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

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                                Selman Breitman tip

ATTORNEYS AT LAW

LOVE (SBN 162028),
Imanbreitman.com

ii GUNTER (SBN 170810).
chanbreitman.com

GILLI FF. STEWART (SBN 260070),
gstewart Imanbreitman.com
SELMAN BREITMAN LLP

33 New Montgomery, Sixth Floor

San Franeiseo, CA 94105

Telephone: (415) 979-0400

Facsimile: (415) 979-2099

jgunter@

Attorneys for Defendant
OAKFABCO, INC.

ELECTRONICALLY

FILED

Superior Court of California,
County of San Francisco

JAN 25 2011

Clerk of the Court
BY: VANESSA WU
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO- UNLIMITED JURISDICTION

ROBERT ROSS and JEAN ROSS,
Plaintiff,
Vv.
C.C. MOORE & CO. ENGINEERS, ct al.,

Defendant.

“ENEIBITS © (C4
UPPORT OF DEFEN

) FHROUGH D 10 DEC

CASE NO, CGC-10-275731

EXHIBITS C (CC
DECLARATION
GILLIAM F. STEWART IN SUPPORT
OF DEFENDANT OAKFABCO, INC'S
MOTION TO STRIKE

(PART 2)

Date March 8, 20114

Time 9:30 AM.

Dept. : 220

Judge Hon, Harold E. Kahn

December 17, 2010
To be assigned

Complaint Filed
Trial Date

(PART 2)EXHIBITS C (CONTINUED) THROUGH D TO
DECLARATION OF ATTORNEY GILLIAM F. STEWART
IN SUPPORT OF
ABCO, INC.'S MOTION TO STRIKE (PART 2)

DEFENDANT OA

PWARTE EN
(PARE 2)

ENIABIFS € (CONTINUED) THROUGH D TO DECLARATION OF ATPFORSEY GILLEAM FS
SUPPORT OF DEFENDANT OAKFABCO. INC'S MOTION TO STRIKEGC Ow WB Dw hw Ww

Location of Exposure
Dates

Employer Exposure Job Title

Siofert and Rossi Sacramento Convention Insulator 4/1972-

1501 North C Street Center 9/1973 3

Sacramento, CA Sacramento, CA months, on
Cie" St) and off)

Job Duties: Plaintiff installed pipe insulation and 301 cement on the fittings. Plamuff installed
‘TUFF BOND and stick pins. Plaintiff insulated what he believes was a BABCOCK &
WILCOX boiler with asbestos block insulation, all-purpose cement,.mastic and canvas and 352
BLUE cement. Plaintiff worked near pipefitters installing gaskets, pipes and valves. “Plaintiff
worked near laborers sweeping up debris and near welders performing welding and using
asbestos blankets. Plaintiff worked near drywall hangers cutting and installing drywall and near
tapers applying and sanding joint compound. Plaintiff recalls r orting to an Inspector who
worked for the City of Sacramento and believes that they were the general contractor for the
project. Plaintiff-worked in close proximity to laborers who were sweeping debris. Plaintiff
recalls that the laborers were employed by general contractor: JAMES WHITTAKER, INC.
Plaintiff recalls thc following co-workers: Al Cook, c/o Brayton**Purcell LLP; Herb Cook, c/o
Brayton#*Purcetl LLP; Jim White, Jr., address unknown. Plaintiff currently conténds he was
exposed to asbestos during this employment. .

: Location of Exposure
Employer Exposure Job Tite Dates
Siefert and Rossi American River City Insulator . 4/1972-
1501 North C Street College 9/1973 (2
Sacramento, CA Sacramento, CA t weeks, on

and off)

Job Duties: Plaintiff worked in-a pipe chase and in the boiler room. Plaintiff installed used all-
urpose cement on valves. Plaintiff recalls OWENS-CORNING employees at this location.
lamtiff recalls the following contractor: WALKER MECHANICAL, INC. Plaintiff recalls the

following co-worker: Met Swanson, Sacramento, California. Plaintiff currently contends he

was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure ob Title Dates
Siefert and Rossi ‘Truckee High School Insulator 4/1972-
1501 North C Street Truckee, C. . D973 (2
Sacramento, CA weeks, on
and off)

Job Dutics: Plaintiff insulated a tank. Plaintiff used cal-sil blocks, all-purpose cement, fibrous
adhesive cement, and 127 cement. Plaintiff worked near plumbers and pipcfitters installing
pipes, gaskets and valves. Plaintiff récails the following supervisor: Pete Rossi, Sacramento,
Califomia, Plaintiff recalls the following coworker: Richard Dunley, address unknown.
Plaintiff currently contends he was exposed to asbestos during this employment.

i

Me

ut

Ke hypcesR EMAL supper hat 43 ees:1 Location of

Employer Exposure
2

Siefert and Rossi Merchant's Cold Storage
3] 1501 North C Street Salinas, CA

Sacramento, CA

lob Title
Insulator

Exposure
Dates

4/1972+
9/3973 (3
weeks)

4] : .
| Job Dutics: Plaintiff insulated pipes, valves and fittings. Plaintiff worked on hot and cold lines.

6|| contends he was exposed to asbestos during this employment.

45 || Plamtiff used HENRY’S mastic and ONE COTE cement. Plaintiff recalls the following
| coworkers: Ted George, c/o Brayton*Purcell LLP; Bud Weidner, deceased. Plaintiff-currently

7 | Location of . Exposure
8 Employer Exposure Job Title Dates
Plant Insulation Westin Saint Francis Insulator 10/1973-
9} 2271 California Street Powell Street) . 12/1973;
San Francisco, CA an Francisco, CA 3/1974-
10 3/1976;
| 10/1976-
Hi 2/1977 (3
weeks, on
12} and off}
13] Job Duties: Plamtiff mstalled insulation on pipes and valves in the boiler room. Plaintiff used
| PABCO insulation and 127 insulating cement. Plaintiff worked near pipefitters installing pipes,
14]| valves, pumps and gaskets. Plaintiff recalls laborers swecping up debris in his area. Plainti
worked in close proximity to others who were applying KAISER GYPSUM COMPANY, INC.
15]| joint and taping compound. Plaintiff recalls the following supervisors: Glenn

| Schimmelphenig, address unknown. Plaintiff worked in close

| contractors: CONSOLIDATED INSULATION, INC., DOUG!
-COMPANY, INC., SWINERTON & WALBERG COMPANY, C.S. HARDEMAN, INC.,
SCOTT CO. OF CALIFORNIA, SAM P. WALLACE COMPANY, ANDERSON, ROWE &
BUCKLEY, INC., W.L. HICKEY SONS, INC., JAMES NELSON, COAST PLASTERING
COMPANY. Plaintiff recalis the following co-worker: Allan Edwards, deceased. Plaintiff

proximity to the following,
SS INSULATION

‘ob Title

Insulator

1g
19 currently contends he was exposed to asbestos during this employment.
Location of
20 | Employer Exposure
21 || Plant Insulation Letterman General Hospital
2271 California Street San Francisco, CA
22 | San Francisco, CA
23
24
25

