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 “C -D” 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 “C: -D" 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 C222 RUSH LANDING ROAD
POBOX6169
NOVATO, CALIFORNIA 94948-6169

BRAYTON@PURCELL LLP
ATTORNEYS ATLAW

(415) 898-1555

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BHURRRPSERES

ALAN R. BRAYTON, ESQ,, 8.B. #73685
ERIC C. SOLOMON, ESQ,, 8.B, #119131

BRAYTONPURCELL LLP “ofaM |
Attorneys at Law ,
222 Rush Landing Road
P.O. Box 6169
Novato, California 94948-6169
(415) 898-1555
Attorneys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ROBERT ROSS and JEAN ROSS, ) ASBESTOS
No. = CGC-10-275731
Plaintiffs, }

} ANSWERS TO INTERROGATORIES
¥S.

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

4
PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NO: TWO

1, AL General Mills,

B. Vallejo, California.

Cc. 1952 to January 1954; and February to June 1956. Plaintiff currently
cannot be more specific as to the start date, end date and total number of days. Plaintiff's
investigation and discovery are continuing, .

General Mills Company, Post Office Box 1113, Minneapolis, Minnesota.

E. Warehouseman.

F. Plaintiff worked in the feed mill. Plaintiff swept floors.

G. See Exhibit No. 1, attached.

2, See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A.-B. Fort Ord, Monterey, California; and United States Army, Okinawa, Japan.
C. February 9, 1954 to January 27, 1956. Plaintiff currently cannot be more
specific as to the start date, end date and total number of days. Plaintiff's investigation and
iscovery are continuing.
B United States Army.
E. Infantryman.

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b. Please see response to Interrogatory No. 1F, above.

c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust.

IL. Yes.

a. Please refer to Interrogatory No. 1F, above.

b. Plaintiff recalls working near asbestos-containing
MONOKOTE fireproofing on the beams that had been disturbed by various trades, Plaintiff
recalls working near laborers who were sweeping up MONOKOTE-containing debris. Plaintiff
currently cannot identify the manufacturer of each asbestos-containing product. Plaintiff may
have been in close proximity to asbestos-containing products not known to him at this time.
Plaintiff's investigation and discovery are continuing.

c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recails working in close proximity to ACCO MECHANICAL (ACCO|
ENGINEERED SYSTEMS, INC.) laborers. Plaintiff's investigation and discovery are
continuing.

d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials. Plaintiff's investigation and discovery are continuing.

e.(i-ii) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

f.-h. Plaintiff does not recall any safety precautions to protect
him from breathing dust.

. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1, A. State Compensation Building.

B. San Francisco, California.

Cc. 1967 to 1972; and 1977 to 1979 (6 weeks, off and on). Plaintiff currently
cannot be more specific as to the start date, end date and total number of days. Plaintiffs
investigation and discovery are continuing.

Dd. Consolidated Insulation, 517-D Marine View Avenue, Belmont,

California.
Insulator.
F. Plaintiff insulated pipes and ducts.
G. Yes.
1. Plaintiff recalls working in various areas.
2. Please see response to Interrogatory No. 1C, above.
3. Plaintiff recalls the following supervisor: Robert Cantley, c/o
Brayton #% Purcell LLP.
4, See Exhibit No. 3, attached.

5. See Exhibit No. 4, attached.

6. Plaintiff recalls the following contractors: JAMES NELSON, and
insulation contractors PARKER INSULATION COMPANY and PHILIP CAREY
CORPORATION.

7. See Exhibit No. 6, attached.

8.-9. See Exhibit No. 7, attached.

10. Yes.

a Plaintiff insulated pipes and ducts. Plaintiff currently
cannot identify the manufacturer of each asbestos-containing product. Plaintiff performed his
work indoors. Plaintiff's investigation and discovery are continuing.

Db. Please see response to Interrogatory No. IF, above.

c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust.

ll. Yes.

a. Please refer to Interrogatory No. 1F, above.

