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

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                                , LLP

SCO, CA mid

Sule 1300

109 BUSH ETREBT

KEENEY & CORDERY
SAN ERA

‘LAW OFFICES

IMAI, TADLOCK,

{413} 875-7000

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Bruce Imai, Esq. (Bat No, 053800)
Tina Yim, Heq. (Bat No. 232597)

IMAL TADLOCK, KEENEY & CORDERY, LLP

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

Attomeys for Defendant
COMMAIR 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,

Plaintifis,

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

Defendants.

_ Attached is EXHIBIT L PART 1 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 1 OF 2 TO THE
DECLARATION OF TINA YIM IN SUPPORT
OF COMMAIR MECHANICAL SERVICES’
MOTION FOR SUMMARY JUDGMENT OR,
IN THE ALTERNATIVE, SUMMARY
JUDGMENT: - ”

Date: May 9, 2013 .

Time: 9:30 a.m, -

Dept: 503 :

Judge: Hon. Teri L. Jackson

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

EXHIBIT L PART 1 OF 270 THE DECLARATION OF TINA YIM IN SUPPORT OF COMMAIR:
MECHANICAL SERVICES" MOTION FOR SUMMARY JUDGMENT Of, IN THE ALTERNATIVE,
SUMMARY JUDGMENTLAW OFFICES

, LLP

KEENEY & CORDERY

IMAI, TADLOCK,

sulTe L400

PROOF OF SERVICE

1, Heather Cherry, declare:

Tam a resident of the State of Califomia and over the age of eighteen years, and not a
arty 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 1 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 tansmitting 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 above to the person(s) at the
address(es) set forth below,

' |] 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.

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

I declare under penalty of perjury uhder the laws of the State of Califomia that the above
is true and correct.

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

/sf Heather Cherry
Heather Cherry

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

Qe
ATLACHED 15 EXHIBIT L PART 1 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES" MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY JUDGMENT.1 PROOF OF SERVICE
2 Oe
3 I, Tina Yim, declare:
Tam aresident of the State of California and over the age of eighteen years, and not a
4)| party to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA
5 94104. On the date of execution below, I served the within documents:
EXHIBIT L PART 1 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF i
6 COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT. \
7 OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT
by transmitting via facsimile the document;s) listed above to the fax numberfs) set
g foxth below on this date before 5:00 p.m.
9 by placing the document(s) listed above in a sealed envelope with postage thereon.
a 10 fully prepaid, in the United States mail at San Francisco, California addressed as set
3 forth below. : 7 ‘
= ul ee i
a ® by personally delivering the document(s) listed above to the person(s) at the
a 12 L_
Bs address(es) set forth below: .
os 13 :
» a BSE Brayton Purcell, LLP
z meee 14 222 Rush Landing Road
SGREe> Novato, CA 94945-2469
ger sae 15 . .
Z z 16 Qn the date of execution below, I electronically served the document via File &
8 3 ServeXpress on the recipients designated on the Transaction Receipt located on the.
8 v7 File & ServeXpress Web site. .
=
a
3 18 I declare under penalty of perjury under the laws of the State of California that the above
z is true and correct.
19
Executed on February 22, 2013, at San Francisco, California.
20 Lo
21 oe
oe és Tina Yim
22 . . Tina Yim
23|| Ross. Robert and Jean v, C.C, Moore & Co: Engineers, et al.
34 || SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731
25
26
27
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3.
ATTACHED IS EXHIBIT L PART | OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY JUDGMENT,EXHIBIT L3
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ALAN R. BRAYTON, ESO., 8.B. #73685
ERIC C. SOLOMON, ESQ., 8.5. #119131
BRAYTON PURCELL LLP

Attomeys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

| Attomeys for Ptaintiffs

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS,

Plaintiffs,

ASBESTOS

No. CGC-10-275731

¥S.

a

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

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES

RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NO: ONE
ANSWERS
1 a. ROBERT BRUCE ROSS.

b September 9, 1935.
c. 75 years.

a San Francisco, Califormia.

& 6440 East Calle Cayillo, Tucson, Arizona 85750.

Height: 3'11", weight: 215 pounds.
5 58-42-3662. :

Po ot

Not applicable.

ENjured\(9349%pldua-sacsf L wep 1

; ANSWERS TO INTERROGATORoOo Pm Wm BR Ow ow

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Bees oeortaaeoep os

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i, Not applicable,

US 562 37 507.
DO1863195.

Robert or Bob Ross,

r

to. 12" grade, 2 years junior college.
nh Jean Ross.

a October 28, 1936.

B December 15, 1974.

qe Same ag I.e., above.
r Retired.
5. Judy Csborne.
t. 1963.
u Divorced,
2, a Diane Ross.
b. 1963.
e Natural.
d. 21058 Perrigan Drive, Bend, Oregon 97702_
€, Hairdresser.
£ Living.
3 No.
4. None.

