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

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                                LAW OFeices

, LLP

SUITE 1300

KEENEY & CORPERY,

IMAI, TADLOCK,

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

Tina Yim, Esq. (Bat No. 232597)

IMAI, TADLOCK, KEENEY & CORDERY, LLP

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

Attomeys for Defendant
WEBCOR BUILDERS, INC.

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION

ROBERT ROSS and JEAN ROSS,

Plaintiffs,

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

Defendants.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

FEB 22 2013

Clerk of the Court
BY: EDNALEEN JAVIER
Deputy Clerk

CASE NO.: CGC-10-275731
(ASBESTOS)

EXHIBIT F PART 1 OF 2 TO THE .
DECLARATION OF TINA YIM IN SUPPORT
OF WEBCOR BUILDER, INC.’§ MOTION
FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION

Date: May 9, 2013

Time: 9:30 am.

Dept: 503

Judge: Hon. Teri L. Jackson

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

Attached is EXHIBIT F PART 1 OF 2 THE DECLARATION OF TINA YIM IN
SUPPORT OF WEBCOR BUILDER, INC.’S MOTION FOR SUMMARY JUDGMENT OR, IN
THE ALTERNATIVE, SUMMARY ADJUDICATION.

-l-

EXHIBIT F PART 1 OF 2 TO TH DECLARATION OF TINA YIM IN SUPPORT OF WEBCGR BUILDER,
TNC.'S MOTION POR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE, SUMMARY
ADJUDICATION1 PROOF OF SERVICE

2 I, Heather Cherry, declare:

3 Jam a resident of the State of California and over the age of eighteen years, and not a
party to the within action; my business address is 100 Bush Street, Suite 1300, San Franciseo, CA
41) 94104, On the date of execution below, I served the within documents:

Law OFMIcES

5 EXHIBIT F PART 1 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
WEBCOR BUILDER, INC.’8 MOTION FOR SUMMARY JUDGMENT OR, IN THE
6 ALTERNATIVE, SUMMARY ADJUDICATION
7 by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.
& : :
all by placing the document(s) lisied above in a sealed envelope with postage thereon
fully prepaid, in the United States mail at San Francisco, Califomia addressed as set
by 10 forth below.
q .
: e i by personally delivering the document(s) listed above to the person(s) at the
5 2 address(es) set forth below. -
o =: . . . .
oOo f 43 On the date of execution below, I electronically served the document via File &
ae 3 ae ServeXpress on the recipients designated on the Transaction Receipt lecated on the
a ® gs 14 File & ServeXpress Web site. .
3252
ae a3 15 I declare under penalty of perjury under the laws of the State of California that the above
¢ ® 16 || 38 true and comect.
2° . :
eB 7 Executed on February 22, 2013, at San Francisco, California.
Zz .
: 3 18 :
6 19 /sf Heather Cherry
Heather Cherry
20

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

2
EXHIBIT F PART | OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF WEBCOR BUILDER,

INC."S MOTION FOR SUMMARY JUDGMENT OR, [IN THE ALTERNATIVE, SUMMARY
ADIODICATION"Law onrrens
IMAI, TADLOCK, KEENEY & CORDERY, LLP

SUITE 1300
100: BUSH STREET

SAN FRANCISCO, CA 94104

{EL 5) 675.7005

party

PROOF OF SERVICE
I, Tina Yim, declare:

Tam a resident of the State of Califomia and over the age of eighteen years, and nota
to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, CA

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

EXHIBIT F PART 1 OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF
WEBCOR BUILDER, INC.’8 MOTION FOR SUMMARY JUDGMENT OR, IN THE
ALTERNATIVE, SUMMARY ADJUDICATION

by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:06 p.m.

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

>) by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below;

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

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

I declare under penalty of perjury under the laws of the State of California that the above

is true and correct,

Ross, Robert and Jean v.C.C. Moore & Co. Engineers, (WB).

