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

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                1 || Bruce Imai, Esq. (Bar No. 053800)

Tina Yim, Bsq. (Bar No. 232597) 6
2|| IMAL TADLOCK, KEENBY & CORDERY, LLP ECTRONICALLY
100 BUSH STREET, SUITE 1300 ELECTRONIC ao
3|| SAN FRANCISCO, CA 94104 FILED
Telephone: (415) 675-7000 . Superior Court of California,
4] Pacsimile:  (415}675-7008 > County of San Francisco
. FEB 25 2013
5 || Attomeys for Defendant Clerk of the Court
COMMAIR MECHANICAL SERVICES * BY: ALISON AGBAY .
Deputy Clerk
7 .
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 i
% 10 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
it . UNLIMITED JURISDICTION
a + . :
5 12|| ROBERT ROSS and JEAN ROSS, CASE NO.: CGC-10-275741 |
Bz 43 _. | ¢4SBESTOS) , |
2 BSE Plaintiffs, .
GREECE 14 oo EXHIBIT F PART 2 OF 2 TO THE
Bebe ae Vv. DECLARATION OF TINA YIM IN SUPPORT
SePbS2 15 . OF COMMAIR MECHANICAL SERVICES’:
ae MOTION FOR SUMMARY JUDGMENT OR, .
S 2 16|| CC. MOORE & CO. ENGINEERS, et all, IN THE ALTERNATIVE, SUMMARY. -
g * . JUDGMENT
e& 17 .
é Defendants. a Date: May 9, 2013
Z 18 Lo Time: 9:30 am.
= oe Dept: 503
™ 19 : Judge: Hon. Teri L. Jackson
20 . Complaint Filed: December 17, 2010
. Tnal Date: June 10, 2013
21 - .
Attached is EXHIBIT F PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN
22

SUPPORT OF COMMAIR MECHANICAL SERVICES’ MOTION FOR SUMMARY
23 || TUDGMENT OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT.

27

28

-l-
EXHIBIT F PART 7 OF 2 T0 THE DECLARATION OF TINA YIM IN SUPPORT OF COMMAIR
MECHANICAL SERVICES’ MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
SUMMARY JUDGMENT, ULP

SUITE 1100

KEENEY & CORDERY

LAW OFFICES

IMAI, TADLOCK,

EROOF OF SERVICE

I, Heather Cherry, declare:

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

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

by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.

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

by personally delivering the document(s) listed 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 oni thé tecipients 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 under the Iaws of the State of California that the above
is tue and correct.

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

/s/ Heather Cherry
Heather Cherry

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

2
ATTACHED IS EXHIBIT F FART 2 OF 2 TO THE DECLARATION OF TINA TIM IN SUPPORT OF
COMMAI MECHANICAL SERVICES MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY JUDGMENT_» LLP
SUITE L100
196 BURE STREET.

KEENEY & CORDERY.
SAN FRA:

LAW OFFICES

IMAI, TABLOCK,

800, CA S410d

(415) 675-7000

SC Oo WM A he FF &w NM

moo moo N Be ia ia a a
& SR FP BBE BSe TDR EGS os

PROOF OF SERVICE

1, Tina Yim, declare:

Tam a resident of the State of California and over the age of eighteen years, and not a
party to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA

94104. On the date of execution below, I served the within documents:

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

OR, IN THE ALTERNATIVE, SUMMARY JUDGMENT

forth below on this date before 5:00 p.m.

forth below.

address(es) set forth below:

Brayton Purcell, LLP
222 Rush Landing Road
Novato, CA 94943-2469

File & ServeXpress Web site.

is true and correct.

I declare under penalty of perjury under the laws of the State. of Califomis that the above

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

/sf Tina Yim

by transmitting via facsimile the document(s) listed above to the fax number(s) set

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

>|. by personally delivering the document(s) listed above to the person at the

On the date of execution beiow, I electronically served the document via File &
ServeXpreas on the recipients designated on the Transaction Receipt located on the

Tina Yim

Ross, Robert and Jean v.(2.C. Moore & Co. Engineers, et al..
SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731

Bh

ATTACHED IS EXHIBIT F PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
COMMAIR MECHANICAL SERVICES’ MOTION POR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY JUDGMENT.Location of Exposure

Employer Exposure Job Title Dates

Consolidated Insulation San Francisco War Insulator 1/1967-1970
517-D Marine View Ave. Memorial Opera House (Foreman) (L_week, on and
Belmont, CA San Francisco, CA. oft

Job Duties: Plaintiff installed insulation with all-purpose cement. Plaintiff recalls that this was
a remodel and that fireproofing insulation cements and other debris were swept up by laborers
in his work area. Plaintiff recalls the following supervisor; Dick Saiya (Belmont, California).
Plaintiff recalls the folowing co-worker: Gene Thompson (address unknown). Plaintiff
currently contends that he was exposed to asbestos during this employment.

Empl Location of . Exposure
ployer Exposure Job Title Dates

Consolidated Insulation SP.C.A. Insulator 1/196 7-5/1 972
517-D Marine View Ave, San Francisca, CA (3 weeks, on and
Belmont, CA off}

Job Duties: Plaintiff installed insulation on pipes and ducts. Plaintiff had to remove and
replace ceiling tiles. Plaintiff recalls the following supervisor: Dick Saiya (Belmont,
California). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure

Employer Exposure Title Dates

Consolidated Insulation Safeway Bakery Insulator 1/1967-3/1972
517-D Marine View Ave. Richmond, CA (2 weeks, on and
Belmont, CA off)

Job Duties: Plaintiff wrapped ducts and insulated a tank with block insulation, and Blue Mud
cement. Plaintiff warked near laborers sweepi i up debris. Plaintiff recalls the following
supervisor: Dick Saiya (Belmont, California. 4 Jamtiff recalls the following co-workers: Gene
Thompson (address unknown); Robert Cantley Brayton*Purcell LLP; Earl Beck (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Emplayer Exposure Job Title Dates

