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

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Stephen J. Foley SBN 220752
Dennis M. Young SBN 121178
Roger D, Yuen SBN 221243
FOLEY & MANSFIELD, PLLP
300 Lakeside Drive, Suite 1900
Oakland, CA 94612

Telephone: (510) 590-9500
Facsimile: (510) 590-9595
E-mail: ryuen@foleymansfield.com

Attorneys for Defendant

LONE STAR INDUSTRIES, INC.

ELECTRONICALLY

FILED

Superior Court of Califo!
County of San Francis

FEB 21 201

Clerk of the Cou
BY: CAROL BALISTRE
Deputy

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS,
Plaintiffs,

vs.

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

Defendants,

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

INDEX OF EXHIBITS [B C] TO
DECLARATION OF ROGER D. YUEN

IN SUPPORT OF DEFENDANT LONE
STAR INDUSTRIES, INC. 3 MOTION
FOR SUMMARY JUDGMENT, OR IN THE
ALTERNATIVE, 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

INDEX OF EXHIBITS [B-C] TO DECLARATION OF ROGER D. YUEN IN SUPPORT OF
DEFENDANT LONE STAR INDUSTRIES, INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE
ALTERNATIVE, SUMMARY ADJUDICATION

nia,
0

f
(Clerk~

EXHIBIT

DOCUMENT

Exhibit B

Plaintiffs’ Supplemental/Amended Responses to General Order Standard
Asbestos Interrogatories.

Exhibit C

LSI’s Form Interrogatories, Special Interrogatories, Request for Production of
Documents and Request for Admissions to Plaintiff Robert Ross; and Special
interrogatories and Request for Production of Documents to Plaintiff Jean Ross

DATED: February 21, 2013

FOLEY & MANSFIELD, PLLP

By: Kegs A

Stephen J. Foley

Dennis M. Young

Roger D. Yuen

Attorneys for Defendant

LONE STAR INDUSTRIES, INC.

2

INDEX OF EXHIBITS [B-C] TO DECLARATION OF ROGER D. YUEN IN SUPPORT OF
DEFENDANT LONE STAR INDUSTRIES, INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE

ALTERNATIVE, SUMMARY ADJUDICATIONEXHIBIT BBRAYFON@ PURCELL LLP

ep
a

ALAN R. BRAYTON, ESQ., S.B. #73685
ERIC C. SOLOMON, ESQ.., 8.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; j
Defendants as Reflected on Exhibit 1 )
attached to the Summary Complaint )
herein; and DOES 1-8500. )

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING.PARTY: Plaintiff ROBERT ROSS
SET NO(S),: ONE (1)

Plaintiff supplements/amends his Responses to Standard Asbestos Case Interrogatories,
Set One, No. 26 and/or 36, as follows:
SUPPLEMENTAL/AMENDED RESPONSE: Plaintiff incorporates by reference as though

fully set forth herein, all work history jobsites, exposures, 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.

Dated: _ (0/25 120 fe BRAY I de)

“Hie C. Solomon.
Attorneys for Plaintiffs

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EXHIBIT A

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

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

Minneapolis, MN

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

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

United States Army
Okinawa, Japan

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

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

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

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

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

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Location of Exposure

Employer Exposure Job Title Dates
Philip Carey Warehouse Warehouseman 2/1959-8/1959,
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 (RAPID-AMERICAN
CORPORATION), JOHNS-MANVILLE (MANVILLE TRUST), OWENS CORNING
KAYLO (OWENS CORNING FIBERGLAS), UNIBESTOS (UNARCO), EAGLE PICHER
(EAGLE-PICHER INDUSTRIES, INC.), CELOTEX, 85% mag cement, 301 and 352 JOHNS
MANVILLE (MANVILLE TRUST) insulating cement. Plaintiff recalls that the jobsite was
very dusty and that his clothes would get covered in dust. Plaintiff also delivered materials to
various jobsites on approximately 10 occasions. Plaintiff delivered materials to the Jack Tar
Hotel in San Francisco, California. CAHILL CONSTRUCTION (CAHILL CONSTRUCTION
CO., INC.) was the general contractor which employed laborers and cement finishers at the site.
Plaintiff observed CAHILL CONSTRUCTION (CAHILL CONSTRUCTION CO., INC.)
laborers Sweeping debris created by cutting of PHILIP CAREY (RAPID-AMERICAN
CORPORATION) asbestos-containing Pipe insulation and created by cutting of GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) flange gaskets. ANDERSON, ROWE &
BUCKLEY, INC. employed plumbers, pipefitters and sheetmetal workers at the Jack Tar Hotel.
Plaintiff recalis Philip Carey was the insulation contractor at the Jack Tar Hotel. Plaintiff
recalls Bill Houston was the Philip Carey supervisor at the Jack Tar Hotel. Plaintiff recalls the
following supervisor at the warehouse: Ray Scott, Tucson, Arizona. Plaintiff recalls the
following coworkers at the warehouse: Bill Heineche, Sr. (deceased); Bill Heineche, Jr.
(address unknown). Plaintiff currently contends that he was exposed to asbestos during this
employment.