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

és! Tina Yim
Tina Yim

SAN FRANCISCO SUPERIOR COURT NO. CGC-10-275731

ae

EXHIBIT F PART ] OF 2 TO THE DECLARATION OF TINA YIM IN SUPPORT OF WEBCOR BUILDER
INC."3 MOTION FOR SUMMARY MODGMENT OR, IN THE ALTERNATIVE, SUMMARY
: ADJOBICATIONEXHIBIT FBRAYTON@PURCELL LLP
AITO RNEYS AT LAW
2? RUSLE LASGING ROAD

PO BOX E1gy
ROVATG, CALIFORNIA POM E4165

425) BB-ANSS

Bow NM =

Oo Mt

ALAN R BRAYTON, ESQ., 8.B. #73685
ERIC C. SOLOMON, ESQ,, 8B. #719131
BRAYTON® PURCELL LLP

Atiomoys at Law

222 Rush Landing Road

P.0. Box 6169

Novato, California 94948

(415) 898-1555

Axtorneys for Plaintiffs

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO
ROBERT ROSS and JEAN ROSS, j ASBESTOS
No, CGC-10-275731
Plaintiffs,
SUPPLEMENTAL/AMBNDED
vs. RESPONSES TO INTERROGATORIES

C.C. MOORE & CO. ENGINEERS;
Defendants 25 Reflected tar Bxbibit 1

attached to the Summary Complaint

herein: and DOES 1-8500, : j

PROPOUNDING PARTY. STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff ROBERT ROSS
SET NO(S}.: OME (1}

Plaintiff supplements/amenda hig Responses to Standard Asbestos Case Interrogatorizs,
Set One, No. 26 and/or 36, as follows:
SUPPLEMENTAL/AMENDED RESPONSE: Plaintiff incotparaies by reference as though
fully set forth herein, al! work history Jobsites, exposures, co-workers arid related infurmation
identified in the attached Exhibit A, and plaintiff references aad. incorporates herein all

Defendant Specific and Special Interrogatory Responses to fellow in this case.

Dated: 10/25 (2012. BRAYTON*PURGELL LLP
by,

Enc C. Soldmon
Aftomeys far Plaintiffs

Valnjuredh G9 ipdel-supeee3. erp T BOSoom YN mv BP ww

EXHIBIT A

Robert Ross and Jean Ross v. C.C. Moore & Co. Engineers, et al.
Location of Exposure
Employer Exposure Title Dates
General Mills Company General Mills Warehouseman 1952-1/1954:
P.O. Box 1113 Vallejo, CA 2/1956-6/1996
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 ~ Di9/54-1/2 7/56,
Monterey, CA;
United States Army
Ckinawa, Japan

Job Duties: Plaintiff served in the United States Anny as an infinteyna. Plaintiff served at
Fort Ord, Monterey, California, for 14 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 Q 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 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 Tj Jates

Philip Carey Warehouse Warehouseman 2/1959-8/1959;
Cincinnati, OH 101 Williams 12/1959-1/1960
San Francisco, CA (1 week)
Jack Tar Hote)
(ka Cathedral Hill Hotel)
101 ¥an 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 ar
delivering the following asbestos containing products: PHILIP CAREY (RAPID-. CAN
CORPORATION), IGHNS-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 ILLE 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, Califormia. 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
CORFORATION) asbestos-containing pipe insulation and created by cutting of GARLOCK
(GARLGCK 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 sapervisor at the warehouse: Scoit, Tucson, Arizona. Plaintiff recalls the
following coworkers at the warehouse: Bill Heineche, Sr. (deceased); Bill Heineche, Jv.
(axldress unknown). Plaintiff currently contends that he was exposed ta asbestos during this
employment.

P *Plaintift 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 asl estos containing pipe
insulation with a hand saw. Pleintiffmixed asbestos cement and applied cement to fittings and
inegular surfaces. Plaintiff worked in n proximity to the following trades: Plumbers, pipefitters,
sheet metal workers, electricians, sprinkler fitters, carpenters, laborers, lathers and P lerers,
drywallers, flocr installers and ceiling installers. Plaintiff worked in proximity to plumbers
disturbing existing insulation and fireproofing. Plaintiff worked in proximity to pipefitters
working on pumps and valves, and working with asbestas-containing gaskets andy packing. ”
Plaintiff worked in proximity to sheet metal workers disturbing existing asbestos-containt
fireproofing insulatron and installing asbestos-containing flexible duct connectors. Plainii
worked in proximity to electcicians stripping asbestos insulated wire and disturbing existing
asbestos-containing fireproofing and insulation. Plaintiff worked in Proximity fo sprinkler
fitters disturbing existing asbestos-containing fireproofing insulation, Plaintiff wotked in
proximity to laborers performing peneral 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 latbers and

lasterers 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 nsing a circular saw to cut floor tiles that contained
asbestos. Plaintiff worked in proximity to ceiling installers disturbing existing asbestos-

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10

containing fireproofing insulation, Plaintiff cut asbestos-containing insulation with a power
saw and applied asbestos-containing canves 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. Plaintiff recalls scoring and
cutting the block insulation with a handsaw. Plaintiff recalls mixing all-purpose cement and
using JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plamtiff currently
contends he was exposed fo 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 } months)
Menlo Park, CA Yallejo, 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
tecalls boilers manufactured by the following: FOSTER WHEELER CORPORATION

OSTER WHEBLER 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
G. OCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked near
the installation of anew BELL & GOSSETT (ITT INDUSTRIES, INE.) pura which had
original manufacturer's asbestos-containing gaskets wired to it. Plaintiff recalls the following
co-workers: Jack Kish (deceased); Rod Hochstrasser (deceased); Ed Fleigher (deceased),
Plaintiff currently contends that he was exposed to asbestos during this employment.