Consolidated Insulation Kilpatrick Bakery Insulator 1967-1968
517-D Marine View Ave. land, CA (Foreman) (2 months, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes tanks and strainers using calcium silicate, foamglass,
fiberglass and cements. Plaintiff installed 301 cement on the fittings. Plaintiff used cal sil
insulation on a tank and 352 Blue Mud cement and mastic. Plaintiff worked near tpipefitiers
who were installing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LL! kets.
FRANK BONETTI PLUMBING was the plumbing and Pipefitting controller, GOLDEN
GATE DRYWALL, INC. employed tapers and sanders at the site who were hanging. taping and
sanding wallboard, which they covered with asbestas-containing joint compound. Plaintiff cur
into this wallboard in order to insulate piping running through walls. Plaintiff worked near
laborers who were sweeping up debris, Plaintiff worked near sheet metal workers and
electricians, Plaintiff recalls that PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY} was working es an insulation contractor. Plaintiff recalls the following

Alsjuredi19349\ph\Al-supssc3.wpd 51 BCs

:Oo 8 DA Ww & WN

Se a i
Ce WA mH FF WN HS

supervisor, Dick Saiyz, Belmont, California, Plaintiff recalls the following co-worker: Robert
Cantley (c/o Brayton’ Purcell LLP); Roger Fonken {elo Brayton*Purcell LLP}. Plaintiff
currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Sandia National Laboratory Insulator 141967-3/1972
517-D Marine View Ave. Livermore, CA. (1 month, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff recalls the following supervisor:
Richard Saiya (Belmont, California). Plaintiff recalls the following co-workers: Robert
Cantley (c/o B nPurcell LLP}; Earl Beck (deceased); Robert Wildoner (c/o
Brayton?Purceil LLP). Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Napa State Hospital Insulator 1/1967-3/1970
517-D Marine View Ave. Napa, CA {Lmonth, on and
Belmont, CA off)

Job Duties: Plaintiff worked at this site multiple times. Plaintiff wrapped ducts and instelled
PABCO (FIBREBOARD CORPORATION) pipe insulation. Plainti to crawl under the
building in order insulate pipes and recalls that there was asbestos insylation all over the ground
and that his clothes and skin were covered in insulation debris. Plaintiff had to crawl through
the space above the ceiling in order to install insulation, Plaintiff recalls that COOPER
BROTHERS (COOPER BROTHERS, INC.) personnel would tear holes in the plaster walls and
ceiling and that there was dust from the lath and plaster that had been torn out. Plaintiff recalls
there was debris from the freprook as well as fireproofing on the beams. Plaintiff recalls
working near COOPER BRO (COOPER BRO’ , INC.) plumbers and electricians
who used wrenches and hammers to knock-off: existing asbestos-containing PABCO
TBREBOARD CORPORATION} insulation and MONOKOTE (W.R. GRACE & CO.)
while installing their cables.. Plaintiff worked near sheet metal workers who
disturbed the insulation and fireproofing while installing ducts. Plaintiff recalls working near
Pipefitters wha he believes were ftom COOPER BRO’ THERS COOPER BROTHERS, INC.)
while they installed pipes and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
askets. Plaintiff worked next to workers who were putting asbestos-containing ANCHOR
feOLTEC INDUSTRIES, ney cking Into valves. Plaintiff worked near tapers and drywall
hangers from GOLDEN GATE DRY L, INC. who were cutting drywall and applying and
sanding joint compound. Plaintiff recalls working near carpenters and workers wor! ing on the
controls A controls worker working next to plaintiff, disturbed overhead MONOKOTE (WR
GRACE & CO.) fireproofing while installing controls onto coils. Plaintiff recalls working near
sprinkler fitters instal hme pipes and gaskets and disturbing the insulation in order to hang their
pipes, Plaintiff also recalls contractor; JW & SONS. Plaintiff recalls the following
supervisors, Bob Backer, Napa, California; Dick Saiya (Belmont, California); Robert Cantley
f¢ ‘o BraytonPurcell LLP); Jim White, Jr. (Napa, California), Plaintiff currently contends
e was exposed to asbestos during this employment.

if
ff

KeAlujuredh 949i ph A rupsoc3. wpe 52. ECS.wo wm TH A hk wD Pe

Boe eB eB ee Be Be
ow A hk ow Me

BRE SB

Location of Exposure

Employer Exnosure Job Title Dates
Consolidated Insulation US Department of Insufator 1/1967-3/1972
517-D Marine View Ave. Agr ture (3 weeks, on and
Belmant, CA Albany, CA off)

Job Duties: Plaintiff insulated Pipes and duct. Plaintiff recalls using all-purpose cement and
301 cement, Plaintiff recalls working near plumbers and pipefitters installing Pipes, valves end
paskets. Plaintiff recalls working near sheet metal workers who shot studs into the beams,
cocking off the fireproofing. Plaintiff recalls working near D.W. NICHOLSON laborers

sweeping up debris, including wire gasket material and insulation mud approximately 10 feet
below plaintiff. Plaintiff recalls the following insulation contractor: PL ASBESTOS
COMPANY (PLANT INSULATION COMPANY). Plaintiff recalls contractors: D.W.
NICHOLSON CORPORATION, COMMERCIAL AIR, and RODONI-BECKER CQ., INC.
COMMERCIAL AIR personnel disturbed nl previously spastic oenence, whlenaprens due

fireproofing while setting piping and duct supports in plaintiff's presence, whic. lust
throu; me work areas. POMMERCIAL AIR sheet metal workers cut and instafled six
DURO-DYNE Flexible Duct Connectors within three to six feet of plaintiff. Plaintiff recalls
the following supervisor: Dick Saiya (Belmont, California). Plaintiff recalls the following co-
workers: Earl Furr (deceased); Roger Fonken (c/o Brayton¢Purcell LLP); William DeBere
(deceased); Robert Cantley, c/o Brayton%Purcell; Richard Tobey (deceased), Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Kaiser Hospital Insulator 1967-1972
517-D Marine View Ave. 2425 Geary Blvd. (3 weeks)
Belmont, CA San Francisco, CA

