Motion-Secondary: RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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                                Becherer
Kannett &
Schweitzer

1285
Powel St
Emeryille, CA
94608

510-658-3600

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Mark S. Kannett (SBN 104572)
Shahrad Milanfar (SBN 201126)

Jennifer K. Thai (SBN 258612) ELECTRONICALLY
BECHERER KANNETT & SCHWEITZER FILED
1255 Powell Street Superior Court of California,
Emeryville, CA 94608 Orne,
Telephone: (510) 658-3600 County of San Francisco
Facsimile: (510) 658-1151 SEP 21 2010

Clerk of the Court

BY: JUDITH NUNEZ

Attorneys for Defendant Deputy Clerk

Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
CASE NO. CGC-08-274719
RUFUS ALEXANDER,
Plaintiff,

DECLARATION OF JENNIFER K. THAI IN
SUPPORT OF MOTION BY
BRIDGESTONE FIRESTONE NORTH
AMERICAN TIRE, LLC, TO COMPEL
DISCOVERY RESPONSES, AND FOR
MONETARY SANCTIONS AND
TERMINATING SANCTIONS

VS:
ASBESTOS DEFENDANTS (B*P), et al.,

Defendants.
Date: Nov. 18, 2010

Time: 1:30 p.m.
Dept.: 220
Judge Hon. Harold E. Kahn

Complaint Filed: July 1, 2008
Trial Date: Not assigned

te

I, Jennifer K. Thai, do declare as follows:

1. I am an attorney at law duly admitted to practice before all the courts of the
State of California and am an associate at Becherer, Kannett & Schweitzer, attorneys of
record for defendant Bridgestone Firestone North American Tire, LLC (hereinafter
“Bridgestone”), herein. I have personal knowledge of the following facts and could, if called,
testify competently thereto.

2. Attached hereto as Exhibit A is a true and correct copy of the court order

relieving Brayton Purcell as counsel for Plaintiff on October 30, 2009. During his deposition

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC,ee

in June 2009, while he was still represented by counsel, Plaintiff did not identify

2 Bridgestone. Plaintiff admitted that he had never heard of Worldbestos brakes and had no
8 recollection of removing or installing Worldbestos brand brakes. Plaintiff has not provided
4 anything else to suggest a relationship between Bridgestone and Plaintiffs alleged disease.
S 3. Attached hereto as Exhibit B is a true and correct copy of the First Set of
6 Special Interrogatories to Plaintiff by Defendant Bridgestone Firestone North American
7 Tire, LLC, served on Plaintiff on November 20, 2009.
8 4, Attached hereto as Exhibit C is a true and correct copy of the First Set of
9 Requests for Production of Documents to Plaintiff by Defendant Bridgestone Firestone
10 North American Tire, LLC, served on Plaintiff on November 20, 2009.
it 5. Attached hereto as Exhibit D is a true and correct copy of the First Set of
‘12 Requests for Admission to Plaintiff by Defendant Bridgestone Firestone North American
13 || Tire, LLC, served on Plaintiff on November 20, 2009.
14 6. On January-7, 2010, I sent Plaintiff a letter informing Plaintiff that his
15 | responses were due on December 28, 2009 and that I would give him an extension until
16 | January 21, 2010 to provide responses. Attached hereto as Exhibit E is a true and correct
17 || copy of my letter to Plaintiff, dated January 7, 2010.
18 7. On January 25, 2010 I spoke to Plaintiff telephonically regarding the missing
19 | discovery responses. Plaintiff informed me that he was in the process of obtaining counsel
20 | to assist him in preparing responses to Bridgestone’s requests. I agreed to extend the
21 | deadline for his responses from January 21, 2009 to February 10, 2010. Plaintiff assured
22 || me that he would contact her if he was unable to respond by this deadline.
23 8. On February 11, 2010 Bridgestone’s counsel sent a letter to Plaintiff
Rane 24 | reminding him of the January 25, 2010 telephone conversation and requesting that Plaintiff

Schweitzer

25 contact her or provide verified responses by February 19, 2010. Attached hereto as Exhibit

Powell SL 96 | Fisa true and correct copy of my letter to Plaintiff, dated February 11, 2010.
TSS 9. On February 16, 2010 Plaintiff called me to inform me that he was still in the

2g | process of contacting firms to assist him with Bridgestone’s discovery requests. As a

2

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC,courtesy, I agreed to grant a third extension on Plaintiffs discovery responses to March 3,
2010. J also instructed Plaintiff to inform me if he was unable to respond by this time. This
telephonic conversation was confirmed in my February 16, 2010 letter to Plaintiff. In the
February 16" letter Bridgestone’s counsel also warned Plaintiff that if he did not respond to
Bridgestone’s discovery requests by March 3, 2010, that Bridgestone will have no choice but
to file a motion to compel his responses. Attached hereto as Exhibit G is a true and correct
copy of my letter to Plaintiff, dated February 16, 2010.

10. On March 4, 2010 J sent another letter informing Plaintiff that Bridgestone

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had yet to receive his responses and requesting he provide responses by March 11, 2010.
Attached hereto as Exhibit H is a true and correct copy of my letter to Plaintiff, dated March
1} 4,2010.

12 11, On March 5, 2010 Plaintiff informed me via telephone that he was mailing his
13 responses to Bridgestone’s questions.

4 12. On March 9, 2010, I received-Piaintiffs mailing. However, it did not contain
15 | responses to Bridgestone’s discovery requests. Rather it contained Bridgestone’s counsel’s
16 || letter of March 4, 2010 and discovery requests from another defendant in this case.

7 | Attached hereto as Exhibit | is a true and correct copy of Plaintiffs mailing.

