Answer: ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS

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                                JEFFERY J. FADEFF, ESQ. (SBN 111497)
jfadeff@behblaw.com

RESHMA A. BAJAJ, ESQ. (SBN 227106) ELECTRONICALLY
tbajaj@behblaw.com
BASSI], EDLIN, HUIE & BLUM LLP cope tot ED
500 Washington Street, Suite 700 County of San Franckco
San Francisco, CA 94111
Telephone: (415) 397-9006 JUL 05 204
Facsimile: (415) 397-1339 Clerk of the Court

BY: VANESSA WU

Deputy Clerk

Attorneys for Defendant
J.T. THORPE & SON, INC.

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

ROBERT ROSS and JEAN ROSS, Case No. CGC-10-275731

Plaintiffs, DEFENDANT J. T. THORPE & SON,
INC.'S ANSWER TO THIRD AMENDED
COMPLAINT FOR PERSONAL INJURY
AND LOSS OF CONSORTIUM-
ASBESTOS

)
)
)
)
vs. }

C.C. MOORE & CO. ENGINEERS; )
Defendants as Reflected on Exhibit | attached )
to the Summary Complaint herein; and DOES )
1-8500, )
)

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Defendants.

Defendant J. T. THORPE & SON, INC. ("Defendant"), in answer to the third amended
complaint of Plaintiffs ROBERT ROSS and JEAN ROSS, ("Plaintiffs”), admits, denies and
alleges as follows:

Pursuant to the provisions of section 431.30(d) of the Code of Civil Procedure, Defendant
denies each and every, all and singular, both generally and specifically, the allegations of
Plaintiffs’ unverified complaint as they relate to Defendant only, and further denies that Plaintiffs
have been damaged as alleged or at all, by reason of any act or omission on the part of Defendant!
or its agents, servants, or employees.

FIRST DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,Plaintiffs’ Complaint fails to state facts sufficient to constitute a cause of
action against Defendant.
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs have failed to join all persons and parties needed for a just adjudication of this action.
THIRD DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs’ claims are barred by laches, waiver and/or estoppel.
FOURTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

this Court does not have subject matter jurisdiction over this action or alternatively that the Court
lacks jurisdiction due to insufficiency of process or the service thereof and/or improper venue.
FLETH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs have failed to commence this action within the time required by the applicable statute
of limitations, including but not limited to California Code of Civil Procedure sections
337.1,337.15, 338(a), 338(d), 340(3), 340.2, and 343.
SIXTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs were careless and negligent in and about the matters alleged in the complaint and said
carelessness and negligence of Plaintiffs proximately contributed to the happening of the
accident, incident and occurrence alleged in the complaint, and to the injuries, losses and
damages complained of therein, if any there were, and said contributory negligence bars a
recovery or proportionately reduces any potential verdict.
SEVENTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

Plaintiffs failed to mitigate his alleged damages, if there were any.

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,EIGHTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
if Plaintiffs were injured by products used or installed at Defendant's premises, which is denied,
such injury occurred after the expiration of the useful safe life of such products.

NINTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
if Plaintiffs suffered any damages, which is denied, such damages were the sole and proximate
result of an unavoidable accident,

TENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
if Plaintiffs suffered any damages, which is denied, such damages were caused and/or
contributed to by Plaintiffs’ misuse of the product or products and Plaintiffs’ recovery should be
barred or reduced accordingly.

ELEVENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
if Plaintiffs suffered any damages, which is denied, such damages were solely and proximately
caused by material modifications or alterations of the product or products involved in the action
after it or they left the custody and control of Defendant.

TWELFTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
any asbestos-containing product or products alleged to have caused Plaintiffs' injuries were
manufactured, used, installed and/or distributed in mandatory compliance with specifications
promulgated by the United States government under its war powers, as set forth in the U.S.
Constitution, and that any recovery by Plaintiffs is barred as a consequence of the exercise of
those sovereign powers.

THIRTEENTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

any product or products alleged by Plaintiffs to have caused their injuries were manufactured,

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,installed, used or distributed in compliance with specifications provided by third parties to
Defendant and/or in compliance with all applicable healthy and safety statutes and regulations.
FOURTEENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
if Plaintiffs suffered any damages, which is denied, the risk of any such damages was not
foreseeable to Defendant. Defendant at all times material hereto acted in accordance with the
industry custom and practice and the state of scientific knowledge available to manufacturers,
installers and/or users of asbestos-containing products.

FIFTEENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
it received no notice of any dangerous, hazardous or defective condition or any breach of
warranty, either expressed or implied.

SIXTEENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs' claims against Defendant are barred by the holding of Privette v. Superior Court
(1993) 5 Cal. 4th 689.

SEVENTEENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs’ exposure to any asbestos-containing product or products allegedly used or installed at
Defendant's premises was minimal and insufficient to establish the probability that said product
or products were a legal cause of Plaintiffs’ alleged injuries.

EIGHTEENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
this action is barred by the applicable state and/or federal industrial insurance and/or Worker's
Compensation laws, including, but not limited to, California Labor Code Sections 3601 and
3602, and 33 U.S.C. Section 905.

NINETEENTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,at the time of injuries alleged in Plaintiffs’ Complaint, Plaintiffs were employed by persons other
than Defendant; was entitled to receive and did receive Worker's Compensation benefits from
said employer(s) or their insurers; and that said employer(s) were negligent and careless in and
about the matters referred to in Plaintiffs’ complaint. Defendant is, therefore, entitled to set- off
any such benefits received by Plaintiffs against any judgment rendered in Plaintiffs’ favor and
said employer(s) are barred from any recovery by lien or otherwise against Defendant in
connection with this matter.
TWENTIETH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs voluntarily and knowingly assumed the alleged risks and hazards incident to the
alleged operations, acts and conduct at the times and places alleged in Plaintiffs’ Complaint and
that Plaintiffs’ said acts proximately caused and contributed to the alleged damages, if any there
were.

TWENTY-FIRST DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
at all times relevant to the matters alleged in Plaintiffs’ complaint, Plaintiffs’ employers were
sophisticated users of asbestos-containing products and said employers’ negligence in providing
said products to its employees was a superseding and/or intervening cause of Plaintiffs’ injuries
or damages, if any there were.

TWENTY-SECOND DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
there was no concert of action among Defendant and other defendants to this action and that any
alleged liability or responsibility of Defendant, which is denied, is minimal in proportion to the
alleged liability and responsibility of other persons and entities including the other defendants
herein, Plaintiffs should therefore be limited to seeking recovery from Defendant for the
proportion of alleged injuries and damages for which Defendant is allegedly liable or

responsible, all such alleged liability and responsibility being denied.

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,TWENTY-THIRD DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, to the extent that the
complaint alleged that Defendant has "market share" liability or "enterprise lability," the
complaint fails to state facts sufficient to constitute a cause of action against Defendant.

TWENTY-FOURTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
it is entitled to set-off any settlement, judgments, or similar amounts received by Plaintiffs,
against any judgment rendered against it in Plaintiffs’ favor.

TWENTY-FIFTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges, in
accordance with Section 1431.2 of the Civil Code, known as the Fair Responsibility Act of 1986,
that if Plaintiffs’ Complaint states a cause of action, each Defendant is liable, if at all, only for
those non-economic damages allocated to each Defendant in direct proportion to each
defendant's percentage of fault, if any. Defendant requests a judicial determination of the
amount of non-economic damages, if any. Defendant also requests a judicial determination of
the amount of non-economic damages, if any, allocated fo Defendant in direct proportion to
Defendant's percentage of fault, if any, and a separate judgment in conformance herewith.

TWENTY-SIXTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
the damages and injuries, if any, were proximately caused or contributed to, in whole or in part,
by the negligence or fault of other acts and/or omissions of persons or entities other than
Defendant, for which Defendant is not responsible,

TWENTY-SEVENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
neither the complaint nor any purported causes of action alleged therein state facts sufficient to
entitle Plaintiffs to an award of punitive damage against Defendant.

TWENTY-EIGHTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,Plaintiffs’ instant action is barred or, alternatively, merged into a prior cause of action for which
Plaintiffs have previously sued upon, recovered, and dismissed with prejudice, thereby requiring
a complete extinguishment of the instant action due to the doctrines of res judicata and collateral
estoppel.