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b. Plaintiff worked near plumbers and pipefitters installing
pipes, gaskets and valves. Plaintiff recalls that fireproofing was being disturbed by electricians,
controls men, and sheet metal workers. Plaintiff worked near laborers sweeping up debris.
Plaintiff worked near insulators while they used products manufactured by M ET CORK
CORPORATION, Plaintiff currently cannot identify the manufacturer of each asbestos-
containing product. Plaintiff may have been in close proximity to asbestos-containing products
not known to him at this time. Plaintiff's investigation and discovery are continuing.

c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to plumbers and pipefitters.
Plaintiff worked near employees of the following contractors: JAMES NELSON, and insulation
contractors PARKER INSU ATION COMPANY and PHILIP CAREY CORPORATION.
Plaintiff worked near insulators employed by PHILIP CAREY. Plaintiff's investigation and
discovery are continuing.

d. Plaintiff worked near plumbers and pipefitters installing
pipes, gaskets and valves. Plaintiff recalls that fireproofing was being disturbed by electricians,
controls men, and sheet metal workers. Plaintiff worked near laborers sweeping up debris.
Plaintiff, at this time, does not recall the specific manner in which each trade used the asbestos-
containing materials. Plaintiff's investigation and discovery are continuing.

¢.(i-ii) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

f.-h, Plaintiff does not recall any safety precautions to protect
him from breathing dust.

. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A. Alameda County Administration Building.

B. Oak Street, Oakland, California.

c, 1967 to 1972; and 1977 to 1979 (2 weeks). Plaintiff currently cannot be
more specific as to the start date, end date and total number of days. Plaintiff's investigation and
discovery are continuing.

. Consolidated Insulation, 517-D Marine View Avenue, Belmont,

California.
E. Insulator.
FE, Plaintiff applied pipecovering and duct wrap.
G. Yes.
1. Plaintiff recalls working in various areas.
2. Please see response to Interrogatory No. 1C, above.
3, Plaintiff recalls the following supervisor: Dick Saiya, Belmont,
California.
4. Plaintiff recalls the following co-workers: Robert Cantley, c/o
Brayton%*Purcell LLP.

5. See Exhibit No. 4, attached.

6. Plaintiff recalls contractors at this worksite were: NATKIN &
CO., and ALADDIN HEATING.

7. See Exhibit No. 6, attached,

8-9. See Exhibit No. 7, attached.

10. Yes. .

a Plaintiff applied pipecovering. Plaintiff currently cannot
identify the manufacturer of each asbestos-containing product. Plaintiff recalls asbestos-
containing materials were supplied by WESTERN ASBESTOS COMPANY and MacARTHUR,
Plaintiff performed his work indoors. Plaintiff's investigation and discovery are continuing.

b. Please see response to Interrogatory No. IF, above.
c-e. Plaintiff does not recall any safety precautions to protect
him from breathing dust. y
1, es.

KAnjured9349(pld\ai-saesf 2. wpd 76EXHIBIT DBRAYTON¢@PURCELL LLP

ATTORNEYS AT LAW

222 RUSH LANDING ROAD
PO BOX 6169

NOVATO, CALIFORNIA 94948-6169

(415) 898-1555

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ALAN R. BRAYTON, ESQ, S.B. #73685
ERIC C. SOLOMON, ESQ., S.B. #119131
BRAYTON“#PURCELL LLP

Attorneys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948.

(415) 898-1555

Attorneys 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 1
attached te the Sum: Complaint
herein; and DOES 1-8500.

