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

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                                , LLP

‘SUITE 1400
190 BUSH STREET
SAN FRANCISCO, CA 94104

KEENEY & CORDERY

LAW OPICES

IMAI, TADLOCK,

(415) 675-7000

Cc Oo DR A BB YW NH

BR a a
So 6 ea Aw Rw RP FE os

Theodore T. Cordery, Esq. (Bar No. 114730)

Tina arse ar No. 232597)

IMAL, T. K, KEENEY & CORDERY, LLP

100 BUSH STREET, SUITE 1300 ELECTRONICALLY

SAN FRANCISCO, CA 94104 FILED

Telephone: (415) 675-7000 Superior Court of California,

Facsimile: (415) 675-7008 County of San Francisco
FEB 25 2013

Clerk of the Court
BY: WESLEY G. RAMIREZ
Deputy Clerk

Attomeys for Defendant
WEBCOR BUILDERS, INC.

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, _ CASE NO.: CGC-10-279731

(ASBESTOS)
Plaintiffs,
EXHIBIT M PART 1 GF 2 TO THE .

v : DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC.'S MCTION
FOR SUMMARY JUDGMENT OR, IN THE

C.C. MOORE & CO, ENGINERERS, et al., ALTERNATIVE, SUMMARY
ADJUDICATION
Defendants. : 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

Attached is EXHIBIT M PART 2 OF 2 THE DECLARATION OF TINA YIM IN
SUPPORT OF WEBCOR BUILDER, INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION.

ek
EXHIBIT M PART | OF } TO THE DECLARATION OF TINA YIM IN SUPPORT OF WEECOR BUILDER,
ING.'S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADIUDICATION, LLP

‘SUIT 1300
10 BUH STREET

KEENEY & CORDERY

LAW OFBICES

IMAI, TADLOCK,

(415) 675-7090

PROOF OF SERVICE

I, Heather Cherry, declare:

Tam aresident of the State of Califomia and over the age of eighteen years, and nota
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 M PART 2 OF 2 TG THE DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC.’3 MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION

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
fuily prepaid, in the United States mail at San Francisco, Califormia 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 &
Serve Xpress on the recipients designated on the Transaction Receipt located on the
File & ServeXpress Web site.

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

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

‘sf Heather Cherry
Heather Cherry

Ross, Robert and Jean y. C.C. Moore & Co. Engineers,-(WB).
SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731

: 2-
EXHIBIT M PART 1 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF WEEGOR BUILDER,
INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATIONLAW OFFICHS

> LLP

‘Sgnre HOG

KEENEY & CORDERY

IMAL, TADLOCK,

(415) 675-7000

CS Oo DW A DW BB Be HH

Yo bb NM ow oN mea sa a a a
&@ OS Re RG 8B Sk BSED RG EB Ss

PROOF OF SERVICE
I, Tina Yim, declare

Tam. a resident of the State of California and over the age of eighteen years, and not a
y to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA
$4104. On the date of execution below, I served the within documents:

EXHIBIT M PART 2 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC.’°S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION

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:

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

On the date of execution below, I electronically served the document via File &
ServeXpress on the recipients designated on the Transaction Receipt located on the
File & ServeXpress Web site.

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

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

/s! Tina Yim
Tina Yim

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

a
EXHIBIT M PART 1 OF 3 10 THE DECLARATION OP TINA VIMIN SUPPORT OF WEBCOR BUILDER,
INC.'S MOTION FOR SUMMARY IUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATIONOo Mm WD Both wR w ON

i¢

Jeb Duties: Plaintiff wrapped ducts and insulated a tank with block insulation, and BLUE MUD
cement. Plaintiff worked neat laborers sweey ing up debris. Plaintiff recalls the following
supervisor: Dick Satya (Belmont, Californie). laintiff recalls the following co-workers: Gene
Thompson (address unknown); Robert Cantley, Brayton**Purcell LLP; Earl Beck (deceased),
Plaintiff currently contends that he was exposed ta asbestos during this employment.

Location of Exposure
Employer Exposure Iob Title Dates
Consolidated Insnlation Eiipatrics Bakery Thsulatar [Se 7- TSE
S17-D Marine View Ave. Oakland, CA (Foreman) (2 months, on and
Belmont, CA 0

Job Duties: Plaintiff insulated pipes tanks and stramers 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 pipefitters
who were installing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets.
FRANK BONETT! PLUMBING was the plumbing and pipefitting contraller. GOLDEN GATE
DRYWALL, INC. employed tapers and sanders at the sife who were hanging, taping and sanding
wallboard, which they covered with asbestos-containing foint compound. Plaintiff cut 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 as an insulation contractor. Plaintiff recalls the following supervisor, Dick Saiya.
Plaintiff recalls the following co-worker. Robert Cantley (c/o Bnryton Purcell LLP}; oper
Fonken (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 Sandia National Laboratory Insulator 1/1967-3/1972
517-D Marine View Ave. Livermore, CA (1 month, on &
Belmont, CA . aff)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff recalls the following supervisor:
Richard Saiya {Belmon California). Plaintiff recalls the following co-workers: Robert sree

(oe Braytoo*Parcell LLP), Earl Beck (deceased); Robert Wildoner (c/o Brayton Purcel
laintiff 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 (1_month, on and
Belmont, CA, off)

Job Duties: Plaintiff worked at this site multiple times. Plaintiff wrapped ducts and installed
PABCO pipe insulation, Plaintiff had to crawl under the building in order insulate pipes and
recalls that there was asbestos insulation ali over the ground and that his clothes and skin were
covered in insulation debris. Plaintiff tad to crawl through the spate above the ceiling in order
to install insulation. Plaintiff recalls that COOPER BRO’ personnel would tear holes in
the plaster walls and ceiling and that there was dust from the lath and plaster that had been tom
out, Plaintiffrecalls there was debris from the fireproofing as well as fireproofing on the beams,
Plaintiff recalls working near COOPER BROTI plumbers and elecincians who used
wrenches and hammers to knock-off existing asbestos-containing PABCO insulation and