Location of Exposure

Employer Exposure JobTitle Dates

Universal Insulation Hewlett Packard Insulator, 1959 (1-2 weeks)
520 6% Avenue Menlo Park, CA (Apprentice)
Menlo Park, CA .

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

ipes. Plaintiff recalls scoring and cutting the block insulation with a bandsaw. Plaintiff recalls
Taborers from Universal Insulation Company sweeping up MONOKOTE (W.R. GRACE &
CO.), PABCCO (FIBREBCARD CORPORATION) pipecovering, and other debris. Plaintiff
tecalls the following supervisor: Troy Cazby (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
Dates

Employer Exposure Job Title

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

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

Job Duties: Plaintiff applied asbestas-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, includin| , but not limited to: pipefitters, boiler makers, and laborers. Plaintiff worked
in proximity io boilermakers employed by Bay Cities Asbestos Co., Ltd., JAMES

WHITT. (RAYMOND INTERIOR SYSTEMS-NORTH} laborers mixed and sprayed
asbestos-containirig CAFCO ITED STATES MINERAL PRODUCTS COMPANY}
fireproofing and swept dried freproofin; overepry in a Plaintiffs work areas. Electricians
disturbed overhead asbestos-containing MONOKOTE (W.R. GRACE & CO.) fireproofing
while setting their conduit suppocts. Plaintiff worked in proximity to others who were
checking, removing anid replacing asbestos-containing original manufacturer’s packing in new
BELL & GOSSETT (TT USTRIES, 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, packs, Plaintiff recalls that they special
ordered asbestos containing pi e insulation from METALCLAD INSULATION
CORPORATION. WEBC! UILDERS laborers swept and shoveled asbesins-comtaining
PABCO (FIBERBOARD CORPORATION) and JOHNS MANVILLE (MANVILLE TRUST}
Thermobestos thermal insulation scraps and dust, Cafco (NITED STATES MINERAL
PRODUCTS COMPAN Ereproofing dust, and seraps from asbestos-containing
FLEXITALLIC and G. OCK (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).
Piaintiff currently contends that he was exposed to asbestos during this employment.

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

Job Duties: Plaintiff applied asbestos containing insulation to a large tank, Piaintiff applied
EAGLE-PICHER (EAGLE PICHER INDUSTRIES, INC.) asbestos-containing cement on the
heads and fittings. Plaintiff applied EAGLE PICHER mineral woo]. Plaintiff applied KAYLO
(OWENS CO G FIBERGLAS} asbestos-containing insulation on pipes. Plaintiff recalis
using JOHNS-MANVILLE (MANVILLE TRUST) “Thermobestos” asbestos-containing
pipecovering, $5% magnesia cements, and 127 “blue mud.” Plaintiff recalls the following
contractors at this site: PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY) and Bay Cities Asbestos Co., Lid., TIDEWATER REFINERY (TEXACO, INC.}
laborers 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);
Robert Sandoval (deceased); Ron Furia (ceceased), and Laurance Hagen (c/o Bmyton?Purcell
LLP). Plaintiff recalis ihe following employees of PLANT INSULATION COMPANY
PLANT INSULATION COMPANS): on Powers (c/o Brayton®*Purcell LLP); Steve Steele
c/o Brayton%Purcell LLP). Plaintiff currently contends that he was exposed to asbestos during
is employment.

