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

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                                Dennis M. Young, Esq. SBN 121178
Lauren C. Mcleod, Esq. SBN 255886
FOLEY & MANSFIELD, PLLP

300 Lakeside Drive, Suite 1900
Oakland, CA 94612

Telephone: (510) 590-9500

Facsimile: (510) 590-9595

E-mail: dyoung@foleymansfield.com

Attorneys for Defendant

ACCO ENGINEERING SYSTEMS, INC.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

FEB 25 2013

Clerk of the Court
BY: ALISON AGBAY
Deputy Clerk

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS,
Plaintiffs,
vs.

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

ee Se ee

Case No: CGC-10-275731
“Asbestos-Related Case”

EXHIBIT SE” TO DECLARATION OF
DENNIS M. YOUNG IN SUPPORT OF
DEFENDANT ACCO ENGINEERING
SYSTEMS, INC.’S MOTION FOR SUMMARY
JUDGMENT OR, IN THE ALTERNATIVE,
FOR SUMMARY ADJUDICATION

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

1

EXHIBITS “E” TO DECLARATION OF DENNIS M. YOUNG IN SUPPORT OF DEFENDANT ACCO ENGINEERING SYSTEMS, INC.'S MOTION
FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, FOR SUMMARY ADJUDICATIONEXHIBIT EBRAYTON@PURCELL LLP

ATTORNEYS AT LAW
222 RUSH LANDING ROAD.

PO BOX 6169
NOVATO, CALIFORNIA 94948-6169

(415) 898-1555

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44615712

ALAN R. BRAYTON, ESQ., S.B. #73685 LenS
ANNE T. ACUNA, ESQ., S.B. #245369 sun F2012
BRAYTON*PURCELL LLP 2IRPM
Attorneys at Law
222 Rush Landing Road
P.O. Box 6169
Novato, California 94948
(415) 898-1555
Attomeys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ROBERT ROSS and JEAN ROSS, ) ASBESTOS
) No. CGC-10-275731
Plaintiffs,
SUPPLEMENTAL/AMENDED
vs. } RESPONSES TO INTERROGATORIES
C.C. MOORE & CO. ENGINEERS, }
Defendants as Reflected on Exhibit |
attached to the Summary Complaint )
herein; and DOES 1-85 0. )
PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: _ Plaintiff ROBERT ROSS

SET NOS.: ONE and TWO

Plaintiff supplements/amends his Responses to Standard Asbestos Case Interrogatories,
Set One, No. 26, and Set Two, Nos. | through 3, as follows:
SUPPLEMENTAL/AMENDED RESPONSE: Plaintiff incorporates by reference as though
fully set forth herein, all work history jobsites and co-workers and related information identified

in the attached Exhibit A.

Dated: &/ Y 1A

BRAYTON*PURCELL LLP

wy A~ le

Anne T. Acuiia
GRE ‘Attomeys for Plaintiffs

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EXHIBIT A

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

Location of Exposure
Employer Exposure Job Title Dates
General Mills Company General Mills Warehouseman 1952-1/1954;
P.O. Box 1113 Vallejo, CA. 2/1956-6/1956

Minneapolis, MN

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

Location of Exposure
Employer Exposure Job Title Dates
United States Army Fort Ord Infantryman, 2/9/54-1/27/56

Monterey, CA;

United States Army
Okinawa, Japan

Job Duties: Plaintiff served in the United States Army as an infantryman. Plaintiff served at
Fort Ord, Monterey, California, for 16 weeks, and the remainder of his time in Okinawa, Japan.
Plaintiff performed maneuvers and combat exercises. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
A.M. Devincenzi Company A.M. Devincenzi Company Truck Driver 8/1956-2/1959;
1598 Carroll Avenue 1598 Carroll Avenue 12/1959-1/1960
San Francisco, CA San Francisco, CA (2 weeks); 9/1960

Job Duties: Plaintiff loaded and unloaded trucks. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
San Mateo Junior College San Mateo Junior College — Welder 1958-1959
San Mateo, CA San Mateo, CA (Trainee)

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

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Location of Exposure

Employer Exposure Job Title Dates
Philip Carey Warehouse Warehouseman —2/1959-8/1959;
Cinemnati, OH 101 Williams 12/1959-1/1960
San Francisco, CA (I week)
Jack. Tar Hotel

(aka Cathedral Hill Hotel)
1101 Van Ness
San Francisco, CA

Job Duties: Plaintiff unloaded boxcars full of asbestos-containing products. Plaintiff swept
floors and delivered asbestos-containing materials to jobsites. Plaintiff recalls unloading or
delivering the following asbestos-containing products: PHILIP CAREY (RAPID-AMERICAN
CORPORATION), JOHNS-MANVILLE (MANVILLE TRUST), OWENS CORNING
KAYLO (OWENS CORNING FIBERGLAS), UNIBESTOS (UNARCO), EAGLE PICHER
(EAGLE-PICHER INDUSTRIES, INC.), CELOTEX, 85% mag cement, 301 and 352 JOHNS
MANVILLE (MANVILLE TRUST) insulating cement. Plaintiff recalls that the jobsite was
very dusty and that his clothes would get covered in dust. Plaintiff also delivered materials to
various jobsites on approximately 10 occasions. Plaintiff delivered materials to the Jack Tar
Hotel in San Francisco, California. CAHILL CONSTRUCTION (CAHILL CONSTRUCTION
CO., INC.) was the general contractor which employed laborers and cement finishers at the site.
Plaintiff observed CAHILL CONSTRUCTION (CAHILL CONSTRUCTION CO., INC.)
laborers sweeping debris created by cutting of PHILIP CAREY (RAPID-AMERICAN
CORPORATION) asbestos-containing pipe insulation and created by cutting of GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) flange gaskets. ANDERSON, ROWE &
BUCKLEY, INC. employed plumbers, pipefitters and sheetmetal workers at the Jack Tar Hotel.
Plaintiff recalls Philip Carey was the insulation contractor at the Jack Tar Hotel. Plaintiff
recalls Bill Houston was the Philip Carey supervisor at the Jack Tar Hotel. Plaintiff recalls the
following supervisor at the warehouse: Ray Scott, Tucson, Arizona. Plaintiff recalls the
following coworkers at the warehouse: Bill Heineche, Sr. (deceased); Bill Heineche, Jr.
(address unknown). Plaintiff currently contends that he was exposed to asbestos during this
employment.
Plaintiff worked out of Heat & Frost Insulators and Asbestos Workers Local Union

