Motion,Ex Parte: ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS

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                                BRAYTON*PURCELL LLP
ATTORNEYS AT LAW
222 RUSH LANDING ROAD

PO BOX 6169
NOVATO, CALIFORNEA 94948-6169

4415) 808-1585

oem NY KD A BY

10

ALAN R. BRAYTON, ESQ., 8.B. #73685
DAVID R. DONADIO, ESQ., 8.B. #154436
OREN P. NOAH, ESQ., S.B. #136310 ELECTRONICALLY
ASHLEY J. BENSON, ESQ., S.B. #276326

BRAYTON%PURCELL ie F I L E D
Attorneys at Law

222 Rush Landing Road

Superior Court of California,
County of San Francisco

P.O. Box 6169 APR 24 2013
Novato, California 94948-6169 Clerk of the Court
(415) 898-1555 BY: VANESSA WU
Tentative Ruling Contest Email: contestasbestosTR@braytonlaw.com Deputy Clerk

Attorneys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS, ASBESTOS

No, CGC-10-275731

PLAINTIFFS’ EVIDENTIARY
OBJECTIONS TO DEFENDANT
HAROLD BEASLEY PLUMBING AND
HEATING, INC.’S MOTION FOR,
SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION

Plaintiffs,
vs.

C.C. MOORE & CO. ENGINEERS;
Defendants as Reflected on Exhibit |
attached to the Summary Complaint

herein; and DOES 1-8500.

eee

Date: May 8, 2013

Time: 9:30 a.m.

Dept: 503, Hon. Teri L. Jackson

Trial Date: June 10, 2013

Action Filed: December 17, 2010

Plaintiffs respectfully request that this Court rule on plaintiffs’ evidentiary objections in

accordance with California Rules of Court, Rules 3.1352 and 3.1354, Vineyard Springs Estates,
LLC v. Super. Ct. (Wyatt) (2004) 120 Cal.App.4th 633, 635; Sambrano v. City of San Diego

(2001) 94 Cal.App.4th 225, 235; Laird v. Capital Cities/ABC, Inc. (1998) 68 Cal.App.4th 727,

736, and Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group
2005) 10:301.1, ch. 10-F.

Plaintiffs object to and move to strike defendant’s proffered evidence as follows:

1. Plaintiff objects to, and moves to strike, paragraph eight (8) of the declaration of

James Beasley, attached to defendant’s motion for summary judgement.

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PLAINTIFFS' EVIDENTIARY OBJECTIONS 10 DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

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Material Objected To: Grounds for Objection:

1. Paragraph eight (8) of the declaration of 1. Irrelevant and lacks foundation.
James Beasley, attached to defendant’s Mr, Beasley’s awareness is irrelevant of
motion for summary judgement. BEASLEY’s knowledge of the dangers of

asbestos. Mr. Beasley’s personal
obliviousness regarding knowledge of the
dangers of asbestos has no tendency to
prove they shouldn’t have known.
Additionally, if the intended reference is
that BEASLEY did not_ know and couldn’t
have known about the dangers of asbestos,
Mr, Beasley lacks foundation to so state
this. Mr. Beasley has failed to establish any
basis by which his knowledge is imputed
upon the business.

Lack of personal knowledge (Ev. Code
§702(a). Instead of supplying admissible
evidence, Mr. Beasley’s declaration makes
conclusory statements in an attempt to show
that defendant had no knowledge of the
dangers of asbestos. Mr. Beasley fails to
recognize that the standard is not what the
actual knowledge was, but what BEASLEY
should have known. Additionally,

Mr. Beasley states that he was hired on full
time at the company in 1961; however, he
did not become Chief Executive Officer
until 1977. There is no discussion of his
occupation and duties between 1961 and
1977 and as such he has not laid the proper
foundation to show the he knew the goings
on of BEASLEY, namely its knowledge of
asbestos in the 1960s. Mr. Beasley does not
lay a proper foundation for his statements
and thus has failed to give reason that he is
competent to make any such a statement as
tequired by Ev. Code §702(a).