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Location of Exposure
Employer Exposure Job Title Dates

Western Asbestos PG&E Powerhouse Insulator 1/1960-7/1960
3150 37 Street Pittsburg, CA (3 months)

-San Francisco, CA

Job Duties: Plaintiff worked on new construction. Plaintiff mixed asbestos-containing
insulating cement and scored asbestos blocks with a saw. Plaintiff ysed asbestas-containing
JOHNS-MANYVILLE (MANVILLE TRUST) pipecovering, EAGLE PICHER cement and all-
purpose cement at this site. Plaintiff installed asbestos-containing insulation on equipment and
pipes. Plaintiff worked near refractory workers from J.T. THORPE & SON, INC. who were
installing asbestos-containing block, cements and refractory bricks in the boilers, Plaintiff
observed these J.T. THORPE & SON workers mixing refractory cements and cutting firebricks
on nearly 50 occasions. Those refractory cements were contained in sacks that were marked as
containing asbestos. On one 5 minute long occasion, plaintiff entered the boiler where the IT,
THORPE & SON brick masons were applying refractory cement and firebricks. Plaintiff also
“peeked in” to the boiler to observe that Work on several occasions. Plaintiff worked near
boiler makers who he recalls were ftom J.T. THORPE & SON, INC. Carl Ramsey (c/o
Brayton‘ Purcell LLP) was 2 member of the J.T. THORPE & SON, INC. crew. Plaintiit
d near welders using asbestos-containing welding blankets, laborers sweeping up the site

and pipefitiers installing gaskets, valves and pipes. Thurman Gates (deceased) was plaintiff's
supervisor. Plaintiff recalls the following co-workers; Charles Purcell (deceased), Jack Kish
{ceceasesl) John Heyt (c/o BraytonPurcell LLP); Donald Cox (c/o Brayton Purcell LLP); Ed

‘tory (deceased); Charlie Power (deceased). Plaintiff currently contends that he was exposed to
asbestos during this employment.

Location of Bxposure
Emplover Exposure . Job Title Dates

Western Asbestas meen of the Valley Insulator V1960 (3 weeks)
3150 3" Street lospital
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 npes in the boiler room with asbestos-
containing JOHNS-MANVILLE (MANVILLE ST) 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 JobTitle ~ Dates

Heat, Frost é& 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 [ARCO) pipecovering. Plaintiff recalls the following supervisor:
Richard Holmes (deceased). Plaintiff recalls the followimg co-workers: John Chulick (o/o
Brayton Purcell LLP); Ron Furia (deceased), Charles Tobey (c/o Brayton? Purcell LLP);
Charlie Power (deceased); James Kearney, (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.

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Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos MeKinleyvilie High School Insulator 7/1961-10/1961;
3150 3" Street McKinleyville, CA 71962-5/1965
San Francisco, CA (3% weeks, on
. and off}

Job Duties: Plaintiff worked at this site multiple times for about three and % weeks total during
the new construction of the high school. Plaintiff applied asbestos-containing JOHNS-
MANVILLE (MANVILLE TRUST) mize pipecover and used all purpose cement for the
fittings. FRANK M. BCOTH and U. CONSTRUCTION pipe itters and sheetmetal
workers disturbed previously sprayed asbestos-contaming MONOKOTE (W.R, GRACE &
CO.) overhead fireproofing while setting pipe supports and duct supports in plainttff'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 sormpeuntls next
to plaintiff on 1 approximately 20 or more occasions. Plaintiff recalls working esr laborers
employed by NE M. BOOTH who performed clean-up and suigeping 0 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 asl
during this employment.

Location of Exposure
Emplayer Exposure Job Title Dates

Western Asbestos Calaveras Cement Plant tnsulator 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 ashestos-
containing EAGLE PICHER cement and chicken wire. Plaintiff recalls working near pipefitters
who were installing pipes, valves and gaskets. Plaintiff recalls working near others nsmg,
asbestos blankets. lanitt 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 BraytonPurcell L! vs
Richard Cross (deceased). Plaintiff currently contends that he was exposed to asbestos during
this employment.

Location of “Exposure
Employer Exposure Job Title Dates
Wester Asbestos Tidewater Oil Company Insulator 1961-1962
4150 3* Street Avon, CA {Approx 1 month)

San Francisco, CA.

Job Duties: Plaintiff revalls insulating pipes, atank and vessels. Plaintiff used asbestos-
containing EAGLE PICHER cement, and asbestos-containing JOHNS MANVILLE
(MAN' TRUST) and KAYLO (OWENS CORNING F! ERGLAS) pipecovering and
block insulation. Plaintiff worked near laborers, were employed by PL: MAINTENANCE
LANT MAINTENANCE, INC, OF CALIFORNIA) who were siripping existing asbestos-
containing pipe insulation, sweeping up the site and carrying products to the workers.
TIDEWATER OIL (TEXACO, .) faborers were also sweeping and shoveling asbesios-
containing debris in plaintiff's presence at this site. TIMEC (TIMEC COMP: LINC)
workers were stripping asbestos-containing block insulation off the nearby coker, which spread