Exposure
Dates

10/1973-
12/1973;
3/1974-
3/1976,
10/1976-
2A9TT (A
month, on
and off}

Job Duties: Plaintiff worked on a remodel of the hospital. Plaintiff wrapped ducts in the

26 || mechanical rooms and on various other floors. Plaintiff recalls fireproofing on the beams.

Plaintiff recalls the following supervisor: Glenn Schimmelphenig, address unknown. Plaintiff

27 || recalis the following co-worker: Larry Cooper, Cathedral City, California. Plaintiff currently

contends he was exposed to asbestos during this employment.

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Location of . Exposure
Employer Exposure ob Title Dates

Plant Insulation Standard Oil Insulator 10/1973-

2271 California Street Richmond, CA 12/1973;
San Francisco, CA 3/L974-
: 3/1976;

10/1976-

2ALOTT (4

“months, on

and off)

Job Duties: Plaintiff recalls installing insulation on pipes, valves, heat exchangers, towers and
vessels. Plaintiff recalls having to craw! over pipes that were covered with asbestos insulation
to perform his duties. Plaintiffrecalis that his clothes and skin would be covered with dust.
Plaintiff recalls working near welders using welding blankets, laborers sweeping up the site and .
near pipefitters installing gaskets, valves and pipes. Plaintiff recalls that in the moming the
crew would put on their work coveralls in a changing shack on the job site and remove them at
the end of the shift and store them in the changing shack for the next work day. Plaintiff recalls
being around co-workers who would pound their coveralls against the wall to get the dust off of
them. Plaintiff worked near an insulating crew employed by OSCAR ERICKSON who were
disturbing asbestos insulation. Plaintiff recalls contractors: OSCAR ERICKSON, and
BECHTEL. Plaintiff recalls the following supervisors: Glenn Schimmelphemig, address
unknown; Arvis Duncan, deceased. Plaintiff recalls the following co-workers: Don Burnett,
Oakdale, California; Warren Hasse, c/o Brayton%*Purcell LLP; Dick Tobey, deceased; Earl
Riggs, deceased; Roger Fonken c/o Brayton**Purcell LLP; Robert Holbrook, c/o
Brayton*Purcell LLP; Joseph O’Balle, c/o Brayton%*Purcell LLP; Robert Drose, deceased;
Gary Boges, c/o Brayton**Purcell LLP. Plaintiff recalls the following co-workers employed by
OSCAR ERICKSON: John Price, c/o Brayton“*Purcell LLP; and Monty Manwell, c/o
BraytonPurcell LLP. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
Empioyer Exposure Job Title Dates
Plant insulation PG&E Powerhouse Insulator 10/1973-
2271 Califomia Street Pittsburg, CA 12/1973;
San Francisco, CA 3/1974-
3/1976;
10/1976-
2/1977 (3
months, on
and off)

Job Dutics: Plaintiff applied block insulation and pipecovering. Plaintiff installed
POWERHOUSE cement. Plaintiff worked near welders using ashestos blankets and laborers
who were swiceping up debris. Plaintiff worked near pipefitters installing gaskets, valves and
pipes. Plaintiff recalls that in the morning the crew would put on their work coveralls in a
changing shack on the job site and remove them at the end of the shift and store them in the .
changing shack for the next work day. Plaintiff recalls being around co-workers who would
pound their coveralls against the wall to get the dust off of them. Plaintiff recalls the following
supervisors: Glenn Schimmelphenig, address unknown; Arvis Duncan, deceased. Plaintiff
tecalis the following co-workers: Don Burnett, Oakdale, California, Mike Caylor, c/o
Brayton**Purcell LLP; Robert Lee, c/o Brayton Purcell LLP; Richard Ciabaitan, c/o
Brayton Purcell LLP; John McClure, deceased; Edward Johnson, c/o Brayion? Purcell LLP;

Klee tS AK ppcat) wp 45 cesPe a A Hw Bw HN

10

John Price, c/o Brayton%Purcell LLP. Plaintiff currently contends he was exposed to asbestos
during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Plant Insulation Union Oi! Insulator 1/1977-
2271 California Street Rodeo/Oleum, CA 2/1977 (2
San Francisco, CA months)

Job Duties: Plaintiff repaired and.replaced damaged asbestos insulation. Plaintiff recalls
cutting off asbestos insulation to make repairs. Plaintiff installed POWERHOUSE cement,
FOSTER'S mastic and finishing cement. Plaintiff recalls working near pipefitters mstalling
pipes, gaskets, and valves. Plaintiff recalls laborers sweeping up debris. Plaintiff recalls the
following supervisors: Glenn Schimmelphenig, address unknown. Plaintiff recalls the
following co-worker: Ed Armstrong, address unknown. Plaintiff currently contends he w:
exposed to asbestos during this employment. : .

Location of . Exposure

Employer Exposure Job Title Dates

Plant Insulation Anheuser Busch Insulator > 10/1973-

2271 California Street Budweiser) Brewery 12/1973;

San Francisco, CA. ‘airfield, CA 3/1974-
3/1976;
10/1976-
21977 (3
months, on -
and off}

Job Duties: Plaintiff insulated pipes and tanks with cal sil msulation and POWERHOUSE
cement. Plaintiffused HENRY'S mastic on the refrigeration unit, Plaintiff insulated the
bottom of the tanks with cal sil block insulation. Plamtiff worked near pipefitters installing
gaskets, valves, pumps and pipes, Plaintiff worked near welders. Plaintiff recalls the following
supervisors: Glenn Schimmelphenig, address unknown; Arvis Duncan, deceased. Plaintiff
recalls the following co-workers: Robert Holbrook, ¢/o Brayton%*Purcell LLP; Don Burnette,
Oakdale, California; John McClure, deceased; Tom Sherwood, c/o Brayton%*Purcell LLP; Al
Holbrook, deceased. Plaintiff currently contends he was exposed to asbestos during this
employment. . . .

