Exhibit,Appendix: GODOFREDO PIQUE VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                28

BUTY & CURLIANO LLP.
‘ATTORNEYS ATLAW
‘985 — 12 STREET
‘SUITE 1280
‘OAKLAND CA 94607
"310.267.3000

MADELINE L. BUTY, ESQ. [SBN 157186]
WILLIAM J. EDGAR, ESO. [SBN 243473]
BUTY & CURLIANO LLP

555 — 12" Street, Suite 1280

Oakland, California 94607

Tel: 510.267.3000

| Fax: 510.267.0117

Attorneys for Defendant
| PACCAR INC [sued herein as DOE 1]

GODOFREDO PIQUE,
Plaintiff,
Vv.
| ASBESTOS DEFENDANTS (B¢P), etc.

Defendants.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO — UNLIMITED JURISDICTION

Lo

I, WILLIAM J. EDGAR, hereby declare:

1

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

AUG 20 2009
GORDON PARK-LI, Clerk}
BY: JUANITA D. MURPHY

Deputy Clerk

No. 274659

DECLARATION OF WILLIAM J.
EDGAR AND EXHIBITS IN SUPPORT
OF PACCAR INC.’S MOTION FOR
SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION

Date: November 13, 2009
Time: 9:30 a.m.
Dept: 301

Complaint Filed: May 8, 2008
Trial Date: December 14, 2009

1. Tam an associate with the law firm of Buty & Curliano LLP, attorneys of record for
defendant PACCAR INC. I am duly licensed to practice in all Courts in the State of California. If

called upon, I could and would competently testify to the facts set forth herein.

DECLARATION OF WILLIAM J. EDGAR AND EXHIBITS IN SUPPORT OF PACCAR INC.’S
MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION0 Oo UID

10
ll
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

BUTY & CURLIANOLLP
‘ATTORNEYS AT LAW
588-12" STREET

"310.267.3000

2. Attached hereto as Exhibit A is true and correct copy of plaintiffs’ Complaint for

Personal Injury — Asbestos filed May 8, 2008.
3. Attached hereto as Exhibit B is a true and correct copy of the Amendment to

Complaint.

4, Attached hereto as Exhibit C is a true and correct copy of Plaintiff's Responses
Standard Asbestos Case Interrogatories, Friction, Set One Supplemental & Amended.

5. Attached hereto as Exhibit D is a true and correct copy of Plaintiff's Responses to
Standard Asbestos Case Interrogatories, Set Nos. One & Two, Supplemental & Amended.

6. Attached hereto as Exhibit E is a true and correct copy of PACCAR’s Special
Interrogatories, Set One to Plaintiff.

7. Attached hereto as Exhibit F is a true and correct copy of Plaintiff's Responses to
Defendant PACCAR Inc.’s Special Interrogatories, Set One.

8. Attached hereto as Exhibit G is a true and correct copy of PACCAR’s Request for
Production of Documents, Set One to Plaintiff.

9. Attached hereto as Exhibit H is a true and correct copy of Plaintiffs Responses to
Defendant PACCAR’s Request for Production of Documents, Set One.

10. Attached hereto as Exhibit I is a true and correct copy of the relevant portions of the
transcript of the Deposition of Godofredo Pique, Volume 1, taken March 30, 2009.

11. Attached hereto as Exhibit J is a true and correct copy of the relevant portions of the
transcript of the Deposition of Godofredo Pique, Volume 2, taken April 6, 2009.

12. Attached hereto as Exhibit K is a true and correct copy of the relevant portions of
the transcript of the Deposition of Godofredo Pique, Volume 3, taken April 13, 2009.

13. At his deposition sessions, which I personally attended, plaintiff failed to produce
any responsive documents relating to his alleged exposure to asbestos-containing products
attributable to PACCAR.
fff
fit

DECLARATION OF WILLIAM J. EDGAR AND EXHIBITS IN SUPPORT OF PACCAR INC’S
MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONB

ua

28

BUTY &.CURLIANOLLP.
TTORNEYS ATLAW

Terre

\KLAND CA S467

on
‘510.267.3000

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Executed this 19" day of August 2009, at Oakland, California.

Kis mR S—
WILLIAM J, EDGAR

DECLARATION OF WILLIAM J. EDGAR AND EXHIBITS IN SUPPORT OF PACCAR INC.’S
MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONEXHIBIT ABRAYTON®PURCELE LLP

=. ATTORNEYS ATLAW

222 RUSH LANDING ROAD

(415) 898-1555

oe UA hw eb YD

‘ ENDORSED
DAVID R. DONADIO, PER S.B. #154436 FILED :
BRAYTON**PURCELL LL ‘San Francisco County Superior Coun
222 Rush Lancing Road MAY ~ 8 2008
ni rat

P.O. Box 6169 CASB MANAGEMENT CONPERENCE SET

Novato, ‘Califo 94948-6169 GORDON | PARICLI, Clerk
(415) 896- APR 1 6 2009 at eT Gah

Attomeys for Plaintiff .
DEPARTMENT 206

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO -
GODOFREDO PIQUE, ASBESTOS
Plaintiff, CGC +08 "274659
vs. COMPLAINT FOR PERSONAL INJURY -
ASBESTO:

ASBESTOS DEFENDANTS (BaP
As Reflected on Exhibits B, B-1, C,
I; and DOES 1-8500; and SEE
ATTACHED LIST.

ee

1. Plaintiff GODOFREDO PIQUE was bom April 2, 1945.
2. The ©@Brayton@Pureelt Master Complaint for Personal Injury [and Loss of

Consortium|- Asbestos (hereinafter "Master Complaint") was filed January 2, 2003, in San

Francisco Superior Court. A copy of the Master Complaint and General Order No. 55 may be
obtained upon request from Brayton*Purcell, and designated portions of the Master Complaint
are incorporated by reference herein pursuant to the authority conferred by General Order No: 55,
Plaintiff's claims are as set forth in said Master Complaint against defendants herein as follows:
Mt

Ml. rie GAGE le BUBJECT TO

MANDATORY ELECTRONIC FILING
” PURSUANT TO AMENDED G.0. 158
serge 1

MPLA FOR .1
2
3} ALLIS-CHALMERS CORPORATION PRODUCT LIABILITY TRUST
g|[ BUCYRUS INTERNATIONAL, INC.
C.C. MOORE & CO, ENGINEERS
5) CRANECO.
THE GOODYEAR TIRE & RUBBER COMPANY
6|| DANA CORFORATION
THOMAS DEB ENGINEERING CO., INC.
7|| FOSTER WHEELER LLC
GARLOCK SEALING TECHNOLOGIES, LLC
|| PARKER-HANNIFIN CORPORATION .
PLANT INSULATION COMPANY
9) QUINTEC INDUSTRIES, INC,
, RAPID-AMERICAN CORPORATION
10} UNIROYAL HOLDING, INC.
VIACOM, INC.
11} WESTERN MacARTHUR COMPANY
MacARTHUR COMPANY
12) WESTERN ASBESTOS COMPANY
13] PNBUMO ABEX LLC
HONEYWELL INTERNATIONAL, INC.
14|| FORD MoroR COMPANY
GENERAL MOTORS CORPORATION

= 8
dies
ai
z s : 15|] BORG-WARNER CORPORATION BY ITS SUCCESSOR IN INTEREST, BORGWARNER MORSE TEC INC.
$a3sb2 CARLISLE CORPORATION .
Z2=935 161) SCANDURA, INC.
BES s SK AUTO, INC.
gs a £ 17]] IMO INDUSTRIES, INC.
= 3 INGERSOLL-RAND COMPANY

