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

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Walsworth,
Franklin,
Bevins &

McCall, LLP
anronupss ar cae

IAN P. DILLON, State Bar No, 203612
idillon@wfbm.com

PAMELA E, STEVENS, State Bar No. 232609
pstevens@wfbm.com ELECTR
ALEX A. LOZADA, State Bar No. 275416 CTRONICALLY
alozada@wibm.com FILED
WALSWORTH FRANKLIN BEVINS & McCALL, LLP Superior Court of California,
601 Montgomery pireet, Ninth Floor County of San Francisco
San Francisco, California 94111-2612
Telephone: (415) 781-7072 FEB 25 20 13
Facsimile: (415) 391-6258 BY WIKLyAM TRUBE
Deputy Clerk
Attorneys for Defendant
D. ZELINSKY & SONS, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ROBERT ROSS and JEAN ROSS, Case No. CGC-10-275731
Plaintiffs, Hon: Teri L. Jackson
Dept: 503
vs. Date: May 7, 2013
Time:

C.C. MOORE & CO. ENGINEERS; et al.,
EXHIBIT W TO THE DECLARATION
Defendant. OF ALEX A. LOZADA IN SUPPORT OF
DEFENDANT D. ZELINSKY AND SONS,
INC.'S MOTION FOR SUMMARY
ADJUDICATION

Trial Date: June 10, 2013

-l-
EXHIBIT W TO THE DECLARATION OF ALEX A. LOZADA IN SUPPORT OF DEFENDANT D. ZELINSKY
AND SONS, INC'S MOTION FOR SUMMARY ADJUDICATION

2287845.1

3619-3.2595EXHIBIT Wee a ETE annoy tee

ATTORNEYS AT LAW
222 RUSH LANDING ROAD

POBOX 6169

NOVATO, CALIFORNIA 94948-6169

* 415) 98-1955

ou RP NAH Be YN

os

4a818712

ALAN R. BRAYTON, BSQ., 8.B, #73685 sens
ANNE T. ACUNA, ESQ., 8.B. #245369 sun #2042
BRAYTON®PURCELL LLP - “2:
Attorneys at Law
222 Rush Landing Road soe
P.O. Box 6169
Novato, California 94948
(415) 898-1555
Attomeys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS, ASBESTOS

No. CGC-10-275731

Plaintiffs, +

SUPPLEMENTAL/AMENDED

vs. RESPONSES TO INTERROGATORIES

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

herein; and DOES 1-8500.

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NOS.: ONE and TWO

Plaintiff supplements/amends his Responses to Standard Asbestos Case Interrogatories,
Set One, No. 26, and Set Two, Nos. | through 3, as follows:
SUPPLEMENTAL/AMENDED RESPONSE; Plaintiff incorporates by reference as though

folly set forth herein, all work history jobsites and co-workers and telated information identified

in the attached Exhibit A.

Dated: &/ i te BRAYTON*PURCELL LLP

wy A~ be

Anne T. Acuiia
of attomeys for Plaintiffs

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EXHIBIT A ~

Robert Ross and Jean Ross v. C.C. Moore & Co, Engineers, et al,

Employer * \
Genéral Mills Coinpahy
P.O, Box 1113
Minneapolis, MN

Location of

Exposure Job Title
General Mills Warehouseman
Vallejo, CA

Exposure
Dates

1952-1/1954;
2/1956-6/1956

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

Employer
United States Army

Location of

Exposure Job Title
Fort Ord Infantryman.
Monterey, CA;

United States Army
Okinawa, Japan

Exposure
Dates

2/9/54-1/27/56

Job Duties: Plaintiff served in the United States Army as an infantryman, Plaintiff served at

Fort Ord, Monterey, California, 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,

Location of Exposure
Employer 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 (2 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 Dates
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
to asbestos during this employment.

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Location of Exposure

Tunployer Exposure Job ‘Title Dates
Philip Carey Warehouse Warehouseman 2/1959-8/1959;
Cincinnati, OH > > 101 Williams ” 12/1959-1/T960
San Francisco, CA (1 week)
Jack Tar Hotel

(aka Cathedral Hill Hote!)
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 jobsites, Plaintiff recalls unloading or
delivering the following asbestos-containing products: PHILIP CAREY (RAPID-AMERICAN
CORPORATION), JOFINS-MANVILLE (MANVILLE TRUST), OWENS CORNING
KAYLO (OWENS CORNING FIBERGLAS), UNIBESTOS (UNARCO), EAGLE PICHER
(EAGLE-PICHER INDUSTRIES, INC.), CELOTEX, 85% mag cement, 301 and 352 JOHNS
MANVILLE (MANVILLE TRUST) insulating cement. Plaintiff recalls that the jobsite was
very dusty and that bis clothes would get covered in dust. Plaintiff also delivered materials to
various jobsites on approximately 10 occasions. Plaintiff delivered materials to the Jack Tar
Hotel in San Francisco, California, CAHILL CONSTRUCTION (CAHILL CONSTRUCTION
CO. Ne) was the general contractor which een laborers and cement finishers at the site.