Job Duties: Plaintiff applied ashestos-containing insulation to piping and ductwork during
hospital renovations. SON CONTROLS technicians alsa bed the overhead

fi ofing nest plaintiff, while setting their controls tubing. D. ZELINSKY (D. ZELINSKY
& SONS, INC.) painters also sanded the previously mudded, taped and sanded interior walls in
order to Prepare those surfaces for Fainting, which sprcad dust from the previously applied
PACO S (KELLY MOORE PAINT COMPANY} joint and taping muds. Plaintiff
observed laborers employed by general contractor WEBCOR BUILD! sweeping and
shoveling asbestos-containing PACO TEXTURES taping compound, fireproofing, GARLOCK
gasket scraps and insulation is in his work areas on a recurring basis, within 3 to 25 feet of

plaintiff bert Cantley c/o Brayton¢Purcell LLP, was plaintiff's supervisor at this site.
laintiff currently contends he was exposed to asbestos during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation California Pacific Medical Insulator 11967-41972
517-D Marine View Ave. Center (2 weeks, on and
Belmont, CA San Francisco, CA off}

(California Street)

Job Duties: Plaintiff installed insulation and 301 insulating cement on. the fittings, daring 2
hospital remodel pr ject. Plaintiff worked near CAHILL CONTRACTORS, (i LL.
CONSTRUCTION CO., INC.) laborers sweeping up debris and tape! $ applytn and sanding
joint compound. Plaintiff worked near drywall hangers cutting en installing ll and near
sprinkler fitters who installed pipes and gaskets. Plaintiff warked near sheetmetal workers and

KAlnjored\949iple\al-aupssc? pd 53 ECSnear pipefitters installing Bipes, valves and gaskets. Plaintiff observed ANDERSON ROWE &
BUCKLEY pipefitters installing GARLOC. (GARLOCK, SEALING TECHNOLOGIES, LLC)
gaskets and removing and replacing valve packing. Plaintiff observed J.W. McCLENAHAN
Plumbers and pipefitters disturbing previously sprayed esbestos-containing overhead
hreproofing wihin 4 to 25 feet of his work areas on a daily basis. Plaintiff also observed
sonnel employed by , F.W. SPENCER & SON, INC. at this site. Plaintiff recalls the
‘ollawing co-workers Robert Cantley (c/o Brayton’-Purcelt LLP); Robert Wildonner (c/o
Brayton*Purcell LLP). Plaintiff currently contends he was exposed to asbestos during this

employment.

Location of . Exposure
Employer Exposure gb Title Dates
Consolidated Insulation Coast Guard Facility Tnsulator 1/1967-3/1972
517-D Manne View Ave. Monterey, CA (week, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes. Plaintiff worked in the crawl space under the building to
perform his duties. Plaintiff recalls that there was loose insulation under the building that had
come off existing pipes. Plaintiff recalls working near pipefitters installin; pipes and gaskets.
Plaintiff recalls the following supervisor: Dick lye (Belmont, California) Plaintiff recalls the
following co-werkera Robert Cantley (c/o Brayton%Purceil LLP); Earl Beck (deceased).
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure - Job Title Dates
Consolidated Insulation Veterans Administration =‘ Insulator 1/1967-3/1972
517-D Marine View Ave, Hospital (1 week, on and
Belmont, CA Yountville, CA off)

Job Duties: Plaintiff recalls laborers siweeping uP debris in his area and welders who were
using asbestos blankets. Plaintiff recalls all hangers cutting and installing drywall and
tapers applying and sanding joint compound in his work area. Plaintiff recalls pipefitters
installing pipes and | gaskets, Plaintiff recalls the fallowing supervisor: Dick Saiya (Belmont,
California). Plaintiff recalls the following co-worker: Joseph O’ Balle {c/o BraytonPurcell
LLP). Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Unknown Meat Packing Insulator 1/1967-3/1972
$17-D Marine View Ave, Plant (2 weeks, on and
Belmont, CA Sacramento, CA off)

Job Duties: Plaintiff installed insulation on refrigeration lines. Plaintiff used Styrofoam
insulation and all-purpose cement. Plaintiff recalls the following co-worker; Joseph O°Balle
(clo BraytowPurcell LLP). Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Queen of the Valley Insulator 1/1967-3/1972
517-D Marine View Ave. Hospital (3 to 4 weeks, on
Belmont, CA Napa, CA and off)

KAnjoredl 9349 ph AL-supenc) wed 54 EtsJob Duties: Plaintiff worked on a remodel of this facility. Plaintiff recalls installing Sberglass
duct wrap and asbestos-containing pipecoverings and cements. Plaintiff recalls the following
co-worker: Joseph O” Baile (c/o Brayton®Purcell LLP). Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Stonestown Shopping Insulator 1/1967-3/1972
517-D Marine View Ave, Center (1 month, on and
Belmont, CA San Francisco, CA off)

Job Duties: Plaintiff recalls installing insulation and duct wrap. Plaintiff recalls working near
drywall hangers cutting and installing drywall and tapers applying and sanding joint compound.
Plaintiff recalis working near pipetitters installing gaskets, valves and pipes. Plaintiff recalls
the following supervisor: Robert Cantley {elo Brayton Purcell yr) Plaintiff recalls the
following co-worker: Joseph O*Balle (c/o Brayton®Purcell LLP), Plaintiff currently contends
he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 517- Children’s Hospital Insulator 1967-1972
D Marine View Ave. Oakland, CA
Belmont, CA
Job Duties: Plaintiff applied fiberglass duet wrap to duct work and spplied calcium silicate pipe
covering to pipi building remodel project. MONTEREY MECHANICAL plumbers

a a
and pipefiners an ‘ATLAS HEATING & ¥! [LATING COMPANY sheet metal workers
disturbed previously sprayed asbestos-containing fireproofing while setting their piping and
duct su ports in plaintiff's work areas. ©. CONSTRUCTION (CAHILL
CONSTRUCTION CO., INC.) laborers swept and shoveled asbestos~containing fireproofing
dust, calcium silicate pipe covering dust and insulation mud dust, all of which contained.
asbestos, an a regular basis within 5 to 25 feet of plaintiff. Plaintiff's supervisor was Robert
Cantley, ofa Brayton¢ Purcell LLP. His co-worker at this site was Ear] Beck (deceased).
Plaintiff presently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Napa County Hall of Insulator 141967-3/1972
517-D Marine View Ave. Justice (3 days, on and
Belmont, CA Napa, CA oft}