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NOS.: ONE and TWO
Plaintiff supplements/amends his Responses to Standard Asbestos Case Interrogatories,

Set One, No. 26, and Set Two, Nos. | through 3, as follows:
SUPPLEMENTAL/AMENDED RESPONSE: Plaintiff incorporates by reference as though
fully set forth herein, all work history jobsites and co-workers and related information identified
in the attached Exhibit A, and plaintiff references and incorporates herein all Defendant
Specific and Special Interrogatory Responses to follow in this case.
BRAYTON®PURCE
By: a4

Attorneys for Plaintiffs

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EXHIBIT A

Robert Ross and Jean Ross v. CC, 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 219/54-L/27/56
Monterey, CA;
United States Army
Okinawa, Japan
Job Duties: Plaintiff served in the United States Army as an infani . Plaintiff served at

Fort Ord, Monterey, California, for 16 weeks, and the remainder of his time in Okinawa, Japan.
Plaintiff perfo: maneuvers and combat exercises. Plaintiff is currently unaware if he was
exposed to asbestos during this employment.

Location of . Exposure
Employer Exposure dob 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
Emplover 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;
Cincinnati, OH 101 Williams 12/1959-1/1960
San Francisco, CA (1 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, JOHNS-MANVILLE,
OWENS CORNING KAYLO, UNIBESTOS (UNARCO), EAGLE PICHER (EAGLE-PICHER
INDUSTRIES, INC.), CELOTEX, 85% MAG cement, 301 and 352 JOHNS MANVILLE
insulating cement. Plaintiff recalls that the jobsite was very dusty and that his clothes would get
covered in dust. Plaintiff also delivered materials to various jobsites on approximately 10
occasions. Plaintiff delivered materials to the Jack Tar Hotel in San Francisco, California.
CAHILL CONSTRUCTION was the general contractor which employed laborers and cement
finishers at the site. Plaintiff observed CAHILL CONSTRUCTION laborers sweeping debris
created by cutting of PHILIP CAREY asbestos-containing pipe insulation and created by cutting
of GARLOCK flange gaskets. ANDERSON, ROWE & ‘KLEY, INC. employed plumbers,
pipefitters and sheetmetal workers at the Jack Tar Hotel. Plaintiff recalls Phili 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: Biil
Heineche, Sr. (deceased); Bill Heineche, Jr. (address unknown). Plaintiff currently contends
that he was sed te 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 asbestes cement and applied cement to itings 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 pipefitters
workin; ng on pumps and valves, and working with asbestos-containing gaskets and packing.
Plaintiff worked in proximity to sheet workers disturbing existing asbestos-containin;
fireproofing insulation and installing asbestos-containing flexible duct connectors. Plainti
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 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 contained
asbestos. Plaintiff worked in proximity to ceiling installers disturbing existing asbestos-
containing fireproofing insulation. Plaintiff cut asbestos-containing insulation with a power
saw and applied asbestos-containing canvas and asbestos cloth. Plaintiff currently contends that
he was exposed to asbestos during this employment.

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3 | Emplover Exposure Job Title Dates
|| Coast Insulating Products Fertilizer Plant Insulator 8/1959-9/1959
3 || Los Angeles, CA Helm, CA (Apprentice) (approx. 5 wks)
4l Job Duties: Plaintiff carried materials to jor insulators. Plaintiff recalls working with
| JOHNS-MANVILLE block insulation. Plaintiff recalls scoring and cutting the block insulation
5 || with a handsaw. Plaintiff recalls mixing all-purpose cement and using JOHNS MANVILLE
| 352 BLUE cement. Plaintiff currently contends he was exposed to asbestos during this
6], employment.
7h - Location of Exposure
8
| Universal Insulation Mare Island Naval Insulater 1959 (on and off
9]| 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,
led asbestos-containing insulation on pipes and on the boiler in the boiler room. Plaintiff

recalls boilers manufsotured by the following: FOSTER WHEELER CORPORATION and

BABCOCK & WILCOX COMPANY. Plaintiff recalls using UNIBESTOS insulation and

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GA K (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked wear

i
installation of a new BELL & GOSSETT (ITT INDU . INC.) pump which had

14] original manufacturer's asbestos-containing gaskets wired to it, Plaintiff recalls the following

co-workers: Jack Kish (deceased); Rod Hochstrasser (deceased); Ed Fleigher (deceased).
15] Plaintiff currently contends that he was exposed to asbestos during this employment.
16 Location of Exposure
W Employer Exposure Job Title Dates

Universal Insulation Hewlett Packard Insulator 1959 (1-2 weeks)
18 |] 520 6" Avenue Menlo Park, CA (Apprentice)
19 Menlo Park, CA

|| Job Duties: Plaintiff installed asbestos-containing insulation and all- cement on the

20
21

fittings. Plaintiff installed asbestos-containing PABCO (FIBREBO CORPORATION)
insulation and EAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.) insulation cement on
Ri s. 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),

| exposed to asbestos during this employment.

