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

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Stephen J. Foley, Esq. SBN 220752

Lori A. Cataldo, Esq. SBN 218533
Melissa M. Corica, Esq. SBN 260905
Foley & Mansfield P.L.L.P.

1111 Broadway, 10" Floor
Oakland, CA 94607

Telephone: (510) 590-9500
Facsimile: (510) 590-9595

Attorneys for Defendant
LINDSTROM & KING CO., INC,

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

JUN 10 2010

Clerk of the Court
BY: CHRISTLE ARRIOLA
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA,
Plaintiff,

*

ASBESTOS DEFENDANTS (BP), et al.,

Defendants.

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Case No. CGC-07-274230
“Asbestos-Related Case”

EXHIBITS D THROUGH N TO THE
DECLARATION OF MELISSA M. CORICA
IN SUPPORT OF DEFENDANT LINDSTROM
& KING CO., INC.’S MOTION FOR

SUMMARY JUDGMENT

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

Dept: 220

Judge: Hon. Harold E. Kahn
Complaint Filed: August 28, 2007
Trial Date: October 12, 2010

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EXHIBITS D THROUGH N TO THE DECLARATION OF MELISSA M. CORICA IN SUPPORT OF DEFENDANT LINDSTROM & KING'S MOTION
FOR SUMMARY JUDGMENTEXHIBIT DCo ee ND eH Fe WB NH

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Stephen J. Foley, Esq. SBN 220752
Lori A. Cataldo, Esq. SBN 218533
Janell M. Alberto, Esq. SBN 239508
Foley & Mansfield PLLP

1111 Broadway, 10° Floor

Oakland, CA 94607

Telephone: (510) 590-9500

Facsimile: (510) 590-9595

Attomeys for Defendant
LINDSTROM & KING CO., INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO
LOUIS CASTAGNA, ) Case No, CGC-07-274230
)
Plaintiff, ) “Asbestos-Related Case”
)
v. ) DEFENDANT LINDSTROM & KING CO.,
) INC.’S SPECIALLY PREPARED
ASBESTOS DEFENDANTS (BP), etal, —-) INTERROGATORIES TO PLAINTIFF LOUIS
) CASTAGNA
Defendants. )
)
)
PROPOUNDING PARTY: Defendant LINDSTROM & KING CO., INC.
RESPONDING PARTY: Plaintiff LOUIS CASTAGNA
SET NUMBER: ONE

TO PLAINTIFFS AND PLAINTIFFS’ ATTORNEY OF RECORD:

Defendant LINDSTROM & KING CO., INC. (hereinafter “Lindstrom & King”) in the above-
entitled and numbered cause, serves its First Set of Specially Prepared Interrogatories pursuant to
California Code of Civil Procedure § 2030. Lindstrom & King requests that plaintiff answer the
following interrogatories under oath and in accordance with the California Code of Civil Procedure.

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DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
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DEFINITIONS

1. “YOU” and “YOUR” shail mean the plaintiff LOUIS CASTAGNA, his attomey or
attomeys and the agents, servants, and employees of the plaintiff and his attorneys.

2. “DOCUMENT(S)” means any tangible object which displays, records, or contains a
“writing” within the meaning of California Evidence Code § 250, and includes, without being limited
thereto, sales receipts, invoices, purchase orders, warning labels, deposition transcripts, brochures,
policies, procedure manuals, order forms, pay stubs, work logs, and daily time books or diaries.
Evidence Code § 250 provides: ““Writing’ means handwriting, typewriting, printing, photostating,
photographing and every other means of recording upon any tangible thing any form of communication
or representation, including letters, words, pictures, sounds or symbols, or combinations thereof.”

3. “STATEMENT” refers to an oral or written assertion, or nonverbal conduct of a person,
if it is intended by him/her as an assertion.

4, “YOU and YOUR” refers to each Responding Party, all agents, all attorneys, and anyone
acting on behalf of each Responding Party.

5. “PERSON” shall mean and include all natural persons, firm, association,
partnership, sole proprietorship, joint venture, corporation, estate, trust receiver, syndicate, municipal
corporation, and any other form of legal entity or other group or combination acting as a unit.