Plaintiff observed CAHILL CONSTRUCTION (CAHILL CONSTRUCTION CO., INC.)
laborers sweeping debris created by cutting of PHILIP CAREY (RAPID-AMBRICAN
CORPORATION) asbestos-containing pipe insulation and created by cutting of GARLOCK.
GARLOCK SEALING ‘TECHNOLOGIES, LLC) flange gaskets. ANDERSON, ROWE &
BUCKLEY, INC. employed phimbers, pipefitters and shectmotal workers at the Jack ‘Tar Hotel,
Plaintiff recalls Philip Carey was the insulation contractor at the Jack Tar Hotel. Plaintiff
tecalls Bill Houston was the Philip Carey supervisor af the Jack Tar Hotel, Plaintiff recalls the
following supervisor at the warchouse: Ray Scott, Tucson, Arizona. Plaintiff recalls the
following coworkers at the warehouse: Bill Heineche, Sr. (leceased); Bill Meineche, 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-c ntaining insulation to pipes, pumps, flanges,
valves, duct work, plenums, boilers and ves: Plaintiff cut the asbestos-containing pipe
insulation with a hand saw. Plaintiff mixed asbestos coment and applied cement to fittings and
irregular surfaces. Plaintiff worked in proximity to the following trades: Plumbers, pipefitters,
sheet metal workers, clectricians, 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 and valves, and working with asbestos-containing gaskets and packing.
Plaintiff worked in proximity to sheet metal workers disturbing existing asbestos-contuining
fireproofing insulation and installing asbestos-containing flexible duct connectors, Plaintit?
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 Hreproofing insulation, Plaindff worked in
proximity to laborers performing general clean up, including swecping up asbestos-containing
debris, which caused dust, Plaintiff worked in proximity to carpenters disturbing existing
asbestos-containing fireproofing insulation. Plaintiff worked in proximity to tathers and

lasterers 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 Moor installers using a circular saw to cut floor tiles that contained
asbestos. Plaintiff worked in proximity to ceiling installers disturbing existing asbestos-

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containing fircprooting insulation, Plaintiff cut asbestos-conlaining insulation with a power
saw and applied asbestos-containing canvas and asbestos cloth, Plaintiff currently contends that
he was exposed to asbestos during this employment. . .

: Location of ae Exposure
Employer Exposure Job Title Dates
Coast Insulating Products Fertilizer Plant Insulator 8/1959-9/1959
Los Angeles, CA. Helm, CA (Apprentice) (approx. 5 wks)

Job Duties: Plaintiff carried materials to journeyman insulators: Plaintiff recalls working with
JOHNS-MANVILLE (MANVILLE TRUST) block insulation. Plaintiff recalls scoring and
cutting the block insulation with a handsaw. Plaintiff recalls mixing all-purpose cement and
using JOHNS MANVILLE (MANVILLE TRUST) 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 Plaintif
installed asbestos-containing insulation on pipes and on the boiler in the boiler room, Plaintiff
recalls boilers manufactured by the following: FOSTER WHEELER CORPORATION
(FOSTER WHEELER LLC (hKA FOSTER WHEELER CES UNM RCOY and BABCOCK.
& WILCOX COMPANY. Plaintiff recalls using UNIBESTOS (UNARCO) insulation and
magnesium. Plaintilf recalls working near pipefitters installing pipes and asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked near
the installation of a new BELL & GOSSETT (ITT INDUSTRIES, INC pump which had
original manufacturer’s asbestos-containing gaskets wired to it. Plainti 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.

Location of Exposure
Employer Exposure Job ‘Title Dates
Universal Insulation Hewlett Packard Insulator 1959 (1-2 weeks)
520 6" Avenue Menlo Park, CA (Apprentice)

Menlo Park, CA

Job Duties: Plaintiff installed asbestos-coniaining insulation and all-purpose cement on the
fittings, Plaintiff installed asbestos-containing PABCO (FIBREBOARD CORPORATION)
insulation and FAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.) insulation cement on
pipes. Plaintiff recalls scoring and cutting the block insulation with a handsaw. Plaintiff reealis
laborers from Universal Insulation Company sweeping up MONOKOTE (W.R, GRACE &
CO), PABCO (FIBREBOARD CORPC RATIONS pipecovering, and other debris. Plaintiff
recalls the following supervisor: Troy Cozby (decenset), Plaintiff recalls the following co-
worker: Rod Hochstrasser (deceased), Plaintiff currently contends that he was exposed to
asbestos during this employment.

