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

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                                GABRIEL A. JACKSON, State Bar No. 98119
ANTHONY C. CHIOSSO, State Bar No. 209014
achiosso@jjr-law.com

JACKSON JENKINS RENSTROM LLP

55 Francisco Street, 6th Floor

San Francisco, CA 94133

Tel: 415.982.3600

Fax: 415.982.3700

Attorneys for Defendant
COSCO FIRE PROTECTION, INC.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

APR 19 2012

Clerk of the Court
BY: VANESSA WU
Deputy Clerk

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO

ROBERT ROSS AND JEAN ROSS,
Plaintiffs,
v.
C.C. MOORE & CO. ENGINEERS;
Defendants as Reflected on Exhibit 1
attached to the Summary Complaint
herein; and DOES 1-8500,, et al.

Defendants.

Case No CGC-10-275731

EXHIBITS D THROUGH E TO DECLARATION OF
ANTHONY C. CHiOSSO IN SUPPORT OF
DEFENDANT COSCO FIRE PROTECTION, INC. 'S
MOTION FOR SUMMARY JUDGMENT AND/OR
SUMMARY ADJUDICATION

DATE: July 10, 2012

TIME: 9:30 a.m.

DEPT: 503

COMPLAINT FILED: 12/17/10
TRIAL DATE: None

EXHIBITS TO DECLARATION OF ANTHONY C. CHIOSSO IN SUPPORT OF MOTION FOR SUMMARY JUDGMENTEXHIBIT DBRAYTON®PURCELL LLP

ATTORNEYS AT LAW

222 RUSH LANDING ROAD

PO BOX 6169

NOVATO, CALIFORNIA 94948-6169

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ALAN R. BRAYTON, ESQ., S.B. #73685
ERIC C. SOLOMON, ESQ., $.B. #119131
BRAYTON*PURCELL LLP

Attomeys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attorneys for Plaintiffs

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

No, CGC-10-275731
Plaintiffs,

ROBERT ROSS and JEAN ROSS, ASBESTOS
ANSWERS TO INTERROGATORIES

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

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: _ Plaintiff ROBERT ROSS
SET NO: ONE

.NSWERS

1, a ROBERT BRUCE ROSS.

b, September 9, 1935.

c. 75 years.

d. San Francisco, California.

e. 6440 East Calle Cavillo, Tucson, Arizona 85750.
Height: 5' 11", weight: 215 pounds.
558-42-3662.

=m

Not applicable.

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i, Not applicable.

j. US 562 37 507.

k. D01863135,

1 Robert or Bob Ross.

m. 12 grade, 2 years junior college.
n, Jean Ross.

o. October 28, 1936.

Pp. December 15, 1974.

q.

Same as 1.e., above.

rt Retired,
Ss. Judy Osborne.
t 1963,
u. Divorced,
2. a Diane Ross.
b. 1963,
©. Natural.
d. 21058 Perrigan Drive, Bend, Oregon 97702.
€. Hairdresser.
f Living.
3 No.
4, None.
5. Plaintiff is currently able to recall the following addresses:
present: 6440 East Calle Cavillo, Tucson, Arizona 85750.

Plaintiff's investigation and discovery are continuing.

Plaintiff completed high school, and attended 2 years of junior college.

No.
Plaintiff was a member of the United States Army from 1954 to 1956. Plaintiff’s

ep we ID

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service number is US 562 37 507. Please see response to Interrogatory No. 26, below.

10. _ Excluding plaintiff's expert consultants, plaintiff recalls the following physicians:

s Pp

e
ft

Dr. Arnold Hollander.

1200 North El Dorado Place, Tucson, Arizona.
Biopsy.

October 2010 to the present.

Colon cancer.

Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a.
b.
Arizona 85716.
c.
d,
e
f.

Dr, Roger A. Davis.
Gastroenterolgy Associates, 1601 North Tucson, Suite 114, Tucson,

Blood work, exams and treatment.
September 2010 to the present.
Tests and blood work.

Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a
b.

Unknown at present.
Veterans Administration Medical Center, CBOC, 2115 Northeast Wyatt

Court, Suite 201, Bend, Oregon 97701.

©
d.
e
f.

General health maintenance exams and treatments.
2010 to the present.
General health maintenance.

Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

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10

18

db

Oregon 97701.

©.
d.

&.

f.

Unknown at present.
Cascade Family Practice, 1247 Northeast Medical Center Drive, Bend,

Cancer screening, and related treatment,
October 2010 to the present.
Colon cancer.

Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

€.

f.

Plaintiff does not recall.

Queen of the Valley Hospital, Napa, California.

Plaintiff was treated for a kidney stone.

Approximately 2000.

Kidney stone.

Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

11. Excluding those used by plaintiff's expert consultants, plaintiff currently recalls

the following hospitals:
a. Palo Verde Surgical Associates.
b. 630 North Alvernon, Suite 180, Tucson, Arizona.
c. Surgery for colon cancer, and related care.
d. October 2010,
e Colon cancer, surgery.
£ Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

KAlnjured\9349\pld\ai-sacsf I.wpd

Queen of the Valley Hospital.
Napa, California,d. Approximately 2000.

e Kidney stone.

f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry, Defendants may obtain copies of records through Berry & Berry.

12, Excluding any taken by plaintiff's expert consultants, plaintiff recalls the

following x-rays:

a Cascade Medical Imaging, address unknown.

b. August 29, 2005; 1 view.

c. Chest.

d, Unknown.

€. Plaintiff's investigation and discovery are continuing.

a, Radiology Ltg, Tucson, Arizona.

b, December 2005.

c, Chest.

d. Unknown.

e. Plaintiff's investigation and discovery are continuing.

13, Excluding any taken by plaintiff's expert consultants, plaintiff recalls the

following pulmonary function tests:

a. Bend Memorial Hospital, Post Office Box 1018, Bend, Oregon 97708.

b. September 2005.

c Dr. Jacobs; David Fredstrom.

d. Follow up for CT scan.

a Unknown.

f No,

g Not applicable.

h. Plaintiff's investigation and discovery are continuing.

c Plaintiff was treated for a kidney stone.

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14, _ Please see response to Interrogatory No.'s 10 and 11 , above. Plaintiff defers to his
medical records as the best source of information for medications prescribed,

15. Notat this time. Plaintiff's medical records are equally available to defendants
through Berry & Berry, designated defense counsel.

16. Plaintiff has the following complaints from asbestos exposure: shortness of
breath, coughing and tiredness.

a. Unknown at present.
b. No cessation.
c Plaintiff is currently unaware of any physical change.

d. Plaintiff contends that his lungs have primarily been affected. However,
as the lung function affects the rest of the body, plaintiff also contends that all parts of his body
have been affected.

ef, Plaintiff's investigation and discovery are continuing,

g. Plaintiff does not at this time contend that he has lost time from work as a
result of his asbestos related conditions. Plaintiff's investigation and discovery are continuing.

h. Not applicable.

i Plaintiff's investigation and discovery are continuing.

a-b. Plaintiff was diagnosed with colon cancer on or about October 2010, and
with asbestosis and asbestos-related pleural disease on or about May 2009,
c.-l. Information protected by either the attorney work-product doctrine or the
attorney-client privilege. Plaintiff's investigation and discovery are continuing.
18. No.
19. Shortness of breath, and coughing.
20. See Interrogatory No. 10, above.
21. Unknown.
22. Yes.
a.-e, Plaintiff suffered a back injury on 1973. Plaintiff's investigation and

K Alnjured\19349%ipldtai-saest .wpd 6discovery are continuing.
23. Yes.
a. Plaintiff recalls smoking from 1950 to 1983.
db. Plaintiff recalls smoking cigarettes. Plaintiff inhaled.
c, Plaintiff recalls he usually smoked approximately 20 cigarettes per day,
d. Plaintiff recalls he usually smoked 1 pack of cigarettes per day.
e Plaintiff recalls smoking Lucky Strike, Camel, Kool, Kent and Marlboro

brand cigarettes.
f. No.
24. Yes.
Gordon Ross, plaintiff's father.

b. 1935 to 1953.
c Raleigh brand cigarettes.
d. Unknown.
25. Plaintiff recalls first consuming alcoholic beverages at age 15. Plaintiff stopped
drinking approximately 25 years ago, and currently does not consume alcoholic beverages.

26. Plaintiff is currently able to identify the following employment information:

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 Job Title Dates
United States Army Fort Ord, Monterey,CA; — Infantryman 2/9154-1/27/56
United States Army
Okinawa, Japan

Job Duties: Plaintiff served in the United States Army as an infantryman. Plaintiff served at Fo:
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.oS me YN AH hw Pe

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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 t

asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Philip Carey Warchouse Warehouseman 2/1959-8/1959;
Cincinnati, OH 101 Wiiliams 12/1959-1/1960

San Francisco, CA (1 week)

Jack Tar Hotel

(akc Cathedral Hill Hotel)

101 Van Ness

San Francisco, CA

Job Duties: Plaintiff unloaded boxcars full of asbestos containing products. Plaintiff swept
floors and delivered asbestos-containing materials to job sites. Plaintiff recalls unloading or
delivering the following asbestos-containing products; PHILIP CAREY, JOHNS-MANVILLE,
OWENS CORNING KAYLO, UNIBESTOS (UNARCO), EAGLE PICHER (EAGLE-PICHER
INDUSTRIES, INC.), CELOTEX, 85% MAG cement, 301 and 352 JOHNS MANVILLE
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 was the Rencral contractor which employed laborers and cement
finishers at the site. ANDERSON, ROWE & BUCKLEY, INC. employed plumbers, pipefitters
and sheetmetal workers at the Jack Tar Hotel. Plaintiff recalls Phili are 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: Scott,
Tucson, Arizona. Plaintiff recalls the following coworkers at the warehouse: Bill leineche, 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 pipefitters working on pumps and

