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

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                                LAW BTNICES

. LLP

SURTE 1308

KEENEY & CORDERY.

IMAI, TADLOCK,

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Bruce Imai, Esq. (Bar Ne. 053800}
Tina Yim, Esq, (Bar No. 232597)

IMAI, TADLOCK, KEENEY & CORDERY, LLP

100 BUSH STREET, SUITE 1300
SAN FRANCISCO, CA 94104
Telephone: (415) 675-7000
Facsimile: (415) 675-7008

Attorneys for Defendant
COMMATR MECHANICAL SERVICES

IN THE SUPERIOR. COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION... °

ROBERT ROSS and JEAN ROSS,

Plaintiffs,

cc. MOORE & CO, ENGINEERS, et aL.

Defendants:

. Date: May 9, 2013

Attached is EXHIBIT L PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN
SUPPORT OF COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY
JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT.

ELECTRONICALLY
FILED

. Superior Court of California,
County of San Francisco

FEB 25 2013

Clerk of the Court
BY: ALISON AGBAY
Deputy Clerk

CASE NO:: CGC-10-275731
(ASBESTOS)

EXHIBIT L PART 2 OF 2 TO THE
DECLARATION OF TINA YIM IN SUPPORT
OF COMMAIR MECHANICAL SERVICES’
MOTION FOR. SUMMARY JUDGMENT OR,
IN THE ALTERNATIVE, SUMMARY
JUDGMENT

Time: 9:30 am.
Dept: 503 -
Judge: Hon. Teri L. Jackson

Complaint Filed: “December 17, 2010
Trial Date: Time 10, 2013

EXHIBIT LPART 2 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF COMMAIR
MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
SUMMARY JUDGMENTLAW OFFICES

3, LLP

Botte 15.

KEENEY & CORDERY

IMAI, TADLOCK,

(413) 675-7900

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PROOF OF SERVICE

- I, Heather Cherry, declare:

- Tam aresident of the State of California and over the age ‘of eighteen years, and not a
party to the within action; my business address is 100 Bush Street; Suite 1300, San Francisco, CA
94104. On the date of execution below, i served the within documents:

EXHIBIT L PART 2. OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT

. OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT:

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

by personally delivering the document(s} listed atiove’ to the person(s) at the
address(es) set forth below.

*| Gn the date of execution below, I electronically s served the document via File &

File & ServeXpress Web site.

‘Brayton Purcell, LLP

222 Rush Landing Road
Novato, CA 94945-2469

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

. Executed on February 22, 201 3, at San Francisco, California.

“Isi Heather Cherry
“Heather Cherry

-Ross, Robert and Jean v.C.C. Moore & Co. Enpineers, etal.
| SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731. °

2
ATTACHED IS EXHIBIT L PART 2 OF 2 T0 THE DECLARATION OF TINA VIM IN SUBPORT OF
COMMATR MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT OR, INTHE
ALTERNATIVE, SUMMARY JUDGMENT.

ServeXpress on the recipients designated on the Transaction Receipt located on theLast OFmCES:

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SAN FRAI

(ats) 675-7000

PROOF OF SERVICE

I, Tina Yim, declare:

Tam a resident of the State of Califomia and over the age of eighteen years, and nat a

party to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA
94104. On the date of execution below, I served the within documents:

-EXHIBIT L PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES’ MOTION FOR. SUMMARY JUDGMENT

. OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT

by transmitting via facsintile the document(s) listed above to the fax number(s) set
forth below on this date before 3:00 p.m.

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

>| by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below:

Brayton Purcell, LLP
222 Rush Landing Road
Novato, CA 94945-2469

[| On the date of execution below, I electronically served the document via File &

ServeXpress on the recipients designated on the Transaction Receipt located on the
File & ServeXpress Web site:

~. [declare under penalty of perjury under the laws of the State of California that the above
is true and correct.

Executed on February 22, 2013, at San Francisco, California.

és/ Tina Yim
_ Tina Yim

Ross, Robert and Jean v. C.C. Moore & Co. Engineers, et al.
SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731

3

ATTACHED [5 EXHIBIT L PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY’ JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY IUDGMENT.Jeb Duties: Plaintiff wrapped ducts and insulated a tank with block insulation, and BLUE MUD
cement. Plaintiff worked near laborers sweeping up debris. Plaintiff recalls the following
supervisor, Dick Saiya (Belmont, California). Plamtiff recalls the following co-workers: Gene
Thompson (address unknown); Robert Cantley, Brayton%*Purcell LLP; Berl Beck (deceased),
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Y Consolidated! Insufattor Kitpatritk Bakery Insulator [867-1865 .
517-D Marine View Ave. Oakland, CA (Foreman) (2 months, on and
Belmont, CA o

Job Duties: Plaintiff insulated pipes tanks and strainers using calcium silicate, foamelass,
fiberglass and cemenis. Plaintiff installed 301 cement on the fittings. Plaintiff used cal sil
insulation on a tank and 352 BLUE MUD cement and mastic. Plaintiff worked near pipefitters
who were installing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets.
FRANK BONETTI PLUMBING was the plumbing and pipefitting controller. GOLDEN GATE
DRYWALL, INC. employed tapers and sanders at the site who were hanging, taping and sanding;
wallboard, which they covered with asbestos-contaming joint compound. Plaintif cut into this
wallboard in order to insulate piping running through walls. Plaintiff worked near laboters who
were sweeping up debris, Plaintiff worked near sheet metal workers and electricians. Plaintiff
recalls that PLANT ASBESTOS COMPANY (PLANT INSULATION COMPANY) was
poring as an insulation contractor. Plaintiff recalls the following supervisor, Dick Satya.
Plaintiff recalls the following co-worker: Robert Cantley (c/o Brayton%Purcell LLP); Roger
Fonken (c/o Brayton*Purvell LLP). Plaintiff currently contends that he was exposed to ashestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Sandia National Laboratory Insulator W196F-3/1972
517-D Marine View Ave. Livermore, CA C_ month, on &
Belmont, CA 0

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff recalls the following supervisor:
Richard Saiya (Belmont, California). Plaintiff recalls the following co-workers: Robert Canitle

(c/o Brayion**Purceli LLP); Earl Beck (deceased); Robert Wildoner (c/o Brayton’Purcell LLP).

laintiff curently contends he was exposed to asbestos during this employment.