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MONOKOTE fireproofing while installing their cables. Plaintiff worked near sheet metal
workers whe disturbed the insulation and fireproofing while installing ducts, Plaintiff recalls
working near pipefitters who he believes were from COOPER BROTHERS while they installed
pipes and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintif?
worked next to workers who were. petting asbestos-containing ANCHOR packing into valves.

carpenters and workers wor ing on the controls A controls worker working next to plaintiff,
disturbed overhead MONOKO

‘recalls working near sprinkler fitters installing pipes and’ gaskets and dishitbing the iisafation in F

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation US D ent of Insulator 1/1967-3/1972,
517-D Marine View Ave. Agriculture G weeks, on and
Belmont, CA any, CA off)

Job Duties: Plaintiff insulated pipes and duct. Plaintiff recalls using all-purpose cement and 301
cement. Plaintiff recalls working near plumbers and pipelitters installing pipes, valves and
geokets Plaintiff recalls wording near sheet metal workers who shot studs into the beams,

ocking off the freproofing. Plaintiff recalls working near D.W. NICHOLSON laborers
sweeping up debris, mcluding wire gasket material and insulation mud approximately 10 feet
below plaintiff. Plaintiff recalls the following insulation contractor: P EN ASBESTOS
COMPANY (PLANT INSULATION COMPANY). Plaintiff recalls contractors: D.W.
NICHOLSON CORPORATION, COMMERCIAL AIR, and RODONI-BECKER (O., INC.
Plaintiff recalls the fellawing supervisor, Dick Saiya Belmont, California), Plaintiff recalls the
following co-workers: Earl Furr (deceased); Roger Fonken (cfo Brayton%*Purceli LLP); William
DeBere (deceased); Robert Cantley c/o Brayton’? Purcell; Richard Tobey (deceased), Plaintiff
currently contends that he was expased to asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Kaiser Hospital Insulator 1967-1972
$17-D Marine View Ave. 2425 Geary Blvd.
Belmont, CA San Francisco, CA

Job Duties: Plaintiff applied, asbestos-containing insulation to piping and ductwork during
hospital renovations. D, ZELINSKY painters also sanded the Breviously mudded, taped and
sanded interior walls in order to prepare those surfaces for painting. Robert Cantley, c/o
Brayton’ Porcel] LLP, was plaintif?’s supervisor at this site. Plaintiff curently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure itle Dates
Consolidated Insulation California Pacific Medical Insulator W196 71972
$17-D Marine View Ave. Center | (2 weeks, on and
Belmont, CA, San Francisca, CA off}

(California Street)

51wm FD A me

Job Duties: Plaintiff installed jnsulation and 301 insulating cement on the fittings. Plaintiff
worked near laborers sweeping up debris and tapers applying and sanding joint compound.
Plaintiff worked near drywall hangers cutting and installing drywall and near sprinkler fitters
who installed pipes and gaskets. Plaintiff worked near shestmetal workers and near pipefitters
installing pipes, valves and gaskets, Plaintiff observed ANDERSON ROWE & BUCKLEY
pipefitters installing GARLOCK (GARLOCK SEALING TECHNCLOGIBS, LLC) gaskets and
removing and rey lasing valve packing, Plaintiff recalls contractors ANDERSON, ROWE &
BUCKLEY, INC,, J.W. MCCLENAHAN COMPANY, FW, SPENCER & SON, INC., and
CAHILL CONTRACTORS, INC. Plaintiff recalls the following, co-workers: Robert. Cantley
{c/o Brayton**Pitcell CLP); Joseph O-Balte le Bias ion PircelTELPY. Plaintiif currently
contends he Was exposed to asbestos during this employment.

Lactation of Exposure
Employer Exposure - iob Title Dates
Consolidated Insulation Coast Guard Facility Insulator V1 967-3/1972,
517-D Marine View Ave. Mouterey, CA (lL week, on and
Belmont, CA aff)

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
comt off existing pipes. Plaintiff recalls working near pipefitters installing pipes and gaskets.
Plaintiff recalls the jollowing supervisor: Dick alya. Belmont, California); plaintiff recalls the
following co-workers: Robert Cantley (c/o Brayton“Purcell LLP); Barl Beck (deceased.
Plaintiff curently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Veterans Administration Insulator 1/1 967-3/1972
517-D Marine View Ave. Hospital (Lweek, on and
Belmont, CA Yountville, CA off}

asbestos blankeis. Plaintiff recalls d: hangers cutting and installing drywall and tapers
applying and sanding joint compoun, s work area, Plaintiff recalls pipefitters installing

ipes and gaskets, Plaintiff recalls the following supervisor: Dick Saiya (Belraont, California).
Bint recalls the following co-worker: Joseph O'Balie (c/o Brayton*Purcell LLP), Plaintiff
curreatly contends he was exposed to ashestos during this employment.

Job Duties: Flainttif recalls laborers sol up debris in his area and welders who were using
int

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Unknown Meat Packing —_Insulator 1/1967-3/1972
517-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
{c/o Brayton*Purcell LLP). Plaintiff currently contends he was exposed to asbestos during this
employment.