"Plaintiff worked out of Heat & Frost Insulators and Asbestos Workers Local Union
No. 16, Plaintiff recalls applying asbestos-containing insulation to pipes, pumps, flanges,
valves, duct work, plenums, boilers and vessels. Plaintiff cut the asbestos-containing pipe
insulation with a hand saw. Plaintiff mixed asbestos cement and applied cement to fittings and
irregular surfaces. Plaintiff worked in proximity to the following trades: Plumbers, pipefitters,
sheet metal workers, electricians, sprinkler fitters, carpenters, laborers, lathers and plasterers,
drywallers, floor installers and ceiling installers. Plaintiff worked in proximity to plumbers
disturbing existing insulation and fireproofing. Plaintiff worked in proximity to > ipefitters
working on pumps and valves, and working with asbestos-containing gaskets and packing.
Plaintiff worked in proximity to sheet metal 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 lathers 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 using a circular saw to cut floor tiles that contained
asbestos. Plaintiff worked in proximity to ceiling installers disturbing existing asbestos-

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containing fireproofing insulation. Plaintiff cut asbestos-containing insulation with a power
saw and applied asbestos-containing canvas and asbestos cloth. Plaintiff currently contends that

he was exposed to asbestos during this employment.

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

Job Duties: Plaintiff carried materials to journeyman insulators. Plaintiff recalls working with
JOHNS-MANVILLE (MANVILLE TRUST) block insulation. 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. Plaintiff currently
contends he was exposed to asbestos during this employment.

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

Job Duties: Plaintiff insulated pipes under the loading docks and in the pipe hangers Plaintiff
installed asbestos-containing insulation on pipes and on the boiler in the boiler room. Plaintiff
recalls boilers manufactured by the following; FOSTER WHEELER CORPORATION
(FOSTER WHEELER LLC 'KA FOSTER WHEELER CORPORATION)) and BABCOCK
& WILCOX COMPANY. Plaintiff recalls using UNIBESTOS (UNARCO) insulation and

esium. Plaintiff recalls working near pipefitters installing pipes and asbestos-containing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff worked near
the installation of a new BELL & GOSSETT (ITT INDUSTRIES, INC.) pump which had
original manufacturer’s asbestos-containing 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 Job Title Dates
Universal Insulation Hewlett Packard Insulator 1959 (1-2 weeks)
520 6" Avenue Menlo Park, CA (Apprentice)

Menlo Park, CA

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

ipes. Plaintiff recalls scoring and cutting the block insulation with a handsaw. Plaintiff recalls
Taborers from Universal Insulation Company sweeping up MONOKOTE (W.R. GRACE &
CO.), PABCO (FIBREBOARD CORPORATION) pipecovering, and other debris. Plaintiff
recalls the following supervisor: Troy Cozby (deceased). Plaintiff recalls the following co-
worker: Rod Hochstrasser (deceased). Plaintiff currently contends that he was exposed to
asbestos during this employment.