Location af Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Napa State Hospital Insulator 1/1967-3/1970
S17-D Marine View Ave. Napa, CA (1 month, on and
Belmont, CA off}

Job Duties: Plaintiff worked. at this site multiple times. Plaintiff wrapped ducis and installed
PABCO pipe insulation. Plaintiff had to crawl under the building in order insulate pipes and
recalls that there was asbestos insulation all over the ground and that his clothes and skin were
covered in Insulation debris. Plaintiff had to crawl through the space above the ceiling in order
to install insulation. Plaintiff recalls that COOPER BRO’ personnel would tear holes in
the plaster walls and ceiling and that thers was dust from the lath and plaster that had been torn
out, Plaint#ff recalls there was debris from the fireproofing as well as fireproofing on the beams.
Plaintiff recalls working near COOPER BROTHERS plumbers and electacians who used
wrenches and bammers to knock-off existing asbestos-containing PABCO insulation and

50MONOKOTE fireproofing while installing their cables. Plaintiff worked near sheet metal
workers who disturbed the insulation and fireproofing while installing ducts. Plaintiff recalls
working near pipefitters who he belicves were from COOPER BROTHERS while they installed
pipes and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff

estos-containing ANCHOR packing into valves.

worked next to workers who were putting ash
Plaintiff worked near tapers and drywall hang

ers from GOLDEN GATE DRYWALL, INC. who

|. disturbed overhead MONOKO
‘recaffs working near sprinter fitters instalting pipes and gaskets and disturbing the insulation in

were cutting drywall and applying and sanding joint compound, Flaintiff recalls working near
carpenters and workers worl ‘ng. on the controls A controls worker working next to plaintiff,
' Greproofing, while installing controls onte coils. Plaintiff

order to hang their pipes. Plaintiff also recalls contractor, JW & SONS. Plaintiff recalls the
following supervisors, Bob Backer, Napa, Califomia; Dick Saiya (Belmont, California); Robert
Cantley (c/o Brayton Purcell LIV: Jim White, dr. (Napa, California), Plaintiff currentiy
contends that he was exposed to asbestos during this employment.

Location of

Exposnre
Exposure

Employer Job Title Dates
Consolidated Insulation US Department of
417-D Marine View Ave, Agi pure
Belmont, CA

insulator 1/1967-3/1972
(3 weeks, on and

any, CA off}

Job Duties: Plaintiff insulated pipes and duct. Plaintiff recalls using all-purpose cement and 301
cement. Plaintiff recalls working near plumbers and pipefitiers installing pipes, valves and

askets. Plaintiff recalls working near sheet metal workers whe shot studs inte the beams,
Fnocking off the fireproofing. Plaintiff recalls working near D.W. NICHOLSON laborers
sweeping up debris, including wire gasket material and insulation mud approximately 10 feet
below plaitiff. Plamtiff recalls the following insulation contractor: PL, ASBESTOS
COMPANY (PLANT INSULATION COMPANY). Plaintiff recalls contractors: D.W.
NICHOLSON CORPORATION, COMMERCIAL AIR, and RODONI-BECKER CO., INC,
Plaintiff recalls the Jollowing supervisor: Dick Saiya (Belmont, California}. Plainti#f recalls the
following co-workers: Earl Furr (deceased); Roger Fonken (c/o Brayton®'Purcell LLP), William,
DeBere (deceased), Robert Cantley c/o Brayton’ Purcell; Richard Tobey (deceased), Plaintiff
currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Kaiser Hospital Insulator 1967-1972
517-D Marins View Ave. 2425 Geary Blvd.
Belmont, CA San Francisco, CA

Job Duties: Plaintiff applied asbestos-containing insulation to piping and ductwork during
hospital renovations. D, ZELINSKY painters also sanded the previously mudded, taped and
sanded interior walls in order to Prepare those surfaces for painting. Robert Cantley, c/o
Brayton%*Pureell LLP, was plaintifi’s supervisor at this site. Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure.
Employer oguires Job Title Dates

Consolidated Insulation
517-D Marine View Ave.
Belmont, CA

Califormia Pacific Medical Insulator
Center

San Francisea, CA

{California Street)

1

1/1967-3/1972
(2 weeks, on and
off}oo YW RH Bw Ny

Bee ee eB Bee
ny HB tr B&B we N SH &

19

Job Duties: Plaintiff installed insulation and 301 insulating cement on the fittings. Plaintiff

worked near laborers sweeping up debris and tapers ap

Plaintiff worked near

lying and sanding joint compound.
t d drywall hangers cutting and insta) Ig drywall and near s rinkler fitters
who installed pipes and gaskets. Plaintiff worked near sheetmetal workers and

near pipefitt
installing pipes, yelves and gaskets. Plaintiff observed ANDERSON ROWE & BUCKLEY
pipefitters installing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets and

removing and replacin

valve packing. Pisintiff recalls contractors ANDERSO)
BUCELEY, INC., JW. MC!

IN, ROWE &°

ENAHAN COMPANY, F.W. SPENCER & SON, INC., and

| CAHILL CONTRACTORS, INC. Plaintiff recalls the following. co-workers: Rabert Cantley

(cfo Brayton *Piicell LLP); Toseph Or palte {oo Bisyton*¥Puireell LEP}. Plainif currently
contends he was exposed io asbestos during this employment.

Employer

Consolidated Insulation
517-D Marine View Ave,
Belmont, CA

Location of
Exposure

Coast Guard Facility
Monterey, CA

Job Title
Insulator

Exposure
Dates

1/1967-3/1972.
(I week, on and
off}

Job Duties: Plaintiff insulated pipes. “Plaintiff worked in the crawl space under the building to
perform his duties, Plaintiff recalls that there was loose insulation under the building that had

come off existing pipes. Plaintiff recalls warki
Plaintiff recalls the following supervi

ng near pipefitters installing pipes and gaskets,
ior: Dick Saiya (Belmont, Califomia); plaintiff recalls the
following co-workers: Robert Cantley (c/o Brayton Purcell LLP}, Earl B

(deceased).