18} LESLIE CONTROLS, INC.
HOPEMAN BROTHERS, INC.
19] 17. THORPE & SON, INC.
METROPOLITAN LIFE INSURANCE, COMPANY
20], OWENS-ILLINOIS, INC. .
21 || GATKE CORPORATION
AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS, INC.
22|| | UNDERWRITERS LABORATORIES, INC.

and DOES 1-8500,
23
Defendants.
24
25
26
27

Godofredo Pique vs, Asbestos Defendants (BSP)
28], San Francisco Superior Courtao

“WATEXT Aue uo 10 jutejduros soyseyqj ayy Ul YUOy 19s se sopyUe oyeUIOIe so|P pur,
oO Quay - Weceqypneryz) yrsnuam |

. (uoneasoidarstyy jeuorusyuy
o-. Alsseq/pnelys) Wussyeuln

: Quawyessu0puoneyuasaiderstyy

fl (uonsy Jo HasU0D) mUDa}XIg

Oo G@urpuuy soyg ayeig)
Wusayty “Wyusaynoy

. (saotaaq] Araye
oO Asoyenidsay) wusoutyy quien

oO (CWT aA) Hwonarg “yUD,

(IVOMHT) PY UoNesuad
Oo sue410M JOMIEH pur aloyssu07) THUR
@inp pue ssueualuIEW floy souor
aousdySen ‘ssoulyyomeasuy),
oO YS “YWaaag “XS

(Aartgery 10)9e1107)
ABUMQ SestMeIg) YLT

(aninosu0D
Jo 8507) yumo.t

~ (uopejuasaiday
aspedt) PAWL

(Amery omg) puosas
(eousdy gan) ising
Tomy jo sent

Oo 8
jae Wow
Wo

400
yoo
ao
d

a
«|B &Co NAN Hh Aw

10

we

3. Plaintiff's asbestos-related injury, date of diagnosis, employment status, and

history of exposure to asbestos are as stated on Exhibit A.

4. Plaintiff's claims against defendant VIACOM, INC, {successor by mergér to
CBS CORPORATION which is successor-in-interest to WESTINGHOUSE ELECTRIC
CORPORATION) exclude military and federal government jobsites.

Dated: S148

Krta109501

R’

«ASI

BRAYTON® PURCELL LLP

B

” David R. Donadio

Attomeys for PlaintiffEXHIBIT Awo Ory AH aBwn

~
~~ oS

EXHIBITA
Plaintiff's exposure to asbestos and asbestos-containing products occurred at various
locations inside the State of California, including but not limited to:
Location of . Exposure
Dates

Employer Exposure Sob Title
US Navy . 1968-1970

Naval Training Center Trainee 3-4 months
San Diego, C.

PRISTER DER-327), Boiler Tender approx. 6 months
fare Island Naval
Shipyard, Vallejo, CA

VANCE (DER-387), Boiler Tender approx, 15 months
Mare Island Naval
Shipyard, Vallejo, CA

SAINT PAUL (CA-73) . Boiler Tender approx, 1 month

US Government Sea Land Container Utility man 1974-1979
Civil Service Company, Port of Oakland,
“Oakland, CA ,

United Parcel Service, Inc, United Parcel Service Mechanic 1979-1988
Atlanta, GA 8400 Pardee Drive

Oakland, CA

* shop

Federal Express : Federal Express. Mechanic 1988-1990
Oakland International .
Airport, Oakland, CA
+ shop

East Bay Regional Park East Bay Regional Park Mechanic 1990 to January
District, Oakland, CA District, Peralta Oaks 2008
Court, Oakland, CA

NON-OCCUPATIONAL EXPOSURE:

FRICTION: From approximately 1978 until 2002, plaintiff changed the brakes of his persona!
vehicles. Plaintiff. replaced the front disc and rear drum brakes of his 1978 CHEVROLET
(GENERAL MOTORS) Malibu station wagon in the early 1980s. Plaintiff Burchased BENDIX

[ONEY WELL INTERNATIONAL, INC.) replacement brakes from KRAGEN AUTO (CSK
AUTO, INC.) in the San Francisco Bay Area. Plaintiff also replaced the original front disc pads
and rear brake shoes on his-1999 FORD F-150 in approximately 2000.

u“
a“

(PLAINT 71 EXHIBIT A (cont'd.)

x

3 Plaintiffs exposure to asbestos and asbestos-containing products caused severe and

4]] permanent injury fo the plaintiff, including, but not limited to breathing difficulties, asbestosis,
5 |] lung and/or other cancer, mesothelioma, and/or other lung damage. Plaintiff was diagnosed

6 || with lung cancer on or about February 2008."

7 Plaintiff stopped working on January 2008 due to his lung.cancer.EXHIBIT Bow wm I AW KRY DN

EXHIBIT B

DEFENDANTS

ALLIS-CHALMERS CORPORATION PRODUCT
LIABILITY TRUST

BUCYRUS INTERNATIONAL, INC.

C.C, MOORE & CO. ENGINEERS

CRANE CO,

THE GOODYEAR TIRE & RUBBER COMPANY

DANA CORPORATION

THOMAS DEE ENGINEERING CO,, INC.

FOSTER WHEELER LLC

MacARTHUR COMPANY

WESTERN ASBESTOS COMPANY

PNEUMO ABEX LLC

HONEYWELL INTERNATIONAL, INC,

FORD MOTOR COMPANY

GENERAL MOTORS CORPORATION

BORG-WARNER CORPORATION BY ITS

SUCCESSOR IN INTEREST, BORGWARNER

MORSE TEC INC.

GARLOCK SEALING TECHNOLOGIES, LLC CARLISLE CORPORATION
PARKER-HANNIFIN CORPORATION SCANDURA, INC,
PLANT INSULATION COMPANY CSK AUTO, INC,
QUINTEC INDUSTRIES, INC. IMO INDUSTRIES, INC.
RAPID-AMERICAN CORPORATION INGERSOLL-RAND COMPANY
UNIROYAL HOLDING, INC. LESLIE CONTROLS, INC.
VIACOM, INC, DOES 1-800
WESTERN MacARTHUR COMPANY

ALTERNATE ENTITY
BUCYRUS INTERNATIONAL, INC. BUCYRUS-ERIE

MARION POWER SHOVEL COMPANY, THE
OSGOOD COMPANY
GENERAL EXCAVATOR COMPANY

CRANE CO, -

CRANE COMPANY

CRANE PLUMBING & HEATING
CRANE PUMPS & SYSTEMS, INC,
CRANE SUPPLY

- BURK PUMPS

MIDWEST PIPING CO,

MIDWEST PIPING & SUPPLY CO.

MIDWEST INVESTMENT

PACIFIC STEEL BOILER CORPORATION
ss PACIFIC VALVES

CRANE VALVE GROUP

DEMING PUMPS

REPCAL BRASS MANUPACTURING CO.

CHAPMAN VALVE COMPANY

‘JENKINS BROS.

GARLOCK SEALING
TECHNOLOGIES, LLC

GARLOCK, INC.
COLTEC INDUSTRIES, INC,

FAIRBANKS-MORSE

FAIRBANKS MORSE ENGINES
BELMONT PACKING & RUBBER. Co.
GARLOCK PACKING CO,

U.S. GASKET CO,

GOODRICH CORPORATION

ENPRO INDUSTRIES, INC,FOSTER WHEELER LLC
PARKER-HANNIFIN CORPORATION

UNIROYAL HOLDING, INC.
VIACOM, INC,

WESTERN MacARTHUR
COMPANY,

PNEUMO ABEX LLC

GENERAL MOTORS CORPORATION

EXUIBIT B fcont'd.)
ALTERNATE ENTITY
FOSTER WHEELER CORPORATION

“ SACOMA-SIERRA, INC.