Wt
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: 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 (HIBREBOARD 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, Lid., LTD, JAMES
WHITTARER (RAYMOND INTERIOR SYSTEMS-NORTH) laborers mixed and sprayed
asbestos-containing CAFCO (UNITED STATES MINERAL PRODUCTS COMPANY)
fireproofing and swept dried fireproofing overs pray in plaintiff's work areas. Electricians
disturbed overhead asbestos-containing MONOK TE (W.R. GRACE & CO.) fireproofing
while setting their conduit supports, Plaintiff 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 FLEXTITALLIC, INC, gaskets. Plaintiff recalls that CAL-STEAM SUPPLY COMPANY
supplied asbes' containing FLEXITALLIC, INC. gaskets. Plaintiff recalls that they special
ordered asbestos-containing pipe insulation from METALCLAD INSULATION
CORPORATION. WEBCOR BUILDERS laborers swept and shoveled asbestos containing
PABCO (FIBERBOARD CORPORATION) and JOHNS MANVILLE (MANVILLE TRUST)
Thermobestos thermal insulation scraps and dust, Cafco (UNITED STATES MINERAL
PRODUCTS COMPANY) fireproofing dust, and scraps from asbestas-containing
FLEXITALLIC and GARLOCK (GARLOCK SEALING TECITINOLOGIES, LLC) gaskets
near plaintiff on a recurring basis, Plaintiff recalls the following foreman: Robert Cantley (c/o
BraytonPurcell 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)

bestos-containing insulation to a large tank, Plaintiff applied
EAGLE-PICHER (EAGLE-PICHER INDUSTRIES, INC.) asbestos-containing cement on the
heads and fittings. Pidintif{' applied EAGLE PICHER mineral wool. Plaintiff applied KAYLO
(OWENS CORNING FIBERGLAS) asbestos-containing insulation on pipes. Plaintiff recalls
using JOHNS-MANVILLE (MANVILLE TRUST) “Thermobestos” asbestes-conta ining
pipecovering, 85% magnesia coments, and 127 “bluc mud,” Plaintiff applied CHILDERS (H &
C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks, adhered the blocks to the
Jarge tank, and “rasped off? the extraded CHILDERS (H & C INVESTMENT ASSOCIATES,
INC.) Fibrous Adhesive after it dried, using a metal rasp, Plaintiff recalls the following
contractors at this site: PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY) and Bay Cities Abestos Co., Lid., TIDEWATER REFINERY (TEXACO, INC.)
laborers swept and shoveled asbestos-containing debris near plaintiff. Plaintiff recalls the
following foremen: Robert Robbins (deceased); and Allen Holbrook Weceascd, 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

Job Dutics: Plaintiff applied

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‘c/o Brayton*Purcell LLP ). Plaintiff currently contends that he was exposed to asbestos

(lo Bay INSULATION COMPANY): Ron Powers (c/o Brayton%+Purcelf LLP); Steve Steele
luring this employment.

. Location of wes Exposure
Employer Exposure Jeb 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-containing
JOHNS-MANVILLE (MANVILLE TRUST) pipecovering, EAGLE PICHER cement and all-
purpose cement at this site. Plaintiff installed asbestos-containing insulation on equipment and
pipes. Plaintiff “plied block insulation to two large heat gxchangers and to three large tanks.

laintiff applied CHILDERS (II & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
to the blocks, adhered the blocks to the heat exchangers and tanks, and “vasped off” the
extruded CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it
dried, via use of a metal rasp. Plaintiff worked near refractory workers from J.T. THORPE &
SON, INC. who were installing asbestos-containing 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, Plaintiffrecalls the following co-workers: Charles
Purcell (deceased), Jack Kish (deceased); John Hoyt (c/o Brayton*+Purcell LLP); Donald Cox
(c/o Braytone*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 lospital
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 boilev room with asbestos-
containing JOHNS-MANVILLE (MANVILLE TRUST) 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 Jeb 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 (¢/o Brayton%Purcell LLP);
Charlie Power (deceased); James Kearney, (deceased); Roger Fonken (c/o Brayton* Purcell

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LLP); Donald Cox (c/o Brayton*Purcell LLP). Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer . Exposure “ Job Title Dates ~
Western Asbestos McKinleyville High School Insulator 7/1961-10/1961;
3150 3" Street McKinleyville, C. 711962-5/1965
San Francisco, CA 3% weeks, on
and off)