No. 16. Plaintiff recalls applying asbestos-containing insulation to pipes, pumps, flanges,
valves, duct work, plenums, boilers and vessels, Plaintiff cut the asbestos-containing pipe
insulation with a hand saw. Plaintiff mixed asbestos cement and applied cement to fittings and
irregular surfaces. Plaintiff worked in proximity to the following trades: Plumbers, pipefitters,
sheet metal workers, electricians, sprinkler fitters, carpenters, laborers, lathers and plasterers,
drywallers, floor installers and ceiling installers. Plaintiff worked in proximity to plumbers
disturbing existing insulation and fireproofing. Plaintiff worked in proximity to pipcfitters
working on pumps and valves, and working with asbestos-containing gaskets and packing.
Plaintiff worked in proximity to sheet metal workers disturbing existing asbestos-containing
fireproofing insulation and installing asbestos-containing flexible duct connectors. Plaintifi
worked in proximity to electricians stripping asbestos insulated wire and disturbing existing
asbestos-containing fireproofing and insulation. Plaintiff worked in proximity to sprinkler
fitters disturbing existing asbestos-containing fireproofing insulation. Plaintiff worked in
proximity to laborers performing general clean up, including sweeping up asbestos-containing
debris, which caused dust. Plaintiff worked in proximity to carpenters disturbing existing
asbestos-containing fireproofing insulation. Plaintiff worked in proximity to lathers and
plasterers mixing asbestos-containing plaster and disturbing existing fireproofing and
insulation, Plaintiff worked in proximity to drywallers cutting drywall, taping joints, and
mixing and sanding asbestos-containing joint compound, which was a dusty process. Plaintiff
worked in proximity to floor installers using a circular saw to cut floor tiles that contained
asbestos. Plaintiff worked in proximity to ceiling installers disturbing existing asbestos-

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

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

Job Duties: Plaintiff carried materials to journeyman insulators. Plaintiff recalls working with
JOHNS-MANVILLE (MANVILLE TRUST) block insulation. Plaintiffrecalls scoring and
cutting the block insulation with a handsaw, Plaintiff recalls mixing all-purpose cement and
using JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff currently
contends he was exposed to asbestos during this employment.

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

Job Duties: Plaintiff insulated pipes under the loading docks and in the pipe hangers Plaintiff
installed asbestos-containing insulation on pipes and on the boiler in the boiler room, Plaintiff
recalls boilers manufactured by the following: FOSTER WHEELER CORPORATION
(FOSTER WHEELER LLC (FKA FOSTER WHEELER CORPORATION)) and BABCOCK
& WILCOX COMPANY. Plaintiff recalls using UNIBESTOS (UNARCO) insulation and
magnesium. Plaintiff recalls working near pipefitters installing pipes and asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked near
the installation of a new BELL & GOSSETT (ITT INDUSTRIES, INC.) pump which had
original manufacturer’s asbestos-containing paskets wired to it. Plaintiff recalls the following
co-workers: Jack Kish (deceased); Rod Hochstrasser (deceased); Ed Fleigher (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

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

Menlo Park, CA

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

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Location of Exposure

Employer Exposure Job Title Dates

AC&S UC Berkeley (Central Insulator 1960-1962;

Lancaster, PA Steam Plant), 1965-1966
Berkeley, CA (1 week)

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
and PABCO (FIBREBOARD CORPORATION) block insulation, calcium silicate
pipecovering, blue cement and mag cement to a boiler, Plaintiff recalls working near other
trades, including, but not limited to: pipefitters, boiler makers, and laborers. Plaintiff worked
in proximity to boilermakers employed by Bay Cities Asbestos Co., Ltd., LTD. JAMES
WHITTAKER (RAYMOND INTERIOR SYSTEMS-NORTH) laborers mixed and sprayed
asbestos-containing CAFCO (UNITED STATES MINERAL PRODUCTS COMPANY)
fireproofing and swept dried fireproofing overspray in plaintiff's work areas. Electricians
disturbed overhead asbestos-containing MONOKOTE (W.R. GRACE & CO.) fireproofing
while setting their conduit supports. Plaintiff worked in proximity to others who were
checking, removing and replacing asbestos-containing original manufacturer’s packing in new
BELL & GOSSETT (ITT INDUSTRIES, INC.) pumps, Plaintiff recalls the following
manufacturers of asbestos products: PLANT ASBESTOS COMPANY {PLANT
INSULATION COMPANY). Plaintiff worked alongside pipefitters who were installing and
removing asbestos-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
and FLEXITALLIC, INC. gaskets. Plaintiff recalls that CAL-STEAM SUPPLY COMPANY
supplied asbestos-containing FLEXITALLIC, INC. gaskets. Plaintiff recalls that they special
ordered asbestos-containing pipe insulation from METALCLAD INSULATION
CORPORATION. WEBCOR BUILDERS laborers swept and shoveled asbestos-containing
PABCO (FIBERBOARD CORPORATION) and JOHNS MANVILLE (MANVILLE TRUST)
Thermobestos thermal insulation scraps and dust, Cafco (UNITED STATES MINERAL
PRODUCTS COMPANY) fireproofing dust, and scraps from asbestos-containing
FLEXITALLIC and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets
near plaintiff on a recurring basis. Plaintiff recalls the following foreman: Robert Cantley (c/o
BraytonPurcell LLP). Plaintiff recalls the following co-worker: Earl Beck (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Tidewater Associated Oil —_ Insulator 1959-1965