S. Piaintiff is currently able to recall the following addresses:
present: 6440 East Calle Cavillo, Tucson, Arizona 85750.
Plaintiff's investigation and discovery are continving.

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

&g. No,
3 Plaintiff was a member of the United States Army from 1954 to 1956.

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Plaintit? s

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service number is US 562 37 507. Please see response to Lnterrogatory No. 26, below.

10. Excluding plaintiff's expert consultants, plaintiff recalls the follawing physiofans:

a Dr. Amold Hollander.

b. 1200 North El Dorado Place, Tucson, Arizona,

c Biopsy.

d, October 2010 te the present.

2. Colon cancer,

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

4. Dr. Roger A. Davis,

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

c Bload work, exams and treatment.

4 September 2010 to the present.

e. Tests and blood work.

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

a, Unknown at present.

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

“ General health maintenance exams and treatments.

4, 2010 to the present,

8, General health maintenance.

f Plaintiff has provided authorizations for the release of medical records ta

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

‘FA uresh] 9349 \plehai-aacal Lp 3a, Unknown at present.

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

c Cancer screening, and related treatment.

d, October 2010 to the present.

6 Colon cancer.

£ Plaintiff has provided authorizations for the release of medical records to

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

a Plaintiff does not recall.

be Queen of the Valley Hospital, Napa, California.

e Plaintiff was treated for a kidney stone.

da Approximately 2000.

é. Kidney stone.

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

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

the following hospitals:

a. Palo Verde Surgical Associates.

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

o. Surgery for colon cancer, and related care.

d. October 2010.

e. Colon cancer, surgery.

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

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

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

KAlojused\ 934% pldai-satel apd 41 Plaintiff was treated for a kidney stone.
2 d. Approximately 2000.
3], & Kidney stone.
4 of Plaintiff bas provided authorizations for the release of medical records to
5 || Bey & Berry. Defendants may obtain copies of records through Berry & Berry.
6 12, Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
: 7 | following x-rays: .
8g a Cascade Medical Imaging, address unknown.
9 b August 29, 2005; 1 view.
10 t Chest.
1] a Unknown,
12 & Plaintiff's investigation and discovery are continuing,
13
I¢ a Radiology Lig, Tucson, Anzona.
154. D. December 2005.
16 , & Chest.
7 . ad Unknown.
18 ¢. Plaintiff's investigation and discovery are continuing.
19 13. Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
20 || following pulmonary fimetion tests:
21 a Bend Memorial Hospital, Post Office Box 1018, Bend, Oregon 57708.
22 b September 2005,
23 ¢, Dr. Jacabs; David Fredstrom.
24 4. Follow up for CT scan.
25 a Unknown.
26 f. Na.
27 zB Not applicable.
, 28 h. Plaintiff's investigation and discovery are continuing.
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14.

Please see response to Interrogatory No.'s 10 and 11, above. Plaintiff defers to his

medical records as the best source of information for medications prescribed.

15.

Not at this time, Plaintiff's medical records are equally available to defendants

through Berry & Berry, designated defense counsel.

16.

Plaintiff has the following complaints from asbestas exposure: shortness of

breath, coughing and tiredness.

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

d. Plaintiff contends that his lungs have primarily been affected. However,

as the lung fiction affects the rest of the body, plaintiff also cantends that all parts of his body
have been affected.

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

& Plaintitf does not at this time contend that he has lost time from work as a

result of his asbestas related conditions. Plaintiff's investigation and discovery are continuing,

17.

h. Not applicabie.
i, Plaintiff's investigation and discovery are continuing.
Yes.

a-b, Plaintiff was diagnosed with colon cancer on or about October 2010, and

with asbestosis and asbestos-related pleural disease on or about May 2009.

cl Information protected by either the attormey work-product doctrine or the

attorney-client privilege. Plaintiff's investigation and discovery are continuing.

18.
19.
20.
21.
22.

No.

Shortness of breath, and coughing.
See Interrogetory No. 10, above.
Unknown.

Yes.

a-t. Plaintiff suffered a back injury on 1973. Plaintiff's investigation and

KAinjurect$o49%pldtintatel Lynd 61} discovery are continuing.
2 23. Yes,
3 a. Plaintiff recalls snoking from 1950 to 1983.
4 b. Plaintiff recalls smoking cigarettes. Plainiiff inhaled.
3 c. Plaintiff recalls he wswally smoked approximately 20 cigarettes per day.
6 d. Plaintiff recalls he usually smoked 1 pack of cigareties per day.
7 &. Plaintiff recalls smoking Lucky Strike, Camel, Kool, Kent arid Marlboro
8 brand cigarettes. '
9 £ No,
10 24, Yes, ‘
11 a Gordon Rass, plaintiff's father.
R b.  193St0 1983,
13 c. Raleigh brand cigarettes,
14 d Unknown,
15 25. Plaintiff recalls first consuming alcoholic beverages at age 15. Plaintzff stopped
16 | drinking approximately 25 years ago, and currently does not consume alcoholic beverages.
17 26. Plaintiffis currently able to identify the following employment information:
18 Location of Exposure
Employer Exposure . Job Title * Dates
8 General Mills Company General Mills Warehouseman 1952-1/1954; 4
20} P.O. Box 1113 Vallejo, CA 2/1956465/1 956 £