8 13. On March 12, 20101 sent a letter to Plaintiff informing him that I had received
19 | his letter but that it did not contain answers to Bridgestone’s questions. I attached the three
20 || sets of the discovery requests which Bridgestone had originally sent on November 20, 2009
21 | and instructed Plaintiff to provide answers to these questions by March 24, 2010. [also

22 | included verifications to go with his responses for each of the sets of questions, informing
23 | Plaintiff that signing them meant that he was “declaring under oath or upon penalty of

Becher: 24 || perjury” that his answers to each of the three sets of questions are true. | further requested
it - ,
Schweltzer 25 | that he provide the documents that he identifies in his answers to Bridgestone’s Request for

155

Powell St 26 | Production of Documents by March 24, 2010. I cautioned that if he did not respond to all

Frmeryville, CA

27 || three sets of questions by March 24, 2010 that I would be forced to file a motion to compel

3

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC,we

Plaintiffs answers by March 30, 2010. Attached hereto as Exhibit J is a true and correct

2 copy of my letter to Plaintiff, dated March 12, 2010.
$ 14. OnMarch 15, 2010 Plaintiff called me to inform me that his papers were
4 destroyed two years ago when his house burned down. He then stated that his papers were
5 with prospective attorneys. J asked Plaintiff to answer the questions to the best of his
6 knowledge. | also clarified what the verifications were. Plaintiff stated that he understood
7 and would provide answers on a separate paper.
8 15. On March 18, 2010 Plaintiff called me to inform me that he had sent
9 everything. ,
10 16. On March 19, 2010 I received Plaintiffs mailing, which consisted of Plaintiffs
11 || standard Asbestos Case Interrogatories which Brayton Purcell had assisted him in drafting
12 | in August of 2008 with some notations in the margins that were inapplicable to Bridgestone.
13 | The mailing also included verification pages Bridgestone’s counsel had sent in the March 15,
14 | 2010 letter, which Plaintiff signed. He also enclosed an appointrvent notification and an
15 | examination request from Discovery Diagnostics, Inc. for May of 2009 for chest x-rays, and a
16 || printout from the Mesothelioma Resource Center. Attached hereto as Exhibit K is a true
17 | and correct copy of Plaintiffs mailing.
18 17. OnApril 6, 2010, Plaintiff left me messages telephonically to check if ] had
19 || received the documents and to find out what more he needed to do.
20 18. On April 9, 2010, I returned Plaintiff's phone call to inform him that what he
21 | sent was nonresponsive. Plaintiff stated he would call me back to discuss further. He never
22 | did.
23 19. This Court, at a case management conference on April 29, 2010, ordered a

Becher, 24 discovery stay as to motions to compel further responses to any written discovery until the
Schweitze +
enwewer 25 | next case management conference on August 4, 2010. The Court ordered defendants with

35
Powell St 26 || outstanding discovery to re-send written discovery requests. Plaintiff was ordered to

Emeryville, CA
94608

smases69 7 | respond by June 30, 2010. Attached hereto as Exhibit L is a true and correct copy of the

2g || court’s order.

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DECLARATION OF JENNIFER K. THAI IN SUPPORT OF MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC,1
20. On May 17, 2010, Bridgestone re-sent its discovery requests to Plaintiff and
2
gave Plaintiff two additional days past the court ordered response time to July 2, 2010.
3
Attached hereto as Exhibit M is a true and correct copy of my letter to Plaintiff, dated May
4 17, 2010.
5 21. Bridgestone never received any responses from Plaintiff on or after July 2,
© | 2010.
7 22. Bridgestone sent another letter to Plaintiff on August 6, 2010, requesting that
8 | plaintitt provide responses by August 20, 2010. Plaintiff did not respond to this letter.
9 | Attached hereto as Exhibit N is a true and correct copy of my letter to Plaintiff, dated
10 | August 6, 2010.
i 23. Bridgestone has not received any responses to its discovery requests to date.
12 1 declare under penalty of perjury under the laws of the State of California that the
13 | foregoing is true and correct and that this declaration is executed on the date undersigned
14 | in Emeryville, California.
15 ‘
Dated: September 21, 2010 &
16 ifér KK. Thai
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Schweitzer
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DECLARATION OF JENNIFER K. THAI JN SUPPORT OF MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC,Exhibit A* 1
MC—053
[ATTORNEY OF PARTY WITHOUT ATTORNEY (Weine, state bar nurnbar, and address): FOR COURT USE ONLY

Nancy T. Williams Esq. (State Bar # 201095)
| Brayton <> Purcell LLP

222 Rush Landing Road j L
Novato, CA 94948-6169

San Francisce County Superior Court
vreverrone no: (415) 898-1555 Fax No. (Optionat:(415) 898-1247 OCT 3 0 2009

EAL ADDRESS (Optenel
artonney Fo namey: Plaintif f(s)

| SuPenion COURT OF CALIFORNIA, GOUNTY OF SAN FRANCISCO G@RDON PAR Ui, Clerk
srreet aopress: 400 McAllister Street BY: Shi cien

MAILING ADDRESS:
cry ano zie cove: San Francisco 94102
RANCH NAME:
CASE NAME: CASE NUMBER
RUFUS ALEXANDER y. ASBESTOS DEFENDANTS (BP) 274719
Hearne oste:October 30, 2009
ORDER GRANTING ATTORNEY'S * errs 301 ve:9:30 a.m.
MOTION TO BE RELIEVED AS COUNSEL—CIVIL arrore non: Peter Busch

onre action rnco: July 1, 2008
wins bare: N/A,

1. The motion of (name of attorney): Nancy T. Williams Esq.
to be relieved as counsel of record for (name of cient): Rufus Alexander, ct al. '
a party to this action or proceeding, came on regulary for hearing at the date, time, and place indicaled above.

2. The following persons were present al the hearing:

Gxnonts, Gaus Ere Bla eugecdy LLP

FINDINGS
3. Atlomey has
a. personally served the client with papers in support of this motion.
b, [x] served client by mait and submitted a declaration establishing that the service requirements of California Rules of Court,
rule 3.1362, have been satisfied.

4, Attorney has shown sufficient reasons why the motion to be relieved as counsel should be granted and why the atlorney has brought
a motion under Code of Civil Procedure section 284(2) instead of filing a consent under section 284(1).