Plaintiff currenily contends he was exposed to asbestos ducing this employment,

Exoployer

Consolidated Insulation
517-D Marine View Ave.
Belmont, CA

Location of
Exposure

Veterans Administration

Hospital
Yountville, CA

Job Title

insulator

Exposure
Dates

1/1967-3/1972
{1 week, on and
off)

Job Duties: Plaintiff recalls laborers sweeping up debris in his area and welders who were using

asbestos blankets. Plaintiff recalis d

lL hangers cutti

and installing

drywall and tapers

applying and sanding joint compound in his work area. Plaintiff recalls pipefitters installing

pipes and gaskets. PI

laintiff recalls the following co-worker: Joseph O"Ball
currently contends he was exposed to asbestos during this employment.

Employer

Consolidated Insulation
517-D Marine View Ave,
Belmont, CA

Location af
XDOSUTE

Unknown Meat Packing
Plant
Sacramento, CA

aintiff recalls the followin: supervisor: Dick Saiya
‘Balle (c/o Brayton*Pureell LLP), Plaintiff

Job Title

Insulator

elmont, California), -

Exposure
Dates

1/1967-3/1992
{2 weeks, on and
aff)

Job Duties: Plaintiff metalled insulation on refrigeration hnes, Plaintiff used Styrofoam

insulation and all-purpose cement. Plaintiff reo:

is the following co-worker, Joseph O”Balle

(clo Brayton*Purcell LLP). Plaintiff eurrently contends he was exposed to asbestos during this

employment.
He
Mf

§2ws co OO Oe

ei
wb WwW RF oS

16

Employer

Consolidated Insulation
517-D Marine View Ave,
Belmont, CA

Job Duties: Plaintiff worked on a remodel of this facility. Plaintiff recalls installin,
duct serap laintiff recalls the followin

Location of
Expogurg

Queen of the Valley
Hospital
Napa, CA

r LEP. is currently ona ware if he‘was
Location of
Employer - Exposure
Consolidated Insulation Stonestown Shopping
417-D Marine View Ave, Center
Belmont, CA San Franciseo, CA.

ig co-worker: Jos
Was € oe

Exposure
Job Title Dates
Insulator 1/1967-3/1972,

(3 to 4 weeks, on

and off)

ig fiberglass

h O' Balle (cfo Brayton’ Purcell
asbestés during titsemployment:
Exposure
Title jes
Insulator 1/1967-3/1972,

(] month, on and

off}

Job Duties: Plaintiff recalls installing insulation and duct wrap, Plaintiff recalls working near

drywall hangers cutting and installing drywall and tapers appl:
Plaintiff recalls working near pipefitters installing gaskets, val
obert Cantley (c/9 Brayton%Purcell LLP). Plaintiff recalls the following
joseph O* Balle {c/o Brayton Purcell LLP). Plaintiff currently contends he was
exposed to asbestos during this emplo

following supervisor.
eo-worker:

Employer

Consolidated Insulation
517-D Marine View Ave,
Belmont, CA ,

ymeni.

Location of
Exposure

Napa County Hall of
Justice
Napa, CA

‘ing and sanding joint compound.
Toes and pipes. Plante recalls the

Exposure
Joh Title Dates
Insulator W1967-3/1972

3 di id
oo on ant

Job Duties: Plaintiff insulated piping and wrapped duct. Plaintiff currently contends he was
exposed to asbestos during this employment.

Employer

Consolidated Insulation
517-D Marine View Ave,
Belmont, CA

Location of

Expo sure

Kaiser Hospital
Vall ejo, CA

Exposure

Job Title Dates

Insulator 1/1967-3/1972
(3 weeks, on and
off)

Job Duties; Plaindif recalls imstalling insulation and duct wrap. Plaintiff recalls having to
remove and replace ceiling tiles to perform his job duties, Plaintiff recalls fireproofing on the
. Plaintiff applied PABCO pipe insulation and cements, Plaintiff worked near tapers

beams.
applying and sanding joint compound. Plaintiff recalls the following contractors at this site:
DU

FIRE PROTECTION and BROADWAY PLUMBING, employees were disturbing
asbestos-containing fireproofing. Plaintiff currently recalls the following supervisor, Dick Saiya
Belmont, Califorme). Plaintiff currently recalls the following

rayton Purcell LLP); Robert Cantley (c/o Brayton*Purcel
Plaimtiff currently contends he was exposed to asbestos during this employment.

iff
if

33

co-workers: Joseph O "Balle
LLP); Earl Beck (eceased),

(ofp |me

Oo wm NA BB WY

RR eee ee ee
BRR BRE S Se BARES BES

Location of Exposure

Employer Exposure Job Tith Dates

Consolidated Insulation Alta Bates Hospital Tasulator 1/1967 - 1972;

517-D Marine View Ave. Gakland, CA . 1977 - 3/1980

Belmont, CA (3 to 4 weeks, on
and off}

| Job Duties: Plaintiff worked at this facility multiple times throughout his employment with

. iene previtioty-wrtas iby MONOKOTE;
IMPERIAL PLASTERING, and NATIONAL GYPSUM. Plaintiff recalls the following
contractors: ALADDIN HEATING, GOLDEN GATE DRYWALL, INC., BARNES
CONSTRUCTION CO., EMERICK SHERT METAL CO., Plaintiff recalls the followin
supervisor: Dick Seiya Belmont, Califomia}. Plaintiff recalls co-workers: Robert Cantley (efo
Brayton Purcell LLP); Earl Beck (deceased); and Bob Wildoner (c/o BraytonPurcell LLP),
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure ~
Employer . Exposure Job Title Dates
Consolidated Insulation Mills Building Insulator 1/1967-3/1972
317-D Marine View Ave. @usk/Montgomery) (on and off}
Belmont, CA San Francisto, CA

Job Duties: Plaintiff installed asbestos insulation and wrapped duct. Plaintiff worked near
lumbers and pipefitters who were installing pipes, valves, and gaskets. DOUGLASS
INSULATION COMPANY. insulators cut and applied calcium silicate pipecovering on wet heat
and steam piping near plaintiff. Plaintiffrecalls that fireproofing was being disturbed by the
electricians and the ceiling tile workers. Plaintiff recalls contractors: DOUGLASS
INSULATION COMPANY, INC., DELUCCHI SHEET METAL WORKS, C.8. HARDEMAN,
INC, LW. MCCLENAHAN COMPANY, MCCLURE ELECTRIC, INC., and ZELLER
PLASTERING. Plaintiff currently contends he was exposed to ashestos during this employment.