COURT’S RULING ON OBJECTION NO. 1:

Dated: Sustained:

Overruled:

2. Plaintiff objects to, and moves to strike, paragraph nine (9) of the declaration of
James Beasley, attached to defendant’s motion for summary judgement.

dif

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PLAINTIFFS' EVIDENTIARY OBJECTIONS 10 DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC.S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

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Material Objected To: Grounds for Objection:

2. Paragraph nine (9) of the declaration of 2. irrelevant and lacks foundation.
James Beasley, attached to defendant’s Employment of physicians and nurses is
motion for summary judgement. irrelevant of BEASLEY’s knowledge of the

dangers of asbestos. The non employment
of medical personnel has no tendency to
prove BEASLEY shouldn’t have known
about the dangers of asbestos. Additionally,
if the intended reference is that BEASLEY
did not know and couldn’t have known
about the dangers of asbestos, Mr. Beasley
lacks foundation to so state this,

Mr. Beasley has failed to establish any basis
by which his knowledge is imputed upon
the business.

Lack of personal knowledge (Ev. Code
§702(a). Instead of supplying admissible
evidence, Mr. Beasley’s declaration makes
conclusory statements in an attempt to show
that defendant had no knowledge of the
dangers of asbestos. Mr. Beasley fails to
recognize that the standard is not what the
actual knowledge was, but what BEASLEY
should have known. Additionally,

Mr. Beasley states that he was hired on full
time at the company in 1961; however, he
did not become Chief Executive Officer
until 1977. There is no discussion of his
occupation and duties between 1961 and
1977 and as such he has not laid the proper
foundation to show the he knew the goings
on of BEASLEY, namely its knowledge of
asbestos in the 1960s. Mr. Beasley does not
lay a proper foundation for his statements
and thus has failed to give reason that he is
competent to make any such a statement as
tequired by Ev. Code §702(a).

COURT’S RULING ON OBJECTION NO, 2:

Dated: Sustained:

Overruled:

3. Plaintiff objects to, and moves to strike, paragraph ten (10) of the declaration of
James Beasley, attached to defendant’s motion for summary judgement.

dif

KAinjuredi 193-8) ltiobj eva BEASLY mfp 3 AJB
PLAINTIFPS' EVIDENTIARY OBJECTIONS 10 DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

Material Objected To: Grounds for Objection:

3. Paragraph ten (10) of the declaration of 3. irrelevant and lacks foundation.
James Beasley, attached to defendant’s Mr. Beasley’s awareness of documents
motion for summary judgement. regarding studies and tests received by

BEASLEYis irrelevant of BEASLEY’s
knowledge of the dangers of asbestos.

Mr. Beasley’s personal obliviousness
regarding what documents were received by
BEASLEY regarding the knowledge of the
dangers of asbestos has no tendency to
prove they shouldn’t have known.
Additionally, if the intended reference is
that BEASLEY did not_ know and couldn’t
have known about the dangers of asbestos,
Mr. Beasley lacks foundation to so state
this. Mr. Beasley has failed to establish any
basis by which his knowledge is imputed
upon the business,

Lack of personal knowledge (Ev. Code
$702(a). Instead of supplying admissible
evidence, Mr, Beasley’s declaration makes
conclusory statements in an attempt to show
that defendant had no knowledge of the
dangers of asbestos. Mr. Beasley fails to
tecognize that the standard is not what the
actual knowledge was, but what BEASLEY
should have known. Additionally,

Mr. Beasley states that he was hired on full
time at the company in 1961; however, he
did not become Chief Executive Officer
until 1977. There is no discussion of his
occupation and duties between 1961 and
1977 and as such he has not laid the proper
foundation to show the he knew the goings
on of BEASLEY, namely its knowledge of
asbestos in the 1960s. Mr. Beasley does not
lay a proper foundation for his statements
and thus has failed to give reason that he is
competent to make any such a statement as
required by Ev. Code §702(a).

COURT’S RULING ON OBJECTION NO, 3:

Dated: Sustained:
Overruled:
if
it
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PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

4, Plaintiff objects to, and moves to strike, in it’s entirety the declaration of Kyle

Dotson, attached to defendant’s motion for summary judgement.

Material Objected To:
4, The entirety of the declaration of Kyle

Dotson, attached to defendant’s motion for
summary judgement.

COURT’S RULING ON OBJECTION NO. 4:

Dated:

Grounds for Objection:

4. Lacks foundation.

Mr. Dotson has not laid a proper foundation.
for his statements and thus has failed to give
reason that he is competent to make any
such a statement as required by Ev. Code
§702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.

Sustained:

Overruled:

5. Plaintiff objects to, and moves to strike, paragraph five (5) of the declaration of

Kyle Dotson, attached to defendant’s motion for summary judgement.