ORDER
5. Atlorngyf relieved as counsel of record for client
a, effective upon the filing of the proof of service of this signed order upon the client.
&” [_] effective on (specify date):

6, Theclien’s [X] current lastknown address and telephone number:
Mr. Rufus Alexander, 170 Cashmere Street, Apt. D, San Francisco, California 94124

If the client's currant address is known, service on the client must hereafter be made at that address unless otherwise ordered in item
13. If the current address is not known, service must be made according to Code of Civil Procedure section 1011 (b) and rule 3.252 of
the California Rules of Court.

7. a. The ne: scheduled hearing in this action or proceeding is set for (date, time, and place):
PT Bee 2009 at 1:30 p.m., San Francisco Superior Court, Dept. 206
b. The hearing will concem (subject matter):Status and Setting Conference

NOTICE TO CLIENT
You or your new attomey, if any, must prepare for and attend this hearing. Page ¥ of 3
Fear pied te Mara Use ORDER GRANTING ATTORNEY'S Gade a Ca Protos. 828
We08S few. Janay 2007, MOTION TO BE RELIEVED AS COUNSEL—CIVIL sere atc go?

LexisNexiy') Automated Colifornia Judicial Council FormsMC~053

CASE NAME: CASE NUMBER:

RUFUS ALEXANDER v. ASBESTOS DEFENDANTS (B<>P) 274719

8. The follawing additional hearings and others proceedings (including discovery matters) are set in this action (describe the date,
lime, place. and subject matier of each):

9. The trial in this action or proceeding:
a, LX | is not yet set.
b. is set for (specify date, time, and place):

10. Client is hereby notified of the following effects this order may have upon parties.

NOTICE TO CLIENT

Your present attorney will no longer be representing youl. You may not in most cases represent yourself if you are
one of the parties on the following list:

+ A guardian = Apersonal representative * A guardian ad Item
+ Aconservator + A probate fiduciary + Anunincorporated association
+ Atrustee + Acorperation

If you are one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL
REPRESENTATION. Failure to retain an attorney may lead to an order striking the pleadings or to the entry of a
default judgment.

44. Client is notified that, if the client will be representing himself or herself, the client shall be solely responsible for the case.

NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
‘You will not have an attorney representing you. You may wish to seek legal assistance. ff you do not have a new
attorney to represent you in this action or proceeding, and you are tegally permitted to do so, you will be
representing yourself. It will be your responsibility to comply with all court rules and applicable laws. If you fail to
do s0, oF fail to appear at hearings, action may be taken against you. You may lose your case.

42. Client is notified that it is the client's duty to keep the court informed at alt umes of the client's currant address.

NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
The court needs to know how to contact you. If you do not keep the court and other parties informed of your current
address and telephone number, they will not be able to send you notices of actions that may affect you, including
actions that may adversely affect your interests or result in your losing the case.

13, The court further orders (specify):

Date: 1ofaef Aq

JUOGF OR JUDICIAL OFFICER.

(PETER J. BuscH

TACOS [Rev Jonwary 17007] ORDER GRANTING ATTORNEY'S Pogn ol
MOTION TO BE RELIEVED AS COUNSEL—CIVIL

LexisNexis®) Automated California Judicial Council FormsExhibit BDo Oe NA HW RY NH

SO
oN A HA F BW N SY Oo

Mark S. Kannett (SBN 104572)

Shahrad Milanfar (SBN 201126)

Jennifer K. Thai (SBN 258612)

BECHERER KANNETT & SCHWEITZER

p256 Powell Street -
me (10) 658-3600

Tel one: -(5 36! —, HON

Telephon (By 0) 658-1151 : let @

Attorneys for Defendant
Bridgestone Firestone North American Tire, LLC,

successor to Bridgestone Firestone, Inc. 8) 4!

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

} CASE NO. GGC-08-274719

RUFUS ALEXANDER,
SPECIAL INTERROGATORIES TO
Plaintiff, PLAINTIFF RUFUS ALEXANDER BY
DEFENDANT BRIDGESTONE
vs. . FIRESTONE NORTH AMERICAN TIRE,
Cc
ASBESTOS DEFENDANTS (BP), etal., .
)
Defendants, . )
)

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, LLC
RESPONDING PARTY: Plaintiff Rufus Alexander -
SET NO.: One (1) ,

: Defendant BFS requests that the responding party,-plaintiff Rufus Alexander
(Plaintiff), answer the following individual set of interrogatories, under oath, within thirty
(30) days, pursuant to California Code of Civil Prosedure §§ 2030.010 through 2030.410.
As used herein, the term “DEFENDANT or BFS’ refers, but is not limited; to Bridgestone
Firestone North American Tire, LLC, Bridgestone / Firestone, Inc., Firestone Tire and
Rubber Company, World Bestos Corporation.

Each answer provided by the responding party must be "as complete and straightforward as

the information reasonably available fo the responding party permits.” Code Civ. Proc. §

-lL- :
BFS’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET-ONEwo oe NH NW RF WYN

See Be Be Be SP Se Pe oe
oN A WH F WN YF SO

2030.220(a). {f an interrogatory cannot be answered completely, the responding party must
answer to the extent possible. Code Civ. Proc, § 2030.220(b).. If the responding party does
not have personal knowledge sufficient to respond fully to an interrogatory, that party shall
so state and shail make a reasonable and good faith effort to obtain the information by
inquiry to other natural persons or organizations, except where the information is equally
available to the propounding party. Code Civ. Proc. § 2030.220(c). Whenever an
interrogatory may be answered by referring fo a document, the document may be attached
as an exhibit to the response and referred to in the response. {f the document has more
than one page, refer to the page.and section where the answer to the interrogatory can be
found. , :
INTERROGATORY NO. 1

If YOU contend that BFS is responsible for any product(s) which caused YOU to be

exposed to asbestos, specifically describe each product by product name, part number and
manufacturer. :

[A number of terms contairied in these interrogatories are typed in capital letters.
When in capital letters, YOU and YOUR means plaintiff, RUFUS ALEXANDER, as well as
anyone acting or purporting to act on their behalf, including, but not limited to, YOUR
agents, YOUR employees, YOUR insurance companies, their agents, their employees,
YOUR attomeys, YOUR accountants, YOUR investigators, and anyone else acting on
YOUR behall_] :
INTERROGATORY NO. 2

If You contend that BFS is responsible for any product(s) which caused YOU to be

exposed to asbestos, please describe in detail the manner in which YOU used each
product.

