Exhibit,Appendix: LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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                                JEFFREY M. VUCINICH, ESQ. BAR#: 67906

STEPHEN V. HARRINGTON, ESQ. BAR#: 222064
CLAPP, MORONEY, BELLAGAMBA, VUCINICH, ELECTRONICALLY

BEEMAN & SCHELEY

A PROFESSIONAL CORPORATION
1111 Bayhill Drive, Suite 300

San Bruno, CA 94066

(650) 989-5400 (650) 989-5499 FAX

Attorneys for Defendant
CONTRA COSTA ELECTRIC, INC.

FILED

Superior Court of California,
County of San Francisco

JUN 23 2010

Clerk of the Court
BY: JUDITH NUNEZ
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA.

COUNTY OF SAN FRANCISCO
LOUIS CASTAGNA, ASBESTOS
CASE NO. CGC-07-274230
Plaintiff,

vY

ASBESTOS DEFENDANTS (BP) As
Reflected on Exhibits B, B-1, C, D,H, I;
and DOES 1-8500,

Defendants.

G:\Data\DOCS\0431\03845\MS7\Bxhd

EXHIBIT 4 OF INDEX OF EXHIBITS IN
SUPPORT OF DEFENDANT CONTRA
COSTA ELECTRIC, INC.’S MOTION
FOR SUMMARY JUDGMENT

Date: September 9, 2010
Time: 9:30 a.m.
Dept: 220

1

EXHIBIT 4 OF INDEX OF EXHIBITS IN SUPPORT OF DEFENDANT CONTRA COSTA ELECTRIC,

INC.’S MOTION FOR SUMMARY JUDGMENTEXHIBIT 4(See

19873814

BRAYTON@PURCELL LLP

ATTORNEYS AT LAW

222 RUSH LANDING ROAD

POBOX 6165
NOVATO, CALIFORNIA 94948-6169

{435} 858-1555

ee ee
BN - Oo

14

Co we YW A hw AY

ALAN R. BRAYTON, ESQ,, 8.B, #73685
KIMBERLY J. CHU, ESQ., S.B. #206817 ee
BRAYTON*PURCELL LLP LLP LLP LLP MG
Attorneys at Law

222 Rush Landing Road

P.O. Box 6169 ,
Novato, California 94948-6169
(415) 898-1555

Nees

Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA, : ASBESTOS

No. 274230

Plaintiff, .

ANSWERS TO INTERROGATORIES

vs. :

ASBESTOS DEFENDANTS (BP)

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff LOUIS CASTAGNA.
SET NO: TWO

1, A. Jimmy A. McClanahan, Mack & Sons Trailer Repair.

B. 32410 Dearborn Street, Hayward, California 94544.

Cc. 1966, Plaintiff currently cannot be more specific as to the start date, end
date and total number of days. Plaintiff's investigation and discovery are continuing.

dD Jimmy A, McClanahan, Mack & Sons Trailer Repair, 32410 Dearborn
Street, Hayward, California 94544. . .

E. Brake Mechanic.

fF Plaintiff replaced brakes, brake linings and wheel beatings on 40-foot
trucks. Plaintiff had to grind brakes durin, repairs and reline metal frames with new asbestos-
containing brake linings manufactured by BENDIX. .

es.

Plaintiff recalls working in various areas.
Please see response to Interrogatory No. 1C, above.
See Exhibit No, 2, attached.
See Exhibit No. 3, attached.
See Exhibit No. 4, attached.
See Exhibit No. 5, attached.
See Exhibit No. 6, attached.

MaAVPe Sr

KAlnjured\02208\AE-sacsI2.wpd I8-9. See Exhibit No. 7, attached,
10, Yes. .

. . a. Plaintiff replaced brakes, brake linings and wheel bearings.
Plaintiff had to grind brakes during repairs and reline metal frames with new asbestos-containing
brake linings manufactured by BENDIX. Plaintiff currently cannot identify the manufacturer of
each asbestos-containing product. Plaintiff performed his work indoors. Plaintiff's investigation
and discovery are continuing.

. Please ste response to Interrogatory No. IF, above.
c-e, Plaintiff does not recall any safety precautions to protect
him from breathing dust.

Wl, Yes, .
a. Please refer to Interrogatory No. LF, above.
db Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite, Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to him at this time. Plaintiff's investigation and
discovery are continuing, - . :
& Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite. Plaintiff's investigation and discovery are continuing.

. d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

. e.(iti) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing.

f-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust,
2. See Exhibit No. 8, attached.
3, See Exhibit No. 9, attached.

lL ALB. S. S$ HENRY G. DALTON (1916).
Cc. July 25 to September 21, 1967; September 22 to October 1, 1967; and

October 1 to November 8, 1967. Plaintiff currently cannot be more specific as to the start date,
end date and total number of days. Plaintiff's investigation and discovery are continuing.
Interlake Steamship Company. .

BE. Wiper, and Fireman (September 22 to October 1, 1967).

