Exhibit,Appendix: ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                PATRICIA G. ROSENBERG, SBN 154820
HAAS & NAJARIAN, LLP

58 Maiden Lane, Second Floor

San Francisco, CA 94108

Telephone: 415.788.6330

JAMES N. SINUNU, SBN 62802
JUNIPER BACON, SBN 256687
SINUNU BRUNI LLP

333 Pine Street, Suite 400

San Francisco, CA 94104
Telephone: 415.362.9700
Facsimile: 415.362.9707
jsinunu@sinunubruni.com
jbacon@sinunubruni.com

Attorneys for Defendant
MCCLURE ELECTRIC, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO-UNLIMITED JURISDICTION

ROBERT ROSS and JEAN ROSS,

Plaintiffs,

VS.

C.C. MOORE & CO. ENGINEERS:
Defendants as Reflected on Exhibit 1
attached to the Summary Complaint
herein; and DOES 1-8500.

Ne ee eee

Defendants.

1

ELECTRONICALLY
FILED

Superior Court of California,

County of San Francisco

FEB 28 2013
Clerk of the Court
BY: CAROL BALISTRERI

Deputy Cle

Case No.: CGC-10-275731

EXHIBIT B TO DECLARATION OF
JUNIPER BACON IN SUPPORT OF
DEFENDANT MCCLURE ELECTRIC,
INC.’S MOTION FOR SUMMARY
JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION

Complaint Filed: December 17, 2010
Trial Date: June 10, 2013

EXHIBIT B TO DECLARATION OF JUNIPER BACON IN SUPPOR'T OF DEFENDANT MCCLURE ELECTRIC, INC.°S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY ADJUDICATION

ekExhibit BATTORNEYS AT LAW
222 RUSH LANDING ROAD
PO BOX 6162
NOVATO, CALIFORNIA 9448-6169
{A15) 898-1 555

BRAYTON@PURCELE LLP

ALAN R, BRAYTON, ESQ., 8.B. #73685
ERIC C, SOLOMON, ESQ, S.B. #119131 eee
BRAYTONPURCELL LLP 318RM
Attomeys at Law :
222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attorneys for Plaintiffs

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS,

} ASBESTOS
Plaintiffs, }
)

No. CGC-10-275731

ANSWERS TO INTERROGATORIES
vs.

C.C, MOORE & CO. ENGINEERS, et al.

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NO: ONE

ANSWERS

1. a. ROBERT BRUCE ROSS.

b. September 9, 1935.

©. 75 years.

d. San Francisco, California.
6440 East Calle Cavillo, Tucson, Arizona 85750.
Height: 5' 11", weight: 215 pounds.
558-42-3662.
Not applicable.

= hm o

KAlnjurec\9249\pldhai-saesf Lwpd 1i, Not applicable.

je US 562 37 507.

k. 101863135.

1, Robert or Bob Rass.

m. 12" grade, 2 years junior college.
n Jean Ross.

oo. October 28, 1936.

p December 15, 1974,
q. Same as |.e., above.
r Retired.
8. Judy Osborne.
t 1963.
u. Divorced.
2. a. Diane Ross.
db. 1963.
e. Natural.

d 21058 Perrigan Drive, Bend, Oregon 97702.

€. Hairdresser.
£ Living.

3. No,

4, None.

3. Plaintiff is currently able to recall the following addresses:
present: 6440 East Calle Cavillo, Tucson, Arizona 85750.

Plaintiffs investigation and discovery are continuing.

Plaintiff completed high school, and attended 2 years of junior college.

No.

eo we ND

Plaintiff was a member of the United States Army from 1954 to 1956. Plaintiff's

KAlnjured IS349\pldwi-sagst Lwpd 2CO Oe IW DAW RF WN

RP MR N KN NY Se Se eB Be ee em ew eB
SBXRSRREESERYXSESGREWVAREEBDHAAS

service number is US 562 37 507. Please see response to Interrogatory No. 26, below.
10. Excluding plaintiff's expert consultants, plaintiff recalls the following physicians;
a, Dr. Amold Hollander.
b. 1200 North El Dorado Place, Tucson, Arizona.
c Biopsy.
d. October 2010 to the present.
e. Colon cancer.
f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a. Dr. Roger A. Davis.

b. Gastroenterolgy Associates, 1601 North Tucson, Suite 114, Tucson,
Arizona 85716.

c. Blood work, exams and treatment.

d. September 2010 to the present.

e. Tests and blood work.

f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a. Unknown at present.

b. Veterans Administration Medical Center, CBOC, 2115 Northeast Wyatt
Court, Suite 201, Bend, Oregon 97701.

c. General health maintenance exams and treatments.

d. 2010 to the present.

e. General health maintenance.

f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

KAnjured\1834%%plhwi-sacsf 1.wpd 3Ce NDA mH BR WKY

NN YN NY NY NN NY Se S| Se Be es ee eRe ee
oI A A BOW NHN = FS Gwe NI DH BF YH | SS

a. Unknown at present.

b. Cascade Family Practice, 1247 Northeast Medical Center Drive, Bend,
Oregon 97701,

c. Cancer screening, and related treatment.

d. October 2010 to the present.

e Colon cancer.

f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a. Plaintiff does not recall.
b. Queen of the Valley Hospital, Napa, California.
c. Plaintiff was treated for a kidney stone.

d. Approximately 2000.

e. Kidney stone.

f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

11. Excluding those used by plaintiff's expert consultants, plaintiff currently recalls

the following hospitals:

a. Palo Verde Surgical Associates.

b. 630 North Alvernon, Suite 180, Tucson, Arizona.

c. Surgery for colon cancer, and related care.

d. October 2010.

e. Colon cancer, surgery.

f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a, Queen of the Valley Hospital.
b. Napa, California.

KMnjured\1934%\pldiai-sacsf 1.wpd 4e

Plaintiff was treated for a kidney stone.

