On December 17, 2010 a Hearing was filed involving a dispute between Ross, Jean, Ross, Robert, and Acco Engineered Systems, Inc., Advanced Mechanical, Advance Mechanical Contractors, Inc., Air Systems Mechanical Contractor, A & K Heating Company, Inc., Albay Construction Company, Allen-Simmons Heating & Sheet Metal Company Inc., Allied Fire Protection, Allied Sprinkler Company, Inc., Allsberry Mechanical Corporation, Anderson, Rowe & Buckley, Inc., Associated Insulation Of California, A. Teichert & Son, Inc., Balliet Bros. Construction Corporation, Banner Drywall & Painting Co. Inc., Barnes Construction Co., Bayer Cropscience Inc., Bayer Cropscience, Inc., Successor To Amchem, Bell Products Inc., Beta Mechanical Contractors, L.P., Bragg Investment Company, Inc., Cahill Construction Co., Inc., Cahill Construction Services, Inc., Cahill Contractors, Inc., California Drywall Co., Castro Construction, Inc., C.C. Moore & Co. Engineers, Cincinnati Valve Company, Cjr Plastering, Clausen-Patten, Inc., Clausen-Patten, Inc., A Dissolved Corporation, Climate Air, Inc., Climate Control Co., Inc., Collins Electrical Company, Inc., Commair Mechanical Services, Consolidated Insulation, Inc., Cosco Fire Protection, Inc., Cosco Sprinkler, Critchfield Mechanical, Inc., C & R Plastering, Inc., Csk Auto, Inc., Cupertino Electric, Inc., Delucchi Sheet Metal Works, Dilland Sederberg Plumbing, Does 1-8500, Domco Products Texas Inc., Domco Products Texas, L.P., Donovan Construction, Dorn Refrigeration, Dorn Refrigeration And Air Conditioning, Dpr Construction, Duro Dyne Corporation, D.W. Nicholson Corporation, D. Zelinsky & Sons, Inc., Emil J. Weber Electric Co., Erwin Mechanical Inc., Ex- Fme, Inc. (Fka Fischbach And Moore Electric,, Fairmont Hotel Company, Fluor Corporation, Foley Electric Co., Foley Electric, Inc., Fuller Floors, General Mills, Inc., Giampolini & Co., Graybar Electric Company, Inc., Hanson Permanente Cement, Inc. Formerly Known As, Harold Beasley Plumbing And Heating, Inc., Harry Lee Plumbing & Heating, H & C Investment Associates, Inc., Henry C. Beck Company, Imperial Plastering & Drywall, Insulation Specialties, Inc., James A. Nelson Co., Inc., Johnson Controls, Inc., Jones Plastering Company, Joseph Bruno Sheet Metal Co., Inc., J.T. Thorpe & Son, Inc., J.W. Mcclenahan Company, J.W. Mcclenahan Company, Inc., Kentile Floors, Inc., Laub Sheet Metal Works, Lone Star Industries, Inc., Mack Construction Co., Magee, Robert, Malm Metal Products, Inc., Marine Engineering And Supply Company, Marshco Auto Parts, Inc., Mattock Construction Company, Mcclure Electric, Inc., Metropolitan Life Insurance Company, Michael Brothers, Midstate Mechanical, Inc., Mitchell Bros. Truck Lines, Inc., Monsanto Company, Sued As "Pharmacia Corporation", Oakfabco, Inc., Ortho-Craft, Pacific Fireproofing, Pacific Mechanical Corporation, Parker Insulation Contracting & Supply Co. Inc., Perini Corporation, Pharmacia Corporation, Which Will Do Business In, Pribuss Engineering, Pribuss Engineering, Inc., Raymond Interior Systems-North, Red Top Electric Co. Emeryville, Inc., Robert Magee, Rollie R. French, Inc., Rollins Construction, Rountree Plumbing & Heating Inc., Scott Co. Of California, S F L, Inc., S.J. Amoroso Construction Co., Inc., Slakey Brothers, Inc., Sugden Engineering Co., Swinerton Builders, Temper Insulation, Temporary Plant Cleaners, Inc., Texaco, Inc., The Goodyear Tire & Rubber Company, The W.W. Henry Company, Tuttle And Bailey Corp, Van Mulder Sheetmetal, Van-Mulder Sheet Metal, Inc., Walnut Creek Sheet Metal, Furnace & Air, W.C. Thomason, W.C. Thompson, Webcor Builders, Inc., Westburne Supply, Inc., Willard Electric, Wright Schuchart Harbor, Wright Schuchart Harbor Company, Ross, Jean, Ross, Robert, for civil in the District Court of San Francisco County.