Material Objected To:
5, Paragraph five (5) of the declaration of

Kyle Dotson, attached to defendant’s
motion for summary judgement.

COURT’S RULING ON OBJECTION NO. 5:

Grounds for Objection:

5. Lacks foundation.

Mr. Dotson has not laid a proper foundation
for his statements and thus has failed to give
reason that he is competent to make any
such a statement as required by Ev. Code
§$702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.

Merely stating “it is well established” is not
sufficient to make a showing of such. In
addition to failing to show his qualifications
specific to asbestos, Mr. Dotson also fails to
show what scientific research he has
conducted or reviewed to reach such a broad
and conclusory statement.

Dated: Sustained:
Overruled:
it
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PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCO OW YN DR A BY De

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6. Plaintiff objects to, and moves to strike, paragraph six (6) of the declaration of

Kyle Dotson, attached to defendant’s motion for summary judgement.

Material Objected To:
6. Paragraph six (6) of the declaration of

Kyle Dotson, attached to defendant’s
motion for summary judgement.

COURT’S RULING ON OBJECTION NO. 6:

Dated:

Grounds for Objection:

6. Lacks foundation.

Mr. Dotson has not laid a proper foundation.
for his statements and thus has failed to give
reason that he is competent to make any
such a statement as required by Ev. Code
§702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.

Merely stating “it is well established” is not
sufficient to make a showing of such. In
addition to failing to show his qualifications
specific to asbestos, Mr. Dotson also fails to
show what scientific research he has
conducted or reviewed to reach such a broad
and conclusory statement.

Sustained:

Overruled:

7. Plaintiff objects to, and moves to strike, paragraph seven (7) of the declaration of

Kyle Dotson, attached to defendant’s motion for summary judgement.

Material Objected To:
7. Paragraph seven (7) of the declaration of

Kyle Dotson, attached to defendant’s
motion for summary judgement.

dif

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Grounds for Objection:

7. Lacks foundation.

Mr. Dotson has not laid a proper foundation
for his statements and thus has failed to give
reason that he is competent to make any
such a statement as required by Ev. Code
§702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.

Merely stating “it is well established” is not
sufficient to make a showing of such. In
addition to failing to show his qualifications
specific to asbestos, Mr. Dotson also fails to
show what scientific research he has
conducted or reviewed to reach such a broad
and conclusory statement,

AIB

PLAINTIFFS' EVIDES
FOR SUMMARY JUDGM.

ARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC.°S MOTION
JENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

COURT’S RULING ON OBJECTION NO, 7:

Dated: Sustained:

Overruled:

8. Plaintiff objects te, and moves to strike, paragraph eight (8) of the declaration of

Kyle Dotson, attached to defendant’s motion for summary judgement.

Material Objected To: Grounds for Objection:

8. Paragraph cight (8) of the declaration of 8. Lacks foundation and irrelevant.

Kyle Dotson, attached to defendant’s Mr. Dotson has not laid a proper foundation
motion for summary judgement. for his statements and thus has failed to give

teason that he is competent to make any

such a statement as required by Ev, Code
§702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.

Merely stating “it is well established” is not
sufficient to make a showing of such. In
addition to failing te show his qualifications
specific to asbestos, Mr. Dotson also fails to
show what scientific research he has
conducted or reviewed to reach such a broad
and conclusory statement.

Additionally, it is irrelevant of what
knowledge the insulation trade had of the
tisks associated with asbestos, as there is no
showing of this knowledge being imputed
on plaintiff. The standard at issue is what
defendant knew or should have known.
Even if plaintiff himself knew about the
risks associated with asbestos, the
sophisticated user defense does not amount
to a complete defense and defendant would
still be required to act with reasonable care.

COURT’S RULING ON OBJECTION NO. 8:

Dated: Sustained:
Overruled:
if
it
Mt
KAinjuredi 193-8) ltiobj eva BEASLY mfp 7 ASB

PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCO OW YN DR A BY De

RM NR NY NYY BR Ye Be Be Se Se ee Be Be Be
eo WA A PB OH se So we IY DR mA BW BW ee oS

9. Plaintiff objects to, and moves to strike, paragraph nine (9) of the declaration of

Kyle Dotson, attached to defendant’s motion for summary judgement.

