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

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Evanthia Spanos, Esq., CSB No. 111178

BERRY & BERRY

A Professional Law Corporation ELECTRONICALLY

2930 Lakeshore Avenue

Oakland, CA. 94610-1428 cutee Poni
Telephone: (510) 250-0200 County of San Francisco
Designated Defense Counsel : DEC

09 2009
GORDON PARK-LI, Clerk
BY: VANESSA WU
Deputy Clerk

SUPERIOR COURT ~ UNLIMITED JURISDICTION -- STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

LOUIS CASTAGNA, No. 274230

JOINT STATUS AND SETTING
CONFERENCE STATEMENT FOR
ASBESTOS STATUS AND SETTING
CONFERENCE CALENDAR

Plaintiffs,
vs.

ASBESTOS DEFENDANTS.
> Date: December 17, 2009

Time: 1:30 PM

j Dept: 206 —The Hon, James J. McBride
Action Filed: June 6, 2007
Trial Date: TBD

Defendants.

BERRY & BERRY SUBMITS THE FOLLOWING STATEMENT REGARDING THE.
STATUS OF JOINT MEDICAL DISCOVERY

This is a living asbestosis claim.

The deposition of plaintiff commenced in June 2008 and was continued over multiple
sessions but has not concluded. Plaintiffs continued deposition is scheduled to take place
December 15 and 17, 2009. If the deposition does not conclude at that time, defendants will
object to trial setting.

The statements submitted by plaintiffs and defense counsel are attached collectively as
Exhibit A.

Dated: December 9, 2009 Respectfully Submitted,

/s/_Evanthia Spanos, Esq.
Designated Defense Counsel

LOUIS CASTAGNA y. ASBESTOS DEFENDANTS
San Francisco Superior Court No. 274230
Joint Status and Setting Conference StatementEXHIBIT APOBOX6169
NOVATO, CALIFORNIA 94945-6169
(415) 898-1555

222 RUSH LANDING ROAD

BRAYTON®PURCELL LLP
ATTORNEYS ATLAW

ec oe IN DH BF WN

GILBERT L. PURCELL, ESQ., S.B. #113603
DAVID R. DONADIO, ESQ., S.B. #154436
OREN P. NOAH, ESQ., S.B. #136310
BRAYTON**PURCELL LLP

Attorneys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attorneys for Plaintiff(s)

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO
LOUIS M. CASTAGNA, ASBESTOS
No. 274230
Plaintiff (s),
JOINT CASE MANAGEMENT
vs. CONFERENCE STATEMENT
ASBESTOS DEFENDANTS (B%P) Date: December 17, 2009
Time: 1:30 p.m.
Dept: 206
PLAINTIFF SUBMITS THE FOLLOWING ANSWERS TO CASE MANAGEMENT
CONFERENCE QUESTIONS:
1. When was complaint filed?
6/6/07
2. Has the five-year mandatory dismissal statute been tolled or extended for any reason?
No
3. Have all defendants been served? If no, explain why the defendants have not been

served. Plaintiff shall provide a detailed explanation as to why any defendant has been named

but not served,
With the exceptions noted below, yes.
- DOE defendants
-C.C.P § 474

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- defendants which were named solely for purposes of trust claims processing, to wit:
WESTERN MacARTHUR COMPANY, including alternate entities
McARTHUR COMPANY and WESTERN ASBESTOS COMPANY

4, Have all defendants answered or had defauit taken? If not, explain why. Plaintiff shall

provide a detailed explanation as to why any defendant has been named, served but not

answered; or named, served but not answered and not defaulted.

All named defendants have either answered, their defaults have been taken, or they have
been dismissed, except as described in response to Question No. 3, above.

5. Describe with specificity the status of discovery including but not limited to (a) whether

or not written discovery has been completed, (b) what depositions have been completed, (¢)

what depositions remain to be completed, and (d) what other discovery remains to be

completed.

(a) No. Plaintiff has responded to all G.O. discovery including general interrogatories,
requests for production, and the following other written discovery:

Initiated By: Defendant - Chicago Bridge & lron Company

Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 06/10/2008

Initiated By: Defendant - Contra Costa Electric, Inc.
Type: Special Interrogatories, Request for Production of Documents

Completed: 02/27/2009

Initiated By: Defendant - Durametallic Corporation
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,

Request for Production of Documents

Completed: 07/28/2008

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Initiated By: Defendant ~ Elliott Turbomachinery Co., Inc.

Type: Special Interrogatories, Judicial Council Form interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 07/07/2008

Initiated By: Defendant - Ford Motor Company

Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 10/28/2009

Initiated By: Defendant - Foster Wheeler LLC (FKA Foster Wheeler Corporation)
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 06/09/2008

Initiated By: Defendant - IMO Industries, Inc.
Type: Special Interrogatories, Request for Admissions, Request for Production of Documents

Completed: 11/04/2009

Initiated By: Defendant - Lindstrom & King Co. Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 11/14/2008

Initiated By: Defendant - Nibco Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 07/01/2008

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Initiated By: Defendant - Oakfabeo, Inc.
Type: Special Interrogatories, Request for Production of Documents

Completed: 08/05/2008

Initiated By: Defendant - Paccar Inc.

Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents —

Completed: 06/13/2008

Initiated By: Defendant - Paccar Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 08/12/2008

Initiated By: Defendant - Pacific Gas & Electric Company

Type: Special Interrogatories, Judicial Council Form Interrogatorics, Request for Admissions,
Request for Production of Documents

Completed: 05/19/2008

Initiated By: Defendant - Performance Mechanical, Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 08/21/2009

Initiated By: Defendant - Plant Insulation Company
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 06/05/2008

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Initiated By: Defendant - Red-White Valve Corp.
Type: Special interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 10/27/2008

Initiated By: Defendant - Rockwell Automation, Inc.

Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 08/11/2008

Initiated By: Defendant - Scott Co. of California
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 06/19/2008

Initiated By: Defendant - Sequoia Ventures Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 08/06/2008

Initiated By: Defendant - Sta-Rite Industries, LLC
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Completed: 12/01/2008
Initiated By: Defendant - Swinerton Builders
Type: Special Interrogatories, Request for Production of Documents

Completed: 07/02/2008

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Initiated By: Defendant - Taco, Inc.
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents, Request for Production of Documents

Completed: 08/14/2008

Initiated By: Defendant - Timec Company, Inc.
Type: Special Interrogatories, Request for Production of Documents
Completed: 06/26/2008

Initiated By: Defendant - Tosco Refining Company, Inc.
‘Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Production of
Documents

Completed: 05/19/2009

Initiated By: Defendant - William Powell Company, The
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents
Completed: 11/07/2008
Responses to the following discovery have not yet been received:
Initiated By: Defendant - Copeland Corporation
Type: Special Interrogatories, Judicial Council Form interrogatories, Request for Admissions,
Request for Production of Documents

Due: 12/22/2009

Initiated By: Defendant - Fisher Controls International LLC
Type: Special Interrogatories, Judicial Council Form Interrogatories, Request for Admissions,
Request for Production of Documents

Due: 12/18/2009

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(b) — Completed depositions include:

Deponent: Castagna, Louis M.

Deponent Type: Plaintiff/Injured Party
Depo Date: 06/17/08, Part 1, Status: Continued

Depo Date:
Depo Date:
Depo Date:
Depo Date:
Depo Date:
Depo Date:
Depo Date:

09/10-12/08, Parts 2-4, Status: Continued
09/24-25/08, Parts 5-6, Status: Continued
03/02-05/09, Parts 7-9, Status: Continued
04/07/09, Part 10, Status: Continued
04/09/09, Part: 11, Status: Suspended
09/14/09, Part 12, Status: Continued
09/16/09, Part 13, Status: Continued

(c) The following depositions are noticed:

Deponent: Castagna, Louis M.

Deponent Type: Plaintiff/Injured Party
Depo Date: 12/15/2009, Part: 14-15, Status: Noticed

In addition, plaintiff anticipates noticing the depositions of additional defendants and/or

employers as discovery and investigation warrant,

(d) Plaintiff anticipates propounding written discovery of additional defendants as

discovery and investigation warrant.

6. Does plaintiff intend to add any defendants?

At present, no.

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7. Does plaintiff intend to seck trial preference pursuant to California Code of Civil

Procedure section 36?
Not at this time; however, plaintiff reserves the right to file for preference if plaintiff's
medical condition warrants it.

Dated: November 30, 2009 BRAYTON**PURCELL LLP

By: __/s/ David R. Donadio

David R. Donadio
Attorneys for Plaintiff

K Mnjuredh 102298temestnt121709.wpd_ 8DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Plaintiff's Attorney: BRAYTON

Full Case Name: CASTAGNA, LOUIS v. Asbestos Defendants (BP), et al.

Case Docket No: 274230

Client (exactly as it appears on Answer): Albay Construction Company
Has defendant answered? Yes

Have all eross-complaints been filed? Not Applicable

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No.
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?* Discovery not yet completed

What non-expert discovery is anticipated by defendant in the future?* RFA/RFP/Spec/Form

Firm Name: Archer Norris

Submitted by: /s/ Gene Blackard Date: December 3, 2009

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate email for each case to sfcmestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: : : Plaintiff Attorney: BRAYTON PURCELL

[List First and Last Names]
LOUIS CASTAGNA v. ASBESTOS DEFENDANTS (B*P)

Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): CBS Corporation, a Delaware corporation, f/k/a Viacom Inc.,
~ successor by merger to CBS Corporation, a Pennsylvania corporation, f/k/a Westinghouse Electric Corporation

Has defendant answered? “Yes

Have all cross-complaints been filed? Unknown. CBS Corporation does not currently intend fo file a cross-
complaint.