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valves, and working with asbestos-containing gaskets and packing. Plaintiff worked in proximity]
to sheet metal workers disturbing existing asbestos-containing fireproofing insulation and
installing asbestos-containing flexible duct connectors. Plaintiff 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 performin;
general clean up, including sweeping up asbestos-containing debris, which caused dust. Plainti
worked in proximity to carpenters disturbing existing asbestos-containing fireproofing insulation,
Plaintiff worked in proximity to lathers and plasterers 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-containing fireproofing insulation. Plaintiff cut asbestos containing.
insulation with a power saw and applicd asbestos containing canvas and asbestos cloth. Plainti
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 joumeyman insulators. Plaintiff recalls working with
JOHNS-MANVILLE block insulation. Plaintiff recalls scoring and cutting the block insulation
with a handsaw. Plaintiff recalls mixing all-purpose cement and using JOHNS MANVILLE 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 and
BABCOCK & WILCOX COMPANY. Plaintiff recalls using UNIBESTOS insulation and_
magnesium. 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 INDUS 3, INC pump which had
original manufacturer’s asbestos-containing paskets 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
Empioyer 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 (FIBREBO, CORPORATION)
insulation and EAGLE PICHER (EAGLE-PICHER INDUSTRIES, INC.) insulation cement onoO Oo WN A WB ww

pipes. Plaintiff recalls scoring and cutting the block insulation with a handsaw, Plaintiff recalls
aborers from ALBA Y CONSTRUCTION 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.

Location of Exposure
Employer Exposure Job Title Dates
AC&S UC Berkeley (Central Insulator 1960 - 1962;
Lancaster, PA Steam Plan}, 1965 - 1966

Berkeley, CA (1 week)

and PABCO (FIBREBCARD 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., LTD. JAMES WHITTAKER laborers
mixed and sprayed asbestos-containing CAFCO (UNITED STATES MINERAL PRODUCTS
COMPANY) fireproofing and swept dried fireproofing overspra in plaintiff's work areas.
Electricians disturbed overhead as! estos. containing MONO! OTE (W.R. GRACE & CO.)
fireproofing while setting their conduit supports. Plaintiff worked in proximity to others who

Job Duties: Plaintit?: appticd CORPORATIONS boc (OWENS CORNING FIBERGLAS)

were checking, removing and replacing asbestos-containing original manufacturer’s cking in
new BELL & GOSSETT (ITT INDUS’ S, INC.) pumps. Plaintiff recalls the following
manufacturers of asbestos products; PLANT ASBESTOS COMPANY (PLANT INSULATION
COMPANY), Plaintiff worked alongside fi efitters who were installing and removing asbestos-
containing GARLOCK (GARLOCK SEALING TECHNOLOGEES, L! ) and FLEXITALLIC,
INC. gaskets, Plaintiff recalls that CAL-STEAM SUPPLY COMPANY supplied asbestos-
containing FLEXITALLIC, INC Baskets, Plaintiff recalls that they special ordered asbestos pipe

insulation from METALCLAD INSULATION CORPORATION. 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 tank, Plaintiff applied EAGLE-
PICHER (EAGLE-PICHER INDUSTRIES, INC.) asbestos-containing cement on the heads and
fittings. Plaintiff applied KAYLO (OWENS CO! IG FIBERGLAS) asbestos-containing
insulation on pipes. Plaintiff recalls using JOHNS-MANVILLE asbestos-containiny
pipecovering Plaintiff recalls the following contractors at this site: PLANT ASBESTOS
BOMPA (PLANT INSULATION COMPANY) and BAY CITIES ASBESTOS CO., LTD.
TIDEWATER REFINERY laborers swept and shoveled asbestos-containing debris near plaintiff :
Plaintiff recalls the following foremen: Robert Robbins (deceased); and Allen Holbrool
(deceased). Plaintiff recalls the following co-workers: Lou Hanson (address nknown); Robert
Robbins (deceased); Robert Sandoval (deceased); Ron Furia (deceased); and Laurance Hagen
{eo Brayton**Purcell LLP). Plaintiff recalls the following employees of PLANT INSULATION
‘(OMPANY (PLANT INSULATION COMPANY): Ron Powers (c/o Brayton*Purcell LLP);
Steve Steele (address unknown). Plaintiff currently contends that he was exposed to asbestos
during this 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

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 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 materials in the boilers, 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-containiny welding blankets, laborers sweeping up the site and pipefitters installing

skets, 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); lie
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 pipecovering and all purpose cement. Plaintiff recalls the
following co-worker: Jim White, oP Napa, California. Plaintiff currently contends that he was
exposed to asbestos during this employment.