6. “DOCUMENT(S)’ means any tangible object which displays, records, or contains a
“writing” within the meaning of California Evidence Code § 250, and includes, without being limited
thereto, sales receipts, invoices, purchase orders, warning labels, deposition transcripts, brochures,
policies, procedure manuals, order forms, pay stubs, work logs, and daily time books or diaries.
Evidence Code § 250 provides: “‘Writing’ means handwriting, typewriting, printing, photostating,
photographing and every other means of recording upon any tangible thing any form of communication
or representation, including letters, words, pictures, sounds or symbols, or combinations thereof.”

7. “STATEMENT” refers to an oral or written assertion, or nonverbal conduct of a person,
if it is intended by him/her as an assertion.

8. “YOU and YOUR” refers to each Responding Party, all agents, all attorneys, and anyone

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DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
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acting on behalf of each Responding Party.

9. “ASBESTOS-CONTAINING MATERIAL” means a material or product which consists
of, or contains the mineral asbestos.

10. “ASBESTOS PRODUCT(S)’ as used herein, shall mean “RAW ASBESTOS” or
“ASBESTOS CONTAINING MATERIAL.”

11. With respect to an ASBESTOS PRODUCT(S), “IDENTIFY” shall mean to IDENTIFY
to the fullest extent possible the asbestos product’s manufacturer, brand name, trade name and supplier.

12. With respect to a PERSON, “IDENTIFY” shall mean to state the name, occupation,
address (or last known address), and telephone number of the person.

13, With respect to a DOCUMENT, “IDENTIFY” shall mean to state the title, if any, the
date, the originator or author, the sender(s), recipient(s) and a general description of the content of such
DOCUMENT.

14. With respect to an area, “IDENTIFY” shall mean to describe by unit number, machinery,
or physical characteristics, the particular location with specificity permitting WPC to locate where
within the facility the work occurred.

INTERROGATORIES
SPECIAL INTERROGATORY NO, 1:

IDENTIFY each insurance policy that may cover YOU in whole or in part for the damages
related to the incident that is the subject of this instant action, including but not limited to the identity of
the carrier, the nature and limits of the coverage, and the policy number.

SPECIAL INTERROGATORY NO. 2:

IDENTIFY each fact in support of YOUR contention that Lindstrom & King is liable to YOU as
alleged in YOUR Complaint.

SPECIAL INTERROGATORY NO, 3:

State the basis for YOUR contention that Lindstrom & King is liable to YOU as alleged in
YOUR complaint.
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DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
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SPECIAL INTERROGATORY NO. 4:

If YOU contend YOU were exposed to ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please IDENTIFY
each fact in support of such contention.

SPECIAL INTERROGATORY NO, 5:

If it is YOUR contention that YOU were exposed to ASBESTOS-CONTAINING MATERIAL
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please
IDENTIFY the site, location and/or place where each such alleged exposure occurred.

SPECIAL INTERROGATORY NO. 6:

If it is YOUR contention that YOU were exposed to ASBESTOS-CONTAINING MATERIAL
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please
IDENTIFY the dates of each and every such alleged exposure.

SPECIAL INTERROGATORY NO. 7:

If it is YOUR contention that YOU were exposed to ASBESTOS-CONTAINING MATERIAL
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please
IDENTIFY the name of each employer for whom YOU worked during each such alleged exposure.
SPECIAL INTERROGATORY NO. 8:

If it is YOUR contention that YOU were exposed to ASBESTOS-CONTAINING MATERIAL
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please
IDENTIFY the type of work or activity that YOU were engaged in during each such alleged exposure.
SPECIAL INTERROGATORY NO. 9:

If it is YOUR contention that YOU were exposed ta ASBESTOS-CONTAINING MATERIAL

supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please
IDENTIFY how each such exposure occurred including the specific Lindstrom & King work involved.
SPECIAL INTERROGATORY NO. 10:

If YOU contend YOU were exposed to ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please IDENTIFY

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each of YOUR co-workers and supervisors during the times of each such alleged exposure.
SPECIAL INTERROGATORY NO. 11:

If YOU contend YOU were exposed to ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please IDENTIFY
each person having knowledge of relevant facts related to each such alleged exposure.