Avon, CA. (3 weeks)

Job Duties: Plaintiff applied asbestos-containing insulation to a large tank, Plaintiff applied
EAGLE-PICHER (EAGLE-PICHER INDUSTRIES, INC.) asbestos-containing cement on the
heads and fittings. Plaintiff applied EAGLE PICHER mineral wool. Plaintiff applied KAYLO
(OWENS CORNING FIBERGLAS) asbestos-containing insulation on pipes. Plaintiff recalls
using JOHNS-MANVILLE (MANVILLE TRUST) “Thermobestos” asbestos-containing
pipecovering, 85% magnesia cements, and 127 “blue mud.” Plaintiff applied CHILDERS (H &
C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks, adhered the blocks to the
arge tank, and “rasped off” the extruded CHILDERS {H&C INVESTMENT ASSOCIATES,
INC.) Fibrous Adhesive after it dried, using a metal rasp. Plaintiff recalls the following
contractors at this site: PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY) and Bay Cities Abestos Co., Ltd., TIDEWATER REFINERY (TEXACO, INC.)
aborers swept and shoveled asbestos-containing debris near plaintiff. Plaintiff recalls the
following foremen: Robert Robbins (deceased); and Allen Holbrook (deceased). Plaintiff
recalls the following co-workers: Lou Hanson (address unknown); Robert Robbins (deceased);
obert Sandoval (deceased); Ron Furia (deceased); and Laurance Hagen (c/o Brayton#Purcell
LLP). Plaintiff recalls the following employees of PLANT INSULATION COMPANY

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(PLANT INSULATION COMPANY): Ron Powers (c/o Brayton%Purcell LLP); Steve Steele
(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
Western Asbestos PG&E Powerhouse Insulator 1/1960-7/1960
3150 3" Street Pittsburg, CA

San Francisco, CA

Job Duties: Plaintiff worked on new construction. Plaintiff mixed asbestos-containing
insulating cement and scored asbestos blocks with a saw. Plaintiff used asbestos-containing
JOHNS-MANVILLE (MANVILLE TRUST) pipecovering, EAGLE PICHER cement and all-
purpose cement at this site. Plaintiff installed asbestos-containing insulation on equipment and
pipes. Plaintiff applied block insulation to two large heat exchangers and to three large tanks.
Plaintiff applied CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
to the blocks, adhered the blocks to the heat exchangers and tanks, and “rasped off” the
extruded CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive afier it
dried, via use of a metal rasp. Plaintiff worked near refractory workers from J.T. THORPE &
SON, INC. who were installing asbestos-containing block, cements and refractory materials in
the boilers. Plaintiff worked near boiler makers who he recalls were from J.T. THORPE &
SON, INC. Carl Ramsey (c/o Brayton#Purcell LLP) was a member of the J.T. THORPE &
SON, INC. crew. Plaintiff worked near welders using asbestos-containing welding blankets,
laborers sweeping up the site and pipefitters installing gaskets, valves and pipes. Thurman.
Gates (deceased) was plaintiff's supervisor. Plaintiff recalls the following co-workers: Charles
Purcell (deceased), Jack Kish (deceased); John Hoyt (c/o Brayton¢Purcell LLP); Donald Cox
(c/o Brayton*Purcell LLP); Ed Story (deceased); Charlie Power (deceased). Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Queen of the Valley Insulator 7/1960 (3 weeks)
3150 3" Street Hospital
San Francisco, CA Napa, CA

Job Duties: Plaintiff removed and replaced asbestos-containing ceiling tiles in order to install
insulation. Plaintiff recalls that some of the ceiling tiles would break when he tried to remove
them, causing a cloud of dust. Plaintiff insulated pipes in the boiler room with asbestos-
containing JOHNS-MANVILLE (MANVILLE TRUST) pipecovering and all purpose cement.
Plaintiff recalls the following co-worker: Jim White, Jr., Napa, California. Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Heat, Frost & Asbestos Maritime Union Insulator Approx. 1960
Workers Union Mission Street (1 day)
Local 16 San Francisco, CA

Job Duties: Plaintiff insulated domestic hot water pipes and ducts. Plaintiff used asbestos-
containing UNIBESTOS (UNARCO) pipecovering. Plaintiff recalls the following supervisor:
Richard Holmes (deceased). Plaintiff recalls the following co-workers: John Chulick (c/o
Brayton#Purcell LLP); Ron Furia (deceased); Charles Tol ‘bey (c/o Brayton*Purcell LLP);
Charlie Power (deceased); James Kearney, (deceased); Roger Fonken (c/o Brayton Purcell

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

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos McKinleyville High School Insulator 7/1961-10/1961;
3150 3" Street McKinleyville, CA 7/1962-5/1965
San Francisco, CA (34 weeks, on
and off)