SACOMA MANUFACTURING COMPANY
EJS, AUTOMOTIVE CORPORATION
CONDREN CORPORATION, THE
PARKER SEAL COMPANY

UNIROYAL, INC.

CBS CORPORATION

WESTINGHOUSE ELECTRIC CORPORATION
WESTINGHOUSE ELECTRIC AND .
MANUFACTURING COMPANY

B.F. STURTEVANT

KPIX TELEVISION STATION

PARAMOUNT COMMUNICATIONS, INC.

WESTERN ASBESTOS CO.

MAC ARTHUR COMPANY

BAY CITIES ASBESTOS COMPANY
F.K. PINNBY, INC.

PNEUMO ABEX CORPORATION

ABEX CORPORATION

AMERICAN BRAKE SHOE COMPANY

EATON BRAKE SHOES

EATON MANUFACTURING CO.

AMERICAN BRAKE SHOE AND FOUNDRY COMPANY

AMERICAN BRAKEBLOK, DIVISION OF AMERICAN
BRAKE SHOE AND FOUNDRY CO.

AMERICAN BRAKEBLOK CORPORATION

AMERICAN BRAKE MATERIALS CORPORATION |

AMERICAN BRAKE SHOE AND FOUNDRY (DE)

NEW DEPARTURE

CHEVROLET

A.C, DELCO CO,

BUICK AUTOMOTIVE CORPORATION
CADILLAC

PONTIAC

LaSALLE

OLDSMOBILE

GM GOODWRENCH -

ROCHESTER PRODUCTS DIVISION
EUCLID ROAD MACHINERY CO.
FRIDGIDAIRE (for exposure pre 4/9/1979)

EXHIBIT BSo OO INAH kh YW HD

PNR PN YPN RK Ke we ew ew ew Be ee ee
eu Aas ON =| 5F OMIA RBH =

ew

HONEYWELL INTERNATIONAL, INC,

FORD MOTOR COMPANY

BORGWARNER MORSE TEC, INC,

. ALTERNATE ENTITY

HONEYWELL, INC.
HONEYWELL CONTROLS
ALLIEDSIGNAL, INC.
ALLIED-SIGNAL, INC,
‘THE BENDIX CORPORATION
BENDIX PRODUCTS AUTOMOTIVE DIVISION
BENDIX PRODUCTS DIVISION, BENDIX AVIATION CORP.
BENDIX HOME SYSTEMS
ALLIED CORPORATION
ALLIED CHEMICAL CORPORATION
GENERAL CHEMICAL CORPORATION
FRAM
FRICTION MATERIALS OF LOS ANGELES
NORTH AMERICAN REFRACTORIES COMPANY
EM SECTOR HOLDINGS INC.
UNIVERSAL OIL PRODUCTS COMPANY
BOYLSTON CORPORATION
EHRHART & ASSOCIATES, INC.
EHRHART & ARTHUR, INC.
GARRETT AIR RESEARCH CORP.
STANLEY G, FLAGG & CO.
MERGENTHALER LINOTYPE COMPANY
ELTRA CORPORATION
BUNKER RAMO-ELTRA CORPORATION
UNION TEXAS NATURAL GAS CORPORATION
UNION OIL AND GAS OF LOUISIANA
UNION SULPHUR AND OIL CORPORATION

. UNION SULPHUR COMPANY, INC., THE
MINNEAPOLIS-HONEYWELL REGULATOR COMPANY
SIGNAL COMPANIES, INC,, THE
HANCOCK OIL COMPANY*
BARRETT DIVISION, ALLIED CHEMICAL & DYE
CORPORATION

BRITISH LEYLAND MOTORS, INC.
BRITISH MOTOR CORPORATION
JAGUAR CARS, INC,

TRIUMPH

LINCOLN CONTINENTAL

AUSTIN HEALEY

 BORG-WARNER CORPORATION
AP BORG & BECK

BORG & BECK
YORK BORG WARNER

EXHIBIT B |

“AlCARLISLE CORPORATION

CSK AUTO, INC,

IMO INDUSTRIES, INC,

INGERSOLL-RAND COMPANY

* CARLISLE MANAGEMENT COMPANY

EXHIBIT B (cont'd.)
ALTERNATE ENTITY
CARLISLE DELAWARE CORPORATION

MOTION CONTROL INDUSTRIES, INC.
CARLISLE TIRE & RUBBER COMPANY
GEAUJA COMPANY

TENSOLITE COMPANY

BRAEMAR CORPORATION
CONTINENTAL CARLISLE CORPORATION
DIGITAL CONTROLS CORPORATION
GRAHAM MAGNETIC INCORPORATION

KRAGEN AUTO SUPPLY CO,
NORTHERN AUTOMOTIVE CORPORATION
CHECKER AUTO PARTS, INC.

‘TBDPC CORPORATION

PACCAR AUTOMOTIVE, INC.

GRAND AUTO, INC. .

AL'S AND GRAND AUTO SUPPLY, INC.
SCHUCK’S AUTO SUPPLY

TOPPS AUTOMOTIVE °

TRAK AUTO PARTS

TRANSAMERICA DELAVAL, INC. .
ENTERPRISE ENGINE & MACHINERY CO.
DE LAVAL STEAM TURBINE, INC,
DELAVAL STEAM TURBINE

DELAVAL INDUSTRIES INC.

DE LAVAL TURBINE, INC.

GENERAL METALS CORPORATION
CROW CENTRIFUGAL PUMPS

INGERSOLL-DRESSER PUMP
DRESSER-RAND CO,

PACIFIC PUMP WORKS

FLOWSERVE CORPORATION
INGERSOLL ROCK DRILL COMPANY
TERRY STEAM TURBINE CO,
WHITON MACHINE COMPANY
RAND DRILL COMPANY

» RAND & WARING DRILL AND COMPRESSOR COMPANY

INGERSOLL-SERGEANT
SCHLAGE LOCK COMPANY
VON DUPRIN

THE TORRINGTON COMPANY
BLAW-KNOX COMPANY
ALDRICH PUMPS

EXHIBIT B

ioe NY A Ww eB wD

LESLIE CONTROLS, INC.

EXHU nit'd.

EI 'E ENTITY

LESLIE CO,

LESLIE

LESLIE EVENTEMP
LESLIE TYFON

LESLIE CONSTANTEMP
LUBRASOFTEXHIBIT B-1O-eo ANH Rw Dd

DEFENDANTS

HOPEMAN BROTHERS, INC.