* Losation of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation City Administration Insulator 1/1 967-3/1972
517-D Marine View Ave. Building (2 months, on and
Belmont, CA Cutting Boulevard off]
Richmond, CA

Job Duties: Plaintiff worked in the boiler room. Plaintiff insulated pipes and ducts on a hot
water heater. Plaintiff worked with BORDEN's fibrous adhesive, EAGLE-PICHER cement, and
PABCO [27 BLUE cement, Plaintiff worked near plumbers and pipefitters installing pipes,
gaskets and valves. Plaintiff worked near Srywalt hangers cutting and installing drywall,
Plaintiff worked near GOLDEN GATE DRYWALL tapers mixing, applying and sanding
asbestos-containing joint compound. Plaintiff recalls that fireproofing was being disturbed by
the controls men. Plaintiff recalls contractors: GOLDEN GATE DRYWALL, ey
ANDERSON, ROWE & BUCKLEY, INC., RODONI-BECKER CO., INC., ALLIED FIRE

PROTECTION, and CAHILL CONTRACTORS, INC, Plaintiff recalis the following supervisor}

Richard Saiya (address unknown). Plaintiff recalls the following co-workers: Gene Thompson
address rin); Harl Beck {deceased}; Robert Cantley (c/o Brayton**Purcell LLP); Mickey
obnson {address unknown). Plaintiff currently contends he was exposed te asbestos during this

employment.

54Location of Exposure
Employer Exposure, Job Tile Dates
Consolidated Insulation 690 Market Street Insulator 1/1967-3/1972
517-D Marine View Ave. San Francisco, CA C1 week, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near pipefitters installing pipes,
gaskets and valves, and using ing, Plaintiff recalls working near sieet metal workers who
shat stads inte te beams, krieeltizi¢ aff tie fitéprocfing. Piein
up debris. Plaintiff worked near MONTEREY MECHANICAL pipefitters who were applying
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. The MONTEREY.
MECHANICAL pipefitters also disturbed finished and taped sheetrocked walls when making
wall penetrations for piping. Plaintiff recalls the following supervisor: Richard Saiya (address
unknown). Plaintiff recalls the following coworkers: Robert Cantley (c/o Brayton Purcell
LLP); Earl Beck (deceased), Plaintiff currently contends he was exposed to-asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 50 California Street M1967-3/1972,

Insulator
§17-D Marine View Ave. San Francisco, CA : (2 weeks, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff used cal-sil insulation and all-purpose
cement. Plaintiffrecalls the following supervisor: Richard Satya (address unknown). Biantife
recalls the following coworker: Robert Cantley (c/o Brayton%*Purcel] LLP). Plaintiff currently
contends he was exposed to asbestos during this employment. .

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Bt. Mary's Church Insulator WA967-B972
517-D Marine View Ave. San Francisco, CA (6 weeks, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers and pipefitters
installing pipes, gaskets and valves, and using packing. Plaintiff worked near drywall. hangers
cutting and installing drywell. Plaintiff worked near tapers applying and sanding joint
compound. Plaintiff recalls working near sheet metal workers who shot studs into the beams,
knocking off the fireptocfing, Plaimtiff recalls that fiveproafing was being disturbed by the
ROBERT SHAW controls technicians. Plaintiff worked near sprinkler fitters who had 10 disturb
the fireproofing in order to install their pipes. Plaintiff worked near laborers sweeping up debris.
Plain recalls the following contractors: general contractor CLAUSEN PATTEN, sheet metal
contractor DELUCCHI SHEET METAL WORKS, and drywall contractors GOLDEN GATE
DRYWALL, INC, and D, ZELINSKY & SONS, INC, The D. ZELINSKY crew was taping and
sanding asbestos-containing taping compounds 5 ta 20 feet from plaintiff, and was painti:
theveafier. Plaintiff recalls the following supervisor: Richard Saiya (address unknown), Plaintif’
tecalls the following coworkers: Sal Morales (deceased); Joseph O’ Balle (c/o Braytoa*Purcell
LLP). Plaintiff curently contends. he was exposed to asbestos during this employment.

if
Al

35

Workéd'near Lehirers sweeping} |I

wo Oo ADH ew

See
nh AW HH Oo

17

| Plaintiff worked near plumbers and
: Can i

Location of Exposure
Employer Exposure. Job Title Dates

Consolidated Insulation Highland Hospital Insulator 1/1967-3/1972
517-D Marine View Ave, Oakland, CA {1 month, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts in the ceilings and worked in the boiler room.
k tpefitters installing pipes, gaskets and valves, and using
pecking: Plemrtttt tear ceiling instaite: ply were cutting ex! imstattng cof “tités.
Jaintiff recalls that fireproofing was being disturbed by the ceiling installers. Plaintiff worked
near floor tile installers who were eurting and installing floor tiles. Plaintiff recalls that
fireproofing was being disturbed by the floor tile installers. Plaintiff recalls working near sheet
metal workers who shot studs into the beams, knocking off the Ereproofing, Plaintiff recalls
seeing others spraying W.R. GRACE MONOKOTE fireproofing spray, Plaintiff worked near
laborers sweeping up debris. Plaintiff worked near insulators ¢mp! oyed by the followin
contractors: WESTERN ASBESTOS COMPANY, PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY), Plaintiff recalls general contractors DPR CONSTRUCTION, and
ROTHSCHILD & RAFFIN, INC.; mechanical contractor ALADDIN HEATING
CORPORATION drywall contractors CIR PLASTERING and GOLDEN GATE DRYWALL,
INC.; and COSCO SPRINKLER. Plaintiff observed pipefiters and sheetmetal workers shooting
studs into overhead fireproofing, cutting and installing GARLOCK (GARLOCK SBALING
TECHNOLOGIES, LLC) gaskets, and Cutting and installing flexible duct connectors while
fabricating steam and act piping and duct work. Plaintiff worked alongside pipefitters who
disturbed overhead MONOKOTE fireproofing while setting pipe supports, and. who disturhed
existing asbestos-containing pipecovering near plaintiff while fabricating new piping. Plaintiff
recalls REODES & JAMIESON supplied asbestos-containing products. Plaintiff recalls the
following supervisor: Robert Cantley (c/o Brayton+Purcell LLP). Plaintiff recalls the following]
coworker: Stan Silva (deceased). Plaintiff also worked with these co-workers employed b
PLANT ASBESTOS COMPANY (PLANT INSULATION COMPANY): Joe MeLeay (address
unknown), and Phil Peterson (c/o BraytonPurcell LLP). Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation American Can Company = Insulator 1/1967-3/1972
$17-D Marine View Ave. San Leandro, CA (4 days, on and
Belment, CA o

