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  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • CHARLES TOBEY VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS et al ASBESTOS document preview 
						
                                
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                                BRYDON
HUGO & PARKER

John R. Brydon [Bar No. 083365]
Brian H, Buddell [Bar No. 166103]

George A. Otstott [Bar No.184671] ELECTRONICALLY
BR IN HUGO & PARKER
Be Main Street, 200 Floor supeky IL ED.
an. Francisco, : ornra,
Telephone: (415) 808-0300 County of San Francisco
Facsimile: (415) 808-0333 MAY 05 2010
Clerk of the Court
Attorneys for Defendant BY: RAYMOND K. WONG
BAYER CROPSCIENCE, INC,, successor to : Deputy Clerk
AMCHEM PRODUCTS, INC.

SUPERIOR COURT ~ STATE OF CALIFORNIA.
COUNTY OF SAN FRANCISCO ~ UNLIMITED JURISDICTION

CHARLES TOBEY, (ASBESTOS)
Case No, CGC-07-274226
Plaintiff,

vs. / PROOF OF SERVICE OF INDEX OF
MOTIONS IN LIMINE AND MOTIONS
ASBESTOS DEFENDANTS (B*P), IN LIMINE,

Defendants. Date: May 10, 2010
Dept: 206
Judge: Hon, James J, McBride

LexisNexis Transaction 1D 30951796

lam a resident of the State of California, over the age of 18 years, and not a party to
the within action. My electronic notification address is service@bhplaw.com and my:
business address ig 135 Main Street, 20% Floor, San Francisco, California 94105, On the date
below, I served the following:
DEFENDANT BAYER CROPSCIENCE, INC’s:

INDEX OF MOTIONS IN LIMINE AND TRIAL BRIBFS SUBMITTED BY

MIL No, 1: To Prohibit Use in The Presence of The Jury of The Terms “Asbestos
Industry” or “Member of The Asbestos Industry”

MIL No. 2: To Preclude All Parties from Mentioning or Referring to the Existence of
Insurance or Insurance Coverage.

MIL No.3: Defendant Bayer Cropscience, Inc.‘s Joinder In Other Defendants’
Motions In Limine

MIL No.5: To Bxclude Any Evidence Or Argument Concerning Settlement
Discussions Between The Parties

1

INDEX OF MOTIONS IN LIMINE AND TRIAL BRIEFS SUBMITTED BY DEFENDANT BAYER

CROPSCIENCE, INC.BRYDON

HUGO & PARKER
TS Male Symes
wr
Sn Prancaes, £4 94405

MIL.No. 6: To Preclude Evidence Regarding Defendants’ Membership In Trade
Associations, Or Receipt Of Trade Association Publications, Or Other
Constitutionally Protected Activities

MIL No. 7: To Exchide Any Evidence And Argument Concerning The Sale Of
Asbestos-Containing Products Or Other Conduct By H.B. Fuller

MIL No. 8: To Exclude all References At Trial To Evidence Regarding Asbestos
Abatement Efforts or Regulatory Bans On The Use Of Asbestos

MIL No.9: To Preclude Lay Opinion On Whether Products Released Asbestos
Fibers Or Contained Asbestos

MIL No. 13: To Exclude Any Of Plaintiff's Expert Witnesses Not Deposed Prior To
tial :

MIL No. 16: To Exchude All Opinions from Plaintiffs’ Expert Witness Charles Ay
Regarding Benjamin Foster Products

MIL No. 20: To Exclude Evidence Re A “Continuing” Duty to Warn and Post-Sale
Conduct or Knowledge

MIL No. 22: To Exclude All Evidence And Argument ‘That Knowledge Of The
Dangers Of Asbestos-Containing Products Of Others May Be Imputed To Bayer
Cropscience, Inc.

on the following:

BRAYTON PURCELL LLP (Novato) AND SEE LEXIS NEXIS SERVICE LIST
222 Rush Landing Road By Lexis Nexis E-Service Only

Novato, CA 949.

Fax: (415) 898-1247

By Personal Delivery and.

Lexis Nexis. E-Service

x By transmitting electronically the document(s) listed above as set forth on
the electronic service list on this date before 5:00-p.m.

o By transmitting via facsimile the document(s) listed above to the fax number(s)
set forth above on this date before 5:00 p.m.

o By placing the- document(s) listed above in a sealed envelope and {Placing the
envelope for collection and mailing on the date below following the firm's
ordinary business practices. { am readily familiar with the firm's practice of
collection and processing correspondence for mailing. Under that 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, 1am 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 affidavit.

° By placing the document(s) listed above in a sealed envelope designated for
Federal Express overnight delivery and depositing same with fees thereupon

prepaid, in a facility regularly maintained by Federal Express, addressed as set
‘orth above.

2

INDEX OF MOTIONS IN LIMINE AND TRIAL BRIEFS SUBMITTED BY DEFENDANT BAYER

CROPSCIENCE, INC.BRYDON
HuGo & Parker
AS Maghe Sraeerr
28" FLooa
‘San Prangigna, CA 94103

X By causing personal delivery of the document(s) listed above to. the person(s) at.
the address(es) set forth above.

I declare under penalty of perjury that the above is true and correct. Executed on

May 5, 2010, at San Francisco, California.

Wands 2. barred iy

Wanda 0. Claudio

3

INDEX OF MOTIONS IN LIMINE AND TRIAL BRIEFS SUBMITTED BY DEFENDANT BAYER
CROPSCIENCE, INC.