24]
| Location of Exposure
25 || Employer Exposure Job Title Dates
26] AC&S UC Berkeley (Central Insulator 1960-1962;
PA Steam Plant, 1965-1966
27 Berkeley, CA (i week)

28 | Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
and PABCO (FIBREBOARD CORPORATION) block insulation, calcium silicate

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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 Proxim to boilermakers employed by Bay Cities Asbestos Co., Ltd., LTD. JAMES
WHITTAKER laborers mixed and sprayed asbestos-containing CAFCO (UNITED STATES
MINERAL PRODUCTS COMP. fireproofing and swept dried fireproofing overspray in
plaintiffs work areas. Electricians disturbed overhead asbestos-containing MONOKOTE (W.R.
RACE & CO.) fireproofing while setting their conduit supports. Plaintiff worked in
proximity to others who were checking, femoving and lacing asbestos-containing original
manufacturer’s packing in new BELL & GOSSE a INDUSTRIES, INC) pam
Plaintiff recalls the following manufacturers of asbestos products: PLANT ASBESTOS
COMPANY (PLANT INSULATION COMPAN’ ¥) Plaintiff worked alongside bipefitters 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 asbosios-containing pi ¢ insulation from
METALCLAD INSULATION CORPORATION. WEBCOR BUILDERS laborers swept and
shoveled asbestos-containing PABCO (FIBERBOARD CORPORATION) and JOHNS
MANVILLE Thermobestos thermal insulation scraps and dust, Cafco fireproofing dust, and
soraps from asbestos-containing FLEXITALLIC and GARLOCK gaskets near plaintiff on a
recurring basis. Plaintiff recalls the following foreman: Robert Cantley (c/o Brayton*+Purcell
LLP). Plaintiff recalls the following co-worker: Earl Beck (deceased). Plaintiff currently

contends that he was exposed to s 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 INDUS’ S, INC.) asbestos-containing cement on the
heads and fittings. Plaintiff applied EAGLE PICHER mineral wool. Plaintiff applied KAYLO
(OWENS CORNING FIBER! ) asbestos-containing insulation on pipes. Plaintiff recalls
using JOHNS-MANVILLE “Thermobestos” asbestos-containing pipecovering, 85% magnesia
cements, and 127 “blue mud.” Plaintiff applied CHILDERS (H&C IN VESTMENT
COMPANY) Fibrous Adhesive to blocks, adhered the blocks to the large tank, and “rasped off”
the extruded CHILDERS Fibrous Adhesive after it dried, using a metal Fasp. Maintift recalls
the following contractors at this site: PLANT ASBESTOS COMPANY qi
INSULATION COMPANY) and BAY CITIES ASBESTOS CO., LTD., TIDEWATER
REFINERY (TEXACO, INC.) laborers swept and shoveled asbestos-containing debris near
plaintiff Plaintiff recalls the following foremen: Robert Robbins (deceased); and Allen
lolbrook (deceased). Plaintiff recalls the following co-workers: Lou Hanson (address
unknown); Robert Robbins (deceased); Robert Sandoval (deceased); Ron Furia (deceased); and
Laurance Hagen (c/o Brayton¢+Purcell LLP). Plaintiff recalls the following employees of
PLANT INSULATION ‘COMPANY (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

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

insulating cement and scored asbestos blocks with a saw. Plaintiff used asbestos-containin;