2 d. Approximately 2000.
ay €. Kidney stone.
4 f. Plaintiff has provided authorizations for the release of medical records to
3) Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
6 12. Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
7|| following x-rays:
8 a. Cascade Medical Imaging, address unknown.
9 b. August 29, 2005; 1 view.
10 &. Chest.
i d. Unknown.
12 @. Plaintiff's investigation and discovery are continuing.
13
4 a. Radiology Ltg, Tucson, Arizona.
15 b. December 2005.
16 © Chest.
7 d. Unknown.
18 €. Plaintiffs investigation and discovery are continuing.
19 13. Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
20 || following pulmonary function tests:
21 a. Bend Memorial Hospital, Post Office Box 1018, Bend, Oregon 97708.
22 b September 2005.
23 ©. Dr. Jacobs; David Fredstrom.
24 d Follow up for CT sean.
25 &. Unknown.
26 f. No.
27 g. Not applicable.
28 h. Plaintiff's investigation and discovery are continuing.

KAinjuedtt 9345 pldtai-ssost Lwpd 3DP DW we DR Hm Nm

14. Please see response to Interrogatory No.'s 10 and 11, above. Plaintiff defers to his
medical records as the best source of information for medications prescribed.

15. Not at this time. Plaintiff's medical records are equally available to defendants
through Berry & Berry, designated defense counsel.

16. Plaintiff has the following complaints from asbestos exposure: shortness of

breath, coughing and tiredness.

a. Unknown at present.
b. No cessation.
c. Plaintiff is currently unaware of any physical change.

d. Plaintiff contends that his lungs have primarily been affected. However,
as the lung function affeets the rest of the body, plaintiff also contends that all parts of his body
have been affected.

e.-f. Plaintiff's investigation and discovery are continuing.

g Plaintiff does not at this time contend that he has lost time from work as a
result of his asbestos related conditions. Plaintiff's investigation and discovery are continuing.

h. Not applicable.

i, Plaintiff's investigation and discovery are continuing.

17. Yes.

a-b. Plaintiff was diagnosed with colon cancer on or about October 2010, and
with asbestosis and asbestos-related pleural disease on or about May 2009.

¢.-l. Information protected by cither the attomey work-product doctrine or the
attorney-client privilege. Plaintiffs investigation and discovery ate continuing.

18. No,

19. Shortness of breath, and coughing.
20. See Interrogatory No. 10, above.
21. Unknown.

22. Yes,

ae. Plaintiff suffered a back injury on 1973. Plaintiff's investigation and

KAinjuredht9349\pidiwiesaest F expe 6DO OD Sm th om WM

moN BD MM MM Nm me eet
Se QA A BF HW DW Se SB Oo ew NR HW BBN mm &

discovery are continuing.
23, Yes,
a. Plaintiff recalls smoking from 1950 to 1983,
b, Plaintiff recails smoking cigarettes. Plaintiff inhaled.
c. Plaintiff recalls he usually smoked approximately 20 cigarettes per day.
d. Plaintiff recalls he usually smoked 1 pack of cigarettes per day.
8 Plaintiff recalls smoking Lucky Strike, Camel, Kool, Kent and Marlboro

brand cigarettes.

f. No.
24. Yes.
a Gordon Ross, plaintiff's father.

b. 1935 to 1953.
G Raleigh brand cigarettes.
d. Unknown.
25. Plaintiff recalls first consuming alcoholic beverages at age 15. Plaintiff stopped
drinking approximately 25 years ago, and currently does not consume alcoholic beverages.

26. Plaintiff is currently able to identify the following employment information:

Location of Exposure
Employer Exposure Job Title Dates
General Mills Company General Mills Warehouseman 1952-1/1954;
P.O, Box 1113 Vallejo, CA 2/1956-6/1986

Minneapolis, MN

Job Duties: Plaintiff worked in the feed mill. Plaintiff swept floors. Plaintiff is currently
unaware if he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Tithe Dates
United States Army Fort Ord, Monterey,CA; Infantryman 2ANS4- 1/27/56
United States Army

Okinawa, Japan

Job Duties: Plaintiff served in the United States Army as an infantryman. Plaintiff served at For
Ord, Monterey, Catifornia, for 16 weeks, and the remainder of his time in Okinawa, Japan.
Plaintiff performed maneuvers and combat exercises. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.Do em YW BR ww Rw NF

Se UB aan bk oN OS

20

Location of Exposure

Emplover Exposure Job Title Dates

A.M. Devincenzi Company A.M. Devincenzi Company Truck Driver 8/1956-2/1959:
1598 Carroll Avenue 1598 Carroll Avenue 12/1959-1/1960
San Francisco, CA San Francisco, CA (@ weeks); 9/1960

Job Duties: Plaintiff loaded and unloaded trucks. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title
San Mateo Junior College San Mateo Junior College Welder 1958-1959
San Mateo, CA San Mateo, CA (Trainee)

Job Duties: Plaintiff attended welding classes. Plaintiff is currently unaware if he was exposed t
asbestes during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Philip Carey Warchouse Warehouseman 2/1959-8/1959;
Cineinnati, OH 101 Wilhams 12/1959-1/1960

San Francisco, CA (1 week)

Jack Tar Hotel

{aka Cathedral Hill Hotel)

1101 Van Ness

San Francisco, CA

Job Duties: Plaintiff unloaded boxcars full of asbestos-containing products, Plaintiff swept
floors and delivered asbestos-containing materials to job sites. Plaintiff recalls unloading or
delivering the following asbestos-containing products: PHILIP CAREY, JOHNS-MANVILLE,
OWENS CORNING KAYLO, UNIBESTOS (UNARCO), EAGLE PICHER (EAGLE-PICHER
INDUSTRIES, INC.), CELOTEX, 85% MAG cement, 301 and 352 JOHNS MANVILLE
insulating cement. Plaintiff recalls that the jobsite was very dusty and that his clothes would get
covered in dust. Plaintiff also delivered materials to various jobsites on approximately 10
oceasions. Plaintiff delivered materials to the Jack Tar Hotel in San Francisco, California.
CARILL CONSTRUCTION was the Raper contractor which employed laborers and cement
finishers at the site. ANDERSON, ROWE & BUCKLEY, INC. employed plumbers, pipefitters
and sheetmetal workers at the Jack Tar Hotel. Plaintiff recalls Philip Carey was the insulation
contractor at the Jack Tar Hotel. Plaintiff recalls Bill Houston was the Philip Carey supervisor at
the Jack Tar Hotel. Plaintiff recalls the following supervisor at the warehouse: Ray Scott,
Tucson, Arizona. Plaintiff recalls the following coworkers at the warehouse: Bill Heineche, Sr.
(deceased); Bill Heineche, Jr. (address unknown). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Plaintiff worked out of Heat & Frost Insulators and Asbestos Workers Local Union No. 16.
Plaintiff recalls applying asbestos-containing insulation to pipes, pumps, flanges, valves, duct
work, plenums, boilers and vessels. Plaintiff cut the asbestos-containing pipe insulation with a
hand saw. Plaintiff mixed asbestos cement and applied cement to fittings and irregular surfaces.
Plaintiff worked in proximity to the following trades: Plumbers, pipefitters, sheet metal workers,
electricians, sprinkler fitters, carpenters, laborers, lathers and plasterers, drywallers, floor
installers and ceiling installers. Plaintiff worked in proximity to plumbers disturbing existing
insulation and fireproofing. Plaintiff worked in proximity to pipefitters working on pumps andm oO OD wm PD HM FF BW BH