Minneapolis, MN

21 .
Job Duties: Plaintiff worked in the feed mill. Plaintiff swept floors. Plaintiff is currently
22) unaware if he was exposed to asbestos during this employment. .
23 Location of Exposure
Employer Exposure Job Title Dates
24
United States Army Fort Ord, Monterey, CA; Infantryman 2/9 /54- 1/27/56
25 United States Army

Okinawa, Japan

Job Duties: Plaintiff served in the United States Army as an infantryman. Plaintiff served at Fo:
27]| Ord, Monterey, Califomia, for 16 weeks, and the remainder of his time in Okinawa, Japan.
Plaintiff performed maneuvers and combat exercises. Plaintiff is currently unaware if Ee was
28] expased 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 42/1959-1/1960
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 waware if be was exposed t
asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Philip Carey Warehouse Warebonseman = 2/1959-8/1959:
Cincinnati, OH 101 Williams 12/1959-1/1960

San Francisco, CA C1 week)

Jack Tar Hotel

(aka Cathedral Hitl Hotel)

1101 Van Ness

San Francisco, CA

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

Plaintitf worked out of Heat & Frost Insulators and Asbestos Workers Local Union No. 16
Plaintiff recalls applying asbestos-containing insulation ts pipes, pumps, flanges, valves, duct
work, plenums, boilers and vessels. Plaintiff cut the asbestos-containing pipe insulation with a
hand saw. Plaintiff mixed asbestos cement and applied cement to fittings and lrepular surfaces,
Plaintiff worked in proximity to the follawing trades: Plumbers, pipefitters, sheet metal workers,
electricians, sprinkler fitters, carpenters, laborers, lathers and plasterers, drywallers, floor
installers and ceiling installers. Plaintiff worked in proximity to plumbers disturbing existing
insulation and fireproofing. Plaimiff worked in proximity to pipefitters working on pumps andoom aT ON A me Ow ONO

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PRRRB Se RFA EAH AS

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vatves, and working with asbestos-containing gaskets and packing. Plaintiff worked in proximity
to sheet metal workers disturbing existing asbestos-containing fireproofing insulation and
installing asbestos-containing flexible duct connectors. Plaintiff worked in proximity to
electricians stripping asbestos insulated wire and disturbing existing asbestos-containing
fireproofing and insulation. Plaintiff worked in proximity to sprinkler fitters disturbing existing
asbestos-containing fireproofing insulation, Plaintiff worked im proximity to laborers performiny
general clean up, including sweeping up asbestos-containing debris, which caused dust, Plainti
worked in proximity to carpenters disturbing existing asbestos-containing fireproofing insulation |
Plaintiff worked in proxi to lathers and plasterers mixing asbestos containing plaster and
disturbing existing: firepreofate:and insulation: Pham vce dir proximity tore
cutting drywall, taping joints, and mixing and sanding asbestos-containing joint compound,
which was a dusty process, Plaintiff worked in proximity to floor installers using a circular saw
to cut floor tiles that contamed asbestos. Plaintiff worked in proximity to ceiling installers
disturbing existing ashestos-containing fireproofing insulation. Plaintiff cut asbestos containing
insulation with a power saw and applied asbestos containing canvas and asbestos cloth, Plainti!
currently contends that he was exposed to asbestos during this employment.

Exposure

Location of
Emplover 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 te joume

insulators. Plaintiff recalls working with

JOHNS-MANVILLE block insulation, Plaintiff recalls scoring and cutting the block insulation

with a handsaw._ Platntiff recalls mixing all-purpose cement and using JOHNS MANVILLE 352
BLUE cement, Plaintiff currently contends he was exposed to asbestos during this employment.

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

Job Duties: Plaintiff msulated pipes under the loading docks and in the pipe hangers Plaintiff
installed asbestos-containing imsulation on pipes and on the boiler in the boiler room, Plaintiff

zeealls boilers manufactured by the following: POSTER.

WHEELER CO!

RPORATION and

BABCOCK & WILCOX COMPANY. Plaintiff recalls using UNIBESTOS insulation and

OLOG!

magnesium, Plaintiff recalls working near pipefitters installing pipes and asbesios-containing
GARLOCE (GARLOCK SEALING TEC 5. LLCS gaskets. Plaintiff worked near
the installation ofa new BELL & GOSSETIT (TT INDUSTRIES, INC pomp which had
original manufacturer's asbestos-containing gaskets wired to it. Plaintiff recalls the following
co-workers: Jack Kish (deceased); Rod Hochstrasser (deceased); Ed Fleigher (deceased).
Plaintiff cuzrently contends that he was exposed to asbestos during this employment.