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

Location of Exposure
Employer Exposure dob Tile Dates
Consolidated Insulation Kaiser Hospital Insulator 11967-3/1972
517-D Marine View Ave. Vallejo, CA (3 weeks, on and
Belmont, CA off}

ii

KAlnjured947phhAL-supsec wp 55 ECSOm a DH bw Ne

ee
nada Aw Rw RD SF Go

Job Duties; Plaintiff recalls installing insulation and duct wrap. Plaintiff recalls having to
remove and replace ceiling tiles to perform his job duties. Plaintiff recalls fireproofing on the
beams. Plaintiff applied PABCO (FIBREBO. CORPORATION) pipe insulation and
cements. Plaintiff worked near tapers applying and sanding joint compound. Plaintiff recalls
the Following contractors at this site: IED FIRE PROTECTION and BROADWAY
PLUMBING. Plaintiff observed ALLIED FIRE PROTECTION employees were disturbing
ashestos-containing fireproofing, while setting their sprinkler pipe supports into the overhead,
which accurred near plaintiff over a four day period. Plaintiff currently recalls the following
superviser: Dick Saiya (Belmont, California). Plaintiff currently recalls the following co-
workers: Joseph O"Balle (c/o BraytonPurcell LLP), Robert Cantley (c/o Braytoné Purcell
LLP); Earl Beck (deceased). Plaintiff currently contends he was exposed to asbestos during this

employment,
Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Alta Bates Hospital Insulator 1/1967-1972;
517-D Marine View Ave. Oakland, CA . 1977-3/1980 (3 to
Belmont, CA 4 ane on and
o

Job Duties: Plaintiff worked at this facility multiple times throughout his employment with
Consolidated, Plaintiff recalls ashestos-containin: : products manufactured by MONOKOTE
(WR. GRACE & CO, IMPERIAL PLASTE! (UNITED STATES GYPSUM
COMPANY) and NATIONAL GYPSUM. Plaintiff recalls the following contractors:
ALADDIN HEATING, GOLDEN GATE DRYWALL, INC., BARNES CONSTRUCTION
CO., EMERICK SHEET METAL CO., Plaintiff recalls the following supervisor: Dick Sina
(Belmont, California). Plaintiff recalls co-workers Robert Cantley (c/o Brayton? Purcell LLP),
Earl Beck (deceased); and Bok Wildoner (c/o Brayton¢Purcell LLP). Plaintiff currently
contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Mills Building Insulator VL967-3/1972
517-D Marine View Ave. {(BushyMontgomery)
Belmont, CA an Francisco, CA (10 man days}

Job Duties: Plaintiff installed asbestos insulation and wrapped duct. Plaintiff worked near
fumbers end i efitters who were installing pipes, valves, and gaskets. DOUGLASS
ISULATION COMPANY insulators cut and applied calcium silicate pipecovering on wet

j heat and stearn piping near plaintiff. Plaintiff recalls that fireproofing was being disturbed

the electricians and the ceiling tile workers. Plaintiff recalls contractors: , DELUCCHI SHEET

t METAL WORKS, CS, IEMAN, INC., MCCLURE ELECTRIC, INC., and ZELLER

PLASTERING, DOUGLASS INSULATION COMPANY insulators were cutting and applying
fiberglass and asbestos-containing UNIBESTOS GUTSBURGH CORNING CO! PANY) pipe
covering nearby. Plaintiff observed DELUCCHI SHEET METAL personnel cutting,
fabricating and installing new DURO DYNE Flexible Duct Connectors within 4 to 25 feet of
his work areas at this site. Plaintiff inadvertently “cut into” the asbestos cloth component of
some of these DURO DYNE Flexible Duct Connectors while a peri fiberglass insulation to
them. Plaintiff worked in close proximity to JW. MeCLENAHL plumbers and McCLURE
ELECTRIC, INC. electricians who were disturbing previously sprayed asbesios-containing
overhead fireproofing while setting theit fine and conduit supports, which spread dust
throughout plaintiff's work areas. Plaintiff observed iaborers, employed by SWINERTON &

KAlnjuredv 934 ipleval-supine? pd 56 ECSWALBERG, who were sweeping and shoveling asbestos-containing plaster, sheetrock mud, and
UNIBESTOS pipe covering dust and debris near plaintiff on a recurring basis. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation City Administration Insulator 1/1967-3/1972
517-D Marine View Ave. Buildin; (2 months, on and
Belmont, CA Cutting Houlevard off)

Richmond, CA

Job Duties: Plaintiff worked in the boiler room. Plaintiff insulated d pipes and ducts on a hot
water heater. Plaintiff worked with BORDEN’s fibrous adhesive, EAGLE-PICHER cement,
and PABCO (FIBREBOARD CORPORATION) 127 BLUE cement, Plaintiff worked near
lumbers and pipefitters installing pines, gaskets and valves. Plaintiff worked near drywall
hangers cutting and installing di . Plaintiff worked near GOLDEN GATE DRYWALL
tapers mixing, applying and sanding asbestos-containing joint compound. Plaintiff recalls that
fireproofing was being disturbed by the contrals men. Plaintiff recalls contractors: GOLDEN
GATE DRYWALL, INC., ANDERSON, ROWE & BUCKLEY, INC., RODONI-BECKER
Co., INC., ALLIED FIRE PROTECTION, WEBCOR BUILDERS and CAHILL
CONTRACTORS, INC. (CAHILL CONSTRUCTION CO., INC.). Plaintiff observed
ALLIED FIRE PROTECTION sprinkler fitters and ANDERSON ROWE & BUCKLEY
ipefitters and plumbers disturbing the previously sprayed asbestos-containing overhead
Froprooiing while secting their pipe supports near plaintiff, which regularly occurred over a
nine to fifteen da: i Plaintiff observed WEBCOR BUILDERS’ and CAHILL
CONSTRUCTION *§ (CAHILL CONSTRUCTION CO., INC.) laborers sweeping and
shoveling asbestos-containing fi Ofing, drywall mud, and insulation debris, within 3 to 20
feet of plaintiff, which spread visible dust throughout his work area, Plaintiff recails the
following supervisor: Richard Saiya (Belmont, California). Plaintiff recalls the following co-
workers: Gene Tene Re (address unknown); Ear] Beck (deceased); Robert Cantley (c/o