nN

Oo MN A tA Rw

BN yw YN RN
oat aw Bo H = Ss

valves, and working with asbestos-containing gaskets and packing. Plaintiff worked in proximity
to sheet metal workers disturbing existing asbestos-containing fireproofing insulation and
installing asbestas-containing flexible duct connectors, Plaintiff worked in proximity to
electricians stripping asbestos insulated wire and disturbing existing asbestos-containing
fireproofing and insulation. Plaintiff worked in proximity to sprinkler fitters disturbing existing
asbestos-containing fireproofing insulation. Plaintiff worked in proximity to laborers performin
general clean up, including sweeping up asbestos-containing debris, which caused dust. Plainti
worked in proximity to carpenters disturbing existing asbestos-containing fireproofing insulation,
Plaintiff worked in proximity to lathers and plasterers mixing asbestos containing plaster and
disturbing existing fireproofing and insulation. Plaintiff worked in proximity to drywallers
cutting drywall, taping joints, and mixing and sanding asbestos-containing joint compound,
which was a dusty process. Plaintiff worked in proximity to floor installers using a circular saw
to cut floor tiles that contained asbestos. Plaintiff worked in proximity to ceiling installers

disturbing existing asbestos-containing fireproofing insulation. Plaintiff cut asbestos containin,

insulation with a power saw and applied asbestos containing carivas and asbestos cloth. Plainti
currently contends that he was exposed te asbestos during this employment.

Location of Exposure
Emplover Exposure Job Title Dates
Coast Insulating Products Fertilizer Plant Insulator 8/1959-9/1959
Los Angeles, CA Heim, CA (Apprentice) f{approx. 5 wks)

Job Duties: Plaintiff carried materials to journeyman insulators. Plaintiff recalls working with
JOHNS-MANVILLE block insulation. Plaintiff recalls scoring and cutting the block insulation
with a handsaw. Plaintiff recalis mixing all-purpose cement and using JOHNS MANVILLE 352
BLUE cement. Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Universal Insulation Mare Island Naval Insulator 1959 (on and off
520 6” Avenue Shipyard (Apprentice) for 3 months)
Menlo Park, CA Vallejo, CA

Job Duties: Plaintiff insulated pipes under the loading docks and in the pipe hangers Plaintiff
installed asbestos-containing insulation on pipes and on the boiler in the boiler room. Plaintiff
recalls boilers manufactured by the following: FOSTER WHEELER CORPORATION and
BABCOCK & WILCOX COMPANY. Plaintiff recalls using UNIBESTOS insulation and
magnesium. Plaintiff recalls working near pipefitters installing pipes and asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked near
the installation of anew BELL & GOSSETT (ITT INDUST! INC.) pump which had _
original manufacturer's asbestos-containing gaskets wired to it. Plaintiff recalls the following

co-workers: Jack Kish (deceased), Rod Hochstrasser (deceased); Ed Fleigher (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

Employer

Universal Insulation
520 6" Avenue
Menlo Park, CA

Job Duties: Plaintiff installed asbestos-containing insulation and all-purpose cement on the
fittings. Plaintiff installed asbestos-containin|

insulation and EAGLE P:

Location of
Exposure

Hewlett Packard
Menlo Park, CA

Job Title

insulator
(Apprentice)

ig PABCO (FIBREBOA
ICHER (EAGLE-PICHER INDUSTRIES, INC.) insulation cement on

Exposure
Dates

1959 (1-2 weeks)

CORPORATION)oD we ND HW BF WN

pi es, Plaintiff recalls scoring and cutting the block insulation with a handsaw. Plaintiff recalls
laborers from ALBAY CONSTRUCTION COMPANY sweeping up MONOKOTE (W.R.
GRACE & CO.), PABCO (FIBREBOARD CORPORATION) pipecovering, and other debris,
Plaintiff recalls the following supervisor: Troy Cozby (deceased). Plaintiff recalls the following
co-worker: Rod Hochstrasser (deceased). Plaintiff currently contends that he was exposed to
asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
AC&S UC Berkeley (Central Insulator 1960 - 1962;
Lancaster, PA Steam Plant), 1965 - 1966

Berkeley, CA (1 week)

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
and PABCO (FIBREBOARD CORPORATION) block insulation, calcium silicate pipecovering,
blue cement and mag cement to a boiler. Plaintiff recalls working near other trades, including,
but not limited to: pipefitters, boiler makers, and laborers. Plaintiff worked in proximity to
boilermakers employed by Bay Cities Asbestos Co., Ltd., LTD. JAMES WHITTAKER laborers
mixed and sprayed asbestos-containing CAFCO (UNITED STATES MINERAL PRODUCTS
COMPANY) fireproofing and swept dried fireproofing overspray in plaintiff's work areas.
Electricians disturbed overhead asbestos-containing MONOKOTE (W.R. GRACE & CO.)
fireproofing while setting their conduit supports. Plaintift worked in proximity to others who
were checking, removing and replacing asbestos-containing original manufacturer’s packing in
new BELL & GOSSETT (ITT INDUSTRIES, INC.) pumps. Plaintiff recalls the following
manufacturers of asbestos products: PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY). Plaintiff worked alongside pipefitters who were installing and removing asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) and FLEXITALLIC,
INC. gaskets, Plaintiff recalls that CAL-STEAM SUPPLY COMPANY supplied asbestos-
containing FLEXITALLIC, INC. gaskets. Plaintiff recalls that they special ordered asbestos pipe
insulation from METALCLAD INSULATION CORPORATION. Plaintiff recalls the following
foreman: Robert Cantley (c/o Brayton%Purcell LLP). Plaintiff recalls the following co-worker:
Earl Beck (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Tidewater Associated Oil Insulator 1959-1965