Job Duties: Plaintiff worked at this site multiple times for about three and 4 weeks total during
the new construction of the high school. Plaintiff applied asbestos-containing JOHNS-
MANVILLE (MANVILLE TRUST) mag pipecovering and used all purpose cement for the
fittings. FRANK M. BOOTH and BRIZARD CONSTRUCTION pipefitters and shectmetal
workers disturbed previously sprayed asbestos-containing MONOKOTE (W.R. GRACE &
CO.) overhead fireproofing while setting pipe supports and duct supports in plaintiff's work
areas. pipefitters and plumbers employed by HAROLD BEASLEY PLUMBING AND
HEATING, INC. Plaintiff recalls contractor FRANK M. BOOTH personnel cut and installed
asbestos-containing flexible duct connectors next to plaintiff and his crew. CALIFORNIA.
DRYWALL tapers were sanding previously applied asbestos-containing taping compounds next
to plaintiff on approximately 20 or more occasions. Plaintiff recalls working near laborers
employed by FRANK M. BOOTH who performed clean-up and sweeping of asbestos-
containing drywall mud, fireproofing and insulation debris. . Plaintiff recalls the following co-
worker: Harold Smith (deceased), Plaintiff currently contends that he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Calaveras Cement Plant Insulator 1961-1965
3150 3" Street Redding, CA (1 month)

San Francisco, CA

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

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Tidewater Oil Company Insulator 1961-1962
3150 3" Street Avon, CA (Approx | month)

San Francisco, CA

Job Duties: Plaintiff recalls insulating pipes, a tank and vessels. Plaintiff used asbestos-
containing EAGLE PICHER cement, and asbestos-containing JOHNS MANVILLE
(MANVILLE TRUST) and KAYLO (OWENS CORNING FIBERGLAS) pipecovering and
block insulation. Plaintiff applied CHILDERS (H & C INVESTMENT ASSOCIATES, INC.)
Fibrous Adhesive to the blocks, applied the blocks to the tank, and “rasped off” the extruded
CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it dried, via

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use of a metal rasp. Plaintiff worked near laborers, were employed by PLANT
MAINTENANCE (PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping
existing asbestos-containing pipe insulation, sweeping up the site and carrying products to the
workers, TIDEWATER OIL (TEXACO, INC.) laborers were also sweeping and shoveling
asbestos-containing debris in plaintiff's presence at this site. TIMEC (TIMEC COMPANY,
INC.) workers were stripping asbestos-containing block insulation off the nearby coker, which
spread dust throughout plaintiff's work areas. PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY) personnel were applying asbestos-containing PABCO
(FIBREBOARD CORPORATION) caleium silicate pipecovering near plaintiff for
approximately 3 days. Plaintiff saw CROCKETT ELECTRIC electricians performing electrical
work in his work areas. Plaintiff worked alongside pipefitters who were installing and
removing asbestos-containing FLEXITALLIC, INC. gaskets. SLAKEY BROTHERS delivered
asbestos cement piping to this site on flatbed trucks. Plaintiff observed cutting and laying of
that asbestos cement piping for a few minutes. Plaintiff recalls the following co-workers:
Ronald A. Powers (c/o Brayton®Purceil LLP), Lou Hanson (address unknown); Robert
Robbins (deceased); Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

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

San Francisco, CA

Job Duties: Plaintiff worked on an addition to the plant. Plaintiff cut and installed calcium
silicate block insulation on a vessel using asbestos-containing CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to adhere the block. Plaintiff flat
troweled asbestos-containing EAGLE PICHER cement on the vessel. Plaintiff installed
asbestos-containing JOHNS-MANVILLE (MANVILLE TRUST) pipecovering. Plaintiffs co-
workers included Robert Robbins and Leo Hansen (both deceased). Plaintiff currently contends
that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Insulator 1961-1965
3150 3" Street Pittsburg, CA (3 months)

San Francisco, CA

Job Duties: Plaintiff recalls installing asbestos pads and asbestos-containing JOHNS-
MANVILLE (MANVILLE TRUST) insulation. Plaintiff recalls using asbestos-containing
EAGLE PICHER cement. Plaintiff applied CHILDERS (H & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive onto the blocks, and then adhered the blocks to the
boiler. After the CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
dried, plaintiff “rasped off” the material using a metal rasp, which spread dust throughout his
work areas. Plaintiff recalls J.T. THORPE & SON, INC. was the refractory contractor at this
jobsite. Plaintiff recalls that asbestos-containing materials supplied by WESTERN ASBESTOS
COMPANY and J.T. THORPE & SON, INC., were used at this worksite. Plaintiff recalls other
trades working on a BABCOCK & WILCOX boiler. Plaintiff worked near electricians
employed by CONTRA COSTA ELECTRIC, INC who were disturbing asbestos-containing
pipe insulation while installing conduit. Plaintiff recalls maintenance personnel from PG&E
were removing asbestos-containing materials from this boiler. Plaintiff recalls working near
pipefitters who were removing asbestos from pipes. Plaintiff also recalls other trades sweeping
the area where he was working. Plaintiff recalls the following co-workers: Earl Riggs
(deceased); Doyle Davidson (deceased); Ed Story (deceased); Ronald Furia (deceased); Jack

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Jagoda (c/o Paul & Hanley); Harry Fry (foreman) (deceased); Donald Cox (c/o Brayton¢Purcell
LLP); Derrell Cozby (c/o Brayton*-Purcell LLP). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Colgate Palmolive Insulator 7/1961-10/1961;
3150 3" Street Berkeley, CA. 7/1962-5/1965
San Francisco, CA (5 weeks, on and
off)