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ot wee NON Dm mt wo oh LAUGHLIN, FALBO. LEVY & MORES! avid W. Hughes (SBN 88738) 588 1th Street, Suite 1900 Oakland, CA 94607 Telephone: (510) 628-0496 Facsimile: (510) 628-0499 Attorneys for Defendant, INSULATION SPECIALTIES, INC. 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, Defendants. To Plaintiffs and all Other Parties and Their Attorneys of Record: Defendant INSULATION SPECIALTIES, INC. hereby joins Defendant DOMCO PRODUCTS TEXAS INC.’S (“DOMCO”) Notice of Motion and Motion to Dismiss Plaintiffs’ Claims Arising From the Alleged Asbestosis, Asbestos-Related Pleural ELECTRONICALLY FILED Superior Court of California, County of San Francisco OCT 26 2011 Clerk of the Court BY: ANNIE PASCUAL Deputy Clerk ASBESTOS No: CGC 10-275731 DEFENDANT INSULATION SPECIALTIES, INC.’S JOINDER IN DEFENDANT DOMCO PRODUCTS TEXAS INC.’S NOTICE OF MOTION AND MOTION TO DISMISS PLAINTIFFS’ CLAIMS ARISING FROM THE ALLEGED ASBESTOSIS, ASBESTOS-RELATED PLEURA DISEASE, AND OTHER LUNG INJURIES Date: November 15, 2011 Time: 9:30 a.m. Dept.: 503 Judge: Hon. Teri L. Jackson Defendant Insulation Specialties, Inc.’s Joinder in Defendant Demco Products Motion to Dismiss Plaintiff's Claims Arising From the Alleged Asbestosis, Ashestos-Related Pleural Disease, and Other Lung InjuriesDW C6 ND A BP WY NH N NM RY RY NH RD RD ee oe UA A £ BW NH eke OS Oo eH DA FF WN - Disease, and Other Lung Injuries, Memorandum of Points and Authorities, Declaration of Shelley Tinkoff, and Exhibits and Attachments, and on such other and further evidence as may be presented in reply to Plaintiffs’ anticipated opposition and at the hearing on the motion. Joining party intends to proceed with the motion even if DOMCO withdraws its notice or is not longer a party to this action on the date for the scheduled hearing. This Joinder is made on the grounds set for in DOMCO’s Motion, in that they apply equally to Defendant INSULATION SPECIALTIES, INC. INSULATION SPECIALTIES, INC. was not a named defendant in Robert Ross v. Asbestos Defendants (San Francisco Superior Court Case Number CGC-07-274099), and was never served with summons and complaint in said action. Plaintiffs cannot split their cause of action for claims related to asbestosis, asbestos-related pleural disease, and other lung injuries. DATED: october 2 | »2011 LAUG SI LLP Attorneys for Defendant INSULATION SPECIALTIES, INC. -2- Defendant Insulation Specialties, Inc.’s Joinder in Defendant Demco Products Motion to Dismiss Plaintiff's Claims Arising From the Alleged Asbestosis, Asbestos-Related Pleural Disease, and Other Lung InjuriesCo OW © SN DR A Rh YD YN eS DO NW DR A BRB HW HL Ny NM NY NY NN KR NY ec 2 KR hw BBW YH & S PROOF OF SERVICE Case : ROBERT ROSS AND JEAN ROSS vs. C.C. MOORE & CO. ENGINEERS , et al. Case #: CGC-10-275731 Court : Superior Court of California, County of San Francisco I am a citizen of the United States, employed in the city of Oakland. My business address is 555 12th Street, Suite 1900, Oakland CA, 94607. I am over the age of 18 years and not a party to the above entitled action. On October 26, 2011, I served the following: DEFENDANT INSULATION SPECIALTIES, INC.’S JOINDER IN DEFENDANT DOMCO PRODUCTS TEXAS INC.’S NOTICE OF MOTION AND MOTION TO DISMISS PLAINTIFFS’ CLAIMS ARISING FROM THE ALLEGED ASBESTOSIS, ASBESTOS- RELATED PLEURAL DISEASE, AND OTHER LUNG INJURIES ON ALL PARTIES DESIGNATED ON THE TRANSACTION RECEIPT OF THE LEXIS/NEXIS WEBSITE I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed “Ch 1, at Oakland (California. Mont-\Lyet— Deborah Sorah Proof of Service