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation > Fireman’s Fund Insulator 10/1973-
2271 California Street Novato, CA 12/1973;
San Francisco, CA . 3/1974-
3/1976;
10/1976-
2/1977 (1
month, on
and off)

Job Duties: Plaintiff worked in the mechanical rooms. Plaintiff installed all-purpose cement
and 127 BLUE MUD cement on valves. Plaintiff removed and replaced ceiling les and had to
disturb existing insulation on pipes. Plaintiff recalls working near pipefitters installing pipes,

Kreck Ata seppiecd wd 46 ecsgaskets, and valves, Plaintiff worked near sheetrockers and tapers installing and sanding joint
compound. Plaintiff recalis laborers sweeping up debris. Plaintiff recalls the following
supervisers: Glenn Schimmelphenig, address unknown; Gary Hanson, address unknown.
Plaintiff recalis the following co-worker: Dick Tobey, deceased. Plaintiff currently contends
he was exposed io asbestos during this employment.

Location of Exposure
Employer " ‘Exposure Job Title Dates
Plant Insulation Colgate-Palmolive Insulator : 10/1973-
2271 Califormia Street Berkeley, CA . 12/1973;
San Francisco, CA 3/1974-
3/1976;
10/1976-
2/1977 (1
month, on
and off}

Job Duties: Plaintiff insulated tanks with foam glass insulation and insulated pipes with
calcium-silicate insulation. Plaintiff installed all-purpose cement. Plaintiff recalls laborers
sweeping up debtis, Plaintiff-recalis the following supervisor: Allan Edwards, address
unknown. Plaintiff recalls the following co-worker: Gury Hansen, c/o BraytonPurcell LLP.
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation : Phillips Petroleum Insulator 10/1973-
2271 California Street Company/ Lyon Oil 12/1973;
San Francisco, CA Company 3/1974-
, Avon, CA 3/1976;
10/1976-
QASTTC
month, on
and oft}

Job Duties: .Plaintiff performed maintenance work after a large fire at the refinery. Plaintiff
installed PABCO insulation on a large tank, the surrounding piping and associated valves.
Plaintiff used POWERHOUSE cement. Plaintiff recalls working near pipefitters installing
pipes, gaskets, and valves. Plaintiff recalls pipefitters installing GARLOCK SEALING
TECHNOLOGIES, LLC and FLEXITALLIC gaskets. Plaintiff recalls laborers employed by

“TOSCO OIL sweeping up debris. Plaintiff recalls the following contractors: BECH'

CORPORATION (DE), SANTA FE BRAUN, INC. AS SUCCESSOR-IN-INTEREST TO C.F.
BRAUN, INC., OSCAR E, ERICKSON, INC., FOLEY-PMI, INC.. MONTEREY
MECHANICAL COMPANY. Plaintiff recalls the following supervisors: Glenn

‘Schimmelphenig, addrcss unknown; Al Holbrook, address unknown. Plaintiff recalls the

following co-workers: Robert Holbrook, address unknown; Roger Fonken, c/o

Brayton*? Purcell LLP; Dick Tobey, deceased. Plaintiff currently contends he was exposed to
asbestos during this employment.

Mil

Me

iW

Kafapuned TACALopysact mp 47 eesLogation of Exposure

Employer Exposure Job Title Dates
Plant Insulation Mare Island Naval Insulator 10/1973-
2271 California Street Shipyard 12/1973;
San Francisco, CA Vallejo, CA 3/1974-
3/1976;
USS TROUT (SS-566) 10/1976-
2N977 1
month, on
and off)

USS GUDGEON (SS-567}

Job Duties: Plaintiff repaired the insulation on two World War I] submarines. Plaintiff had to
remove some of the existing asbestos insulation in order to perform his duties. Plaintiff worked
near welders using asbestos blankets and pipefittcrs who were installing pipes, valves, pumps,
and gaskets. Plaintiff recalls that the following supervisor: John Price, c/o BraytonPurcell
LLP. Plaintiff recalls the following co-workers: Tom Sherwood, c/o Brayton*Purcell LLP;
Mike Hammer, address unknown; Rich Ciabattari, c/o Brayton¢*Purcell LLP; Edward Johnson,
c/o Brayton%+Purcell LLP; Doug Moon, address unknown. Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure _

Employer Exposure Job Title Dates
Plant Insulation * General America Soda Ash Insulator 110/1973-
2271 California Street Plant 12/1973;
San Francisco, CA Green River, Wyoming 3/1974-
3/1976;
10/1976-
2/1977 (2
months)

Job Duties: Paintiff insulated a boiler with 48 insulation and cal sil insulation. Plaintiff
applied CHEVRON covercote black mastic, Plaintiff worked near welders and near pipefitiers
installing pipes and gaskets. Plaintiff recalls the following co-workers: Arvis Duncan,
deceased: Robert Holbrook, c/o Brayton**Purcell LLP; Bill Detoe, deceased; Larry Hagen, San
Pablo, California; Mike Caylor, c/o Brayton%*Purcell LLP; Rich Ciabattari, Richmond,
California; Don Bass, c/o Brayton%Purcell LLP. Plaintiff currently contends he was exposed
to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Queen of the Valley Insulator 10/1973-
2271 California Street Hospital 12/1973;
San Francisco, CA Napa, CA 3/1974-
3/1976;
10/1976-
2977 (4
months, on
and off)

Ui

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RN me mmm
= S&S 0 wm WD UY BF WN

22

Job Duties: Plaintiff worked on an addition to the hospital. Plaintiff wrapped ducts. Plaintiff
worked in the boiler room and underneath the building where the existing asbestos insulation
was being disturbed. Plaintiff recalls insulating pipes that had some of the existing insulation
removed in order to tic in new pipes to the existing pipes. Plaintiff worked near pipefitters who
installed pipes, gaskcts and valves, Plaintiff recalls the following co-workers: Joseph O"Balle,
c/o Brayton**Purcell LLP; Bud Drose, deceased. Plaintiff currently contends he was exposed
to asbestos during this employment.