De :
BFS’ SPECIAL INTERROGATORIES TO PLAINTIEF, SET ONEee a ee
ow eT A A FF WN KF OS

Oo em IN DHA FF WN

INTERROGATORY NO. 3

If YOU contend that YOU were exposed to any asbestos-containing product(s) for
which BFS is responsible, please IDENTIFY any and all DOCUMENTS, which support
YOUR contention. .

[A fumber of terms contained in these interrogatories are typed in capital letters.
When in capital letters, IDENTIFY, when used with respect to a DOCUMENT, means to set
forth a description sufficient to distinguish the individual DOCUMENT from all other
DOCUMENTS. DOCUMENT means a “writing” as defined in California Evidence Code
section 250, and includes the original or a copy of handwriting, typewriting, printing,
photostatting, photographing, and every other means of recording upon any tangible thing
and form of conimunicating or representation, including Jetfers, words, pictures, sounds, or
symbols, or combinations of them.] -
INTERROGATORY NO. 4

If YOU contend that YOU were exposed to any asbestes-containing product(s) for
which BFS is responsible, please IDENTIFY each PERSON YOU believe may have
knowledge of facts supporting YOUR contention.

[A number of terms contained in these interrogatories are typed in capital letters.
When in capital Jetters, PERSON includes a natural person, firm, association, organization,
partnership, business, frust, corporation, and/or public entity: IDENTIFY means, with :
respect to a PERSON, to set forth such PERSON'’s full name, last known address, including
city, state, zip code, and last known telephone number-]

INTERROGATORY NO. & :

If YOU contend that YOU purchased, for private use, any asbestos-containing
product(s) for which BFS is responsible, please describe each purchase by identifying the
product(s) purchased; the seller, the seller's street address and location, and the date of

each such purchase.

. 3+
BES’ SPECIAL INTERROGATORIES TO PLAINTIEF, SET ONECo ew NH A FF WN

Soe Be Be om ee
oN DH RF YN SK O

INTERROGATORY NO. 6

If YOU contend that YOU ever purchased, for private use, any asbestos-containing
product(s) for which BFS is responsible, please {DENTIFY all DOCUMENTS which support
YOUR contention. :
INTERROGATORY NO. 7

If YOU contend that YOU- ever purchased, for private use, any asbestos-containing
product(s) for which BFS is responsible, please IDENTIFY each PERSON whom YOU
believe may have knowledge of facts which support YOUR contention.

INTERROGATORY NO. 8 ,
If YOU contend that anyone else purchased, for YOUR use, any asbestos-containing

product(s) for which BFS is responsible, please describe each purchase by identifying the
product(s) purchased, the seller, the seller's street address and location, and the date of
each such purchase. :

INTERROGATORY NO. 9

if YOU contend that anyone else ever purchased, for YOUR use, any asbestos-
containing product(s) for which BFS is responsible, please IDENTIFY alt DOCUMENTS
which support YOUR contention. ,
INTERROGATORY NO. 10

If YOU contend that anyone else ever purchased, for YOUR use, any asbestos-
containing product(s) for which BFS is responsible, please IDENTIFY each PERSON whom
YOU believe may have knowledge of facts which support YOUR contention.

DATED: November 20, 2009 BECHERER KANNETT & SCHWEITZER

B Bridgestone Firestone North American Tire, LLC

4 .
BFS’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET ONE _Cwm IN A HA RF WN

eae et
ou DH eh WD YH So

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION \

. ~ {, Barbara Golstein, declare that [ am, and was at the time of service of the
documents herein referred to; over the age of 18 years, and not a party to the action; and |
arn employed in the County of Alameda, State of California. My business address is 1255
Powell Street, Emeryville, California 94608.

On November kD , 2009, | electronically served the document(s) via LexisNexis File
& Serve described as: -

« SPECIAL INTERROGATORIES To PLAINTIFF RUFUS ALEXANDER
BY DEFENDANT BRIDGESTONE FIRESTONE
.NORTH AMERICAN TIRE, LLC

on the recipients designated on the. Transmission Receipt located on the LexisNexis File &
Serve website. :

| declare under penalty of perjury pursuant to the laws of the State of California that,
the foregoing is true and correct and that this declaration was e on November kD,
2009, at Emeryville, California. ;

Barbara Golstein

5.

en
BES’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET ONEwo re KY BH AH FF WY NY

et
ow A A Rk DB HE SD

PROOF OF SERVICE

|,-Barbara Golstein, declare that ! am employed in the County of Alameda, State of
Califomia; | am.over the age of eighteen (18) years and not a party to the within entitled
action; my business address is 1255 Powell Street, Emeryville, California 94608.

On November ab 2009, | caused fo be served the foregoing:

. SPECIAL INTERROGATORIES TO PLAINTIFF RUFUS
ALEXANDER BY DEFENDANT BRIDGESTONE FIRESTONE
NORTH AMERICAN TIRE, LLC

In said action by placing a true copy thereof enclosed in a sealed envelope and served in
the manner andior manners described below to each of the parties herein and addressed as
follows:

Plaintiff, in Pro Per Rufus Alexander
170 Cashmere Sireet, No. D
San Francisco, CA 94124

XI (By Mail) | deposited such envelope with pestage thereon fully prepaid to be placed in
the United States Mail at Emeryvilie, California. | am familiar with the mail collection
practices of Becherer Kannett & Schweitzer Attorneys and pursuant to those practices the
envelope would be deposited with the United States Postal Service the same day.

(By Personal Delivery) | caused such envelope to be delivered by hand to the office of
the addressee(s).

[1 (By Overnight Courier) I caused such envelope to be delivered via overnight courier

-|| service to the addressee(s) designated.