F. Plaintiff was a wiper on board . Plaintiff performed
general maintenance in the engine room, Plaintiff cleaned generators. Plaintiff chipped and
scraped asbestos insulated pipes. Plaintiff repaired insulation on pipes using EAGLE-PICHER
insulation cement and pipecovering, JOHNS-MANVILLE pipecovering, and PABCO insulation
cement. Plaintiff poured the insulation cement into a 55 gallon drum and added water, Plaintiff
mixed and handled the insulation with his hands, Plaintiff used ANCHOR PACKING packing
for valves, ANCHOR gasket materials, GARLOCK gaskets (cut and fitted), and asbestos
welding blankets. Plaintiff recalls the boilers were manufactured by FOSTER WHEELER.

. es.

1. Plaintiff recalls working in various areas, including the engine

room.
Please s¢e response to Interrogatory No. 1C, above.
See Exhibit No. 2, attached.
See Exhibit No. 3, attached,
See Exhibit No. 4, attached.
See Exhibit No. 5, attached.
See Exhibit No. 6, attached.
~9. See Exhibit No. 7, attached,
0. Yes.

SEN ABALN

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| asbestos insulated pipes. Plaintiff repaired insulation on pipes using EAGLE-P.
. cement and pipecovering, JOHNS-MANVILLE pipecovering, and PABCO insulation cement.

a Plaintiff cleaned generators. Plaintiff chipped and scraped

Plaintiff poured the insulation cement into a 55 gallon drum and added water. Plaintiff mixed
and handled the insulation with his hands. Plaintiff used ANCHOR PACKING packing for
valves, ANCHOR gasket materials, GARLOCK gaskets (cut and fitted), and asbestos welding
blankets. Plaintiff recalls the boilers were manufactured by FOSTER WHEELER. Plaintiff
performed his work indoors, Plaintiff's investigation and discovery are continuing.

Please see response to Interrogatory No. 1F, above.
c-e. Plaintiff does not recall any safety precautions to protect

him from breathing dust.
Th. Yes. 7
a Please refer to Interrogatory No. 1F, above. :
b. Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite. Plaintiff currently cannot identify the -
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to him at this time, Plaintiffs investigation and
discovery are continuing. :
. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite. Plaintiff's investigation and discovery are continuing. —_-

d. ‘The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

eici) -The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing,

him from breathing dust.
2, See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B. SS. WALTER E. WATSON (1920),
April 9 to 25, 1968; May 2 to 27, 1968; May.31 to October 5, 1968;

c.
October 6 to 10, 1968; and October 14 to 22, 1968. Plaintiff currently cannot be more specific as|
to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

e

f-h. Plaintiff does not recall any safety precautions to protect

D. Interlake Steamship Company.
E. Wiper; and Oiler (May 31 to October 5, 1968; and October 14 to 22, 1968)
F. On board WALTER E. WATSON, plaintiff was a fireman. Plaintiff
erformed routine maintenance, maintained fire boxes in FOSTER WHEELER boilers, cleaned
Poer tubes, and repaired boilers. Plaintiff replaced GARLOCK gaskets, replaced valves, and re}
packed valve stems. Plaintiff opened and closed manways, steam drums, and mud drums.
. es,

1 Plaintiff recalls working in various areas.

2. Please see response to Interrogatory No. 1C, above.
3 See Exhibit No, 2, attached.

4. See Exhibit No. 3, attached,

5. See Exhibit No. 4, attached.

6. Sce Exhibit No. 5, attached.

i. See Exhibit No. 6, attached.

8.-9, See Exhibit No. 7, attached.

10. :
Plaintiff maintained fire boxes in FOSTER WHEELER

: a.
boilers, cleaned boiler tubes, and repaired boilers. Plaintiff replaced GARLOCK gaskets,
replaced valves, and re-packed valve stems. Plaintiff opened and closed manways, steam drums,

KAlnjwec\O2298\AI sacs 2.wpd 3

CHER insulation} -CO OM WA Ww eR WL

10

and mud drums. Plaintiff used the same products described for employment on the $.S. HENRY)
G, DALTON (1916), above. Plaintiff currently cannot identify the manufacturer of each
asbestos-containing product. Plaintiff performed his work indoors. Plaintiff's investigation and
discovery are continuing.

. Please see response to Interrogatory No. IF, above.

. c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust. :
ll. Yes. :
a Please réfer to Interrogatory No. 1F, above.

, bt. Plaintiff believes he was exposed to raw asbestos or
asbestos-containing materials by others at this worksite. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known'to him at this time. Plaintiff's investigation and
discovery are continuing,

ek Plaintiff is not an expert in the identification‘of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite, Plaintiff's investigation and discovery are continuing.

. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

etic) The trades were located in and around all areas of this

worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are

continuing. :
f£-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust. .
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B. §.S. WILLIAM P. SNYDER JR, (1906).
C. April 2 to September 23, 1969, and July 15 to September 25, 1970.

Plaintiff currently cannot be more specific as to the start date, end date and total number of days.
Plaintiff's investigation and discovery are continuing.
. Dd, Interlake Steamship Company.
E. Oiler. :
F, As an oiler on boatd WILLIAM P. SNYDER JR.., plaintiff checked gauges|
and ensured all operating and lubricated, and cleaned filters for water intakes and FOSTER
WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and DELAVAL steam
turbines.
Yes.

