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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eo fC SMS DB FS BP BS NM FR 28 BRYDON HUGO & PARKER 18 Main Brant? 2OP FLOR San Fransieeo, CA 94105. Edward R. Hugo [Bar.No, 124839] James C. Parker [Bar No. 106149} Shelley K. Tinkoff [Bar No, 187498] ELECTRONICALLY BRYDON HUGO & PARKER FILED 6 Main Street, 20th Flo OF Superior Court of California, Telephone: ¢ 415) 808-0300 County of San Francisco Facsimile: (415) 808-0333 APR 20 2009 GORDON PARK-LI, Clerk Attorneys for Defendant BY: ANNIE PASCUAL FOSTER WHEELER LLC Depully Clerk SUPERIOR COURT ~- STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO ~ UNLIMITED JURISDICTION LOUIS CASTAGNA, (ASBESTOS Case No. CGC-07-274230 Plaintiffs, v8. JOINDER OF DEFENDANT FOSTER WHEELER LLC TO THE WILLIAM ASBESTOS DEFENDANTS (BYP), etal, | POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE; PLAINTIFF'S Defendants. DEPOSITION Date: May 11, 2009 ‘Time: 10:30 am. rep 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 FOSTER WHEELER LLC (‘Foster Wheeler’), 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 Dept 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. For purposes of this Joinder, Defendant Foster Wheeler hereby adopts and incorporates by reference, WPC’s moving papers as if their own, including the Notice of 1 JOINDER OF DEFENDANT FOSTER WHEELER LLC TO THE WILLIAM POWELL. COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF'S DEPOSITIONoOo ND HT FF CN we Beh et oOo ef NV OA & FS BV NK DS BRYDON HUGO & PARKER 1a Main Seer We FLOOR ‘Bast Frasicisco, CA 94105 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. Foster Wheeler 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. Dated: April 17, 2009 BRYDON HUGO & PARKER By: isi Ker 1. Hoang Shelley kK. Tinkoft Ken L. Hoang Attorneys for Defendant FOSTER WHEELER LLC 2 JOINDER OF DEFENDANT FOSTER WHEELER LLC TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFI’S DEPOSITIONbes OS 6 SM Dw fh Bw 10 Castagna, Louis San Francisco County puperior Court Case No, CGC-07-274230 LexisNexis Transaction No. 24759680 PROOF OF SERVICE / Tam a resident of the State of California, over the age of 18 years, and nota party to the within action. My electronic notification address is fervice@bhplaw.com and my business address is 135 Main Street, 20% Floor, San Francisco, California 94105. On the date below, I served the following: JOINDER OF DEFENDANT FOSTER WHEELER LLC TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFE'S DEPOSITION on the following: BRAYTON PURCELL LLP (Novato) AND SEE LEXIS NEXIS SERVICE LIST 222 Rush Landing Road Novato, CA 949 Fax: (415) 898-1247 x By transmitting electronically the document(s) listed above as set forth on the electronic service list on this date before 5:00 pm. o By transmitting via facsimile the document(s) listed above to the fax number(s) set forth above on this date before 5:00 pam. o By placing the document(s) listed above.in.a sealed envelope and placing the envelope for.coliection and mailing on the date below following the firm's ordinary business practices. Lam readily familiar with the firm’s Practice of collection andl processing correspondence for mailing. Under ‘hat practice it would be deposited with U.S. Postal service on the same day with postage thereon fully prepaid at San Francisco, California in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in avit. o By placing the document(s) listed above in a sealed envelope dlesigniated for Federal Express overnight delivery.and depositing same with fees thereupon prepaid, in a facility regularly maintained by Federal Express, addressed as set forth above. 9° By causing personal delivery of the document(s) listed above to the person(s) at the address(es) set forth hove. I declare under penalty of perj Executed on April 17, 4009, = San. Frandis 10, PROOF OF SERVICE