Job Duties: Plaintiff imsulated pipes and duets. Plaintiff used cal-sil insulation and 301 all-
purpose cement, Plaintiff worked near pipefitters installing pipes, gaskets and. valves, and using
packing, -Plaintiff worked near laborers swee} ing up debris. Plaintiff recalls the following
supervisor: ‘Richard Satya (address inknownh, latntiff recalls the following coworkers; Robert
Cantley (fo Brayton‘? Purcell LLP); Earl Beck (deceased); Robert Wildoner (clo
BraytonPurcell LLP). Plaintiff currently contends he was exposed to ashestos during this
employment.

Location of Exposure
Employer Exposure : Job Title Dates
Consolidated Insulation 1 Bush Street Insulator 1/1967-3/1972
S17-D Mazine View Ave. San Francisco, CA (2 weeks, on and
Belmont, CA off)

36eae
OW DN to Bm Ww Ym Ss

19

oO ow Hw Row

Job Duties: Plaintiff insulated pipes and ducts, Plaintiff worked near pipefitters installing pipes,
gaskets and valves, and using packing. Plaintiff recalls working near sheet metal workers who
shot studs into the beams, knocking off the fireproofing. Plaintiff recalls others spra, ing
fiteproofing spray. Plaintiffrecalls contractors: BALLIET BROTHERS CONS ve iON
CORPORATION, PACIFIC MECHANICAL, and ATLAS HEATING AND VENTILATING
COMPANY, LTD. Plaintiff recalls the following supervisor: Rabert Cantley (c/o
BraytonPurcell LLP). Plaintiff curently contends he was exposed fo asbestos during this

employment.
. Locatiorrof : u
Employer SUT, Job Title Dates
Consolidated Insulation Heng Keng Bank Insulator 1/1967-3/1972
517-D Marine View Ave. San cisco, CA {1 week)
Belmont, CA eadquarters—L60
ansome Street)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers and pipefitters
installing pipes, gaskets and valves, and using packing, Plaintiff worked near drywel Bangers
cutting and. instal ing drywall. Plaintiff worked near tapers applying and sanding joint
compound. Plaintiff recalls working near sheet metal workers who shot studs int the beams,
knocking off the fireproofing, Plaintiff recalls working ground controls men, and that
fireproofing was being disturbed by the controls men. Plaintiff worked near HONG KONG

B maintenance workers who Were sweeping up debris. Plaintiff also worked near
electricians, sprinkler fitters, and refrigeration technicians. Plaintiff recalls seeing MONOKOTE
used at this jobsite. Plaintiff recalls the following supervisors: Robert Cantley (c/o

Brayton Purcell LLP), Richard Saiy (address unknown), Plaintiff recalls the following
coworker: Earl Beck (deceased), Plaintiff currently contends he was exposed to asbestos during
this employment. .

Lovation of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 111 Pine Street Insulator 1/1967-3/1972;
517-D Marine View Ave. San Francisco, CA S/T7-1/81
Belmont, CA GO arerks: on and
o

Job Duties: Plaintiffinsulated domestic water pipes and ducts, Plaintiff worked near pipefitters
installing pipes, gaskets and valves, and using packing. Plaintiff recalls working near sheet me
workers who shot studs into the beams, knocking off the fireproofing. FREDERICK
MEISWINKEL, D. ZELINSR'Y, sweeping asbestos-containing debris in plaintiff's presence.
Plaintiff saw MEISWINKEL personne} using bags of asbestos-containiny joint compounds,
mixing the material and sanding it alter it was applied to interior walls. Plaintiff saw
ZELINSKY personnel mixing, taping and sanding asbestos-containing taping compounds and
then parting in plaintiff's presence, Plaintiff worked near laborers swt pin e debris. Plaintifi
recalls the following supervisor: Robert Cantley (c/o Brayton Purcelf L Py, lamtiif cunenily
contends he was exposed 10 asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 433 Bush Street. Insulator 1/1967-3/1972;
517-D Marine View Ave. Ban Francisco, CA S/77-1/81
Belmont, CA oon. on and
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Job Duties; Plaintiff insulated pipes and ducts. Plaintiff worked near pipefitters installing pipes,
gaskets and valves, and using packing, Plaintiff recalls working near sheet metal workers who
shot studs into the beams, knocking off the fireproofing. Plaintiff worked near laborers sweepin;
up debris. Plaintiff recalls the following supervisor: Robert Cantley (c/o Brayton%Purcell Ti
Plaintiff currently comtends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated lnsulatton - Nava Station Treasure Tosntator EFOG7-37fO 72
517-D Marine View Ave. Island S/77-1/81
Belmont, CA San Francisco, CA (1 month, on and
off)

Job Duties: Plaintiff insulated pipes and ducts in the barracks and in the boiler room. Plaintiff
‘nsed cal-sil insulation in the boiler room and fibergtass insulation in the barracks, Plaintiff used
all purpose mud. Plaintiffrecalls general contractor: ROLLINS CONSTRUCTION, mechianical
contractor, JAMES NELSON, electrical contractor; and BANNER DRYWALL & PAINTING.
Plaintiff recalls the following supervisors: Richard Saiya (address unknown); Robert Cantley,
cfo Brayton**Purcell LLP. Plaintiff recalls the following coworker: Jack Jagoda, Martinez,
California (c/o Pan) & Hanley LLP). Plaintiff currently contends he was exposed to asbesios
during this employment.

Location of Exposure
Employer Exposure Job Title Dates,
Consolidated Insulation IBM * Insulator 1987-1972;

$17-D Marine View Ave. San Jose, CA ” 1977-1981
Belmont, CA .