Avon, CA (3 weeks)

Job Duties: Plaintiff applied asbestos containing insulation to a tank. Plaintiff applied EAGLE-
PICHER (EAGLE-PICHER INDUSTRIES, INC.) asbestos-containing cement on the heads and
fittings, Plaintiff applied KAYLO (OWENS CORNING FIBERGLAS) asbestos-containing
insulation on pipes. Plaintiff recalls using JOHNS-MANVILLE asbestos-containin|
pipecovering Plaintiff recalls the following contractors at this site: PLANT ASBESTOS
COMPANY (PLANT INSULATION COMPANY) and BAY CITIES ASBESTOS CO., LTD.
TIDEWATER REFINERY laborers swept and shoveled asbestos-containing debris near plaintift :

Plaintiff recalls the following foremen: Robert Robbins (deceased); and Allen Holbroo!
(deceased). Plaintiff recalls the following co-workers: Lou Hanson (address unknown); Robert
Robbins (deceased); Robert Sandoval (deceased); Ron Furia (deceased); and Laurance Hagen
(c/o Brayton%*Purcell LLP). Plaintiff recalls the following employees of PLANT INSULATION
COMPANY (PLANT INSULATION COMPANY): Ron Powers (c/o Brayton%*Purcell LLP);
Steve Steele (rddress unknown). Plaintiff currently contends that he was exposed to asbestos
during this employment.

10Location of Exposure

Employer Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Insulator 1/1960-7/1960
3150 3 Street Pittsburg, CA

San Francisco, CA

Job Duties: Plaintiff worked on new construction. Plaintiff mixed asbestos-containing
insulating cement and scored asbestos blocks with a saw. Plaintiff used asbestos-containin
JOHNS-MANVILLE pipecovering, EAGLE PICHER cement and all-purpose cement at this site.
Plaintiff installed asbestos-containing insulation on equipment and pipes, Plaintiff worked near
refractory workers from J.T. THORPE & SON, INC. who were installing asbestos-containin,
block, cements and refractory materials in the boilers. Plaintiff worked near boiler makers who
he recalls were from J.T. THORPE & SON, INC. Carl Ramsey (c/o Brayton%*Purcell LLP) was
a member of the J.T. THORPE & SON, INC. crew. Plaintiff worked near welders using
asbestos-containing welding blankets, laborers sweeping up the site and pipefitters installing
gaskets, valves and pipes. Thurman Gates (deceased) was Plaintiff's supervisor. Plaintiff recalls
the following co-workers: Charles Purcell (deceased), Jack Kish (deceased); John Hoyt (c/o
Brayton**Purcell LLP); Donald Cox (c/o Brayton‘ Purcell LLP); Ed Story (deceased); Charlie
Power (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Queen of the Valley Insulator 7/1960 (3 weeks)
3150 3" Street Hospital
San Francisco, CA Napa, CA

Job Duties: Plaintiff removed and replaced asbestos-containing ceiling tiles in order to install
insulation. Plaintiff recalls that some of the ceiling tiles would break when he tried to remove
them, causing a cloud of dust. Plaintiff insulated pipes in the boiler room with asbestos-
containing JOHNS-MANVILLE pipecovering and all purpose cement. Plaintiff recalls the
following co-worker: Jim White, Jr., Napa, California. Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Heat, Frost & Asbestos Maritime Union Insulator Approx. 1960
Workers Union Mission Street (1 day)
Local 16 San Francisco, CA

Job Duties: Plaintiff insulated domestic hot water pipes and ducts. Plaintiff used asbestos-
containing UNIBESTOS (UNARCO) pipecovering. Plaintiff recalls the following supervisor:
Richard Holmes (deceased). Plaintiff recalls the following co-workers: John Chulick (c/o
Brayton**Purcell LLP); Ron Furia (deceased): Charles Tobey (c/o Brayton**Purcell LLP);
Charlie Power (deceased); James Kearney, (deceased); Roger Fonken velo Brayton**Purcell
LLP); Donald Cox (c/o Brayton%*Purcell LLP). Plaintiff currently contends he was exposed to
asbestos during this employment.

it
itt

11- © GC ww HR HW BF YN &

oe
CO wo NS A wu B&B WW

NR N YPM MW NH YY
oN A A BR NM Ee SO

Location of Exposure
Employer Exposure Jeb Title Dates
Western Asbestos McKinleyville High School Insulator 7/1961-10/1961;
3150 3” Street McKinleyville, CA 7/1962-5/1965
San Francisco, CA (3 % weeks, on
and off}

Job Duties: Plaintiff worked at this site multiple times for about three and % weeks total during
the new construction of the high school. Plaintiff applied asbestos-containing JOHNS-
MANVILLE mag pinecovering and used all purpose cement for the fittings. FRANK M.
BOOTH and BRIZARD CONSTRUCTION pipefitters and sheetmetal workers disturbed
previously sprayed asbestos-containing MONOKOTE (W.R. GRACE & CO.) overhead

reproofing while setting pipe supports and duct supports in plaintiff's work areas, FRANK M.
BOOTH personnel cut and installed asbestos-containing flexible duct connectors next to plaintiff]
and his crew. Plaintiff recalls working near laborers empleo ed by FRANK M. BOOTH who
performed clean-up and sweeping and CALIFORNIA D YWwal drywall hangers, tapers and
sanders. Plaintiff recalls the following co-worker: Harold Smith (deceased). P' aintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Calaveras Cement Plant Insulator 1961-1965
3150 3" Street Redding, CA (1 month)

San Francisco, CA

Job Duties: Plaintiff worked on a new addition te the plant. Plaintiff applied asbestos-
containing EAGLE PICHER cement and chicken wire. Plaintiffrecalls working near pipefitters
who were installing pipes, valves and gaskets. Plaintiff recalls working near others using
asbestos blankets. Plaintiff recalls the following supervisor: Tiny Evans (deceased). Plaintiff
recalls the following co-workers: Clark “Rags” Purcell (deceased); Doyle Davidson (deceased);
Earl Riggs (deceased); Hank Meyers (deceased), Donald Cox (c/o Brayton4*Purcell LLP);
Richard Gross (deceased). Plaintiff currently contends that he was exposed to asbestos during
this employment,