Location of Exposure
Employer ° Exposure Job Title Dates
Plant Insulation Standard Oil Building insulator 3/1974-
2271 California Street - San Francisco, CA 31976
San Francisco, CA (500 Market Street)

Job Duties: Plaintiff wrapped ducts. Plaintiff worked between the ceiling bars to do. his work.
Plaintiff recalls W.R. GRACE MONOKOTE fireproofing had been sprayed in his work area.
Plaintiff worked near ceiling tile workers who were cutting and installing cciling tiles, Plaintiff
recalls the following supervisor: Glenn Schimmelpheni , address unknown, Plaintiff recalls
the following co-worker: Bud Drose, deceased. P! jaintiff currently contends he was exposed to
asbestos during this employment. .

Location of Exposure
Employer Exposure Job Title Dates
Owens-Corning Fiberglas Anheuser Busch Insulator ANST6-
| Owens Cornmg Parkway (Budweiser) Brewery 10/1976 (3
Toledo, OH Fairfield, CA to4
: months)

Job Duties: Plaintiff recalls that his job duties were similar. to those at Budweiser Brewery
listed above. Plaintiff recalls the following supervisor: Carl Ramsey, c/o Brayton**Purcell
LLP. Plaintiff recalls the following co-workers: Dallas Peterson, deceased; Ted Schicbold, c/o
BraytonPurce'] LLP; Phil Peterson, c/o BraytonPurcell LLP; Herb Woods, c/o
Brayton¢*Purcell LLP; Harry Transue, c/o Brayton¢Purcell LLP; Tim Murphy, c/o
Brayton®Purcell LLP; Roger Bellamy, c/o Brayton Purcell LLP; Eric Bailey, c/o
Brayton**Purcell LLP. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
Employer - Exposure Job Title Dates
Owens-Coming Fiberglas Madules-Alaska Insulator 4/1976-
1 Owens Coming Parkway Sacramento, CA 10/1976 (3
Toledo, OH months)

Job Duties: Plaintiff installed insulation. Plaintiff used HENRY’S MASTIC on joints.
Plaintiff sprayed on INSULKOTE mastic. Plaintiff recalls the following foreman: Grant Cook,
c/o BraytonPurcell LLP. Plaintiff recalls the following co-workers: Russ Utterback,
Carmichzel, California; Ralph Drummer, c/o Brayton’Purcell LLP; Tom Begley, c/o
BraytonPurcell LLP; Jim Schwant, Clayton, Califomia; John Pollack, Clayton, California.
Plaintiff currently contends he was exposed to asbestos during this employment.

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K Gaia HAL upreae w 49 ccs,1

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Location of Exposure

Employer Exposure Job Tithe Dates
Plant Insulation Standard Oil Insulator 1974-1980
2271 California Strect Richmond, CA

San Francisco, CA

Job Duties: Plaintiff recalls installing insulation on pipes, valves and heat exchangers. Plaintiff
recalls having to crawl over pipes that were covered with asbestos insulation to perform ins
duties. Plaintiff recalls that his clothes and skin would be covered with dust. Plaintiffrecalls
working near welders using welding blankets, laborers sweeping up the site and near pipefitters
installing gaskets, valves and pipes, Plaintiff recalls that in the morning the crew would put on
their work coveralls in a changing shack on the job site and'remove them at the end of the shift
and store them in the changing shack for the next work day. Plaintiff recalls being around co-
workers who would pound thetr coveralls against the wall to get the dust off of them. Plainuif
recalls the following supervisors: Glenn Schimmelphenig, address unknown, Arvis Duncan, —
deceased. Plaintiff recalls the following co-workers: Don Burnett, Oakdale, Califomia; Warren
Hasse, c/o Brayton** Purcell LLP; Dick Tobey, deceased; Earl Riges, deceased; Roger Fonken
c/o Brayton Purcell LLP, Robert Holbrook, c/o Brayton*Purcell LLP; Joseph Q’Balle, c/o
Brayton**Purcell LLP; Robert Drose, address unknown; John Price, c/o Brayton**Purcell LLP;
Gary Boggs, c/o Brayton**Purcell LLP. Plaintiff currently contends he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Western MacArthur Louisiana Pacific Insulator 1/1974-
2855 Mandela Parkway Samoa, CA 3/974 G-
Oakland, CA, 4 weeks}

Job Duties: Plaintiff insulated vessels, pipes, valves and parts of the boiler using KAYLO
calcium silicate pipe-covering block and cements. Plaintiff tied into existing calcium silicate
pipe-covering. Plaintiff worked near LOUISIANA PACIFIC laborers sweeping up debris and
near welders. Plaintiff recalls the following co-workers: Dale Wright, Santa Rosa, Califomia;
James O'Neal, deceased. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Westem MacArthur Union Oil Insulator V1974-
2855 Mandela Parkway Rodeo/Oleum, CA . 3/1974 (3
Oakland, CA . weeks, on
. and off)

Job Duties: Plaintiff repaired existing insulation. Plaintiff applied POWERIIOUSE cement
and mastic, Plaintiff recalls that in the morning the crew would put on their work coveralls in a
changing shack on the job site and remove them at the end of the shift and store them in the
changing shack for the next work day. Plaintiff recalls being around co-workers who would
pound their coveralls against the wall to get the dust offaf them. Plaintiff worked ncar
pipefitters installing gaskets, valves and pipes. Plaintiff recalls the following supervisor: Pete
Laskier, Santa Rosa, Califomia. Plaintiff recalls the following co-workers: Charles Treadway,
deceased; Bill Armstrong, deceased; Mike Brissotte, deceased; Charles Evans, deccased.
Plaintiff currently contends he was exposed to asbestos during this employment.

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22

Location of Exposure

Employer Exposure Job Title Dates
Western MacArthur * Chevron Chemical Insulator V1 974-
2855 Mandela Parkway (aka Ortho Plant) 341974 (2
Oakland, CA. Richmond, CA weeks, on
and off)

Job Duties: Plaintiff insulated pipes with cal sil insulation and insulating cement on the fittings.

Plaintiff worked near welders and near pipefitters installing valves, gaskets, pumps and pipes.
Plaintiff recalls the following supervisor: Pete Laskier, Santa Rosa, California, Plaintiff recalls
the following co-workers: Dale Wright, Santa Rosa, California; Charles Treadway, deceased;
Mike Brissotte, deceased. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of Exposure
Employer Exposure Job Title Dates
Western MacArthur Todd Shipyard . Insulator V1974-
2855 Mandela Parkway Alameda, CA. 3/1974 (3
Oakland, CA weeks, on
and off)

Job Duties: Plaintiff worked on an aircraft carricr. Plaintiff worked in the boiler room,
Plaintiff recalls the following superintendent: Alan Vasen, address unknown. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer SUT . Job Title Dates
Combustion Engineering PG&E Powerhouse Insulator 2/1977-
ELL9 Riverfront Parkway Pittsburg, CA 3/1977 GB
Chattanooga, TN weeks)

Job Duties: Plaintiff repaired the tubing on a boiler. Plaintiff worked inside the boiler.
Plaintiff applied block and pipe insulation, and applied POWERHOUSE cement. Plaintiff
worked near welders and pipefitters installing valves, gaskets, pumps and pipes. Plaintiff
worked near laborers sweeping up debris. Plaintiff recalls the following supervisor: Bill
Muncie, Sacramento, Cahfomta. Plaintiff recalls the followmg co-workers: John Pollack,

|, Clayton, California; Dale Wright, Santa Rosa, California; Pete Trujillo, deceased; Bill Munson,

deceased; Willey Uterback, Sacramento, California; Spencer Pennington, deceased. Plaintiff

currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Combustion Engineering Mojave Powerhouse (SCE) _ Insulator 2/1977-
1119 Riverfront Parkway Laughlin, NV 3/1977
Chattanooga, IN - month)

Job Duties: Plaintilf applied a glass blanket to a boiler. Plaintiff worked with cal sil insulation
and POWERHOUSE cement. Plaintiff worked near welders and pipcefiticrs installing valves,
iskeis, pumps and pipes, and using asbestos cloth, Plaintiff recalls that BECHTEL
CORPORATION was the general contractor. Plaintiff recalls the following co-workers: Dale
Wright, address unknown; Willey Utterback, Sacramento, California; Spencer Pennington,

Keslsesit 982. capparch pd SI es10

Co we Ww Aw & YN

deceased; Clifford Ballou, c/o Brayton*Purcell LLP; Dick Simas, deceased. Plaintiff currently
contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Jeb Title Dates
Douglass Insulation Laguna Honda Hospital Insulator 4/1977-
3990 Ralston Avenue and Rehabilitation Center 5/1977 (2
Hillsborough, CA San Francisco, CA weeks)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near plumbers installing pipes,
gaskets ard valves. Plaintiff recalls working near sheet metal workers who shot studs into the

ms, knocking off the fireproofing. Plaintiff worked near laborers sweeping up debris.
Plaintiff recalls the following supervisor. Tom Douglass, deceased. Plaintiff recalls the
following co-worker: Joseph O’ Balle, c/o Brayton**Purcell LLP. Plaintiff currently contends
he was exposed to asbestos during this émployment. .

Location of Exposure
Employer Exposure . Job Title Dates
Douglass Insulation UCSF Medical Center Insulator 4It977-
3990 Ralston Avenue San Francisco, CA 5/1977,

Hillsborough, CA

Job Duties: Plaintiff repaired and installed pipe insulation. Plaintiff worked near pipefitters
installing pipes, gaskets and valves. Plaintif? worked near ceiling installers'cutting and
installing ceiling tiles. Plaintiff worked near sprinkler fitters using fireproofing spray. Plaintiff
worked near laborers sweeping up debris. Plaintiff recalls that fireproofing was being disturbed
by the ceiling tile workers and sprinkler fitters. Plaintiff recalls the following supervisor: Tom
Douglass, deceased. Plaintiff currently contends he was exposed to asbestos during this
employment.

Location of . Exposure
Employer Exposure dob Title Dates
Douglass Insulation . 555 Market Street Insulator 4N977-
3990 Ralston Avenue San Francisco, CA 5/1977 C1
Hillsborough, CA week)

Job Duties: Plaintiff repaired and installed pipe insulation. Plaintiff worked near plumbers
installing pipes, gaskets and valves. Plaintiff worked near drywall hangers cutting and
installing drywall. Plaintiff worked near tapers applying and sanding joint compound. Plaintiff
worked near ceiling tile workers cutting ceiling tiles. Plaintiff worked near laborers sweeping
up debris. Plaintiff recalls that fireproofing was being disturbed by the ceiling tile workers.
Plaintiff recalls employees of mechanical contractor KLEIN MECHANICAL werc installing
pipe. Plaintiff recalls employees of BROADWAY PLUMBING were installing plumbing and
disturbing fireproofing on the ceiling. Plaintiff recalls the following supervisor: Tom
Douglass, deccased. Plaintiff recalls the following co-worker: Joc O’Balle, South San
Francisco, Califomia. Plaintiff currently contends he was exposed to asbestos during this
employment.

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10

Location of Exposure

Employer Exposure Job Title - Dates

Douglass Insulation Douglass Insulation Shop — Insulator ANOTI-SH9TT (4
399) Ralston Avenue Yosemite Strect or 5 times)
Hillsborough, CA San Francisco, CA

Job Duties: Plaintiff delivered materials in the company van, which at varying times contained
asbestos-containing materials. Plaintiff also retrieved asbestos-containing matenals from the
shop. Plaintiff crawled in confined ceiling spaces in close proximity to existing asbestos-
containing products. Plaintiff recalls handling POWERHOUSE cement, 127 cement,
UNIBESTOS pipe insulation, and PABCO pipe insulation. Plaintiff recalls the following
supervisor: Tom Douglass, deccased. Plaintiff currently conténds he was exposed to asbestos
during this employment.

