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  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
						
                                

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z 2 a Nova DAVID R. DONADIO, ESQ., S.B. #154436 NANCY T. WILLIAMS, ESQ., S.B. #201095 nwilliar aytonlaw.com BRAYTON#PURCELL LLP ELECTRONICALLY Attorneys at Law FILED 222 Rush Landing Road Superior Court of California, Post ee 6169 County of San Francisco Novato, California 94948-6169 09/06/2016 (415) 898-1555 09 /s of 42 Court BY:ROMY RISK Attorneys for Plaintiffs Deputy Clerk SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO ROBERT ROSS and JEAN ROSS, ) ASBESTOS ) No. CGC-10-275731 Plaintiffs, ) ) EX PARTE APPLICATION FOR ORDER vs. ) | ADDING CASE TO OCTOBER 20, 2016 ) STATUS CONFERENCE C.C. MOORE & CO. ENGINEERS; ) Defendants as Reflected on Exhibit | ) attached to the Summary Complaint ) Date: September 7, 2016 herein; and DOES 1-8500. ) Time: 11:00 a.m. Dept.: 503, The Hon. Garrett L. Wong Trial Date: N/A Action Filed: December 17, 2010 APPLICATION Plaintiffs hereby apply to have case added to the October 20, 2016 Status Conference. Plaintiffs make this request based upon the good cause shown in the accompanying Declaration of Nancy T. Williams. Plaintiffs filed their survival/wrongful death action on December 17, 2010. On January 19, 2016 the matter was reported as resolved. The matter is currently scheduled for a January 5, 2017 Order to Show Cause hearing regarding dismissal of the action. On May 12, 2016, Intervenor Fireman’s Fund was granted leave to set aside default as to defaulted defendant Associated Insulation. Although no answer or Complaint in Intervention has| been filed by or on behalf of defendant Associated Insulation, plaintiffs anticipate the court will allow Associated Insulation to proceed as an active defendant in some regard. To that end and to KAnjured.19349 pid'app-spteadd.ise-wpd 1 Now EX PARTE APPLICATION FOR ORDER ADDING CASE TO OCTOBER 20, 2016 STATUS CONFERENCEavoid further delay to plaintiffs’ having this matter resolved, plaintiffs request now that the action] be placed back on the court’s active calendar so it may be assigned a trial date as to plaintiffs’ claim against defendant Associated Insulation. Dated: September 6, 2016 BRAYTON*PURCELL LLP By: /s/ Nancy T. Williams Nancy T. Williams Attorneys for Plaintiffs KMnjure.19349ipkapp-xptadise.p 2 rw EX PARTE APPLICATION FOR ORDER ADDING CASE TO OCTOBER 20, 2016 STATUS CONFERENCESD mY DH FF WN HS BRAYTON@PURCELL LLP ATIORNEYS AT LAW 222 RUSH LANDING ROAD POBOX 6169 NOVATO, CALIFORNIA 94948-6169 (415) 898-1555 PROOF OF SERVICE BY FILE & SERVEXPRESS Iam employed in the County of Marin, State of California. I am over the age of 18 ears and am not a party to the within action. My business address is 222 Rush Landing Road, -O. Box 6169, Novato, California, 94948-6169. On September 6, 2016 I caused electronic service (E-Service) of the following documents: EX PARTE APPLICATION FOR ORDER ADDING CASE TO OCTOBER 20, 2016 STATUS CONFERENCE MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF EX PARTE APN FOR ORDER ADDING CASE TO OCTOBER 20, 2016 STATUS CE DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER-ADDING CASE TO OCTOBER 20, 2016 STATUS CONFERENCE [PROPOSED] ORDER GRANTING PLAINTIFFS’ EX PARTE APPLICATION ADDING CASE TO OCTOBER 20, 2016 STATUS CONFERENCE on the interested parties in this action by causing File & ServeXpress E-service program to transmit a true copy thereof to the following party(ies): SEE ATTACHED SERVICE LIST The above document was transmitted by File & ServeXpress E-Service and the transmission was reported as complete and without error. Executed on September 6, 2016 at Novato, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Ul het Robert Ross and Jean Ross v. C.C. Moore and Co. Engineers Inc., et al. San Francisco Superior Court Case No. CGC-10-275731 PROOF OF SERVICE BY E-SERVICEDate Created: 9/6/2016-8:30:07 AM Brayton-Purcell Service List Run By : Lucio, Claudia (CCL) Created by: LitSupport.- ServiceList - Reporting Matter Number: 19349.004 - Robert Ross Berry and Berr : 475 14" Street, Suite 550 Oakland, CA 94612 510-250-0200 510-380-6354 (fax) Defendants: Berry and Berry (B&B) Selman Breitman, LLP - San Francisco Office 33 New Montgomery, 6" Floor San Francisco, CA S4105 415-979-0400 415-979-2099 (fax) Defendants: Associated Insulation of California (ASSOC)