Location af Exposure
Employer Exposure Job Title Dates
Universal Insulation Hewlett Packard Insulator 1939 (1-2 weeks)
$20 6" Avenue Menlo Park, CA (Apprentice)
Menlo Park, CA

Job Duties: Plaintiff installed asbestos-containing insulation and all-purpose cement on the
fittings. Plaintiff installed asbestos-containing PABCO (FIBREBOARD CORPORATION)
insulation and EAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.) insulation cement on

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

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

Berkeley, CA C1 week}

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

employment.
Location of Exposure
Employer Exposure Job Title Dates
Western Asbestas Tidewater Associated Oil ‘Insulator 1959-1965
Avon, CA (3 weeks)

Job Duties: Plaintif applied asbestos-containing msulation to a tank. Plaintiff applied EAGLE-
PICHER (EAGLE-PI! R INDUSTRIES, IN id fabestos-containinng cement on the heads and
fittings. Plaintiff applied KAYLO (OWENS CORNING FIBERGLAS) asbestos-containing
insulation on pipes. Plaintiff recalls using JOHNS-MANVILLE asbestos-containin;
pipecovering Plaintiff recalls the following contractors at this site: PLANT ASBESTOS
BOMPA (PLANT INSULATION COMPANY) and BAY CITIES ASBESTOS CO., LTD.

TIDEWATER. REFINERY laborers swept and shoveled asbestos-containing debris near plaintiff] .

Plaintiff recalls the following foremen: Robert Robbins (deceased); and Allen Holbroo
(deceased). Plaintiff recalls the following co-workers: Lou Hanson (address unknown); Robert
Robbins (deceased), Robert Sandoval (deceased); Ron Furia (deceased); and Laurance Hagen

c/a Brayton’ Purcell LLP). Plaintiff recalls the following employees of PLANT INSULATION

OMPANY (ELANT INSULATION COMPANY): Ron Powers (e/o Brayton*sPurcell LLP),
Steve Steele (address unknown). Plaintiff currently contends thar he was exposed to asbestos
during this employment.

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Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos * PG&E Powerhouse Insulator 11960-7/1960
4150 3" Street Pittsburg, CA.

San Francisco, CA

Job Duties: Plaintiff worked on new construction. Plaintiff mixed asbestos-containing

insulatin;

cement and scored asbestos blocks with asaw. Plaintiff used asbestos-containi

JOBNS-MEANYVELER pinseovering, EAGER PICHER cement and al}

Plaintiff installed asbéstos-containing insulation on eqazpment and pipes. Plaintiff worked near
refractory workers from .T. THORPE & SON, INC. who were installing asbestas~containin;
block, cements and refractory matetials in the boilers. Plaintiff worked near boiler makers wha
he recalis were from J.T. THORPE & SON, INC. Carl Ramsey (c/o Brayton**Purcell LLP} was
a member of the J.T. THORPE & SON, INC. crew. Plaintiff worked near welders using
asbestos-containing welding blankets, laborers sweeping up the site and pipefitters installing
gaskets, valves and pipes. Thurman Gates (deceased) was plaintiff’s supervisor. Plaintiff recalls
the following co-werkers: Charles Purcell (deceased), Jack Kish (deceased); John Hayt (c/o
Brayton Purcell LLP}; Donald Cox {c/o Brayton Parcell LLP); Ed Story (deceased); Charlie
Power (deceased), Plaintiff currently contends that he was exposed to asbestos during this

se Cement af tits site:

employment.

, Location of Exposure
Employer Exposure Job Title Dates
Wester Asbestos use of the Valley Insulator F960 (3 weeks)
31503 Street ospital
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 whem he tried to remove
them, causing a cloud of dust, Plaintiff insulated pipes in the boiler room with asbestos-
containing JOHNS-MANVILLE pipecovering and all purpose cement. Plaintiff recalls the
following co-worker: Jim White, Jz., Napa, California. Plaintiff currently contends that he was
exposed to asbesias during this employment.

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

Job Duties: Plaintiff insulated domestic hot water pipes and ducts. Plaintiff used asbesias-
containing UNIBESTOS UN ARCO pipecovering. Plaintiff recalls the following supervisor:
Richard Holmes (deceased). Plaintiff recalls the follo co-workers: John Chulick (c/o
Brayton**Purrell LLP); Ron Furia (deceased); Charles Tobey (c/o Brayton*Purcell LCP);
Charhe Power {deceased)s James Kearney, (deceased), Roger Fonken (c/o Brayton*Purcell
LLP); Donald Cox (o/¢ Brayton’Purce]] LLP}. Plaintiff currently contends he was exposed to
asbestos during this employment.