1 Plaintiff recalls working in various areas.
2. Please see response to Interrogatory No. 1C, above.
3 See Exhibit No. 2, attached.
4, See Exhibit No. 3, attached.
5. ° See Exhibit No. 4, attached,
6. See Exhibit No. 5, attached,
2. See Exhibit No. 6, aftached,
8.-9. See Exhibit No. 7, attached.
. 10. Yes. _
a. Plaintiff checked ga es and ensured all operating and
lubricated, and cleaned filters for water intakes and FOST: WHEELER boilers. Plaintiff also
cleaned heat exchangers, generators, and DELAVAL steam turbines. Plaintiff used the same
products described for employment on the, 1. IN (1916), above. Plaintiff
curently cannot identify the manufacturer of each asbestos-containing product, Plaintiff
performed his work indoors Plaintiff's investigation and discovery are continuing.
. Please see response to Interrogatory No. LF, above.
c-e. Plaintiff does not recall any safety precautions to protect

KAlnjured\102298\AL-sa0st2.sypd 4Oo me ND HH F WH

10

him from breathing dust.
ll. Yes.
a, Please refer to Interrogatory No. IF, above.

. be Plaintiff believes he was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to him at this time. Plaintiff's investigation and
discovery are continuing.

. c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to engineers, wipers, firemen, and
oilers. Plaintiff's investigation and discovery are continuing.

. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials, Plaintiffs investigation and discovery are continuing.

. , 26H) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing, .

fi-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust,
. + See Exhibit No. 8, attached.
3. See Exhibit No, 9, attached.

1. A. Emerald Mining Company.
B. Unknown location.
Cc. 1968 to 1970. Plaintiff currently cannot be more spécific as to the start
date, end date and total number of days. Plaintiffs investigation and discovery are continuing.
Emerald Mining Company, c/o Diamond Shamrock Corporation, 1100
Superior Avenue, Cleveland, Ohio 44114, .
E. Merchant Marine. .
F. Plaintiff is currently unable to recall the specifics of this employment.
G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

1 A Liberty Bell. . .
. B 109 Fifth Avenue South, Hurley, Wisconsin 54534,
c, 1967, Plaintiff currently cannot be more specific as to the start date, end
date and total number of days. Plaintiff's investigation and discovery are continumg, .
. Pamela & Fred Fontecchio & Betty Lehocky, Liberty Bell, 109 Fifth
Avenue South, fiarley, | Wisconsin 54534.

‘ook.
F. Plaintiff prepared and cooked pizzas, while employed at this family-owned

G. _ See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached. .
3. See Exhibit No. 9, attached.

1. A. Hammermifl Paper Company.
B. Erie, Pennsylvania. .
Cc. October to December 1968. Plaintiff currently cannot be more specific as
to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing. :

business.

D. Manpower, Incorporated & Domestic Subsidiaries, Post Office Box 1300,
Milwaukee, Wisconsin 53201.

E, Clerk. oo,
F, Plaintiff worked in the shipping and receiving room sending out paper

KXinjured\102298\AF-sacsE2.wpd 5wR WN

orders, Plaintiff would go through the plaut and encountered paper line (rollers) area and
observed mechanical work being done, . . .
. 8. .
Plaintiff worked in the shipping and receiving room.
Please. see response to Interrogatory No. 1C, above,
it No. 2, attached,
it No. 3, attached,

-9, See Exhibit No. 7, attached.

Yes .
a. Plaintiff believes he was exposed to raw asbestos or
asbestos-containing materials at this worksite. Plaintiff currently carmot identify the
manufacturer of each asbestos-containing product, Plaintiff performed his work indoors.
Plaintiff's investigation and discovery are continuing.

s Please see. response to Interrogatory No. 1F, above.
ee. Plaintiff does not recall any safety precautions to protect

Yes,

a. Please refer to Interrogatory No. LF, above.

b, Plaintiff would go through the plant and encountered paper
ling (rollers) area and observed mechanical work being done. Plaintiff: believes he was exposed
to rai asbestos or asbestos-containing materials by others at this worksite. Plaintiff currently
cannot identify the manufacturer of each asbestos-containing product. Plaintiff may have been in
close proximity to asbestos-containing products not known to him at this time. Plaintiff's
investigation and discovery are continuing.

C Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite. Plaintiff's investigation and discovery are continuing.

d. ‘The trades were installing, disturbing and/or handling the
asbestos products, Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

et) ‘The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing. °

him. frorm breathing, dust

f-h. Plaintiff does not recall any safety precautions to’ protect
him from breathing dust,

2. See Exhibit No. 8, attached,

3. See Exhibit No. 9, attached.

1. A. Valley Engineers, Incorporated. .
B. 2610 West Shaw Lane, Suite 104, Fresno, California . .
Cc. October to December 1969, Plaintiff currently cannot be more specific as
to the start date, end date and total number of days. Plaintiff's investigation and discovery are ~

continuing. , -

Dd. Valley Engineers, Incorporated, 2610 West Shaw Lane, Suite 104, Post
Office Box 12227, Fresno, California 93777-2227.