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Tidewater Oil Company Insulator 1961-1962
3150 3" Street Avon, CA (Approx | month)

San Francisco, CA

Job Duties: Plaintiff recalls insulating pipes and vessels. Plaintiff used asbestos-containin
EAGLE PICHER cement, and asbestos-containing KAYLO (OWENS CORNING FIBERCLAS)
block insulation, Plaintiff worked near laborers, were employed by PLANT MAINTENANCE
(PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping existing asbestos-
containing pipe insulation, sweeping up the site and carrying products to the workers. PLANT
ASBEST! OMPANY (PLANT INSULATION COMPANY) personnel were applying _
asbestos-containing PABCO (IBREBOARD CORPORATION) calcium silicate pipecovering
near plaintiff for approximately 3 days. Plaintiff saw CROCKETT ELECTRIC electricians
performing electrical work in his work areas. Plaintiff worked alongside pipefitters who were
installing and removing asbestos-containing FLEXITALLIC, INC. gaskets. Plaintiff recalls the
follewing co-workers; Lou Hanson (address unknown); Robert Robbins (deceased); Robert
Sandow (deceased), Plaintiff currently contends that he was exposed to asbestos during this
employment. :

12CD me IO HH BW Ww

Location of Exposure

Employer Exposure Job Title Dates
Western Asbestos Monsanto Chemical Insulator 1961-65 (Approx
3150 3" Street Avon, CA 1 month)

San Francisco, CA

Job Duties: Plaintiff worked on an addition to the plant. Plaintiff cut and installed calcium
silicate block insulation on a vessel using asbestos-containing CHILDERS Fibrous Adhesive to
adhere the block. Plaintiff flat troweled asbestos-containing EAGLE PICHER cement on the
vessel. Plaintiff installed asbesios-containing JOHNS-MANVILLE pipecovering. Plaintiff’s co-
workers included Robert Robbins and Leo Hansen (both deceased). Plaintiff currently contends
that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Insulator 1961-1965
3150 3” Street Pittsburg, CA (3 months)

San Francisco, CA

Job Duties: Plaintiff recalls installing asbestos pads and asbestos-containing JOHNS-
MANVILLE insulation. Plaintiff recalls using asbestos-containing EAGLE PICHER cement.
Plaintiff recalls J.T. THORPE & SON, INC. was the refractory contractor at this jobsite.
Plaintiff recalls that the asbestos-containing materials listed above were supplied by WESTERN
ASBESTOS COMPANY and J.T. THORPE & SON, INC., were used at this worksite. Plaintiff
recalls other trades working on a BABCOCK & WILCOX boiler. Plaintiff worked near
electricians employed by CONTRA COSTA ELECTRIC, INC who were disturbing asbestos-
containing pipe insulation while installing conduit. Plaintiff recalls maintenance personnel from
PG&E were removing asbestos-containing materials from this boiler. Plaintiff recalls working
near pipefitters who were removing asbestos from pipes. Plaintiff also recalls other trades
sweeping the area where he was working. Plaintiff recalls the following co-workers: Earl Riggs
(deceased); Doyle Davidson (deceased); Ed Story (deceased); Ronald Furia (deceased); Jack
Jageda (c/o Paul & Hanley); Harry Fry (foreman) (deceased); Donald Cox (c/o Brayton%Purcell
LLP); Derrell Cozby (c/o Brayton%*Purcell LLP). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Golgate Palmolive Insulator 7/1961-10/1961;
3150 3" Street Berkeley, CA 7/1962-5/1965
San Francisco, CA Gyreeks. on and
0:

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE Pipecovering, and
asbestos-containing EAGLE PICHER and 301 cement onto a tank. Plaintiff used mag insulation]
JOHNS MANVILLE 352 BLUE cement. Plaintiff recalls working near COLGATE
PALMOLIVE laborers sweeping around his work area. Plaintiff recalls the following contractor:
PACIFIC MECHANICAL, Plaintiff observed L.J. KRUSE COMPANY pipefitters handling
asbestos-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets.
Plaintiff observed L.J. KRUSE repacking one new valve using asbestos-containing valve packing|
material. Plaintiff recalls the following supervisor: Robert Robbins (deceased). Plaintiff recalls
the following co-workers: Lowell Squires (deceased); Jim White, Jr. (Napa, California); Lou
Hansen (deceased); Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

13Oo Uw FW A WP WwW LD

Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos Gerber Foods Insulator 7/1961-10/1961;

3150 3" Street Oakland, CA 71962-51965

San Francisco, CA (3 weeks, on and
off)

Job Duties: Plaintiff wrapped asbestos-containing insulation with chicken wire and applied all-
purpose cement over it. Plaintiff applied asbestos-containing JOHNS MANVILLE calcium
silicate pipecovering and insulation cements. Plaintiff appli¢d JOHNS MANVILLE 352 BLUE
cement, Plaintiff worked near pipefitters installing pipes valves and asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff recalls the
following co-workers: Bennie Norrie (deceased), Lou Hansen (deceased); Robert Robbins
(deceased), Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Ampex Systems Corp. Insulator 1961-1962 (2-3
3150 3" Street Redwood City, CA weeks, on and off}

San Francisco, CA

Job Duties: Plaintiff worked in proximity to DOUGLASS INSULATION pipefitters who were
appli calcium silicate material. Pipefitters dismantled a chiller, removing asbestos-containing|
ARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff observed
pipefitters working on a pump, which involved replacement of asbestos-containing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff recalls the following co-
workers: Everett Waining (San Jose, California); Jim Keamey (deceased); Jim White, Jr. (Napa,
California). Plaintiff currently contends that he was exposed to asbestos during this employment,

Employer Location o Exposure
Exposure Job Title Dates

Western Asbestos Pacific Bell Telephone Insulator 1961-1965

3150 3” Street San Francisco, CA G months)

San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct wrap and asbestos-containing MUNDET 85%
magnesia pipe insulation in an & story building. Plaintiff worked in the boiler room where
asbestos insulation was being removed and installed Plaintiff worked near laborers who were
sweeping the floors and_pipefitters who were installing and removing asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked in
roximity to FOLEY ELECTRIC electricians. Plaintiff recalls the following supervisor, John
Erraba ( ceased). Plaintiff recalls the following co-workers: Pancho, and Ron Powers (c/o