KAlnjured\1 2309 ple A supe spd 7 ecsdust throughout plaintiff's work areas. PLANT ASBESTOS COMPANY (PLANT
INSULATION OME ANY) Personnel were applying | asbestos-containing PABCO
GIBREBOARD CORPO! TON) 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 insralling and
removing asbestos-containing FLEXITALLIC, INC. gaskets. SLAKEY BROTH! delivered
asbestos cement piping to this site on flatbed trucks. Plaintiff observed cutting and laying of
that asbestos cement piping for afew 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 3 Street Avon, CA 1 month)

San Francisca, CA

Job Duties: Plaintiff worked on an addition to the plant. Plaintiff flat troweled asbestos-
containing EAGLE PICHER cement on the vessel. Plaintiff installed asbestos-containin
JOHNS-MANVILLE (MANVILLE TRUST) pipecovering. Plaintiff's co-workers included
Robert Robbins and Leo Hansen (both deceased), Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of : Exposure
Employer Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Insulator 1961-1965
3150 3 Street Pittsburg, CA (moath
San Francisco, CA. continuous work)

Job Duties: Plaintiff recalls installing asbestos pads and asbestos-containing JOLINS-
MANVILLE (MANVILLE TRUST) insulation. Plaintiff recalls JT. THORPE & SON, INC.
was the refractory contractor at this Jobsite. Plaintiff observed J.T. THORPE & SON brick
masons and hod carriers re-bricking two boilers during this project. Plaintiff observed the J.T.
THORPE & SON personnel removing fizebrick, mortar and other material from the boiler
during a 5 to 10 day period, and thereafter, observed those personnel mixing new refractory
cement and cutting new brick, which the brick masons installed into the boilers. 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 workin;
ona BABCOCK & WILCOX boiler, Plaintiff worked near electricians employed by CON BA
COSTA ELECTRIC, INC who were disturbing asbestos-cont ipe insulation while
installing conduit, Plaintiff recalls maintenance Personnel from PG&E were removing
asbestos-containing materials from this boiler. Plaintiff zecalls working near pipetitters 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 Jagoda (c/o Paul &
Hanley); Harry Fry (foreman) eased); Donald Cox (c/o Brayton%Purcell LLP), Derrell
Cozby (clo Brayton’ Purcell LLP). Plaintiff currently contends that he was exposed to asbestos
during this employment.

it
Mt

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wom wy eM M MM NM oy oe “= oo oo
BUR DF ESOR RF SSSR U RADE HES

Location of Exposure

Employer Exposure Job Title Dates

Westem Asbestos Colgate Palmolive Insulator 7/1961-L0/1961;

3150 3" Street Berkeley, CA H1962-5/1965

San Francisco, CA (5 weeks, on and
0:

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE (MANVILLE TRUST)
Pipecovering, and ashestos-containing EAGLE PICHER and 301 cement onto a tank. Plaintiff
used mag insulation, JOHNS LE .NVILLE TRUST) 352 BLUE cement. 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, Plemtiff observed L.J, KRUSE COMPANY pipefitters handling ashestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff
observed L.J. KRUSE repacking one new valve using asbestos-containing valve packiry
material, Plaintiff recalls the following, fupervisor; Robert Robbins (deceased). Plein
recalls the following co-workers: Lowell Squires (deceased); Jim White, Jr. (Napa, Califomia);
Lou Hansen (deceased); Robert Sandoval (deceased). Plaintiff currently contends that he was
exposed io asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Westem Asbestos Gerber Foods Tnsnlator FA1961-10/1 961;
3150 3" Street Oakland, CA /1962-5/1965
San Francisco, CA. . a weeks, on and
a

Job Duties: Plaintiff pmapped asbestos-containing insulation with chicken wire and applied all-
purpose cement over it. Plaintiff applied asbestos-containing JOHNS MANVILLE
ILLE TRUST) calcium silicate Fi eeovering and insulation cements. Plaintiff applied
OHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff worked near
ipefitters installing Pipes valves and asbestos-containing GARLOCK (GARLOCK SEALING
TECHNOLOGIES. ) gaskets. Plaintiff recails the following co-workers: Bennie Norrie
(deceased), Lou Hansen (deceased), Robert Robbins (deceased). Plaintiff currently contends
that he was exposed fo as s during this employment,

Location of Exposure
Employer Exposure Job Title Dates
Westem Asbestos Anup 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 te 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 porting ona puree which invelved replacement of asbestos-centaining
GARLOUCK (GARLOCK 5: iG TECHNOLOGIES, LLC} gaskets. Plaintiff recalls the
following co-workers: Everett Wai (San Jose, California); Jim Kearney (deceased); Jim
White, Jr. (Napa, California), Plaintiff currently contends that he was exposed to asbestos
during this employment.

