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  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • LOUIS CASTAGNA VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
						
                                

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RICHARD D. DUMONT, ESQ. (SBN 107967) PAUL J. GAMBA, ESQ. (SBN 146097) TIMOTHY D. F. BARTEAU, ESQ. (SBN 236112) ELECTRONICALLY VASQUEZ ESTRADA & DUMONT LLP FILED 1000 Fourth Street, Suite 700 San Rafael, CA 94901 Telephone: (415) 453-0555 Fax: (415) 453-0549 Attorneys for Defendant LAMONS GASKET COMPANY Superior Court of California, County of San Francisco APR 24 2009 GORDON PARK-LI, Clerk BY: JUDITH NUNEZ Deputy Clerk THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION LOUIS CASTAGNA, Plaintiff, vs. ASBESTOS DEFENDANTS (BP), et al. Defendants. eS CASE NO. CGC-07-274230 DEFENDANT LAMONS GASKET COMPANY’S JOINDER TO THE WILLIAM POWELL COMPANY’S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF’S DEPOSITION Date: May 11, 2009 Time: 10:30 a.m. Dept. 610 Judge: Comm. Bruce E. Chan Action Filed: June 6, 2007 Trial Date: None Set TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant LAMONS GASKET COMPANY (hereinafter “Lamons”) hereby joins in the Notice of Motion and Motion for Protective Order Re: Plaintiff's Deposition, filed by co-defendant THE WILLIAM POWELL COMPANY (hereinafter “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. WPC’s Motion seeks at a minimum an additional twenty (20) hours to fully and adequately complete the deposition of plaintiff Louis Castagna (hereinafter “Plaintiff’), and to ascertain the L DEFENDANT LAMONS GASKET COMPANY’S JOINDER TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF’S DEPOSITION — CASE NO. CGC-07-274230extent to which Plaintiff has facts to support his claimed exposures and to demonstrate each Defendants’ respective role, if any, therein. For purposes of this Joinder, Defendant Lamons hereby adopts and incorporates by reference WPC’s moving papers as if they were Lamons’ own papers, including the Notice of Motion, Motion, Memorandum of Points and Authorities, and exhibits and declarations filed by WPC in support of their Motion. For purposes of this Joinder, Lamons also hereby adopts and incorporates by reference any Joinder filed by any other co-defendant herein. Lamons is prepared to proceed with the motion and hearing as scheduled even if WPC, or any other joining party, was to withdraw the motion, or is no longer a party. As more fully detailed in the Memorandum of Points and Authorities filed by WPC, because of Plaintiff's lengthy pauses and detailed responses, Lamons was unable to reasonably and effectively question Plaintiff regarding any alleged work with and/or around any product and/or material Plaintiff attributes to Lamons. Counsel for Lamons was in the midst of questioning Plaintiff regarding such product and/or materials when plaintiff determined that he was unable to continue for the day, and counsel for WPC suspended the deposition. As such, to be able to properly defend itself and to evaluate the case, Lamons asserts its need for additional time to depose Plaintiff. Plaintiff will not be prejudiced by this Joinder because he has already been provided reasonable and legally sufficient notice of the motion and the scheduled hearing date. Dated: April 24, 2009 VASQUEZ ESTRADA & DUMONT LLP /s/ Timothy D. F. Barteau By: Timothy D. F. Barteau Attorneys for Defendant LAMONS GASKET COMPANY 2 DEFENDANT LAMONS GASKET COMPANY’S JOINDER TO THE WILLIAM POWELL COMPANY'S MOTION FOR PROTECTIVE ORDER RE: PLAINTIFF’S DEPOSITION — CASE NO. CGC-07-274230