Location of Exposure
Em T Exposure Job Ti Dates
Heat, Frost & Asbestos Maritime Union Insulator Approx. 1960
Workers Union Mission Street (I 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 following co-workers: John Chulick (c/o
Brayton**Purcell LLP); Ron Furia (deceased); Charles Tobey (c/o Brayton Purcel LLP);
Charlie Power (deceased); James Kearney, (deceased), Roger Fonken (c/o Brayton%Purcell
LLP); Donald Cox (c/o Brayton**Purcel! 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 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 ¥2 weeks total during
the new construction of the high school. Plaintiff applied asbestos-containing JOHNS-
MANVILLE mag  pipecoverin and used all purpose cement for the fittings. FRANK M,
BOOTH and B: RD CONSTRUCTION ‘Fe fitters and sheetmetal workers disturbed
previously sprayed asbestos-containing MO) OTE (W.R. GRACE & CO.) overhead
fireproofing while setting pipe supports and duct supports in Plaintift s work areas. FRANK M.
BOOTH personnel cut and installed asbestos-containing flexible duct connectors next to plaintiff|
and his crew. Plaintiff recalls working near laborers employed by FRANK M. BOOTH who
performed clean-up and sweeping and CALIFORNIA DRYWALL drywall hangers, tapers and
sanders. 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 Rifgs (deceased); Hank Meyers (deceased); Donald Cox (c/o Brayton*+Purcell LLP);
Richa ss (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 1 month)

San Francisco, CA

Job Duties: Plaintiff recalls insulating pipes and vessels, Plaintiff used asbestos-containing
EAGLE PICHER cement, and asbestos-containing KAYLO (OWENS CORNING FIBERGLAS)
block insulation. Plaintiff worked near laborers, were employed by PLANT MAINTENANCE
(PLANT MAINTENANCE, INC. OF CALIFORNIA) who were stripping existing asbestos-
containin; pipe insulation, Sweeping up the site and carrying products to the workers. PLANT
ASBEST' ‘OMPANY (PLANT INSULATION COMPA! personnel were applying _
asbestos-containing PABCO FIBREBOARD CORPORATION) calcium silicate pipecovering
near plaintiff for approximately 3 days. Plaintiff saw CROCKETT ELECTRIC electricians

erforming electrical work in his work areas. Plaintiff worked alongside pipefitters who were
installing and removing asbestos-containing FLEXITALLIC, INC, gaskets, Plaintiff recalls the
following co-workers: Lou Hanson (address unknown); Robert Robbins (deceased); Robert
Sandov (deceased). Plaintiff currently contends that he was exposed to asbestos during this
employment. :

12Ce WA mH RY YB

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BRx) As a general rule, within 30 days after you are served
with these interrogatories, you must serve your responses on
the asking party and serve copies of your responses on all
other parties to the action who have appeared. See Code of
Civil Procedure sections 2030.260-2030.270 for details.

(c) Each answer must be as complete and straightforward
as the information reasonably available to you, including the
information possessed by your attorneys or agents, permits. If
an interrogatory cannot be answered completely, answer it to
the extent possible.
{d) If you do not have enough personal knowledge to fully
answer an interrogatory, say so, but make a reasonable and
good faith effort to get the Information by asking other persons
or organizations, unless the information is equally available to
the asking party.
(8) Whenever an interragatory may be answered by
referring to a document, the document may be attached as an
exhibit to the response and referred to in the response. If the
document has more than one page, refer to the Page and
section where the answer to the interrogatory can be found.
{f} Whenever an address and telephone number for the
same person are requested in more than one interrogatory,
you are required to furnish thern in answering only the first
interrogatory asking for that information.
(g) Ifyou are asserting a privilege or making an objection to
an interrogatory, you must specifically assert the privilege or
‘state the objection in your written response.
(h) Your answers to these interrogatories must be verified,
dated, and signed. You may wish to use the following form at
the end of your answers:

! daclare under penalty of perjury under the laws of the
State of Califomia that the foregoing answers are true and
correct.

{DATE} (SIGNATURE)

Sec. 4, Definitions
Words in BOLDFACE CAPITALS in these interrogatories
are defined as follows:
{a) (Check one of the following):
(1) INCIDENT includes the circumstances and
events surrounding the alleged accident, injury, or
other occurrence or breach of contract giving rise to
this action or proceeding.

tote

Form Approved for Optional Use
udicial Caune of California
DISC-001 [Rev, January 1, 2008)

Page |
FORM INTERROGATORIES—GENERAL 5, iff 54 2090610 2050.10, 2008716
is
fa[J (2) INCIDENT means (insert your definition here or
on a separate, attached sheet labeled "Sec.
4(a)(2)"):

(b) YOU OR ANYONE ACTING ON YOUR BEHALF
includes you, your agents, your employees, your insurance
companies, their agents, their employees, your attomeys, your
accountants, your investigators, and anyone else acting on
your behalf,

(c) PERSON includes a natural person, firm, association,
organization, partnership, business, trust, limited liability
company, corporation, or public entity.