Brayton“?Purcell LLP); Mickey Johnson (address unknown). Plaintiff currently contends he
was exposed to asbestas during this emplayment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 690 Market Street Insulator 141967-3/1972
517-D Marine View Ave. San Francisco, CA CL week, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near pipefitters installing
pipes, gaskets and valves, and using packing. Plaintiff recalls working near sheet metal workers
o shot studs into the beams, knocking off the fireproofing. Plaintiff worked near laborers
sweeping up debris. Plaintiff warked near MONTEREY HANICAL pipefitters who were

9p lying GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. The

5 'Y MEC! ICAL pipettes also disturbed finished and taped sheetrocked walls
when making wall penetrations for piping. Plaintiff recalls the following supervisor: Richard
Saiya Belmont, California). Plaintiff recalls the following coworkers Robert Cantley (c/o
Brayton’ Purcell LLP}; Earl Beck (deceased), Plaintiff currently contends he was exposed to
asbestos during this employment.

iif
He

Alojured\1904 9p HVA Fsupsae wrod Ss? CEwoe Wd De FY Ne

Be ee BO
ay Ana bY NH = So

N ty
= S

Location of . Exposure
Employer Exposure Job Title Dates

Consolidated Insulation 50 California Street Insulator 1/1967-3/1972
517-D Marine View Ave, San Francisco, CA (2 weeks, on and
Belmont, CA off}

Job Duties; Plaintiff insulated pipes and ducts. Plaintiff used cal-sil insulation and all-purpose
cement. Plaintiff recalls the following supervisor: Richard Saiya (Belmont, California).
Plaintiff recalls the following coworker Robert Cantley (c/o Brayton®Purcell LLP), Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates

Consolidated Insulation St. Mary's Church Insulator 1/1967-3/1972
517-D Marine View Ave. San Francisco, CA (6 weeks, on and
Belmont, CA, off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers and pi efitters
installing pipes, gaskets and valves, and using packing. Plaintiff worked near drywall hangers
cutting a ing ing drywall. Plaintiff worked near tapers applying and sanding joint
compound. Plaintiff recalls working near sheet metal workers who shot studs into the beams,
knocking off the fireproofing. Plaintiff recalls that fireproofing was being disturbed by the
ROBERT SHA controls technicians. Plaintiff worked near sprinkler fitters who had to
disturb the fireproofing in order to install their pipes, Plaintiff worked near laborers swe: ing
up debris. Plaintiff recalls the following contractors: Plumbing peneral contractor CLAUS
PATTEN, sheet metal contractor DELUCCHI SHEET METAL WORKS, and

contractors GOLDEN GATE DRYWALL, INC. and D. ZELINSKY & SONS, INC. Plaintiff
observed CLAUSEN-PATTEN plumbers disturbing the previously sprayed asbestos-containing
overhead fireproofing while setting piping supports, which spread visible dust throughout
plaintiff's work areas, Plaintiff also observed CLAUSEN-PATTEN personnel swee) ng up
metal and gasket debris within 6 feet of plaintiff. The D, ZELINSKY (D. ZELINS|

SONS, INC, crew was taping and sanding asbestos-containing taping compounds 5 to 20 feet
from plaintiff, and was painting thereafter. Plaintiff recalls the following supervisor: Richard
Saiya (Belmont, California). Plaintiff recalls the following coworkers; Sal Morales (deceased),
Joseph O’ Balle (efe Brayton**Purcell LLP). Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer 5 Job Title Dates
Consolidated Insulation Highland Hospital Insulator M1967-3/1972
517-D Marine View Ave. CG d, CA (1 month, on and
Belmont, CA off)

Job Duties: Plaintiff insulated pipes and ducts in the ceilings and worked in the boiler room.
Plaintiff worked near plumbers and pipefitters installing pipes, gaskets and valves, and usi
eoking. Plaintiff worked near ceiling installers who were cutting and installing ceiling tiles.
Paint recalls that fireproofing was being disturbed by the ceiling installers. Plaintiff worked
near floor tile installers who were cutting and installing floor tiles, Plaintiff recalls that
fireproofing was being disturbed by the floor tile installers. Plaintiff recalis working near sheet
metal workers who shot studs into the beams, knocking off the fireproofing. Plaintiff recalls
sccing others spraying W.R, GRACE MONOKOTE fireproofing tay. Plaintiff worked near
laborers sweeping up debris. Plaintiff worked near insulators om loyed by the followin;
contractors; TERN ASBESTOS COMPANY, PLANT ASBESTOS COMPANY (PLANT

KAlnjurad S40 IAAT apc wet 58 ECS1

Mos ow OR Le & Wo oN

BS RRRRRES SHS RR EES SS

INSULATION COMPANY). Plaintiff recalls genezal contractor ROTHSCHILD & RAFFIN,
INC; mechanteal eontractor ALADDIN HEATING CORPORATION drywall contractits CAR
PLASTERING and GOLDEN GATE DEYWALL,.INC,; and COSCO SPRINKLER (COBCO
FIRE PROTECTION, ING.) Plaintiff ebserved Pip id sheetinetal workers shacting:
studs into pustiead rppecofin , Cutting and installing CK CGARLOCK SEALING
TECHNOLOGIES, LLC) gaskets, and cutting and instal ble duct connectors while
fabricating steam and water piping and duet work, Plaintiff worked alongside pipefitiers who
disturbed overhead MONOKOTE (W.R, GRACE & CO.) fireproofing while setting Pips
supports, and wha disturbed existing ashestos-cottalning pipecbveriiig near pleut ile
Fabricating new ipite. Plaintiff chseived sprinkler fitie genployed by COSCO FIRE
PROTECTION disturbing previously sprayed WR. GRACE C& ; Monakote ashestos- .
conidming ovethend fireproofitig while setting sprinkler'spports 3 to 20 feet from plaintt3,
Plaintiff revalls thie following supervisor: Ro! ext Cantley icfo Brayton? Purcell . Planitint
recalls the following coworker: “Stan Silva (deceased): Platutiff-alse worked. with the folldwing.
¢o-worker employe by PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY): Phil Petersos (deceased). Pliintiff currently contends he was exposed to
asbestos during this-empleyment.

