On July 01, 2008 a Motion-Secondary was filed involving a dispute between Alexander, Rufus, and Actuant Corporation, All Asbestos Defendants, American Honda Motor Co., Inc., Arvinmeritor, Inc., Erroneously Sued Herein As The, Asbestos Defendants, Bmw North America, Llc, Bmw Of North America, Llc, Bmw Of North America,Llc From The Third Cause Of, Borg-Warner Corp. By Its Sii Borgwarner Morse Tec, Bridgestone Firestone North American Tire, Llc,, Carlisle Corporation, Caterpillar Inc., Clark Equipment Company, Cummins Engine Company, Dana Companies, Llc (Erroneously Sued As Dana, Deere & Company, Designated Defense Counsel, Does 1-8500, Fiat Usa, Inc., Ford Motor Company, Gatke Corporation, A Bankrupt, Defunct, Dissolved, General Motors Corporation, Hennessy Industries, Inc., Honeywell International Inc., Lear Siegler Diversified Holdings Corp., Mack Trucks, Inc., Maremont Corporation, Nacco Materials Handling Group, Inc., Navistar, Inc., Formerly Known As International, Nissan Forklift Corporation, Nissan Motor Co., Ltd., Nissan North America, Inc., North America And Nissan Technical Center North, Plant Insulation Company, Pneumo Abex Llc Successor In Interest To Abex, The Budd Co., Toyota Motors Sales, U.S.A., Inc., for ASBESTOS in the District Court of San Francisco County.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
San Francisco, CA 94111 Gordon & Rees LLP Embareadero Center West 278 Battery Street, Suite 2000 15 MICHAEL J, PIETRYKOWSKI (SBN: 118677) JOHN F. HUGHES (SBN: 111638) CHRISTOPHER D. STRUNK (SBN: 214110) ELECTRONICALLY GORDON & REFS LLP FILED Embarcadero Center West Superior Court of California, 275 Battery Strect, Twentieth Floor County of San Francisco San Francisco, CA 94111 NOV 10 2010 Telephone: (415) 986-5900 Facsimile: (415) 986-8054 or rhe our Deputy Clerk Attorneys for Defendant THE BUDD COMPANY SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO RUFUS ALEXANDER, CASE NO, CGC-08-274719 DECLARATION OF CHRISTOPHER D. STRUNK IN SUPPORT OF THE BUDD COMPANY’S NOTICE OF MOTION AND MOTION TO EXCLUDE TESTIMONY, DECLARATION, OR PARTICIPATION OF PLAINTIFF RUFUS ALEXANDER AT TRIAL AND REQUEST FOR TERMINATING SANCTIONS IN Plaintiff, ASBESTOS DEFENDANTS (BP) Defendants. CONTEMPT Date: November 18, 2010 Time: 9:30 a.m. Dept.: 220 Judge: Hon. Hon. Harold E. Kahn Trial Date: None set el i Net! Nl! Se St! Nt tt! Sat at” Sr! 1, Christopher D. Strunk, hereby declare: 1. Tam an attorney duly licensed to practice before the courts of the State of California. I am an associate practicing with Gordon & Rees LLP, attorneys of record for defendant THE BUDD COMPANY (“BUDD”). The facts stated herein are true of my own personal knowledge except those matters stated on information and belief, and, as to those matters, | believe them to be true. If called as a witness, J could and would competently testify to -l- DECLARATION OF CHRISTOPHER STRUNK IN SUPPORT OF MOTION TO EXCLUDEUB wk a Gordon & Rees LLP Embarcadere Ceater West 275 Battery Street, Suite 2000 San Francisco, CA S411 28 EVI Gigs Loneeasanry | the same. 2. I personally attended plaintiff's deposition on October 18, 2010. A true and correct copy of the transcript is not available, but | will provide it as soon as it becomes available. Plaintiff, however, did not attend his Court-mandated deposition, and efforts to contact him around 10:00 am on the date of his deposition via two telephone numbers revealed that those numbers were no longer in service. 1 personally telephoned Berry & Berry at about 10:30 am on October 18, 2010, and in a discussion with Evanthia Spanos, it was communicated to me that Berry & Berry received no communications from plaintiff indicating he was unable to attend the deposition, 1 made a statement on the record was made at approximately 10:35 am. I declare under penalty of perjury ander the laws of the State of California that the foregoing is true and correct. » “ Executed on October 21, 2010 at San Francisco, Calif fornia, . 4 CHRISTOPHER D.STRUN -2- DECLARATION OF CHRISTOPHER STRUNK IN SUPPORT OF EX PARTE