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Location of Exposure
Employer Exposure Job Title Dates
Consolidated insulation Queen of the Valley Insulator =—«*1/1967-3/1972
§17-D Marine View Ave. Hospital (G3 to 4 weeks, on
Belmont, CA Napa, CA and off}

Job Duties: Plaintiff worked on a remodel of this facility, Plaintiff recalls installing fiberglass
duct wrap. Plaintiff recalls the follawing oe-worker. Joseph O’Balle (co Brayton? Purcell
S dering tits emtpliypmient®

| CEPY, Plaintiffis comentty anawate if he was exposed‘tt'asBestis ¢

Lovation of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Stonestown Shopping Insulator 11867-31972
417-1) Marine View Ave. Center (1 month, on and
Belmont, CA San Francisco, CA off)

Job Duties: Plaintiff recalls installing insulation and duct wrap. Plaimiff recalls working near
drywall hangers curing and installing drywall and tapers spying and sanding joint compound.
Plaintiff recalls working near pipefitters installing gaskets, valves and pipes. Plaintiff recalls the
following supervisor: Hobert Cantley (c/o Brayton%Pureell LLP). Plaintiff recalls the following}
co-worker: Joseph O°Balle (c/o Breyton’ Purcell LLP), Plaintiff curently contends he was
expased to asbestos ducing this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Napa County Hall of Insulator 1/1967-471972
417-D Marine View Ave. Justice (3 days, on and
Belmont, CA Napa, CA off}

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

Location of Exposure
loyer Exposure Job Title
Consolidated Insulation Kaiser Hospital Insulator 1/1967-311972
517-D Marine View Ave. Vallejo, CA, (3 weelcs, on and
Belmont, CA. . otf)

Job Duties: Plaintiff reoalls 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. Plainuff applied PABCO pipe insulation and cements. Plaintiff worked near tapers
applying and sanding joint compound. Plaintiff recalls the following contractors at this site:
er ED FIRE PROTECTION and BROADWAY PLUMBING, employees were disturbing
asbestos-containing fireproofing. Plaintiff currently recalls the following supervisor: Dick Satya
(Belmont, Galitersia laintiff currently recalls the iollowing co-workers; Joseph O" Balle (c/o
Brayton’*Purcell LEP); Robert Cantley (e/o Brayton“*Purcell LLP); Earl Beck (deceased,
Plaintiff currently contends he was exposed to asbestos during this employment.

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Location of
Employer Exposure,

Consolidated Insulation Alta Bates Hospital _
517-D Marine View Ave. Oaldand, CA
Belmont, CA

Job Duties: Plaintiff worked at this facility multiple times throughout his employment with
Conselidated, Praniffrecalts ashestoss ining f Tiarafaetared by MONK E
IMPERIAL PLASTERING, and NATIONAL GYPSUM. Plaintiff recalls the following

Exposure
Dates

1/1967 - 1972;
1977 - 3/1980

(3 to 4 weeks, on
and off)

OFE,

contractors: ALADDIN HEATING, GGLDEN GATE DRY WALL, INC., BARNES
CONSTRUCTION CO., EMERICK SHEET METAL CO., Plaintiff recalls the followin
supervisor: Dick Saiye (Relmont, Conant: Piaintiff reealls co-workers: Robert Cantley (c/o
Brayton Pincell LLP); Earl Beck (deceased); and Bob Wildoner (c/o Brayton%*Purcell LLP).
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of
Employer Focposure
Consolidated Insvlation Mills Building

517-D Marine View Ave. {Bush/Montgomery)
Belmont, CA an Francisca, CA

Exposure ~

Dates

11967-31972
(on and off}

Job Duties: Plaintiff installed asbestos insulation and wrapped duct Plaintiff worked near

plumbers ani Finer ra who were installing pipes, valves, and paskets. DOUGLASS

SULATIO

OMPANY insulators cut and. applied calcium silicate pipecovering an wet heat

and steam piping near plainfiff. Plaintiff recalls that fireproofing was being disturbed by the.
electricians and the ceiling tile workers. Plaintiff recalls contraciors: DOUGLASS
INSULATION COMPANY, INC., DELUCCHI SHEET METAL WORKS, C.5. HARDEMAN,
INC., J-W. MCCLENAHAN COMPANY, MCCLURE ELECTRIC, INC., and ZELLER
PLASTERING, Plaintiff currently contends be was exposed to asbestos during this employment.

* Location of
Employer Exposure
Consolidated Insulation City Administration

517-D Marine View Ave. Building
Belmont, CA Cutting Boulevard
Richmond, CA

Exposure
Dates

1/1967-3/1972
(2 months, on and
a

Job Duties: Plaintiff worked in the boiler oom. Plaintiff insulated pipes and ducts on a hot
water heater. Plaintiff worked with BORDEN'’s fibrous adhesive, EAGLE-PICHER cement, and
PABCO 127 BLUE cement. Plaintiff worked near plumbers and pipefitters installing pipes,

gaskets and valves. Plaintiff worked near

drywall hangers cutting and installing drywall.
laintiff worked near GOLDEN GATE DRYWALL tapers mixing, applyin|

and sandin;
asbestos-containing joint compound. Plaintiff recalls that fireproofin;

cing disturbed by

the controls men. Plaintiff recalls contractors: GOLDEN GATE DRY WALL, INC.,
ANDERSON, ROWE & BUCKLEY, INC., RODONI-BECKER Co., INC., ALLIED FIRE
PROTECTION, and CAHILL CONTRACTORS, INC. Plaintiff recalls the following supervisor:

Richard Satya (address unknown). Plaintiff recalls the followi
ankncwnys Earl Beck {deceased}: Robert Cantley (c/o

fatdees s

co-workers: Gene Thompson
ayton®Purcell LLF); Mickey

ohnson {address unknown), Plaintiff curently contends he was exposed to askestas during this

employment.