SPECIAL INTERROGATORY NO. 12:

IDENTIFY the area of knowledge of each person having knowledge of the relevant facts relating
to each of YOUR alleged exposures to ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King.

SPECIAL INTERROGATORY NO. 14:

For every individual with knowledge of relevant facts relating to YOUR alleged exposure to
ASBESTOS-CONTAINING MATERIAL supplied, sold, labeled, distributed, produced, processed, or
manufactured by Lindstrom & King, please IDENTIFY whether their deposition has been taken,
including the date it was taken, the name and cause number of the action in which it was taken, the court
reporting agency, and the court which had jurisdiction over the action in which it was taken,

SPECIAL INTERROGATORY NO. 15:

if YOU contend YOU were exposed ta ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please IDENTIFY
each DOCUMENT which pertains to or relates to each such exposure, including but not limited to
STATEMENTS, depositions, affidavits, correspondence or memoranda.

SPECIAL INTERROGATORY NO, 16:

IDENTIFY the person who has custody of each DOCUMENT identified in the preceding
interrogatory which pertains to, or relates to, YOUR alleged exposure to ASBESTOS-CONTAINING
MATERIAL supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom &
King.

SPECIAL INTERROGATORY NO. 17:
If YOU contend YOU were exposed to ASBESTOS-CONTAINING MATERIAL supplied, sold,

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DEFENDANT LINDSTROM & KING CO., INC,"S SPECIALLY PREPARED INTERROGATORIES
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labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please describe the
physical appearance of such Lindstrom & King product to which exposure is claimed, including but not
limited to the shape, color, dimensions, weight, composition, texture, and any writings or identifying
markings.

SPECIAL INTERROGATORY NO. 18:

If YOU contend YOU were exposed to ASBESTOS-CONTAINING MATERIAL supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King, please describe the
packaging of such Lindstrom & King products to which exposure is claimed, including, but not limited
to, any labels, writings or identifying markings including the specific name of the product.

SPECIAL INTERROGATORY NO. 19:

IDENTIFY each fact in support of the allegation in YOUR complaint that Lindstrom & King is
liable to YOU for exemplary and/or punitive damages.
SPECIAL INTERROGATORY NO. 20:

IDENTIFY all persons with knowledge of those facts which support the allegation in YOUR
complaint that Lindstrom & King is liable to YOU for exemplary and/or punitive damages.

SPECIAL INTERROGATORY NO. 21:

IDENTIFY all DOCUMENTS that contain, relate to, or reflect those facts which support the
allegation in YOUR complaint that Lindstrom & King is liable to YOU for exemplary and/or punitive
damages.

SPECIAL INTERROGATORY NO. 22:

IDENTIFY each and every site or location from which YOU or YOUR agents took samples of,
or did testing on, suspected or alleged ASBESTOS-CONTAINING MATERIALS YOU contend were
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King.

SPECIAL INTERROGATORY NO. 23:

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IDENTIFY each and every date on which YOU or YOUR agents took samples of or did testing
on suspected or alleged ASBESTOS-CONTAINING MATERIALS, including, but not limited to,
suspected or alleged ASBESTOS-CONTAINING MATERIALS YOU contend were supplied, sold,

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DEFENDANT LINDSTROM & KING CO,, INC."S SPECIALLY PREPARED INTERROGATORIES
TO PLAINTIFF LOUIS CASTAGNAce Ww KAD eh BR WB Ne

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labeled, distributed, produced, processed, or manufactured by Lindstrom & King.
SPECIAL INTERROGATORY NO. 24:

IDENTIFY the name, address and telephone number of each and every person commissioned by,
acting at the direction of, or authorized by YOU or YOUR agents to take samples or conduct testing of
suspected or alleged ASBESTOS-CONTAINING MATERIALS YOU contend were supplied, sold,
labeled, distributed, produced, processed, or manufactured by Lindstrom & King.

SPECIAL INTERROGATORY NO. 25:

IDENTIFY the physical appearance and nature of the material sampled or tested by YOU or
YOUR agents that is, or was, suspected or alleged by YOU as ASBESTOS-CONTAINING
MATERIALS supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom
& King, including, but not limited to, the shape, color, dimensions, weight, composition, texture, and
any writings or identifying markings.

