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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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(GOOD 087474/165908330.

MICHAEL J. PIETRYKOWSKI (SBN: 118677)
mpietrykowski@gordonrees.com

KATHRYN J. LAFEVERS (SBN: 252003) ELECTRONICALLY
klafevers@gordonress.com FILED

GORDON & REES LLP Superior Court of Calfforni
Embarcadero Center West oe ean Frceaae

County of San Francisco

275 Battery Street, Twentieth Floor

San Francisco, CA 94111 AUG 28 2013
Telephone: (415) 986-5900 Clerk of the Court
Facsimile: (415) 986-8054 BY: WILLIAM TRUPEK

Deputy Clerk

Attorneys for Defendant
THE GOODYEAR TIRE & RUBBER COMPANY

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO
ROBERT ROSS.and JEAN ROSS, ) CASE NO. CGC-10-275731
)
Plaintiffs, ) THE GOODYEAR TIRE & RUBBER
) COMPANY’S JOINDER IN OTHER
v. ) CO-DEFENDANTS’ MOTIONS IN
) LIMINE [MIL 4 4]
ALTA BUILDING MATERIAL COMPANY., )
etal, ) Action Filed: December 17,2010
) Trial Date: September 9,2013
Defendants. )
2
)
)
)
)
)
)
)
)

PLEASE TAKE NOTICE THAT:

Defendant The Goodyear Tire & Rubber Company (“Goodyear”) hereby joins in each
and every motion in limine regarding non-diverse issues submitted by each and every co-
defendant in the above-entitled case and/or consolidated group of cases,.and in each and every
opposition regarding non-diverse issues filed by such co-defendants to plaintiffs’ motions in
limine in the -above-entitled case and or consolidated group of cases. Should such defendants
resolve this/these case(s) or be dismissed, Goodyear reserves its right to brief and/or argue such

motions as if they were its own.
-1-

“THE GOODYEAR TIRE & RUBBER COMPANY'S JOINDER IN OTHER CO-DEFENDANTS’ MOTIONS IN

LIMINEGordon & Rees LLP
Embarcadero Center West
— 2 DW wo NY A Ww

275 Battery Street, Suite 2000
San Francisco, CA 94111

Ce YD A & &

yo RP MR we NR MY NY
CS EA A FB OB YH mm S

DATED: August 28, 2013 GORDON & REES LLP

THE GOODYEAR TIRE & RUBBER
COMPANY

2.

THE GOODYEAR TIRE & RUBBER COMPANY’S JOINDER IN OTHER CO-DEFENDANTS’ MOTIONS IN
LIMINEoC UD em BS DR HW BB WN

=

PROOF OF SERVICE
ROBERT ROSS AND JEAN Ross v. C.C. MOORE & Co, ENGINEERS
SAN FRANCISCO SUPERIOR COURT CaSE NUMBER CGC-10-275731

Lam a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon & Rees LLP 275 Battery Street, Suite
2000, San Francisco, CA 94111. On August 28, 2013 I served.the within documents:

DEFENDANT THE GOODYEAR TIRE & RUBBER COMPANY'S JOINDER IN
OTHER CO-DEFENDANTS’ MOTION IN LIMINE [MIL#4]

by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below.on this date before:5:00 p.m.

by personally having Nationwide Legal, Inc, delivery the document(s) listed above
to the person(s).at the address(es) set forth below.

O oO 8

by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in United States mail in the State of California at San Francisco,
addressed as set. forth below.

by electronically serving the document(s) described above via File & Serve Xpress
on the recipients designated on the Transaction Receipt that is located on the File &
Serve Xpress website and as set forth below:

XI

BRAYTON®PURCELL
222 Rush Landing Road
Novato, CA 94948

Tele: 415-898-1555

Plaintiffs’ Counsel

[am readily familiar with the firm’s practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S, Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. [ am aware-that on
motion of the party served, service is presumed invalid if postal cancellation date. or postage
meter date is more than one day after the date of deposit for mailing in affidavit.

I declare under penalty of perjury under the laws of the State of California that the above
is true and correct:

Executed on August 28, 2013 at San Francisco, California.

Proof of Service