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it

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MR RD Ne am i
BERR PR ORE FS Carn agatEBR AGS

Location of Exposure
Employer Exposure Job Title Dates

Westem Ashestos McKinleyville High School Insulator 741961-10/1961;

3150 3 Street McKinleyville, CA ~ TA962~5/1965

Sam Francisco, CA (34 weeks, on
and off}

| Job Dutiés: Plaintiff worked at this site multiple times for about three, and 4 weeks total during

the new constructor ofthe high schook Paint tppiied'astsests-contaming JOHNS-
MANVILLE mag pipecovering and used all purpose cement for the fittings, FRANK. M.
BOOTH and BRIZ. CONSTRUCTION pipefitiers and sheetmetal workers disturbed

reviously sprayed asbestos-containing MONGKOTE (W.R. GRACE & CO.) overhead

reproafing while setting pipe supports and duct supports in plaintiff's work areas. FRANK M.,
BOOTH personnel. cut and installed asbestos-containing flexible duct connectors next to plaintift|
and his crew, Plaintiff recalls working near laborers employed by FRANK M. BOOTH who
performed clean-up and sweeping and CALIFORNIA DRYWALL drywall hangers, tapers and
sanders. Plaintiff recalls the following co-worker: Harold 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 Tasulator 1961-1965
3150 3 Street Redding, CA (L month)
San Francisca, CA

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

Location of . Exposure
Employer Exposure Job Title Dates

Westem Asbestos Tidewater Oil Company = Insulator 1961-1962
3150 3” Street Avon, CA. {Approx I month)
San Francisco, CA

Job Duties: Plaintiff recalls insulating pipes and vessels. Plaintiff used asbestos containing
EAGLE PICHER cement,.and asbestos-containing KAYLO (OWENS CORNING FIBERULAS)
block insulation, Plaintiff worked near laborers, were employed by PLANT MAINTENANCE.

(PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping existing asbestos-
cantainin| pine insulation, Sweeping up the site and carrying products to the workers. PLANT
ASBES’ COMPANY (PLANT INSULATION COMPANY) personnel were applying
asbestos-containing PABCO (FIBREBOARD CORPORATION) calcium silicate pipecovering
near plaintiff for approximately 3 days. Plaintiff saw CROCKETT ELECTRIC electricians
performing electrical work in his work areas. Plaintiff worked alongside pipefitters who were
installing and removing asbestos-containing FLEXITALLIC, INC. gaskets. Plaintiff recalls the
following co-workers: i Hanson (address unknown); Rebert Robbins deceased); Robert
Sandoval (deceased}. Plaintiff currently comtends that he was exposed to asbestos during this
employment. .

121

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PM Se ee Se es ee ee
BORRE BRA SF Se DRG RG SS

Silicate block insulation on a vessel using ashestos-containing CHILDERS Fibrous Adhesive to

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

San Francisco, CA
Job Duties; Plaintiff worked on an addition to the plam. Plaintiff cut and installed calcium

adbere the biock. Plaintiff far trowelet asbestos-contaiming EXGEE MCHER cement on the
vessel. Plaintiff installed asbestos-containing JOHNS-MANVILLE pipecovering, Plaintiff's co-
workers included Robert Robbins and Leo Hansen (both deceased). Plaintiff currently contends
that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Tnsulater 1961-1965
3150.3" Street Pittsburg, CA (3 months)

San Francisco, CA

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

Location of Exposure
Emplover Exposure Job Title Dates
Western Asbestos Calgate Palmolive Insulator 71961-10/1961;
3150 3" Street Berkeley, CA T962-5/1 965
San Francisco, CA (5 weeks, on and
a!

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE Pipecovering, and
asbestos-comtaining EAGLE PICHER and 30[ cement onto a tank. Plaintiff used mag insulation,
JOHNS MANVILLE 352 BLUE cement. Plaintiff recalls working near COLGATE
PALMCLIVE laborers sweeping around his work ares. Plaintiff recalls the following contractor,
PACIFIC MECHANICAL, Plaintiff observed L.J.. KRUSE COMPANY pipefiters handling
asbestos-containing GARLOCK (GARLOCK SEALING TECHNGLOGIES, LLC) gaskets.
Plaintiff observed L.J. KRUSE repacking one new valve using asbestos containing valve packing!
material. Plaintiffrecalls the following supervisor: Robert Robbins (deceased). Plaintiff recalls
the following co-workers: Lowell Squires (deceased); Jim White, Je. (Napa, California); Lou
Hansen (deceased); Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to ashestos daring this employment.

13DO Oo WM DH HW RB Ww HN

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestas Gerber Foods Insulater 74196] «10/1961;
3150 3 Street Oakland, CA 7/1962-5/1965
San Francisco, CA (3 weeks, on and

off)

Job Duties: Plaintiff wray asbestos-containing insulation with chicken wire and apglied all-
purpose cement‘over it, Plaintiff sppliadasbestos-contsinng FOUNS MANVILLE caleiiun ,

silicate pipecovering and insulation cements. Plaintiff applied JOHNS MANVILLE 352 BLUE
cement, Plaintiff worked near ipefitiers installing i valves and asbestos-cantaini
GARLOCK (GARLOCK SEAL iG TECHNOLO! IES, LLC) gaskets. Plaintiff s the
following co-workers: Bennie Norrie (deceased), Lou Hansen (deceased); Robert, Robbins
(deceased). Plaintiff currently contends that he was exposed to asbestos during this emplayment.

