On December 17, 2010 a Motion-Secondary was filed involving a dispute between Ross, Jean, Ross, Robert, and Acco Engineered Systems, Inc., Advanced Mechanical, Advance Mechanical Contractors, Inc., Air Systems Mechanical Contractor, A & K Heating Company, Inc., Albay Construction Company, Allen-Simmons Heating & Sheet Metal Company Inc., Allied Fire Protection, Allied Sprinkler Company, Inc., Allsberry Mechanical Corporation, Anderson, Rowe & Buckley, Inc., Associated Insulation Of California, A. Teichert & Son, Inc., Balliet Bros. Construction Corporation, Banner Drywall & Painting Co. Inc., Barnes Construction Co., Bayer Cropscience Inc., Bayer Cropscience, Inc., Successor To Amchem, Bell Products Inc., Beta Mechanical Contractors, L.P., Bragg Investment Company, Inc., Cahill Construction Co., Inc., Cahill Construction Services, Inc., Cahill Contractors, Inc., California Drywall Co., Castro Construction, Inc., C.C. Moore & Co. Engineers, Cincinnati Valve Company, Cjr Plastering, Clausen-Patten, Inc., Clausen-Patten, Inc., A Dissolved Corporation, Climate Air, Inc., Climate Control Co., Inc., Collins Electrical Company, Inc., Commair Mechanical Services, Consolidated Insulation, Inc., Cosco Fire Protection, Inc., Cosco Sprinkler, Critchfield Mechanical, Inc., C & R Plastering, Inc., Csk Auto, Inc., Cupertino Electric, Inc., Delucchi Sheet Metal Works, Dilland Sederberg Plumbing, Does 1-8500, Domco Products Texas Inc., Domco Products Texas, L.P., Donovan Construction, Dorn Refrigeration, Dorn Refrigeration And Air Conditioning, Dpr Construction, Duro Dyne Corporation, D.W. Nicholson Corporation, D. Zelinsky & Sons, Inc., Emil J. Weber Electric Co., Erwin Mechanical Inc., Ex- Fme, Inc. (Fka Fischbach And Moore Electric,, Fairmont Hotel Company, Fluor Corporation, Foley Electric Co., Foley Electric, Inc., Fuller Floors, General Mills, Inc., Giampolini & Co., Graybar Electric Company, Inc., Hanson Permanente Cement, Inc. Formerly Known As, Harold Beasley Plumbing And Heating, Inc., Harry Lee Plumbing & Heating, H & C Investment Associates, Inc., Henry C. Beck Company, Imperial Plastering & Drywall, Insulation Specialties, Inc., James A. Nelson Co., Inc., Johnson Controls, Inc., Jones Plastering Company, Joseph Bruno Sheet Metal Co., Inc., J.T. Thorpe & Son, Inc., J.W. Mcclenahan Company, J.W. Mcclenahan Company, Inc., Kentile Floors, Inc., Laub Sheet Metal Works, Lone Star Industries, Inc., Mack Construction Co., Magee, Robert, Malm Metal Products, Inc., Marine Engineering And Supply Company, Marshco Auto Parts, Inc., Mattock Construction Company, Mcclure Electric, Inc., Metropolitan Life Insurance Company, Michael Brothers, Midstate Mechanical, Inc., Mitchell Bros. Truck Lines, Inc., Monsanto Company, Sued As "Pharmacia Corporation", Oakfabco, Inc., Ortho-Craft, Pacific Fireproofing, Pacific Mechanical Corporation, Parker Insulation Contracting & Supply Co. Inc., Perini Corporation, Pharmacia Corporation, Which Will Do Business In, Pribuss Engineering, Pribuss Engineering, Inc., Raymond Interior Systems-North, Red Top Electric Co. Emeryville, Inc., Robert Magee, Rollie R. French, Inc., Rollins Construction, Rountree Plumbing & Heating Inc., Scott Co. Of California, S F L, Inc., S.J. Amoroso Construction Co., Inc., Slakey Brothers, Inc., Sugden Engineering Co., Swinerton Builders, Temper Insulation, Temporary Plant Cleaners, Inc., Texaco, Inc., The Goodyear Tire & Rubber Company, The W.W. Henry Company, Tuttle And Bailey Corp, Van Mulder Sheetmetal, Van-Mulder Sheet Metal, Inc., Walnut Creek Sheet Metal, Furnace & Air, W.C. Thomason, W.C. Thompson, Webcor Builders, Inc., Westburne Supply, Inc., Willard Electric, Wright Schuchart Harbor, Wright Schuchart Harbor Company, Ross, Jean, Ross, Robert, for civil in the District Court of San Francisco County.