SPECIAL INTERROGATORY NO. 26:

IDENTIFY the person who had, or has, custody of each item of material sampled or tested by
YOU or YOUR agents that is, or was, suspected or alleged by YOU to be ASBESTOS-CONTAINING
MATERIALS supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom
& King,

SPECIAL INTERROGATORY NO. 27:

IDENTIFY all findings and conclusions made by YOU or YOUR agents relating to sampled
material that is, or was, suspected or alleged by YOU to be ASBESTOS-CONTAINING MATERIALS
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King.

SPECIAL INTERROGATORY NO. 28:

IDENTIFY all DOCUMENTS that contain, relate to, or reflect, the findings or conclusions
IDENTIFIED in YOUR response to interrogatory number 27.
SPECIAL INTERROGATORY NO. 29:

If YOU contend that YOUR exposure to ASBESTOS-CONTAINING MATERIAL allegedly

supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King

7
DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
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occurred during, or as a result of, any repairs, remodeling or construction at any home where YOU
resided or were present IDENTIFY the date and location of such exposure(s).

SPECIAL INTERROGATORY NO. 30:

If YOU contend that YOUR exposure to ASBESTOS-CONTAINING MATERIAL allegedly
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King
occurred during, or as a result of, any repairs, remodeling or construction at any home where YOU
resided or were present describe in detail the type of work done by Lindstrom & King.

SPECIAL INTERROGATORY NO. 31:

If YOU contend that YOUR exposure to ASBESTOS-CONTAINING MATERIAL allegedly
supplied, sold, labeled, distributed, produced, processed, or manufactured by Lindstrom & King
occurred during or as a result of any repairs, remodeling or construction at any home where YOU
resided or were present IDENTIFY all DOCUMENTS that contain, relate to, or reflect such repair,
remodel, or construction.

SPECIAL INTERROGATORY NO. 32:

If YOU contend that YOUR exposure to ASBESTOS-CONTAINING MATERIAL allegedly
supplied, sold, tabeled, distributed, produced, processed, or manufactured by Lindstrom & King
occurred during or as a result of any repairs, remodeling or construction at any home where YOU
resided or were present, please IDENTIFY each fact in support of such contention, IDENTIFY all
persons with knowledge of those facts and IDENTIFY all DOCUMENTS that contain, relate to, or
reflect those facts.

SPECIAL INTERROGATORY NO. 33:

For each of the asbestos product liability bankruptcy trusts against which YOU submitted a
claim, state the date of submission of the claim, and the date and amount of settlement.
SPECIAL INTERROGATORY NO, 34:

IDENTIFY all parties with whom YOU have settled in this case. (The term “parties” refers to
the defendants named in YOUR complaint).
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DEFENDANT LINDSTROM & KING COQ., INC.’S SPECIALLY PREPARED INTERROGATORIES
TO PLAINTIFF LOUIS CASTAGNA1 || SPECIAL INTERROGATORY NO. 35:
2 IDENTIFY all asbestos product liability bankruptcy trusts against which YOU have submitted a
3 || claim. See Exhibit “A”.
4
5 || Dated: October |, 2008 FOLEY & MANSFIELD, P.L.L-P.
6
7 BY: hy Mh itt
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9 eae meys tor Defendant
10 LINDSTROM & KING CO., INC.
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12
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26
27
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DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
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EXHIBIT A

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DEFENDANT LINDSTROM & KING CO., INC."S SPECIALLY PREPARED INTERROGATORIES
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EXHIBIT “A”

Bankrupt Entity or Entities shall include, but are not limited solely to, the following:

Amatex Corp.

American Club

American Shipbuilding, Inc.
A.P. Green Indus.
Armstrong World Industries
Atra Group, Inc.

Babcock & Wilcox
Bethlehem Steel

Brunswick Fabricators
Burns & Roe Enterprises
Cassiar Mines

Celotex Corp.

C.E. Thurston

Chemetron Corp.
Combustion Engineering
Continental Producers Corp.
Delaware Insulations
Eastco Industrial Safety Corp.
Eagle-Picher

E.J. Bartells

Federal Mogul

Flintkote

Forty-Eight {nsulations, Inc.
Fuller-Austin Insul.

G-1 Holdings (GAF Corp)
Gatke Corp.

Harbison-Walker Refractories Co.

Harnischfeger Corp.
Hillsborough Holdings
H.K. Porter Co.

Huxley Development Corp.
Johns-Manville Co.

Joy Technologies

Kaiser Aluminum

Keene Corp.

Kentile Floors

Lykes Brothers Steamship
M.H. Detrick

National Gypsum Co.
Nicolet, Inc.

North American Refractories
Owens Corning

PACOR.

Pittsburgh Corning
Plibrico Refractories
Porter-Hayden

Prudential Lines, Inc.
Raytech

Rock Wool Mfg.

Rutland Fire & Clay

Shook & Fletcher

SGL Carbon

Skinner Engine Co.
Standard Asbestos Mfg. & Insul.
Standard Insulations, Inc.
Synkoloid

UNR Industries, Inc.

US Lines

USG (US Gypsum) Corp.
Washington Group Int’l, Inc.
Waterman Steamship Corp.
Wallace & Gale Co.

W.R. Grace

1

DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED INTERROGATORIES
TO PLAINTIFF LOUIS CASTAGNACOD me BR HW RB YW NY

Louis Castagna vs. Asbestos Defendants (BP)

San Francisco County Superior Court No.: 274230
Our File No.: 10770-0001

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION

1, the undersigned, declare as follows:

Tam employed in the County of Alameda, California, and I am over the age of 18 years
and not a party to the within action. My business address is 1111 Broadway, 10™ Floor,
Oakland, California, 94607.

On the date executed below, I electronically served the documents(s) via LexisNexis

File & Serve described as:

* DEFENDANT LINDSTROM & KING CO., INC.’S SPECIALLY PREPARED
INTERROGATORIES TO PLAINTIFF LOUIS CASTAGNA — SET ONE

on the recipients designated on the Transaction Receipt located on the LexisNexis File& Serve
website.

1 declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on October 2, 2008, at

Oakland, California.

/s/ Hattie M. Brown
HATTIE M. BROWN

ole

PROOF OF SERVICE BY ELECTRONIC TRANSMISSIONEXHIBIT EBRAYTON®PURCELL LLP
ATTORNEYS ATLAW
222 RUSH LANDING ROAD

PO BOX 6169

NOVATO. CALI

(415) 898-1555

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ALAN R. BRAYTON, ESQ,, S.B. #73685
DAVID R. DONADIO, ESQ., S.B. #154436; % 6 nt
JAMES P. NEVIN, ESQ., S.B. #220816
BRAYTONPURCELL LLP

Attomeys at Law bey

222 Rush Landing Road

P.O. Box 6169 :
Novato, California 94948-6169 Spe Lo me
(415) 898-1555 . ee

Attomeys for Plaintiff

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ASBESTOS
No. 274230

LOUIS CASTAGNA,

Plaintiff,
PLAINTIFF’S RESPONSE TO
DEFENDANT LINDSTROM & KING CO.
INC.’S SPECIALLY PREPARED
INTERROGATORIES, SET NO. ONE

VS.

ee

ASBESTOS DEFENDANTS (BP)

PROPOUNDING PARTY: Defendant LINDSTROM & KING CO. INC.
RESPONDING PARTY: Plaintiff LOUIS CASTAGNA.
SET NO.: ONE (1)

RESPONSE TO SPECIAL INTERROGATORY NO. 1: Plaintiff objects that this Interrogatory
is over broad, vague, and ambiguous as to undefined terms including, but not limited to
“Sncident”and “identity”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attomey-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff’ s retained expert
consultants in violation of C.C.P. § 2034.210.

Plaintiff further objects to this Interrogatory upon the ground that it violates Code of
Civil Procedure § 2017.010 in that defendant improperly seeks information not relevant to the
subject matter of the action. Furthermore, defendant improperly seeks information that is not
likely to lead to discovery of admissible evidence because no logical inference of liability can
be drawn therefrom. Moreover, plaintiff is waiting for defendant to submit its responses to

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plaintiff's Standard Interrogatories to all defendants, as ordered by San Francisco Superior
Court General Order No. 129, paragraph 4.B., which were due on 120 days after the complaint
was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff’s claims for damages will be presented by plaintiff's retained litigation
consultants pursuant to C.C.P. § 2034.010 et seq., at the appropriate time before trial. Plaintiff
further refers defendant to plaintiff's medical records and billings which are equally available to
defendants through coordinating defense counsel, Berry & Berry, pursuant to C.C.P. §
2030.220(c), plaintiff, after making a reasonable and good-faith effort to obtain the information
by inquiry to other natural persons or organizations, believes that there is no further relevant
and/or responsive information to disclose at this time. Plaintiff reserves the right to supplement
this Response as investigation and discovery are continuing.

RESPONSE TO SPECIAL INTERROGATORY NO. 2: Plaintiff objects to this Interrogatory
on the grounds, and to the extent, that it seeks documents protected by the attorney-client
privilege and/or the attorney work-product doctrine.

Furthermore, defendant improperly seeks information that is not likely to lead to
discovery of admissible evidence because no logical inference of liability can be drawn
therefrom. Moreover, plaintiff is waiting for defendant to submit its responses to plaintiff's
Standard Interrogatories to all defendants, as ordered by San Francisco Superior Court General
Order No. 129, paragraph 4.B., which were due on 120 days after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: During his career as a wiper, oiler and specially during his career as a steamfitter at
several locations, plaintiff installed, removed, and performed maintenance work on asbestos-
containing NIBCO and CRANE valves. Plaintiff recalls doing maintenance on new and old
valves. Plaintiff replaced gaskets and internal packing. Plaintiff recalls when he worked on the
valves, he opened the valves and checked the packing material, and often replaced the packing
rings. This asbestos-containing packing rings were manufactured by defendant LINDSTROM
& KING Co, INC. By so doing, plaintiff breathed the toxic levels of asbestos-laden dust that
was released into the ambient air.

LINDSTROM & KING CO. INC. knew that it’s asbestos-containing products, would be
open, handled, broken and otherwise disturbed and manipulated, resulting in the release of
airborne asbestos fibers, and that through such foreseeable use and/or handling, plaintiff would
be exposed to such asbestos fibers. Defendant did not warn plaintiff that toxic levels of
asbestos-laden dust would be released into the ambient air. As a result of defendant’s conduct,
plaintiff was exposed to asbestos fibers and dust released into the ambient air from
asbestos-containing products. Consequently, plaintiff was exposed to and breathed asbestos
fibers and dust and developed an asbestos-related injury.

The hazards associated with exposure to asbestos and the effect of asbestos exposure
have been well documented since last century. As early as the 1930s, there existed a wealth of
information available for defendant which evidences that exposure to asbestos and asbestos-
containing products was a health hazard. California promulgated industrial safety standards for
workmen around asbestos-containing products beginning in the 1930s. By 1937, California
listed asbestosis as a compensable disease under Workers’ Compensation laws. Numerous
articles and studies relating to the health hazards of exposure to asbestos have appeared in
medical and scientific literature since the turn of the 20 century and have also been
summarized in various publications. Additionally, safety orders have existed since the 1940s
regarding the control of asbestos dust in the workplace. Therefore, defendant knew or should
have known of the health hazards associated with exposure to asbestos and asbestos-containing
products prior to their manufacture, distribution, sale, and supply, and failed to take available
safety precautions.

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Defendant, as a manufacturer, supplier and/or distributor of asbestos-containing
products, owed a duty to exercise due care to foreseeable users of Products sold, supplied and/or
distributed by defendant. Further, defendant failed to warn plaintiff as a consumer of the
dangers inherent in these products. Defendant also breached its duties by supplying and
distributing products which were defective in that they caused asbestos-containing fibers to be
released into the ambient air when said products were used in a foreseeable manner by
foreseeable users. The defect existed in the defendant's products at the time they left the
possession of defendants. Further, defendant failed to adequately warm of the risks to which
plaintiff and other similarly-situated users, consumers and bystanders were exposed and failed
to appropriately label such products of the dangers inherent in said products. Defendant’s
conduct was willful, malicious, and done with a wanton disregard for plaintiff’s safety and the
safety of other consumers. After a reasonable and good-faith inquiry, plaintiff presently has no
further information responsive to this Interrogatory. Plaintiff’s investigation and discovery are
continuing. Plaintiff expressly reserves the night to amend this Response pending the outcome
of plaintiff's investigation.

RESPONSE TO SPECIAL INTERROGATORY NO. 3: Plaintiff objects to this Interrogatory
on the grounds, and to the extent, that it seeks documents protected by the attorney-client
privilege and/or the attorney work-product doctrine.

Furthermore, defendant improperly seeks information that is not likely to lead to
discovery of admissible evidence because no logical inference of liability can be drawn
therefrom. Moreover, plaintiff is waiting for defendant to submit its responses to plaintiff's
Standard Interrogatories to all defendants, as ordered by San Francisco Superior Court General
Order No. 129, paragraph 4.B., which were due on 120 days after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 4: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled’, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210. Moreover, plaintiff is waiting for defendant to
submit its responses to plaintiff's Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

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RESPONSE TO SPECIAL INTERROGATORY NO. 5: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff’s retained expert
consultants in violation of C.C.P. § 2034.210. Moreover, plaintiff is waiting for defendant to
submit its responses to plaintiff’s Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served,

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 6; Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210. Moreover, plaintiff is waiting for defendant to
submit its responses to plaintiff's Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 126 days
after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 7: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210.

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Plaintiff objects that this Interrogatory seeks the premature disclosure of trial witnesses
and is therefore in violation of the attorney work-product doctrine. City of Long Beach v.
Superior Court (1976) 64 Cal.App.3d 65. Moreover, plaintiff is waiting for defendant to submit
its responses to plaintiff's Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff recall the following coworkers, who are witnesses with information relating
to plaintiff’s exposure to asbestos-containing products manufactured, distributed or sold by
detendant LINDSTROM & KING CO. INC.: Mike Hernandez (current business agent),
address currently unknown; James Saathoff, c/o Brayton*Purcell LLP; Doyle Williams, address
currently unknown; Ed Wetison, deceased; Ed Russell, address currently unknown; Larry
Blevins, Concord, California, Dick Dole, address currently unknown; supervisor Vern Gosney,
c/o Paul, Hanley & Harley.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 8: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Moreover, plaintiff is waiting for defendant to submit its responses to plaintiff's Standard
Interrogatories to all defendants, as ordered by San Francisco Superior Court General Order No.
129, paragraph 4.B., which were due on 120 days after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 203 1.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 9: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Moreover, plaintiff is waiting for defendant to submit its responses to plaintiff's Standard
Interrogatories to all defendants, as ordered by San Francisco Superior Court General Order No.
129, paragraph 4.B., which were due on 120 days after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 2 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

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RESPONSE TO SPECIAL INTERROGATORY NO. 10: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff’s retained expert
consultants in violation of C.C.P. § 2034.210.

Plaintiff objects that this Interrogatory seeks the premature disclosure of trial witnesses
and is therefore in violation of the attorney work-product doctrine. City of Long Beach y.
Superior Court (1976) 64 Cal. App.3d 65. Moreover, plaintiff is waiting for defendant to submit
its responses to plaintiff’s Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff incorporates by reference his Response to Interrogatory No. 7 above.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 11: Plaintitf objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C-P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210.

Plaintiff objects that this Interrogatory seeks the premature disclosure of trial witnesses
and is therefore in violation of the attorney work-product doctrine. City of Long Beach v.
Superior Court (1976) 64 Cal.App.3d 65. Moreover, plaintiff is waiting for defendant to submit
its responses to plaintiffs Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served.

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Plaintiff recall the followmg coworkers, who are witnesses with information relating
to plaintiff's exposure to asbestos-containing products manufactured, distributed or sold b
defendant LINDSTROM & KING CO. INC.: Mike Hernandez (current business agent), address
currently unknown; James Saathoff, c/o Brayton%Purcell LLP; Doyle Williams, address
currently unknown; Ed Wetison, deceased; Ed Russell, address currently unknown; Larry
Blevins, Concord, California, Dick Dole, address currently unknown, supervisor Vern Gosney,
c/o Paul, Hanley & Harley.