JOHNS- ILEE 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 ex ers and to three large tanks. Plaintiff applied

| CHILDERS (H&C INV! ENT COMPANY) Fibrous Adhesive to the blocks, adhered the

blocks to the heat exchangers and tanks, and “rasped off” the extruded CHILDERS Fibrous

Adhesive after it dried, via use of a metal rasp. Plaintiff worked near refractory workers from

J.T. THORPE & SON, INC. who were installing asbestos-containing block, cements and

refractory materials in the boilers. Plaintiff worked near boiler makers who he recalls were

from J.T, THORPE & SON, INC. Carl Ramsey (c/o Brayton®Purcell LLP) was a member of

| the J.T. THORPE & SON, INC. crew. Plaintiff worked near welders using asbestos-containing

| welding blankets, laborers sweeping up the site and pipefitters installing gaskets, valves and

| pipes. Thurman Gates ( ) was plaintiff's supervisor. Plaintiff recalls the following co-

i workers: Charies 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 asbestes-
containing JOHNS-MANVILLE pipecovering and all purpose cement, Plaintiff recalls the
following co-worker: Jim White, oP Napa, California, Plaintiff currently contends that he was
| exposed to asbestos during this employment.

Location of . Exposure
|| Employer Exposure Job.Tithe Dates
Heat, Frost & Asbestos Maritime Union Insulator Approx. 1960
Workers Union Mission Street Ci 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: Jobn Chulick (c/o

| Brayton%Purcell LLP); Ron Furia (deceased); Charles Tobey {clo Brayton’Purcell LLP);
Charlie Power (deceased), James Keamey, (deceased); Roger Fonken (c/o Brayton¢ Purcell

| 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 F/1961-1L0/1961;
| 3150 3 Street McKinleyville, CA 7N1962-S11965
San Francisco, CA GB G ieeks. on
and o!

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15
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18
19
20
2
2
23
24
25
26
27
28

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 mag pipecovering and used all purpose cement for the fittings. FRANK M.
BOOTH and BRIZA CONSTRUCTION pipefitters and sheetmetal workers disturbed

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

reproofing while Setting pi e supports and duct supports in plaintiffs work areas. pi fitters
and plumbers employed by HAROLD BEASLEY PLUMBING AND HEATING, ice
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 1
mud, fireproofing and insulation debris, . Plaintiff recalls the following co-worker: Id
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 pipefitiers
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 Ripas (deceased); Hank Meyers (deceased); Donald Cox (c/o Brayton®Purcell LLP):
Richi ross (deceased). Plaintiff currently contends that he was exposed to asbestos during
this employment.

Location of Exposure

Employer Exposure = “si tssti‘i«itéS Title

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 and |
KAYLO (OWENS CORNING FIBERGLAS) ipecovering and block insulation. Plaintiff
applied CHILDERS (H&C INVESTMENT OMPANY) ibrous Adhesive to the blocks,
applied the blocks to the tank, and “rasped off” the extruded CHILDERS Fibrous Adhesive

er it dried, via use of a metal rasp. Plaintiff worked near laborers, were employed by PLANT
MAINTENANCE (PLANT NANCE, INC. OF CALIFORNIA) who were stripping
existing asbestos containing pipe insulation, sweeping up the site and carrying products to
workers. TIDEWATER OIL laborers were also sweeping and shoveling asbestos-containing
debris in plaintiff's presence at this site. TIMEC workers were stripping asbestos-containing
block insulation off the nearby coker, which spread dust throughout plaintiff's work areas.
PLANT ASBESTOS COMPANY LAN INSULATION COMPANY) personnel were
applying asbestos-containing PABCO (FIBREBOARD CORPORATION} calcium silicate
pipecovering near plaintiff for approximately 3 days. Plaintiff saw CROCKETT ELECTRIC
electricians performing electrical work in his work areas. Plaintiff worked alongside pipefitters
who were installing and removing asbestos-containing FLEXITALLIC, ING. gaskets. .
SLAKEY BROTHERS delivered asbestos cement piping to this site on flatbed trucks. Plaintiff