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE (MANVILLE TRUST)
pipecovering, and asbestos-containing EAGLE PICHER and 301 cement onto a tank. Plaintiff
used mag insulation, JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff
applied CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks,
placed the blocks onto the tank, and “rasped off” the extruded CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it dried, via use of a metal rasp.
Plaintiff recalls working near COLGATE PALMOLIVE laborers sweeping around his work
area. Plaintiff worked alongside PACIFIC MECHANICAL Company pipefitters who were
fabricating iron piping systems. Plaintiff recalls the following contractor: PACIFIC
MECHANICAL, Plaintiff observed L.J. KRUSE COMPANY pipefitters handling asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff
observed L.J. KRUSE repacking one new valve using asbestos-containing valve packing
material, Plaintiff recalls the following supervisor: Robert Robbins (deceased). Plainuff
recalls the following co-workers: Lowell Squires (deceased); Jim White, Jr. (Napa, California);
Lou Hansen (deceased): Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Gerber Foods Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 7/1962-5/1965
San Francisco, CA (3 weeks, on and
off)

Job Duties: Plaintiff wrapped asbestos-containing insulation with chicken wire and applied all-
purpose cement over it. Plaintiff applied asbestos-containing JOHNS MANVILLE
(MANVILLE TRUST) calcium silicate pipecovering and insulation cements. Plaintiff applied
JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff applied CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to block, applied the block to
irregular surfaces, and “rasped off” the extruded CHILDERS (H & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive after it dried, via use of a metal rasp. Plaintiff worked
near pipefitters installing pipes valves and asbestos-containing GARLOCK (GARLOCK
SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff recalls the following co-workers:
Bennie Norrie (deceased); Lou Hansen (deceased); Robert Robbins (deceased). Plaintiff
currently contends that he was exposed to asbestos during this employment.

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

San Francisco, CA

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Job Duties: Plaintiff worked in proximity to DOUGLASS INSULATION pipefitters who were
applying calcium silicate material. Pipefitters dismantled a chiller, removing asbestos-
containng GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff
observed pipefitters working on a pump, which involved replacement of asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff recalls the
following co-workers: Everett Waining (San Jose, California); Jim Kearney (deceased); Jim
White, Jr. (Napa, California). Plaintiff currently contends that he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Pacific Bell Telephone Insulator 1961-1965
3150 3" Street San Francisco, CA (3 months)

San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct wrap and asbestos-containing MUNDET
(CROWN CORK & SEAL COMPANY, INC.) 85% magnesia pipe insulation in an 8 story
building. Plaintiff worked in the boiler room where asbestos insulation was being removed and
installed Plaintiff worked near laborers who were sweeping the floors and pipefitters who were
installing and removing asbestos-containing GARLOCK (GARLOCK SEALING
TECHNOLOGIES, LLC) gaskets. Plaintiff worked in proximity to FOLEY ELECTRIC
electricians. Plaintiff observed FOLEY ELECTRIC personnel disturbing previously sprayed
asbestos-containing overhead fireproofing while setting supports for their electrical conduit in
plaintiff's work areas. Plaintiff recalls the following supervisor, John Straba (deceased),
Plaintiff recalls the following co-workers: Pancho (deceased), and Ron Powers (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
Western Asbestos G&E Insulator 1961-1965
3150 3" Street Antioch, CA (5-6 months)

San Francisco, CA

Job Duties: Plaintiff worked on new construction, Plaintiff delivered materials to this worksite.
Plaintiff appried insulation to piping, fittings and to a large boiler. Plaintiff installed asbestos-
containing block insulation with chicken wire over the top of it. Plaintiff used 352
CANADIAN BLUE asbestos shorts, 127 Blue Cement 85% magnesia cement and EAGLE
PICHER (EAGLE-PICHER INDUSTRIES, INC.) 66 cement. Plaintiff also applied asbestos-
containing PABCO (FIBREBOARD CORPORATION) and OWENS CORNING FIBERGLAS
asbestos pipe insulation to flanges on a boiler. Plaintiff recalls that the asbestos-containing
PABCO (FIBREBOARD CORPORATION) and OWENS CORNING (OWENS CORNING
FIBERGLAS) asbestos pipe insulation was supplied by PG&E. Plaintiff applied CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to blocks, applied the blocks
to the boiler, and “rasped off” the extruded CHILDERS (H & C INVESTMENT
ASSOCIATES, INC.) Fibrous Adhesive after it dried, via use of a metal rasp. Plaintiff recalls
general contractor C.C. MOORE (C.C. MOORE & CO. ENGINEERS) employing laborers.
Plaintiff recalls seeing others working on STOCKHAM (SVI CORPORATION) valves and
strainers which had asbestos-containing ANCHOR (COLTEC INDUSTRIES, INC.) packing on
them, Plaintiff recalls working near boilermakers, employed by BABCOCK & WILCOX who
were installing the boiler and near employees from J.T. THORPE & SON, INC. who were
installing the refractory materials inside the boiler, and working on turbines. Plaintiff recalls
working near electricians from CONTRA COSTA ELECTRIC who were disturbing asbestos
materials while walking on asbestos insulated piping, two to three feet from plaintiff. Plaintiff

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recalls working near insulators from OWENS CORNING FIBERGLAS. Plaintiff recalls the
following supervisor: Thurman Gates (deceased). Plaintiff recalls the following co-workers:
Ron Powers (c/o Brayton%Purcell LLP); Jim White, Jr. (Napa, California); Bill Armstrong
(deceased); Ronald Furia (deceased); John Hoyt (c/o Brayton¢Purcell LLP); Art Klimack c/o
Brayton®Purcell LLP; Al Leandro (c/o Brayton%Purcell LLP}; Walter Lee (c/o
Brayton#Purcell LLP); Derrell Cozby (c/o Brayton#Purcell LLP); Maurice Lawrence (c/o
Brayton%Purcell LLP); John Kiss (deceased), Paul Westbrook (c/o Brayton¢Purcell LLP); Carl
Ramsey (c/o Brayton*Purcell LLP); Dick Nelson (deceased). Plaintiff currently contends that
he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Hercules Powder Insulator 7/1961-10/1961;
3150 3" Street Hercules, CA 7/1962-5/1965
San Francisco, CA (1 month, on and
off)