Job Duties: Plaintiff worked at this site multiple times for about three and 4 weeks. total during
the new construction of the high school. Plaintiff applied asbestos-containing JOTINS-
MANVILLE (MANVILLE TRUST) mag pipecovering 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 fireproofing while setting pipe supports and duct supports in plaintiff's work
areas, pipefitters and plumbers employed by HAROLD BEASLEY PLUMBING AND
HEATING, INC, Plaintiff recalls contractor FRANK. M. BOOTH persomel cut and installed
asbestos-containing flexible duct connectors next to plaintit and his crew, CALIFORNIA
DRYWALL tapers were sanding previously applied asbestos-containing taping compounds next
to plaintiff on approximately 20 or more occasions. Plaintiff recalls working near laborers
employed by FRANK M. BOOTH who performed clean-up and sweeping of asbestas-
containing cheswall oud, fireproofing and insulation debris. . Plaintiff recalls the following co-
LAT OU

worker: Smith (deceased). Plaintiff 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 to the plant. Plaintiff applied asbestos-
containing EAGLE PICHER cement and chicken wire, Plaintiff reealls working near pipefitters
who were installing pip sand gaskets, Plaintiff recalls working near others using
asbestos blankets. Plamtiff recalls the following supervisor: Tiny Evans (deceased). Plainuff
recalls the following co-workers: Clark “Rags” Purcell (ilecoased); Doyle Davidson (deceased);
Larl Riggs (deceased); Hank Meyers (deceased); Donald Cox (c/o Brayton’Purcell LLP):
Richard Cross (deceased). Plaintiff currently contends that he was exposed to asbestos during
this employment,

Location of Exposure
Enyployer 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, a tank and vessels. Plaintiff used asbestos-
containing EAGLE PICHER cement, and asbestos-containing JOHNS MANVILLE
(MANVILLE TRUST) and KAYLO (OWENS CORNING F opr GAS) ipecovering and
block insulation. Plaintiff applied CHILDERS (1 & C INVESTMENT $SOCIATE: INC.)
Fibrous Adhesive to the blocks, applicd the blocks to the. tank, and “rasped off” the extruded
CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it dried, via

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use of a metal rasp. Plaintiff worked near laborers, were employed by

PLANT

MAINTENANCE (PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping

existing asbestos-containin,

Pi ¢ insulation, sweeping up the s
workers. TIDEWATER OIL ( i

ite and carrying products to the

fEXACO, INC.) laborers were also sweeping and shoveling

asbestos-containing debris in plaintiff's presence at this site. TIMEC (TIMEC COMPANY,
INC.) workers were stripping asbestos- containing block insulation off the nearby coker, which

spread dust throughout
INSULATION co

(FIBREBOARD CORPORATION) calcium si!
approximately 3 days. Plaintiff saw CROCKETT ELECTRIC

laintiff's work areas. PLANT ASBESTOS COMPANY (PLANT
IMPANY) personne! were applying asbestos-containing PABCO.
ilicate pipecovering near plaintiff for

electricians performing electrical

work in his work areas. Plaintiff worked alongside pipefitters who were installing and
removing asbestos-containing FLEXITALLIC, INC. gaskets. SLAKEY BROTHERS delivered
asbestos cement piping to this site on flatbed trucks. Plaintiff observed cutting and laying of
that asbestos cement piping for a few minutes. Plaintiff recalls the following co-workers:
Ronald A, Powers (c/o Brayton*Purcell LLP), Lou Hanson (address unknown); Robert
Robbins (deceased); 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 Monsanto Chemical Insulator 1961-65 (Approx.
3150 3™ Street Avon, CA 1 month)

San Francisco, CA

Job Duties: Plaintiff worked on an addition fo the plant. Plaintiff cut and installed calcium

silicate block insulation on a vessel using asbestos-containing CHILDERS

INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to ad)
troweled asbestos-containing EAGLE PICHER cement on the

(H &C
here the block, Plaintiff flat
vessel. Plaintiff installed

asbestos-containing JOHNS-MANVILLE (MANVILLE TRUST) pipecovering. Plaintiff's co-

workers included Robert Robbins 2
that he was exposed to asbestos during this employment.

nd Leo Hansen (both deceased). Plaintiff currently contends

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 (MANVILLE TRUST) insulation. Plaintiff recall!
EAGLE PICHER cement, Plaintiff applied CHILDERS (H&
ASSOCIATES, INC.) Fibrous Adhesive onto the blocks, and t

s using asbestog-containing
CINVESTMENT
hen adhered the blocks to the

boiler. After the CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
dried, plaintiff “rasped off” the material using a metal rasp, which spread dust throughout his
work areas. Plaintiff recalls J.T, THORPE & SON, INC. was the refractory contractor at this

jobsite. Plaintiff recalls that asbestos-containing materials supplied by WEST

ERN ASBESTOS

COMPANY and J.T. THORPE & SON, INC, were used at this worksite, Plaintiffrecalls other

trades working on a BABCOCK & WILCOX boiler, Plaintiff
employed by CONTRA COSTA ELECTRIC, INC who were d
pipe insulation while installing conduit, Plaintiff recalls maint
were removing asbesios-containing materials from this boiler,

worked near electricians

isturbing asbestos-containin:
enance personnel from PG&L
Plaintiff recalls working near

pipefitters who were removing asbestos from pipes. Plaintiff also recalls other trades sweeping
the areca where he was working, Plaintiff recalls the following co-workers: Earl Riggs
(deceased); Doyle Davidson (deceased); id Story (deceased); Ronald Furia (deceased); Jack