(1 (Via Facsimile) | caused said document{s) to be transmitted to the facsimile number(s)
of the addressee(s) designated.

| declare under penalty of perjury that the preweins § is true and rect and that this
declaration is executed on November AL) fornia

Batbara ‘Golstein’

|
BFS’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET ONEPage 1 of 2

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LexisNexis File & Serve Transaction Receipt

Transaction ID: . 28151504 ° . .
Submitted by: Barbara Golsteln, Becherer Kannett & Schweitzer-Emeryville
_ Authorized by: Jennifer Thai, Becherer Kannatt & Schweltzer-Emeryville
Authorize and file oni Nov 20 2009 10:12AM PST
Court: CA Superior Court County of San Francisco
Division/ Courtroom: N/A
Case Class: Civil
Case Typar Personal Injury-Asbestos ‘
Case Number: 274719
Case Name: Alexander vs Asbestos Defendants (Brayton)
‘Transaction Option: Serve Only - Public.
Billing Reference; BFS/Rufus Alexander
Read Status for e-services: ~ Not Purchased
Documents List
3 Document(s)
Attached Document, 6 Pages Document ID: 25792499 PDE Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00
Document title: .
Requests for Admission to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC -
‘Attached Document, 7 Pages Document ID: 25792542 PDF Format | Original Format
Document Type: . ” Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00
Document title:

Requests for Production of Documents to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire,’
uc

Attached Document, 6 Pages Document ID: 25792959 PDF Format j Oriainal Format
Document Type: Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00

Document title:

Special Interrogatories to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC
Expand All - ,
E1_Sending Parties (1) -

Party pt Attorney Firm Attorney Type
Bridgestone Firestone North American Tire, Defendant Milanfar, “ Becherer Kannett & Schweitzer- Attorney in
LLC (pending) Shahrad Emeryville a Charge
B)_Becipi 18)
E1_Service List (18) . :
“ontert Party Wee Attorney Firm ype Method
Service Alexander, Rufis Plainuff = Pollack, Dean = —s Burnham Brown-Oakland = Attorney EE

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Darnell . Service

Service Alexander, Rufus Plaintiff — Rundin, Walter C Burnham Brown-Oakland Attomey
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Service Alexander, Rufus Plaintiff Gonzales, Susana Burnham Brown-Oakiand Attomey = Eo
Service ArvinMeritor Inc _ Defendant Oberg, Lisa McKenna Long & Aldridge Gone’ in Service
service BA Wof North AMEE! Defendant Ames, Richard NeDoroeh LtP-san cheney ine ice

Francisco
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. INCISCD

Sefvie Carlisle Co Inc Defendant Davidson, Africa E Bassi Edin flule & Blum Atormey in Ee”
Service Chrysler LLC - Defendant Kuenster, Jennifer N20" Peabody LLP-San — Atiomeyim ice
Service Cummins Engine Co Inc Defendant colden, Catherine jackson & Wallace-San aimey in E vice
Service - Pana Co LLC Defendant oe Asbestos ' Brydon Hugo & Parker-San_ aeorey In Eee
. Service eo ac Defendant Glaspy, David —_Glaspy & Glaspy aan’ ne rvice
Service Hennessy Industries Defendant Goetz, Andy J een ere Chae in Scnvice
Service teas Stealer Diversified Defendant’ Keesal, Sarnuel A Keesal ‘Young B Logan-Long Gaus. in E rvlce
Service Mack Tucks Inc Defendant Ostertag, James 3 Nixon Penbody LLP-San ere vice
Servica ee Defendant. Reilley, Mary E Krieg Keller Shoan Rellley & gaa in Scivice
Service Plant Insulation Corp Defendant Travis, Monte S Travis & Pon aay Oe ewica
Service Preumo Abex Uc Defendant sannsel Asbestos Brydon Hugo & Parker-San Greet in Cwice
Service ToYoER Motor Sales perandant Counsel, Asbestos Bryson Hage & Parker-San Atorney in

E}_adaitional Recipients (0)
E1_case Parties

Retupnte My Bleck Semves.s}

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none 7. co. - wera ner rok aa bom toua tt nninnnanExhibit C_

Ce A AM hk WN

eee
Soe U aA AR GE ES

Mark S. Kannett (SBN 104572)

Shahrad Milanfar (SBN 201126)

Jennifer K. Thai (SBN 258612) - .
BECHERER KANNETT & SCHWEITZER
1255 Powell Street

Emeryville, CA 94608 .
Telephone: (510) 658-3600 1
Facsimile: (510) 658-1151

Attomeys for Defendant
Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

: . CASE NO. CGC-08-274719
RUFUS ALEXANDER,
: Plaintiff,

REQUESTS FOR PRODUCTION OF
DOCUMENTS TO PLAINTIFF RUFUS
ALEXANDER BY DEFENDANT
BRIDGESTONE FIRESTONE NORTH
AMERICAN TIRE, LLC

vs.
ASBESTOS DEFENDANTS (B«P}, et al.,
Defendants.

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, LLC
RESPONDING PARTY: _ Plaintiff Rufus Alexander ,
SET NO.: One (1)

Pursuant to the provisions of Code of Cjvil Procedure § 2031.010, et seq., Plaintiff Rufus

Alexander is hereby requested to identify and produce for inspection and copying at the law

offices of Becherer Kannett & Schweitzer, 1255 Powell Street, Emeryville, Califomia, 94608,
the following tangible. things or writings (as that term is defined by Evidence Code § 250)
within Plaintiffs possession, custody and/or control. True and correct copies of the

documents described herein with an appropriate verification to the authenticity will be

-l- - :
BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEeo oe NA A fF WN

eo a
An nF BN SF OD

Becherer
Kanneft &
Schweitzer 28

1255
Powall Sf.
Emeryville, CA
4608

540-658-3500

accepted in lieu of the original documents. With respect to photographs, color laser copies
will be accepted | in lieu of the original photographs. :

Pursuant to the provisions of Code of Civil Procedure § 2031.060, if you object to the
production of any document or category of document, you must identify with particularity any
document being withheld from production, and set forth clearly the extent of, and the
specific grounds for, the objection. ,

lf written response is not served in compliance with the time fimit set forth in Code of
Civil Procedure Section 2031.290, all objections will be deemed waived.