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS) pipecovering.
Plaintiff applied foamglass insulation to piping. Plaintiff applied CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the foamglass, and later “rasped
off” the extruded CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive
after it dried, via use of a metal rasp. Plaintiff worked alongside pipefitters who were installing
and removing FLEXITALLIC, INC. gaskets in plaintiffs presence. Plaintiff worked in
proximity to METALCLAD INSULATION CORPORATION insulators who were applying
asbestos-containing thermal insulation. Plaintiff recalls the following supervisor: Lowell
Squires (deceased). Plaintiff recalls the following co-workers: Jim White, Jr. (Napa,
California); Lou Hanson (address unknown); Carl Ramsey (c/o Brayton¢Purcell LLP); Robert
Sandoval (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Georgia Pacific Insulator 7/1961-10/1961;
3150 3" Street Arcata, CA 7/1962-5/1965
San Francisco, CA (2-3 months, on
and off)

Job Duties: Plaintiff removed asbestos-containing PABCO (FIBREBOARD CORPORATION)
and JOHNS MANVILLE (MANVILLE TRUST) block insulation that was covered in 352
BLUE cement and black mastic from a large vessel at a particle board mill. Plaintiff applied
asbestos-containing JOHNS MANVILLE (MANVILLE TRUST) and PABCO (FIBREBOARD
CORPORATION) block to a tank. Plaintiff insulated a boiler and related pipes. Plaintiff
worked alongside GEORGIA PACIFIC maintenance personnel who were sweeping and
cleaning asbestos laden dust and debris from asbestos-containing block insulation. Plaintiff
recalls the following supervisor: Robert Evans (deceased). Plaintiff recalls the following co-
workers: Howard Johnson (deceased); Jim White, Jr., (Napa, California); Donald Cox (c/o
Brayton#Purcell LLP); Edward Meyer (c/o Brayton¢Purcell LLP); Charlie Power (deceased):
Myron Jorgenson (deceased): Charles Purcell (deceased); Earl Riggs (deceased), Doyle
Davidson (deceased); Harry Fry (deceased); Robert Evans, Ray House (deceased). Plaintiff
currently contends that he was exposed to asbestos during this employment.

dif

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Employer
Western Asbestos

3150 3" Street
San Francisco, CA

K Mnjured!19349'pld‘Al-supsac2.wpd

Exposure
Dates

7/1961-10/1961;
7/1962-5/1965

Location of
Exposure

Bethlehem Steel
Shipbuilding
San Francisco, CA

Job Title

Insulator

Triple A Machine Shop
(Pier 64)
San Francisco, CA

(on and off for
approx. 1 week
each time)

Willamette Shipyard
Richmond, CA

Pacific Ship Repair
(Pier 36)
San Francisco, CA

Todd Shipyard
Oakland, CA

Matson Navigation
(Pier 30)
San Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH P. KENNEDY
IR.
(DD-850)

CHEYENNE
T-AG-174)

HAWAIIAN PLANTER
(1945)

GRAFFIAS
(AF29)

MATHEWS
(AKA-96)

MERRICK
(AKA-97)

TWINING
(DD-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY
(1932

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Location of Exposure
Employer Exposure Job Title Dates

Western Asbestos BLAND
(contd.) (APA-134)

PONTCHARTRAIN
(WPG-70y

CALIFORNIAN
(aes

AMERICAN ROBIN 1963-1965
(7923)

ROSE KNOT
5

HAWAIIAN
(T1946)

Job Duties: Plaintiff insulated pipes, turbines, valves, and boilers using asbestos-containing
JOHNS MANVILLE (MANVILLE TRUST) and PABCO (FIBREBOARD CORPORATION)
block and pipecovering. Plaintiff removed and repaired asbestos-containing insulation.
Plaintiff used asbestos cloth to wrap around valves and boilers, Plaintiff recalls using EAGLE
PICHER cements and 352 Blue Mud cement. Plaintiff worked near pipefitters who were
removing asbestos-containing insulation and who were installing pipes, asbestos-containing
gaskets, valves and pumps. Plaintiff recalls pipefitters in his work area installing asbestas-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets and cutting
gaskets from sheet gasket material. Plaintiff recalls welders using asbestos cloth during the
course of their work. Plaintiff worked near the FOSTER WHEELER (FOSTER WHEELER
LLC (FKA FOSTER WHEELER CORPORATION)) boilers aboard the HAWAIAN
PLANTER, the GRAFFIAS, the MATHEWS, the MERRICK, the GENERAL W.A. MANN,
the MONTEREY and the ROSE KNOT. Plaintiff observed other workers installing and
removing asbestos-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
and/or FLEXITALLIC, INC. gaskets aboard several of these ships. Plaintiff observed shipyard
personnel including TRIPLE A personnel who were tearing off asbestos-containing thermal
insulation and who were sweeping and cleaning asbestos-containing debris in plaintiff's
presence. Plaintiff recalls the following coworkers: Tom Andrews (c/o Brayton#Purcell LLP);
Joseph O’Balle (c/o Brayton#Purcell LLP); Jack Barbera (address unknown); Gene Bennett,
Vacaville, California; Rudolph Brajkovick (deceased); John Byron (address unknown); Robert
Evans (deceased); Harry Fry (deceased}; Ronald Furia (deceased); Thurman Gates (deceased);
Victor Gomez (c/o Brayton%Purcell LLP); Bill Green, Sr. (deceased); Bill Green, Jr,
(deceased); Ronald Grist, Newark, California: Bill Heinicke (deceased); Frank Howard
(deceased); John Jagoda, Martinez, California: Myron Jorgensen (address unknown); Harvey
Jorgensen (address unknown); James Logue (c/o Brayion*Purcell LLP); Tony Lopes, Fremont,
California; Andy Grant (address unknown); Richard Porter (address unknown); Joseph
Sandoval (deceased); Robert Sandoval (deceased); William Stein (address unknown); Ed Story
(deceased); Fred Strickland (deceased); Howard Tracy (deceased); Jack Kish (deceased): Paul
Schiebold (San Francisco, California); Dale Wright (Santa Rosa, California); Andy Grant
(address unknown); Lowell Squires (deceased); Jim White, Jr. (Napa, California); Benjamin
Norrie (deceased), Plaintiff currently contends that he was exposed to asbestos during this
employment.