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Location of Exposure

Employer Exposure Job Title Dates

ACES UC Berkeley (Central Insulator 1960-1962;

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

Job Duties: Plaintiff applied asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
and PABCO (FIBREBOARD CORPORATION) block insulation, calcium silicate
pipecovering, blue cement and mag cement to a boiler. Plaintiff recalls working near other
trades, including, but not limited to: pipefitters, boiler makers, and laborers. Plaintiff worked
in proximity to boilermakers employed by Bay Cities Asbestos Co., Ltd., JAMES

WHITTAKER (RAYMOND INTERIOR SYSTEMS-NORTH) laborers mixed and sprayed
asbestos-containing CAFCO ITED STATES MINERAL PRODUCTS COMPANY)
fireproofing and swept dried fireproofin overspray in plaintiff's work areas. Electricians
disturbed overhead asbestos-containing MONOKOTE (W.R. GRACE & CO.) fireproofing
while setting their conduit supports. Plaintiff worked in proximity to others who were
checking, removing and replacing asbestos-containing original manufacturer’s packing in new
BELL & GOSSETT (ITT INDUSTRIES, INC.) pumps. Plaintiff recalls the following
manufacturers of asbestos products: PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY). Plaintiff worked alongside pipefitters who were installing and
removing asbestos-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC
and FLEXITALLIC, INC. gaskets. Plaintiff recalls that CAL-STEAM SUPPLY COMPAN
supplied asbestos-containing FLEXITALLIC, INC. gaskets. Plaintiff recalls that they special
ordered asbestos containing ipe insulation from METALCLAD INSULATION
CORPORATION. WEBC UILDERS laborers swept and shoveled asbestos containing
PABCO (FIBERBOARD CORPORATION) and JOHNS MANVILLE (MANVILLE TRUST)
Thermobestos thermal insulation scraps and dust, Cafeo (UNITED STATES MINERAL
PRODUCTS COMPANY) fireproofing dust, and scraps from asbestos-containing
FLEXITALLIC and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets
near plaintiff on a recurring basis. Plaintiff recalls the following foreman: Robert Cantley (c/o
Brayton¢Purcell LLP). Plaintiff recalls the following co-worker: Earl Beck (deceased).
Plaintiff currently contends that he was exposed to asbestos during this employment.

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

Avon, CA (3 weeks)

Job Duties: Plaintiff applied asbestos-containing insulation to a large tank, Plaintiff applied
EAGLE-PICHER (EAGLE-PICHER INDUST RIES, INC.) asbestos-containing cement on the
heads and fittings. Plaintiff aj plied EAGLE PICHER mineral wool. Plaintiff applied KAYLO
{OWENS CO iG FIBER’ S) asbestos-containing insulation on pipes. Plaintiff recalls
using JOHNS-MANVILLE (MANVILLE TRUST) “Thermobestos” asbestos-containing
pipecovering, 85% 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., Ltd., 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 (deceased); and Laurance Hagen (c/o Brayton* Purcell
LLP). Plaintiff recalls the cllowing em loyees of PLANT INSULATION COMPANY

(PLANT INSULATION COMPA x: on Powers (c/o Brayton Purcell LLP); Steve Steele
{clo 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 3" 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 used asbestos-containing
JOHNS-MANVILLE (MANVILLE TRUST) pipecovering, EAGLE PICHER cement and all-
purpose cement at this site. Plaintiff installed asbestos-containing insulation on equipment and
pipes. Plaintiff 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 J.T.
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 from J.T. THORPE & SON, INC. Carl Ramsey (c/o
Brayton%Purcell LLP) was a member of the J.T. THORPE & SON, INC. crew. Plaintiff
worked near welders using asbestos-containing welding blankets, laborers sweeping up the site
and pipefitters installing gaskets, valves and pipes. Thurman Gates (deceased) was plaintiff's
supervisor. Plaintiff recalls the following co-workers: Charles Purcell (deceased), Jack Kish
(deceased); John Hoyt (c/o Brayton*Purcell LLP); Donald Cox (c/o Brayton%Purcell LLP); Ed
Story (deceased); Charlie Power (deceased). Plaintiff currently contends that he was exposed to
asbestos during this employment.

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

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

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

Job Duties: Plaintiff insulated domestic hot water pipes and ducts. Plaintiff used asbestos-
containing UNIBESTOS (UNARCO) pipecovering. Plaintiff recalls the following supervisor:
Richard Holmes (deceased). Plaintiff recalls the following co-workers: John Chulick (c/o
Brayton¢Purcell LLP); Ron Furia (deceased); Charles Tobey {clo 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

Western Asbestos McKinleyville High School Insulator 7/1961-10/1961;
3150 3" Street McKinleyville, C. 7/1962-5/1965
San Francisco, CA (3% weeks, on

and off)