THOMAS DEE ENGINEERING CO,, INC.
J.T. THORPE & SON, INC.
DOES 1-800; DOES 1001-2000
ALTERNATE ENTITY

J.T, THORPE & SON, INC. THE THORPE COMPANY
THORPE PRODUCTS CO.
ST, THORPE NORTHWEST

EXHIBIT B-)EXHIBIT C1 . -EXHIBIT C
DEFENDANTS
HOPEMAN BROTHERS, INC. WESTERN MacARTHUR COMPANY
THOMAS DEE ENGINEERING CO., INC. MacARTHUR COMPANY
J.T. THORPE & SON, INC. WESTERN ASBESTOS COMPANY

2

3

4

5) Sarena meso
6

7

8

9

LOCATION "TIME PERIOD
HOPEMAN BROTHERS, INC. Various Various

CONTRACTOR
DEFENDANTS

THOMAS DEE ENGINEERING CO.,INC. Various Various
10] 1.7, THORPE & SON, INC. Various Various
11 |] C.c. MOORE & CO. ENGINEERS Various Various
12 || PLANT INSULATION COMPANY Various . Various
13] WESTERN MacARTHUR Various Various

COMPANY/MacARTHUR
14 || COMPANY/WESTERN ASBESTOS
15 |] COMPANY
16
17
18
19
20 /
21 : : . .
22 ‘ :
“23
24
25
26
27
28 ‘ 7 EXHIBIT C. EXHIBIT Hwo wad Aw Bw NY =

Re RNY HR RN NY! ee ew Be ee Be ee
AAU S OUNnH =| SOW AH PB YwWNH = Oo

28

EXHIBITH

DEFENDANTS

METROPOLITAN LIFE INSURANCE COMPANY
PNEUMO ABEX LLC :
BORGWARNER MORSE TEC, INC.
HONEYWELL INTERNATIONAL, INC. {successor-in-
interest to ALLIEDSIGNAL, INC.)
THE BUDD COMPANY
DAIMLERCHRYSLER CORPORATION
DANA CORPORATION
FORD MOTOR COMPANY
GENERAL MOTORS CORPORATION
BRIDGESTONE/FIRESTONE
NORTH AMERICAN TIRE, LLC
LEAR SIEGLER DIVERSIFIED HOLDINGS CORP.
MAREMONT CORPORATION
MORTON INTERNATIONAL, INC.
PARKER-HANNIFIN CORPORATION
STANDARD MOTOR PRODUCTS, INC.
GATKE CORPORATION
GARLOCK SEALING TECHNOLOGIES, LLC
BRASSBESTOS BRAKE LINING COMPANY
H. KRASNE MANUFACTURING COMPANY

STUART-WESTERN, INC,

RITESET MANUFACTURING COMPANY
ASBESTOS MANUFACTURING COMPANY

FIBRE & METAL PRODUCTS COMPANY

LASCO BRAKE PRODUCTS

L.J, MILEY COMPANY .
ROSSENDALE-RUBOIL COMPANY

SOUTHERN FRICTION MATERIALS COMPANY
U.S. SPRING & BUMPER COMPANY

AUTO FRICTION CORPORATION

EMSCO ASBESTOS COMPANY

FORCEE MANUFACTURING CORPORATION :
MOLDED (NDUSTRIAL FRICTION CORPORATION
NATIONAL TRANSPORT SUPPLY, [NC,

SILVER LINE PRODUCTS, INC.

STANDCO, INC. 5

UNIVERSAL FRICTION MATERIALS COMPANY

* WHEELING BRAKE BLOCK MANUFACTURING

COMPANY
OWENS-ILLINOIS, INC,
BELL ASBESTOS MINES LTD.

AUTO SPECIALTIES MANUFACTURING COMPANY DOES5000-8000

EXHIBIT HEXHIBIT IEXHIBIT 1
DEFENDANTS

METROPOLITAN LIFE INSURANCE COMPANY

OWENS-ILLINOIS, INC.

PNEUMO ABEX LLC

GATKE CORPORATION

GARLOCK SEALING TECHNOLOGIES, LLC

AMERICAN CONFERENCE OF GOVERNMENTAL INDUSTRIAL HYGIENISTS, INC.
UNDERWRITERS LABORATORIES, INC.

DOESS000-7500EXHIBIT BPO BOX 6169

NOVATO, CALIFORNIA 94948-6169

BRAYTON@PURCELL LLP
ATTORNEYS AT LAW
222 RUSH LANDING ROAD

(415) 898-1355

DAVID R. DONADIO, FSO. S.B. #154436
BRAYTON¢PURCELL LL!

Attorneys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attomeys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
GODOFREDO PIQUE, ) ASBESTOS
) No. 274659
Plaintiff,
AMENDMENT TO COMPLAINT

vs.

ASBESTOS DEFENDANTS (BP)

—_—

[C.C.P. Section 474]

Plaintiff amends the complaint in this action as follows:

Plaintiff has learned the true names of the defendants designated in the complaint as

fictitious DOES as set forth below:

TRUE NAME

PACCAR INC.
ALTERNATE ENTITIES:
PETERBILT MOTORS COMPANY
PETERBILT TRUCK COMPANY
PETERBILT TRUCK CENTER, INC.
KENWORTH TRUCK COMPANY
PACIFIC CAR AND FOUNDRY COMPANY
KW
BRADEN WINCE CO,

W
W
Ww

ENujurest09505 deel wpd
AMENDMENT TO COMPLAINT

FICTITIOUS
DOE 12 Oo UA mH BF wn

NN MP NY NNN YD ee ee eB ee Be ee
oN A A BON = SF BHO AKIN AHWR DONE DS

Plaintiff hereby substitutes such true names for the fictitious names as set forth above

wherever said names appear in the complaint.
Dated: Hizaby BRAYTON“PURCELL LLP

wy ©

" David R. Donadio
Attorneys for Plaintiff

KAtnjuresh 1 09505\doe! ws 2
AMENDMENT TO COMPLAINTEXHIBIT CoO AA HW PF WN |

ea ae
A F&F Dw Ne &

POBOX 6169
(415) 898-1555

NOVATO, CALIFORNIA 94948-6169
in

ATTORNEYS AT LAW
222 RUSH LANDING ROAD

BRAYTON@PURCELL LLP

NN fF =
= So wm NX

YN NY YN ND
eorI AA FY DN

ALAN R. BRAYTON, ESQ,, 8.B. #73685
KIMBERLY J. CHU, ESQ., 8.B. #206817
BRAYTON“*PURCELL LLP

Attorneys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attorneys for Plaintiff

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO
GODOFREDO PIQUE, : ) ASBESTOS
No. 274659
Plaintiff,

SUPPLEMENTAL AND AMENDED
vs. : ANSWERS TO INTERROGATORIES
ASBESTOS DEFENDANTS (B¢*P) ) (FRICTION)

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
FRICTION
RESPONDING PARTY: Plaintiff GODOFREDO PIQUE
SET NO: ONE (SUPPLEMENTAL AND AMENDED)
ANSWERS

1. GODOFREDO PIQUE.
2. Yes,
A. Inter-Island Construction Corporation, 127 Ayala Avenue, Makati, Rizal,
Philippines. , |
B. June 14, 1962 to March 30, 1964.
Cc. Plaintiff currently does not recall the names of any of his supervisors.
Plaintiff recalls that Francisco Cacho, address presently unknown, owned Inter-Island
Construction Corporation. Plaintiff's investigation and discovery are continuing.

D, __ . Plaintiff recalls the following co-workers: Mr Magat, address presently

KAlnjured\109505%ai-frietion-supp.wpd 1unknown; Francisco Gallardo, address unknown; Arsenio Melendes, address Presently unknown,
Plaintiff's investigation and discovery are continuing,

E. Plaintiff currently does not recall the names of any other persons with
knowledge regarding his exposure at this jobsite. Plaintiffs investigation and discovery are _
continuing.