(d) DOCUMENT means a writing, as defined in Evidence
Cade section 250, and includes the original or a copy of
handwriting, typewriting, printing, photostats, photographs,
electronically stored information, and every other means of
recording upon any tangible thing and form of communicating
or representation, including letters, words, pictures, sounds, or
symbols, or cot tions of them.

(e) HEALTH CARE PROVIDER includes any PERSON
teferred to in Code of Civil Procedure section 687,7(e)(3).

{f, ADDRESS means the street address, including the city,
state, and zip code.

Sec. 5. Interrogatories

The following interrogatories have been approved by the
Judicial Council under Code of Civil Procedure section 2033.710:

CONTENTS

1.0 Identity of Persons Answering These Interrogatories
2.0 General Background Information—Individual

3.0 General Background Information—Business Entity
4.0 Insurance

5.0 [Reserved]

6.0 Physical, Mental, or Emotional injuries

7.0 Property Damage

8.0 Loss of Income or Earning Capacity

9.0 Other Damages

10.0 Medical History

11.0 Other Claims and Previous Claims

12.0 Investigation — General

13.0 investigation — Surveillance

14.0 Statutory or Regulatory Violations

15.0 Denials and Special or Affirmative Defenses

16.0 Defendant's Contentions Personal Injury

17.0 Responses to Request for Admissions

18.0 [Reserved]

19.0 [Reserved]

20.0 How the Incident Occurred—Motor Vehicle

25.0 [Reserved]

30.0 [Reserved]

40.0 [Reserved]

50.0 Contract

60.0 [Reserved}

70.0 Unlawful Detainer [See separate farm DISC-003}
101.0 Economic Litigation [See separate form DISC-004]
200.0 Employment Law [See separate form DISC-002]

Family Law [See separate form FL-7145]

DISC-001
1.0 Identity of Persons Answering These Interrogatories

X | 1.1 State the name, ADDRESS, telephone number, and
relationship to you of each PERSON who prepared or
assisted in the preparation of the responses to these
interrogatories. (Do not identify anyone who simply typed or
reproduced the responses.)

2.0 General Background Information—individual

2.1 State:

(a) your name;

(b) every name you have used in the past; and

(c) the dates you used each name.

2.2 State the date and place of your birth.

2.3 At the time of the INCIDENT, did you have a driver's
license? If so, state:

(a) the state or other issuing entity;

(b) the license number and type;

(c) the date of issuance; and

(d) all restrictions.

2.4 At the time of the INCIDENT, did you have any other
permit or license for the operation of a motor vehicle? Ifso,
state:

(a) the state or other issuing entity;

(b) the license number and type;

(c) the date of issuance; and

(d) all restrictions.

2.5 State:

(a) your present residence ADDRESS;

(b) your residence ADDRESSES for the past five years; and
{c) the dates you lived at each ADDRESS.

2.6 State:

{a) the name, ADDRESS, and telephone number of your
present employer or place of self-employment; and

(b) the name, ADDRESS, dates of employment, job title,
and nature of work for each employer or
‘self-employment you have had from five years before
the INCIDENT until today.

2.7 State:

(a) the name and ADDRESS of each school or other
academic or vocational institution you have attended,
beginning with high school;

(b) the dates you attended;

(c) the highest grade level you have completed; and

(d) the degrees received.

2.8 Have you ever been convicted of a felony? If so, for
each conviction state:

(a) the city and state where you were convicted;

(b) the date of conviction;

(©) the offense; and

(d) the court and case number.

2.8 Can you speak English with ease? If not, what
language and dialect do you normally use?

2.10 Gan you read and write English with ease? Hnot, what
language and dialect do you normally use?

DISC-001 [Rev January 1, 2008) FORM INTERROGATORIES—GENERAL Page 2of82.11 At the time of the INCIDENT were you acting as an

agent or employee for any PERSON? If so, state:

(a) the name, ADDRESS, and telephone number of that
PERSON: and

(b) adescription of your duties.

2.12 At the time of the INCIDENT did you or any other

person have any physical, emotional, or mental disability or

condition that may have contributed to the occurrence of the

INCIDENT? If so, for each person state:

(a) the name, ADDRESS, and telephone number;

(b) the nature of the disability or condition; and

(c) the manner in which the disability or condition
contributed to the occurrence of the INCIDENT.

2.13 Within 24 hours before the INCIDENT did you or any

person involved in the INCIDENT use or take any of the

following substances: alcoholic beverage, marijuana, or
other drug ar medication of any kind (prescription or not)? If

80, for each person state:

(a) the name, ADDRESS, and telephone number;

(b) the nature or description of each substance;

(c} the quantity of each substance used or taken;

(d) the date and time of day when each substance was used
or taken;

(6) the ADDRESS where each substance was used or
taken;

(f) the name, ADDRESS, and telephone number of each
person who was present when each substance was used
or taken; and

(9) the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who prescribed or furnished
the substance and the condition for which it was
prescribed or furnished.