KAlnjnced\ 934 pid -supsee2.wpd 8Jagoda (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 no Exposure ~*
Employer Exposure Job Title Dates
Western Asbestos Colgate Palmolive Insulator TA961-10/1961;
3150 3” Street Berkeley, CA 7/1962-5/1965
San Francisco, CA & verks, on and

oO

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE (MANVILLE TRUST)
pipecovering, and asbestos-containing EAGLE PICHER and 301 cement onto a tank, Plaintiff
used may insulation, JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff
applied CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks,
placed the blocks onto the tank, and “rasped off" the extruded CHILDERS (ec
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it dried, via us¢ of a metal rasp.
Plaintiff recalls working near COLGATE PALMOLIVE laborers sweoping around bis work
area, Plaintiff worked alongside PACIFIC MECHANICAL Conipany pipefitters who were
fabricating iron piping systems. Plaintiff recalls the following contractor: PACIFIC
MECHANICAL, Plaintiff observed L.J. KRUSE COMPANY ipefitters handling asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LIC) gaskets. Plaintiff
observed L.J. KRUSE repacking one new valve using asbestos-containing valve packing
material, Plaintiff recalls the following supervisor: Robert Robbins (deceased). Plaintilf
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.

Location of Exposure
Employer Exposure Job Title Dates
‘Western Asbestos Gerber Foods Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 741962-5/1965
San Francisco, CA G weeks, on and
0

Job Duties: Plaintiff wrapped asbestos-containing insulation with chicken wire and applied all-
purpose cement over it, Plaintiff applied asbestos-containing JOHNS MANVILLE
(MANVILLE TRUST) calcium silicate pipecovering and insulation cements. Plaintiff applicd
JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff applied CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to block, applied the block to
irregular surfaces, and “rasped, off” the extruded CHILDERS (H_ & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive after it dried, via use of a metal rasp, Plaintiff worked
near pipefitters installing ripes valves and asbestos-containing GARLOCK (GARLOCK.
SUALL G TECHNOL cd 38, 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

KAlnjured\l9349\pid\AL-supsuc2.wpd 9Job Duties: Plaintiff worked in proximity to DOUGLASS INSULATION*pipefitters who were
applying calcium silicate material. Pipefitters dismantled a chiller, removing asbestos-
containing GARLOCK (GARLOCK ALING 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 Kearney (deceased); 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
Western Asbestos Pacific Bell Telephone Insulator 1961-1965
3150 3" Street San Francisco, CA (3 months)

San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct wrap and asbestos-containing MUNDET
(CROWN CORK & SEAL COMPANY, INC.) 85% magnesia pipe insulation in an 8 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 proximity to FOLEY ELECTRIC
electricians. Plaintiff observed FOLEY ELECTRIC personnel disturbing previously sprayed
ashestos-containing overhead fireproofing while setting supports for their electrical conduit in
plaintiff's work areas. Plaintiffrecalls the following supervisor, John Straba (deceased).
Plaintiff recalls the following co-workers: Pancho (deceased), and Ron Powers (c/o
BraytonPurcell 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

Job Duties: Plaintiff worked on new construction. Plaintiff delivered materials to this worksite,
Plaintiff applied insulation to piping, fittings and to a large boiler. Pla installed asbestos-
containing block insulation with chicken wire over the top of it. Plaintiff used 352
CANADIAN BLUE asbestos shorts, 127 Blie Cement 85% magnesia cement and EAGLE
PICHER (BAGLE-PICHER INDUSTRIS, INC.) 66 cement, Plaintiff also applied asbestos-
containing PABCO (FIBREBOARD CORPORATION) and OWENS CORNING PIBERGLAS
asbestos pe insulation to flanges on a boiler, Plaintiff recalls that the asbestos-containing
PABCO hy IBREBOARD CORPORATION) and OWENS CORNING (OWENS CORNING
FIBERGLAS) asbestos pipe insulation was sapplicd by PG&E. Plaintiff applied CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks, applied the blocks
to the boiler, and “rasped off" the extruded CHILDERS (H & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive after it dried, via-use of a metal rasp. Plaintiff recalls
general contractor C.C. MOORE (C.C, MOORE & CO, ENGINEERS) employing laborers.
Plaintiff reealls seeing others working on STOCKHAM (SVI CORPORATIONS valves and
strainers which had asbestos-containmg ANCHOR (COLTEC INDUSTRIES, Ne Bagkin on
them. Plaintiff recalls working near boilermakers, employed by BABCOCK & WILCOX who
were installing the boiler and near employees from LT, THORPE & SON, INC, who 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