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23

Location of Exposure

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

San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct 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 bemg removed and
installed Plaintiff worked near laborers who were swesping the floors and pipefitters who were
installing and removing asbestos-containing GARLO GARLOCK SBALIN iG
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 clecizical conduit in
pleintifi's work areas, Plaintiff recalls the following supervisor, John Straba (deceased).
laintiff recalls the following co-workers: Pancho (deceased), and Ron Powers (c/o
Brayton Parcel 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 Insulator 1961-1965
3150 3 Street Antioch, CA (5-6 months)

San Francisco, CA.

Job Duties: Plaintiff worked on new construction. Plaintiff delivered materials fo this worksite.

Plaintiff applied insulation to piping, fittings and to a large boiler. Plaintiff installed ashestos-
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 CO. 1G FIBERGLAS
asbestos pe inalahon to flanges on a boiler, Plaintiff recalls that the asbestos-containing
PABCO MI REBOARD CORPORATION) and OWENS CORNING (OWENS CORNING
FIBERGLAS) asbestos pipe insulation was supplied by PG&E, Plaintitf recalls general
contractor C.C. MOGRE (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, ING) packing on them.
Plaintiff recalls working near boilermakers, omployed by BABCOCK & ‘COX who were
installing the boiler and near employees from J.T. THORPE & SON, INC. who were mstailing
the refractory materials inside the boiler, and working on turbines. Plaintiff worked in close
proximity to the J.T. THORPE & SON brick masons and hod carriers for approximately 2
months, and observed them mixing refractory cement and cutting and installing fire brick.
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
laintiff. *Plaintct recalls working near insulators from OWENS ING FIBERGLAS.
Paint recalls the following supervisor: Thurman Gates (deceased), Plaintiff recalls the
following co-workers: Ron Gowers (c/o Brayton*Purcell LLP); Jim White, Jr, (Napa,
Californie), Bill Armstrong (deceased); Ronald Furia (deceased); John Hoyt (c/o
Brayton®! ell LLP); Art Klimack c/o Brayton%Purcell LLP; Al Leandro (c/o
Breyton*Purcell ; Walter Lee (c/o Brayton*Purcelt LLP); Derrell Cozby {c/o
B nPurcell LLP}; Maurice Lawrence (c/o BraytonPurcell 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 ashestos during this
employment.

keltgjured\ 914% pha supsec3.wpd 10 ECSI

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BSRRRREBBRERESSaRaADECOB HS

Location of Exposure

Employer Exposure Job Title Dates

Wester Asbestos Hercules Powder Tnsulator : FSE1-10/1961;

3150 3 Street Hercules, CA 11962-5/1965

San Francisco, CA (1 month, on and
off)

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS) pipecovering.

Plaintiff pplied foamglass insulation to Pivine. Plaintiff worked alongside pipefitters who

were installing and removing FLEXITALLIC, INC. gaskets in plaintiff's presence. Plaintiff

worked in proximity ta METALCLAD INSULATION CORPORATION insulators who were

applying asbestos-containing thermal insulation. Plaintiff recalls the following supervisor:

Lowell Squites (deceased), Plaintiff recalls the following co-workers: Jim White dr. (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 37 Street Arcata, CA 71962.5/1965

San Franciseo, 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 332
BLUE cement and black mastic from a large vessel at a particle board mill. Plaintiff applied
asbestos-containing JOHNS MANVICLE (MANVILLE RUST) 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
cunrently contends that he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposore Job Title Dates,
Western Asbestos Bethlehem Steel Insulator 7/196 1-10/1961;
3150 3" Street Shipbuilding 711962-5/1965
San Francisco, CA San Francisca, CA
Triple A Machine Shop (on and off for
(Pier 64) approx. 1 week
San Francisco, CA each time)
Willamette Shipyard
Richmond, CA

ff

Egjured 9349p Ale upsnedwpd il EtsEmployer
Western Asbestos

3150.3” Street
San Francisco, CA (contd.)

Alef 93 Hp Eup pd

Location of
Exposure

Bethlehem Steel

Shipbuilding

San Francisco, CA

Pacific Shi, ei
Her 36) PRep
an Francisca, CA.