Material Objected To: Grounds for Objection:

9. Paragraph nine (9) of the declaration of 9. Lacks foundation and misleading.

Kyle Dotson, attached to defendant’s Mr. Dotson has not laid a proper foundation.
motion for summary judgement. for his statements and thus has failed to give

reason that he is competent to make any
such a statement as required by Ev. Code
§702(a). He has stated minimal
qualifications, none of which are specific to
asbestos or the handling of asbestos.
Merely stating “absent evidence to the
contrary” is not sufficient to make a
showing of such. In addition to failing to
show his qualifications specific to asbestos,
Mr. Dotson also fails to show what
scientific research he has conducted or
teviewed to reach such a broad and
conclusory statement.

Additionally, plaintiffs have produced
expert Richard Cohen, M.D., M.P.H., who
unlike Mr. Dotson has the proper foundation
and the research toe support his opinions,
who present evidence to the contrary of Mr.
Dotson’s unfounded beliefs.

COURT’S RULING ON OBJECTION NO. 9:

Dated: Sustained:

Overruled:

10. Plaintiffs object to, and move to strike, the deposition transcripts of Mr.
Arthur Klimack, Exhibit Q to the Declaration of George S. Sullivan in Support of
Defendant’s Notice of Motion and Motion for Summary Judgment or, in the alternative,

Summary Adjudication served concurrently with defendant’s moving papers.

Material Objected To: Grounds for Objection:
10. Deposition of Arthur Klimack in its 10. This deposition was taken in a matter
entirety. other than this case. The witness has not

been shown to be unavailable, Therefore
the testimony is inadmissible hearsay,
offered without exception.

Me

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PLAINTIFFS! EVIDE:

INTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC.“S MOTION
FOR SUMMARY JUDGM.

JENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

Further, Mr. Klimack in no way has shown
the knowledge he possessed along with any
knowledge the Local 16 union possessed
was conveyed upon plaintiff, so any
opinions that he may have about the union
or its members are lacking in foundation,
speculative, irrelevant and therefore
inadmissible.

COURT’S RULING ON OBJECTION NO. 10:

Dated: Sustained:

Overruled:

11. Plaintiffs object to, and move to strike, the deposition transcripts of Mr.
Arthur Klimack, Exhibit R to the Declaration of George S. Sullivan in Support of
Defendant’s Notice of Motion and Motion for Summary Judgment or, in the alternative,

Summary Adjudication served concurrently with defendant’s moving papers.

Material Objected To: Grounds for Objection:
11. Deposition of Arthur Klimack in its 11. This deposition was taken in a matter
entirety, other than this case. The witness has not

been shown to be unavailable. Therefore
the testimony is inadmissible hearsay,
offered without exception.

Further, Mr. Klimack in no way has shown
the knowledge he possessed along with any
knowledge the Local 16 union possessed
was conveyed upon plaintiff, so any
opinions that he may have about the union
or its members are lacking in foundation,
speculative, irrelevant and therefore
inadmissible.

COURT’S RULING ON OBJECTION NO, Tt:

Dated: Sustained:
Overruled:
Me
Mt
Me
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PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

12. Plaintiffs object to, and move to strike The Asbestos Worker from April 1957
Exhibit S to the Declaration of George S. Sullivan in Support of Defendant’s Notice of
Motion and Motion for Summary Judgment or, in the alternative, Summary Adjudication

served concurrently with defendant’s moving papers in its entirety.

Material Objected To: Grounds for Objection:
12. The Asbestos Worker from April 1957 12. The publication lacks foundation, is
in its entirety. based upon speculation and hearsay, is

irrelevant and therefore inadmissible,
(Evid. Code §§ 210, 350, 403, 405, 702,
1200-1205.)

Mr. Sullivan’s opinions regarding the
potential authenticity of The Asbestos
Worker journals lack foundation, are based
upon. speculation and hearsay, are therefore
irrelevant and inadmissible.

No foundation has been offered to show that
Mr. Sullivan is capable of authenticating
any volumes of The Asbestos Worker
journals, let alone those at issue here.

COURT’S RULING ON OBJECTION NO, 12:

Dated: Sustained:

Overruled:

13. Plaintiffs object to, and move to strike The Asbestos Worker from October1957
Exhibit T to the Declaration of George S. Sullivan in Support of Defendant’s Notice of
Motion and Motion for Summary Judgment or, in the alternative, Summary Adjudication

served concurrently with defendant’s moving papers in its entirety.

Material Objected To: Grounds for Objection:
13. The Asbestos Worker from October 13. The publication lacks foundation, is
1957 in its entirety. based upon speculation and hearsay, is

irrelevant and therefore inadmissible.
(Evid. Code §§ 210, 350, 403, 405, 702,
1200-1205.)