Job Duties: Plaintiff applied fiberglass duct wrap to duct work and applied fiberglass and
calcium silicate i ecovering and Insulation cements to piping valves and fittings during new
construction and diving multiple remodel projects. Plaintiff cut and applied KAYLO (OWENS
CORNING FIBERGLAS) pipecovering and JOHNS MANVILLE pipecovering. Plaintiff worked
near these and other tradesmen who disturbed previously applied asbestos-containing overhead
fireproofing while Ranging supports for piping duct work, sprinkler systems, controls, and
electrical conduit or while sweeping and cleaning debris that had colfected in the work areas.
Plaintiff also observed IBM personnel sweeping and cleaning asbestos-containing debris in his
work areas. Plaintiff also worked next to D, ZELINSKY painters sanding asbestos-containing
joint and taping cornpounds on interior walls, in order to prepare those surfaces for painting.
Plaintiff’s supervisor was Robert Cantley (c/o Hrayton%+Purcell LLP). Plaintiff currently
contends that he was exposed to asbestos during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Lockheed Insulator 1967-1972;
517-D Marine View Ave. Sunnyvale, CA 1977-1981

Belmont, CA

Job Duties: Plaintiff performed intermittent “fill-in” work. Plaintiff worked on new construction
and on repair and maintenance crews. Plaintiff applied fiberglass duct wrap to duct work and
plied fiberglass and calctum silicate pipecovering and insulation cements to piping, valves, and
felines. Plaintitf worked in n proximity to a range of trades, including pipefitters, sheetmetal
workers, electricians, drywall hangers, tapers, and sanders, cement masons, tile setters,
maintenance personnel, and laborers. CUPERTINO ELECTRIC COMPANY served as electrical

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contractor on one or more of these projects. CUPERTINO ELECTRIC personnel disturbed
asbestos-containing overhead fireproofing while setting supports for their electrical conduit in
plaintiff's presence. Plaintiff also worked next to D. ZELINGKY painters sanding asbestos-
containing joint and taping compounds on interior walls, in order to prepare those surfaces for
painting. Plaintiffs supervisor was Robert Cantley lo Brayton%*Purcell LLP), Plaintiff

currently contends that he was exposed i¢ asbestos during this employment.
Location of Exposure
Employer Exposure Job Title, Dates,
Consolidated Insulation Lucky Deli Plant Insulator 1969 (1 week, on
San Leandro, CA and

Job Duties: Plainnff installed insulation to plumbing pipe. Plaintiff recalls insulators from
ASSOCIATED INSULATION installing cal-sil insulation to the pipes and the valves and
asbestos cernent ta the fittings. Plaintiff identifies ASSOCLATED INSULATION employee
Maurice Lawrence (c/o BraytonPurcell LLP). Plaintiff recalls the following co-worker:
Richard Collins (c/o Brayton} Parcell LLP). Plaintiff currently contends that he was exposed to
asbestos during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 101 California Street, Insutator 1970 - 1972;
517-D Marine View Ave. San Francisco, CA 1977 - 1979
Belmoni, CA (on and off)

Job Duties: Plaintiff applied asbestas-containing insulation to duct wrap and piping in the boiler
room. Plaintiff recalls trades employed by ORTHO-CRAFT were sweeping the area. Plaintiif
recalls pipefitters and other trades were disturbing MONOKOTE freprnoting on and. around the
ceilings, Plaintiff recalls the following contractor: GOLDEN GATE DRYWALL, INC.,
Plaintiff recalls supervisor: Robert Cantley (c/o Brayton%Purcell LLP). Plaintiff recalls co-
workers; Earl Beck (deceased); and Bob Wildoner (c/o Brayton%*Purcell LLF). Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Napa Junior College Napa Junior College Student 1970-1972,
Napa, CA Wapa, CA

Job Duties: Plaintiff attended welding classes. Plaintiffis currently anaware if he was exposed
to asbestos during this Training.

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Asrojet-General Insulator 4/1972-9/1973
1501 North C Street Rancho Cordova, CA (18 working days}

Sacramento, CA

Job Duties: Plaintiff insulated a large vessel and related piping with PARCO asbestos block and
PABCO pipecovering, and Fibrous Adhesive. Plaintiff installed JOHNS MANVILLE 382
BLUE cement and mastic. Plaimtiff worked near laborers sweeping up debris and near welders
using asbestos blankets. Plaintiff worked near pipefitters installing gaskets, pipes, valves and

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pumps, Plaintiff recalls the following mechanical contractor; FOLEY-PMI. Plaintiff recalls the
following supervisor: Pete Rossi, Sacramento, Califomia. Plaintiff recalls the following co-
workers: AJ Cook (c/o Brayton**Purcell LLP); Herb Cook (c/o Brayton**Purcell LLP}, Mike
Harnmer (address unknown); Jim White Jr. (Napa, California). Plaintiff currently contends he
was exposed fo asbestos during this employment. .

Location of . Exposure
Employer Exposure . Job Title _ Dates
| Siefertand Rossi General WMHs: hesuliter "RFD
1501 North C Street Lodi, CA

Sacramento, CA

Job Duties: Plaintiff applied asbestos-containing insulation, mud, mastic and canvas to pipes an
fittings. Plainiiif recalls using cal-sil pipecovermg and asbestos mud. Plaintiff recalls usin,
products manufactured by PABCO, Plaintiff recalls trades emplayed by GENERAL MILLS
were sweeping up in plaintiffs presence. Plaintiff worked as foreman on this job. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Kaiser Hospital Insulator Af1972-9/1973
1501 North C Street Sacramento, CA (3 weeks, on and
Sacramento, CA off}

Job Duties: Plaintiff insulated pipes and wrapped ducts. Plaintiff worked near laborers sweepin:
up debris. Plaintiff worked near pipefitters installing gaskets, pipes and valves. Plaintiff recalls
having to remove and replace ceiling tiles in order to perform his job duties. Plaintiff recalls
existing fireproofing on the ceiling tiles. Plaintiff recalls mechanical contractor: LAWSON
MECHANICAL, CLAWSON MECHANICAL pipefitters and sheetmetal workers disturbed
previously sprayed overhead fireproofing while setting pipe and duct supports in plaintiff's work
areas. Plaintiff recalls the following supervisor: Pete Rossi, Sacramento, California. Plaintiff
recalls the following co-worker: Wally Friswald (deceased). Plaintiff currently contends he was
exposed to asbestos during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Sacramento Convention —_— Insulator 4/1 9729/1973
1501 North C Street Center (3 months, on and
Sacramento, CA, Sacramento, CA . off}
: (16" st.)