F. Heavy Equipment Mechanic.

G Plaintiff worked as a heavy equipment mechanic. Plaintiff ‘performed

Tepair and maintenance work on bulldozers, cranes, loaders, back hoes, mixer trucks, dump

© mxA Dw Bw WD

trucks and small.engines. Plaintiff removed and installed engine gaskets and brake bands on
cranes. Plaintiff removed and replaced cable-winch brakes on CATERPILLAR bulldozers.
Plaintiff was present when clutches were removed and replaced on CATERPILLAR bulldozers.
Plaintiff removed and replaced-drum brakes on INTERNATIONAL HARVESTER, dump trucks

10
Mt
12
13
14
15
16
7
18
19
20
2

and Hino dump trucks and was Present when others did the same. Plaintiff used compressed air
to clean out the brake areas. Plaintiff arced the replacement brakes, Plaintiff re-lined brake
shoes with BENDIX (HONEYWELL INTERNATIONAL) brake linings, Plaintiff filed the
BENDIX (HONEYWELL INTERNATIONAL) replacement brake linings. Plaintiff was present
when others removed and replaced brakes, clutches and engine gaskets on GMC mixer trucks,
Plaintiff removed and replaced BORG WARNER clutch assemblies. Plaintiff sanded and
toughed up the BORG WARNER replacement clutch assemblies. Plaintiff was present when
others installed BORG WARNER replacement clutch assemblies. Plaintiff removed and
installed gaskets in WISCONSIN portable engines.

22
23
24
25
26
27
28

H Please refer to Interrogatory No. 2.G above.

I Please refer to Interrogatory No. 2.G above.

J. Please refer to Interrogatory No. 2.G above.

K. Plaintiff used compressed air to clean out the brake areas.

L. Unknown at present. Plaintiff's investigation and discovery are

continuing.

5

Plaintiff re-lined brake shoes with BENDIX (HONEYWELL

KAinjured\109S0S\ai-friction-supp.wpd 2CP Omrny Dh F WK |

Qe es Be eB Be ew ew we ee
oS Owe IN KD Hh RB YW NK Oo

21

CC. Please refer to Interrogatory No. 2.BB above.
DD. Please refer to Interrogatory No. 2.BB above.
EE. Plaintiff has no documents responsive to this Interrogatory. Plaintiff's

investigation and discovery are continuing.

A. E.E. Black, Limited, The Dole Project, General Santos Island, Cotabato,
Phillippines.

B. March 17, 1964 to September 5, 1965.

Cc. Plaintiff currently does not recall the names of any of his supervisors.
Plaintiff's investigation and discovery are continuing.

D. Plaintiff recalls the following co-workers: Mr. Mendoza, Philippines;
Francisco Gallardo, address unknown. Plaintiff's investigation and discovery are continuing.

E. Plaintiff currently does not recall the names of any other persons with
knowledge regarding his exposure at this jobsite. Plaintiffs investigation and discovery are
continuing. .

F. Heavy Equipment Mechanic.

G. Plaintiff worked as a heavy equipment mechanic. Plaintiff performed
Tepair and maintenance work on bulldozers, cranes, loaders/backhoes, mixer trucks, dump trucks
and small engines. Plaintiff was present when others performed clutch work on CATERPILLAR
bulidozers. Plaintiff removed and replaced clutches .on JOHN DEERE loaders/backhoes and sa
others perform the same work. Plaintiff removed and replaced drum brake assemblies on
INTERNATIONAL HARVESTER dump trucks and saw others perform the same work.
Plaintiff re-lined brake shoes with BENDIX (HONEYWELL INTERNATIONAL, INC.) brake
linings. Plaintiff filed and sanded the BENDIX (HONEYWELL INTERNATIONAL, INC.)
replacement brake linings. Plaintiff removed and installed CUMMINS engine gaskets.on dump
trucks. Plaintiff was present when others performed brake work on GMC and REO mixer trucks]
Plaintiff performed clutch removals and replacements on INTERNATIONAL HARVESTER.
dump trucks and was present when others did the same. Plaintiff removed BORG WARNER —

KAlnjured\10950S\ai-friction-supp-wpd 41|| clutch assemblies. Plaintiff used compressed air to clean out the clutch areas. Plaintiff sanded

and roughed up the BORG WARNER replacement clutches prior to installation. Plaintiff recalls

2

3] generators and compressors manufactured by ALLIS-CHALMERS.

4 H. Please refer to Interrogatory No. 2.G above.

5 L Please refer to Interrogatory No. 2.G above.

6 J Please refer to Interrogatory No. 2.G above.

7 K, Plaintiff used compressed air.

8 L. Plaintiff used compressed air to clean out the clutch areas.

9 . M. Plaintiff installed BENDIX (HONEYWELL INTERNATIONAL, INC.)

10] brake linings. Plaintiff installed BORG WARNER clutches. Plaintiff's investigation and

11] discovery are continuing.

12 N.-O. Plaintiff is currently unaware of any arcing or grinding of asbestos

13 |] containing friction products.

14 P. Yes. Plaintiff filed and sanded the BENDIX (HONEY WELL

15 INTERNATIONAL, INC.) replacement brake linings. Plaintiff sanded and roughed up the ,
16] BORG WARNER replacement clutches prior to installation.

17 Q-R. Plaintiff is currently unaware of any cutting or drilling of asbestos

18} containing friction products.

19 ’ S$. Yes.

20 T. Plaintiff removed BORG WARNER clutch assemblies. Plaintiff is

21} unaware of the specific manufacturers of each asbestos-containing friction product which he
22] removed. Plaintiff's investigation and discovery are continuing.

23 U. Plaintiff currently does not recall any such written information. Plaintiffs
24 || investigation and discovery are continuing.

25 Vv. Plaintiff recalls working on bulldozers, cranes, loaders/backhoes, mixer
26 || trucks, dump trucks and small engines.

27 W. Plaintiff recalls CATERPILLAR bulldozers, JOHN DEERE

28 || loaders/backhoes, INTERNATIONAL HARVESTER dump trucks, GMC and REO mixer

KAlnjured\109505\ai-friction-supp.wpd 5trucks, and INTERNATIONAL HARVESTER dump trucks. Plaintiff cannot identify the
manufacturer of each piece of equipment. Plaintiff's investigation and discovery are continuing.

Xx. Please see response to Interrogatory No. 2.G above.

Y. Please see response to Interrogatory No. 2.G above.

Zz. Plaintiff cannot presently recall the identities of any suppliers of asbestos-
containing friction products. Plaintiff's investigation and discovery are continuing.

AA. Please see response to Interrogatory No. 2.Z above.

BB. Plaintiff does not recall any safety equipment or precautions.

CC. Please refer to Interrogatory No. 2.BB above.

DD. Please refer to Interrogatory No. 2.BB above.

EE. Plaintiff has no documents responsive to this Interrogatory. Plaintiff's

investigation and discovery are continuing.

A. Arguelto Sheil, 3900 California Street, San Francisco, California.

B. October 1967 to June 1968.

Cc Plaintiff currently does not recall the names of any of his supervisors.
Plaintiff's investigation and discovery are continuing.

D.. Plaintiff recalls the following co-worker: John Savory, San Francisco,
California. Plaintiff's investigation and discovery are continuing,

E. Plaintiff currently does not recall the names of any other persons with
knowledge regarding his exposure at this jobsite. Plaintiff's investigation and discovery are
continuing.

F. Gas station attendant.

G. Plaintiff worked as a gas station attendant. Plaintiff changed oil and
pumped gas. Plaintiff performed brake checks. Plaintiff worked in close proximity to mechanics}
performing brake work on FORD, GENERAL MOTORS and CHRYSLER vehicles. Plaintiff
was present when BENDIX (HONEYWELL INTERNATIONAL, INC.) replacement brake
assemblies were sanded, filed and installed.

KNinjured\0950S\ai-frietion-supp.wpd 6he

u. ‘Please refer to Interrogatory No. 2.G above.
L Please refer to Interrogatory No. 2.G above.
J.