KAlnjureds19349\pldAT-Supsac.wpd 7 ECSobserved cutting and laying of that asbestos cement piping for a few minutes. Plaintiff recalls
the following co-workers: Ronald A. Powers (c/o Brayton>Purcell LLP), Lou Hanson (address

unknown); Robert Robbins (deceased); Robert Sandoval (deceased). Plaintiff currently
contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Monsanto Chemical Insulator 1961-65 (Approx
3150 4 Street Avon, CA 1 eee Pro
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 Fibrous Adhesive to
adhere the block. Plaintiff flat troweled asbestos-containin, SAGLE PICHER cement on the
vessel. Plaintiff installed asbestos-containing JOHNS-! ILLE pipecovering. Plaintiff's
co-workers included Robert Robbins and Leo Hansen (both deceased). Plaintiff curently
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 insulation. Plaintiff recalls using asbestos-containing EAGLE PICHER cement,
Plaintiff applied CHILDERS (H&C INVESTMENT COMPANY) Fibrous Adhesive onto the
blocks, and then adhered the blocks to the boiler. After the CHILDERS 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-containin,

pipe insulation while installing conduit. Plaintiff recalls maintenance personnel from PG&!
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 Ri

(deceased); Doyle Davidson (deceased); Ed Stor deceased, Ronald Furia (deceased; Jack
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 711962-5/1965
San Francisco, CA (5 weeks, on and
ol

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE pipecovering, and
asbestos-containing EAGLE PICHER and 301 cement onto a tank. Plaintiff used mag
insulation,

KAlnjured 93491 plA\Al-Supsac. wpd 8 ECS1

JOHNS MANVILLE 352 BLUE cement. Plaintiff applied CHILDERS (H&C INVESTMENT
COMP. Fibrous Adhesive to blocks, placed the blocks onto the , and “rasped off” the
extruded CHILDERS 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, Biantift

|| 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
follow!

supervisor: Robert Robbins (deceased), Plaintiff 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 dob Title Dates
Western Asbestos Gerber Foods Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 71962-5/1965
San Francisco, CA Goveeks, on and
0}

Job Duties: Plaintiff wrapped asbestos-containing insulation with chicken wire and applied all-
purpose cement over it. Plaintiff applied asbestos-containing JOHNS MANVILLE calcium
silicate pi vering and insulation cements. Plaintiff applied JOHNS MANVILLE 352 BLUE
cement. Plaintiff applied CHILDERS (H&C INVESTMENT COMPANY) Fibrous Adhesive to
block, applied the block to irregular surfaces, and “rasped off” the ex: CHILDERS
Fibrous Adhesive after it dried, via use ofa metal rasp. Plaintiff worked near pipefitters

| installing pipes valves and asbestos-containing G. OCK (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

Job Duties: Plaintiff worked in proximity to DOUGLASS INSULATION pipefitters who were
applying calcium silicate material. Pipefitters dismantled a chiller, removing asbestos-

| containing 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, CACO Oo AA HW F&F WH —

YPN BYP YY YR DN NN | Be Be es Se es ee ee
oN A A BBN |= So ON ADAH Bw NK GS

Job Duties: Plaintiff installed fiberglass duct wrap and asbestos-containing MUNDET 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 eipetiteers 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
Emplover Exposure Job Title Dates
Western Asbestos PG&E Insulator 1961-1965
3150 3" Street Antioch, CA (5-6 months)

San Francisco, CA

Job Duties: Plaintiff worked on new construction. Plaintiff delivered materials to this worksite.
Plaintiff applied insulation to piping, fittings and to a large boiler. 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 and OWENS CORNING asbestos pipe insulation was supplied by PG&E. Plaintiff
applied CHILDERS (H&C INVESTMENT COMPANY) Fibrous Adhesive to blocks, applied
the blocks to the boiler, and “rasped off” the extruded CHILDERS Fibrous Adhesive after it
dried, via use of a metal rasp. Plaintiff recalls general contractor C.C. MOORE employing
laborers. Plaintiff recalls seeing others working on STOCKHAM valves and strainers which
had asbestos-containing ANCHOR ¢ 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 recalls working near insulators from
OWENS CORNING FIBERGLAS. Plaintiff recalls the following supervisor: Thurman Gates
(deceased). Plaintiff recalls the following co-workers: Ron Powers (io 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 tee ‘Walter Lee (c/o Brayton*+Purcell LLP), Derrell Cozby (c/o