Todd Shipyard
Oakland, CA

Matson Navigation
(Pier 30)
San Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH DP. KENNEDY
Tk.
(DD-850)

CHEYENNE
(T-AG-I7)

HAWAIIAN PLANTER
(1945)

FRAFFIAS
(AF-29)

Job Title
Insulator

MATHEWS
(AKA-96)
MERRICK
(AKA)

TWINING
{DD-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY
(1952)

BLAND
{APA-[34)

PONTCHARTRAIN
(WPG-70)

12

Exposure
Dates

7/1961-10/1961;
FA962-5/1965Location of Exposure

Employer Exposure Job Title Dates
Western Asbestos Bethlehem Steel - Insulator T/1961-L0/1961;
3150 3 Street Shipbuilding . W1962-5/1965
San Francisco, CA (contd.) San Francisco, CA

1946) /

AMERICAN ROBIN 1963-1965

{1943)

O!

(1945)

HAWAIIAN

(1946)

Job Duties: Plaintiff insulated pres, turbines, valves, and boilers using asbestos-containizy
(OHN! TLE TRUST) and PABCO (FIBREBOARD CORPORATION)
block and pipecovering. Plaintiff removed and repaired asbestos-containing insulation.
Plaintiff aed 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 jastalling pipes, asbestos-containing
gaskets, valves and 3. Plaintiff recalls pipefitters in his work area installing asbestos-
containing GARLOEX (GARLOCE, SEA TECHNOLOGIES, LLC) gaskets and cutting
gaskeis from sheet gasket material. Plaintiff recalls welders using asbestos cloth during the,
E

| course of their work. Plaintiff worked near the FOSTER WHEELER (FOSTER WHE

LLC (FKA FOSTER WHEELER CORPORATION)) boilers aboard the
PLANTER, the GRAFFIAS, the MATHEWS, the MERRICK, the G! .
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 themmal
insulation and who were sweeping and cleaning asbestos-containing debris in plaintiff's
sence, Plaintiff recalls the allowing cowor ers: Tom Andrews (c/o Brayton*Purcell LLP},
joseph OF Balle (c/o Brayton*Pureelt ); 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 BraytonPurcell LLP); Bill Green, Sr. (deceased); Bill Green, Jr.
(deceased); Ronald Grist, Newark, California; Bill Heimicke (deceased); Frank Howard
(deceased : John Jagoda, Martinez, California; Myron Jorgensen {address unknown): Harvey
orgensen (address unknown); James Logue (c/o Brayton Purcel LLP), Tony Lopes, Fremont,
Califomia; Andy Grant (address unknown); Richard Porter (address own}; Joseph
Sandoval (deceased); Robert Sandoval (deceased); William Stein (address unknown), Ed Story
deceased); Fred Strickland (deceased), Howard Tracy (deceased); Jack Kish (deceased); Paul
chiebald (San Franciseo, California); Dale Wright (Santa Rosa, California); Andy Grant
(address own); Lowell Squires (deceased); Jim White, Jr. (Napa, California); Benjamin
Norrie (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment.

if
if

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RFS 6 aU AH BW hw Be

Location of Exposure
Dates

Employer Exposure Job Title

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

3150 3" Street San Francisco, CA. TAI62-5/1965

San Francisco, CA (2 weeks, on and
. off)

Job Duties: Plaintiff worked in a crawl space under the building and had to drag equipment to

the plumbing pipes that he was insulating. Plaintiff recalls that the area was dusty and that his

clothes and skin were covered with dust. Plaintiff used asbestos-contaiaing PABCO

(eREBOARD CORPORATION) cal sil pipe insulation, FOSTERS (BAYER
OPSCIENCE INC.) 30-36 mastic and 15 S-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 1/1962-5/1965
San Francisco, CA Anny, San Francisca, CA Gs days, on and
o

Job Duties: Plaintiff made asbestos Fads 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 (Geceased 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
Westem Asbestos Humboldt Bay Powerhouse Insulator 7/1961-10/1961;
3150 3" Street PGE) 7/1962-12/1962
San Francisco, CA Bureka/Humboldt County, (5 months, on and

off)