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

Job Duties: Plaintiff inswlated pi

es and ducts, Plaintiff worked near pipefitters installing pipes,
1

gaskets and valves, and using packing. Plaintiff recalls working near sheet metal workers ‘whi

shot studs intit-the bers,

Kttscking offthie
up debris. Plaintiff worked near MONTEREY
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC} g

ICAL pipefitters who were applying
ets. The MON YY

MECHANICAL pipefitters also disturbed finished and taped sheetrocked walls when making

wall penetrations for piping. Plaintiff recalls the following s

apervisor: Ri

chard Saiya (address

unknown}, Plaintiff recalls the following coworkers: Robert Cantley (cfo Brayton’Purcell
LLP); Earl Beck (deceased). Plaintiff currently contends he was exposed to asbestos during this

employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 50 California Street Insulator 11967-3/1972
517-D Marine View Ave. San Francisco, CA (2 weeks, on and
Belmont, CA off}

Job Duties: Plaintiff insulated
cement. Plaintiff recalls the fo
recalls the following coworker: Kobert Cantley (c/o Brayton!

pies and duets. Plaintiff used cal-sil insulation and all-purpose
owing supervisor: Richard Saiya (address umknown). Plaintiff

contends he was exposed to asbestos during this employment.

cell LLP). Plaintiff currently

: Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation St. Mary’s Church Insulator 11967-34972.
S17-D Marine View Ave. Sen Francisco, CA {6 Weeks, on and
Belmont, CA off}

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers and pipefitters
installing Fipes, baskets and valves, and using packing, Plaintiff worked near drywall hangers
cutting and installing drywall. Plaintiff worked near tapers applying and sanding joint
compound. Plaintiff recalls working ocar sheet metal workers who shot studs into the beams,
knocking off the fireproofing. Plaintiff recalls that fireproofing was being disturbed by the
ROBERT SHAW controls technicians, Plaintiff worked near sprinkler fitters who had to disturb
the fireproofing in order ta install their pipes. Plaintiff worked near laborers swee) ng Up debris.
Plaintiff recalls the following contractors: general contractor CLAUSEN PALTEN, eet metal
contractor DELUCCHI SHEET METAL WORKS, and drywall contractors GOLDEN GATE
DRYWALL, INC. and D. ZELINSK'Y & SONS, INC. The D. ZELINSKY crew was taping and
sanding asbestos-contaming taping compounds § to 20 feet from plaintiff, and was printin:
there: . Plaintiff recalls the following supervisor: Richard Saiys (address umknown), Ptsinni
tecalla the following coworkers: Sal Morales (deceased); Joseph O’Balle (c/o Brayton’ Purcell
LLP). Plaintiff currently contends he was exposed fo as' s Outing this employment.

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Losation of Exposure
Employer Exposure Job Title Bates
Consolidated Insulation Highland Hospital Insulator 1/1967-3/1972
517-D Marine View Ave. Oakland, CA {L 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. pipeditters installing pipes, gaskets and valves, and using

perk ing, Plain worked near ectttig ‘were-chtting amd trstiiitnes cetting nites,
faint recalls that fireproofing was being disturbed by the ceiling Ieee ee worked

near floor tile installers who were suiting and installing floor tiles. Plaintiff recalls that
fireproofing was being disturbed by the floor tile installers, Plaintiff recalls working near sheet
metal workers whe shot studs inte the beams, knocking off the fireproofing. Plaintif recalls
secing others spraying W.R. GRACE MONOKOTE fireproofing spray. Plaintiff worked near
laborers sweeping up debris. Plafatiff worked near insulators employed by the following
contractors: WESTERN ASBESTOS COMPANY, PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY). Plaintiff recalls general contractors DPR. CONSTRUCTION, and
ROTHSCHILD & RAFFIN, INC.; mechanical contractor ALADDIN HEATING
CORPORATION drywall contractors CIR PLASTERING and GOLDEN GATE DRYWALL,
INC.; and COSCO SPRINKLER. Plaintiff observed pipefitters and shieetmetal workers shooting
studs into overhead roofing, cutting and installmg GARLOCK (GARLOCK SEALING
TECHNOLOGIES, LLC) gaskets, and cutting and installing flexible duct connectors while
fabricating steam and water piping and duct work. Plaintiff worked alongside pipefitters who
disturbed overhead MONOKCTE fireproofing while setting pipe supports, and wha disturbed
existing asbestas-containing (pecovering near plaintiff while fabricating new piping, Plaintiff
recalls RHODES & I, ‘ON supplied asbestos-containing products. Plaintiff Tecails the
following supervisor: Robert Cantley (c/o BraytonPurcell LLP}. Plaintiff recalls the following]
coworker: Stan Silva {igeeased . Plaintiff also worked with these co-workers employed by
PLANT ASBESTOS COMPANY (PLANT INSULATION COMPANY): Joe Met eary {address
unknown), and Phil Peterson (c/o Brayton*Purcell LLP). Plaintiff curréntly contends he was
exposed to asbestos during this employraent.

Location of : Exposure
Employer Exposure Job Title Dates
Consolidated Insulation American Can Company Insulator 1/1967-3/1972
517-D Marine View Ave, San Leandro, CA (4 days, on and
Belmont, CA off]

Job Duties: Plaintiff insulated pipes and ducts. Plaintiffused cal-sil insulation and 301 all-
ptrpose cement, Plaintiff worked near pipefitters installing pipes, gaskets and valves, and using
packing. Plaintiff worked near laborers sweeping up debris. Plaintiff recalls the followi:
supervisor: Richard Saiya (address unknown). Plaintiff recalls the following coworkers: Robert
Cantley (efo Brayton Purcell LLP); Earl Beck (deceased); Robert Wildoner (c/o
Brayton%Purcell LLP). Plaintiff currently contends he was exposed to asbestos during this

employment.

