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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
  • 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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                                LAW ORFICES

IMAI, TADLOCK, KEENEY & CORDERY, LLP

SUITE 1309

100 BUSH STREET

(415) 675-7008

Oo Ww DH Mm

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

Tina Yim, Esq. (Bar No, 232597)

IMAI, TADLOCK, KEENEY & CORDERY, LLP ELECTRONICALLY
100 BUSH STREET, SUITE 1300

SAN FRANCISCO, CA 94104 FILED
Telephone: (415) 675-7000 Superior Court of California,

Facsimile: (415) 675-7008 County of San Francisco
MAR 23 2012
Attorneys for Defendant Clerk of the Court
WEBCOR BUILDERS, INC. BY: VANESSA WU
Deputy Clerk
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, CASE NO.: CGC-10-275731
(ASBESTOS)
Plaintiffs,
DECLARATION OF TINA YIM IN
v. SUPPORT OF DEFENDANT WEBCOR
BUILDERS, INC.’S OPPOSITION TO
PLAINTIFFS' MOTION TO
C.C. MOORE & CO. ENGINEEERS, et al., CONSOLIDATE ACTIONS AND
CONTINUE TRIAL DATE
Defendants. Complaint Filed: December 17, 2010
Trial Date: Not yet set
Date: April 2, 2012
Time: 9:30 a.m.
Dept: 503
Judge: Hon. Teri L. Jackson
|, Tina Yim, declare:
1. Tam an attorney at law duly licensed to practice law before all the courts of the

State of California and am an associate with Imai, Tadlock, Keeney & Cordery, LLP, attorneys of
record for defendant Webcor Builders, Inc. in the above-entitled matter.

2. Attached hereto as Exhibit A is a true and correct copy of the relevant portions of
Robert Ross’ Complaint captioned Robert Ross v. Asbestos Defendants (BP), San Francisco

Superior Court Case No. CGC-07-274099.

ele
DECLARATION OF TINA YIM IN SUPPORT OF DEFENDANT WEBCOR BUILDERS, INC.S
OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE ACTIONS AND CONTINUE TRIAL DATELAW OFFICES

, LLP

KEENEY & CORDERY,

IMAI, TADLOCK,

SAN FRANCISCO, CA 94)04

(415) 675-7000

B WN

3. Attached hereto as Exhibit B is a true and correct copy of the relevant portions of
Plaintiffs Robert and Jean Ross’ Complaint captioned Robert Ross and Jean Ross v. C.C. Moore
& Co. Engineers, et al., San Francisco Superior Court Case No. CGC-10-275731.

4. Attached hereto as Exhibit C is a true and correct copy of dismissals of claims
arising from the May 2009 diagnosis of asbestosis and asbestos-related pleural disease of
defendants Webcor Builders, Inc.; Henry C. Beck Company; Commair Mechanical Services;
Clausen Patten, Inc.; H.& C Investment Associates; Giampolini & Company; Pacific Mechanical
Corporation; Cahill Construction Services, Inc.; Slakey Brothers, Inc.; Albay Construction
Company; Foley Electric, Inc.; California Drywall Co.; Johnson Controls, Inc.; Temporary Plant
Cleaners, Inc.;.A. Teichert & Son, Inc.; Swinerton-Builders; Kentile Floors, Inc.; Van-Mulder
Sheet Metal, Inc.; ACCO Engineered Systems, Inc.;.D.W. Nicholson Corporation; Marshco Auto
Parts, Inc.; J.W. McClenahan Company, Inc.; Red Top Electric Co. Emeryville, Inc.;

I declare under penalty of perjury that the foregoing is true and correct. Executed at San.

Francisco, California on March 23, 2012.

Tina Yim = V

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DECLARATION OF TINA YIM IN SUPPORT OF DEFENDANT COMMAIR MECHANICAL SERVICES”
OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE ACTIONS AND CONTINUE TRIAL DATELAW oretces

IMAI, TADLOCK, KEENEY & CORDERY, LLP

100 BUSH STREET

SUTTE 1300
SAN FRANCISCO, CA 94104

(415) 675-7000

PROOF OF SERVICE

I, undersigned, declare:

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

DECLARATION OF TINA YIM IN SUPPORT OF DEFENDANT WEBCOR BUILDERS,
INC.’S OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE ACTIONS AND
CONTINUE TRIAL DATE

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.

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.

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

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

I am readily familiar with the firm's practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after date of deposit for mailing in affidavit.

I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.

Executed on March 23, 2012, at San Francisco, Califomia.

“Cuda

Samantha Oryall

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

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DECLARATION OF TINA YIM IN SUPPORT OF DEFENDANT WEBCOR BUILDERS, INC,’S.
OPPOSITION TO PLAINTIFFS‘ MOTION TO CONSOLIDATE ACTIONS AND CONTINUE TRIAL DATE