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

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

San Francisco, CA

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

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

San Francisco, CA

Job Duties: Plaintiff recalls insulating pipes, a tank and vessels. Plaintiff used asbestos-
containing EAGLE PICHER cement, and asbestos-containing JOHNS MANVILLE
(MANVILLE TRUST) and KAYLO (OWENS CORNING FIBERGLAS) Pipecovering and
block insulation. Plaintiff worked near laborers, were employed by PLANT MAINTENANCE
(PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping existing asbestos-
containing pipe insulation, sweeping up the site and carrying products to the workers.
TIDEWA OIL (TEXACO, INC.) laborers were also sweeping and shoveling asbestos-
containing debris in plaintiff's presence at this site. TIMEC ‘C COMPANY, INC.)
workers were stripping asbestos-containing block insulation off the nearby coker, which spread

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| Robert Robbins and Leo Hansen (both dece:
| exposed to asbestos during this employment.

dust throughout plaintiff's work areas. PLANT ASBESTOS COMPANY FLAant
INSULATION COMPANY) personnel were applying asbestos-containing PABCO
(FIBREBOARD CORPORATION) calcium silicate Pipscovering near plaintiff for
approximately 3 days. Plaintiff saw CROCKETT ELECTRIC electricians performing electrical
work in his work areas. Plaintiff worked alongside pipefitters who were installing and
removing asbestos-containing FLEXITALLIC, INC. gaskets. SLAKEY BROTHERS delivered
asbestos cement piping to this site on flatbed trucks. Plaintiff observed cutting and laying of
that asbestos cement sping 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 3 Street Avon, CA 1 month)

San Francisco, 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) pij ecovering. Plaintiff's co-workers included
sed). Plaintiff currently contends that he was

Location of Exposure
Emplover Exposure Job Title Dates
Western Asbestos PG&E Powerhouse Insulator 1961-1965
3150 3" Street Pittsburg, CA (Imonth
| San Francisco, CA continuous work)

Job Duties: Plaintiff recalls installing asbestos pads and asbestos-containing JOHNS-

MANVILLE (MANVILLE TRUST) insulation. Plaintiff recalls J.T. 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 firebrick, 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 CONT!
COSTA ELECTRIC, INC who were disturbing asbestos-containing pi e insulation while
installing conduit. Plaintiff recalls maintenance personnel from PG&E were removing
asbestos-containing materials from this boiler. Plaintiff recalls working near pipefitters who
were removing asbestos from pipes. Plaintiff also recalls other trades sweeping the area where
he was working. Plaintiff recalls the following co-workers: Earl Riggs (deceased); Doyle
Davidson (deceased); Ed Story {deceased); Ronald Furia (deceased); Jack Jagoda (c/o Paul &
Hanley); Harry Fry ‘foreman) (deceased); 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.

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Location of Exposure

Employer Exposure Job Title

Western Asbestos Colgate Palmolive Insulator 7/1961-10/1961;
3150 3" Street Berkeley, CA 711962-5/1965
San Francisco, CA (5 weeks, on and

off)

Job Duties: Plaintiff installed asbestos-containing JOHNS MANVILLE (MANVILLE TRUST)
pipecovering, and asbestos-containing EAGLE PICHER and 301 cement onto a tank. Plaintiff
used mag insulation, JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff
recalls working near COLGATE PALMOLIVE laborers sweeping around his work area.
Plaintiff worked alongside PACIFIC MECHANICAL Company pipefitters who were

fabricating iron piping systems. Plaintiff recalls the following contractor: PACIFIC
MECHANICAL, Plaintiff observed L.J. KRUSE COMPANY Eipefiters handling asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets. Plaintiff
observed L.J. KRUSE repacking one new valve using asbestos-containing valve packing
material. Plaintiff recalls the following supervisor: Robert Robbins (deceased), 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 Job Title Dates
Western Asbestos Gerber Foods Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 711962-5/1965
San Francisco, CA Geeks on and
0

Job Duties: Plaintiff wrap ed asbestos-containing insulation with chicken wire and applied all-
ose cement over it. Plaintiff applied asbestos-containing JOHNS MANVILLE
MANVILLE TRUST) calcium silicate Bi covering and insulation cements. Plaintiff applied
JOHNS MANVILLE (MANVILLE TRUST) 352 BLUE cement. Plaintiff worked near
ipefitters installing Pipes valves and asbestos-containing GARLOCK (GARLOCK SEALING
‘ECHNOLOGIES, LLC) gaskets. Plaintiff recalls the following co-workers: Bennie Norrie
(deceased); Lou Hansen (deceased); Robert Robbins (deceased). Plaintiff currently contends

at 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 Bi efitters wor ing on a ump, which involved replacement of asbestos-containing
GARLOCK (GARLOCK 5! iG TECHNOLOGIES, LLC) gaskets. Plaintiff recalls the
following co-workers: Everett Waining (San Jose, California); fim Kearney (deceased); Jim
White, Jr. (Napa, California). Plaintiff currently contends that he was exposed to asbestos
during this employment.