K Anjused\1934ApldVAL-supsac2.wpd 10CeO YW DH Bw Ne

YN PN NY NN YD NF Be ee ee ee Ee OD
or A A SYS NHN &— Seo we UAH BSH AOS

recalls working near insttlators from OWENS CORNING FIBBRGLAS. Plaintiff recalls th
following supervisor: Thurman Gates erased Plaintiff recalls the following co-workers:
Ron Powers (c/o BraytonPurcell LLP); Jim White, Jr, (Napa, California), Bill Armstrong
(deceased); Ronald Furia (deceased); John Hoyt (c/o Brayton¢Purcell LLP); Art Klimack c/o
Brayton¢Purcelt LLP; Al Leandro (c/o Brayton®Purcell LLP); Walter Lee (c/a .
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); Cart
Ramsey (c/o Brayton¢Purcell LLP); Dick Nelson (deceased). Plaintiff currently contends that
he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Hercules Powder Insulator 7/1961-10/1961;
3150 3" Street Hercules, CA 7/1962-5/1965
San Francisco, CA G so on and
ol

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS) pipecovering,
Taint applied foamglass insulation to piping. Plaintiff applied CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the foamglass, and later “rasped
off” the extruded CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
after it dried, via use of a metal rasp. Plaintiff worked alongside pipefitters who were installing
and removing FLEXITALLIC, INC. gaskets in plaintifi’s presence. Plaintiff worked in
proximity to METALCLAD IN SULATION CORPORA TON insulators who were applying

asbe: containing thermal insulation, Plaintiff recalls the following supervisor: Lowell
Squires (deceased). Plaintiff recalls the following co-workers: Jim White, Jr, (Napa,
Califormia); Lou Hanson (address unknown); Carl Ramsey (c/o Brayton*Pureell 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;
3150 3" Street Areata, CA 7/1962-S/1965
San Francisco, CA (2-3 months, on
and off)

Job Duties: Plaintiff removed asbestos-containing PABCO (FIBREBOARD CORPORATION)
and JOHNS MANVILLE (MANVILLE TRUST) 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 JOUNS MANVILLE (MANVILLE TRUST) and PABCO (FIBREBOARD
CORPORATION) biock 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. Plaintilf
recalls the following supervisor: Robert Evans (deceased), Plaintiff recalls the following co-
workers; Howard Johnson (deceased); Jim White, Jr, (Napa, California); Donald Cox (c/o
Brayton¢Purcell LLP); Edward Meyer (c/o Brayton¢+Purcell LLP); Chatlie Power (deceased);
Myron Jorgenson (deceased); Charles Purcell (deceased); Earl Riggs (deceased); Doyle
Davidson (decease) Harry Fry (deceased), Robert Evans, Ray House (deceased), Plaintiff!
quently contends that he was exposed to asbestos during this employment,

i]

Mt

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by oN NN YN NN NH ee ee ee ia
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Employer
Western Asbestos

3150 3" Street _
San Francisco, CA

KNlnjured\L9340\pld\AF-supsac2.wpd

Location of
Exposure Job Title

Bethlehem Steel. Insulator
Shipbuilding
San Francisco, CA
Triple A Machine Shop
Pier 64)
an Francisco, CA

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
(DD-850)

CHEYENNE
(T-AG-174)

HAWATIAN PLANTER
(1945)

GRAFFIAS
(AF-29

MATHEWS
9

MERRICK

(AKA-97

TWINING
(DD-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY
(1982)

12

Exposure
Dates

7/1961-10/196 1;
7N962-5/1965

(on and off for
approx. | week
each time)oO Cem IN DAN BR WN

BN YP NR RN NY Ke ee eh Re me SB ee
SYA RA Bw HO se Se wera AA RG we =

Location of Exposure
Employer Exposure Job Title Dates

Western Asbesto: BLAND
(contd.) . (APA=T34)

PONTCHARTRAIN
(WPG-70)

CALIFORNIAN
(1946)

Ag RICAN ROBIN 1963-1965
1943)

ROSE KNOT

(1945)

HAWAITIAN
1946)

Job Duties: Plaintiff insulated pipes, turbines, valves, and boilers using asbestos-containing
JOHNS MANVILLE (MANVILLE TRUST) and PABCO (FI3REBOARD CORPOR ATION)
block and pipecovering. Plaintiff removed and repaired asbestos-containing insulation.
Plaintiff used asbestos cloth fo wrap around valves and boilers, Plaintiff recalls using EAGLE
PICHER cements and 352 Blue Mud cement. Plaintiff worked near pipefitiers who were
removing asbestos-containing insulation and who were { ing pipes, asbestos-containing
gaskets, valves and pumps. Plaintiff recalls pipefitters in his work area installing asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskeis 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 (FOSTER WHEELER
LLC (FKA FOSTER WHEELER CORPORATION)) 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 asbesios-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
and/or FLEXITALLIC, INC, gaskets aboarel several of these ships. Plaintiff observed shipyard
personnel inching TRIPLE A personnel who were tearing off asbestos-containing thermal
Insulation and who were sweeping aud cleaning asbestos-containing debris in plaintiff's
presence, Plaintiff recalls the following 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 Jorgenson (address unknown); Harvey

orgensen (address unknown); James Logue (c/o Brayton*Purcell LLP); Tony Lopes, Fremont,
California; Andy Grant (address unknown); Richard Porter (address unknown); Joseph
Sandoval (deceased); Robert Sandoval (deceased); William Stein (address unknown); Bd Story
(deceased); Fred Strickland (deceased); Howard Tracy (deceased); Jack Kish (deceased); Paul
Schiebold (San Francisco, California); Dale Wri ght (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,