Location of Exposure
Employer Exposure Job Title Dates .
Consolidated Insulation Sun Valley Shopping Insulator S/7T-UBL (2
S17-D Marine View Ave. Center weeks, on and off)
Belmont, CA Concord, CA

Job Duties: Plaintiff does not currently recall the specifics of this employment. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer . Exposure Job Title Dates
Consolidated Insulation Kaiser Hospital Insulator S/1977-141981 (4
. (Broadway Street) weeks, on and off)
Oakland, CA

Job Duties: Plaintiff insulated pipes and ducts, Plaintiff worked near cciling tile workers who
were cutting and installing ceilmg tiles. Plaintiff worked near floor tile workers cutting and
installing floor tiles. Plaintiff recalls that fireproofing was being disturbed by the ceiling tile
workers. Plaintiff recalls the following supervisor: Robert Cantley, c/o Brayton%*Purcell LLP.
Plaintiff recalls the following co-workers: Jim White, Jr, address unknown; Joseph O’Balle,
c/o Bra on**Purcell LLP; Del Furia, deceased; Richard Collins, c/o Brayton%Purcell LLP.
Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer . Exposure Job Title | Dates
Consolidated Insulation Vallejo City Hall Insulator 1977 (3 weeks, on
517-D Marine View Aye. Vallejo, C. and off}

Belmont, CA

Job Duties: Plaintiff insulated pipes. Plaintiff worked near tapers installing and sanding joint
compound and near drywall hangers cutting and installing drywall. Plaintiff recalls the
folowing supervisor: Robert Cantley, c/o Brayton*Purcell LLP. Plaintiff recalls the following
co-workers: Jim White, Jr., address unknown; Warren Haase, 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 Dates
Consolidated Insulation 500 Howard St. . Insulator 1977 (1
517-D Marine View Ave. San Francisco, CA week, on
Belmont, CA and off)

Job Duties: Plaintiff wrapped ducts. Plaintiff worked near employees spraying an acoustical
ceiling and near tapers applying and sanding joint compound. Plamtiff recalls the following
supervisor: Robert Cantley, c/o Brayton*Purcell LLP. Plaintiff currently contends he was
exposed to asbestos during this employment.

| Location of Exposure

| Employer Exposure Job Title Dates
Consolidated Insulation Veterans Administration Insulator 1977
317-D Marine View Ave. Hospital (approx 2
Belmont, CA Palo Alto, CA months)

Job Daties: Plaintiff installed cal sil insulation and wrapped ducts. Plaintiff repaired insulation

| and had to remave some of the existing asbestos insulation. Plaintiff worked near laborers

sweeping up debris and pipefitters inslalling pipes, gaskets and valves. Plamtiff worked near

i ling joint compound. Plaintiff believes that one of the suppliers of
asbestos products to this site was CAL-STEAM SUPPLY. Plaintiff recalls the following
supervisor: Robert Cantley, c/o Brayton*Purcell LLP. Plaintiff currently contends he was
exposed to asbestas during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Davies Symphony Halt Insulator : 1977-1980
| 517-D Marine View Ave. San Francisco, CA . (3 weeks,
| Belmont, CA on and off}

Job Duties: Plaintiff wrapped ducts and insulated piping. Plaintiff recalls that fireproofing was

| being disturbed by electricians, sprinkler fitters and sheet metal workers. Plaintiff recalls

working near pipefitters installing gaskets, pipes, and valves. Plaintiff recalls the following
supervisors; Robert Cantley, c/o BraytonPurcell LLP; Earl Beck, deceased. Plaintiff recalls
the following co-workers: Robert Wildoner, c/o Brayton%Purcell LLP; Greg Beck, Sonoma,
Califomia; Vernon Farquhar, c/o Brayton%*Purcell-LLP. Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation 459 Post St. Insulator 1977-1980
517-D Marine View Ave. San Francisco, CA (I week, on
Belmont, CA and off}

Job Duties: Plaintiff installed insulation. Plaintiff worked near pipefitters installing gaskets,
valves, and i pipes. Plaintiff worked near plumbers, welders and shect metal workers. Plaintiff
recalls the following supervisor: Robert Cantley, c/o Brayton’*Purcell LLP. Plaintiff recalls
the following co-workers: Earl Beck, deceased; Mark Cantley, c/o Brayton%*Purcell LLP;
Robert Wildoner, c/o Brayton%Purcell LLP; Veron Farquhar, 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 Dates

Consolidated Insulation - Mare Island Naval Insulator 1977 (3 to
$1L7-D Marine View Ave. Shipyard 4 weeks, on
Belmont, CA Vallejo, CA and off)

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked throughout one of the
butidings including in the boiler room and in the mechanical rooms. Plaintiff installed
FOSTER’S MASTIC. Plaintiff recalls working near pipefitters from AMOS & ANDREWS
INC., who were installing pipes, gaskets and valves. Plaintiff recalls working near tapers
applying. and sanding joint compound. Plaintiff recalls the following supervisor: Dick Saiya,
elmont, California. Plaintiff recalls the following co-worker: Jim White, Jr., address ,
unknown. Plaintiff currently contends he was exposed to ashestos during this employment.

Location of . Exposure
Employer E Job Title Dates
Consolidated Insulation US Air Force Insulator 19773
517-D Marine View Ave. Travis Air Force Base weeks, on
Belmont, CA Fairfield, CA. and off)

Job Duties: Plaintiff insulated two tanks. Plaintiff installed 301 cement and BLUE MUD
cement. Plaintiff recalls the following supervisor: Robert Cantley, c/o Brayton%*Purcel! LLP.

|| Plaintiff recalls the following co-worker: Jim White, Jr., address unknown. Plaintiff currently

contends he was exposed to asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Sonoma State Hospital Insulator 1977 @.
517-D Marine View Ave. Eldridge, CA weeks, on
Belmont, CA. and off}

Job Duties: Plaintiff insulated pipes with cal sil and used asbestos cement and zestons for the
fittings. Plaintiff worked near welders and near pipefitters and plumbers from PETERSON
MECHANICAL installing pipes, gaskets and valves for the heating and air conditioning.
Plaintiff worked near employees working on the controls and believes that they were employed
by JOHNSON CONTROLS. Plaintiff recalls the following supervisor: Robert Cantley, c/o
Brayton**Purcell LLP. Plaintiff recalls the following co-workers: Jim White, Jr., address
unknown; Warren Haase, c/o Brayton%*Purcell LLP. Plaintiff currently contends he was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Santa Rosa Junior College — Insulator 1977 (2
517-D Marine View Ave. Santa Rosa, CA wecks, on
Belmont, CA and off)

Job Duties: Plaintiff worked on a remodel and had to remove some existing insulation on the
job. Plaintiff insulated ducts and pipes. Plaintiff worked near plumbers and pipefitters from
ALL & SONS who were installing gaskets and piping for the heating and air-conditioning.
Plaintiff recalls working near sheet metal workers from MALM SHEET METAL who were
disturbing the insulation. Plaintiff recalls the following supervisor: Robert Cantley, c/o

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Brayton%Purcell LLP. Plaintiff recalis the following co-worker, Jim White, Ir., address
unknown. Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title
Consolidated Insulation Roosevelt Middle School Insulator 1977 (1
517-D Marine View Ave. San Francisco, CA week, on and
Belmont, CA {460 Arguello) ~ off

Job Duties: Plaintiff worked on an addition to the school. Plaintiff had to remove and replace ©
ceiling tiles. Plaintiff insulated pipes and had to disturb some of the existing insulation.
Plaintiff recalls the following supervisor: Robert Cantley, c/o Brayton**Purcell LLP. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Standard Oi] Building Insulator 1977 (1 weel
517-D Marine View Ave. San Francisco, CA on and off)
Belmont, CA {500 Market St.)