Location of , Exposure
Employer Exposure Job Tile Dates
Consolidated Insulation American Can Cofnpariy —_Tnsulator L967 -31 923
. 51 7-D Marine View Ave. San Leandro, CA. (4 days, onand

Belmont, CA off):

suilated pipes and ducts. P used .cal-sil insulation and 30] all-

iff worked nesr pipefiners ing pipes, gaskets and valves, and using:

near laborers eweoping ui jaintiff recalls the following

Loeation of Expastits
Empliyer Exposure fob Title Dates
Consolidated Insulation I Bush Street Insulator HIS6R3 A972
517-D Marine View Ave, San Francisco, CA. (2 weeks, an and
Belmoni, CA off}

Job, Duties: Plajntit insulated pipes and ducts fiberal
pipefitters installing pipes, paskets and valves,

sheet neta workers ws shet studs into the earns. k
reealls.o ts su ing fiteprdoting spray. Plaintiff recalls c
CONSTRUCTIO CORPORATION PACIIC MECHANI
AND VENTILATING COMPANY, LTD. Plaintiff observed
CORPORATION personnel disturbing previow agbestos-contuining overlicad
fireproofing while setting heir supports within Ss fest of plaintiff. Additionally,
plaintiff observed PACING ICAL CORPORATION personnel cutting, inst and
removing flange ese, an a few occasions, 5 to 25 feet from plaintif. Plaintiff observed
BALLIET BR ERS laborers sweeping and shoveling asbestos laden fireproofing,
insulation, areal and gasket debris in plaintifi’s work areas. Plaintiff observed enters
hanging KAISER, GYPSUM COMP. wallboard at this site. Plaintiff recalls the follawing
spperviser: Robert.Cantley fefo Brayton Purcell LLP). Plaintiff carrently contends he was
exposed t9.asbestes during this employment.

pipe-coverings. Plaintiff worked near
king. Plaintiff recalls working near
eprookt ; Plaintift
ALLIET BROTHERS
TLAS HEATING

KAMnjured 9349 BALsopsae3 wed 59. ECSwa aw mA HW FY KN

Be ee ee a
Se OA wm Fb BE S

Location of Exposure

Employer Exposure Job Title Dates
Consolidated Insulation Hong Kong Bank Insulator VW1967-3/1972
517-D Marine View Ave. San Francisco, CA (1 week)
Belmont, CA. (Headquarters 60

ausome Street}

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers and pipefitters
installing pipes, eis and valves, and using packing, Plaintiff worked near pers
cutting and in: drywall, Plaintiff worked near tapers applying and sanding joint
compound. Plaintiff recalls working near sheet metal workers who shot studs into the beams,
knocking off the fireproofing. Plaintiff recalls working around controls men, and that
fireproofing was being disturbed by the controls men. Plaintiff worked near BALLIET

BR laborers who were sweeping up asbestos-containing fireproofing, insulation and
drywall debris. Plaintiff also worked near electricians, sprinkler fitters, and refrigeration
technicians. Plaintiff recalls seeing MONOKOTE {W.R. GRACE & CO.) used at this jobsite.
Plaintiff recalls the following supervisors Robert Cantley (c/o Brayton’ Purcell LLP}; Richard
Saiya (Belmont, California), Plaintiff recalls the following coworker: Earl Beck (deceased).
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure fob Tile Dates
Consolidated Insulation Federal Building Insulator 1967-1972
517-D Marine View Ave. 450 Golden Gate Avenue (one week}
Belmont, CA San Francisco, CA

Job Duties: Plaintiff applied fiberglass insulation to ductwork and applied calcium silicate pipe
insulation to piping and equipment during a week long remodel project. JOSEPH BRUNO
SHEET METAL personnel were disturbing previously sprayed asbestos-containing overhead
fireproofing while setting their duct and heating pipe supports in plaintiff's work areas. Robert
Cantley, c/o Brayton#Purcell LLP, was plaintiff's supervisor on this site. Plaintiff currently

contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 111 Pine Street Insulator 1/L967-3/1972;
517-D Marine View Ave. San Francisco, CA 5f77-1/81
Belmont, CA Caeeks, on and
: a

Job Duties: Plaintiff insulated domestic water pipes and ducts, Plaintiff worked near pipefitters
installing pipes, and valves, and using packing, Plaintiff recalls working near sheet
metal workers who shot studs into the beams, knocking off the fir roofing: Plaintiff recalls
contractors at this site included: JOHNSON CONTROLS, INC, EREDE cK
MEISWINKEL, D. ZELINSKY (D. ZELINSKY & SONS, INC.), sweeping asbestos-containing
debris in plaintiff's presence. Plaintiff saw MEIS WINKEL personnel using bags of asbestos-
containing HAMILTON MATERIALS “Red Dot” joint compounds, mixing the material and
sanding it after it was applied to interior walls. Plaintiff saw ZELINSKY (D. ZELINSKY &
SONS, INC.) personnel mixing, taping and sandin; asbestos containing taping oom junds and
then painting in plaintiff's presence. Plaintiff worked near SWINERTON & AL BERG
laborers whe were sweeping up and shoveling asbestos-containing debris, JGHNSON
CONTROLS technicians img controls and tubing near plaintiff. Plaintiff recalls the following
supervisor: Robert Cantley (c/o Brayton*Purcell LLP). Plaintiff's co-workers on this project

RAlnjuroc SS44p 1.04 Coupee avd 60 BCS

i
|
|
iOw oN A Hh Bb YON

eo UA AB eB eS

19

included Joseph O'Balle (c/o Brayton Purceli LLP). Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer . Exposure Job Title Dates