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

San Francisco, CA.

Job Duties: Plaintiff worked in proximity to DOUGLASS INSULATION pipefitters whe were.
applying calcium silicate material. Pipefitters dismantled a chiller, removing asbestos-containing
GARLOCK. (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff observed
pipefitters working on a puny , which involved replacement of asbestos-containing GARLOCK
{GARLOCK SEALING ECHNOLOGIES. Lich 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,

Employer Location of Exposure.
. Exposure Job Title Detes

Wester Asbestos Pacific Bell Telephone Insulator 1961-1965

3150 3" Street San Francisca, CJ (3 months)

San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct weap and asbestos-containing MUNDET 85%
magnesia pipe insulation in an & story building. Plaintiff worked in the boiler room where
asbestos insulation was being removed and installed Plaintiff worked near laborers who were
sweeping the floors and i efitters who were installing and removing asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plairitiff worked in

roximity to FOLEY ELECTRIC electricians. Plaintiff recalls the following supervisor, John
Eraba (deceased). Plaintiff recalls the following co-workers: Pancho, and Ron Powers (c/o
BraytonPurcell LLP). Plaintiff currently contends that he was exposed ta asbestos during this
emplosanent.

Location of . Exposure
Employer Exposure ‘ob Tith Dates
Western Asbestos PG&E Insulator 1961-1965
3150 3” Street Antioch, CA (5-6 months)

San Franciseo, CA

4wo Wa RA tr FR Ww Ne

ee
BRSBEBEERARRE GH TS

23

Job Duties: Plaintiff worked an new construction. Plaintiff delivered materials to this worksite.
Plaintiff installed ashestoscontaining block insulation with chicken wire over the top of it.
Plaintiff used 152 CANADIAN BLUE asbestos shorts, 127 Blue Cement 85% magnesia cement
and EAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.) 66 cement. Plaintiff also applied
asbestos-containing PABCO (FIBREBOARD CORPORATION and OWENS CORNING
FIBERGLAS asbestos pipe insulation to flanges on a boiler. Plaintiff recalls that the asbestos-
containing PABCO and OWENS CORNING asbestos pipe insulation was supplied by PG&E.
Plaintiff recalts general contractor €.C, MOORE employing laborers. Plaintiih recalls seeing

| others working on STOCKHAM valves and strainers which had asbestos-containing ANCHOR

ekg ort them, Plaintiifrecalts werking-near boilemmskers, employed by BABE K &
WIL :X who were installing the boiler and neat employees from J.T. 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 recalls working near insvlators from OWENS CO. (G FIBERGLAS. Plaintiff
recalls the following supervisor: Thurman Gates (deceased). Plaintiff recalls the following co-
workers: Ron Powers (/o Brayton’+Purcel] LLP); Jim White, Jr. (Napa, California); Bill
Ammstrong (deceased), Ronald Puria (deceased); John Hoyt (c/o Brayton? Purcell LLP}; Art
Klimack c/o Brayton Purcell LLP; Al Leandro (c/o Brayton*Purcell LLP); Walter Lee (c/o
Brayton%Purcell ie Derrell Cozby (c/o Brayton Purcell LE Maurice Lawrence (e/o

cio

Brayton Purcell LLP}; John Kiss (deceased), Paul Westbrook Brayton® Purcell LLP), Carl
Ramsey (c/o Brayton Purcell LLP); Dick Nelson (deceased). Plaintiff currently contends that
he was exposed to asbestas during this employment.

Location of Exposure
Employer Exposure Job Title Bates
Western Asbestos Hercules Powder insulator F/1961-1 0/1961;
3150.34 Street Hercules, CA VW1962-5/1965
San Francisco, CA Canoe. on and

a

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS} pipecoverin;
Plaintiff worked alongside pipefitters who were installing and removing PLERITALLIC. fc.
gaskets in plaintiff's presence. Plaintiff worked in proximity 10 METALCLAD INSULATION
CORPORATION insulators who were applying asbestos-containing thermal insulation. Plaintiff]
Tecalls the following supervisor: Lowell Squires (deceased), Plaintiff recalls the following co-
workers: Jim White, Jr. (Napa, Gallfeanta Lou Hanson (address unknown); Carl Ramsey (c/o
Brayton’*Purcell LLP}; Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

: Location of Exposure
Employer Exposure Job Title Dates
Westem Asbestos Georgia Pacific Insulator 7/1961-10/1961;
3150 3” Street Areata, CA 71962-51965
San Francisco, CA. . (2-3 months, on
and off]

Job Duties: Plaintiff removed asbestos-contaiaing PABCO and JOHNS MANVILLE block
insulatian that was covered in 352 BLUE cement and black mastic from a large vessel at a
Patticle board mili. Plaintiff applied asbestos-containing JOHNS MANVILLE and PABCO
lock 10 a tank. Plaintiff insulated a boiler and related pipes. Plaintiff worked alongside
GEORGLA PACIFIC maintenance personnel who were sweeping and cleaning asbestos laden
dust and debris from asbestos-containing block insulation. Plaintitf recal|s the following
supervisor: Robert Evans (deceased). Plaintiff recalls the following co-workers: Howard

15oO wm DY WR A eR we NE

ous
= 2

Johnson (deceased); Jim White, Jr., apa, California); Donald Cox (c/o BraytonPurcell LLP);
P); Charlie Power (deceased); Myron Jorgenson

Edward Meyer (c/s Brayton¢Purcell L1

{deceased}; Charles Purcell (deceased), Earl Riggs (deceased); Doyle Davidson (deceased):

larry Fry (deceased); Robert Evans, Ray House (deceased). Plaintiff currently contends that he

was exposed to asbestos during this employment.