Brayton**Purcell LLP). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Insulator 1961-1965
3150 3" Street Antioch, CA (5-6 months)

San Francisco, CA

14CO OM NM DR Bw Ne

ho wo mM RR NN eee
BOR RRESS SB SBA ADE OST S

Job Duties: Plaintiff worked on new construction. Plaintiff delivered materials to this worksite.
Plaintiff installed asbestos-containing block insulation with chicken wire over the top of it.
Plaintiff used 352 CANADIAN BLUE asbestos shorts, 127 Blue Cement 85% magnesia cement
and EAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.} 66 cement. Plaintiff also applied
asbestos-containing PABCO (FIBREBOARD CORPORATION and OWENS CORNING
FIBERGLAS asbestos pipe insulation to flanges on a boiler. Plaintiff recalls that the asbestos-
containing PABCO and OWENS CORNING asbestos pipe insulation was supplied by PG&E.
Plaintiff recalls general contractor C.C. MOORE employing laborers. Plaintiff recalls seeing
others working on STOCKHAM valves and strainers which had asbestos-containing ANCHOR
packing on them. Plaintiff recalls working near boilermakers, employed by BABCOCK &
WILCOX who were installing the boiler and near employees from J.T, THORPE & SON, INC.
whe were installing the refractory materials inside the boiler, and working on turbines. Plaintiff
recalls working near electricians from CONTRA COSTA ELECTRIC who were disturbing
asbestos materials while walking on asbestos insulated piping, two to three feet from plaintiff.
Plaintiff recalls working near insulators from OWENS CORNING FIBERGLAS. Plaintiff
recalls the following supervisor: Thurman Gates (deceased). Plaintiff recalls the following co-
workers: Ron Powers (c/o Brayton Purcell LLP); Jim White, Jr. (Napa, California); Bill
Armstrong (deceased); Ronald Furia (deceased); John Hoyt (c/o Brayton%+Purcell LLP); Art
Klimack c/o Brayton%Purcell LLP; Al Leandro (c/o Brayton%Purcell LLP); Walter Lee (c/o
Brayton‘*Purcell LLP); Derrell Cozby (c/o Brayton*Purcell LLP); Maurice Lawrence (c/o
Brayton% Purcell LLP); John Kiss (deceased), Paul Westbrook (c/o Brayton**Purcell LLP); Carl
Ramsey (c/o Brayton%* Purcell LLP); Dick Nelson (deceased). Plaintiff currently contends that
he was exposed to asbestos during this employment.

Location of Exposure
Emplover Exposure fob Title Dates
Western Asbestos Hercules Powder Insulator 7/1961-10/1961;
3150 3 Street Hercules, CA 7/1962-5/1965
San Francisco, CA Garon, on and
o

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS pipecovering |
Plaintiff worked alongside pipefitters who were installing and removing FLEXITALLIC, INC.
gaskets in plaintiff's presence. Plaintiff worked in proximity te METALCLAD INSULATION
CORPORATION insulators who were applying asbestos-containing thermal insulation. Plaintiff!
recalls the following supervisor: Lowell Squires (deceased), Plaintiff recalls the following co-
workers: Jim White, Jr. (Napa, callfomie)s Lou Hanson (address unknown): Carl Ramsey (c/o
Brayton Purcell LLP); Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Georgia Pacific Insulator 7/196 1-10/1961;
3156 3” Street Arcata, CA 711962-5/1965
San Francisco, CA (2-3 months, on
and off}

Job Duties: Plaintiff removed asbestos-containing PABCO and JOHNS MANVILLE block
insulation that was covered in 352 BLUE cement and black mastic from a large vessel at a
particle board mill. Plaintiff applied asbestos-containing JOHNS MANVILLE and PABCO
lock to a tank. Plaintiff insulated a boiler and related pipes. Plaintiff worked alongside
GEORGIA PACIFIC maintenance personnel who were sweeping and cleaning asbestos laden
dust and debris from asbestos-containing block insulation. Plaintiff recalls the following
supervisor: Robert Evans (deceased). Plaintiff recalls the following co-workers: Howard

152 OD WR A

Jchnson (deceased), Jim White, Jr., (Napa, California); Donald Cox (c/o Brayton**Purcell LLP);
Edward Meyer (c/o Brayton%Pureel! LLP); Charlie Power (deceased); Myron Jorgenson
(deceased), Charles Purcell (deceased); Earl Riggs (deceased); Doyle Davidson (deceased);
Harry Fry (deceased); Robert Evans, Ray House (deceased). Plaintiff currently contends that he
was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates

Western Asbestos Bethichem Steel Insulator FAG -10/1961;
3150 3" Street Shipbuilding 7/1962-5/1965
San Francisco, CA San Francisco, CA
Triple A Machine Shop (on and off for
ier 64) approx. | week
an Francisco, CA each time)

Willamette Shipyard
Richmond, CA.

Pacific Ship Repair
Pier 36)
an Francisco, CA

Todd Shipyard
Oakland, CA

Matson Navigation
Pier 30)
-San Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH P. KENNEDY
IR-(DD-830)

CHEYENNE (T-AG-174)

HAWAIIAN PLANTER
(1945)

GRAFFIAS (AF-29)
MATHEWS (AKA-96)
MERRICK (AKA-97)
TWINING (DD-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY (1952)
BLAND (APA-134)

16Oo UM wm NK OW Fk BW oN

Oo oe NA A BR YN

yboN & NRHN NN WY
oT a vA BR YM NM es S

Employer Location of . Exposure
Exposure Job Title Dates

Western Asbestos (contd.) PONTCHARTRAIN Insulator 7/1961-10/1961;
(WPG-70) 7/1962-5/1965

CALIFORNIAN (1946)

AMERICAN ROBIN 1963 - 1965
(1943)

: ROSE KNOT(1945)
HAWATIAN (1946)

