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  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview 
						
                                
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Eugene C. Blackard Jr. (Bar No. 142090)
Jocelyn M. Soriano (Bar No. 201169)

Jasun C. Molinelli (Bar No. 204456)

jmolinelli@archernorris.com ELECTRONICALLY

ARCHER NORRIS FILED

A Professional Law Corporation Superior Court of California,

2033 North Main Street, Suite 800 County of San Francisco

Walnut Creek, California 94596-3759 FEB 22 2013

Telephone: 925.930.6600

Facsimile: 925.930.6620 oven ofthe cout
Deputy Clerk

Attorneys for Defendant
ALBAY CONSTRUCTION COMPANY

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS, Case No. CGC-10-275731
Plaintiff, DECLARATION OF JASUN C.
MOLINELLI IN SUPPORT OF MOTION
v. FOR SUMMARY JUDGMENT

C.C. MOORE & CO. ENGINEERS, et al., Date: May 9, 2013

Time: 9:30 a.m.
Defendants. Dept.: 503

Judge: Hon. Teri L. Jackson

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

DECLARATION

I, Jasun Molinelli, declare as follows:

1. 1 am an attorney duly licensed to practice before all the courts in the State of
California, and am an associate with the law firm of Archer Norris, attorneys of record herein for
Defendant ALBAY CONSTRUCTION COMPANY (“Albay”). I am personally familiar with the
facts set forth to competently testify to them if required to do so.

1. Attached to the Index of Exhibits as Exhibit “A” is a true and correct copy of the
relevant portions of the transcript from the Deposition of Plaintiff.

2. Attached to the Index of Exhibits as Exhibit “B” are true and correct copy of the

Declaration of Gary Miles.
ALB191/1532007-1

DECLARATION OF JASUN C. MOLINELLI IN SUPPORT OF ALBAY’S MSJ3. Attached to the Index of Exhibits as Exhibit “C” is a true and correct copy of
Albay’s Responses to GO 129 Interrogatories.

4, Attached to the Index of Exhibits as Exhibit “D” are true and correct copies of
Albay’ s Special Interrogatories, Request for Production of Documents, Request for Admissions
and Form Interrogatories to plaintiff.

3. Attached hereto, collectively as Exhibit “E” are true and correct copies of the
Plaintiff s responses to Albay’s Special Interrogatories, Request for Production of Documents,
Request for Admissions and Form Interrogatories

6. T have reviewed all of plaintiff's discovery responses (oral and written) and all
other factual documentation filed by plaintiff in this matter and have identified all potential
witnesses named by plaintiff against Albay.

7. All available witnesses identified by plaintiff, if applicable, have been deposed and
have no information or knowledge related to plaintiff's claims against Albay which creates a
triable issue of material fact that plaintiff was exposed to asbestos at the hands of Albay.

8. Afier conducting a reasonable inquiry and diligent search, all other potential

witnesses against Albay are unavailable pursuant to Evidence Code § 240.
I declare under penalty of perjury that the foregoing is true and correct. Executed on

February 21, 2013, at Walnut Creek, California.

JASUN MOLINELLI

ALB191/1532007-1 2

DECLARATION OF JASUN C. MOLINELLI IN SUPPORT OF ALBAY’S MSJ