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Location of Exposure

Employer Exposure Job Title

Western Asbestos Pacific Bell Telephone Insulator 1961-1965
3150 3" Street San Francisco, CA (3 months)
San Francisco, CA

Job Duties: Plaintiff installed fiberglass duct wrap and asbestos-containing MUNDET
(CROWN CORK & SEAL COMP, , INC.) 85% magnesia pipe insulation in an 8 story
building. Plaintiff worked in the boiler room where asbestos insulation was being removed and
installed Plaintiff worked near laborers who were sweeping the floors and _pipefitters who were
installing and removing asbestos-containing GARLOCK (GARLOCK SEALING
TECHNOLOGIES, LLC) gaskets. Plaintiff worked in proximity to FOLEY ELECTRIC
electricians. Plaintiff observed FOLEY ELECTRIC personnel disturbing previously sprayed
asbestos-containing overhead fireproofing while setting supports for their electrical conduit in

laintiff'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’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 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

CANAD! BLUE asbestos shorts, 127 Blue Cement 85% magnesia cement and EAGLE
PICHER (EAGLE-PICHER INDUSTRIES, INC.) 66 cement. Plaintiff also applied asbestos-
containing PABCO (FIBREBOARD CORPORATION) and OWENS CORNING FIBERGLAS
asbestos Pipe insulation to flanges on a boiler. Plaintiff recalls that the asbestos-containing
PABCO (FIBREBOARD CORPORATION) and OWENS CORNING (OWENS CORNING
FIBERGLAS) asbestos pipe insulation was Supplied by PG&E. Plaintiff recalls general
contractor C.C. MOORE (C.C. MOORE & CO, ENGINEERS) employing laborers. Plaintiff
recalls Seeing others working on STOCKHAM (SVI CORPORATION) valves and strainers
which had as! estos-containing ANCHOR (COLTEC INDUSTRIES, INC.) packing on them.
Plaintiff recalls working near boilermakers, emplo ed 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 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
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 (c/o Brayton*Purcell LLP); Jim White, Jr. (Napa,
California); Bill Armstrong (deceased); Ronald Furia (deceased); John Hoyt (c/o
Brayton’Purcell CLP Art Klimack c/o Brayton¢Purcell LLP; Al Leandro (c/o
Brayton¢Purcell LLP); Walter Lee (c/o Brayton*Purcell LLP); Derrell Cozby (c/o
Brayton¢Purcell LLP); Maurice Lawrence (c/o Brayton¢Purcell LLP); John Kiss (deceased),
Paul Westbrook (c/o Brayton*-Purcell LLP); Carl Ramsey (c/o Brayton*Purcell LLP); Dick
Nelson (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment.

K\injured\t9349\pld\Al-supsac3.wpd 10 ECSOo Oo NY DW BF WwW YD em

RNR YK RN RN NY SE eH ew me me ee ee
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Location of Exposure

Employer Exposure Job Title Dates

Western Asbestos Hercules Powder Insulator 7/1961-10/1961;

3150 3" Street Hercules, CA 711962-5/1965

San Francisco, CA Caronth, on and
0!

Job Duties: Plaintiff installed KAYLO (OWENS CORNING FIBERGLAS) pipecovering.
Plaintiff ‘applied foamglass insulation to Piping: Plaintiff worked alongside pipefitters who
were installing and removing FLEXIT Al LIC, INC. Baskets in faintiff's resence. Plaintiff
worked in proximity to METALCLAD INSULATION CORPORATION insulators who were
applyin 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 711962-5/1965
San Francisco, CA {2-3 months, on
and off)