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Oo we YN DAH BF BW NY Oe RR eR EP FS SRE REA E SHR KS 26 27 Bi ALAMEDA, "CA 94501-1084 (S10) 444-7688 JOHN G. COWPERTHWAITE, CSB# 96375 jcowperthwaite@bsralaw.com ENNETT, SAMUELSEN, REYNOLDS & ALLARD A Professional Corporation Attorneys at Law 1301 Marina Village Parkway, Suite 300 Alameda, California 94501-1084 Telephone: Bt 0 444-7688 ELECTRONICALLY FILED Superior Court of California, County of San Francisco MAR 22 2013 Clerk of the Court Facsimile: (510) 444-5849 BY: WILLIAM TRUPEK Deputy Clerk Attorneys for Defendant SLAKEY BROTHERS, INC. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO ROBERT ROSS and JEAN ROSS, NO. CGC-10-275731 Plaintiffs, AMENDED DECLARATION OF RICHARD L, REYNOLDS IN vs. SUPPORT OF MOTION FOR SUMMARY JUDGMENT C.C. MOORE & CO., ENGINEERS, et al. Date: May 14, 2013 Defendants. Time: 9:30 a.m. / Dept.: Trial Date: June 10, 2013 1, Richard L. Reynolds, declare: 1. lam an attorney licensed to practice law before all the Courts of the State of California and am a member of the Law Firm of Bennett, Samuelsen, Reynolds and Allard, counsel for defendant Slakey Brothers, Inc. in the above-entitled matter. The following facts are within my personal knowledge and if called as a witness | would be competent to testify thereto. 2. | represented defendant Slakey Brothers, Inc. as counsel of record in the matter of Annah K. Coe, ef al. v. Qwens-Coming Fiberglas Corporation, et al. filed in the Superior Court of the State of California in and for the City and County of San Francisco, Action Number 948807. 1+ DECLARATION OF RICHARD L. REYNOLDSOo OD DR UW B&B WB Bm —_ oa BENNETT, SAMUELSEN, A PROFESSIONAL CORP, 1307 MARINA VILLAGE PARKWAY, | SUITE 300 ALAMEDA, CA 94501-1084 (510) 444-7688 3. In the matter of Annah K. Coe, et al. V Owens-Coming Fiberglas Corporation et _al., the deposition of Henry W. Howard was taken at Tooker & Antz , Certified Shorthand Reporters, 131 Stuart St., Suite 201, San Francisco, California on January 6, 1994. | personally attended said deposition as counsel of record for Defendant Slakey Brothers, inc. During the course of said deposition, Mr. Howard was questioned by plaintiffs counsel concerning the declaration Mr. Howard signed on November 17, 1993, in support of Slakey Brothers’ Motion for Summary Judgment in the Annah K. Coe matter. A true and correct copy of said declaration about which he was questioned and that was referred to and reviewed by Mr. Howard at the time of his deposition is attached hereto as Exhibit A. 4. Mr. Howard's deposition testimony concerning said declaration was recorded at page 9, lines 7 through 17 of said deposition transcript and a true and correct copy of that portion of the deposition transcript is attached hereto as Exhibit B. Exhibit B is Mr. Howard’s testimony that he gave under oath in my presence. 5. In the Annah K. Coe matter | submitted a declaration in support of Defendant Slakey Brothers Inc.'s reply to Plaintiff's Supplemental Opposition to Motion for Summary Judgment and deciared that | had obtained copies of excerpts from local telephone directories showing that Slakey Brothers Oakland, Inc., and its various related companies in the San Francisco Bay Area, held themselves out as the entities they purported to be. Attached hereto as Exhibit C are true and correct copies of the excerpts from the local telephone directories that | obtained at that time. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this dectaration was executed in Alameda, California on March 22, 2013. o Z / we Sol A Richard L. Reyholds -2- DECLARATION OF RICHARD L. REYNOLDS