Job Duties: Plaintiff insulated ducts and installed INSULKOTE. Plaintiff worked near floor
installers installing floor tiles, laborers sweeping up debris and near tapers applying and
sanding joint compound. Plaintiff recalls the following supervisor: Robert Cantley, c/o
Brayton%Purcell LLP. Plaintiff currently contends he was exposed to asbestos during this

employment.

. Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Bullocks : Insulator 1977 (1
517-D Marine View Ave. Palo Alto, CA month, on
Belmont, CA (Stanford Shopping Center) and off)

Job Duties: Plaintiff insulated ducts. Plaintiff worked near pipefitters installing gaskets, pipes
and valves. Plaintiff worked near floor installers. Plaintiff recalls the following supervisor:
Robert Cantley, c/o Brayton¢Purcell LLP. Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Veterans Administration Insulator 1965-1993
517-D Marine View Ave. Hospital (on and
Belmont, CA Palo Alto, CA off)

Job Duties: Plaintiff installed cal-sil insulation and installed all-purpose cement. Plaintiff
removed and replaced ceiling tiles. Plaintiff worked near laborers sweeping up debris.
Plaintiff worked near welders and pipefitters idstalling pipes, gaskets and valves. Plaintiff
recalls the following supervisor: Dick Saiya, Belmont, California. Plaintiff recalls the
following co-workers: Ron Kitt. address unknown; Kelly Durr, deceased; Robert Cantley, c/o
Brayton**Purcell LLP. Plaintiff currently contends he was exposed to asbestos during this
employment.

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Emplo: Exposure Job Title Dates

Consolidated Insulation UCSF Medical Center Insulator 1977-1979

517-D Marine View Ave. San Francisco, CA (4 months,

Belmont, CA. {Parnassus Street); on and off)
Long’s Hospital

San Francisco, CA

Job Dutics: Plaintiff insulated pipes and installed board glass. Plaintiff worked near plumbers
and pipefitiers installing pipes, gaskets and valves. Plaintiff recalls the following supervisor:
Robert Cantley, c/a Brayton+Purcell LLP. Plaintiff recalls the following coworkers: Richard
Collins, c/o Brayton® Purcell LLP; Bill Dalton, address unknown; Greg Beck, Sonoma,
Califomia; Bill Houston, deceased; Jim White, Jr, address unknown. Plaintiff currently
coritends he was exposed to asbestos during this employment.

Location of » Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Levi Strauss Insulator 5/77-1/8b
$17-D Marine View Ave. San.Francisco, CA {1 month,
Belmont, CA on and off}

Job Duties: Plaintiff insulated pipes and ducts. Plaintiff worked near pipefitiers installing
pipes, gaskets and valves, and using packing. Plaintiff recalls the following supervisor: Robert
Cantley, c/o Brayton%Purcell LLP. Plaintiff recalls the following coworkers: Mike Lind,
address unknown; Greg Beck, address unknown; Earl Beck, deceased. Plaintiff currently
contends he was exposed to asbestos during this employment.

Location of ‘ Exposure
Employer Exposure Job Tit Dates
Consolidated Insulation Pacific Bell Insulator : 5/77-1/81
57-D Marine View Ave. San Francisco () week, on
Belmont, CA (85 Second Street} and off}

Job Duties: Plaintiff insulated pipes and installed board glass. Plaintiff recalls the following
supervisor: Robert Cantley, c/o Brayton*Purcell LLP. Plaintiff recalls the following
coworkers: Earl Beck, deceased; Robert Wildoner, c/o Brayton Purcell LLP. Plaintiff
currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Social Services Building Insulator 1978 (2
517-D Marine View Ave. San Francisco, CA months, on
Belmont, CA (150 Otis Street) ~ and off)

Job Dutics: Plaintiff insulated pipes and ducts. Plaintiff worked near sprinkler fitters installing
sprinkler systems. Plaintiff worked near pipefitters who he believes were employed by
ANDERSON ROWE & BUCKLEY, installing gaskets, pipes and valves. Plaintiff worked
near an employee he believes was from JOHNSON CONTROLS who were working on the
controls. Plaintiff recalls the following supervisor: Robert Cantley, 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 Dates
Consolidated Insulation UCSF School of Dentistry Insulator 1978 (3
517-D Marine View Ave. San Francisco, CA - weeks, on
Belmont, CA and off}
Job Duties: Plaintiff insulated pipes. Plaintiff recalls that the general contractor at this site was
DILLINGHAM. Plaintiff worked near emp loyees from GOLDEN GATE DRYWALL who
Were applying and sanding joint compound. Plaintiff recalls the following supcrvisor: Robert
Cantley, c/o Brayton*Purcell LLP. Plaintiff recalls the following co-workers: Greg Beck,
Sonoma, California, Mike Lind, Sonoma, California; Robert Hussey, address unknown.
Plaintiff currently contends he was exposed to ashesios during this employment.

Location of Exposure
Employer. Exposure Job Title Dates
Consolidated Insulation Veterans Administration Insulator 1978 (1
517-D Marine View Ave. Hospital month, on
Belmont, CA Martinez, CA and off)

Job Duties: Plaintiff insulated ducts. Plamtiff worked near employees who were working on
the controls. Plaintiff worked near sprinkler fitters and pipefitters who were installing pipes,
valves, and gaskets. Plaintif¥ worked near drywall hangers, and tapers who were applying and
sanding jomt compound. Plaintiff worked near sheet metal workers and worked near
fireproofing. Plaintiff recalls the following supervisor: Robert Cantley, c/o Brayton*¢Purcell
LLP. Plaintiff currently contends he was exposed to asbestos during this employment.

