On June 06, 2007 a Party Discovery was filed involving a dispute between Castagna, Louis, and Advocate Mines Limited, Albay Construction Company, All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, American Conference Of Governmental Industrial, American Conference Of Governmental Industrial Hyg, American Standard, Inc., Ameron International Corporation, A.O. Smith Corporation, Asbestos Defendants, Asbestos Manufacturing Company, Auto Friction Corporation, Auto Specialties Manufacturing Company, Baugh Construction Company, Bechtel Corporation, Bell Asbestos Mines Ltd., Borgwarner Morse Tec, Inc., Brassbestos Brake Lining Company, Bridgestone Firestone North American Tire, Llc, Briggs & Stratton Corporation, Bucyrus International, Inc., Caterpillar Inc., Cbs Corporation, A Delaware Corporation, Chevron Products Company, Chevron U.S.A. Inc., Chicago Bridge & Iron Company,, Chrysler Llc Fka Daimlerchrysler Company Llc,, Conocophillips Company, Consolidated Insulation, Inc., Contra Costa Electric, Inc., Copeland Corporation, Copeland Corporation, Llc Fka Copeland Corporation, Crane Co., Csk Auto, Inc., Daimlerchrysler Company Llc, Formerly Known As, Daimlerchrysler Corporation, Dana Corporation, Dillingham Construction N.A., Inc., Does 1-8500, Douglass Insulation Company, Inc., Durametallic Corporation, Eaton Corporation, Eaton Electrical Inc., Elliott Company,, Elliott Turbomachinery Co., Inc., Emsco Asbestos Company, Fibre & Metal Products Company, Fibre & Metal Products Company, Inc., Fisher Controls International Llc, Fmc Corporation, Fmc Corporation-Chicago Pump, Forcee Manufacturing Corp., Ford Motor Company, Foster Wheeler Llc, Garlock Sealing Technologies, Llc, Gate City Plumbing & Heating, Gatke Corporation, General Electric Company, General Motors Corporation, Genuine Parts Co., Genuine Parts Company, Henry Vogt Machine Co., H. Krasne Manufacturing Company, Honeywell International Inc.,, Hopeman Brothers, Inc., Imo Industries Inc., Ingersoll-Rand Company, Interlake Steamship Co., Johnson Controls, Inc., J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Kelly-Moore Paint Company, Inc., Lamons Gasket Company, Landsea Holding Company, Lasco Brake Products, Lear Siegler Diversified Holdings Corp., Lindstrom & King Co., Inc., L.J. Miley Company, Maremont Corporation, Metropolitan Life Insurance Company, Molded Industrial Friction Corporation, Morton International, Inc., National Automotive Parts Association, National Transport Supply, Inc., Nibco Inc., Oakfabco, Inc., Owens-Illinois, Inc., Paccar Inc., Pacific Gas & Electric Company, Pacific Mechanical Corporation, Parker-Hannifin Corp., Performance Mechanical, Inc., Plant Insulation Company, Pneumo Abex Llc, Quintec Industries, Inc., Rapid-American Corporation, Red-White Valve Corporation, Republic Supply Company, Riley Power Inc., Riley Power, Inc., Erroneously Sued As Babcock, Riteset Manufacturing Company, Rockwell Automation, Inc., Rossendale-Ruboil Company, Santa Fe Braun, Inc., Schlage Lock Company, Scott Co. Of California,, Sequoia Ventures Inc., Shell Oil Company, Silver Line Products, Inc., Southern Friction Materials Company, Special Electric Company, Inc., Special Materials, Inc.-Wisconsin, Standard Motor Products, Inc., Standco, Inc, Sta-Rite Industries, Llc, Stuart-Western, Inc., Swinerton Builders Fka Swinerton & Walberg Co., Taco, Inc., Temporary Plant Cleaners, Inc., Terry Corporation Of Connecticut, Terry Steam Turbine Co., The Budd Company, The Dow Chemical Company, The Industrial Maintenance Engineering Contracting, The William Powell Company, Thomas Dee Engineering Company, Timec Company, Inc., Tosco Refining Company, Inc., Trane Us, Inc., Triple A Machine Shop, Inc., Tyco International, Underwriters Laboratories, Inc., Uniroyal Holding, Inc., Universal Friction Materials Company, Unocal Corporation, U.S. Spring & Bumper Company, Warren Pumps, Llc, Wheeling Brake Block Manufacturing Company, Yarway Corporation, Zurn Industries, Llc, Formerly Known As Zurn, for civil in the District Court of San Francisco County.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
Cc my KH A kek BH Dm yb oN YP YR NY MN NB YD Be BR ee eR RB Be oe SAHA WwW FB BN = SE DH AN DH BE WwW NY KF S Gary D. Sharp, Esq. | SBN 116216 T. Eric Sun, Esq. SBN 187486 Sabrina L. Axt, Esq. SBN 238186 ELECTRONICALLY Foley & Mansfield PLLP FILED 1111 Broadway, 10" Floor Superior Court of California, Oakland, CA 94607 County of San Francisco Telephone: (510) 590-9500 Facsimile: (510) 590-9595 coAkR 29 2009... BY: WILLIAM TRUPEK Attorneys for Defendant Deputy Clerk COPELAND CORPORATION LLC SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO LOUIS CASTAGNA, Case No. CGC-07-274230 Plaintiff, “Asbestos-Related Case” JOINDER OF DEFENDANT COPELAND CORPORATION LLC TO THE WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF’S DEPOSITION vs. ASBESTOS DEFENDANTS (Bé¢P), Defendants. DATE: May 11, 2009 TIME: 10:30 am DEPT.: 610 JUDGE: Comm. Bruce E. Chan Complaint Filed: June 6, 2007 Trial Date: None Set Mele el et Ne Ne it ee! St TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant COPELAND CORPORATION LLC (“COPELAND”) hereby joins in the Notice of Motion and Motion For Protective Order Re: Plaintiff's Deposition, filed by its co-defendant THE WILLIAM POWELL COMPANY (“WPC”). WPC’S Motion is to be heard on May 11, 2009, at 10:30 a.m. in Dept. 610 of the above-referenced Court and seeks at a minimum an additional (20) hours to obtain the rest of Plaintiff's testimony and ascertain the extent to which Plaintiff has facts to support his claimed exposures and each Defendants’ role if any, therein. Mil 1 JOINDER OF DEFENDANT COPELAND CORPORATION LLC TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF'S, DEPOSITIONFor purposes of this Joinder, Defendant COPELAND hereby adopts and incorporates by reference, WPC’s moving papers as if their own, including the Notice of Motion, Motion and Memorandum of Points and Authorities and exhibits and declarations filed by WPC in support of their Motions; any Joinder, together with all pleadings and documents filed this matter by other co-defendants herein. COPELAND is prepared 1o proceed with the motion and hearing as scheduled even if WPC or any other joining party withdrew the motion or is no longer a party. As more fully detailed in the Memorandum of Points and Authorities filed by WPC, Plaintiff's lengthy pauses and detailed responses made it impossible to cover adequately Mr. Castagna’s work history and alleged exposure to COPELAND products. As such, to be able to properly defend itself and to evaluate the case, COPELAND asserts its need for additional time to depose Plaintiff. Plaintiffs will not be prejudiced by this Joinder because they have already been provided reasonable and legally sufficient notice of the motion and the scheduled hearing date Dated: April 24 2009 FOLEY & MANSFIELD, P.L.L.P. BY: a oe Gary D. ham T. Eric Sun Sabrina L. Axt Attorneys for Defendant COPELAND CORPORATION LLC 2 JOINDER OF DEFENDANT COPELAND CORPORATION LLC TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF'S DEPOSITION