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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
						
                                

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SONJA E. BLOMQUIST, SBN 099341, sblomquist@lowball.com GUY W. STILSON, SBN 142194, gstilson@lowball.com KAREN L. MOORE, SBN 199400, kmoore@lowball.com ELECTRONICALLY LOW, BALL & LYNCH 505 Montgomery Street, 7" Floor FILED San Francisco, California 94111-2584 Supertor Court of Calffornia, Telephone (415) 981-6630 08/19/2015 Facsimile (415) 399-1506 08/19/2015 Attorneys for Defendant ee hoe 7 —— GIAMPOLINI & COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO ROBERT ROSS and JEAN ROSS, Case No. CGC-10-275731 Plaintiff, GIAMPOLINI & COMPANY’S TRIAL WITNESS LIST Vv. Judge: Hon. Harold E. Kahn C.C. MOORE & CO. ENGINEERS; Time: 11:15 a.m. Defendants as Reflected on Exhibit I Dept: 613 attached to the Summary Complaint herein; and DOES 1-8500, Complaint Filed: November 8, 2012 Trial Date: August 10, 2015 Defendants. Defendant GIAMPOLINI & COMPANY (hereinafter "GMP") designates the following witness list for trial and hereby joins in all other defendants' designation of witnesses in this matter: Name Party Estimated Anticipated Testimony Calling Length of Testimony | ret Greg Quilici GMP 2 hours Mr. Quilici is CEO of Giampolini & Company. | He is expected to testify as to their business practices and safety practices at Bay area job sites. Dr. Gail GMP 3 hours Gail D, Stockman, M.D. Pulmonologist. Dr, Stockman Stockman is a specialist in the area of respiratory diseases. Dr. Stockman will testify regarding the nature and cause of plaintiffs medical condition, other alternative causes of plaintiff's medical condition, the effect of exposure to various . substances on the development and manifestation -1- GIAMPOLINI & COMPANY'S LIST OF TRIAL WITNESSES C:\Users\wendy\Desktop\Scans\Witness List -1.doeName | David Weiner | GMP~ Sheldon H. GMP Rabinovitz, Ph.D., CIH RN, BSN Dated: August A 2015 Estimated Length of Testimony _ Anticipated Testimony | of obstructive and restrictive conditions, diseases | of the respiratory system, related issues and state of the art. /Thour | 2 hours David Weiner, M.B.A, A.M., Mr. Weiner is expected to testify about the field of forensic economics and plaintiff's claims for economic and non-economic damages. Mr. Weiner will testify generally regarding the concept of present value and its application to economic losses, including income, earnings, benefit loss and loss of household services. Dr. Rabinovitz may testify about Defendant’s work practices, the products used and their function and fiber release, if any, from such products. Additionally, he may testify regarding the plaintiff's identification and use of these products, As a certified industrial hygienist and toxicologist, Dr. Rabinovitz may testify about the nature of the working environment at various job sites, warnings and government regulations of asbestos in the work place. PT hour GIAMPOLINI & COMPANY'S LIST OF TRIAL WITNESSES C:\Users\wendy\Desktop\Scans\Witness List -1.doc. Ms. Rockholt will testify regarding relatedness of treatment, propriety of amounts billed, and amounts paid, She may testify regarding the chronology of presentation of symptoms and plaintiff's co-morbidities. LOW, BALL & LYNCH se si By © tA en SONJA E. BLOMQUIST GUY W. STILSON KAREN L. MOORE Attorneys for Defendant GIAMPOLINI & COMPANY 19)Ro win Ross v. C.C. Moore & Co. Engineers, et al. San Francisco Case No, CGC-10-275731 PROOF OF SERVICE I am over the age of eighteen (18) years and not a party to the within action. [ am employed at Low, Ball & Lynch, 505 Montgomery Street, 7th Floor, San Francisco, California 94111. On the date indicated below, I served the following document GIAMPOLINI & COMPANY’S LIST OF TRIAL WITNESSES on the listed addresses: Brayton Purcell [ ] And All Defense Counsel 222 Rush Landing Road [SEE ATTACHED LIST] Novato, CA 94948-6169 Telephone: 415 898-1555 [ ] (All counsel in this action (list attached) 415-898-1555 (voice) were faxed a letter advising of the documents 415-898-1247 (fax) provided plaintiff and an offer to provide copies upon request. Letter enclosed.) {] (BY MAIL) I placed a true copy, enclosed in a sealed, postage paid envelope, and deposited same for collection and mailing at San Francisco, California, following ordinary business practices, addressed as set forth below. U] (BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the addressees noted above or on the attachment herein by Legal Services. tl (BY FACSIMILE) I caused the said document to be transmitted by Facsimile transmission to the number indicated after the addresses noted above or on the attachment herein. {1 (BY OVERNIGHT COURIER) | caused each such envelope addressed to the parties to be deposited in a box or other facility regularly maintained by the overnight courier or driver authorized by the overnight courier to receive documents. [xX] (BY E-MAIL/ELECTRONIC TRANSMISSION) I caused the said document(s) to be sent to the person(s) at the e-mail address(es) indicated above or on the attachment herein. /T electronically served the document(s) via LexisNexis File & Serve on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website] lam readily familiar with this law firm’s practice for the collection and processing of documents for regular and certified mailing, overnight mail, personal service, electronic transmission, and facsimile transaction, and said document(s) are deposited with the United States Postal Service or overnight courier depository on the same day in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed at San Francisco, California on August | _, 2015. 3 4 Wendy * Ferrera -3- GIAMPOLINI & COMPANY'S LIST OF TRIAL WITNESSES — C:\Users\wendy\Desktop\Scans\Witness List -1.doc