Job Duties: Plaintiff insulated pipes, turbines, valves, and boilers using asbestos-containing
JOHNS MANVILLE and PABCO (FIBREBOARD CORPORATION) block and pipecovering.
Plaintiff removed and repaired asbestos-containing insulation. Plaintiff used asbestos cloth to
wrap around valves and boilers. Plaintiff recalls using EAGLE PICHER cements and 352 BLUE
MUD cement. Plaintiff worked near pipefitters who were removing asbestos-containing
insulation and who were installing pipes, asbestos-containing gaskets, valves and pumps.
Plaintiff recalls pipefitters in his work area installing asbestos-containing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) gaskets and cutting gaskets from sheet gasket
material. Plaintiff recalls welders using asbestos cloth during the course of their work. Plaintiff
worked near the FOSTER WHEELER boilers aboard the HAWAIIAN PLANTER, the
GRAFFIAS, the MATHEWS, the MERRICK, the GENERAL W.A. MANN, the MONTEREY
and the ROSE KNOT. Plaintiff observed other workers installing and removing asbestas-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) and/or
FLEXITALLIC, INC. gaskets aboard several of these ships. Plaintiff observed shipyard
rsonnel including TRIPLE A personnel who were tearing off asbestos-containing thermal

insulation and who were sweeping and cleaning asbestos-containing debris in plaintiff's

resence. Plaintiff recalls the foll lowing coworkers: Tom Andrews (c/o Brayton%*Purcell] LLP);

joseph O’ Balle (c/o Brayton*Purcell LLP); Jack Barbera (address unknown); Gene Bennett,
Vacaville, California; Rudolph Brajkovick (deceased); John Byron (address unknown); Robert
Evans (deceased), Harry Fry (deceased); Ronald Furia (deceased); Thurman Gates (deceased);
Victor Gomez (c/o Brayton®*Purcell LLP); Bill Green, Sr. (deceased); Bill Green, Jr. (deceased);
Ronald Grist, Newark, California; Bill Heinicke (deceased); Frank Howard (deceased); John
Jagoda, Martinez, California; Myron Jorgensen (address unknown); Harvey Jorgensen (address
unknown); James Logue (c/o Brayton*Purcell LLP); Tony Topes, Fremont, California: Andy
Grant (address unknown), Richard Porter (address unknown); Joseph Sandoval (deceased);
Robert Sandoval (deceased); William Stein (address unknown); Ed Story (deceased); Fre:
Strickland (deceased), Howard Tracy (deceased), Jack Kish (deceased); Paul Schiebold (San
Francisco, California); Dale Wright (Santa Rosa, California): Andy Grant (address unknown);
Lowell Squires (deceased); Jim White, Jr. (Napa, California); Benjamin Norrie (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Emplover Exposure Job Title Dates
Western Asbestos Grace Cathedral Insulator F/1961-10/1961;
3130 3” Street San Francisco, CA 7/1962-5/1965
San Francisco, CA. Cok on and
o

Job Duties: Plaintiff worked in a crawl space under the building and had to drag equipment to
the plumbing pipes that he was insulating. Plaintiff recalls that the area was dusty and that his

1?Oo WM A HM Be WY NM

= 6

12

clothes and skin were covered with dust. Plaintiff used asbestos-containing PABCO
({FIBREBOARD CORPORATION) cal sil pipe insulation, FOSTERS 30-36 mastic and JOHNS-
MANVILLE 301 cement. Plaintiff recalis the following foreman: Paul Schiebold (San
Francisco, California). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Western Asbestos Pad Insulator 7/1961-10/1961;
3150 3” Street Shop, 3” Avenue and 7/1962-5/1965
San Francisco, CA Army, San Francisco, CA (2 -3 days, on and
off)

Job Duties: Plaintiff made asbesios pads to be installed on ships. Plaintiff recalls the following
supervisor; Bill Green, Sr. (deceased). Plaintiff recalls the following co-worker: Leo Hughes
(deceased); Jorgy Jorgensen (deceased); Paul Schiebold (San Francisco, California). Plaintiff
currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure dob Title Dates
Western Asbestos PG&E Nuclear Powerhouse Insulator 7/1961-10/1961;
3150 3° Street Humboldt County 711962-12/1962
San Francisco, CA Eureka, CA (5 months, on and
off)

Job Duties: Plaintiff carried asbestos-containing materials to co-workers. Plaintiff applied
asbestos-containing mag blocks and pipecovering to pipes valves and vessels. Plaintiff installed
352 cement and FOSTER’s Fibrous Adhesive. Plaintiff used asbestos-containing JOHNS-
MANVILLE, UNIBESTOS (UNARCO until June 1962; PITTSBURGH CORNING
CORPORATION from July 1962), PABCO (FIBREBOARD CORPORATION) and 48
insulation. Plaintiff recalls the following foreman: Ed Story (deceased), Plaintiff recalls the
following co-workers: Harry Fry (deceased); Donald Cox (c/o Brayton%*Purcell LLP}; Ronald
Furia (deceased), Howard Johnson (deceased); Charles Tobey (c/o Brayton%*Purcell LLP); Doyle
Davidson (deceased); Earl Riggs (deceased); Richard Gross (deceased). Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PORE Insulator 7/1961-10/1961;
3150 3" Street San Francisco, CA 7/1962-12/1962
San Francisco, CA {Potrero Station} (2 weeks)

7/1961-10/1961;
F196 2-5/1965
(2 to 3 weeks, on
and off}

Job Duties: Plaintiff recalls working on a boiler during a remodel. Plaintiff recalls applying
KAYLO (OWENS CORNING FIBERGLAS) asbestos blocks and PABCO (FIBREB!
CORPORATION) all-purpose cement. Plaintiff worked near employees from PG&E who were
sweeping and cleaning asbestos laden dust and debris in his area. Plaintiff recalls the following
supervisor: John Straba (deceased). Plaintiff currently contends that he was exposed to asbestos
during this employment. .