2
3 Please refer to Interrogatory No. 2.G above.
4 K. Plaintiff is unaware of the method the mechanics used to clean the brake
5 || assembly. Plaintiff's investigation and discovery are continuing.
6] L. Plaintiff did not do clutch repair at this jobsite.
7 M. Plaintiff was present when BENDIX (HONEYWELL INTERNATIONAL
8 || INC.) replacement brake assemblies were installed. Plaintiff's investigation and discovery are
9} continuing.
10 N.-P. Plaintiff was present when BENDIX (HONEYWELL INTERNATIONAL,
11] INC.) replacement brake assemblies were sanded, and filed.
12 Q.-R. Plaintiff is currently unaware of any cutting or drilling of asbestos
13]| containing friction products. Plaintiff's investigation and discovery are continuing.
14 8. Yes.
15 T. Plaintiff is unaware of the specific manufacturers of each asbestos-
16] containing friction product removed. Plaintiffs investigation and discovery are continuing.
17 U. Plaintiff currently does not recall any such written information. Plaintiffs
18 || investigation and discovery are continuing. ,
19 Vv. Plaintiff recalls cars and pickup trucks.
20 W. Plaintiff worked in close proximity to mechanics performing brake work
21]| on FORD, GENERAL MOTORS and CHRYSLER vehicles. Plaintiff's investigation and
221 discovery are continuing.
23 X. Please see response to Interrogatory No. 2.G above.
24 I Y. Please see response to Interrogatory No. 2.G above.
25 Z. Plaintiff cannot presently recall the identities of any suppliers of asbestos-
26 |} containing friction products. Plaintiff's investigation and discovery are continuing.
27 AA. Please see response to Interrogatory No. 2.Z above.
28 BB. Plaintiff does not recall any safety equipment or precautions.
 iAtnjured\109S0S\ai-friction-supp.wpe 7~~

CC. Please refer to Interrogatory No. 2.BB above.
DD. Please refer to Interrogatory No. 2.BB above.
BE, Plaintiff has no documents responsive to this Interrogatory. Plaintiff's

investigation and discovery.are continuing.

A. Cliff Andrews Shell, San Francisco, California.
B. October 1969 to March 1970.

“C. Plaintiff currently does not recall the names of any of his supervisors.

Co wr awn es WY NY

Plaintiff's investigation and discovery are continuing.

D. Plaintiff recalls the following co-workers: John Savory, San Francisco,
California; and Danillo Salonga, San Francisco, California. Plaintiff's investigation and ©
discovery are continuing. :

E. Plaintiff currently does not recall the names of any other persons with
knowledgé regarding his exposure at this jobsite. Plaintiff's investigation and discovery are
continuing. :

F, Gas station attendant.

G. Plaintiff worked as a gas station attendant. Plaintiff changed oil and
pumped gas. Plaintiff performed brake checks. Plaintiff worked in close proximity to mechanics
performing brake work. Plaintiff was present when BENDIX (HONEY WELL
INTERNATIONAL, INC.) replacement brake assemblies were sanded, filed and installed.
Plaintiff cleaned and swept up the shop.

H. Please refer to Interrogatory No. 2.G above.

L Please refer to Interrogatory No. 2.G above.

I. Please refer to Interrogatory No. 2.G above.

K. Plaintiff is unaware of the method the mechanics used to clean the brake
assembly. Plaintiff's investigation and discovery are continuing.

L. __ Plaintiff did not do clutch repair at this jobsite.

M. Plaintiff was present when BENDIX (HONEYWELL INTERNATIONAL,

KNnjured\l09S0S\i-friction-supp.wpd” 8INC.) replacement brake assemblies were installed. Plaintiff's investigation and discovery are

2} continuing. /
N.-P. Plaintiff was present when BENDIX (HONEYWELL INTERNATIONAL,

3

4|| INC) replacement brake assemblies were sanded, and filed.

3 Q-R. Plaintiffis currently unaware of any cutting or drilling of asbestos
6 || containing friction products. Plaintiff's investigation and discovery are continuing.

7 8. Yes.

8 T. Plaintiff is unaware of the specific manufacturers of each asbestos-

U. Plaintiff currently does not recall any such written information. Plaintiff's
investigation and discovery are continuing. :

V. Plaintiff recalls cars and pickup trucks.

W._ Plaintiff cannot identify the manufacturer of each motor vehicle worked
on. Plaintiff's investigation and discovery are continuing, ‘

XxX. Please see response to Interrogatory No. 2.G above.

Y. Please see response to Interrogatory No. 2.G above.

Z. Plaintiff cannot presently recall the identities of any suppliers of asbestos-
containing friction products. Plaintiff's investigation and discovery are continuing.

AA. _ Please see response to Interrogatory No. 2.Z above.

BB. Plaintiff does not recall any safety equipment or precautions.

CC. Please refer to Interrogatory No. 2.BB above.

DD, Please refer to Interrogatory No. 2.BB above.

EE. Plaintiff has no documents responsive to this Interrogatory. Plaintiff's

investigation and discovery are continuing.

A. Sunset Scavenger Company, San Francisco, California.
B. July 1970 to June 1972; and January 1972 to September 1973.
Cc. Plaintiff currently does not recall the names of any of his supervisors.

KNlnjured\109505\ai-friction-supp.wpd 9oo ra DH Hw WEN

10

Plaintiff recalls that the owner of Sunset Scavenger Co. was Leonardo Steffanelli, address
currently unknown. Plaintiff's investigation and discovery are continuing.

D. Plaintiff recalis the following co-workers: Gary, last name unknown and
address currently unknown; Mr. Bautista, fist name unknown and address currently unknown.
Plaintiff's investigation and discovery are continuing.

E. Plaintiff currently does not recall the names of any other persons with
knowledge regarding his exposure at this jobsite. Plaintiff's investigation and discovery are
continuing.

FE Lube man.

G. Plaintiff worked out of Teamsters Local 665, San Francisco, California, as
a ‘lube man’ for a mobile lubrication company that serviced utility trucks, such as WHITE
(TUBE CITY IMS CORPORATION) and HEIL CO. garbage trucks. Plaintiff performed his
work at Sunset Scavenger Co. in San Francisco, California. Plaintiff checked oil and changed oil
filters. Plaintiff was present when others performed brake work, including the removal and
replacement of brake assemblies. Plaintiff was present when others cleaned out the brake areas
with compressed air. Plaintiff saw boxes of BENDIX (HONEY WELL INTERNATIONAL,
INC.) replacement brakes.

H. Please refer to Interrogatory No. 2.G above.

I Please refer to Interrogatory No. 2.G above.

c Please refer to Interrogatory No. 2.G above.

K Plaintiff was present when others cleaned out the brake areas with
compressed air. :

L Plaintiff did not do clutch repair at this jobsite.

M. Plaintiff saw boxes of BENDIX (HONEYWELL INTERNATIONAL,
INC.) replacement brakes, Plaintiff's investigation and discovery are continuing.

N.-R. Plaintiff is currently unaware of any arcing, grinding, sanding, cutting or
drilling of asbestos containing friction products. Piaintiff’s investigation and discovery are

continuing.