dif

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Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos Grace Cathedral Insulator 7/1961-10/1961;

3150 3" Street San Francisco, CA 7/1962-5/1965

San Francisco, CA @ oss on and
©

Job Duties: Plaintiff worked in a crawl space under the building and had to drag equipment to
the plumbing pipes that he was insulating. Plaintiffrecalls that the area was dusty and that his
clothes and skin were covered with dust. Plaintiff used asbestos-containing PABCO
(FIBREBOARD CORPORATION} cal sil pipe insulation, FOSTERS (BAYER
CROPSCIENCE INC.) 30-36 mastic and JOHNS-MANVILLE (MANVILLE TRUST) 301
cement. Plaintiff recalls the following foreman: Paul Schiebold (San Francisco, California).
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Western Asbestos Pad Insulator 7/1961-10/1961;
3150 3" Street Shop, 3% Avenue and 7/1962-5/1965
San Francisco, CA Army, San Francisco, CA (2 -3 days, on and
off)

Job Duties: Plaintiff made asbestos pads to be installed on ships. Plaintiff recalls the following
supervisor: Bill Green, Sr. (deceased). Plaintiff recalls the following co-worker: Leo Hughes
(deceased); Jorgy Jorgensen (deceased); Paul Schiebold (San Francisco, California). Plaintiff
currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Nuclear Powerhouse Insulator 7/1961-10/1961;
3150 3" Street Humboldt County 7/1962-12/1962
San Francisco, CA Eureka, CA. (5 months, on and
off)

Job Duties: Plaintiff carried asbestos-containing materials to co-workers. Plaintiff applied
asbestos-containing mag blocks and pipecovering to pipes valves and vessels. Plaintiff installed
352 cement and FOSTER’s (BAYER CROPSCIENCE INC.) and CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive. Plaintiff applied the FOSTER’s
(BAYER CROPSCIENCE INC.) and CHILDERS (H & C INVESTMENT ASSOCIATES,
INC.) Fibrous Adhesive to blocks, applied the blocks to the reactor top, and “rasped off” the
extruded, dried FOSTER’s (BAYER CROPSCIENCE INC.) and CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesives using a metal rasp, which spread dust
throughout plaintiff's work areas. Plaintiff used asbestos-containing JOHNS-MANVILLE
MANVILLE TRUST), UNIBESTOS (UNARCO until June 1962; PITTSBURGH CORNING
CORPORATION from July 1962), PABCO (FIBREBOARD CORPORATION) and 48
insulation. Plaintiff recalls the following foreman: Ed Story (deceased). Plaintiff recalls the
following co-workers: Harry Fry (deceased); Donald Cox (c/o Brayton¢*Purcell LLP); Ronald
Furia (deceased); Howard Johnson (deceased); Charles Tobey (c/o Brayton¢Purcell LLP);
Doyle Davidson (deceased); Earl Riggs (deceased); Richard Gross (deceased), Plaintiff
currently contends that he was exposed to asbestos during this employment.

dif

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Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos PG&E Insulator 7/1961-10/1961;

3150 3” Street San Francisco, CA 7/1962-5/1965

San Francisco, CA (Potrero Station) (2 to 3 weeks, on
and off)

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

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Dow Chemical Insulator 7/1961-10/1961;
3150 3" Street Pittsburg, CA. 7/1962-5/1965
San Francisco, CA (1 month, on and
off)

Job Duties: Plaintiff carried materials to the journeymen. Plaintiff applied KAYLO (OWENS
CORNING FIBERGLAS) asbestos blocks, PABCO (FIBREBOARD CORPORATION)
cement and 352 BLUE cement to a large tank. Plaintiff applied CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the blocks, adhered the blocks to
the tank, and “rasped off” the extruded CHILDERS (H & C INVESTMENT ASSOCIATES,
INC.) Fibrous Adhesive after it dried, via use of a metal rasp. Plaintiff recalls working near
pipefitters installing pipes, valves, pumps and FLEXITALLIC, INC. gaskets. Plaintiff recalls
the following foreman: Robert Robbins (deceased). Plaintiff recalls the following co-workers:
Lou Hansen (deceased); Robert Sandoval (deceased); Charles Tobey (c/o Brayton¢-Purcell
LLP); Earl Riggs (deceased); Doyle Davidson (deceased). Plaintiff currently contends that he
was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Shell Oil Insulator 7/1961-10/1961;
3150 3" Street Martinez, CA 7/1962-5/1965
San Francisco, CA (6 weeks, on and
off)