3.0 General Background Information — Business Entity

3.1 Are you a corporation? If so, state:

(a) the name stated in the current articles of incorporation;

{b) all other names used by the corporation during the past
10 years and the dates each was used;

(c) the date and place of incorporation;

(@) the ADDRESS of the principal place of business; and

(e) whether you are qualified to do business in California.

3.2 Are you a partnership? If so, state:

(a) the current partnership name;

(b) all other names used by the partnership during the past
10 years and the dates each was used;

(©) whether you are a limited partnership and, if so, under
the laws of what jurisdiction;

(d) the name and ADDRESS of each general pariner; and

(e) the ADDRESS of the principal place of business.

3.3. Are you a limited liability company? If so, state:

(@)_ the name stated in the current articles of organization;

(b) all other names used by the company during the past 10
years and the date each was used;

(©) the date and place of filing of the articles of organization;

(d)_ the ADDRESS of the principal place of business; and

(e) whether you are qualified to do business in California.

40

5.0
60

DISC-001
3.4 Are you a joint venture? If so, state:
(a) the current joint venture name;
(b) all other names used by the joint venture during the
past 10 years and the dates each was used;
(c) the name and ADDRESS of each joint venturer; and
(d) the ADDRESS of the principal place of business.

3.5 Are you an unincorporated association?

if so, state:

(a) the current unincorporated association name;

(b) all other names used by the unincorporated association
during the past 10 years and the dates each was used;
and

(c) the ADDRESS of the principal place of business.

3,6 Have you done business under a fictitious name during
the past 10 years? If so, for each fictitious name state:

(a) the name;

(b) the dates each was used;

(c) the state and county of each fictitious name filing; and
(a) the ADDRESS of the principal place of business.

3.7 Within the past five years has any public entity regis-
tered or licensed your business? If so, for each license or
Tagistration:

{a) identify the license or registration;

{b) state the name of the public entity; and

(©) state the dates of issuance and expiration.

Insurance

4.1 At the time of the INCIDENT, was there in effect any
policy of insurance through which you were or might be
insured in any manner (for example, primary, pro-rata, or
excess liability coverage or medical expense coverage) for
the damages, claims, or actions that have arisen out of the

INCIDENT? If so, for each policy state:

(a) the kind of coverage;

(b) the name and ADDRESS of the insurance company;

(c) the name, ADDRESS, and telephone number of each
named insured;

(d) the policy number;

(e) the limits of coverage for each type of coverage con-
tained in the policy;

(f) whether any reservation of rights or cantroversy or
coverage dispute exists between you and the insurance
company; and

(g) the name, ADDRESS, and telephone number of the
custodian of the policy.

4.2 Are you self-insured under any statute for the damages,
claims, or actions that have arisen out of the INCIDENT? If
80, specify the statute.

[Reserved]
Physical, Mental, or Emotional Injuries

6.1 Do you aitribute any physical, mental, or emotional
injuries to the INCIDENT? (If your answer is “no,” do not
answer interrogatories 6.2 through 6.7).

62. Identify each injury you attribute to the INCIDENT and
the area of your body affected.

DISC-001 [Rev. Janusry 1, 2008]

FORM INTERROGATORIES—GENERAL

Page 30186.3 Do you still have any complaints that you attribute to
the INCIDENT? If so, for each complaint state:

(a) a description;

{b) whether the complaint is subsiding, remaining the same,
or becoming worse; and

(©) the frequency and duration,

6.4 Did you receive any consultation or examination

(except from expert witnesses covered by Code of Civil

Procedure sections 2034.210-2034.310) or treatment froma

HEALTH CARE PROVIDER for any injury you attribute to

the INCIDENT? If so, for each HEALTH CARE PROVIDER

‘state:

(a) the name, ADDRESS, and telephone number;

{b) the type of consultation, examination, or treatment
provided;

(c) the dates you received consultation, examination, or
treatment; and

(d) the charges to date.

6.5 Have you taken any medication, prescribed or not, as a
result of injuries that you attribute to the INCIDENT? If so,
for each medication state:

(a) the name;

(b) the PERSON who prescribed or furnished it;

(c) the date it was prescribed or furnished;

(d) the dates you began and stopped taking it; and

(8) the cost fo date.

[1] 6.6 Are there any other medical services necessitated by
the injuries that you attribute ta the INCIDENT that were not
previously fisted (for example, ambulance, nursing,
prosthetics)? Ifso, for each service state:

(a) the nature;

(b) the date;

(ce) the cost; and

(d) the name, ADDRESS, and telephone number
of each provider.

6.7 Has any HEALTH CARE PROVIDER advised that you

may require future or additional treatment for any injuries

that you attribute to the INCIDENT? If so, for each injury

state:

(a) the name and ADDRESS of each HEALTH CARE
PROVIDER;

{b) the complaints for which the treatment was advised; and

(c) the nature, duration, and estimated cost of the treatment.
treatment.