EL Steamfitter. . ey .

F. Plaintiff performed work on a pipeline. Plaintiff laid pipes and assisted
welder. Plaintiff recalls handling LINCOLN FLEE D 5P welding rods on a daily basis and
installing PLEXITALLIC gaskets.

Yes.

1. Plaintiff recalls working in various areas. *

2. Please see response to Interrogatory No. 1C, above.

3. Plaintiff recalls supervisor Damon Leaper, address currently

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unknown.
4 See Exhibit No, 3, attached.
5, See Exhibit No. 4, attached.
6. See Exhibit No. 5, attached,
1. See Exhibit No. 6, attached.
8.-9. See Exhibit No. 7, attached.

10, Yes, :

. a, Plaintiff laid ph es. Plaintiff recalls handling LINCOLN
FLEETWELD 5P welding rods and installing FLEXITALLIC gaskets, Plaintiff currently cannot
identify the manufacturer of each asbestos-containing product. Plaintiff performed his work
indoors. Plaintiff's investigation and discovery are continuing. ,

. Please see response to Interrogatory No. 1F, above.
. oo ce. Plaintiff does not recall any safety precautions to protect

him from breathing dust.

11.

Yes, .
a. Please refer to Interrogatory No. 1F, above.
b Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite, Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing prodacts not known to him at this time. Plaintiff's investigation and
discovery are continuing.

c Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite. Plaintiffs investigation and discovery are continuing.

d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

e(i-ii) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing,

8 f£-h. - Plaintiff does not recall any safety precautions to protect
him from breathing dust.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A. Pipeline.
B. Grass Valley, California,
Cc October 22 to November 16, 1969, Plaintiff currently cannot be more
specific as to the start date, end date and total number of days. Plaintiff's investigation and
iscovery are continuing. ., oo,
dD. ARB, Incorporated, 26000 Commercentre Drive, Lake Forest, California
92630, - “ :

E. —_ Steamfitter (apprentice). a
F, Plaintiff laid pipes and installed FLEXITALLIC gaskets. Plaintiff assisted
a welder and handled LINCOLN FLEETWELD 5? welding rods. Plaintiff ground welds with a
MILWAUKEE grinder and changed the grinding wheels.
- 8.

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.
Plaintiff recalls supervisor Damon Leaper, address currently
unknown.

it No. 6, attached.

2
3
4.
5.
6
8-9. See Exhibit No. 7, attached.

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10

10. Yes,
a Plaintiff laid pipes and installed FLEXITALLIC gaskets.
Plaintiff assisted a welder and handled LINCOLN FLEETWELD SP welding rods, Plaintiff
ground welds with a MILWAUKEE grinder and changed the grinding wheels, Plaintiff
performed his work indoors and outdoors. Plaintiff's investigation and discovery are continuing.
. Please see response to Interrogatory No. if, above.
c-e. Plaintiff does not recall any safety precautions to protect

him fiom breathing dust.
il. Yes.
a. Please refer to Interragatory No. 1F, above.
b. Plaintiff recalls working around laborers cleaning and

, sweeping. Plaintiff currently cannot identify the manufacturer of each asbestos-containing
own

product, Plaintiff may have been in close proximity to asbestos-containing products not
to him at this time. Plaintiff's investigation and discovery are continuing.

ee c. jaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to laborers. Plaintiffs
investigation and discovery are continuing,

. d. The trades were installing, disturbing and/or handling the.,
asbestos prodicts. Plaintiff, at this.time, does not recall the specific manner in which each trade
used the asbestos-containing materials, Plaintiff's investigation and discovery are continuing.

. e.(i-ii) The trades were located in and around all areas of this
worksite in close proxisity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing.

: f-h. Plaintiff does not recall any safety precautions to protect

him from breathing dust. .
. See Exhibit No. 8, attached.

3. See Exhibit No. 9, attached.

1. A San Leandro Equipment Rental, Incorporated.

B. San Leandro, California. .

c. January to March 1970, Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

D. San Leandro Equipment Rental, Incorporated, 4 Greenwich Office Park,
Greenwich, Connecticut 06831.

EL Maintenance Mechanic. |

F. Plaintiff replaced exhaust gaskets on BRIGGS & STRATTON gasoline
motors in lawnmowers. Plaintiff maintained and repaired lawnmowers, gardening equipment,
and cement mixers.

g

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.
See Exhibit No. 2, attached. .

See Exhibit No. 3, attached.

See Exhibit No, 4, attached.

See Exhibit No. 5, attached.

See Exhibit No. 6, attached.

See Exhibit No. 7, attached.

Yes.

“ a. Plaintiff replaced exhaust gaskets on BRIGGS &
STRATTON gasoline motors in lawnmowers. Plaintiff maintained and repaired lawnmowers,
gardening equipment, and cement mixers, Plaintiff currently cannot identify the manufacturer of
each asbestos-containing product. Plaintiff performed his work indoors. Plaintiff's investigation
and discovery are continuing.