KAtnjured\10950S\ai-friction-supp.wpd 10EXHIBIT DPOBOX 6169
NOVATO, CALIFORNIA 94948-6169

BRAYTON@PURCELL LLP
ATTORNEYS AT LAW
222 RUSH LANDING ROAD
(415) 898-1595

eC OI AHA RB WN Ye

Roe ee oe ee eK =
S 6 we U2 aAaar GBH S

21

ALAN R. BRAYTON, ESQ., S.B. #73685
BRYN C. GALLAGHER, ESQ,, S.B. #256592
BRAYTON*®PURCELL LLP

Attomeys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948

(415) 898-1555

Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

GODOFREDO PIQUE, ASBESTOS

No, 274659

Plaintiff,

SUPPLEMENTAL/AMENDED
vs. RESPONSES TO INTERROGATORIES
ASBESTOS DEFENDANTS (BP)

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff GODOFREDO PIQUE
SET NOS.: ONE and TWO

Plaintiff supplements/amends his Responses to Standard Asbestos Case Interrogatories,
Set One, No. 26, and Set Two, Nos. 1 through 3, as follows:

SUPPLEMENTAL/AMENDED RESPONSE: Plaintiff incorporates by reference as though

fully set forth herein, all work history jobsites and co-workers and related information identified

in the attached Exhibit A.
Dated: 5 = 4 -{ } BRAYTON**PURCELL LLP

KAlnjured\109505\pId\Al-supsac3.wpd 1 begEXHIBIT A

Godofredo Pique v. Asbestos Defendants (BYP)

Location of Exposure
Employer Exposure Job Title Dates
Inter-Island Construction Inter-Island Construction Heavy 6/14/62-3/30/64
Corporation Corporation Equi ment
127 Ayala Avenue 127 Ayala Avenue lechanic

Makati, Rizal, Philippines Makati, Rizal, Philippines

Job Duties: Plaintiff worked as a heavy equipment mechanic. Plaintiff performed repair and
maintenance work on bulldozers, cranés, loaders, back hoes, mixer trucks, dump trucks and
small engines. Piaintiff removed and installed engine gaskets and brake bands on cranes.
Plaintiff removed and replaced cable-winch brakes on CATERPILLAR bulldozers. Plaintiff
was present when clutches were removed and replaced on CATERPILLAR bulldozers,
Plaintiff removed and replaced drum brakes on INTERNATIONAL HARVESTER
(NAVISTAR, INC.) dump trucks and Hino dump trucks and was present when others did the
same. Plaintiff used compressed air to clean out the brake areas. Plaintiff arced the
replacement brakes. Plaintiff re-lined brake shoes with BENDIX (HONEYWELL
INTERNATIONAL) brake linings. Plaintiff filed the BENDIX (HONEYWELL
INTERNATIONAL) replacement brake linings. Plaintiff recalled removing gaskets from the
axle shaft of INTERNATIONAL HARVESTER dump trucks that had an “TH” on them.
Plaintiff was present when others removed and replaced brakes, clutches and engine gaskets on
GMC mixer trucks. Plaintiff removed and replaced BORG WARNER clutch assemblies.
Plaintiff assisted in tae removal of the BORG WARNER replacement clutch assemblies.
Plaintiff was present when others installed BORG WARNER replacement clutch assemblies.
Plaintiff removed and installed gaskets in WISCONSIN portable engines. Plaintiff recalls that
Francisco Cacho, address presently unknown, owned Inter-Island Construction Corporation.
Plaintiff recalls the following co-workers: John Magat, (supervisor), address presently
unknown; Francisco Gallardo, address unknown; Arsenio Melendes, address presently
unknown, Rolando Melendes, address presently unknown, Mr. Mendoza, address presently
unknown. Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
E. E. Black, Ltd. E. E. Black, Ltd. Heavy 3/17/64-9/5/65
Honolulu, HI The Dole Project Equi ment

General Santos Island, lechanic

Cotabato, Philippines

Job Duties: Plaintiff worked as a heavy equipment mechanic. Plaintiff performed repair and
maintenance work on bulldozers, cranes, loaders/backhoes, mixer trucks, dump trucks and
small engines. Plaintiff was present when others performed clutch work on CATERPILLAR
bulldozers. Plaintiff removed and replaced clutches on JOHN DEERE loaders/backhoes and
saw others perform the same work. Plaintiff re-lined brake shoes with BENDIX
(ONEY WELL INTERNATIONAL, INC.) brake linings. Plaintiff filed and sanded the

ENDIX (HONEY WELL INTERNATIONAL, INC.) replacement brake linings. Plaintiff
removed and installed CUMMINS engine gaskets on dump trucks. Plaintiff was present when
others performed brake work on GMC and REO (DIAMOND REO TRUCKS, INC.) mixer
trucks, Plaintiff removed BORG WARNER clutch assemblies. Plaintiff used compressed air
to clean out the clutch areas. Plaintiff sanded and roughed up the BORG WARNE

deja sens plAAL-opsc on 2 toeco ON DA BR WD

yen wy NY YK NW Boe ee
2 UF FESREBSERBRARAEBSRES

replacement clutches prior to installation. Plaintiff recalls generators and compressors
manufactured by ALLIS-CHALMERS. Plaintiff recalls the following co-workers: Mr.
Mendoza, Philippines; Francisco Gallardo, address unknown, Caesar Mediaoch, (supervisor),
address unknown. Plaintiff currently contends he was exposed to asbestos during this

employment.

Location of Exposure
Employer Exposure Job Title Dates
Kurt Siebert Arguello Shell Gas Station 10/1967-6/1968
Arguello Shell 3900 California Street Attendant
3900 California Street San Francisco, CA

San Francisco, CA

Job Duties: Plaintiff worked as a gas station attendant. Plaintiff changed oil and pumped gas.
Plaintiff performed brake checks. Plaintiff worked in close proximity to mechanics performing
brake work on FORD, GENERAL MOTORS and CHRYSLER vehicles, Plaintiff was present
when BENDIX (HONEY WELL INTERNATIONAL, INC.) replacement brake assemblies were
sanded, filed and installed, Plaintiff recalls the following co-worker: John Savory, San
Francisco, California. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of . Exposure
Employer Exposure ob Tit) Dates

US Navy Naval Training Center Trainee 5/6/68-7/18/68
San Diego, C.

BRISTER (DER-327), Fireman 8/12/68-9/12/68
Pearl Harbor Naval
Shipyard, Honolulu, HT

VANCE (DER-387), Boiler Tender —_ 9/12/68-9/1969
Pearl Harbor Naval
Shipyard, Honolulu, HI

VANCE (DER-387),
Naval Repair Facility
Sasebo, Japan

VANCE (DER-387),
Mare Island Naval
Shipyard, Vallejo, CA

SAINTPAUL (CA-73) Boiler Tender —_10/10/69-2/2/70,
Naval Repair Facility for approx. 4
North Island months

San Diego, CA

Job Duties: Plaintiff joined the Navy in 1968. Plaintiff served as a fireman and boiler tender.
Plaintiff was responsible for general maintenance and upkeep of the boilers, pumps, valves,
steam traps and forced draft blowers in the fire and boiler rooms.

Plaintiff recalls first serving on board the BRISTER (DER-327), Plaintiff boarded the
BRISTER (DER-327) at Pearl Harbor Naval Shipyard, Honolulu, Hawaii. Plaintiff recalls
sailing to the Naval Repair Facility, Sasebo, Japan and to Vietnam while on board the VANCE

KAInjured\O9S0S\pLAAT-supeseS.wwpd 3 begoO ADH Bw He

boN PW RP YP YN YM DW — —_
ey Aw RDN SF FS CREURZRTEBDHE TS

(DER-387). On board the VANCE (DER-387), plaintiff inspected and cleaned boiler tubes as
necessary. Plaintiff recalls cleaning the bilges and removing asbestos insulation from piping in
the fireroom while on the VANCE. Plaintiff was present when others worked on FAIRBANKS
MORSE (COLTEC INDUSTRIES, INC.) engines aboard the BRISTER and VANCE. On
board the VANCE, plaintiff recalls the installation of VICTOR (DANA CORPORATION)
gaskets. Plaintiff recalls that this ship ended up at Mare Island Naval Shipyard, Vallejo,
California, in preparation for decommissioning.