Job Duties: Plaintiff installed pine insulation and 301 cement on the fittings. Plaintiff insulated
what he believes was a BABCOCK & WILCOX boiler with asbestos block insulation, afl-
purpose cement, mastic and canvas and 352 BLUE cement, ‘Plaintiff worked near pipefitters
installing gaskets, pipes and valves. Plaintiff worked near laborers sweeping up debris and near
welders performing welding and using asbestos blankets. Plaintiff worked near drywall hangers
cutting and installing drywall and near bapets applying and sanding joint compound. Plainti:
recalls reporting to an inspector whe worked for the City of Sacramento and believes that the

City of Sacramento was the general contractor for the project. Plaintiff worked in proximity to
JAMES WHITTAKER, INC. (RAYMOND INTERIOR SYSTEMS-NORTH) laborers who were
mixing and spraying CAFCO (UNITED STATES MINERAL PRODUCTS COMPANY)
fireproofing and who were sweeping 4P. dried fireproofing debris in plaintiff’s presence. Plaintiff}
recalls the following contractors: LAWSON MECHANICAL, and TEICHER’ mo

60CONSTRUCTION CO. LAWSON MECHANICAL personnel swept up ashestos-containing
block insulation debris near plaintiff in a large boiler room. Plaintiff recalls the following ca-
workers: Al Cook {c/o Braytom Purcell LIP); Herb Cook (c/o Brayton**Purcell LLP); Jim
White, Jr. (Naps, California), Plaintiff currently contends he was exposed to asbestos during this|
employment. .
Location of Exposure
Employer Exposure Job Title Dates
| Stefert and’ Russt AmericarRiver City : Insolator” HITLIST
1501 North C Street College (2 weeks, on and.
Sacramento, CA Sacramenta, CA off}
Job Duties: Plaintiff worked in a pipe chase and in the boiler room. Plaintiff installed used all-
urpose cement on valves, Plaintitf recalls the following co-worker: Me] Swanson, Sacramento,
Palfornia. Plaintiff is currently unaware if he was exposed td asbestos during this employment.
Location of Exposure
Emplover Exposure Job Title Dates
Siefert and Rossi Truckee High School Tnsulator AANG72-H1975
1501 North C Strert Truckee, C. (2 weeks, anand
Sacramento, CA off) .

Job Duties: Plaintiff insulated a tank. Plaintiff used cal-sil blocks, all-purpose cement, fibrous
adhesive cement, and 127 cement. Plaintiff worked near plumbers and pipefitters installing

apes, gaskets and valves. Plaintiff worked near insulators employed by NORCAL
INSULATION who were installing cal-sil insulation, Plaintiff recalls the following supervisor:
Pete Rossi, Sacramento, California. Plaintiff recalls the following coworker: Richard Dunley
(address unknown), Plamtiff curently contends he was exposed to asbestos during this
employment. :

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Merchant’s Cold Storage = Insulator AN1972-S/1979
1501 North © Street Salinas, CA. (3 weeks)

Sacramento, CA

Job Duties: Plaintiff insulated pipes, valves and fittings. Plaintiff worked on hot and cold Lines.
Piaintiif used ONE COTE cement. Plaintiff recalls the following coworkers: Ted George (c/a

Brayton%*Purcell LLP); Bud Weidner (deceased). Plaintiff currently contends he was exposed to
asbestos during this employment. .

Location of : Exposure
Employer Exposure Job Title Dates
Plant Insulation Westin Saint Francis Insulator 1Of1973-12/1973:

227) California Street
San Francisea, CA

(Powell Sweet}

3/1974-3/1 976;
San Francises, CA.

10/1976-2/1977

(21 to 26 days)

Job Duties: Plaintiff installed insulation on pipes and valves in the boilerroom. Plaintiff used
PABCO insulation and 127 insulating cement DOUGLASS INSULATION COMPANY
insulators applied calcium silicate pipecovering and asbestos-containing cements to boiler reom

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piping. Plaintiff worked. neat pipefitters installing pipes, valves, pumps and gaskets, -Plaintiff
worked in) proximity to CONSOLIDATED INSULATION, INC. and DOUGLASS
INSULATION COMPANY, INC. insulators removing ald asbestos-containing insulation,
Plaintiff warked beneath LERA ELECTRIC personnel who were disturbing fre roofing above
laintifé. Plaintiff worked in proximity to the following contractors: CRIT: HRLELD
CHANICAL, INC. CONSOLIDATED INSULATION, INC., DOUGLASS INSULATION
COMPANY, INC., CS. HARDEMAN, INC., SAM P. WALLACE COMPANY, ANDERSON,
ROWE & BUCKLEY, INC., JAMES NELSON, COAST PLASTERING COMBANY. Plaintiff
worked alongside CONSOLIDATED INSULATION employees Robert Cantley (c/a
BraytorePintelt LEP) and Bark Beek (deceastd, while they were cutting sid appa
asbestos-containing PABCO pipecovering and insulation cements, Plaintiff recalls the following
supervisor: Glen Schimmelphenig faderess unknown). Plaintiff recalls the following co-
worker: Allan Bdwards (deceased). Plaintiff currently contends he was exposed to asbestos

during this employment.
Location of Exposure

Employer Exposure Job Title Dates

Plant Insulation Jetterman Hospital Insulator 10/1973-12/1973;

2271 Califormia Street & Medical Center Bf1974-3/1 976:

San Francisca, CA San Francisco, CA LO/1976-2/1977
(month, on and
9:

Job Duties: Plaintiff worked on a remodel of the hospital. Plaintiff wrapped ducts inthe -
mechanical rooms and on various other floors. Plaintiff recalis fireprooting on the beams.
Plaintiff recalls the following supervisar. Glenn Schimmelphemg (address unknown), Plaintiff
recalls the following co-worker: Larry Cooper, Cathedral City, California. Plaintiff currently
contends he was exposed to asbestos during this employment.