18oO OD SP SON HR me ON

hone

13

Lecation of Exposure

Employer Exposure Job Title Dates

Western Asbestos Dow Chemical Insulator 7/1961-10/1961;

3150 3" Street Pittsburg, CA 7/1962-5/1965

San Francisco, CA (1 month, on and
off)

Job Duties: Plaintiff carried materials to the journeymen. Plaintiff applied KAYLO (OWENS
CORNING FIBERGLAS) asbestos blocks, PABCO (FIBREBOARD CORPORATION) cement
and 352 BLUE cement. Plaintiff recalis working near pipefitters installing pipes, valves, pumps
and FLEXITALLIC, INC. gaskets. Plaintiff recalls the following foreman: Robert Robbins

deceased Plaintiff recalls the following co-workers: Lou Hansen (deceased); Robert Sandoval
deceased); Charles Tobey (c/o Brayton“*Purcell LLP); Earl Riggs (deceased); Doyle Davidson
deceased), Plaintiff currently contends that he was exposed te asbestos during this employment.
Location of Exposure
Employer Exposure dob Title Dates
Western Asbestos Shell Off Insulator 7/1961-10/1 961;
3150 3 Street Martinez, CA 711 962-5/1 965
San Francisco, CA eareeks, on and
°

Job Duties; Plaintiff cut asbestos block insulation and mixed and applied insulating cement.
Plaintiff worked with asbestos-containing insulating products manufactured by JOHNS-
MANVILLE, and with KAYLO (OWENS CORNING FIBERGLAS) . Plaintiff recalls working
near pipefitters from FOLEY-PML installing pipes, new LUNKENHEIMER valves, pumps and
asbestos-containing DURABLA (DURABLA MANUFACTURING COMPANY, INC.) gaskets.
PLANT ASBESTOS COMPANY PLANT INSULATION COMPANY) supplied asbestos-
containing insulation materials, including PABCO pipe-covering to the site, Plaintiff recalls the
following foreman: Robert Robbins (deceased). Plaintiff recalls the following co-workers: Lou
Hansen (aeceased): Jim White, Jr. (Napa, California); Charles Tobey (c/o Brayton“*Purcell
LLP); Robert Sandoval (deceased); Ed Meyer (ee Brayton%*Purcell LLP); Hank Meyers
{address unknown). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 7/1962- 12/1962
San Francisco, CA (2 weeks, on and
e

Job Duties: Plaintiff removed asbestos block insulation and existing insulation on a boiler.
Plaintiff mixed asbestos cement in a trough with a hoe. Plaintiff installed asbestos-containing
PABCO cement. Plaintiffrecalls working near boilermakers, and near pipefitters who were
installing gaskets. Plaintiff observed PG&E laborers sweeping and cleaning asbestos laden dust
and debris in plaintiff's work areas. Plaintiff recalls the following supervisor: Benjamin Norrie
(deceased). Plaintiff currently contends that he was exposed to asbestos during this employment.

i
Ut

19Oo 26 em WY WH A YN

=
Co Me WA AW & BN

20

Location of Exposure
Em C Exposure dob Title Dates
Western Asbestos Vallecitos Atomic Insulator 7/1961-10/1961;
3150 3" Street Laboratory 711962-5/1965
San Francisco, CA Pleasanton, CA oes on and
0:

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
block insulation, KAYLO (OWENS CORNING FIBERGLAS) pipecovering, 352 cement,
EAGLE-PICHER INDUSTRIES, INC. 66 mud, and new LUNKENHEIMER COMPANY
valves. Plaintiff had to crawl into tight areas that contained loose asbestos insulation. Plaintiff
worked near pipefitters installing pipes, valves, and asbestos-containing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) and FLEXITALLIC, INC. gaskets. Pipefitters
also were cutting and installing- packing into LUNKENHEIMER valves. Plaintiff recalls the
following supervisor: Benjamin Norrie (deceased), Plaintiff recalls the following co-workers:
Lou Hansen (deceased); Robert Sandoval (deceased); Ed Meyer (c/o Brayton%*Purcell LLP),
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Expesure
Employer Exposure Job Title Dates
Western Asbestos Missile Base Insulator 7/1961-10/1961;
3150 3" Street Live Oak, CA 7/1962-S/1965
San Francisco, CA QO month, on and
off}

Job Duties: Plaintiff applied rubber insulation and $20 mastic, Plaintiff worked near other
tradesmen who installe asbestos-containing ANCHOR acking, and asbestos-containing
DURABLA (DURABLA MANUFACTURING COMPANY, INC.) gaskets. Plaintiff worked
near welders who were using asbestos blankets. Plaintiff worked near electricians and near

ipefitters who were installing pipes, asbestos-containing DURABLA (DURABLA
MANUFACTURING COMPAN ; INC.) gaskets, and pumps. Laborers built scaffolds and
swept asbestos: containing PABCO insulation debris, created by PLANT ASBESTOS
COMPANY (PLANT INSULATION COMPANY), in plaintiff's work areas. PLANT
ASBESTOS COMPANY (PLANT INSULATION COMPANY) employed another insulation
crew that was applying asbestos-containing PABCO pipe insulation 5 to 30 feet from plaintiff.
Plaintiff recalls the followin supervisor: Jim Clark (address unknown). Plaintiff recalls the
following co-workers: Donald Cox (c/o Brayton%*Purcell LLP); Dale Wright (Santa Rosa,
Califomia); Tiny Evans (deceased); Paul Brown (c/o Brayton%Purcell LLP. Plaintiff currently
contends that he was expased to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos University of California Insulator 7/1961-10/1961;
3150 3” Street Berkeley, CA 7/1962-5/1968
San Francisco, CA (Boiler Plant} (3 weeks)

Job Duties: Plaintiff worked in the boiler plant. Plaintiff applied KAYLO (OWENS CORNING
FIBERGLAS) asbestos block insulation to the boiler piping. Plaintiff recalls working near
laborers sweeping up asbestos-containing debris. Plaintiff recalls working near pipefitters
installing pipes, valves and asbestos-containing GARLOCK (GARLOCK SEALING

TECHNO IES, LLC) gaskets. BAY WESTERN was a contractor employing pipefitters
removing asbestos-containing pipe insulation. Plaintiff recalls the following coworkers: Lou

20Location of Exposure
Employer Exposure Job Title Dates
| Western Asbestos Standard Oil Insulator 7/1961-10/1961;
| 3150 3" Street Richmond, CA 7i1962-5/1965
| San Francisco, CA (3 weeks, on and
off)

i {address unknown). Plaintiff recalls the following co-workers: Harry Fry (deceased); John Hoyt,
| Powers (c/o Brayton“Purcell LLP); Ru

Location of Exposure
Employer Exposure Job Title Dates
| Western Asbestos Shell Oi Insulator 7/1961-10/1961;
| 3150 3 Street Martinez, CA 7/1962- 12/1962
San Francisco, CA gyeeks. on and
0.

Hanson (address unknown); Robert Robbins (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Emplover Exposure Job Title Dates
Wes