DEFINITIONS

4. As used in this request, the term "DOCUMENT(S)" means any tangible object
which displays, records, or contains a “writing” within the meaning of California Evidence
Code §250, and includes, without being limited thereto, sales receipts, invoices, purchase
orders, warning labels, deposition transcripts, brochures, policies, procedure manuals, order
forms, pay stubs, work logs, and daily time books or diaries. Evidence Code §250 provides:
“Weiting’ m means handwriting, typewrifing, printing, photostating, photographing, and every
other means of recording upon any tangible thing any form of communication or
representation, including letters, words, pictures, sounds or symbols, or combinations
thereof.”

2. “YOU" and “YOUR’ refers to each Responding Party, all agenis, all attorneys, and
anyone acting on behalf of each Responding Party,

3.. When the context so requires, reference to the masculine gender includes the ~~
feminine and neuter, the feminine gender includes-the masculine and neuter, the singular
includes the plural, and the plural includes the singular.

“4. As used herein, the term “DEFENDANT” refers, but is not limited, fo Bridgestone
Firestone North American Tire, LLC, Bridgestone 1 Firestone, Inc., Firestone Tire and :

Rubber Company, World Bestos Corporation.

2-
FS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEwm me NNR RF WYN

Boe ee ee ee
mardnnw ££ we fF

20
21

26

5. As used herein, the term “ASBESTOS-CONTAINING PRODUCTS” means any
product that contains, or that you allege contains, any amount of the mineral asbestos,
including but not limited to, all law asbestos, vermiculite, amosite, trimolite, and chrysotile
and crocidilite. . ,

6. “PERSON” as used herein refers to any individual, partnership, firm, association,
corporation or other government, business or legal entity. :

7. As-used herein, the term “MEDICAL TREATMENT FACILITY” means hospitals,
dispensaries, laboratories, optometry clinics, psychological clinics, clinics of all other kinds,
mental institutions, radiology laboratories, pathology laboratories, rest homes, sanitariums,
convalescent homes, and all other institutions, organizations and facilities wherein are
practiced the healing arts.

8. As used herein, the term “MEDICAL PRACTITIONER” refers fo all physicians,
osteopaths, dentists, chiropractors, nurses, psychiatrists, psychologists, optometrists,
physical therapists, and all other persons practicing, or purporting to practice, the healing
aris_

DOCUMENTS TO BE PRODUCED
1. All DOCUMENTS described or identified by YOU in YOUR response to
EFENDANT'S Special Interrogatories, Set No. 1, if any.
2, All DOCUMENTS not previously identified and produced evidencing, relating to, or

conceming, any relationship of any kind between DEFENDANT and the persons claimed to
have incurred an asbestos-related injury in this action.

3. All DOCUMENTS supporting the amount of YOUR damages, including, but not
limited to, employment records, invoices, bills, work fogs or daily work diaries, household
expenses, and medical records from any MEDICAL TREATMENT FACILITY, medical
records from any MEDICAL PRACTITIONER and any medical bills.

4. All DOCUMENTS concerning oF reflecting any and all settlement reached with
other defendants in this lawsuit or any other fawsuits involving in which it was alleged that a

person or persons were exposed to asbestos or asbestos-containing products,

Be
‘BES’ REQUESTS FOR PRODUCTION TO PLAINTIEF, SET ONEOo wm NAH A YN

Soe
Aa ee BRE

5. All personal and/or work diaries kept by YOU at any time.

6. All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU were exposed fo asbestos-containing products suppiod by this
propounding DEFENDANT.

7. Alt DOCUMENTS representing, recording, referring or relating to YOUR
allegations that You came into physical contact with asbestos-containing products supplied
by this propounding DEFENDANT.

8. Ali DOCUMENTS representing,-recording, referring or relating to YOUR
allegations that YOU were in the vicinity of others working with asbestos-containing
products supplied by this propounding DEFENDANT. :

3. All DOCUMENTS representing, recording, referring or relating to YOUR :
allegations that YOU were exposed to asbestos-containing products supplied by this
propounding DEFENDANT. :

40. All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU came into physical contact with asbestos-containing products supplied
by this propounding DEFENDANT,

11. Al[ DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU were in the vicinity of others working with asbestos-containing
products supplied by this propounding DEFENDANT.

“42, All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU were exposed to asbestos-containing products sold by this
propounding DEFENDANT.

43. All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU came into physical contact with asbestos-containing products sold by
this propounding DEFENDANT. :

44. All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU were in the vicinity of others working with asbestos-containing
products sold by this propounding DEFENDANT.

‘ Ae
FS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEeC em ND mh PR Ww NY

See om eB Oe es Se es
oe N DA UA FY NY SK GS

15. Each and every box, package, container or carton in YOUR possession which
bears the trade name, logo, or trademark of the asbestos-containing products
manufactured, supplied, or sold by this propounding DEFENDANT, to which YOU claim

[YOU were exposed.

16. Allstatements, however recorded, of witnesses taken by YOU, YOUR attomeys
or investigators working for YOUR attomeys, or other agents, for which no privilege or claim
of work product is asserted.

. 47. Any and all DOCUMENTS reldted to any claims YOU ever made for any
asbestos-related injuries, which claims were made before or after this lawsuit.

18. Any and all DOCUMENTS relating to any payments requested or received from
the Johns-Manville Trust. : ,

149. Any and all DOCUMENTS related to any claims YOU ever made to any
Bankruptcy Trust based on any asbestos-related injuries, which claims were made before or
after this lawsuit,

20. Any and all DOCUMENTS relating to any payments requested or received from
any Bankruptcy Trust by YOU for any asbestos-related injury(ies).

24. Any and all DOCUMENTS that support or contradict YOUR responses fo each

Request for Admissions.