Mr, Sullivan’s opinions regarding the

potential authenticity of The Asbestos

Worker journals lack foundation, are based
Me

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PLAINTIFFS' EVIDENTIARY OBJECTIONS 10 DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

upon speculation and hearsay, are therefore
irrelevant and inadmissible.

No foundation has been offered to show that
Mr. Sullivan is capable of authenticating
any volumes of The Asbestos Worker
journals, let alone those at issue here.

COURT’S RULING ON OBJECTION NO. 13:

Dated: Sustained:

Overruled:

14. Plaintiffs object to, and move to strike The Asbestos Worker from April 1958
Exhibit U to the Declaration of George S. Sullivan in Support of Defendant’s Notice of
Motion and Motion for Summary Judgment or, in the alternative, Summary Adjudication

served concurrently with defendant’s moving papers in its entirety.

Material Objected To: Grounds for Objection:
14. The Asbestos Worker from April 1958 14, The publication lacks foundation, is
in its entirety. based upon speculation and hearsay, is

irrelevant and therefore inadmissible.
(Evid. Code §§ 210, 350, 403, 405, 702,
1200-1205.)

Mr, Sullivan’s opinions regarding the
potential authenticity of The Asbestos
Worker journals lack foundation, are based
upon speculation and hearsay, are therefore
irrelevant and inadmissible.

No foundation has been offered to show that
Mr. Sullivan is capable of authenticating
any volumes of The Asbestos Worker
journals, let alone those at issue here.

COURT’S RULING ON OBJECTION NO. 14:

Dated: Sustained:

Overruled:

15. Plaintiffs object to, and move to strike The Asbestos Worker from May 1959
Exhibit V to the Declaration of George S. Sullivan in Support of Defendant’s Notice of
Motion and Motion for Summary Judgment or, in the alternative, Summary Adjudication
served concurrently with defendant’s moving papers in its entirety.

KAinjuredi 193-8) ltiobj eva BEASLY mfp ii AJB

PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

Material Objected To: Grounds for Objection:

15. The Asbestos Worker from May 1959 in 15. The publication lacks foundation, is

its entirety. based upon speculation and hearsay, is
irrelevant and therefore inadmissible.
(Evid. Code §§ 210, 350, 403, 405, 702,
1200-1205.)

Mr. Sullivan’s opinions regarding the
potential authenticity of The Asbestos
Worker journals lack foundation, are based
upon speculation and hearsay, are therefore
irrelevant and inadmissible.

No foundation has been offered to show that
Mr. Sullivan is capable of authenticating
any volumes of The Asbestos Worker
journals, let alone those at issue here.

COURT’S RULING ON OBJECTION NO, 15:

Dated: Sustained:

Overruled:

16. Plaintiffs object to, and move to strike The Asbestos Worker from February
1963 Exhibit W to the Declaration of George S. Sullivan in Support of Defendant’s Notice
of Motion and Motion for Summary Judgment or, in the alternative, Summary

Adjudication served concurrently with defendant’s moving papers in its entirety.

Material Objected To: Grounds for Objection:
16. The Asbestos Worker from February 16. The publication lacks foundation, is
1963 in its entirety. based upon speculation and hearsay, is

irrelevant and therefore inadmissible.
(Evid. Code §§ 210, 350, 403, 405, 702,
1200-1205.)

Mr. Sullivan’s opinions regarding the
potential authenticity of The Asbestos
Worker journals lack foundation, are based
upon speculation and hearsay, are therefore
irrelevant and inadmissible.

No foundation has been offered to show that
Mr. Sullivan is capable of authenticating
any volumes of The Asbestos Worker
journals, let alone those at issue here.

Mit
dif

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PLAINTIFFS' EVIDENTIARY OBJECTIONS 10 DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC.S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATIONCo em YW KD hw BR YY

10

COURT’S RULING ON OBJECTION NO. 16:

Dated: Sustained:
Overruled:
Dated: _ April 24, 2013 BRAYTON*PURCELL LLP

By: /s/ Ashley J. Benson

Ashley J. Benson
Attorneys for Plaintiff

KAinjuredi 193-8) ltiobj eva BEASLY mfp 13

AIB

PLAINTIFFS' EVIDENTIARY OBJECTIONS TO DEFENDANT HAROLD BEASLEY PLUMBING AND HEATING, INC."S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION