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  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview
  • RODRICK BRECKLER et al VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON et al ASBESTOS document preview 
						
                                
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| STEVEN SPAULDING, State Bar No. 148392
ll HO aAND, . hee State Bar No tooo 5
AND, LONGO, MORAN, DUNST & DOUKAS, LLP
| 333 Pine Street, Sth Floor ELECTRONICALLY
San Francisco, CA 94104 FILED
Telephone: (415) 781-7050 Superior Court of California,
County of San Francisco

|| Attorneys for Defendant JUL 05 2011
AIRGAS-NORTHERN CALIFORNIA & NEVADA, INC. ofthe Court
(Sued herein as Successor-in-interest to GEORGE ROSSMAN, INC., DEWAN SCS
Deputy Clerk

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

CO G2 WA A B&B &wW

RODRICK BRECKLER and JOANN No. CGC-08-274566

BRECKLER,
INDEX TO AIRGAS-NORTHERN
Plaintiffs, CALIFORNIA & NEVADA, INC.'S
MOTION IN LIMINE
v.
Date: July 11, 2011
ASBESTOS DEFENDANTS (B-P), Time: 11:15 a.m.
Dept.: TBA
Defendants.

Defendant AIRGAS-NORTHERN CALIFORNIA & NEVADA, INC. hereby designates and
submits the following Motions in Limine:
1. For the Court to Pre-Clear Demonstrative and Physical Evidence
To Disclose Identities, Amounts, Source and Dates of Prior Settlements

To Exclude Common Reference to Defendant as "The Industry" or Similar
References

»

To Exclude Depositions and Declarations Taken in Other Actions
To Exclude Evidence Not Disclosed Prior to Trial During Discovery
To Exclude Evidence of Similar Pending Actions

To Exclude Mention or Evidence of Defendants' Insurance Coverage

To Exclude Witnesses from the Courtroom Except for Experts

2 PR DH Ww Ss

To Preclude Kenneth Cohen, John Templin, Charles Ay, or Any Similarly Situated
Plaintiff's Expert from Making Unsolicited Statements During Trial

10. Reservation of Rights to Join and Joinder in Motions in Limine

TT:
AIRGAS-NORTHERN CALIFORNIA & NEVADA, INC.'S INDEX TO MOTIONS IN
LIMINEpet kh bd
Ve De

11. To Exclude Any Evidence Pertaining to Labor Code Statutes or General Industry

OC OO BW DR A B&B

Safety Orders

12. To Exclude Evidence Concerning Dangers of Asbestos Exposure in Other
Occupations and of Other Asbestos-Related Diseases

13. To Exclude Vials and Other Infirm Demonstrations of Airborne Asbestos
Concentrations

i4. To Exclude the Testimony of Charles Ay

15. To Exclude Plaintiffs' Use of Any Videotape, Study, Report or Evidence Regarding
Fiber Release From Any Asbestos-Containing Product

16. To Preclude Expert Testimony, Exhibits, or Experimental Results of Any Expert
Witness Not Provided at Deposition

17, To Preclude Speculation Testimony From Plaintiffs

18. To Exclude the Testimony of Ken Cohen

19. To Request a Kelly Hearing Pursuant to Evidence Code Section 402 To Preclude
Evidence of a Causal Association between Asbestos Exposure and Kidney Cancer

Dated: July 1, 2011 HOAGLAND, LONGO, MORAN, DUNST & DOUKAS, LLP
By:

LEOPOLDO J. CHANCO
Attorneys for Défendant
ATRGAS-NORTHERN CALIFORNIA & NEVADA, INC.

73.
AIRGAS-NORTHERN CALIFORNIA & NEVADA, INC.'S INDEX TO MOTIONS IN
LIMINEHoagland, Longo,

Attorneys of Law

‘San Franciseo, CA

2 C2 VW DR A BR Be Nm

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e® S22 3 AA ESB H EF S

21

CASE NAME: Breckler, Rodrick and Joann Breckler v. Asbestos Defendants (B-P)

DOCKET NO.: CGC-08-274566

DOCUMENT: Defendant Airgas-Northern California & Nevada, Inc. Index to Motions In Limine
PROOF OF SERVICE BY ELECT! TRANS,

Iam employed in the County of San Francisco, State of California. Iam over the age
of 18 and not a party to the within action; my business address is 333 Pine Street, Fifth Floor, San
Francisco, California 94104,

On the below stated date, I electronically served the above named document on the
recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website.

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

foregoing is true and correct and that this declaration was executed on July 1, 2011 in San Francisco,

wy aeaa Ae Pll Ga

ORegina M. McCall

California.Co ew WV A WR eR BY De

DS BD ath
Sp = S&S Se UF QE GH ES

Fifth Flaot
Sen Francisco, CA 27

28

CASE NAME: Breckler, Rodrick and Joann Breckler v. Asbestos Defendants (B-P)
DOCKET NO.: CGC-08-274566
DOCUMENT: Defendant Airgas-Northern California & Nevada, Inc. Motions In Limine and Index

thereto
PROOF OF SERVICE BY MAIL

(CCP Section 1013.A, 2015.3)

Jam employed in the County of San Francisco, State of California. Iam over the age
of 18 and not a party to the within action; my business address is 333 Pine Street, Fifth Floor, San
Francisco, California 94104,

On the below stated date, I served the above named. document on the parties in this
action by placing the original/copy enclosed in a sealed envelope addressed as shown below.

Yam familiar with the firm's practice of collection and processing correspondence for
mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary course of
business. I am aware that on motion of the party serviced, service is presumed invalid if postal
cancellation date or postage meter date is more than one (1) day after the date of deposit for mailing

in affidavit:

Brayton Purcell
222 Rush Landing Road
Novato, CA 94948

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

foregoing is true and correct and that this declaration was executed on July 1, 2011 in San Francisco,

wee. We de
By: Lehague Ht .
egina M. McCall

California.