DATED: November “20, 2009 BEGCHERER KANNETT & SCHWEITZER
ee K. Thai

‘Attorreys’ for Defendant

Bridgestone Firestone North American Tire, LLC

5 -
BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONECoord aunr Bw NH

eos Ss
wn == &

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION

1, Barbara Golstein, declare that | am, and was at the time of service of the
documents herein referred to, over the age of 18 years, and not a party to the action; and |
am employed in the County of Alameda, State of Califomia. My business address is 1255
Powell Street, Emeryville, California 94608. :

On November 2 , 2009, | electronically served the document(s) via LexisNexis File
& Serve described as:

« REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF
RUFUS ALEXANDER BY DEFENDANT BRIDGESTONE FIRESTONE

NORTH AMERICAN TIRE, LLC

on the recipients designated on the Transmission Receipt located on the LexisNexis File &
Serve website. : :

| déclare under penalty of perjury pursuant to the laws of the Stafe of California that,
the foregoing is true and correct and that this declaration was oxeculgs on November
2009, at Emeryville, Califomia. : r

bara Golstein

6-
BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEoe SM DR WH HR WN

esas
ce KN Hk BW HY FEF S

Powell SL
Emeryiille, CA
94608
Si0-B58-S6n0

PROOF OF SERVICE

1, Barbara Golstein, declare that | am employed in the County of Alameda, State of
California; | am over the age of eighteen (18) years and not a party to the within entitled
action; my business address is 1255 Powell Street, Emeryville, Califomia 94608.

On November hb, 2009, 1 caused fo be served the foregoing:

° REQUESTS FOR PRODUCTION OF DOCUMENTS TO
PLAINTIFF RUFUS ALEXANDER BY DEFENDANT BRIDGESTONE
FIRESTONE NORTH AMERICAN TIRE, LLC

In-said action by placing a true copy thereof enclosed in a sealed envelope and served in
the manner and/or manners described below to each of the parties herein and addressed as
follows:

Plaintiff, In Pro Per Rufus Alexander
170 Cashmere Street, No. D
San Francisco, CA 94124

KI (By Mail) I deposited such envelope with postage thereon fully prepaid to be placed in
the United States Mail at Emeryville, Califomia. 1 am familiar with the mail collection
practices of Becherer Kannett & Schweitzer Attorneys and pursuant to those practices the
envelope would be deposited with the United States Postal Service. the sarne day.

(J (By Personal Delivery) | caused such envelope to be delivered by hand to the office of
the addressee(s).

oO (By Overnight Courier) | caused such envelope to be delivered via ovemight courier
service to the addressee(s) designated. - ‘

[_] (Via Facsimile) t caused said document(s) to be transmitted to the facsimile number(s)
of the addressee(s) designated.

| declare under penalty of perju ing i correct and that this
declaration is executed on November 4.4 i /

-7-
BFS’ REQUESTS FOR PRODUCTION TO PLAINTEEF, SET ONEPage 1 of 2

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era anten ante ian at e  e

LexisNexis File & Serve Transaction Receipt

Transaction ID: ” 28151504

Submitted by: Barbara Golstein, Bécherer Kannett & Schweitzer-Emeryville
Authorized by: Jennifer Thal, Becherer Kannett & Schweitzer-Emeryvilie
Authorize and file on: - Nov 20 2009 10:124M PST

Court: : CA Superior Court County of San Francisco
Division/Courtroom: N/A

Case Class: Civil .
‘Case Type: Personal Injury-Asbestos

Case Number: 274719 .

Case Name: Alexander vs Asbestos Defendants (Brayton)

Transaction Option: Serve Only - Public

Billing Reference: BF5/Rufus Alexander

Read Status for e-service: Not Purchased

Documents List

3 Document(s)
Attached Document, 6 Pages Document ID: 25792499 ‘ PDF Format | Original Format
Docament Type: . Access: Statutory Fee: Linked:
Discovery — use for electronic service only Public $0.00
Document title:
Requests for Admission to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC
Attached Document, 7 Pages Pocument IP: 25792542 PDE Format ] Original Format
Document Type: Access: Statutory Fee: Linked:

__ Discovery ~ use for electronic service only Public _ $0.00
Document title:

Requests for Production of Docurnents to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire,
uc -

Attached Document, 6 Pages Document ID: 25792959 - PDF Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery ~ use for electronic service only Public $0.00
Document title:
Special Interrogatories to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LUC
Expand Ail -
_Sending Parties (1)
Party wey Attorney _ Firm Attorney Type.

Bridgestone Firestone North American Tire, Defendant Milanfar, Becherer Kannett & Schweitzer- Attomey in

LLC (pending) Shahrad 7 Emeryville Charge
E]_Recipients (18} .

El Setvice List (1

Delivery Party Attorney
Option Party Type Attorney Firm ‘Type Methed
Service Alexander, Rufus Plaintiff — Pollack, Dean Bumhem Brown-Oakland = Attomey E

mrica wiry n_

st mainnnanDarmelt Service

Alexander, Rufus ati 4 EB
Service Darel! Plaintiff  Rundin, WalterC Burnham Brown-Oakland = Attorney Service
Alexander, Rufus , E-
Service Darnell ‘ Plainttf Gonzales, Susana Burmibamn Brown-Oakdand = Attorney Service
« McKenna Long & Aldridge Attorney in E- .
Service ArvinMeritor Inc Defendant Oberg, Lisa Lup-San Franeiseo Chm Service
. Carrol Burdick &
BM W of North America . Attorney In E-
Service vc Defendant Ames, Richard — McDonough LLP-San Chai Service