Plaintiff currently identifies himself, c/o Brayton*Purcell LLP.

Plaintiff identifies doctors and other medical professionals listed in plaintiff's medical
records, which are equally available from coordinating defense counsel, Berry & Berry, 2930
Lakeshore Avenue, Oakland, California 94610, (510) 835-8330.

Plaintiff further identifies Defendant LINDSTROM & KING CO. INC’s Person(s) Most
Knowledgeable and Custodian of Records ; and officers, directors, and agents, c/o Foley &
Mansfield L.LP.

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Plaintiff further identifies CRANE valves Person(s) Most Knowledgeable and
Custodian of Records, William N. McLean and Anthony D. Pantaleoni.

Plaintiff further identifies NIBCO valves Person(s) Most Knowledgeable and
Custodian of Records, Gordon D. McCroby.

Plaintiff further identifies John Madsen, Director of Madsen & Howell.

Plaintiff further identifies all defendants to this action, including their Person(s) Most
Knowledgeable; Custodian(s) of Records; and officers, directors, and agents, c/o defendants’
attorneys of record. A list of defendants’ attorneys of record is equally available from
coordinating defense counsel, Berry & Berry, 2930 Lakeshore Avenue, Oakland, California
94610, (510) 835-8330.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 12: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with regard to the use of undefined
terms including, but not limited to, “area of knowledge.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C.P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attomey work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210.

Plaintiff objects that this Interrogatory seeks the premature disclosure of trial witnesses
and is therefore in violation of the attorney work-product doctrine. City of Long Beach v.
Superior Court (1976) 64 Cal-App.3d 65. Moreover, plaintiff is waiting for defendant to submit
its responses to plaintiff's Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served,

Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows: Persons listed on Interrogatory No. 11 are witnesses with information relating to
plaintiff’ s exposure to asbestos-containing products manufactured, distributed or sold by
defendant LINDSTROM & KING CO. INC.

Pursuant to C.C.P. § 2031.230, plaintiff, after making a diligent search and reasonable
inquiry to obtain the information by inquiry to other natural persons or organizations, believes
that he has no further relevant and/or responsive documents to produce at this time. Plaintiff
reserves the right to supplement this Response, as investigation and discovery are continuing
and plaintiff has not completed preparation for trial.

RESPONSE TO SPECIAL INTERROGATORY NO. 13: Defendant did not serve
Interrogatory No. 13. to plaintiff.

RESPONSE TO SPECIAL INTERROGATORY NO, 14: Plaintiff objects to this Interrogatory
on the grounds that it is vague and ambiguous, particularly with tegard to the use of undefined
terms including, but not limited to, “supplied”, “sold”, “ labeled”, “distributed” and “produced.”

Plaintiff objects that this Interrogatory is compound, conjunctive, and contains subparts,
in violation of C.C-P. § 2030.060.

Plaintiff objects to this Interrogatory on the grounds, and to the extent, that it seeks
documents protected by the attorney-client privilege and/or the attorney work-product doctrine.
Plaintiff further objects on the grounds, and to the extent, that this Interrogatory seeks the
premature disclosure of documents within the possession of plaintiff's retained expert
consultants in violation of C.C.P. § 2034.210.

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Plaintiff objects that this Interrogatory secks the premature disclosure of trial witnesses
and is therefore in violation of the attorney work-product doctrine. City of Long Beach v.
Superior Court (1976) 64 Cal.App.3d 65. Moreover, plaintiff is waiting for defendant to submit
its responses to plaintiff's Standard Interrogatories to all defendants, as ordered by San
Francisco Superior Court General Order No. 129, paragraph 4.B., which were due on 120 days
after the complaint was served.

1 Subject to the foregoing objections and without waiver thereof, plaintiff respond as
follows:

Plaintiff identifies the deposition transcripts and al! exhibits attached thereto of John
Madsen taken on July 21, 1986 in the matter of Robert C. Bonden v. A.C. & S. Inc., et al.
Superior Court of New Jersey, Case No. 00150-83 equally available to defendant through court
reporters Brody & Geise