Location of . Exposure
Employer Exposure Job Title Yates
Consclidated Insulation ] Bush Street Insulator V1967-3/1972
517-0 Marine View Ave. San Francisco, CA (weeks, on and
Belmont, CA off)

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Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near pipefitters installing pipes,
kets and valves, and using packing. Plaintiff recalls working near sheet metal workers who
Shot studs into the beams, knocking off the fireproofing. Plaintiff recalls others sprayin
fireprooting spray. Plaintiff recalls contractors: BALLIET BROTHERS CONSTRUCTION
CORPORATION, PACIFIC MECHANICAL, and ATLAS HEATING AND VENTILATING
COMPANY, LTD. Plaintiff recalls the following supervisor: Robert Cantley (clo
Brayton*Purcell LLP). Plaintiff curently contends he ‘was exposed to asbestos during this

employment
. Locediorrof Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Hong Kong Bank * Insulator 1/1967-3/1972,
517-D Marine View Ave. San Francisco, CA Q) week}
Belmont, CA feadquarters—1 60
aoscme Street)

Job Duties: Plaintiff msulated pipes and ducts. Plaintiff worked near plumbers and pipefitters
installing pipes, sskets and valves, and using packing, Plaintiff worked near drywall’ Rangers
curting and installing drywall, Plainttif worked near tapers applying and sanding joint
compound, Plaintiff recalls working near sheet metal workers who shot studs into the beams,
knocl ing off the fireproofing. Plaintiff recalls working around controls men, and that

Breproo ing was being disturbed by the cantrols men. Plaintiff worked near HONG KONG

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

Brayton Purcell wedi Richard Sate (address unknown). Plaintiff recails the following
coworker: Earl Beck (deceased). Plaintiff currently contends he was exposed to asbestos duting

this employment.
Location of Exposure
Employer Expasure Job Title Dates
Consolidated Insulation 111 Pine Street Insulator 1/1967-3/1972;
517-D Marine View Ave. San Francisco, CA S/77-L/81
Belmont, CA Geeks, on and
oa

Job Duties: Plaintiff insulated domestic water pipes and ducts. Plaintiff worked near pipefitters
installing pipes, gaskets and valves, and using packing. Plaintiff recalis working near sheet metal|
workers who shot studs into the beams, knocking off the fireproofing, FREDERICK
MEISWINKEL, D. ZELINSKY, sweeping asbestos-containing debris in plaintiff's presence,
Plaintiff saw MEIS WINKEL personnel using bags of asbestos containing joint compounds,
mixing the material and sanding it after it was applied to imtertor walls. Plaintiff saw
ZELINSKY personnel mixing, taping and sanding asbestos-containing taping compounds and
then painting in plaintiff's presence. Plaintiff worked near laborers sweeping up debris. Plainti
recalls the following supervisor: Robert Cantley (c/o BraytonPurcel! 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 Insulator VWI967-31972;
517-D Marine View Ave. San Francisco, CA Sf77-1181
Belmont, CA (1) menth, on and
2

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20

Job Duties: Plaintiff insulated pipes and. ducts. Plaintiff worked near pipefitters installing pipes,
gaskets and valves, and using packing. Plaintiff recalls working near sheet metal workers Who
shat studs into the bearns, knocking off the fireproofing. Plaintiff worked near laborers sweeping!

debris. Plaintiff recalls the following supervisor: Robert Cantley (c/o Brayton’-Purcell LLP)|
Plaintiff currently contends ke was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consotidizted HnsuPattinr Navat Station Treasore Insufator HISSEIGTA:
517-D Marine View Ave. Tsland S/TT- LBL
Belmont, CA San Francisco, CA (L month, on and
off)

Job Duties: Plaintiff insulated pipes and ducts in the barracks and in the boiler room. Plaintiff
used cal-sil insulation in the boiler roora and fiberglass insulation in the barracks. Plaintiff used
all purpose mud. Plaintiff recalls general contractor: ROLLINS CONSTRUCTION, mechanical
contractor, JAMES NELSON, electrical contractor; and BANNER DRYWALL & PAINTING.
Plaintiff recalls the following superasors: Richard Saiya (address unknown): Robert Cantley,
c/o Brayton’Purcell LLP, Plaintiff recalls the following coworker: Jack Jagoda, Martinez,
California (c/o Paul & Hanley LLP). Plaintiff currently contends he was exposed ta asbestos
during this employment.

Lovation of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation TBM "Insulator 1967-1972;

517-D Marine View Ave. San Jose, CA 1977-1981
Belmont, CA. .

Job Duties: Plaintiff applied fiberglass duct wrap to duct work and applied fiberglass and
calcium silicate  Fipecovering and Insulation cements to piping valves and fittings during new
construction and during multiple remodel Projects. Pleinuff cut and applied KAYLO (OWENS
CORNING FIBER.GLAS) pipecovering and JOHNS E pipecovering, Plaintiff worked
near these and other tradesmen who disturbed previously applied asbestos-containing overhead
fireproofing while hanging supports for Pi ping duct work, sprinkler systems, controls, and.
electrical conduit or while sweeping and cleaning debris that had collected in the work areas.
Plaintiff also observed JAM personnel sweeping and cleaning asbestos-containing debris in his
work areas. Plaintiff also worked next to D. INSKY painters sanding ashestos-containing
joint and taping compounds on interior walls, in order to prepare those surfaces for painting.

laintiff’s supervisor was Robert Cantley (c/o Brayton*Purcell LLP). Plaintiff currently
contends that he was exposed to asbestos during this employrnent.

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

Belmont, CA

Job Duties: Plaintiff performed mtermittent “fill-in” work Plaintiff worked on sew construction!
and on ir and maintenance crews. Plaintiff applied fiberglass duct wrap to duct work and
applied fiberglass and calcium silicate pipecovering and insulation cements to piping, vabves, anc}
fittings. Plaintiff worked fi: proximity to a range of trades, including pipefitters, sheetmetal
workers, electricians, drywall hangers, lepers, and sanders, cernent masons, file setters,
maintenance personnel, and laborers. CUFERTINO ELECTRIC COMPANY served a5 electrical

