H.
SMITH IN SUPPORT; INDEX OF EXHIBITS (EXHIBIT A);
EXHIBITS B through D; EXHIBIT E (3 parts); and [PROPOSED]
ORDER

[electronically served the above referenced document(s) through LEXISNEXIS FILE
AND SERVE. E-service in this action was completed on all parties listed on the
service list with LEXISNEXIS FILE AND SERVE. This service complies with the
court’s order in this case.

As Reflected on Vendor’s Transaction Receipt

I declare under penalty of perjury that the foregoing is true and correct. Executed on June

24, 2010, at Walnut Creek, California.
(dpne Gee baon

Anne M. Graham

ALBOQO3/9775 10-1

1

PROOF OF SERVICE