7.0 Property Damage

7.1 Do you attribute any loss of or damage to a vehicle or

other property to the INCIDENT? If so, for each item of

property:

(a) describe the property;

{b) describe the nature and location of the damage to the
property;

8.0

DISC-001

(c) state the amount of damage you are claiming for each

item of property and how the amount was calculated; and

{d) if the property was sold, state the name, ADDRESS, and

telephone number of the seller, the date of sale, and the
sale price.

7.2 Has a written estimate or evaluation been made for any

item of property referred to in your answer to the preceding

interrogatory? If so, for each estimate or evaluation state:

{a) the name, ADDRESS, and telephone number of the
PERSON who prepared it and the date prepared;

(b) the name, ADDRESS, and telephone number of each
PERSON who has a copy of it; and

(c) the amount of damage stated.

7.3 Has any item of property referred to In your answer to

interrogatory 7.1 been repaired? If so, for each item state:

(a) the date repaired;

(b) a description of the repair;

(c) the repair cost;

{d) the name, ADDRESS, and telephone number of the
PERSON who repaired it;

(e) the name, ADDRESS, and telephone number of the
PERSON who paid for the repair.

Loss of Income or Earning Capacity

8.1 Do you attribute any loss of income or eaming capacity
to the INCIDENT? (if your answer is “no,” do not answer
interrogatories 8.2 through 8.8).

8.2 State:

(a) the nature of your work;

(>) your job title at the time of the INCIDENT; and
(c) the date your employment began.

8.3 State the last date before the INCIDENT that you
worked for compensation.

8.4 State your monthly income at the time of the INCIDENT
and how the amount was calculated.

8.5 State the date you retumed to work at each place of
employment following the INCIDENT.

8.6 State the dates you did not work and for which you lost
income as a result of the INCIDENT.

8.7 State the total income you have lost to date as a result
of the INCIDENT and how the amount was calculated.

8.8 Will you lose income in the future as a result of the
INCIDENT? If so, state:

{a} the facts upon which you base this contention;

(0) an estimate of the amount;

(c)_ an estimate of how long you will be unable to work; and
(d) how the claim for future income is calculated.

186-008 (Rev, January 1, 2008] FORM INTERROGATORIES—-GENERAL Page 4 of 89.0 Other Damages

9.1 Are there any other damages that you attribute to the

INCIDENT? If so, for each item of damage state:

(a) the nature;

(b) the date it occurred;

(c) the amount; and

(d) the name, ADDRESS, and telephone number of each
PERSON to whom an obligation was incurred.

9.2 Do any DOCUMENTS support the existence or amount
of any item of damages claimed in interrogatory 9.1? If so,
describe each document and state the name, ADDRESS,
and telephone number of the PERSON who has each
DOCUMENT.

0.0 Medical History
10.1 At any time before the INCIDENT did you have com-

plaints or injuries that Involved the same part of your body

claimed to have been injured in the INCIDENT? If so, for

each state:

(a) a description of the complaint or injury;

(b) the dates it began and ended; and

{c) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER whom you consulted or
who examined or treated you.

10.2 _ List all physical, mental, and emotional disabilities you

had immediately before the INCIDENT. (You may omit
mental or emotional disabilities unless you attribute any
mental or emotional injury to the INCIDENT.)

10.3 At any time after the INCIDENT, did you sustain

injuries of the kind for which you are now claiming

damages? if so, for each incident giving rise to an injury

state:

(a) the date and the place it occurred;

(b) the name, ADDRESS, and telephone number of any
other PERSON involved;

(c) the nature of any injuries you sustained;

(d) the name, ADDRESS, and telephone number of each
HEALTH CARE PROVIDER who you consulted or who
examined or treated you; and

(e) the nature of the treatment and its duration,

11.0 Other Claims and Previous Claims

11.1 Except for this action, in the past 10 years have you

filed an action or made a written claim or demand for

compensation for your personal injuries? If so, for each

action, claim, or demand state:

{a) the date, time, and place and location (closest street
ADDRESS or intersection) of the INCIDENT giving rise
to the action, claim, or demand;

(b) the name, ADDRESS, and telephone number of each
PERSON against whom the claim or demand was made
or the action filed;

12.0

DISC-001

(c) the court, names of the parties, and case number of any
action filed;

(8) the name, ADDRESS, and telephone number of any
attorey representing you;

(e) whether the claim or action has been resolved or is
pending; and

(® a description of the injury.

11.2. In the past 10 years have you made a written ciaim or

demand for workers' compensation benefits? If so, for each

claim or demand state:

(a) the date, time, and place of the INCIDENT giving rise to
the claim;

(b) the name, ADDRESS, and telephone number of your
employer at the time of the injury;

(c) the name, ADDRESS, and telephone number of the
workers’ compensation insurer and the claim number;

(d) the period of time during which you received workers’
compensation benefits;

{e) a description of the injury;

(f) the name, ADDRESS, and telephone number of any
HEALTH CARE PROVIDER who provided services; and

(g)_ the case number at the Workers' Compensation Appeals
Board.