Job Duties: Plaintiff carried asbestos-containing materials to co-workers. Plaintiff applied -
asbestos-containing mag blocks and pi ecovering (0 pines valves and vessels. Plaintttf installed
352 cement and POSTER's {BAYE OPSC] INC.) Fibrous Adhesive. Plaintiff
applied the FOSTER’s @A YER CROPSCIENCE INC.) Fibrous Adhesive to blocks, applied

blacks to the reactor top, and “rasped off” the extruded, dried FOSTER’s (BAYER
CROPSCIENCE INC.} Fibrous Adhesives using a metal rasp, which spread dust throughout
plaintiff's work areas. Plaintiff vsed asbestos-containing JOHNS. EM. ‘LE
TRUST), UNIBESTOS CO until June 1962; PITTSBURGH CORNING
CORPORATION from July Lg) PABCO (FIBREBOARD CORPORATION) and 48
insulation. Plaintiff recalls the following foreman: Ed Story (deceased). Plaintiff recalls the
following co-workers: Hanry Fry (deceased); Donald Cox (c/a Brayton Purcell LLP); Ronald
Furia Geceased), Howard Jobnson (deceased); Charles Tobey (c/o Brayton+Purcell );
Doyle Davidson (deceased); Earl Riges (deceased); Richard Gross (deceased). Plaintiff
currently contends that he was exposed to asbestos during this employment.

itt
Hf

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ho wom ww woe ee oe
BSRRREBRBEBSE BAA AEEE TS

Location of Exposure

Employer Exposure Job Title * Dates

Western Asbestos PG&E Insulator 7/1961-10/1 961;

3150 37 Street San Francisco, CA 7/1962-5/1 965

San Francisco, CA {Potrero Station) Clo ives on
9

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 worked near employees ftom PG&E who were
sweeping and oleaning ts tos Jaden 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 FA196i-10/1961;
4150 3" Street Pittsburg, CA 7/1962-5/1965
San Francisco, CA (1. month, on and

o

Job Duties: Plaintiff carried materials to the joumeymen. Plaintiff applied KAYLO AQRENS
CORNING FIBERGLASS) asbestos blocks, PABCO (FIBREBO. CORPORATION)
cement and 352 BLUE cement to a large tank, Plainuff recalls working near pipefitrers
installing pipes, valves, pumps and ITALLIC, 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 be
was exposed fo asbesios during this employment.

Location of Exposure
Employer Exposure . Job Title Dates

Wester Asbestos Shell Oil Insulator 7/1961-10/1961;

3150 3" Street Martinez, CA 7f1962-5/1 965

San Francisco, CA. eevee, on and
a

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.
Plaintiff recalls working near pipefitters from FOLEY-PM1 installing pipes, new
LUNKENHEIMER veal es, Pus, and asbestos-containing DURABLA (DURABLA
MANUFACTURING COMPANY, INC.) gaskets. Plaintiff also observed FOLEY-PMI
5 efitters removing existing DURABLA flange gaskets in his presence, on. approaimately 4to
occasions, PLANT ASBESTOS COMPANY (PLANT INSULATION COMPANY)
supplied asbestos-containing insulation materials, inchading PABCO (FIBREBOARD
CORPORATION ipe-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 recails 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),

Kalnjured 1949p dvulaupencd. wed 5 eesRobert Sandoval (deceased); Ed Meyer (c/o 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 FG&E Insulator F1961-10/1961;
3150 3" Street Oakland, CA 7/1 962-12/1962
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 PORE
laborers sweeping and cleaning asbestos laden dust and debris in plaintiff's work areas.
Plaintiff recalls be following supervisor: Benjamin Norrie (deceased). Plaintiff currently
contends that he was expoged to asbestos during this employment.
Location of Exposure
Employer. Exposi Job Title Dates
Westem Asbestos Vallecitos Atomic Insulator 7/1961-10/1961;
“3150 3" Street Laboretery 7/1962.-5/1965
| San Francisco, CA Pleasanton, CA 2 on onand
o!
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 LI IHEIMER COMPANY
valves, while insulating a boiler and associated piping. Plaintiff had to crawl into tight areas
that contained loose aaberiog 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 Nore
(deceased). Plaintiff recalls the following co-workers: Lou Hansen {Geceased); Robert
Sandoval (deceased); Ed Meyer (c/o Braytoné Purcell LLP). Plaintiff currently contends that he
was exposed to asbestos during this employment.
Location of . . Exposure
Employer. Exposure Job Title Dates
Western Asbestos Missile Base Insulator F/1961-10/1961;
3150 3" Street Live Oak, CA 741962-5/1965
San Francisco, CA {Limonth, on and
i

Job Duties: Plaintiff epplied tubber insulation and 520 mastic. Plaintiff worked near other
tradesmen who installed asbestos-conteining ANCHOR (COLTEC INDUSTRIES, INC.
acking, and asbestes-containing DURABLA (DURABLA MANUFACTURING COMPANY,
INC) gaskets. Plaintiff observed workers removi