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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 
						
                                
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                                oOo ON OD oO RB WO LD

SEAN A. COTTLE -- BAR NO. 146229
JILL E. FOX -- BAR NO. 243945

HOGE, FENTON, JONES & APPEL, INC. ELECTRONICALLY
Sixty South Market Street, Suite 1400 FILED
San Jose, California 951 13-2396 Superior Court of California
Phone: (408) 287-9501 ‘sco
Fax: (408) 287-2583 County of San Francisco

, JUL 30 2010
Attorneys for Defendant Clerk of the Court
THE JACK DYMOND COMPANY BY: RAYMOND Bent Sherk

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO

BRECKLER, et al. No. CGC-09-274566
Plaintiffs,
DECLARATION OF RONALD MEREDITH IN
vs. SUPPORT OF MOTION TO ALLOW HOGE,
FENTON, JONES & APPEL, INC. TO
ASBESTOS DEFENDANTS, et al., WITHDRAW AS COUNSEL FOR THE JACK
DYMOND COMPANY
Defendants

Date: August 31, 2010

Time: 9:30 am

Dept.: 220

Judge: Honorable Harold E. Kahn
Trial Date: None set

Complaint Filed: = March 12, 2008

|, RONALD MEREDITH, declare:
1. | am the former President of The Jack Dymond Company (“JDC”), a
dissolved California corporation, and the company’s registered agent for service of

process.

-1-
DECLARATION OF RONALD MEREDITH IN SUPPORT OF MOTION TO ALLOW HOGE,
FENTON, JONES & APPEL, INC. TO WITHDRAW AS COUNSEL FOR THE JACK
DYMOND COMPANY=

oo ODN DW oH PB wD PD

2. JDC was a California corporation engaged primarily in the business of
construction. JDC’s former shareholders dissolved the corporation before the end of 2002
and distributed JDC’s remaining assets. JDC has no insurance assets.

3. On or about April 30, 2010, the former shareholders of JDC entered into a
covenant with plaintiffs, as authorized by designated plaintiffs’ counsel Brayton Purcell, that
if plaintiffs obtain any default judgment against JDC, plaintiffs will not seek to enforce that
judgment against JDC’s former shareholders.

4. After the covenant was fully executed, | instructed JDC’s counsel of record,
Hoge Fenton Jones and Appel, Inc. (“Hoge Fenton’), to stop work on all pending asbestos
matters. | instructed Hoge Fenton to take no further steps to defend JDC against current
and prospective asbestos claims in San Francisco Superior Court. | discharged Hoge
Fenton from representing JDC, other than to take the remaining steps necessary to
withdraw as counsel.

5. | hereby consent to Hoge Fenton's withdrawal! as counsel of record for JDC.
| consent with the understanding that plaintiffs are likely to obtain default judgments against
JDC.

I declare under penalty of perjury under the laws of the State of California that the
above facts are within my personal knowledge; that | can testify to the same if called to do
so in a court of law; that the foregoing is true and correct; and that this declaration was

executed on the Af #cday of July, 2010, at Los Altos, California.

#0ON hat.

-2-
DECLARATION OF RONALD MEREDITH IN SUPPORT OF MOTION TO ALLOW HOGE,
FENTON, JONES & APPEL, INC. TO WITHDRAW AS COUNSEL FOR THE JACK
DYMOND COMPANY