SON ARER LN

“oS

. Please see response to Interrogatory No. LF, above.
ce, Plaintiff does not recall any safety precautions to protect

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°

wheels.

him from breathing dust

ll. ¥es,
a. Please refer to Interrogatory No. LF, above.
. ob Plaintiff believes he was exposed to raw asbestos or
asbestos-containing materials by others at this worksite. Plaintiff currently cannot identify the

manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to him af this time, Plaintiff's investigation and
discovery are continuing.

. c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite, Plaintiff's investigation and discovery are continuing.

a . _ The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manrier in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

_, . e(i-it) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

f-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust.
- See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A. Pipeline.
B. 3" Street & Addison Street, Berkeley, California. .
Cc. April 1 to June 1970. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing. :
144 Dd. Lyles Diversified, Incorporated, Post Office Box 4376, Fresno, California
93744. .
E, Steamfitter (apprentice).
F. Plaintiff laid underground pipes and installed FLEXITALLIC gaskets.
Plaintiff assisted welders and handled LINCOLN FLEETWELD 5P welding rods and asbestos
welding blankets. Plaintiff ground welds with a MILWAUKEE grinder and changed grinding

Yes, ‘

1, Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.
Plaintiff recalls supervisor Damon Leaper, address currently

See Exhibit No. 3, attached.

See Exhibit No. 4, attached.

See Exhibit No. 5, attached.

See Exhibit No, 6, attached.
9. See Exhibit No. 7, attached.
0. Yes.
a. Plaintiff laid underground fi es and installed
FLEXITALLIC gaskets, Plaintiff assisted welders and handled LINCOLN FLEETWELD SP
welding rods and asbestos welding blankets. Plaintiff ground welds with a MILWAUKEE
grinder and changed grinding wheels. Plaintiff performed his work indoors and outdoors.
Plaintiff's investigation and discovery are continuing.

b. Please see response to Interrogatory No. IF, above.

ce. Plaintiff does not recall any safety precautions to protect

pp

unknown,

pos

him from breathing dust,
11 Yes.
a Please refer to Interrogatory No. 1F, above.
b. Plaintiff recalls working around laborers cleaning and

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moe ee
BR SS

sweeping. Plaintiff currently cannot identify the manufacturer of each asbestos-containing
product. Plaintiff may have been in close proximity to asbestos-containing products not known.
to him at this time. Plaintiff's investigation and discovery are continuing.

c. Jaintiff is not an: expert in the identification of trades,
however plaintiff currently recalls working in close proximity to laborers, Plaintiffs
investigation and discovery are continuing.

. d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

. 2.8) The trades were located in and around all areas of this
worksite in close proximity to plaintiffs work area. Plaintiff's investigation and discovery are
continuing. :

f-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust,
2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

1, A Jensens Furniture.

B. 18050 Hesperian Boulevard, San Lorenzo, California,

Cc October 1970 to March 1971. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing. ‘ .

p. Schwartz & Schwartz, Jensens Furniture, 18050 Hesperian Boulevard, San
Lorenzo, California 94580. .

Deliveryman.

F, Plaintiff set up displays and delivered furniture. Plaintiff replaced tiles

with ARMSTRONG finoleam tiles in the apartments’ laundry rooms.
. es.

Plaintiff recalls working in various areas.
Please see response to Interrogatory No. 1C, above.
See Exhibit No, 2, attached.
See Exhibit No. 3, attached.
See Exhibit No. 4, attached,
See Exhibit No. 5, attached,
. See Exhibit No. 6, attached.
9, See Exhibit No. 7, attached.
10. Yes. ‘
a. Plaintiff replaced tiles with ARMSTRONG linoleum tiles.
Plaintiff performed his work indoors. Plaintiff's investigation and discovery are continuing.
. Please see response to Interrogatory No. IF, above.
c-e. Plaintiff does not recall any safety precautions to protect

MAW ALN

him from breathing dust.
ll, Yes. .
a. Please refer to Interrogatory No, LF, above. .
b, Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite, Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product, Plaintiff may have been in close proximity to
asbestos-containing products not known to him at this time. Plaintiff's investigation and
discovery are continuing, .

c. °  Plaintiffis not an expert in the identification of trades,
however plaintiff currently recalls working:in close proximity to various other trades at this
worksite. Plaintiff's investigation and discovery are continuing. :

‘ d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

e.(i-ii) The trades were located in and around ali areas of this

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RM PN NY NR NR NY YB Se Boe ew Be Be ew ee
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worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing. . .
. f-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust.

2. See Exhibit No. 8, attached.

3 See Exhibit No. 9, attached.

1. A. Caesars of Paris.

B, Indianapolis, Indiana.

c. January to March 1971. Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

D. -_ Seneca Ventures Limited, Incorporated, Caesars of Paris, 1347 West 86"
Street, Indianapolis, Indiana 46260. . .

B. Bus boy,

FE Plaintiff bussed tables.

G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached,

1. A-B. GOVERNOR MILLER (1938).
. C. June 30 to November 3, 1971. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing.

dD US. Steel.
. E. Oiler.