58oe WY AW he Ww oY

contractor on one ot mote of these projects. CUPERTINO ELECTRIC personnel disturbed
ashestos-containing overhead freprootin while setting supports for therr electrical conduit in
plaintiff's presence. Plaintiff also worked next to D. ZELINSKY painters sanding asbestos-
containing jaini and taping compounds on interior walls, in order to prepare those surfaces for
painting. laintif?’s supervisor was Robert Cantley (c/o Brayton**Purcell LLP). Plaintiff

tly

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

Job Duties: Plaintiff installed insulation to plums bin pipe. Plaintiff recalls insulators from
ASSOCIATED INSULATION installing cal-sil insulation to the pipes and the valves and
asbestos cement to the fittings. Plaintiff identifies ASSOCIATED INSULATION employee
Maurice Lawrence (c/o Brayton*Purcell LLP). Plaintiff recalls the following co-worker:
Richard Collins (c/o Brayton*Purcell LLP). Plaintiff currently contends that he was exposed to
asbestos during this employment

Location of Expasure
Employer _ Exposure Job Title Dates
Consolidated Insulation 101 Califormia Street, Insulator 1970 - 1972;
517-D Marine View Ave: San Francisca, CA. 1977 - 1979
Belmont, CA fon and off}

Job Duties: Plamtiff applied asbestns-eontalting insulaticn to duct wrap and piping in the boiler
room. Plaintiff recalls fades employed by ORTHO-CRAFT were sweeping the area, Plaintiff
recalls pipefitters and other trades were disturbing MONOKOTE fireproofing on and around the
ceilings. Drains tecalls the following contractor: GOLDEN GATE DRYWALL, INC,
Plaintiff recalls supervisor: Robert Cantley (elo Brayton*Purcell LLP). Plainti Tecalls co-
workers: Earl Beck {deceased); and Bob Wildoner (c/o Brayton*#Purcell LLP). Plaintiff

currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Tide Dates
Napa Junios College Napa Junior College Student : 1970-1972
Napa, CA Napa, CA

Job Duties: Plaintiff attended welding classes. Plaintiff is currently unaware if he was exposed
io asbestos during this Training

Location of Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Aerojet-General Insulator 4/1972-9/ 1973
1501 North C Street Rancho Cordova, CA (14 working days)

Sacramento, CA

Job Duties: Plaintiff insulated a large vessel and related piping with PABCO asbestos block and.
PABCO pipecovering, and Fibrous Adhesive, Plaintiff installed JOHNS MANVILLE 352
BLUE cément and mastic. Plaintiff worked near laborers sweeping up debris and near welders
using asbestos blankets. Plaintiff worked near pipefitiers installing gaskets, pipes, valves and

59woe

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ps, Plaintiff recalls the following mechanical contractor; FOLEY-PMI. Plaintiff recalls the
Eliewing supervisor: Pete Rossi, Sacramento, California. Plaintiff recalls the following co-
workers; Al Cook (c/o Brayton Purcell LLP}; Herb Cook (c/o Brayton%*Purcell LLP}; Mike

Hammer (address unknown); Jim White Jr. (Napa, Califomia), Plaintiff currently contends he

was exposed to asbestos during this employment.

Location of : Exposure
Employer Exposure Job Title Dates
Siefect‘and Rossi Genera Milis; Insutater FO72-207%
1501 North C Street Ladi, CA

Sacramento, CA

Job Duties: Plaintiff. ‘applied asbestos-containing insulation, mud, mastic and canvas to pipes and]
cal-sil pipecovering and asbestos mud. Plaintiff recalls using

‘laintiff recalls trades employed by GENERAL MILLS
emen on this job. Plaintiff

fittings. Plaintiff rec

= using
products manufactured by PABCO,
were sweeping up in plaintiff's presence. Plaintiff worked as

currently contends he was exposed to asbestos during this employment.

Job Duties: Plaintiff insulated pipes and wrapped ducts. Plaintiff worked near laborers sweeping
up debris. Plaintiff worked near pipefitters installing gaskets,
having to remove and replace ceili

. Location of Exposure
Employer Exposure: Job Title Dates
Siefert and Rossi Kaiser Hospital Tasulator 411 972.-9/1 973
1501 North C Street Sacramento, CA (3 weeks, on and
Sacramento, CA off)

exposed to asbestos during this employment.

Location of Exposure

Employer Exposure Job Title Dates
Siefert and Rossi Sacramento Convention Insulator 4/1972-9/1973,
150] North C Street Center (G months, on and
Sacramento, CA Sacramento, CA off}

: (16" St)
Job Duties: Plaintiff installed. pips insulation and 301 cement on the fittings. Plaintiff insulated
what he believes was a BARCOCK & WILCOX boiler with asbestos block insulation, all-

purpose cement, mastic and canvas and 352 BLUE cement. Plaintiff worked near pipefitters

itters pipes and valves, Plaintff recalls
tiles in order fo perform his job duties. Plaintiff recalls
existing fireproofing on the ceiling tiles. Plaintiff recalls mechanical contractor: LAWSON
MECHANI . LAWSON MECHANICAL pipefitters and sheetmetal workers disturbed
previously sprayed overhead fireproafing while Setting pipe and duct supports in plaintiff's work
areas. Plaintiff recalls the feTlowing supervisor: Pete

ssi, Sacramento, Califomia. Plaintiff
recalls the following co-worker:

ally Friswald (deceased), Plaintiff currently contends he was

installing gaskets, pipes and valves. Plaintiff worked neat laborers sweeping up debris and near
welders pérformiag ‘welding and using asbestos blankets. Plaintiff worked near drywall hangers
cutting and installing drywall and near tapers applying and sanding joint campound. Plainti:
recalls Teparting to an inspector who worked for the City of Sacramento and believes that the

City of Sacraménto was the general contractor for the raject. Plaintitf worked in proximity to

I. S WHITTAKER, INC (RAYMOND INTERIOR SYSTEMS-NORTH) labarers who were]
mixing and spraying CAFCO (UNITED STATES MINERAL PRODUCTS COMPANY)
fireproof roofing debris in plaintiffs presence. Plaintiff}

and who were sweeping up dried
recalls the following contractors: SON MECHANICAL, and TEICHERT