Consolidated Insulation 333 Bush Street Tnsulator 1/1967-3/1972;

517-D Marine View Ave. San Francisco, CA 5/77-1/81

Belmont, CA (month, on and
0

Job Duties: Plaintiff insulated pipes and ducts, Plaintiff worked near pipefitters installing
Pipes, gaskets and valves, and using ing. Plaintiff recalls working near sheet metal workers
who shot studs into the beams, knocking off the fireproofing. Plaintitt worked near laborers
sweeping up debris. Plaintiff recalls the following supervisor: Robert Cantley (c/o
Brayton*Purcell LLP), Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
eS

Employer dob Title

Consolidated Insulation Navel Station Treasure Insulator 1/1967-3/1972;

517-D Marine View Ave. Island 3/77-1/81

Belmont, CA San Francisco, CA oon on and
of

Job Duties: Plaintiff insulated pipes and ducts in the barracks and in the boiler room. Plaintiff
used cal-sil insulation in the boiler room and fiberglass insulation in the barracks. Plaintiff used
all purpose mud, Plaintiff recalls general contractors; JAMES NELSON, electrical contractor;

BANNER DRYWALL & PAINTING CO. INC. Plaintiff recalls the folowing supervisors:
Richard Saiya (Belmont, California); Robert Cantley c/o Brayton¢Purcell LLP, Plaintiff recalls
the following caworker: Jack Jagoda, Martinez, California (c/o Paul & Hanley LLP). Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of : Exposure
Employer Exposure Job Title Dates

Consolidated Insulation IBM Insulator 1967-1972;
§17-D Marine View Ave. San Jose, CA 1977-1981
Bélmont, CA

Job Duties: Plaintiff applied fiberglass duct wrap to duct work and applied fiberglass and
calcium silicate py ecovering and insulation cements to piping valves and fittings d new
construction uring multiple remodel projects, Plaintiff cut and Lapplied KAYLO (OWENS
CORNING FIBERGLAS) ipecovering and JOHNS MANVILLE ( ILLE TRUST)
pipecovering. JOHNSO: INTROLS technicians worked nearby, affixing their controls
tubing into the walls and overhead. Plaintiff worked near CRITCHFIELD MECHANICAL
ersonnel and other tradesmen who disturbed previously applied asbestos-containing overhead
fing while hanging supports for piping and duct work. Other tradesmen engaged in
hanging sprinkler systems, controls, and electrical conduit disturbed the previously sprayed
asbestos-containing sprayed fireproofing in plaintiff's presence. or while sweeping and
cleaning debris that had collected in the work areas. Plaintiff also observed IBM personnel
sweeping and cleaning asbestos containing debris in his work areas. During one any, plaintiff
worked next to D. ZELINSKY (D, ZELINSKY & SONS, INC.) painters sanding asbestos-
containing joint and taping compounds on interior walls, in order to prepare those surfaces for
painting, Earl Beck (deceased) was a jobsite co-worker. Plaintiff's supervisor was Robert

‘Anjuna oops epsc') wpd 61 ECSCantley (c/o Brayton’Purcell LLP}. Plaintiff currently contends that he was exposed to
asbestos during this employment.

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

Belmont, CA

Job Duties: Plaintiff performed intermittent “fill-in” work. Plaintiff worked on new
construction and on repair and maintenance crews. Plaintiff applied fiberglass duct wrap to
duct work and applied fiberglass and calcium silicate pipecovering and insulation cements to
piping, valves, and fittings. Plaintiff worked in proximity to a range of trades, including
pipefitters, sheetmetal workers, electricians, drywall hangers, tapers, and sanders, cement
Masons, tile setters, maintenance personnel, and laborers. JOHNSON CONTROLS technicians
disturbed asbestos containing overhead fireproofing while setting their controls tubing near
plaintiff. CUPERTINO ELECTRIC COMPANY served as electrical contractor on one or more
of these projects. CUPERTINO ELECTRIC personnel disturbed asbestos-containing overhead
fireproofing while settin, supports for their electrical conduit in plaintiff's presence. Plaintiff
also worked next ta D. ZEL SKY (D. ZELINSKY & SONS, INC.) painters sanding joint and
taping compounds on interior walls, in order to brepare those surfaces for painting. Plaintiff's
supervisor was Robert Cantley (c/a Brayton¢Purcell LLP}. Plaintiff curently contends that he
was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 517- Unknown Building Insulator 1967-1972
D Marine View Ave. San Francisco Peninsula,
Belmont, CA CA

Jab Duties: Plaintiff applied fiberglass to duct work and applied calcium silicate pipecovering
to piping during new construction of an unknown building on the San Francisco Peninsula.
Plaintiff worked in close proximity to VAN MULDER SHEET METAL personnel who were
disturbing the previously sprayed asbestos-containing overhead fireproofing while setting their

jipe and duct supports, which spread dust throughout plaintiff's work areas. Robert Cantley
fe o Brayton? Purcell LLP) was plaintiff's supervisor during this employment. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 517- Unknown Building Insulator 1967-1972
D Marine View Ave. San Francisco, CA (3-5 days)

Belmont, CA

Job Duties: Plaintiff applied calcium silicate pipecovering to piping and applied Bbaralass
insulation to duct work during remodel of a downtown San Francisco building. JOSEPH
BRUNO SHEET METAL personnel. were disturbing the previously sprayed asbestos-comtaining
overhead fireproofing while setting their pipe and duct supports in plaintiff's work areas, which
spread visible dust onto and arcund plaintitf. Robert Cantley (c/a Brayton#Purceli LLP) was
plaintiff's supervisor at this project. Plaintiff currently contends he was exposed to asbestos
during this employment.