B Plaintiff checked gauges and cleaned filters for water intakes and FOSTER)
WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and DELAVAL steam
turbines, Plaintiff chipped and scraped asbestos insulated pipes. Plaintiff repaired insulation on
pipes using EAGLE-PICHER insulation cement and pipecovering, JOHNS-MANVILLE
pipecovering, and PABCO insulation cement. Plaintiff poured the insulation cement into a 55
gi lon drum and added water. Plaintiff mixed and handled the insulation with his hands.

laintiff used ANCHOR PACKING packing for valves, ANCHOR gasket materials, GARLOCK|
gaskets (cut and Fitted), and asbestos welding blankets.
. es.

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.

See Exhibit No. 2, attached.

See Exhibit No. 3, attached,

See Exhibit No, 4, attached.
- See Exhibit No. 5, attached.
See Exhibit No. 6, attached.
9. See Exhibit No. 7, attached.
10. Yes. .
Ae Plaintiff checked gauges and cleaned filters for water
intakes and FOSTER WHEELER boilers. Plaintiff also cleaned: heat exchangers, generators, and|
DELAVAL steam turbines. Plaintiff chipped and scraped asbestos insulated pipes. Plaintiff
repaired insulation on pipes using EAGLE-PICHER insulation cement and pipecovering,
JOHNS-MANVILLE pipecovering, and PABCO insulation cement. Plaintiff poured the
insulation cement into a 55 gallon drum and added water. Plaintiff mixed and handled the
insulation with his hands. Plaintiff used ANCHOR PACKING packing for valves, ANCHOR
gasket materials, GARLOCK gaskets (cut and fitted), and asbestos welding blankets. Plaintiff
performed his work indoors. Plaintiff's investigation and discovery are continuing.

b. Please see response to Intetrogatory No. 1F, above.

c:e. ~ Plaintiff does not recall any safety precautions to protect

PIAWALNS

him from breathing dust,

KAinjured 102208 l-saest. upd 11SCO em RA UW Fk YH

continuing.
2701 Dd. Marathon Oi] Corporation, 5555 San Felipe Street, Houston, Texas 77056-
a BE. Unknown.

F.° Plaintiff is currently unable to recall the specifics of this employment,

ll. Yes.

a Please refer to Interrogatory No. IF, above,

b Plaintiff believes he was exposed to raw asbestos or
asbestos-containing materials by others at this worksite. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to him at this time. Plaintiff's investigation and
discovery are continuing.

Plaintiff is not an expert in the identification of trades,

however plaintiff currently recalls working in close proximity to engineers, wipers, firemen, and}.

oilers. Plaintiff's investigation arid discovery are continuing,

. The trades were installing, disturbing, and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos~ -containing materials, Plaintiff's investigation and discovery are continuing.

e. Ce ii) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing.

f-h, Plaintiff does not recall any safely precautions to protect

him from breathing dust. .
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

Lh A Marathon Oil Corporation.
B. Unknown location.
Cc July 1971 to June 1972, Plaintiff currently canmot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are

G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached.
3. See Exhibit No, 9 attached,

1. A.’ Hotel Valley Ho.

B. Scottsdale, Arizona.

c. October to December 1971. Plaintiff currently cannot be more specific as
to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

Dd. Westward Ho Junior Hotel Company, Inearporated, Hotel Valley Ho, 635(
Main Street, Scottsdale, Arizona 85008; 3838 East Van Buren, Phoenix, Arizona 85008.

Maintenance Mechanic. .

r Plaintiff maintained refrigeration units and inspected pauges.

G. _ See Exhibit No. 1, attached.

2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A. Ramada Inn.

B. Scottsdale, Arizona.

Cc. January to March 1972. Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

amada, Incorporated c/o Marriott Corporation, 1 Marriott Drive,
Washington, Dg “o0sb 0001 . .
E. Maintenance Mechanic.
F, Plaintiff maintained refrigeration units and inspected gauges.

KAinjured\NO2298\A bsacsf2.wpd 12oo we MB A wm RB BN

G. See Exhibit No. I, attached.
2 See Exhibit No. 8, attached.
3. See Exhibit No, 9, attached.

1. AB. ARTHUR M. ANDERSON (1952).

Apri! 12 to May 4, 1972; and May 5 to 31, 1972. Plaintiff currently canno
be more specific as to the start date, end date and total number of days. Plaintiff's investigation
and discovery are continuing. .

D. U.S. Steel,

g, Oiler. .

_&F Plaintiff checked gauges and cleaned filters for water intakes and FOSTER!
WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and DELAVAL and
GENERAL ELECTRIC steam turbines. Plaintiff chipped and scraped asbestos insulated pipes.
Plaintiff repaired insulation on pipes using EAGLE-PICHER insulation cement and
pipecovering, JOHNS-MANVILLE pipecovering, and PABCO insulation cement. Plaintiff
poured the insulation cement into a 55 gallon drum and added water, Plaintiff mixed and
handled the insulation with his hands. Plaintiffused ANCHOR PACKING packing for valves,

ANCHOR gasket materials, GARLOCK gaskets (cut and fitted), and asbestos welding blankets.
- es.

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.
See Exhibit No. 2, attached,

See Exhibit No. 3, attached,

See Exhibit No. 4, attached.