Does defendant plan to file a cross-complaint? No.
Has the five-year mandatory dismissal statute been tolled or extended for any reason? No.
_ If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?. None ~

What non-expert discovery is anticipated by defendant i in the future? None known at this time. In the event a
discovery dispute arises, counsel for CBS Corporation will meet and confer with counsel for plaintife to resolve all

discovery issues.

Firm Name: Pond North LLP

Attorney’s Signature: cMntboiliirol. Date: _* {4 +2009

Deadline to submit to Berry & Berry — December 4, 2009.
: Send separate email for each case to sfcmestatements@berryandberry.com
4520-1828:508842.1 ‘

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nerDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants Plaintiff's Attorney: Brayton Purcell
[List First aad Last Names}

Case Docket No. CGC -07-274230

Client (exactly as it appears on Auswer): Chicago Bridge & Iron Company, an Illinois corporation
Has defendant answered? Yes

Have all cross-complaints been filed? NA

Does defendant plan to file a cross-complaint?. No

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? No

What client specific discovery has defendant conducted to date, if any?

Propounded Special Interrogatories, set one; Form Interrogatorics, set one; Request for Production of Documents,
set one; Requests for Admission, set one.

What non-expert discovery is anticipated by defendant in the future?

Propound Supplemental Special Interrogatories; Form Interrogatories; Request for Production of Documents;
Requests for Admission,

Propound Special Interrogatories, set two; Form Interrogatories, set two; Request for Production of Documents, set
two; Requests for Admission, set two.

Defendant will be noticing the depositions of the approximately 65 witnesses identified against it by plaintiff.

Plaintiff's deposition is on-going. The next session is scheduled for December 15 and 17, 2009, Plaintiffis only
able to testify a few hours at a time due to a debilitating back condition.

Firm Name: Sack Rosendin, LP

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate email for each ease to sfemestatements@berryandherry.com

oe Date: December aes 2009

Attorney’s Signature:DEFENDANT'S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Plaintiffs Attorney: Brayton Purcell
LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS

Case Docket No.: 274230

Client (exactly as it appears on Answer): CONSOLIDATED INSULATION, INC.

Has defendant auswered? Yes

Have all cross-complaints been filed? Unknown

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? No

What client specific discovery has defendant conducted to date, if any?

None

What non-expert discovery is anticipated by defendant in the future?

Defendant intends to serve client specific Special Interrogatories, Form Interrogatories, Requests for
Production and Requests for Admission; co-worker/witness depositions will be taken if necessary.

Firm Name: Prindle, Amaro, Goetz, Hillyard, Barnes & Reinholtz LLP

Attorney’s Signature: Mary Kirk Hillyard, Esq. Date: December 3, 2009

Deadline te submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.com_ DEFENDANT'S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna Plaintiff’s Attorney: Brayton Purcell
[List First aud Last Names]

Case Docket No,: 274230

Client (exactly as it appears on Answer): Crane Co.

Has defendant answered? Yes

Have all cross-complaints been filed? To the best of our knowledge all cross-complaints have been filed,
Does defendant plan to file a cross-complaint? We do not plan to file a cross-complaint

Has the five-year mandatory dismissal statute been tolled or extended for any reason?

We are not aware of any tolls or extensions for this case
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?
Crane Co. has not yet served special written discovery

What non-expert discovery is anticipated by defendant in the future?

Depositions Completed: Plaintiff deposition has not concluded. Further sessions scheduled in December
Depositions remaining to be completed: Witnesses (if identified in special interrogatories)

Other discovery remaining to be completed: Crane Co. written special discovery

Firm Name: K&L Gates, LLP

Attorney’s Signature: __/s/ Brendan J. Tuohy Date: December 1, 2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
December 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants (BYP) Plaintiff’s Attorney: Brayton Purcell
[List First ad Last Names]

Case Docket No.: SFSC CGC-07-274230

Client (exactly as it appears on Answer): Dillingham Construction, N.A., Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? Unknown

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? None

What non-expert discovery is anticipated by defendant in the future? Continued Deposition of Plaintiff;
Deposition of co-workers (as identified); Client Specific Discovery to Plaintiff

Firm Name: Becherer Kannett & Schweitzer

Attorney’s Signature: Mark S, Jsannett Date: December 4, 2009

Deadline to submit to Berry & Berry — November 5, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v Asbestos Defendants (BP) Plaintiff’s Attorney: Brayton Purcell
[List First and Last Names]

Case Docket No.: 274230

Client (exactly as it appears on Answer): Douglass Insulation Company, Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? Not applicable.

Does defendant plan to file a cross-complaint? Not at this time.

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No.
Tf so, why and for how long?

What client specific discovery has defendant conducted to date, if any? Deposition of plaintiff.

What non-expert discovery is anticipated by defendant in the future? Complete plaintiff's deposition.
Witnesses depositions. Request for Admissions, Request for Production of Documents, Special Interrogatorics,
Judicial Council Form Interrogatories.

Firm Name: Selman Breitman

Attorney’s Signature: /s/ Janice W. Man Date: December 3, 2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Castagna, Louis v. Asbestos Defendants (BP) Plaintiff's Attorney: Brayton Purcell LLP

Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): Elliott Company FICA “Elliott Turbomachinery Co., Inc.”
Has defendant answered? Yes.

Have all cross-complaints been filed? Unknown.

Does defendant plan to file a cross-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long?

No.
What client specific discovery has defendant conducted to date, if any?

Defendant served Special Interrogatories (Set One), Requests for Production (Set One), and Requests for
Admission (Set One).

What non-expert discovery is anticipated by defendant in the future?

This case is not ready to set for trial as Plaintiff's deposition has not concluded. Further deposition of Plaintiffis
necessary duc to Plaintiff's additional claims of exposure at the most recent session of his deposition. This has
been an on-going issue with this Plaintiff's deposition, and necessitated one previous Motion for additional
deposition time for defendants. Unfortunately, only 10 additional hours were granted with numerous Defendants
still needing to follow-up on Plaintiff's claims of exposure. If defendant’s efforts to resolve the matter via meet
and confer with Plaintiff's counsel are unsuccessful, a further discovery Motion for Additional Deposition may be

necessary.

Defendant intends to serve additional Special Interrogatories, Requests for Production and Requests for
Admission.

Defendant may take the depositions of one non-party percipient witnesses.

Firm Name:_Imat Tadlock Keeney & Cordery
Attorney’s Signature: y a Lie 4 UL A~ Date: DPéldmbor 2, 2009

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Fut. CASE NAME:

Louis Castagna, et al. vs. Asbestos Defendants
PLAINTIFF ATTORNEY:

Brayton Purcell

Case DockeT No.!

274230

Cent (EXACTLY As IT APPEARS ON ANSWER):
Ford Motor Company

Has DEFENDANT ANSWERED?

Yes

HAVE ALL CROSS-COMPLAINTS BEEN FILED?
None filed by defendant

DOES DEFENDANT PLAN TO FILE A CROSS-COMPLAINT?
Not at this time

HAS THE FIVE-YEAR MANDATORY DISMISSAL STATUTE BEEN TOLLED Or EXTENDED FoR ANY REASON? IF SO,
Why AND For How Lone? - mo

Not by this defendant

WHAT CLIENT SPECIFIC DISCOVERY HAS DEFENDANT CONDUCTED To Date, IF ANY?
Written discovery has not been propounded

Wuar Non-Exeent Discovery Is ANTICIPATED BY DEFENDANT in THE FUTURE?

Written discovery was propounded by counsel. Once the responses are evaluated, defendant may
propound additional written discovery or notice the depositions of any identified co-workers.
Defendant may also subpoena any bankruptcy trusts identified by Plaintiffs to obtain any claim forms
that were submitted.

Firm Name: Lankford & Crawford, LLP

ATTORNEY'S scumune, 

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Castagna, Louis y, Allis-Chalmers Corporation Product Liability Trust

Plaintiff’s Attorney: David Donadio, Esq.; Brayton Purcell, LLP

[List First and Last Names]

Case Docket No.: 274230

Client (exactly as it appears on Answer): J.T. Thorpe & Son, Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? J.T. Thorpe & Son, Inc. has not filed a cross-complaint. J.T. ‘Thorpe &
Son, Inc. does not know if all of the cross-complaints have been filed.

Does defendant plan to file a cross-complaint?
J.T. Thorpe & Son, Inc, does not intend to file a cross-complaint in this case at this time.

Has the five-year mandatory dismissal statute been tolled or extended for any reason?

Ifso, why and for how long?
To the best of J.T. Thorpe & Son, Inc.’s knowledge: the five-year mandatory dismissal statute has not been tolled

or extended for any reason.

What client specific discovery has defendant conducted to date, if any?

J.T. Thorpe & Son, Inc. has not conducted any written discovery in this case. J.T, Thorpe & Son, Inc. has
participated in depositions in this case.

What non-expert discovery is anticipated by defendant in the future?
J.T. Thorpe & Son, Inc. does not expect to participate in any non-expert discovery in this case.

Date: lov 24 , 2009

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Plaintiff's Attorney: Brayton Purcell LLC

Full Case Name:
[List First and Last Names] Louis Castagna
Case Docket No.: CGC 07 274230

Client (exactly as it appears on Answer): Johnson Controls, Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? Unknown

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? No

What client specific discovery has defendant conducted to date, if any?

None

What non-expert discovery is anticipated by defendant in the future?

Form Interrogatories
Request for Admissions
Request for Production
Special Interrogatories

Firm Name: Becherer Kannett & Schweitzer

Attorney’s Signature: _Mark S. Kannett Date: December 3, 2009

Deadline to submit to Berry & Berry ~ December 5, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT

DECEMBER 17, 2009
Full Case Name: Castagna, Louis v. Asbestos Defendants, et al.
Plaintiff’s Attorney: Brayton Purcell; David Donadio, Esq.

{List First and Last Names}

Case Docket No.: 274230

Client (exactly as it appears on Answer): Kaiser Gypsum Company, Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? Kaiser Gypsum Company, Inc. has not filed a cross-complaint. Brand
Tnsulations, Inc. does not know if all of the cross-complaints have been filed.

Does defendant plan to file a cross-complaint? Kaiser Gypsum Company, Inc. does not intend to file a cross-
complaint in this case at this time.

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? To the best of Kaiser Gypsum Company, Inc.’s knowledge the five-year mandatory
dismissal statute has not been tolled or extended for any reason.

What élient specific discovery has defendant conducted to date, if any? Kaiser Gypsum Company, Inc. has
served on Plaintiff, Standard Interrogatories, Set One, Request for Admissions, Set One, Demand for Inspection of
Documents, Set One, and Special Interrogatories, Set One.

What non-expert discovery is anticipated by defendant in the future? Kaiser Gypsum Company, Inc.
anticipates conducting depositions of former co-workers of Plaintiff.

Firm Name: Bassi, Edlin

Attorney’s Signature: Date: November 29, 2009

Deadline to submit to Berry & Berry -- December 3, 2009,
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants Plaintiff’s Attorney: Brayton Purcell LLP
[List First uid Last Names|

Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): Lamons Gasket Company
Tas defendant answered? Yes.

Have all cross-complaints been filed? Unknown.

Does defendant plan to file a cross-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No,
If so, why and for how long?

“What elient speeific discovery has defendant conducted to date, if any?
» Propounded and received responses to Special Discovery (Requests for Admissions, Requests for the
Production of Documents, Specially Prepared Interrogatories, and Judicial Council Form Interrogatorics),
* Thirteen sessions of the deposition of plaintiff Louis Castagna (for limited time on each day).

What non-expert discovery is anticipated by defendant in the future?
¢ Completion of the deposition of plaintiff Louis Castagna (scheduled to reconvene for additional time
pursuant to Court Order on December 15, 2009, and anticipated to go for limited time each day).
« Supplemental Specially Prepared Interrogatories to determine newly discovered evidence in response to
previous interrogatories.
* Depositions of any percipient witnesses identified in responses to discovery and supplemental discovery,
identified through plaintiff's deposition testimony, or where determined as necessary based on results of

ongoing investigation.

Firm Name: _ Vasquez Estrada & Dumont LLP

Atterney’s Signature: /s/ Paul J. Gamba Date: 12/2/2009

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate cimait for each case to sfcmestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT

DECEMBER 17, 2009
Full Case Name: Louis Castagna v. Asbestos Defendants
Plaintiff's Attorney: Brayton ¢ Purcell LLP
Case Docket No.: San Franciséo Superior Court No.: CGC-07-274230

Client (exactly as it appears on Answer): Lindstrom & King Co. Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? Not Applicable

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No

What client specific discovery has defendant conducted to date, if any?

Defendant Lindstrom & King propounded:

Requests For Production October 2, 2008
Requests For Admission. October 2, 2008
Form Interrogatories October 2, 2008
Special Interrogatories October 2, 2008

What non-expert discovery is anticipated by defendant in the future?

Defendant Lindstrom & King anticipates conducting Depositions of Percipient Witnesses and Co-Workers as
discovery reveals,

Firm Name: Foley & Mansfield, PLLP

Attorney’s Signature: _/ ] j | | Ly Date: November 30, 2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants Plaintiff’s Attorney: Brayton Purcell
[List First and Last Names]

Case Docket No.: SFSC 274230

Client (exactly as it appears on Answer): NIBCO INC.

Has defendant answered? Yes

Have all cross-complaints been filed? N/A

Does defendant plan to file a cross-complaint? N/A

Has the five-year mandatory dismissal statute been tolled or extended for any reason?

If so, why and for how long?
No

What client specific discovery has defendant conducted to date, if any?
Written discovery.

What non-expert discovery is anticipated by defendant in the future?
Depositions have not concluded.

Firm Name: Brydon Hugo & Parker

Attorney’s Signature: /s/ Gregory S. Rosse Date: December 3, 2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: — Louis Castagna Plaintiff’s Attorney: Brayton Purcell
[List First aid Last Names]

Case Docket No.: 274230

Client (exactly as it appears on Answer): PACCAR Inc.

Has defendant answered? Yes

Have all cross-complaints been filed? Yes,

Does defendant plan to file a cross-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No,
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?

Served special interrogatories, request for admissions, form interrogatories and request for production of
documents to plaintiffs.