. Location of . Exposure
Employer Exposure Job Title Dates
Plant Insulation Standard Gil Insulator 10/1973-12/1973,
2271 Califomia Street Richmand, CA 3/1974-3/1976;
San Francisco, CA 10/1976-2/1977
: (4 months, on and
off)

Job Duties: Plaintiff recalls installing insulation on pipes, valves, heat exchangers, towers and
vessels. Plaintiff recalls having to crawl over pipes that were covered with asbestos insulation to
perform his duties. Plaintiff recalls that his clothes and skin would be covered with dust,
Plaintiff recalls working neat welders using welding blankets, laborers sweeping up the site and
near pipefitters installing gaskets, valves and pipes. Plaintiff worked near electricians employed
by CONTRA COSTA ELECTRIC, INC who were disturbing pipe insulation while installing
conduit. Plaintiff recalls the following supervisors: Glenn Schimmelpheni {address unknown);
Arvis Duncan (deceased). Plaintiff recalls the following co-workers. Donald Bumett (Gakdate,
California); Warren Hasse (c/o Brayton Purcell LLP); Richard Tobey (deceased); Ear) Riggs

ea: Rager Fonken (c/o Brayton%*Purcell LLP), Robert Holbrook (c/o Brayton Purcell

LP); Joseph O°Balle (cfo Brayton4+Purcell LLP); Robert Drose (deceased); Gary Boggs (clo
Brayton? Purcell LLP). Plaintiff recalls the following co-warkers employed by OSCAR B,
ERICKSON, INC.: John Pace ilo Brayton Purcell LLP); and Monte Manwill (clo
Brayton*Purcell LLP}, Plaintiff currently contends he was exposed to asbestos during this
employment

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Location of : Exposure

Employer Exposure Job Title Dates

Plant Insulation PG&E Powerhouse Insulator 10/1973-12/1973;

2271 Califormia Street Pittsburg, CA S/1974-3/19763

San Francisco, CA 10/1976-2/1977
(3-4 months, on
and off)

Location of Expasure
Dates

Employer Exposure, Job Title
Plant Insulation Co. Shell Oil Refinery Insulator 1973-1977
2271 Califormia Street Martinez, CA

San Francisca, CA

Job Duties: Plaintiff applied asbestos-containing insulation to piping, vessels and heat
exchangers during a turnaround. Plaintiff contends he was exposed to asbestos during this

Job Duties: Plaintiff applied block insulation and PABCO pipecovering while repairing

damaged boiler and turbine insulation. Plaintiff worked near welders using asbestos blankets and)
PG&E laborers who were sweeping up previously removed asbestas-containing debris. Plaintiff
worked near pipefitters installing gaskets, valves and pipes. Plaintiff worked near pipefitters wha
were installing SUPERIOR valves and GOODYEAR & RUBBER COMP. gaskets.
Plaintiff recalls the following supervisors: Glenn Schimmelphenig (address unknown) Arvis
Duncan (decessed). Plaintiff recalls the following co-workers: Donald Burnett (Oakdale,
Califormia), Mike Caylor (c/o Brayton Purcell ); Robert Lee (c/o Brayton Purcell LLP);
Richard Ciabattari (c/o Brayton*Purceil LLP), John McClure (deceased); Bdward Johnsan (e/a
Brayton Purcell LLP}; John Price (c/o BraytonPurcell LLP). Plaintiff currently contends he
was exposed fo asbestos during this employment.

Location of - Exposure
Employer Exposure . Job Title Dates
Plant Insulation Union Oil, Insulator . 1973-1977
2271 California Street Rodeos Oleum, CA (on and off for
San Franeisco, CA approx. 2 months}

Job Duties: Plaintiff applied cal-sil pipecovering, block and mud. Plaintiff applied JOHNS
MANVILLE Blue Mud, mag mud 127, and FOSTERS adhesive. Plaintiffrecalls using PABCO
products. Plaintiff recalls laborers were spreeping ap and installing asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets, Plaintiff observed
laborers sweeping and shoveling, PABCO piperovering cement, and calcium silicate block
debris undemeatl plaintiff, 5 to 30 feet trom plaintiff. Plaintiffrecalls welders used asbestos
blankets manufactured by RAYBESTOS and “A” cloth. Plaintiff recalls coworkers: Laurance
Hagen (c/o Brayton Purcell LLP); Guy Kennedy (c/o Brayton? Purcell LLP), and Mike Caylor
(fo Brayton*?Purcell LLP). Plaintiff currently contends he was exposed to asbestos during this
employment.

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Location of . Exposure
Employer Exposure Job Title Dates

Plant Insulation Fireman’s Fund Insulator 10/1973-12/1973;

2271 California Street Novato, CA 31974-3/1976;

San Francisco, CA 10/1976-2/1977
(1 month, on and
off)

Job Duties: Plaintiff worked-inr the inechanical'rodmts. Ptairitiffinstatfed all cement ad *

127 BLUE MUD cement on valves. Plaintiff removed and replaced ceiling tiles ‘and had to
disturb existing insulation on the ceiling tiles and pipes. Plaintiff recalls working near pipefitters
installing pipes, gaskets, and valves. Plaintiff worked near sheetrockers and tapers installing and
sanding Joint compound. Plaintiff recalls laborers sweeping up debris, Plaintiff recalls the
following contractors: Plaintiff observed FREDERICK MEISWINKEL INC. personnel usin;
asbestos-containing joint compounds, which they taped and sanded. Plaintiff tecalls PA. R-
HANNIFIN CORPORATION valves and approximately twenty asbestos-containing DURABLA
URABLA MANUFACTURING COMPANY, INC.) gaskets were installed at this site.
laintiff recalls the following supervisors: Glean Schimmelphenig (address unknown); Gary
Hansen, ¢/o Brayton*Purcell. Plaintiff recalls the following co-worker: Richard Tobey
(deceased). Plaintiff currently contends he was exposed to asbestos during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Colgate-Palmolive Insulator 11973-12/1973;
2271 California Street Berkeley, CA 3/1974.3/1 976;
San Francisca, CA, 10/1976-2/1977
(1 month, on and
off)

Job Duties: Plaintiff insulated tanks with foarn glass insulation and insulated pipes with calcium
silicate insulation. Plaintiff installed all-purpose cement. Plaintiff also recalls the following
contractor: PACIFIC MECHANICAL. Plaintiff worked near L.J. KRUSE pipefirters who were
replacing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) flange gasket and
repacking valves, COLGATE PALMOLIVE personnel swept