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.
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© oN A WA BR WN & NY NY NY YN NR N KY HF SF KF ese Fe Fe Be Be Se eS ou A A FF BK SF SF oO OM IRA HA BBY KH KF S Dana Sack, SBN: 92425 Joanne Rosendin, SBN: 121025 SACK ROSENDIN, LLP One Kaiser Plaza, Suite 340 ELECTRONICALLY Oakland, California 94612 FILED Telephone: (510) 286-2200 Superior Court of California, for Defendant County of San Francisco Attorneys for Defendant, CHICAGO BRIDGE & IRON COMPANY, coARR 28.2009 an Illinois corporation BY: WILLIAM TRUPEK Deputy Clerk SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION LOUIS CASTAGNA, NO. CGC - 07 - 274230 Plaintiff, JOINDER OF DEFENDANT CHICAGO BRIDGE & IRON v. COMPANY, AN ILLINOIS CORPORATION, TO THE ASBESTOS DEFENDANTS (BP), et al., WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE Defendants. ORDER RE: PLAINTIFF’S DEPOSITION Date: May 11, 2009 Time: 10:30 a.m. Dept.: 610 Judge: Comm. Bruce E. Chan Complaint Filed: June 6, 2007 Trial Date: None Set TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant Chicago Bridge & Iron Company, an Illinois corporation (“CBI”), hereby joins in the Notice of Motion and Motion for Protective Order Re: Plaintiffs 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 Department 610 of the above referenced Court and seeks at a minimum of an additional twenty (20) hours so as 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. -1- JOINDER OF DEFENDANT CHICAGO BRIDGE & IRON COMPANY, AN ILLINOIS CORPORATION, TO THE WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF'S DEPOSITIONCm NA A FF WHY YPN YD NY RY KR KY NY YY Be Be Be eB ewe Be ese em ot AW BF YB HF Se we IY A A Bw KR =| SS For purposes of this Joinder, Defendant CBI 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 Motion; any Joinder, together with all pleadings and documents filed in this matter by other co-defendants herein. CBI is prepared to proceed with the motion and hearing as scheduled even if WPC or any other joining party withdraws the motion or is no longer a party. 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. Defendant CBI further incorporates herein the Declaration of Dana Sack filed and served concurrently herewith. Under Scheiding v. Dinwiddie Constr. Co., (1* Dist., 1999) 69 Cal. App. 4th 64, CBI cannot obtain summary judgment without obtaining responses from the plaintiff regarding all of the matters discussed above, Counsel for CBI cannot prepare for defense at trial without obtaining responses from the plaintiff regarding all of the matters discussed above nor advise CBI regarding the settlement value of this lawsuit, Defendant CBI requires more than one hour and less than two hours to examine the plaintiff regarding the two oil refineries where he believes he saw CBI employees working at the same time he was working at those locations, If he were to testify that he saw CBI working at any other refineries the same amount of additional time would be required, an additional 1-2 hours. DATED: April 27, 2009 SACK ROSENDIN, LLP Dana Sack Attorneys for Defendant CHICAGO BRIDGE & IRON COMPANY, an Illinois corporation -2- JOINDER OF DEFENDANT CHICAGO BRIDGE & IRON COMPANY, AN ILLINOIS CORPORATION, TO THE WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF’S DEPOSITION