Investigation—General

42.1 State the name, ADDRESS, and telephone number of

each individual:

{a) who witnessed the INCIDENT or the events occurring
immediately before or after the INCIDENT;

(b) who made any statement at the scene of the INCIDENT;

(©) who heard any statements made about the INCIDENT by
any individual at the scene; and

(d) who YOU OR ANYONE ACTING ON YOUR BEHALF
claim has knowledge of the INCIDENT (except for
expert witnesses covered by Code of Civil Procedure
section 2034).

12.2 Have YOU OR ANYONE ACTING ON YOUR

BEHALF interviewed any individual concerning the

INCIDENT? If so, for each individual state:

(a) the name, ADDRESS, and telephone number of the
individual interviewed;

(b) the date of the interview; and

{c) the name, ADDRESS, and telephone number of the
PERSON who conducted the interview.

12.3 Have YOU OR ANYONE ACTING ON YOUR

BEHALF obtained a written or recorded statement from any

individual concerning the INCIDENT? If so, for each

statement state:

(a) the name, ADDRESS, and telephone number of the
individual from whom the statement was obtained;

(o) the name, ADDRESS, and telephone number of the
individual who obtained the statement;

(c) the date the statement was obtained; and

(a) the name, ADDRESS, and telephone number of each
PERSON who has the original statement or a copy.

DISG-001 [Rev. January 1, 2008}

FORM INTERROGATORIES—GENERAL

Page SofCJ

13.0

12.4 Do YOU OR ANYONE ACTING ON YOUR BEHALF
know of any photographs, films, or videotapes depicting any
place, object, or individual concerning the INCIDENT or
plaintiffs injuries? If so, state:

(a) the number of photographs or feet of film or videotape;

(b) the places, objects, or persons photographed, filmed, or
videotaped;

(@) the date the photographs, films, or videotapes were
taken;

(d) the name, ADDRESS, and telephone number of the
individual taking the photographs, films, or videotapes;
and

(e) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the
photographs, films, or videotapes.

12.5 Do YOU OR ANYONE ACTING ON YOUR BEHALF

know of any diagram, reproduction, or model of any place or

thing (except for items developed by expert witnesses

covered by Code of Civil Procedure sections 2034.210-

2034.310) concerning the INCIDENT? If so, for each item

state:

{a) the type (i.e., diagram, reproduction, or model);

(b) the subject matter; and

(c) the name, ADDRESS, and telephone number of each
PERSON who has it.

12.6 Was a report made by any PERSON concerning the

INCIDENT? If so, state:

{a) the name, title, identification number, and employer of
the PERSON who made the report;

(b) the date and type of report made;

(c) the name, ADDRESS, and telephone number of the
PERSON for whom the report was made; and

(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of the report.

127 Have YOU OR ANYONE ACTING ON YOUR
BEHALF inspected the scene of the INCIDENT? If so, for
each inspection state:

{a) the name, ADDRESS, and telephone number of the
individual making the inspection (except for expert
witnesses covered by Code of Civil Procedure sections
2034.210-2034.310); and

(b) the date of the inspection.

investigation—Surveillance

13.1 Have YOU OR ANYONE ACTING ON YOUR BEHALF

conducted surveillance of any individual involved in the

INCIDENT or any party to this action? If so, for each sur-

veillance state:

(a) the name, ADDRESS, and telephone number of the
individual or party;

(b) the time, date, and place of the surveillance;

(c) the name, ADDRESS, and telephone number of the
individual who conducted the surveillance; and

(d) the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy of any
surveillance photograph, film, or videotape.

15.0

16.0

DISC-001
13.2 Has a written report been prepared on the
surveillance? If so, for each written report state:
(a) the title;
(b) the date;
the name, ADDRESS, and telephone number of the
individual who prepared the report; and
the name, ADDRESS, and telephone number of each
PERSON who has the original or a copy.

Statutory or Regulatory Violations

14.1 Do YOU OR ANYONE ACTING ON YOUR BEHALF
contend that any PERSON involved in the INCIDENT
violated any statute, ordinance, or regulation and that the
violation was 2 legal (proximate) cause of the INCIDENT? if
8p, identify the name, ADDRESS, and telephone number of
each PERSON and the statute, ordinance, or regulation that
was violated.

14.2 Was any PERSON cited or charged with a violation of

any statute, ordinance, or regulation as a result of this

INCIDENT? If so, for each PERSON state:

(a) the name, ADDRESS, and telephone number of the
PERSON;

(b) the statute, ordinance, or regulation allegedly violated;

(c) whether the PERSON entered a plea in response to the

d)

@)