Brayton Purcell LLP); Maurice Lawrence (c/o Brayton**Purcell LLP); John (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 ul Job Title Dates
Westem Asbestos Hercules Powder Insulator 7/1961-10/1961;
3150 3 Street Hercules, CA 7/1962-5/1965
San Francisco, CA oon on and
o!

KAlnjured\19349\pId\A1-Supsac, wpd 10 ECSwe mY DH Bw NY me

NN NY N YB NH NN RD me
eI AA BF HN KF SO woe ID DAH WN |

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS) pipecovering.
Plaintiff applied foamglass insulation to piping. Plaintiff applied CHILDERS (H&C
INVES IT COMPANY) Fibrous Adhesive to the foamglass, and later “ off” the
extruded CHILDERS Fibrous Adhesive after it dried, via use of a metal rasp. Plaintiff worked
alongside pipefitters who were installing and removing FLEXITALLIC, INC. gaskets in
plaintiff 's presence. Plaintiff worked in proximity to TALCLAD INSULATION
ORPORATION 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 and JOHNS MANVILLE block
insulation that was covered in 352 BLUE cement and black mastic from a large vessel at a

article board mill. Plaintiff applied asbestos-containing JOHNS MANVILLE and PABCO

lock 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);

larry Fry (deceased); Robert Evans, Ray House (deceased). Plaintiff currently contends that he
was exposed to asbestos during this employment.

Exposure
Dates

Location of
Job Title

Employer

Western Asbestos
3150 3" Street
San Francisco, CA

Mt

K/Ninjured\19349\pI¢\Al-Supsac. wpd

Exposure

Bethlehem Steel
Shipbuilding
San Francisco, CA

Triple A Machine Shop
Pier 64)
an Francisco, CA

Insulator

Willamette Shipyard
Richmond, CA

Pacific Ship Repair
(Pier 36)
an Francisco, CA

Todd Shipyard
Oakland, CA

11

7/1961-10/1961;
T1962-5/1965

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

Ecsow OND HW e WwW Nw

Employer
Western Asbestos

3150 3” Street
San Francisco, CA (contd.)

KAlnjured 94M pLAALSupsse.wpd

Location of
Exposure Job Title

Matson Navigation Insulator

Gier 30)
an Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH P. KENNEDY
(@D-850)

CHEYENNE
(f-AG-174)

HAWAIIAN PLANTER
(1945)

RAFFIA:
{AF-29)

MATHEWS
(AKA-96)

MERRICK
(AKA-97)
TWINING
(D-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY
(1952)
BLAND
(APA-134)
P TRAIN
€WPG-70)

CALIFORNIAN
(1946)

AMERICAN ROBIN
(1943)

ROSE KNOT
(1945)

HAWATIAN
(1946)

12

Exposure
Dates

7/1961-10/1961,;
7/1962-S/1965

1963-1965oe BW A HW AY PV

Job Duties: Plaintiff insulated pipes, turbines, valves, and boilers using asbestos-containin;
JOHNS MANVILLE 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 ps.
Plaintiff recalls  pipefitters in his work area installing asbestos-containing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, Lic) gaskets and cutting gaskets from sheet
asket material. Plaintiff recalls welders using asbestos cloth during the course of their work.
laintiff worked near the FOSTER WHEELER boilers aboard the Li th
the HE: the MERRICK, the GENERAL W. » the
and the ROSE . 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
resence. Plaintiff recalls the following coworkers: Tom Andrews (c/o Brayton%Purcell LLP);
loseph 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 (dé Di 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
lorgensen (address unknown); James Logue (c/o Brayton® Purcel. LLP); Tony Lopes, Fremont,
California; Andy Grant (address unknown); Richard Poster (address own); Jos
Sandoval (deceased); Robert Sandoval (deceased); William Stein (address own); Ed Story
(deceased); Fred Strickland (deceased), Howard Tracy (deceased); Jack Kish (deceased); Paul
Schiebold (San Francisco, California); Dale Wri; t Ganta Rosa, California); Andy Grant _
de ite, Jr. (Napa, California); Benjamin
osed to asbestos during this