Plaintiff recalls being flown to Naval Repair Facility, North Island, San Diego,
California, where he boarded the SAINT PAUL (CA-73). While on board this vessel, plaintiff
performed clean up duties for approximately four months while waiting for his discharge
orders, Throughout his service, plaintiff recalls working with the following servicemen:
Olynger (First Class Petty Officer), Keller, Koonz (First Class Petty Officer), and Fulton, but is
currently unable to recall any first names. Plaintiff currently contends he was exposed to
asbestos during this military service.

Location of Exposure
Employer Exposure Job Title Dates
Clifford F. Andrews Cliff Andrews Shell Gas Station 10/1969-3/1970
Cliff Andrews Shell San Francisco, CA Attendant

318 S. Livermore
Livermore, CA

Job Duties; Plaintiff worked as a gas station attendant, Plaintiff changed oil and pumped gas.
Plaintiff performed brake checks, Plaintiff worked in close proximity to mechanics performing
brake work. Plaintiff was present when BENDIX (HONE ILL INTERNATIONAL, INC.)
replacement brake assemblies were sanded, filed and installed. Plaintiff cleaned and swept up
the shop. Plaintiff recalls the following co-workers: John Savory, San Francisco, California,
Plaintiff recalls for following coworker: Danillo Salonga, San Francisco, California, Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of . Exposure
Employer Exposure tle Dates
Don & John Batbie Sunset Scavenger Co. Lube Man 7/1970-6/1972

Lube-Rite, 36 Gorham Street, San Francisco, CA
San Francisco, CA, later
known as:

Lube-Rite Inc. : 1/1972-9/1973
216 Baden Avenue
So, San Francisco, CA

Job Duties: Plaintiff worked out of Teamsters Local 665, San Francisco, Califomia, as a ‘lube
man’ for a mobile lubrication company that serviced utility and garbage trucks, such as WHITE
(TUBE CITY IMS CORPORATION) garbage trucks. The WHITE garbage trucks had HEIL
compactors. Plaintiff performed his work at Sunset Scavenger Co. in San Francisco, California.
Plaintiff checked oi! and changed oil filters. Plaintiff was present when others performed brake
work, including the removal and replacement of brake assemblies, Plaintiff was present when
others cleaned out the brake areas with compressed air. Plaintiff saw boxes of BENDIX
(HONEYWELL INTERNATIONAL, INC.) replacement brakes. Plaintiff recalls the following
co-workers: Gary, last name unknown and address currently unknown; Mr. Bautista, fist name
unknown and address currently unknown. Plaintiff recalls that the owner of Sunset Scavenger
Co. was Leonardo Steffanelli, address currently unknown. Plaintiff currently contends he was
exposed to asbestos during this employment.

KAtnjuredMO9S0S\pLOAL-supsac3. wpa 4 begwon AH FF wD YE

yboeN YR YY NR KR HK HD ot
&® 8a G 8 8R PTS Fe AaR DESERTS

Location of Exposure

Employer Exposure Job Title Dates

Burlingame Country Club Burlingame Country Club, Bus Boy 7/1970-9/1970,

80 New Place Roa 80 New Place Roa TAIT-12/1971;

Hillsborough, CA Hillsborough, CA 411973-6/1973
(part time)

Job Duties: Plaintiff worked summers as a bus boy. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.

Location of Exposure
Em T Exposure Job Title Dates
California Hyatt Corp. Hyatt, Embarcadero, CA = Handyman 4/1973-6/1973
200 W. Madison
Chicago, IL

Job Duties: Plaintiff worked as a maintenance/handy man. Plaintiff is currently unaware if he
was exposed to asbestos during this employment.

Location of © Exposure
Employer Exposure Job Title Dates
Alltrans Express USA, Inc. _Alltrans Express USA, Inc., Lube Man 7/1973-9/1974

10407 Centurion Pkwy N. San Francisco, CA
Jacksonville, FL

Job Duties: Plaintiff worked as a utility man for trucking company. Plaintiff refueled vehicles
and changed flat tires. Plaintiff was present when others performed brake and clutch work on
truck tractors. Plaintiff recalls truck tractors manufactured by KENWORTH (PACCAR INC,),
PETERBILT (PACCAR INC.) and FREIGHTLINER (DAIMLER TRUCKS NORTH
AMERICA LLC). Plaintiff was Rresent when mechanics removed and replaced brakes on
KENWORTH (PACCAR INC.), PETERBILT (PACCAR INC.) and FREIGHTLINER
(DAIMLER TRUCKS NORTH AMERICA LLC) trucks. Plaintiff washed the wheels on
KENWORTH (PACCAR INC.), PETERBILT (PACCAR INC.) and FREIGHTLINER
(DAIMLER TRUCKS NORTH AMERICA LLC) trucks prior to mechanics replacing the
brakes. Plaintiff recalls changing tires on UTILITY tractors and was present and working
around others performing brake work on UTILITY tractors, Plaintiffrecalls furniture trucks
manufactured by FORD. Plaintiff saw mechanics perform brake, clutch and engine gasket work
on the FORD trucks. Plaintiff recalls that the mechanics installed BENDIX (HONEY W ELL
INTERNATIONAL, INC.) replacement brakes. Plaintiff saw the mechanics sand the BENDIX
(HONEY.WELL INTERNATIONAL, INC.) replacement brakes prior to installation. Plaintiff
recalls the following co-workers: Mr. Reed, first name unknown and address currently
unknown, member of Machinist Union Local 1505; Mr. Samson, first name unknown and
address currently unknown, member of Machinist Union Local 1505. Plaintiff currently
contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
F J Burns Draying F J Bums Draying Lube Man 711973-9/1973
640 Cesar Chavez 640 Cesar Chavez
San Francisco, CA San Francisco, CA

KAtnjured\09S0SipldVAL-supsac3.wpd 5 eg.Job Duties: Plaintiff worked as a lube man aka utility man. Plaintiff worked on various large
tractor and trailers. Plaintiff does not recall the names of any supervisors or coworkers.

Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure lob Title Dates
Thompson Container Corp. Thompson Container Corp., Laborer 7/1974-9/1974
Thompson Aerospace Thompson Aerospace,
232 S. Orange Avenue San Francisco, C.
Brea, CA
Job Duties: Plaintiff worked for an aircraft tire manufacturer. Plaintiff is currently unaware if
he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Sea Land Port of Oakland, Utility man 10/1974-1979
aka S L Service, Inc., Oakland, CA
131 Matthews Station Street,
Matthews, NC

Job Duties: Plaintiff worked out of Teamsters Local 78, Oakland, California, as a utility man
for the Port of Oakland. Plaintiff's main duty was to use a forklift to transport containers from
one end of the yard to the other, Plaintiff changed tires on the UTILITY and FRUEHAUF
(HAYES LEMMERZ) trailers as needed. When changing a tire, plaintiff would remove the
wheel from the trailer and use compressed air to clean out the dust that had accumulated.
Plaintiff worked in close proximity to mechanics who removed and installed brakes on
FREIGHTLINER ER TRUCKS NORTH AMERICA LLC ), PETERBILT,
INTERNATIONAL, and WHITE (TUBE CITY IMS CORPORATION) tractors, and UTILITY
and FRUEHAUF “(HAYES LEMMERZ) trailers. Plaintiff saw clutch assemblies removed and
installed. Plaintiff saw CUMMINS gaskets removed. Plaintiff recalls handling BENDIX
(HONEYWELL INTERNATIONAL) brake shoe assemblies that had been removed and placed
on Pallets Plaintiff recalls the following co-workers: Sunny Wilcome, San Leandro,
California; Johnny Moore, Oakland, California; Mitchell Cuomo, Richmond, California; Joe
Lewis, Oakland, Californ