60CONSTRUCTION CO. LAWSON MECHANICAL personnel swept up esbestos-containing,
block insulation debris near plaintiff in a Large boiler room. Plaintiff recalls the following co-

workers: A] Cook (c/o Brayton Purcell LLP); Herb Cook (o/o Brayton" Purcell LLP), Jim
White, Jr. (Napa, California), Plaintiff currently contends he was exposed te ashestos ducing this}
employment. :
Location of Exposure
Employer Exposure Job Title ates
Siefért amd“ Resst Amerteanr River City : Insulator LOPE TSTT
1561 North C Street . College (2 weeks, on and
Sacramento, CA Sacramento, CA oft}
Job Duties: Plaintiff worked in’a pipe chase and in the boiler room. Plaintiff installed used all-
purpose cement on valves. Plaintiff recalls the following co-worker: Me] Swanson, Sacramento,
California. Plaintiff is currently unaware if he was exposed io asbestos during this employment,
Location of Exposure
Employer Exposure Jeb Tile © Dates
Siefert and Rossi Truckee High School Insulator 4/1972-9/1973
1$0] North © Street Truckee, CA, (2 weeks, on and
Sacramento, CA off} -

Job Duties: Plaintiff insulated a tank. Plaintiff used cal-sil blocks, all-purpose cement, fibrous
adhesive cement, and 127 cement, Plaintiff worked near plambers and Pipefitters installing,
pipes, gaskets and valves, Plaintiff worked near insulators employed by NORCAL
INSULATION who were installing cal-sil insulation. Plaintiff recalls the following supervisor:
Pete Rossi, Sacramento, California. Plaintiff recalls the following coworker; Richard ‘Bunley
{address unknown), Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of : Exposure
Employer Exposure Job Title Dates
Siefert and Rossi Merchant's Cold Storage — Insulator ANLOT2.9/1973
150] North C Street Salinas, CA (3 weeks)

Sacramento, CA

Job Duties: Plaintiff insulated pipes, valves and fittings. Plaintiff worked on hot and cold fines.
Plaintiff used ONE COTE cement. Plaintiff recalls the following coworkers: Ted George (c/o
Brayton Purcell LLP}; Bud Weidner (deceased). Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer Exposure . Job Title Dates
Plant Insulation Westin Saint Francis Insulator 10/1973-12/1973;
2271 Califomia Street (Powell Street) 3/1974-3/1 976;
San Francisca, CA San Francisco, CA 1O/L976-2/1977

(21 to 26 days)
Job Duties: Plaintiff mstalled insulation on pipes and valves in the boiler mom, Plaintiff used

PABCO insulation and 127 insulatmg cement DOUGLASS INSULATION COMPANY
insulators applied calcium silicate pipecovering and asbestos-containing cements to boiler room

61wom ou Rw B YY

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a

piping. Plaintiff worked near pipefitters installing pipes, valves, pumps and gaskets, -Plaintiff
worked in proximity to CONSOLIDATED INSULA ON, INC, and DOUGLASS
INSULATION COMPANY, INC. insulators removing ald ashestos-containing insulanon,
Plaintiff worked beneath LERA ELECTRIC personnel who were disturbin: fireproofing above

laintiff, Plaintiff worked in proximity to the following contractors: CRITCHFIELD

IECHANICAL, INC. CONSOLIDATED INSULATION, INC., DOUGLASS INSULATION

COMPANY’, INC., C.5, HARDEMAN, INC. SAM P. WALLACE COMPANY, ANDERSON,
ROWE & BUCKLEY, INC., JAMES NELSON, COAST PLASTERING COMPANY, Plaintiff
worked alongside CONSOLIDATED INSULATION employees Robert Cantley (c/o

EEPY, and Bark Bee pw were asic? i f
asbesias-containing PABCO pipecovering and ay ineehone Plaintiff ae ‘he followin z
supervisor: Glenn Schimmelphenig (address unknown). Plaintiff recalls the followmg, co-
worker. Allan Edwards (deceased). Plaintiff currently contends he was exposed to asbertos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant lasulefion Letterman Hospital Insulator 10/1973- 12/1973;
2271 Califomia Street & Medical Center F973 976:
San Francisco, CA San Francisco, CA 10/1976-2/1977
(L month, on and
off}

Job Duties: Plaintiff worked on a remodel of the hospital. Plaintiff’ ‘wrapped ducts in the
mechanical rooms and on various other floors. Plaintiff recalls fireprooting on the beams.
Plaintiff recalls the following supervisor: Glenn Sebitnmaclphenig address unknown). Plaintiff
recalls the following co-worker: Larry Cooper, Cathedral City, Califomia. Plaintiff currently
contends he was exposed fo asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Fiant Insulation Standard Oi] Insulator 10/1973-12/1973,
2271 Califomia Street Richmond, CA 3/1974-3/1976;
San Francisco, CA, 1O/1976-2/1 977
Gre nthe, on and
o:

Job Duties: Plaintiff recalls installing insulation on pipes, valves, heat exchangers, towers and
vessels. Plaintiff recalls having to crawl over pipes that were covered with asbestos insulation to
perform his duties. Plaintiff recalls that his clothes and skin would be covered with dust,
Plaintiff recalls working near welders using welding blankets, laborers sweeping up the site and
near pipefitters installing gaskets, valves and pipes. Plaintiff worked near electricians employed
by CONTRA COSTA ELECTRIC, INC who were disturbing pipe insulation while installing
conduit. Plaintiff recalls the following supervisors: Glenn Schimmelphenig (address unknown);
Arvis Duncan (deceased). Plaintiff recalls the following co-workers: Donald Bumett (Caledale,
California); Warren Hasse (c/o Brayton Purcell CLP); Richard Tobey (deceased); Ear! Riges
deceased); Roger Fonken (c/o Brayton**Purcell LLP); Robert Holbrook (c/o Brayton*+Purcell
LP}, Joseph C* Balle (c/a Brayton%+Purcell LLP); Robert Drose (deceased); Gary Hopes fofo
Brayton*Purcell LLP). Plaintiff recalls the following co-workers exaployed by OSCAR E.
ERICKSON, INC.: John Price {clo Brayton Purcell LLP); and Monte Manwill (c/o
Brayton Purcell LLP}. Plaintiff currently contends he was exposed to asbestos during this
employment