KAinjuredkO9ip IA boupsio3 wp 62 ESem WA HW BW KH

OG Fw wee oS

16

Location of Exposure
Dates

Employer Exposure Job Title

Consolidated Insulation $17- Unknown Building Insulator 1967-1972
D Marine View Ave. San Francisco Peninsula,

Belmont, CA CA

Job Duties: Plaintiff applied fiberglass duct wrap to duct work and applied asbestos-containing
calcium silicate pipe covering and asbestos-containing insulation cements to piping during a
remodel of a building on the San Francisco Peninsula, Plaintiff worked in close proximity to
COMMERCIAL AIR. personnel who were disturbing previously sprayed asbestos-containing
overhead fing while setting their Fipine and duct supports, which spread visible dust
throughout plaintiff's work areas. “Plaintiff currently contends he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Lucky Deli Plant Insulator 1969 (1 week, on
San Leandro, CA and 9:

Job Duties: Plaintiff installed insulation to Plumbing pine: Plaintiff recalls insulators from
ASSOCIATED INSULATION (ASSOCIATED INSULATION OF CALIFORNIA) installing
cal-sil insulation to the pipes and the valves and asbestos cement fo the fittings. Plaintiff
identifies ASSOCIATED INSULATION (ASSOCIATED INSULATION OF CALIFORNIA)
employee Maurice Lawrence (c/o Brayton*-Purcell TIP). Plaintiff recalls the follow:
worker: Richard Collins (c/o Brayton¢Purcell LLP). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 101 California Street, Insulator 1970-19735
517-D Manne View Ave. San Francisca, CA 1977-1979
Belmont, CA. (on and off)

Job Duties: Plaintiff applied asbestos-containing insulation to duct wrap and piping in the
boiler room. Plaintiff recalls pipefitters and other trades were disturbing MONOKOTE (WR.
GRACE & CO.} fireproofing on and around the ceilings. Plaintiff recalls the following
contractor: GOLDEN GATE DRYWALL, INC., Plaintiff recalls supervisor Robert Cantley
(co Brayton*Purcell LLP). Plaintiff recalls co-workers: Earl Beck (deceased), and Bob

‘ildoner (c/o BraytonPurcell LLP). Plaintiff currently contends he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 517-101 Market Street Insulator 1970-1977 (2-3
D Marine View Ave.- San Frangiseo, CA weeks)
Belmont, CA
Job Duties: Plaintiff applied asbestos-containing calcium silicate pipecovering and fiberglas
duct wrap during an addition and remodel project. Plaintiff worked in clase proximity to
MARC! PLASTERING personnel who were mudding, taping and sanding asbestos-
containing PACO TEXT URES (KELLY-MOORE PAIN T COMPANY) joint compound in his

presence, and in the presence of his crew, for 16 or more hours. Joseph O"Balle, c/o

KAlnjwredt 9349%pldval-supesc. wpe 63 ECsOo oe Ww DH BP ow Ne

See i a a
een a Gm Bw we Ss

Brayton’*Purcell LLP, was one of plaintiff's co-workers on this project. Plaintiff currently
contends he was exposed to asbestos during this employment. :

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Aetojet-Gencral Insulator 4/1972-9/1973
1501 North C Steset Rancho Cordova, CA (18 working days)

Sacramento, CA

Job Duties: Plaintiff insulated a large vessel and related piping with PABCO (FIBREBOARD
CORPORATION) asbestos block and PABCO (FIBREBO, CORPORATION)
Pipecovering, and Fibrous Adhesive, Plaintiff installed JOHNS MANVILLE (MANVILLE
UST) 352 BLUE cement and mastic. Plaintiff worked near AEROJET-GENERAL laborers
sweeping up asbestos-containi g ansulaion and gasket and packing debris and near welders
using asbestos blankets. Plaintiff worked near pipefitters installing paskets, pipes, valves and
, Plaintiff recalls the following mechanical contractor: FOLEY-PML. ROJET-
GENERAL, supplied nine linear feet of asbestos containing pipecgverlng installed at this site by
laintiff, after the pipecovering was cut to size by a.co-worker on his crew. Plaintiff recalls the
following supervisor: Pete Rossi, Sacramento, California. Plaintiff recalls the following co-
workers: Al Cook (c/o Braytan®Purcell LLP); Herb Cook (c/o Brayton®Purcell io Mike
Hammer (c/o Brayton? Purcell LLP); Jim White Jr. (Napa, Califomia) and Tom McClain
(deceased, formerly c/o BraytonPurcell LLP). Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi General Mills, Insulator 1972-1973
1501 North C Street Lodi, CA

Sacramento, CA

Job Duties: Plaintiff applied asbestos-containing UNIBESTOS (PITTSBURGH CORNING
CORPORATION) insulation, mud, mastic and canvas to pipes and fittings. Plaintiff recalls
using cal-sil pipecovering and asbestos mud. Plaintiff recalls using products manufactured by
PABCO ( BOARD CORPORATION). Plaintiff recalls maintenance trades employed by
GENERAL MILLS were sweeping up in plaintiff's presence. Plaintiff worked as foreman on
this job, Plaintiff currently contends he was exposed to asbestos during this employment.

Locetion of Exposure
mployer Exposure Job Title Dates
Siefert and Rossi Kaiser Hospital Insulator 4/1972-9/1973
1501 North C Street Sacramento, CA {3 weeks, on and
Sacramente, CA . o

Job Duties: Plaintiff insulated pipes and wrapped ducts. Plaintiff worked near laborers
sweeping np debris. Plaintiff worked near pipefitters installing gaskets, pipes and valves.
Plaintiff recalls having to remove and replace ceiling tiles in order to perform his job duties.
Plaintiff recalls gesting fireproofing on the ceiling tiles. Plaintiff recalls mechanical contractor:
LAWSON MECHANICAL, LAWSON MEC! [CAL pipefitters and sheetmetal workers
disturbed previously sprayed overhead fireproofing while setting pipe and duct. supports in
laintiff’ s work areas. Plaintiff recalls the following supervisor: Pete Rossi, Sacramento,
‘alifornia, Plaintiff recalls the following co-worker; Wally Friswald (deceased). Plaintiff
currently contends he was exposed to asbestos during this employment.

KAlpiuredl 93¢S4pM\AL-aupane ped 64 BCSLocation of Exposure

Employer Exposure Igb Title Dates
Siefert and Rossi Sacramento Convention —_—Insulator 4/1972-9/1973
1501 North C Street Center GJ months, on and
Sacramento, CA Sacramento, CA off)

C16" Sty

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