What non-expert discovery is anticipated by defendant in the future?

Completing plaintiff’s deposition and deposing any former coworkers of plaintiff.

Firm Name: BUTY & CURLIANO

Attorney’s Signature: by “ Date: Zy 3 52009

Deadline to submit to Berry & Berry — December 3, 2009,
Please send separate email for cach case to sfcmestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009 ,

Full Case Name: Louis Castagna Plaintiff’s Attorney: Brayton Purcell
(List First aid Last Nantes] . .

Case Docket No.: 274230

Client (exactly as it appears on Answer): Pacific Gas and Electric Company
Has defendant answered? Yes

Have all cross-complaints been filed? Unknown

Does defendant plan to file a cross-complaint? Unknown at this time

Has the five-year mandatory dismissal statute been tolled or extended for any reason? Unknown
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? None

‘What non-expert discovery is anticipated by defendant in the future? Completion of plaintiff's deposition,
possible co-worker witness depositions and client specific discovery.

SAG

Firm Name:

Attorney’s Signature:

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry,comDEFENDANT'S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna y. Asbestos Defendants Plaintiff's Attorney: Brayton Purcell
[List Fivst ard Last Names}

Case Docket No,: 274230

Client (exactly as it appears on Answer): Pacific Mechanical Corporation
Has defendant answered? Yes

Have all cross-complaints been filed? No

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? None

What norexpert discovery is anticipated by defendant in the future?

Request for Admissions

Request for Production of Documents
Request for Special Interrogatories
Request for Form Interrogatories

Firm Name: Low, Ball & Lynch

Attorney’s Signature: /s/ Thomas J. LoSavio Date: December 7, 2009

Deadline to submit to Berry & Berry— December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v, Asbestos Defendants (B<>P) (B #P) Plaintiffs Attorney: Brayton +
Purcell
[List First and Last Names}

Case Docket No. CGC-07-274230

Client (exactly as it appears on Answer): Performance Mechanical, Inc.

Has defendant answered? Yes.

Have all cross-complaints been filed? None have been filed by this defendant.

Dees defendant plan to file a cross-complaint? Not at this time based on discovery conducted to date.
Was the five-year mandatory dismissal statute been tolled or extended for any reason? No.

If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?

Defendant served its client-specific discovery.

What non-expert discovery is anticipated by defendant in the future?

Defendant may need to locate, obtain statements or depose percipient/co-worker witnesses. Defendant may also
need to take the depositions of treating doctors,

Defendant may subpoena bankruptcy trust claim materials, if warranted.

Firm Name: Gordon & Rees LLP

Attorney’s Signature: ¥ Vr ts ¥ ¥ Ling Date: December 2, 2009

Deadline to submit to Berry & Berry — December 3, 2009,

pascnuvoasez2r2e0929.6 Please send separate email for each case to sfemestatements@berryandberry.comDEFENDANT'S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

(9 a a

Full Case Name: —_ Louis Castagna v Asbestos Defendants Plaintiff's Attorney: Brayton Purcell
Case Docket No: 274230

Client (exactly as it appears on Answer): Quintec Industries, Inc.

Has defendant answered? Yes

Have all cross-complaint been filed? No

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason?

If'so, why and for how long? Not to our knowledge

What client specific discovery has defendant conducted to date, if any?*
This client has not conducted any discovery to date.

What non-expert discovery is anticipated by defendant in the future?*
This client does not expect to conduct any additional non-expert discovery in the immediate future.

Firm:

Attorney - Jennifer Commier,, Date: December 1 ,2009
Signature: Wii teA_

Cane b submit to Berry & Berry — December 3, 2009,
Please send separate.email for each case to sfemestatements@beryandberry.com,DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
December 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants
Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): Red-White Valve Corporation

Firm: Foley & Mansfield PLLP

Has defendant answered? Yes.

Have all cross-complaints been filed? To our knowledge, yes.
Does defendant plan to file a cross-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? No.

What client specific discovery has defendant conducted to date, if any? We have served plaintiff with Form
Interrogatories; Special Interrogatories, Set One; Requests for Admission; and Request for Production of
Documents. Plaintiff has responded to all requests.

What non-expert discovery is anticipated by defendant in the future? Percipient witnesses’ depositions need
to be noticed and scheduled.

Submitted by: David J. Mann Date: December 1, 2009DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT

DECEMBER 17, 2009
Full Case Name: LOUIS CASTAGNA v. ASBESTOS DEFENDANTS (BP), et al.
Plaintiff Attorney: Brayton Purcell, LLP

Case Docket No.: 274230

Client (exactly as it appears on Answer): Republic Supply Company
Has defendant answered? Yes

Have all cross-complaints been filed? Unknown

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? None

What non-expert discovery is anticipated by defendant in the future?

None at this time.