62Oo mo sa DA He Ww Ne

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13

Location of Exposure

Employer Exposure Job Title Dates

Plant Insulation Co. Shell Oil Refinery Insulator 1973-1977

2271 California Street Martinez, CA

San Francisco, CA

Job Duties: Plaintiff applied asbestos-containing insulation to piping, vessels and heat

exchangers during a tumaround. Plaintiff contends he was exposed to asbestos during this

Location of Exposure

Emplover Exposure Job Title Dates

Plant Insulation PG&E Powerhouse Insulator 16/1973-12/1973;

2271 California Street Pitsburg, CA 3/1974.3/1976;

San Francisco, CA LOAL976-2/1 977
(3-4 months, on
and off}

Job Duties: Plaintiff applied block insulation and PABCO pipecovering while repairing
damaged boiler and turbine insulation. Plaintiff worked near welders using asbestos blankets
PG&E laborers who were sweeping bp previously removed asbestos-containing debris. Plaintiff
worked near pipefitters mstalling gaskets, valves and Rapes. Plaintiff worked near pipefitters who,
Were installing SUPERIOR valves and GOODYEAR & RUBBER COMP. gaskets.
Plaintiff recalls the following supervisors: Glenn Schimmelphenig {address unknown); Arvis
Duncan (deceased), Plaintiff recalls the following co-workers: Donald Burnett (Oakdale,
California); Mike Caylor (c/o Brayton%Purcell LLP}; Robert Lee (c/o Brayton“ Purcell LLP);
Richard Crabatrarl (cfo Brayton? Purcell LLP); John McClure (deceased); Edward Johnson {evo
Brayton Purcell 9; John Price (c/o Brayton**Purcell LLP}. Plaintiff currently contends he

was exposed to asbestos during this employment.

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

Job Duties: Plaintiff applied cal-sil Ff recovering, Block and mud. Plaintiff applied JOHNS
MANVILLE Blue Mud, mag mud 127, and FOSTERS adhesive. Plaintiff recalls using PABCO
products, Plaintiff recalls laborers were gyecping ap and installing asbestos-comaining
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff observed
laborers sweeping ad shoveling, PABCO pipecovering cement, and calcium silicate block
debris underneath plaintiff, 5 10 30 feet from plaintiff. Plaintiff recalls welders used asbestos
blankets manufactured by RAYBESTOS and “A” cloth, Plaintiff recalls coworkers: Lanrance
Hagen (c/o Breyton*Purcell LLP); Guy Kennedy (c/o Brayton“*Purcell LLP); and Mike Caylor
{o/o Braytoo’Purcell LLP). Plaintiff currently contends he was exposed to asbestos during this
employment,

di
itt
Mf

63Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Fireman’s Fund Insulator 10/1973-12/1973;
2271 California Street Novato, CA 3/1974-3/1976;
San Francisco, CA LOML976-2/1977
(CL month, on and
off)
Joe Duties: PtaintifP worked tiie mechanical rooms.’ Ptaittiffinstatied aft eerfent ant

127 BLUE MUD cement on valves, Plaintiff removed and replaced ceiling tiles and had te
disturb existing insulation on the ceiling tiles and pipes. Plaintiff recalls working near pipefitters
installing pipes, gaskets, and valves, Plaintiff worked near sheetrockers and tapers installing and
sanding joint compound. Plaintiff recalls labovers sweeping up debris, Plaintiff recalls the
following cortractors: Plaintiff observed FREDERICK MEISWINKEL INC. personnel using
asbestos-containing joint compounds, which they taped and sanded. Plaintiff recalls PARKER-
HANNIFIN CORPORATION valves and epproximately twenty asbestos-containing DURABLA
(DURABLA MANUFACTURING COMPANY, INC.) gaskets were installed at this site,
Plaintiff recaj]s the following supervisors: Glenn Schimmelphenig (address unknown); Gary
Hansen, ofo BraytonPurcell. Plaintiff recalls the following co-worker: Richard Tobey
(deceased). Plainnff curently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title
Plant Insulation Calpate-Palmolive Insulator 1O/1973-12/1973;
2271 Califormia Street Berkeley, CA 3/1974-3/1976;
San Francisco, CA 1O/I9FE-21 977
. (1 month, on and
off}

Job Duties: Plaintiff insulated tanks with foam glass insulation and insulated pipes with calcium4
silicate insulation. Plaintiff installed ab purpose cement. Plamtiff also recalls the following
contractor: PACIFIC MECHANICAL. Flaintiff worked near LJ. KRUSE pipefitters who were
replacing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) flange gasket and
repacking valves. COLGATE PALMOLIVE personnel swept up insulation cement debris in
plaintiff's presence. Plaintiff recalls the following supervisor: Allan Bdwards (address
unknown). Plaintiff recalls the following co-worker: Gary Hansen (c/o Brayton%*Purcell LLP).
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Phillips Petroleum Insulator 10/1973-12/1 973;
2271 California Street Company/ Lion Oil S/1974-3/1978:
San Francisco, CA Company 10/1976-2/1977
Avon, CA ‘eo on and.
0

Job Duties: Plaintiff performed maimrenance work after a Jarge fire at the refmery. Plaintif

installed PABCO insulation on a large tank, the surrounding piping and associated valves.

Plaintiff recalls working near peters sactalling pipes, Baskets, and valves. Plaintiff recalls
ipefitters installin; GARLOC (GARLOCK $§ TECHNOLOGIES, LLC) and

E MITALLIC, INC. geskets. Flaintiff observed PLANT. MAINTENANCE (PLANT

MAINTENANCE, INC. OF CALIFORNIA) personnel stripping burnt asbestos-comaining