Job Duties: Plaintiff cut asbestos block insulation and mixed and applied insulating cement.
Plaintiff worked with ashestos-containing insulating products manufactured by JOHNS-
MANVILLE (MANVILLE TRUST), and with KAYLO (OWENS CORNING FIBERGLAS) .
Plaintiff worked next to PLANT ASBESTOS (PLANT INSULATION COMPANY) insulators
who applied CHILDERS (H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to
block insulation, adhered the blocks to a tank, and “rasped off” the dried, extruded CHILDERS
(H & C INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive before applying a finish,
which caused visible dust to spread throughout plaintifP's work area. Plaintiff recalls working
near pipefitters from FOLEY-PMI installing pipes, new LUNKENHEIMER valves, pumps and
asbestos-containing DURABLA (DURABLA MANUFACTURING COMPANY, INC.)

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gaskets. Plaintiff also observed FOLEY-PMI pipefitters removing existing DURABLA flange
gaskets in his presence, on approximately 4 to 20 occasions. PLANT ASBESTOS COMPANY
(PLANT INSULATION COMPANY) supplied asbestos-containing insulation materials,
including PABCO (FIBREBOARD CORPORATION) pipe-covering to the site. Laborers
employed by general contractor ALBAY CONSTRUCTION swept and shoveled asbestos-
containing JOHNS MANVILLE (MANVILLE TRUST) Thermobestos block insulation debris,
asbestos-containing insulation cement debris and dust, and debris created by sawing of 85%
magnesia pipe covering. Plaintiff recalls the following foreman: Robert Robbins (deceased).
Plaintiff recalls the following co-workers: Lou Hansen (deceased); Jim White, Jr. (deceased );
Charles Tobey (c/o Brayton%Purcell LLP); Robert Sandoval (deceased); Ed Meyer (c/a
Brayton Purcell LLP); Hank Meyers (address unknown). Plaintiff currently contends that he
was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Insulator 7/1961-10/1961;
3150 3° Street Oakland, CA 7/1962- 12/1962
San Francisco, CA (2 weeks, on and
off}

Job Duties: Plaintiff removed asbestos block insulation and existing insulation on a boiler.
Plaintiff mixed asbestos cement in a trough with a hoe. Plaintiff installed asbestos-containing
PABCO (FIBREBOARD CORPORATION) cement. Plaintiff recalls working near
boilermakers, and near pipefitters who were installing gaskets. Plaintiff observed PG&E
laborers sweeping and cleaning asbestos laden dust and debris in plaintiff's work areas.
Plaintiff recalls the following supervisor: Benjamin Norrie (deceased). Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Vallecitos Atomic Insulator 7/1961-10/1961;
3150 3" Street Laboratory 7/1962-5/1965
San Francisco, CA Pleasanton, CA (2 weeks, on and
off)

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
block insulation, KAYLO (OWENS CORNING FIBERGLAS) pipecovering, 352 cement,
EAGLE-PICHER INDUSTRIES, INC. 66 mud, and new LUNKENHEIMER COMPANY
valves, while insulating a boiler and associated piping. Plaintiff applied CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive to the blocks, adhered the blocks to
the boiler and to irregular surfaces, and “rasped off” the extruded CHILDERS (H & C
INVESTMENT ASSOCIATES, INC.) Fibrous Adhesive after it had dried, via use of a metal
rasp. Plaintiff had to crawl into tight areas that contained loose asbestos insulation. Plaintiff
worked near pipefitters installing pipes, valves, and asbestos-containing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) and FLEXITALLIC, INC. gaskets.
Pipefitters also were cutting and installing packing into LUNKENHEIMER valves. Plaintiff
recalls the following supervisor: Benjamin Norrie (deceased). Plaintiff recalls the following
co-workers: Lou Hansen (deceased); Robert Sandoval (deceased); Ed Meyer (c/o
Brayton#Purcell LLP). Plaintiff currently contends that he was exposed to asbestos during this
employment.

if

dif

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Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos Missile Base Insulator 7/1961-10/1961;

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

San Francisco, CA u. som on and
o

Job Duties: Plaintiff applied rubber insulation and 520 mastic. Plaintiff worked near other
tradesmen who installed asbestos-containing ANCHOR (COLTEC INDUSTRIES, INC.)
packing, and asbestos-containing DURABLA (DURABLA MANUFACTURING COMPANY,
INC.) gaskets. Plaintiff observed workers removing existing DURABLA gaskets on numerous
occasions in his presence, Plaintiff worked near welders who were using asbestos blankets.
Plaintiff worked near electricians and near pipefitters who were installing pipes, asbestos-
containing DURABLA (DURABLA MANUFACTURING COMPANY, INC.) gaskets, and
pumps. Laborers built scaffolds and swept asbestos-containing PABCO (FIBREBOARD
CORPORATION) insulation debris, created by PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY), in plaintiff's work areas. PLANT ASBESTOS COMPANY
(PLANT INSULATION COMPANY) employed another insulation crew that was applying
asbestos-containing PABCO (FIBREBOARD CORPORATION) pipe insulation 5 to 30 feet
from plaintiff. Plaintiff recalls the following supervisor: Jim Clark (address unknown).
Plaintiff recalls the following co-workers: Donald Cox (c/o Brayton#Purcell LLP); Dale
Wright (Santa Rosa, California); Tiny Evans (deceased); Paul Brown (c/o BraytonPurcell
LLP). Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos University of California Insulator 7/1961-10/1961;
3150 3" Street Berkeley, CA 7/1962-5/1965
San Fra