Firm Name: Foley Mansfield

Attorney’s Signature: J. Scott Wood Date: _Nov. 30 , 2009

Deadline to submit to Berry & Berry — November 5, 2009.
Send separate email for each case to sfemcstatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
, DECEMBER 17, 2009

Full Case Name: Louis Castagna ’ Plaintiff's Attorney: Brayton Purcell LLP
(List First and Last Naraes}

Case Docket No,: 274230

Client (exactly as it appears on Answer): Rockwell Automation, Inc.
Has defendant answered? Yes

Have all eross-complaints been filed? Unknown at this time.

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? Not to Defendant’s knowledge.

What client specific discovery has defendant conducted to date, if any?
Written Discovery
Plaintiff’s Deposition

What non-expert discovery is anticipated by defendant in the future?
Plaintiff’s Deposition

Retaining experts
Witnesses’ Depositions

Firm Name: Tucker Ellis & West LLP

Attorney’s Signature: ‘ Date: December 3, 2009

Deadline to submit to Berry & Berry — December 3, 2009.

Please send separate email for each case to sfcmestatements@berryandberry.com
SFOiManage\097000.000006\170814.1-AP2DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Plaintiff’s Attorney: Brayton Purcell, LLP

Full Case Name: Louis Castagna vs. Asbestos Defendants
[List First and Last Names}

Case Docket No.: 274230

Client (exactly as it appears on Answer): Santa Fe Braun, Inc, as Successor-in-Interest to C.F. Braun, Inc.
Has defendant answered? No

Have all cross-complaints been filed? N/A

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? Plaintiff deposition

What non-expert discovery is anticipated by defendant in the future? None

Firm Name: Morgan Lewis & Bockius, LLP

Attorney’s Signature: /s/ by Amy J. Talarico Date: December 3, 2009

Deadline to submit to Berry & Berry ~ December 3, 2009.
Please send separate email for each case to sfemestatements@berryandberry.com

DB2/21453705.1DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants Phaintiff’s Attorney: Brayton Purcell LLP
[List rst and Last Names| ‘

Case Docket No.:. CGC-07-274230

Client (exactly as it appears on Answer): Scott Co, of California, erroneously sued as the alternate entity of
Broadway Plumbing Co., Inc. and Broadway Mechanical Contractors,

Inc.
Has defendant answered? Yes.

Haye all cross-complaints been filed? Unknown.
Does defendant plan to file a cress-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No.
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?
e Propounded and received responses to Special Discovery (Requests for Admissions, Requests for the
Production of Documents, Specially Prepared Interrogatories, and Judicial Council Form Interrogatories).

e Thirteen sessions of the deposition of plaintiff Louis Castagna (for limited time on each day).

What non-expert discovery is anticipated by defendant in the future?

¢ Completion of the deposition of plaintiff Louis Castagna (scheduled to reconvene for additional time
pursuant to Court Order on December 15, 2009, and anticipated to go for limited time each day).

* Supplemental Specially Prepared Interrogatories to determine newly discovered evidence in response to
previous interrogatories.

¢ Depositions of any percipient witnesses identified in responses to discovery and supplemental discovery,
identified through plaintiff's deposition testimony, or where determined as necessary based on results of
ongoing investigation.

Firm Name: _ Vasquez Estrada & Dumont LLP

Attorney’s Signature: /sf Paul J, Gamba Date: 12/2/2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for cach case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna Plaintiff's Attorney: Brayton
[List First and Last Names] .

Case Docket No.: 274230

Client (exactly as it appears on Answer): Sequoia Ventures Inc.
Has defendant answered? Yes

Have all cross-complaints been filed? N/A

Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how leng?

What client specific discovery has defendant conducted to date, if any? Special interrogatories, form
interrogatories, request for admissions and request for production to the plaintiff, and the plaintiff's discovery
deposition has begun but not concluded.

What non-expert discovery is anticipated by defendant in the future? Depositions of any lay witnesses
identified through discovery or investigation.

Firm Name: Hassard Bonnington LLP

Attorney’s Signature: Y) Landi Vapors Date: December +2009

Deadline to submit to Berry & Berry — December 3, 2009.
Please send separate email for cach case to sfcmestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
December 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants Plaintiff's Attorney: Brayton

Case Docket No. — SFSC 274230

Client (exactly as it appears on Answer): Shell Oil Company

Firm: Nixon Peabody, LLP

Has defendant answered? Yes

Have all cross-complaints been filed? We are not aware of any cross-complaints and don’t intend to file one,
Does defendant plan to file a cross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any? None

What non-expert discovery is anticipated by defendant in the future? None

Firm Name: Nixon Peabody, LLP

Attorney’s Signature. i é y if Date: December 3, 2009

Deadline to submit to Berry & Berry~ December 3, 2009.
Please send separate cmail for each case to sfemestatements@berryandberry.comDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
December 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants
Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): Sta-Rite Industries, LLC

Firm: Foley & Mansfield PLLP

Has defendant answered? Yes.