Location of
Employer Exposure

| Western Asbestos Bethietiom Sieef

3150 3" Street Shipbuilding
San Francisco, CA San. Francisco, CA

Triple A Machine Shop
Pier 64)
an Francisco, CA

Willametie Shipyard
Richmond, CA’
Pacific Ship Repair
{Pier 36)

San Francisco, CA

Todd Shipyard
Oakland, CA

Matson Navigation
(Pier 30}
San Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH P, KENNEDY
TR. (DD-850)

CHEYENNE (T-AG-174)

HA ae TAN PLANTER
1945,

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

GENERAL W.4. MANN
(AP-112)

MONTEREY (1952)
BLAND (APA-134)

16

Job Title
Insulator

Exposure
Dates

FYIST-TO/TO6T,
71962-5/1965

(on and off ior
approx. 1 week
each time)Ba a ee
BRRRERBRRES SL BUR EDR ES

oo WA tt bw ON

Employer Location of Exposure

Exposure Job Title Dates

Western Asbestos (contd) - PONTCHARTRAIN Insulator 7/1961-10/1961,
{WPG-70) T1962-5/1965
CALIFORNIAN (1946)
AMERICAN ROBIN, 1963 - 1965
(ray .

. ROSE ENOT (1945)

HAWAIIAN (1946)

Job Duties: Plaintiff insulated pipes, turbines, valves, and boilers using asbestos-containing
JOHNS MANVILLE and PABCO (FIBREBOARD CORPORATION} block and pipecovering.
Plaintiff removed and repaired asbestos-containing insulation. Plaintiff used asbestos cloth ta
wrep around valves and boilers. Plaintiff recalls using EAGLE PICHER cements and 352 BLUE
cement. Plaintiff worked near pipefitters who were removing asbestos-containing

insulation and who were installing pipes, asbestos-containing gaskets, valves and pumps.
Plaintiff recalls pipefitters in his work area installing asbesias-containing GARLOCK.
(GARLOCK SEALING TECHNOLOGIES, LLC) gaskets and cutting gaskets from sheet gasket
material. Plaintiff recalls welders using asbestos cloth during the course of theix work. Plantiff
worked near the FOSTER WHEELER boilers aboard the HA WATIAN PLANTER, the
GRAFFIAS, the MATHEWS, the MERRICK, the GENERAL WA. MANN, the MCINTEREY
and the ROSE KNOT. Plaintiff observed other workers installing and removing asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) and/or
PLEXITALLIC, INC. gaskets aboard several of these ships, Plaintiff observed shipyard
personnel including TRIPLE A personnel who were tearing off asbestos-containing thermal
insulation and who were sweeping and cleaning asbestos-containing debris in plaintiff's

resence. Plaintiff recalls the following coworkers: Tom Andrews (c/o Brayton*Purcell LLP);

joseph O*Balle (o/o Brayton“*Purcell LLP); Jack Barbera (address unknown); Gene Bennett,
Vacaville, California, Rudolph Brajkovick (deceased); John Byron Aeddress unknown); Robert
Evans (deceased); Harry Fry (deceased); Ronald Furia (deceased); Thurman Gates (deceased);
Victor Gomez (c/o Brayton Purcell LLP); Bill Green, Sr, (deceased); Bill Green, Jr, deceased):
Ronald Grist, Newark, California; Bill Heinicke (deceased); Frank Howard (deceased); John
Jagoda, Martinez, California; Myron Jorgensen {address unknown); Harvey Jargensen (address

nown), James Logue (c/o BraytonPurcell LLP); Tony Lopes, Fremont, California; Andy

Grant (address unknown); Richard Porter (address unknown); oseph Sandoval (deceased);
Robert Sandoval (deceased); William Stein (address unknown); Ed Story (deceased); Fred
Strickland (deceased}, Howard Tracy (deceased); Jack Kish ( ceased): Paul Schiebold (San
Francisco, Califomia); Dale Wright (Santa Rosa, California); Andy Grant {address unknown),
Lowell Squires (deceased), Jim White, Jr. (Napa, California); Benjamin Nore (deceased),
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestas Grace Cathedral Insulator 7/1961-1 0/1961,
3150 3" Street San Francisco, CA T1962-5/1965
San Francisca, CA : Cees, on and
a