Location of : Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Embarcadero (#3) Insulator 1978 (2
517-D Marine View Ave. San Francisco, CA weeks, on
Belmont, CA and off}

Job Duties: Plaintiff insulated ducts. Plaintiff worked near drywall hangers and tapers
applying and sanding joint compound. Plaintiff recalls working near floor installers installing

oor tiles. Plaintiff recalls the controls workers were disturbing existing fireproofing. Plaintiff
recalls that HONEYWELL INTERNATIONAL was the controls contractor. Plaintiff recalls
the following supervisor: Robert Cantley, c/o Brayton%*Purcell LLP. Plaintiff recalls the
following co-worker: Earl Beck, deceased. Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Bank of America Building Insulator 1978 2
517-D Marine View Ave. San Francisco, CA weeks, on
Belmont, CA (100 California St) and off)

Job Duties: Plaintiff insulated ducts. Plaintiff recalls that fireproofing had been disturbed by
other trades and had fallen on the top of the ducts and on the floors. Plaintiff recalls laborers
sweeping up the debris. Plaintiff worked near sheet metal workers disturbing the insulation in
order to install the ducts. Plaintiff worked near sprinkler fitters and pipefitters who were
installing pipes, valves, and gaskets. Plamtiff worked near plumbers. Plaintiff recalls the

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following supervisor: Robert Cantley, c/o Brayton%*Purcel! LLP. Plaintiff recalls the
following co-worker: Earl Beck, deceased. Plaintiff currently contends he was exposed to

asbestos during this employment.

Location of Exposure
Employer Exposure Job Title
Consolidated Insulation Bay View Housing Insulator 1978 (2
517-D Marine View Ave. Development weeks, on
Belmont, CA (Hunters Point) and off)

San Francisco, CA
Job Duties: Plaintiff insulated ducts. Plaintiff recalls the following supervisor: Robert
Cantley, c/o Brayton’*Purcel! LLP, Plaintiff recalls working in the mechanical room near
existing asbestos covered piping. Plaintiff currently contends that he was exposed to asbestos
during this employnient. .

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Sonoma State Hospital Insulator - 19782
517-D Marine View Ave. Eldridge, CA weeks, on
Belmont, CA . and off}
Job Dutics: Plaintiff insulated pipes. Plaintiff performed repairs to existing insulation and had

to remove some of the insulation to make the repairs. Plaintiff worked near employees from
GOLDEN GATE DRYWALL who were applying and sanding joint compound. Plaintiff
recalls the following supervisor: Robert Cantley, c/o Brayton*%*Purcell LLP. Plaintiff recalls
the following co-workers: Warren Haase, c/o Brayton%Purcell LLP; Jim White, Ir., address
unknown. Plaintiff currently contends he was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Kaiser Hospital Insulator 1977-1980 (2
517-D Marine View Ave. Richmond, CA. - (foreman) weeks, on an
Belmont, CA off)

Job Duties: Plaintiff insulated ducts and pipes. Plaintiff worked near employees from
GOLDEN GATE DRYWALL who were applying and sanding joint compound. Plaintiff
recalls working near fireproofing that had been disturbed, Plaintiff recalis laborers sweeping
up the debris. Plaintiff recalls others using asbestos wallboard. Plaintiff recalls contractor:
LATHROP. Plaintiff recalls materials supplied by CERTAINTEED. Plaintiff recalls the
following supervisor: Robert Cantley, c/o Brayton%+Purcell LLP. Plaintiff recalls the
following co-workers: Dick Tobey; deecased; Roger Fonken, c/o Brayton“*Purceli LLP; and
Mark Cantley, c/o BraytonPurcell LLP. Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer Expesure Job Title Dates
Consolidated Insulation Signetics Insulator 1978 (1 week
517-D Marine View Ave, Sunnyvale, CA : on and off)

Belmont, CA

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Job Duties: Plaintiff insulated ducts and pipes. Plaintiff recalls the following supervisor:
Robert Cantley, c/o Brayton’*Purcell LLP. Plaintiff currently contends he was exposed to
asbestos during this employment.

Location of Exposure
Employer ’ Exposure Ieb Title Dates
Consolidated Insulation Golden Gate University Insulator 1978-1979
547-D Marine View Ave. San Francisco, CA G months,
Belmont, CA (Mission St.) on and off)

Job Duties: Plaintiff insulated pipes inside the building and on the roof. Plaintiff insulated
pipes that were tied into pipes that had the existing insulation removed. Plaintiff recalls having
to remove and replace ceiling tiles. Plaintiff worked near drywall hangers who were cutting
and installing drywall. Plaintiff worked near tapers who were applying and sanding joint
compound. Plaintiff worked near sprinkler fitters who installed gaskets and pipes and
disturbed some of the fireproofing in order to install their pipes. Plaintiff worked near
pipefitters who installed gaskets, pipes and valves. Plaintiff worked near laborers who were
sweeping up debris and believes that they might have been hired by PERINI CORPORATION.
Plaintiffrecalls the following supervisor. Robert Cantley, c/o Brayton+Purcell LLP. Plaintiff
recalls the following co-workers: Roger Fonken, c/o Brayton%*Purcell LLP; Dick Tobey,
deceased; Earl Beck, deceased. Plaintiff currently contends he was exposed to asbestos during
this employment.

Location of . Exposure
Employer Exposure Job Title a
Consolidated Insulation Coca Cola Co. Insulator 1978-1979
517-D Marine View Ave. San Francisco, CA (2 weeks,
Belmont; CA _ onand off)

Job Duties: Plaintiff was supplied with some asbestos pipe covering by the owner of
Consolidated, Inc., Dick Saiya, Belmont, California, and he initially installed some of it.
Plaintiff recalls that Dick Salya purchased asbestos from the govemment and changed the
markings on the packaging so that it didn’t say “asbestos”, Plaintiff then threw the rest of it
away and ordered more supplies. Plaintiff wore a 3M paper mask. Plaintiff currently contends
he was exposed to asbestos during this employment,

. Location of : Exposure
Employer Exposure Job Title Dates
Consolidated Insulation Fairfield Hospital Insulator 1979 1
517-D Marine V