Carroll Burdick &

service MW of North America nefendant aaa, McDonough LLP-San ary owice
. incisco-
Service Carlisle Co Inc Defendant Davidson, Aftion E Bassi Eto Huts § Blum Ato in arvice
Service —_Chrysier LLC Defendant Kuenster, Jennifer Noon Peabody 1P-San  Attomey in
Service Cummins Engine Co Inc Defendant Golden, Gatherine Jackson & Wallace-San GmeY 0B vice
‘Service Dana Co LLC Defendant Counsel, Ashestos Brydon Huge & Parker-San aaey mE ice
Service Sattock’Sealing Defendant Glaspy, David Glaspy & Giaspy Cae i owvice
Service Hennessy Industries Defendant Goelz, Andy J Tee beech Amero home’ in Eice
Service Lest Seater versined: Defendant Keesal, Samuel A Keesat Young & Logan-Long Goes in e wiee
Service Mack Trucks Inc Defendant Ostertag, James 7 Nixou Peabody UP-San — Atomey in Ee
Service Necsing Gor Defendant Reflley, Mary E Krieg Keer Sioan Reilley & Gwe? ine eve
Service Plant Insulation Corp Defendant Travis, Monte S Travis & Pon gee’ 0 vice”
Service Pneumo Abex Lic Defendant seansele Asbestos Brydon Huge & Parker-San Chore? in Service
service Toyota Motor Sales grendant, CoueL Asbestos Brydon Hugo &ParkerSan Atomey in” E

LexisNexis® | About LexisNexis | Terms & Conditions | Privacy | Customer Support - 1-888-529-7587
| Copyright © 2009 LexisNexis®, a division of Reed Elseyler Inc. All rights reserved.

en eet

nerein

441A ANNExhibit Dwo co KN DH HW ® WB BD HF

10

Mark S. Kannett (SBN 104572)
Shahrad Milanfar (SBN 201126)
Jennifer K. Thai (SBN 258612)

,BECHERER KANNETT & SCHWEITZER

1255 Powell Street
Emeryville, CA 94608
Telephone: (510) 658-3600
Facsimile: (510) 658-1151

Attorneys for Defendant

Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

CASE NO. CGC-08-2747 19

RUFUS ALEXANDER, :
REQUESTS FOR ADMISSION TO
Plaintiff, PLAINTIFF RUFUS ALEXANDER BY
DEFENDANT BRIDGESTONE
vs. FIRESTONE NORTH AMERICAN TIRE,
LL

ASBESTOS DEFENDANTS (BP), et al.,
"Defendants.

ee eee

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, LLC
RESPONDING PARTY: _ Plaintiff Rufus Alexander
SET NO.: One (4)

Pursuant to the provisions of California Code of Civil Procedure sections 2033.010

through 2033.740, Defendant Bridgestone Firestone North American Tire, LLC requests that

Plaintiff Rufus Alexander (“Plaintiff’) respond fo each of the following requests for
admission, under oath, by admitting fo the truth of the specified matters of fact, opinions
relating to fact, or applications of law to fact. Bridgestone Firestone North American Tire,
LLC requests that a written response be served within thirly (30) days from the date of,

service of these requests.

le
BFS’ REQUESTS FOR ADMISSION TO PLAINTIFF, SET ONE —oe NIN AW HR WN

yN N NYE Be Be se ee Se ee
RBRRBBERB SRR AARERA GS

27

Bridgestone Firestone North American Tire, LLC (BFS) submits its Requests for
Admission pursuant fo C.C.P. § 2033.01 0, within the scope delineated by C.C.P.§
2017.010, ef seq., and subject to the restriction set forth in C.C.P_ § 2019.030, ef seq. If
Plaintiff fails to admit the truth of any of these requests for admission, BFS expressly
reserves its rights under C.C.P. § 2033.420 to bring a motion to recover its expenses
incurred in proving at trial any matters not so admitted.

REQUEST FOR. ADMISSION NO. 1

Admit that YOU never personally handled any brake products manufactured,
supplied, sold or distributed by BFS.

[When in capital ietters, YOU, YOUR, and YOURSELF means plaintiff, RUFUS
ALEXANDER, as well as anyone acting or purporting to act on their behalf, including, but

not limited to, YOUR agents, YOUR employees, YOUR insurance companies, their agents,
their employees, YOUR attorneys, YOUR accountants, YOUR investigators, and anyone
else acting on YOUR behalf] [BFS includes, buti is not limited fo, Bridgesione Firestone '
North American Tire, LLC, Bridgestone / Firestone, Inc., Firestone Tire and Rubber
Company, World Bestos Corporation]

REQUEST FOR ADMISSION NO. 2

Admit that YOU were never present while someone else handled brake products
manufactured, supplied, sold or distributed by BFS.

|| REQUEST FOR ADMISSION NO. 3

* Admit that YOU never personally handled any clutch disc facings manufactured,
supplied, sold or distributed by BFS.
REQUEST FOR ADMISSION NO. 4 >
Admitthat YOU were never present while someone else handled clutch disc facings
manufactured, supplied, sold or distributed by BFS. :
REQUEST FOR ADMISSION NO. 5 .

Admit that YOU never personally handied any automotive gaskets manufactured,
supplied, sold or distributed by BFS.

Je
‘BES? REQUESTS FOR ADMISSION TO PLAINTIFE, SET ONEwo we ND Hh F&F WN

Boe ee Be ee ee
oN AF WF WN PF Oo

19

echerer
Kannett &
‘Schweitzer 28

1255
Powell St.
Emeryila, CA
(94508

510-568-2800

REQUEST FOR ADMISSION NO. 6

- Admit that YOU were never present while someone else handled automotive gaskets
manufactured, supplied, sold or distributed by BFS.

REQUEST FOR ADMISSION NO. 7
Admit that YOU are unable to produce any documents that support YOUR contention

that an asbestos-containing product manufactured, supplied, distributed, or sold by BFS
released fibers which YOU subsequently inhated..
[REQUEST FOR ADMISSIONNO.8

Admit that YOU are unable to identify any individuals who observed the release of
asbestos fibers YOU inhaled from a product manufactured, supplied, distributed, or sold. by
BFS.

REQUEST FOR ADMISSION NO. 9

Admit that neither YOU ever purchased replacement automotive parts which were |
manufactured, supplied, distributed, or sold by BFS.
REQUEST FOR ADMISSION NO. 10 :

Admit that YOU possess no documents or other admissib