See Exhibit No. 5, attached.

See Exhibit No. 6, attached.

-9. See Exhibit No. 7, attached.

PON AUS
BRN ATR Ar

es.
a. Plaintiff checked gauges and cleaned filters for water

intakes and FOSTER WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and|

DELAVAL and GENERAL ELECTRIC steam turbines. Plaintiff chipped and scraped asbestos
insulated pipes. Plaintiff repaired insulation on pipes using EAGLE-PICHER insulation cement
and Pipesovering. JOHNS-MANVILLE pipecovering, and PABCO insulation cement. Plaintiff
joured the insulation cement into a 55 gallon drum and added water. Plaintiff mixed and
andled the insulation with his hands, Plaintiff used ANCHOR PACKING packing for valves,
ANCHOR gasket materials, GARLOCK gaskets (cut and fitted), and asbestos welding blankets.

Plaintiff currently cannot identify the manufacturer of each asbestos-containing product. Plaintiff .

performed his work indoors. Plaintiff's investigation and discovery are continuing.

b. Please see response to Interrogatory No. 1F, above.
c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust .

Yes,
a. Please refer to Interrogatory No. 1F, above.
b, Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product, Plaintiff may have been in close proximity to
asbestos-containing products not known fo him at this time. Plaintiff's investigation and
discovery are continuing. a | .
c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to engineers, wipers, firemen, and
oilers. Plaintiff's investigation and discovery are continuing.

. d. The trades were installing, disturbing and/or handling the
asbestos products, Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

e.i-il) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work’area. Plaintiff's investigation and discovery are

KAlnjured\O2I9RALsacst2.wpd ‘ 13oO we TN AA FR BW wR

- 2

continuing.
f-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust. :
2. See Exhibit No. 8, attached,
3. See Exhibit No..9, attached.
1, A. Yosemite Park & Curry Company Lodge.
B. Yosemite Park, California, :
C. July to December 1972, Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are .
continuing. .
D. Yosemite Park & Curry Company, 100 Universal City Plaza, Universal
City, California 91608,
gE, Groundskeeper.
F Plaintiff gardened and cleaned the sidewalks.
G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

L. AB. TALUGA (AQ-62); and at Triple A Machine Shop, Pier 64, San.
Francisco, California (about 3 to 7 days).

. April to September 1972; and April to June 1973. Plaintiff currently
cannot be more specific as to (he start date, end date and total number of days. Plaintiff's
investigation and discovery are continuing.

_ 7D Commander Military Sealift Com, Pac. Naval Submarine Base, Military
Sealift Com. Pas. Code NBs, 140 Sylvester Road, N84, San Diego, California 92106.
. er.

F.: Plaintiff checked gauges and cleaned filters for water intakes and FOSTER|
WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and DELAVAL steam
turbines. Plaintiff chipped and scraped asbestos insulated pipes. Plaintiff repaired insulation on
pipes using EAGLE-PICHER insulation cement and pipecovering, JOHNS-MANVILLE
pipecovering, and PABCO insulation cement. Plaintiff poured the insulation cement into a 55
alion drum and added water. Plaintiff mixed and handled the insulation with his hands.
laintiff used ANCHOR PACKING packing for valves, ANCHOR gasket materials, GARLOCK
gaskets (cut and fitted), and asbestos welding blankets. Plaintiff fueled other ships.
\. es,
Plaintiff recalls working in various areas. -
Please see response to Interrogatory No. 1C, above.
See Exhibit No. 2, attached,
See Exhibit No. 3, attached.
See Exhibit No. 4, attached.
See Exhibit No. 5, attached.
. See Exhibit No. 6, attached.
9. See Exhibit No. 7, attached.
10: Yes. : :
“ a. Plaintiff checked gauges and cleaned filters for water
intakes and FOSTER WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and|
DELAVAL steam turbines: Plaintiff chipped and scraped asbestos insulated pipes. Plaintiff .
repaired insulation on pipes using EAGLE-PICHER insulation cement and Pipecovering,
JOHNS-MANVILLE pipecovering, and PABCO insulation cement. Plaintiff poured the
insulation cement into a $5 gallon ‘drum and added water. Plaintiff mixed and handled the
insulation with his hands. Plaintiffused ANCHOR PACKING packing for valves, ANCHOR
gasket materials, GARLOCK gaskets (cut and fitted), and asbestos welding blankets. Plaintiff
performed his work indoors and outdoors. Plaintiff's investigation and discovery are continuing.
. ob Please see response to Interrogatory No. 1F, above.
c-e. Plaintiff does not recall any safety precautions to protect

ON AARNE

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| September 17 to Decemt

him from breathing dust,
tl. Yes,
a Please refer to Interrogatory No. 1f, above.

b. Plaintiff lived on board while repairs were being done at
Triple A. Plaintiff currently cannot identify the manufacturer of each asbestos-containing
product. Plaintiff may have been in close proximity to asbestos-containing products not known
to him at this time. Plaintiff's investigation and discovery are continuing. .

oe Plaintiff is not an, expert in the identification of trades,
however plaintiff currently recalls working in close proximity to engineers, wipers, firemen, and
oilers; and the following trades working for TRIPLE A: machinists, mechanics, and welders.
Plaintiff's investigation and discovery are continuing.

d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

. e(i-ii) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

f-b. Plaintiff does not recall any safety precautions to protect
him from breathing dust.