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

Davidson (deceased); Harry Fry (deceased); Robert Evans, Ray House (deceased). Plaintiff
currently contends that he was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Bethlehem Steel Insulator 7/1961-10/1961;
3150 3" Street Shipbuilding 711962-5/1965
San Francisco, CA San Francisco, CA
Triple A Machine Shop (on and off for
(Pier 64) approx. 1 week
San Francisco, CA each time)
Willamette Shipyard
Richmond, CA

Mt

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BNRRERBRRS FeBDABDEBEB ES

Employer
Western Asbestos

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

K\Ainjured\19349%ple\AI-supsac3.wpd

Location of
Exposure

Bethlehem Steel
Shipbuilding
San Francisco, CA

Job Title
Insulator

Pacific Ship Repair
(Pier 36)
San Francisco, CA

Todd Shipyard
Oakland, CA

Matson Navigation
(Pier 30)
San Francisco, CA

Naval Air Station
Alameda, CA

JOSEPH P. KENNEDY
R.

(DD-850)

CHEYENNE
(1-AG-174)
HAWAIIAN PLANTER
(1945)

GRAFFIAS

(AF-29)

MATHEWS

(AKA-96)

MERRICK

(AKA-97)

TWINING

(DD-540)

GENERAL W.A. MANN
(AP-112)

MONTEREY
(1952)

BLAND
(APA-134)

PONT!
(WPG-70)

12

Exposure
Dates

7/1961-10/1961;

711962-5/1965

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PN PY YPN NNR DY ee Be ~~ ew ow

Location of Exposure
Employer Exposure Job Title

Western Asbestos Bethlehem Steel Insulator 7/1961-10/1961;
3150 3” Street Shipbuilding 7/1962-5/1965
San Francisco, CA (contd.) | San Francisco, CA

CALIFORNIAN
(1946)

1963-1965
(1943)

ROSE KNOT
(1945)

H TIAN
(1946)

Job Duties: Plaintiff insulated Pi es, turbines, valves, and boilers using asbestos-containing
JOHNS MANVILLE (MANVILLE TRUST) and PABCO (FIBREBOARD CORPORATION)
block and Pipecovering. Plaintiff removed and repaired asbestos-containing insulation.
Plaintiff used asbestos cloth to wrap around valves and boilers. Plaintiff recalls using EAGLE
PICHER cements and 352 Blue Mud cement. Plaintiff worked near pipefitters who were
removing asbestos-containing insulation and who were installing pipes, asbestos-containing
gaskets, valves and pum s. Plaintiff recalls pipefitters in his work area installing asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets and cutting
gaskets from sheet gasket material. Plaintiff recalls welders using asbestos cloth during the
course of their work. Plaintiff worked near the FOSTER WHEELER (FOSTER WHEELER
LLC (EKA FOSTER WHEELER CORPORATION)) boilers aboard the HAWAILAN
PLANTER, the GRAFFIAS, the MATHEWS, the ME) the GENERAL W.A. MANN.
the MONTEREY and the ROSE KNOT. Plaintiff observed other workers installing and
removing asbestos-containing GARLOCK. (CARLOCK 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
sence. Plaintiff recalls the following coworkers: Tom Andrews (c/o Brayton*Purcell LLP);
joseph O’Balle (c/o Brayton*Purcell LLP); Jack Barbera (address unknown), Gene Bennett,
Vacaville, California; Rudolph Brajkovick (deceased); John Byron (address unknown); Robert
Evans (deceased); Harry Fry (deceased); Ronald Furia (deceased); Thurman Gates (deceased);
Victor Gomez (c/o BraytonPurcell 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
jlorgensen (address unknown); James Logue (c/o Brayton*Purcell LLP); Tony Lopes, Fremont,
California; Andy Grant (address unknown); Richard Porter (address unknown); Joseph
Sandoval (deceased); Robert Sandoval (deceased); William Stein (address unknown); Ed Story
(deceased); Fred Strickland (deceased); Howard racy (deceased); Jack Kish (deceased); Paul
chiebold (San Francisco, California); Dale Wright (Santa Rosa, California); Andy Grant
(address unknown); Lowell Squires (deceased); Jim White, Jr. (Napa, California); Benjamin
Norrie (deceased), Plaintiff currently contends that he was exposed to asbestos during this
employment.

MW
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Kyinjured\#9349\pld\A L-supsac3. wpd 13 ECSeo me NY DA HW BF WN

Location of Exposure

Employer Exposure Job Title Dates

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

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

San Francisco, CA Gareeks. on and
0!