ie

(address unknown); Lowell Squires (deceased); Jim
Norrie (deceased). Plaintiff currently contends that he was exp

employment,
Location of . Exposure
Employer Exposure Job Title Dates
Western Asbestos Grace Cathedral Insulator 7/1961-10/1961;
3150 3" Street San Francisco, CA 711962-5/1965
San Francisco, CA Greeks, on and
o

Job Duties: Plaintiff worked in a crawl space under the building and had to drag equipment to
the Tumbing pipes that he was insulating. Plaintiff recalls that the area was dusty and that his
clothes and skin were covered with dust, Plaintiff used asbestos-containing PABCO
FFIBREBOARD CORPORATION) cal sil pipe insulation, FOSTERS 30-36 mastic and

|OHNS-MANVILLE 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;
3130 7 Street Shop, 3 Avenue and 7/1962-5/1965
San Francisco, CA Army, San Francisco, CA oo days, on and
oO

KAlnjured\9340\plehAL-Supsae. wpd 13 ECSoO DW DH BR WB NY eH

ROR
mw Oo OO OP NY DA HH & WwW NH S&H

22

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 exp 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 FA962-12/1962
San Francisco, CA Eureka, CA (5 months, on and

off)

Job Duties: Plaintiff carried asbestos-containing materials to co-workers. Plaintiff applied
asbestos-containin, blocks and i Pipecoverin to pipes valves and vessels. Plaintiff installed
352 cement and FOSTER’s (BAYER CROPSCIENCE) and CHILDERS (H&C INVESTMENT

COMPANY) Fibrous Adhesive. Plaintiff applied the FOSTER’s and CHILDERS Fibrous
Adhesive to blocks, applied the blocks to the reactor top, and “rasped off” the extruded, dried
FOSTER’s and CHILDERS Fibrous Adhesives using a metal rasp, which spread dust
throughout plaintif?’s work areas. Plaintiff used asbestos-containing JOHNS-MANVILLE,
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.

Location of Exposure
Employer Exposure Job Title Dates
Wester Asbestos PG&E Insulator 7/1961-10/1961;
3150 3" Street San Francisco, CA 7/1962-5/1965
San Francisco, CA {Potrero Station} to weeks, on
and o:

Job Duties: Plaintiff recalls working on a boiler during a remodel. Plaintiff recalls applying
KAYLO (OWENS CORNING FIBERGLAS) asbestos blocks and PABCO (FIBRE! RD
CORPORATION) all-purpose cement. Plaintiff applied CHILDERS (H&C INVESTMENT
COMPANY) Fibrous Adhesive to the blocks, applied the blocks to the boiler surfaces, and
“rasped off” the extruded, dried CHILDERS 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 Cegronth, on and
o! .

Job Duties: Plaintiff carried materials to the joumneymen. Plaintiff applied KAYLO (OWENS
CORNING FIBERGLAS) asbestos blocks, PABC' (FIBREBOARD CORPORATION)
cement and 352 BLUE cement to a large tank. Plaintiff applied CHILDERS (H&C

KyNinjured\9349\piQ\Al-Supsac. wed 14 rcsWO OO CR A Ot

me mt
Ww ND me

INVESTMENT COMPANY) Fibrous Adhesive to the blocks, adhered the blocks to the tank,
and “rasped off” the extruded CHILDERS 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 oe oe Lou Hansen (deceased); Robert

dav: ;