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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
						
                                

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BRAYTON®PURCELL LLP ATTORNEYS AT LAW 222 RUSH LANDING ROAD PO BOX 6169 NOVATO, CALIFORNIA 94948-6169 (A415) 898-1555 ALAN R. BRAYTON, ESQ., S.B. #73685 DAVID R. DONADIO, ESQ., S.B. #154436 NANCY T. WILLIAMS, ESQ., S.B. #201095 NWilliams@pbraytonlaw.com ELECTRONICALLY BRAYTON®PURCELL LLP FILED Attorneys at Law ‘Califor’ 222 Rush Landing Road a ccungoraun menemeot P.O. Box 6169 Novato, California 94948-6169 03/25/2016 (415) 898-1555 BY:NADITA MASON (415) 898-1247 (Fax No.) Deputy Clerk Attorneys for Plaintiffs SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO ROBERT ROSS and JEAN ROSS, ASBESTOS No. CGC-10-275731 PLAINTIFFS' REQUEST FOR WAIVER OF APPEARANCE AT DEFAULT PROVE UP HEARING AS TO DEFENDANT JONES PLASTERING COMPANY Plaintiffs, vs. C.C. MOORE & CO. ENGINEERS; Defendants as Reflected on Exhibit 1 attached to the Summary Complaint herein; and DOES 1-8500. Hearing Date: May 24, 2016 Time: 9:00 a.m. Dept.: 514, Hon. Joseph M. Quinn Trial Date: Not Applicable Filing Date: December 17, 2010 This matter involves damages in connection with Plaintiff ROBERT ROSS 's exposure to asbestos containing products supplied by defendant JONES PLASTERING COMPANY and/or installed and/or disturbed by said defendant as a contractor. Such exposure contributed to cause Plaintiff ROBERT ROSS 's asbestos-related disease, and caused damages to Plaintiffs ROBERT ROSS and JEAN ROSS ("Plaintiffs"). Defendant was served with summons and complaint but did not answer of otherwise respond and is in default. Plaintiffs have filed for entry of default judgment. Plaintiffs' motion for Default Judgment and Prove up is set for hearing on May 24, 2016. The evidence in support of the plaintiffs' damages are set forth in plaintiffs’ application, memorandum and supporting declaration and exhibits thereto. Mt PLAINTIFF'S REQUEST FOR WAIVER OF APPEARANCE AT DEFAULT PROVE UP HEARING AS TO DEFENDANT JONES PLASTERING COMPANYPlaintiffs respectfully request that the Court waive the appearance of the plaintiffs at the Default Prove Up hearing. The facts pertaining to the damages will be presented through the evidence attached to the Declaration of Nancy T. Williams, including the declaration of plaintiff in support of default judgment. Plaintiffs respectfully request that the Court waive plaintiff's appearances for the Default Prove up hearing. Plaintiff will be represented by counsel at the hearing. Dated: _March 22, 2016 BRAYTON#PURCELL LLP By: /s/ Nancy T. Williams Nancy T. Williams Attorneys for Plaintiffs PLAINTIFF'S REQUEST FOR WAIVER OF APPEARANCE AT DEFAULT PROVE UP HEARING AS TO DEFENDANT JONES PLASTERING COMPANY