Have all cross-complaints been filed? To our knowledge, yes.
Does defendant plan to file a cross-complaint? No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, why and for how long? No.

What client specific discovery has defendant conducted to date, if any? We have served plaintiff with Form
Interrogatories; Special Interrogatories, Set One; Requests for Admission; and Request for Production of
Documents. Plaintiff has responded to all requests,

What non-expert discovery is anticipated by defendant in the future? Percipient witnesses’ depositions need
to be noticed and scheduled.

Submitted by: David J. Mann Date: December 1, 2009DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna_y. Asbestos Defendants Plaintiff? Attorney: Brayton Purcell
Case Docket No.: SFSC #CGC07-274230

Client (exactly as it appears on Answer): Swinerton Builders

Firm: Parton | Sell | Rhoades

Has defendant answered? Yes

Have all cross-complaints been filed? No Cross-Complaints have been filed.
Does defendant plan to file a eross-complaint? No

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No
If so, why and for how long?

What client specific discovery has defendant conducted to date, if any?*
Client specific questioning at deposition .
What non-expert discovery is anticipated by defendant in the future?*

Special Interrogatories and Requests for Documents to Claimant and then, if witnesses are listed, the noticing
and completing of the depositions of those witnesses. .

Date: December 3, 2009

Deadline to submit to Berry & Berry ~ December 3, 2009.
Email form to SecretarialDept@berryandberry.com
*Please attach separate sheet if necessary.DEFENDANT'S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

or ee

Full Case Name; Louis Castagna v Asbestos Defendants Plaintiffs Counsel: Brayton Purcell
Case Docket No: 274230

Client (exactly as it appears on Answer): Taco, Inc.

Yas defendant answered? Yes

Have all cross-complaint been filed? no

Does defendant plan to file a cross-complaint? no

Has the five-year mandatory dismissal statute been tolled or extended for any reason?

If so, why and for how long? Not to our knowledge

What client specific discovery has defendant conducted to date, if any?*

Defendant Taco, Inc, has served client-specific written discovery including

specially prepared interrogatories, requests for production of documents and other tangible items,
requests for admission and judicial council form interrogatories.

What:non-expert-discovery is anticipated -by defendant in-the future?*

Defendant has no specific non-expert discovery planned in this case. However, depending on plaintiff's responses
to Taco, Inc.’s written discovery, defendant reserves the right to engage in further non-expert discovery including
but not limited to noticing the depositions of percipient witnesses and conducting site inspections on an as needed
basis.

Firm: Walsworth, franklin, Bevins.& McCall, LLP.

Attorney Margaret F. ea }) ‘/ Date: lov 24,2009
Signature: b Ufa ry ¢ q btedf |. 9
Deadline to submit to perlye decry — December, 2009,
Please send separate-email for each case to sfomestatements@berryandberry.com.DEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009 .

Full Case Name: — Louis Castagna v. Asbestos Defendants Plaintiff Attorney: Brayton*Purcell
~- [List Eivst ond Last Names] .

Case Docket No.: CGC-07-274230

Client (exactly as it appears on Answer): Temporary Plant Cleaners, Inc.

Has defendant answered? Yes.

Have all cross-complaints been filed? Unknown,

Does defendant plan to file a cross-complaint?: No.

Has the five-year mandatory dismissal statute been tolled or extended for any reason? No.
If so, why and for how long? Not applicable.

” ‘What client specific discovery has defendant conducted to date, if any? None.

- What. non-expert discovery is anticipated by defendant in the future? None known at this time. In. the event
a discovery dispute arises, counsel for Temporary Plant Cleaners, Inc. will meet and confer with counsel for

plaintiffs to resolve all discovery issues,

Firm Name: ___Pond North LLP

Attorney’s Signature: J rdalrGhh . Date: December 4 2009

Deadline to submit to Berry & Berry — December 3, 2009. ~
Send separate email for each case to sfcmestatements@berryandberry.com
4438-0145:50837L1

iDEFENDANT’S STATUS AND SETTING CONFERENCE STATEMENT
DECEMBER 17, 2009

Full Case Name: Louis Castagna v. Asbestos Defendants (BP) Plaintiff’s Attorney: Brayton Purcell LLC
[List First aid Last Names]

Case Docket No.: SFSC CGC-07-274230

Client (exactly as it appears on Answer): THE INDUSTRIAL MAINTENANCE ENGINEERING
CONTRACTING COMPANY, INC., dba TIMEC

Has defendant answered? Yes

Elaye all cross-complaints been filed? This defendant has not yet filed a cross-complaint in this matter. The
intentions of co-defendants regarding cross-complaints are unknown at this time.

Does defendant plan to file a cross-complaint? Not at this time, However, we reserve our tight to file a cross
_ complaint as discovery progresses,

Has the five-year mandatory dismissal statute been tolled or extended for any reason?
If so, wh