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-containing PABCO
(IBREBOARD CORPORATION) cal sil pi e insulation, FOSTERS (BAYER

ROPSCIENCE INC.) 30-36 mastic and J 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 Ti Dates
Western Asbestos Western Asbestos Pad Insulator 7/1961-10/1961;
3150 3 Street Shop, 3 Avenue and 7/1962-5/1965
San Francisco, CA Army, San Francisco, CA S days, on and
0!

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

Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Humboldt Bay Powerhouse Insulator 7/1961-10/1961;
3150 3 Street (PG&E), 7/1962-12/1962
San Francisco, CA Eurek fumboldt County, Caronnss on and
0!

Job Duties: Plaintiff carried asbestos-containing materials to co-workers. Plaintiff applied
asbestos-containing mag blocks and Pipecovering to pipes valves and vessels. Plaintiff installed
352 cement and FOSTER’s (BAYER CROPSCIENCE INC.) Fibrous Adhesive. Plaintiff
applied the FOSTER’s (BAYER CROPSCIENCE INC.) Fibrous Adhesive to blocks, applied

¢ blocks 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

laintiff’s work areas. Plaintiff used asbestos-containing JOHNS-MANVILLE MANVILLE

UST), 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.

Mt
Mf

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Location of Exposure

Employer Exposure Job Title

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

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

San Francisco, CA (Potrero Station) (2 to 3 yveeks on
and o:

Job Duties: Plaintiff recalls Working ona boiler during a remodel. Plaintiff recalls applying
KAYLO (OWENS CORNING FIBERGLAS) asbestos blocks and PABCO (FIBREBOARD
CORPORATION) all-purpose cement. 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 711962-5/1965
San Francisco, CA Caronth, on and
0

Job Duties: Plaintiff carried materials to the journeymen. Plaintiff applied KAYLO (OWENS
CORNING FIBERGLAS) asbestos blocks, PABCO (FIBREBO. CORPORATION)
cement and 352 BLUE cement to a large tank. Plaintiff recalls working near pipefitters
installing pipes, valves, pumps and FLEXITALLIC, INC. gaskets. Plaintiff recalls the
following foreman: Robert Robbins (deceased). Plaintiff recalls the following co-workers:
Lou Hansen (deceased); Robert Sandoval (deceased); Charles Tobey (c/o Brayton Purcell
LLP); Earl Riggs (deceased); Dovle Davidson (deceased). Plaintiff currently contends that he

was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure Job Title Dates
Western Asbestos Shell Oil Insulator 7/1961-10/1961;
3150 3" Street Martinez, CA 7/1962-5/1965
San Francisco, CA “ weeks, on and
o!

Job Duties: Plaintiff cut asbestos block insulation and mixed and applied insulating cement.
Plaintiff worked with asbestos 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-PMI installing pipes, new
LUNKENHEIMER valves, pumps and asbestos-containing DURABLA (DURABLA
MANUFACTURING COMPANY, INC.) gaskets. Plaintiff also observed FOLEY-PMI
pi fitters removing existing DURABLA flange gaskets in his presence, on qj proximately 4to
occasions. P: ASBESTOS COMPANY (PLANT INSULATION C ANY)
supplied asbestos-containing insulation materials, including PABCO (FIBREBOARD
Ci REORA TION) pipe covering to the site. Laborers employed by general contractor ALBAY
CONSTRUCTION swept and shoveled asbestos-containing JOHNS TLLE (MANVILLE
TRUST) Thermobestos block insulation debris, asbestos-containing insulation cement debris
and dust, and debris created by sawing of 85% magnesia pipe covering. Plaintiff recalls the
following foreman: Robert Robbins (deceased). Plaintiff recalls the following co-workers:
Lou Hansen (deceased); Jim White, Jr. (deceased ); Charles Tobey (c/o Brayton¢-Purcell LLP);

K Ninjured\19349\pid\Al-supsac3.wpd 15 ECSOo Ge DDH WH & WN

wv N YY NM NY NN NN ee
BReRRREBKRERSESGSAREBDESEHRAS

Robert 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
Western Asbestos PG&E Insulator 7/1961-10/1961;
3150 3" Street Oakland, CA 7/1962-12/1962
San Francisco, CA Greeks. on and
o!