TWENTY-NINTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs’ instant action is barred and discharged, pursuant to Title 11 U.S.C. Section 1141(d),
and that Plaintiffs’ action violates the pending injunction against such claims that exists, by
operation of law, pursuant to Title 11 U.S.C. section 524(a)(2).

THIRTIETH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
its products were manufactured, produced, supplied, sold and distributed pursuant to contract
with the United States government, and that any recovery by Plaintiffs is barred by consequence
of the judicially recognized doctrine of immunity conferred upon that contractual relationship
and any occurrence arising therefrom.

THIRTY-FIRST DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

the allegations of the Complaint are uncertain, vague and ambiguous.

THIRTY-SECOND DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
the allegations of the complaint should be dismissed pursuant to Sections 583.210 through
583,250, and 583.410 through 583.430 of the California Code of Civil Procedure, and other
applicable code sections,

THIRTY-THIRD DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
it does not have and never has had a successor, successor-in-business, successor-in-product line
or portion thereof, successor-in-interest, assignee, predecessor, predecessor-in-business,

predecessor-in-product line or portion thereof, predecessor-in-interest, partner, subsidiary, whole

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,or partial or ownership or membership relationship with the entity upon which Plaintiffs base
their allegations of liability.
THIRTY-FOURTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
it did not have a sufficient market share with respect to products and materials which Plaintiffs
allege caused the alleged injuries and damages. Defendant may not be held liable to Plaintiffs
for any alleged share of said market or upon any theory premised upon market-share liability.

THIRTY-FIFTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

if Plaintiffs sustained injuries or damages attributable to the use of any product researched,
tested, studied, manufactured, fabricated, inadequately researched, designed, inadequately tested,
labeled, assembled, distributed, leased, bought, offered for sale, sold, inspected, serviced,
installed, contracted for installation, repaired, marketed, warranted, arranged, rebranded,
manufactured for others, packaged, advertised and/or which contained or lacked warnings by
Defendant, which allegations are expressly denied, the injuries or damages were proximately
caused by the unreasonable and unforeseeable misuse, abuse, alteration, or improper
maintenance of the product by Plaintiffs or by others.

THIRTY-SIXTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
at all times mentioned, Plaintiffs consented to the alleged acts of Defendant.
THIRTY-SEVENTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
all claims asserted by Plaintiffs were proximately caused by a superseding, intervening cause.

THIRTY-EIGHTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
the entire complaint and each cause of action thereof, is barred on the grounds that the products
or materials referred to in the complaint, if any, were not a substantial factor in bringing about

the injuries and damages alleged by Plaintiffs.

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,THIRTY-NINTH DEFENSE
AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

Plaintiffs are not entitled to an award of punitive or exemplary damages in this action. Such an
award would be unconstitutional unless Defendant is accorded the safeguards provided under the
Constitution of the State of California and the Fourth, Fifth, Sixth, Eighth, and Fourteenth
Amendments to the United States Constitution.

FORTIETH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

to the extent Plaintiffs’ claims arise out of contract, Plaintiffs’ claims do not state facts sufficient
to entitle Plaintiffs to an award of punitive or exemplary damages against Defendant.
FORTY-FIRST DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiff, at all times mentioned, were not in privity of contract with Defendant, and that said
lack of privity bars any recovery by Plaintiffs against Defendant under any theory of breach of
warranty.

FORTY-SECOND DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

Plaintiffs failed to give adequate and timely notice of any alleged breach of warranty.

FORTY-THIRD DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs’ entire complaint is barred by the Statute of Frauds to the extent that any such causes off
action are based on alleged oral agreements.

FORTY-FOURTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
all products and materials researched, tested, studied, manufactured, fabricated, inadequately
researched, designed, inadequately tested, labeled, assembled, distributed, leased, bought,
offered for sale, sold, inspected, serviced, installed, contracted for installation, repaired,

marketed, warranted, arranged, rebranded, manufactured for others, packaged, advertised and/or

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,which contained or lacked warnings by Defendant, which allegations are expressly denied, were
not defective in any manner, as said products and materials conformed with the state-of-the-art in|
existence at all times mentioned in the complaint.
FORTY-FIFTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
its alleged actions, which are the subject of the complaint, were lawful.
FORTY-SIXTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
its alleged actions, which are the subject of the complaint, were justified.
FORTY-SEVENTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs lacks standing to sue Defendant.