See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A. HECLA Mining Company.
B, Casa Grande, Arizona.
CG January to March 1973. Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing. “
HECLA Mining Company, 6500 North Mineral Drive, Coeur D'Alene,
Idaho 83815. :
E. Miner. -
F, Plaintiff mined for copper.
G. _ See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached,

1. A-B. THOMAS WILSON (1943).
Cc. April 11 to August 3, 1973; August 7 to September 1, 1973; and
er 14, 1973. Plaintiff ourrently cannot be more specific as to the start
date, end date and total number of days. Plaintiff's investigation and discovery are continuing.
D. Kinsman Marine Transit Company, Bond Court Building, Suite 911,
Cleveland, Obig 4414.

Oiler.
F, Plaintiff checked gauges and cleaned filtérs for water intakes and FOSTER|

WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and DELAVAL steam
turbines. Plaintiff chipped and scraped asbestos insulated pipes. Plaintiffrepaired insulation on
pipes using EAGLE-PICHER insulation cement and pipecovering, JOHNS-MANVILLE
pipecovering, and PABCO insulation cement, Plaintiff poured the insulation cement into a 55

allon drum and added water. Plaintiff mixed and handled the insulation with his hands.

laintiff used ANCHOR PACKING packing for valves, ANCHOR gasket materials, GARLOCK
gaskets (cut and, fitted), and asbestos welding blankets.

. es.

Plaintiff recalls working in various areas.

Please sec onse to Interrogatory No. 1C, above.
See Exhibit No. 2, attached. ,

See Exhibit No. 3, attached.

See Exhibit No. 4, attached.

Rw he

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6, See Exhibit No. 5, attached,
7 See Exhibit No. 6, attached.
8.9. See Exhibit No. 7, attached.
10, Yes.

a. Plaintiff checked gauges and cleaned filters for water
intakes and FOSTER WHEELER boilers. Plaintiff also cleaned heat exchangers, generators, and|
DELAVAL steam turbines, Plaintiff chipped and scraped asbestos insulated pipes. Plaintiff
repaired insulation on pipes using EAGLE-PICHER insulation cement and Pipecovering,
JOHNS-MANVILLE pipecovering, and PABCO insulation cement. Plaintiff poured the
insulation cement into a 55 gallon drum and added water. Plaintiff mixed and handled the
insulation with his hands. Plaintiff used ANCHOR PACKING packing for valves, ANCHOR
gasket materials, GARLOCK. gaskets (cut and fitted), and asbestos welding blankets. Plaintiff
performed his work indoors. Plaintiff's investigation and discovery are continuing.

b Please see response to Interrogatary No. 1F, above.
c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust. :
. ll. Yes.
a. Please refer to Interrogatory No. 1F, above,
b Plaintiff believes he was exposed to raw asbestos or

asbestos-containing materials by others at this worksite: Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiffmay haye been in close proximity to
asbestos-containing products not known to him at this time. Plaintiff's investigation and
discovery are continuing. :
c Plaintiff is not an expert in the identification of trades,
however plaintift ourrently recalls working in close proximity to engineers, wipers, firemen, and
oilers, Plaintiff's investigation and discovery are continuing.

d. The trades’ were installing, disturbing and/or handling the
asbestos products, Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

etic) ‘The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing,

him from breathing dust.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

f-h. Plaintiff does not recall any safety precautions to protect

1. A Conagra Grocery Praducts Company.

B. Unknown location.

Cc. July to December 1974. Plaintiff currently cannot be more specific as to
the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing,

D, Conagra Grocery Products Company c/o Bric Johnson, One Conagra Drivel
~ CC 240, Omaha, Nebraska 68102, .

E. Unknown. .

EB, Plaintiff is currently unable to recall the specifies of this employment.

G. See Exhibit No. 1, attached. : .

2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A 3 &L Trucking Shop,
B. Hayward, California. .
Cc October to December 1974. Plaintiff currently cannot be more specific as
to the start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing, .
John Fontanct, J & L Trucking, 26712 Wauchula Way, Hayward,

KAlujured022981AL-sacal.wpd 16eo VA Ww eB BW YP

California 94545,

EB. | Mechanic. .

FB, Plaintiff replaced brake linings for semi-trailers and vans manufactured by
TRAILMOBILE, KENWORTH, and PETERBILT. Plaintiff also worked on the brake linings of
WHITE Freightliners. Plaintiff sanded brakes, Plaintiff drilled into brake linings to rivet them to|
the steel holders, Plaingtt used BENDIX brakes.

2 es,
lL Plaintiff recalls working in various areas.
2 Please see response to Interrogatory No, 1C, above.
3 See Exhibit No. 2, attached.
4, See Exhibit No. 3, attached.
5. See Exhibit No. 4, attached,
6, + See Exhibit No. 5, attached.
7. See Exh