Job Duties: Plaintiff removed asbestos block insulation and existing insulation on a boiler,
Plaintiff mixed asbestos cement in a trough with a hoe. Plaintiff installed asbestos-containing
PABCO (FIBREBOARD CORPORATION) cement. Plaintiff recalls working near
boilermakers, and near pipefitters who were installing gaskets. Plaintiff observed PG&E
laborers sweepin and cleaning asbestos laden dust and debris in plaintiff's work areas.

is

Plaintiff recalls the following supervisor: Benjamin Norrie (deceased). Plaintiff currently
contends that he was exposed to asbestos during this employment.

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

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 LUNKENHEIMER COMPANY
valves, while insulating a boiler and associated piping: Plaintiff had to crawl into tight areas
that contained loose asbestos insulation, Plaintiff worked near pipefitters installing Pies,
valves, and asbestos-containing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
and FLEXITALLIC, INC. gaskets. Pipefitters also were cutting and installing packing into
LUNKENHEIMER valves. Plaintiff recalls the following supervisor: Benjamin Norrie
(deceased), Plaintiff recalls the following co-workers: Lou Hansen (deceased); Robert
Sandoval (deceased), Ed Meyer (eo 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 Missile Base Insulator 7/1961-10/1961;
3150 3" Street Live Oak, CA 711962-5/1965
San Francisco, CA Cpronth, on and
°

Job Duties: Plaintiff applied rubber insulation and 520 mastic. Plaintiff worked near other
tradesmen who installed asbestos-containing ANCHOR (COLTEC INDUSTRIES, INC.)
packing, and asbestos-containing DURABLA (DURABLA MANUFACTURING COMPANY,
INC.) gaskets. Plaintiff observed workers removing existing DURABLA gaskets on numerous
occasions in his presence. Plaintiff worked near welders who were using asbestos blankets.
Plaintiff worked near electricians and near pipefitters who were installing pipes, asbestos-
containing DURABLA (DURABLA MANUFACTURING COMPANY, INC.) gaskets, and
pumps. Laborers built scaffolds and swept asbestos-containing PABCO (FIBREBOARD

KAlnjured\19349\pld\Al-supsac3.wpd 16 ECSoD YN DH BF WH

NN BY BW DW YW NR RD ttt
ond A AB YON |§ SO wea DH BW NY |

CORPORATION) insulation debris, created by PLANT ASBESTOS COMPANY (PLANT
INSULATION COMPANY), in Plaintiff's work areas. PLANT ASBESTOS COMPANY
(PLANT INSULATION COMPANY) employed another insulation crew that was applying
asbestos-containing PABCO (FIBREBOARD CORPORATION) pipe insulation 5 to 30 feet
from plaintiff. Plaintiff recalls the following supervisor: Jim Clark (address unknown).
Plaintiff recalls the following co-workers: Donald Cox (c/o Brayton%Purcell LLP); Dale
Wright (Santa Rosa, California); Tiny Evans (deceased); Paul Brown (c/o 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 University of California Insulator 7/1961-10/1961;
3150 3” Street Berkeley. CA 7/1962-5/1965
San Francisco, CA (Boiler Plant) (3 weeks)

Job Duties: Plaintiff worked in the boiler plant. Plaintiff applied KAYLO {OWENS
CORNING FIBERGLAS) asbestos block insulation to the boiler piping. Plaintiff applied
BENJAMIN FOSTER’S (BAYER CROPSCIENCE INC.) Fibrous Adhesive to the lock
insulation, applied the blocks to the boiler, and “rasped off” the dried, extruded FOSTER’S
(BAYER CROPSCIENCE INC.) Fibrous Adhesive via use of a metal rasp. Plaintiff recalls
working near laborers sweeping up asbestos-containing debris. Plaintiff recalls working near
pipefitters installing Pipes. valves and asbestos-containing GARLOCK (GARLOCK SEALING
TECHNOLOGIES, LLC) gaskets. BAY WESTERN (BRAGG INVESTMENT COMPANY,
NO) ‘was a contractor employing pipefitters removing asbestos containing pipe insulation.
BAY WESTERN (BRAGG INVESTMENT COMPANY, INC.) laborers swept and shoveled
asbestos-containing debris and dust in plaintiff's work areas at this site. General contractor
WEBCOR BUILDERS laborers’ swept and shoveled asbestos-containing insulation debris in
plaintiff's work areas, on a daily basis. Plain