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

7Om WN Hh Bh ww

woe
= 3

12

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

Location of Bxposore
Employer Exposure Job Title Dates
| Western Asbestos": Western Asbestos Pad Fisulator- FPSet- LO et;
3150 3” Street Shop, 3“ Avenue and 1 962-5/1968
San Francisco, CA Army, San Francisco, CA (2 -3 days, on and
off)

Job Duties: Plaintiff made. agbestas pads to be installed on hips. 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
Wester Asbestos PG&E Nuclear Powerhouse Insulator 77 961-10/1961;
3150 3" Street Humboldt County F/1962- 12/1962
San Francisco, CA. Eureka, CA (5 months, on and
off)

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

Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos PG&E. Insulator 7/1961- 10/1961,

3150 3° Street San Francisco, CA 7/1962- 12/1962

San Francisco, CA {Potrero Station) (2 weeks}
H1961- 10/1961;
T1962-5/1 965
(2 to 3 weeks, on
aod off}

Job Duties; Plaintiff recalls pomsing ona boiler during aremodel. Plaintiff recalls applyin,
KAYLO [OWENS CORNING FIBERGLAS) asbestos blocks and PABCO (IBREBOA
CORPORATION) all-purpose cement. Plaintiff worked near employees from PG&E whe were
sweeping and cleaning asbestos laden dust and debris in his area. Plaintiff recalls the follawing
supervisor: John Straba (deceased). Plaintiff currently contends that he was exposed to asbestos
during this employment.

18Oo em a A Re ee

Se 32a Gk GBH oS

Location of Exposure

Employer Exposure . Job Title Dates

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

3150 3” Street Pittsburg, CA T962-S/1965

San Francisco, CA (1 month, on and

off}

Job Duties: Plaintiff carried materials to the jouneymen. Plaintiff applied KAYLO (OWENS |

| CORNING FIBERGLASS? ashestes tlecks, PABE 

and Robert Cantley (c/o Brayton%Purcell LLP). Plaintiff currently contends that he was expose
to asbestos during this employment.

Location of . Exposure
Employer Exposure Jab Title Dates
Consolidated Insulation Community College, Insulator 1967 - 1972;

Mission Street, 1977 - 1981

San Francisco, CA Greeks, on and

0

Job Duties: Plaintiff recails inwlaling ducts and pipes. Plaintiff used all-purpose mud. Plaintiff
worked neat DOUGLASS INSULATION trades using MUNDET pipecovering, and GOLDEN
GATE DRYWALL, INC. trades using asbestos-containiag taping mud and sprayed wall texture.

361

Se ND tw & BON

poe ee ee ee ee
BRRRERSBES SRA ERTS

Plaintiff recalls contractors at this worksite were ANDERSON, ROWE & BUCKLEY, INC.
MITCHELL BROTHERS, and GOLDEN GATE DRYWALL, INC. Plaintiff worked beneath
electrical contractors who were disturbing overhead MONOKOTE fireproofing, Plaintiff recalls
materials were supplied by WESTERN MacARTHUR, and SLAKEY ROTHERS
ANDERSON ROWE & BUCKLEY pipefitters used asbestos-containing gaskets and valves,
Plaintiff tecails the following supervisor: Dick Saiya (Belmont, California). Plaintiff recalls the
following co-workers: Earl Beck (deceased); Robert Cantley (c/o Brayton%*Purcell LLP); and
Joseph O*Balle (c/o Brayton®*Purcell LLP). Plaintiff currently contends that he was exposed to

asbestos during this employment.

: Location of Exposure
Employer Exposure fab Tide Dates
Consolidated Insulation Stanford University Insulator 1967 - 1972
517-D Marine View Ave. Eneina Hall (1-2 weeks)
Belmont, CA. Palo Alto, CA

Job Duties: Plaintiff insulated pipes end wrapped ducts. Plaintiff applied fiberglass, ashestos-
containing insulation cement, and FOSTER* Mastic, Plaintiff reealls working near fireproofing
that had been disturbed. Plaintiff recalts that MONTEREY MECHANICAL OMBANT was
the mechanical contractor at this site. Plaintiff recalls pipefitters and plumbers employed by
MONTEREY MECHANICAL COMPANY and electricians employed by CUPERTING
ELECTRIC, disturbing MONOKOTE fireproofing while sett Supports for piping and conduit.
Plaintiff recalls working in proximity to RUDOLPH & SLETTEN laborers and AIR SYSTEMS
MECHANICAL and 0.C. McDONALD sheetmetal workers. Plaintiff worked near drywall
hangers cutting and installing drywall. Plaintiff recalls contractors: FREDERICK.

SWINKEL, INC. plasterers. Plaintiff worked in the same room as FREDERICK
MEISWINKEL plasterers whe Were iene and applying U.S. MINERAL PRODUCTS CAFCO
sprayed fireprooting. Other MEIS WIN! ersonne] were taping and sanding asbestos-
containing joint compounds in plaintiffs work areas. Pla