Mit

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Location of ~ Exposure
Employer Exposure Job Title Dates
Western Asbestos Grace Cathedral Insulator WU 1961-10/1965;
3150 3" Street San Francisco, CA. 7/1962-5/1965
San Francisco, CA @ eels, on and
0

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
clothes and skin were covered with dust. Plaintiff used asbestos-containing PABCO.
(FIBREBOARD CORPORATION) cal sil pipe insulation, FOSTERS (BAYER
CROPSCIENCE INC.) 30-36 mastic and JOHNS-MANVILLE (MANVILLE TRUST) 301
cement, Plaintiff recalls the following foreman: Paul Schiebotd (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 a days, on and
0!

Job Duties: Plaintiff made asbestos 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 Job Title Dates
Western Asbestos PG&E Nuclear Powerhouse Insulator TH961-10/1961;
3150 3" Street Humboldt County T962-12/1962
San Francisco, CA Eureka, CA 6 ones, on and
ol

Job Duties: Plaintiff carried asbestos-containing materials to co-workers, Plaintitf applied
asbestos-containing mag blocks and pipecovering to pipes valves and vessels. Plaintiff installed
352 cement and FOSTER’s (BAYER CROPSCIENCE INC.) and CHILDERS (H& C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive. Plaintiff applied the FOSTER ’s
(BAYER CROPSCIENCE INC.) and CHILDERS (H & C INVESTMENT ASSOCIATES,
INC.) Fibrous Adhesive to blocks, applied the blocks to the reactor top, and “rasped off” the
extruded, dried FOSTER’s (BAYER CROPSCIENCE INC.) and CHILDERS (H_ & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesives using a metal rasp, which spread dust
throughout plaintitf’s work areas. Plaintiff used asbestos-containing JONNS-MANV. LE
MANVILLE TRUST), 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); Donatd Cox (c/o Brayton*Purcell LLP); Ronald
Furia (deceased); Howard Johnson (deceased); Charles Tobey (c/o Brayton+Purcell LLP);
Doyle Davidson (deceased); Barl Riggs (deceased); Richard Gross (deceased), Plaintiff
currently contends. that hé-was exposed to asbestos during this employment.

W

KAlnjured\{9349\pld\AE-supsaez.wpl 14Come BA A RW He

Bon 2S

Location of Exposure
Employer Exposure Job Title Dates .
Western Asbestos PGE a Insulator 7/1961-10/1961;
3150 3 Street ~ San Francisco, CA T1962-5/1965
San Francisco, CA (Potrero Station) (2 to 3 weeks, on

and off)

Job Duties: Plaintiff recalls working on a boiler during a remodel. Plaintiff recalls applying
KAY'LO (OWENS CORNING FIBERGLAS) asbestos blocks and PABCO (FIBREBOARD
CORPORATION) all-purpose cement, Plaintiff applied CHILDERS (1 & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive to the blocks, apptied the blocks to the boiler surfaces,
and “rasped off” the extruded, dried CHILDERS (H & C INVESTMENT ASSOCI ATES, INC.)
Fibrous Adbesive, via use ofa metal rasp. Plaintiff worked near employees from PG&E who
were sweeping and cleaning asbestos laden dust and debris in hig area, Plaintiff recalls the
following supervisor: John Straba (deceased). Plaintiff eurrently contends that he was exposed
to asbestos during (his employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Dow Chemical Insulator 7/1961-10/1961;
3150 3™ Street Pittsburg, CA 1/1962-5/1965
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 CORPORATY IN)
cement and 352 BLUE cement to a large tank. Plaintiff applied CHILDERS (H& C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the blocks, adhered the blocks to
the tank, and “rasped off” the extruded CHILDERS (I & C INVESTMENT ASSOC “IATES,

INC.) Fibrous Adhesive afier it dried, via use of a metal rasp. Plaintiff re

{ls working near

pipefitters installing pipes, valves, umps and PLEXITALLIC, INC. gaskets, Plaintiff recalls

the following forer

man: Robert Robbins (deceased), Plaintiff recalls the following co-workers:

Lou Hansen (deceased); Robert Sandoval (deceased); Charles Tobey (c/o Brayton%Purcell

LLP); Barl Riggs (
was exposed fo asl

deceased); Doyle Davidson (deccased). Plaintiff currently contends that he
bestos duriny this employment,

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Shell Oil Insulator 7/1961-10/1961;
3150 3" Street Martinez, CA 7/1962-5/1965
San Francisco, CA & york on and
0:

Job Duties: Plaint

if cut asbestos block insulation and mixed and applied insulating cement.