FORTY-EIGHTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
any danger or defect on the premises was obvious or could have been observed by Plaintiffs’
exercise of reasonable care.

FORTY-NINTH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that

it warned Plaintiffs’ employers of all dangers on the premises known to Defendant.
FIFTIETH DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
Plaintiffs have improperly split his causes of action and seeks to maintain a duplicative lawsuit
based on the same facts and circumstances as a lawsuit previously filed.

FIFTY-FIRST DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
it presently has insufficient knowledge or information on which to form a belief as to whether it
may have additional, as yet unstated, defenses available. Defendant reserves the right to assert

additional defenses in the event discovery indicates that they would be appropriate.

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,FIFTY-SECOND DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
at all times relative to the matters alleged in the complaint, each of Plaintiffs’ employers, other
than defendant, were sophisticated users of asbestos-containing products and each of them knew
or should have known of the risk or danger of asbestos such that Defendant had no duty to warn

Plaintiffs or his employers pursuant to the holding of Johnson y. American Standard. Inc. (2008)

43 Cal, 4th 56.
FIETY-THIRD DEFENSE

AS A SEPARATE DEFENSE TO EACH CAUSE OF ACTION, Defendant alleges that
at all times relevant to the matters alleged in Plaintiff's compliant, Plaintiff's employers,
including the US Navy, were in control of the premises where Plaintiff's alleged asbestos
exposures occurred and said employers, including the US Navy, owed a duty to Plaintiff to
exercise reasonable care in the management and control of said premises in order to avoid
exposing workers such as Plaintiff to an unreasonable risk of harm and to avoid causing injury to
workers such as Plaintiff.
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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,WHEREFORE, Defendant prays for judgment as follows:

1. That Plaintiffs take nothing by reason of his complaint herein;

2. That judgment be entered in favor of Defendant;

3. For costs of suit incurred herein;

4, For appropriate credits and set-offs arising out of any payment of Workers’

Compensation benefits as alleged above;

5. For a judicial determination of the amount of non-economic damages, if any,
allocated to Defendant in direct proportion to J. T. THORPE & SON, INC.'s percentage of fault,
if any, and a separate judgment in conformance therewith; and

6. For such other and further relief as the Court may deem just and proper.

Date: July 3, 2012 BASSI, EDLIN, HUIE & BLUM LLP

/S/ RESHMA A. BAJAT

RESHMA A. BAJAJ, ESQ. (SBN 227106)
Attorneys for Defendant

J.T. THORPE & SON, INC.

BASSI, EDLIN, HUIE & BLUM LLP

500 Washington Street, Suite 700

San Francisco, CA 94111

Telephone:(415) 397-9006

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J.T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED COMPLAINT FOR PERSONAL INJURY AND LOSS OF CONSORTIUM]
- ASBESTOS,Re: Robert Ross, et al. v. C.C. Moore & Co. Engineers, et al.
San Francisco County Superior Court Case No. CGC-10-275731

PROOF OF SERVICE — ELECTRONIC TRANSMISSION

STATE OF CALIFORNIA/COUNTY OF San Francisco

Tam a citizen of the United States and an employee in the County of San Francisco. I
am over the age of eighteen (18) years and not a party to the within action. My business
address is BASSI, EDLIN, HUIE & BLUM LLP, 500 Washington Street, Suite 700, San
Francisco, California 94111.

On the date executed below, I electronically served the document(s) via LexisNexis
File & Serve, described below, on the recipients designated on the Transaction Receipt located
on the LexisNexis File & Serve website.

DEFENDANT J. T. THORPE & SON, INC.'S ANSWER TO THIRD AMENDED
COMPLAINT FOR PERSONAL INJURY
AND LOSS OF CONSORTIUM-
ASBESTOS
On the following parties:

PLEASE SEE SERVICE LIST PROVIDED BY LEXISNEXIS

I declare under penalty of perjury that the foregoing is true and correct and that this
document is executed on July 5, 2012, at San Francisco, California,

/s/ ALISHA C. PEMBER

ALISHA C. PEMBER

529259

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PROOF OF SERVICE,