Plaintiff worked with asbestos-containing insulating products manufactured by JOHNS-
MANVILLE (MANVILLE TRUST), and with KAYLO (OWENS CORNING FIBERGLAS) .
Plaintiff worked next to PLANT ASBESTOS (PLANT INSULATION COMPANY) insulators
who applied CTULDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to
block insulation, adhered the blocks to a tank, and “rasped off” the dried, extruded CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive before applying a finish,
which caused visible dust to spread throughout plaintiff's work area, Plaintiff recalls working

near pipefitters fro
asbestos-containin,

m FOLEY -PMI installing pipes, new LUNKENHEIMER valves, pumps and
1 DURABLA (DURABLA MANUFACTURING COMPANY, INC.)

KAinjured 193 49pld\Al-supseo2.wpd 15Co me YW DA A FF Bw NY

RRR NR NN NN Be Be ee eB oe Se Be Be
ont DN DH Bh WN KF OD Se HT DH SF YW NH KF S&S

gaskets, Plaintiff also observed FOLE-Y-PMI pipefitters removing existing DURABLA flange
askets in his presence, on approximately 4 io 20 occasions. PLANT ASBESTOS COMPANY

PLANT INSULATION COMPANY) supplied asbestos-containing insulation materials,

including PABCO (FIBREBOARD CORPORATION) pipe-covering to the site. Laborers

| employed by general contractor ALBAY CONSTRUCTION swept and shoveled asbestos-. -

containing JOHNS MANVILLE (MANVILLE TRUST) Thermobestos block insulation debris,
asbestos-containing insulation cement debris and dust, and debris created by sawing of 85%
magnesia pipe covering, Plaintiff recalls the following foreman; Robert Robbins (deceased).
Plaintiff recalls the folowing co-workers: Lou Hansen (deceased); Jim White, Jr. (deceased );
Charles Tobey (wo Brayton*Pureell LLP); Robert Sandoval (deceased); Ed Meyer (c/o

BraytonPurcell 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 T/1961-10/1961;
3150 3" Street Oakland, CA 7/1962- 12/1962
San Francisco, CA oveks on and

0

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 (FIBREBOARD CORPORATION) cement, Plaintiff recalls working near
boilermakers, and near pipefitters who were installing gaskets. Plaintiff observed PO&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,

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Vallecitos Atomic Insulator 7/1961-10/1961;
3150 3" Street Laboratory 71962-5/1965
San Francisco, CA Pleasanton, CA Gove ks, on and
0

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
block insulation, KAYLO (OWENS CORNING FIBERGLAS) pipecovering, 352 cement,
BAGLE-PICHER INDUSTRIES, INC. 66 mud, and new LUNKENHEIMER COMPANY
valves, while insulating a boiler and associated piping. Plaintiff applied CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the blocks, adhered the blocks to
the boiler and fo irregular surfaces, and “rasped off” the exwuded CHILDERS (H & C
INVESTMENT ASSOCIATRS, INC.) Fibrous Adhesive after it bad dried, via use ofa metal
rasp. Plaintiff had to crawl mio 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: Lon Hansen (deceased); Robert Sandoval (deccased); Ed Meyer (c/o |
Brayton*Purcell LLP), Plaintiff currently contends that he was exposed to asbestos during this
employment.

Mt

KAlnjsreds19349\phd\A Esupsac2.wpd 16Como TA mH FR WN

RM BP RMP NM NN MR Be Be ee ee ee me Be
Se 3 AA FF &bNH |= SO we RADA BOW KH SH ST

Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos Missile Base Insulator 7/1961-10/196 L

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

San Francisco, CA (1 month, on and
0

Job Duties: Plaintiff applied rubber insulation and 520 mastic. Plaintiff worked near other
fradesmen who installed asbestos-containing ANCHOR (COLTEC INDUSTRIES, INC.
packing, and asbestos-containing DURABLA (DURABLA MANUFACTURING COMPANY,
INC.) gaskets. Plaintiff observed workers removing existing DURABLA gaskets on numerous
oceasions in bis presence, Plaintiff worked near welders who were using asbestos blankets.
Plaintiff worked near electricians and near pipefitters who were installing pipes, asbestos-
containing DURABLA (DURABLA MANUFACTURING COMPANY, INC.) gaskets, and
pumps, Laborers built scaffolds and swept asbestos-containing PABCO (FIBREBOARD.
CORPORATION) 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 (FIBREBOARD CORPORA