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  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview
  • ROBERT ROSS et al VS. C.C. MOORE & CO. ENGINEERS ASBESTOS document preview 
						
                                
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                                BARBARA R. ADAMS, SBN 99231
GEORGES A, HADDAD, SBN 241785
ADAMS | NYE | BECHT LLP

222 Kearny Street, Seventh Floor

San Francisco, California 94108-4521 ELECTRONICALLY
Telephone: (415) 982-8955 FILED
Facsimile: (415) 982-2042 Superior Court of California,
E-mail: badams@adamsnye.com County of San Francisco
ghaddad@adamsnye.com 08/17/2015

Clerk of the Court
BY:RONNIE OTERO.

Attorneys for Defendant Deputy Clerk

PRIBUSS ENGINEERING, INC.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO

ROBERT ROSS and JEAN ROSS, ASBESTOS
No. CGC-10-275731
Plaintiffs,
DECLARATION OF GEORGES A.
vs. HADDAD IN SUPPORT OF
DEFENDANT PRIBUSS
C.C. MOORE & CO. ENGINEERS; Defendants ENGINEERING, INC.’S OPPOSITION
as Reflected on Exhibit 1 attached to the TO PLAINTIFFS’ MOTION TO
Summary Complaint herein; and DOES 1-8500, CONSOLIDATE
Defendants. 2nd Amended Complaint Filed: 5/16/11

3"? Amended Complaint filed : 5/11/12

I, Georges A. Haddad, declare:

1. lam an attorney licensed to practice in the State of California, and I am a partner in the
law firm of Adams | Nye | Becht, LLP.

2. My law firm represents PRIBUSS ENGINEERING, INC. in the Robert Ross, et al. v.
C.C. Moore & Co. Engineers, et al. (CGC-10-275731) matter captioned above. If called as a witness,
I can competently testify to the facts set forth below.

3. PRIBUSS ENGINEERING, INC. is not a party to the Anthony Roman, Sr., et al. v,
Asbestos Corporation Limited, et al. (CGC-10-275675), Raymond Barragan v. Thomas Dee
Engineering, et al., (CGC-10-275713), and Larrell Fortner, et al. v. Thomas Dee Engineering, et al.
(CGC-11-275935) matters.

Mi 7 1

— ~ DECLARATION OF GEORGES A. HADDAD IN SUPPORT OF DEFENDANT
PRIBUSS ENGINEERING, INC,'S OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE4, On or around August 11, 2015, Plaintiffs filed their motion to consolidate the four
above entitled matters.

5. Based upon my familiarity with the Ross case and my review of the other three
Plaintiffs’ work histories, attached as Exhibits B through E to the Declaration of Geoff T. Sloniker,
Esq. in Support of Plaintiffs’ Motion to Consolidate for Trial Living Colon Cancer/Brayton Cases, the
Plaintiffs in these four cases allege exposures to asbestos from various trades and job locations
throughout the United States, without any overlap or common worksites with Robert Ross other than a
sporadic four and a half month period between 1961 and 1965 in which Mr. Ross may have worked at
one common worksite with Plaintiff Anthony Roman, Jr. Mr. Ross did not work at any other common
worksites with any of the other Plaintiffs that are the subject of this Motion. Moreover, none of the
other three Plaintiffs share a similar occupation with Plaintiff Robert Ross, a career insulator from

1959 to 1986.

6. On March 5, 2007, Plaintiff Ross filed an action alleging non-malignant disease caused by
asbestos exposure. When the instant action was filed, three and one-half years later, defendants
moved to dismiss the allegations of non-malignant diseases in this case. Plaintiffs voluntarily
dismissed such claims. Only colon cancer is alleged as against Pribuss Engineering, Inc. and most if
not all remaining defendants.

I declare under penalty of perjury under the laws of the State of California that the forgoing is

true and correct. This declaration was executed in San Francisco, California on August 17, 2015,
é D

Georg¢s A. Haddad

2

DECLARATION OF GEORGES A. HADDAD IN SUPPORT OF DEFENDANT
PRIBUSS ENGINEERING, INC.’S OPPOSITION TO PLAINTIFFS? MOTION TO CONSOLIDATEXx

PROOF OF SERVICE

lam over the age of eighteen years, not a party to the above-captioned matter, and employed

yy Adams | Nye | Becht LLP at 222 Kearny Street, Seventh Floor, San Francisco, California, where
the service described below took place on the date set forth below.

Person(s) Served:

Electronic service (San Francisco asbestos cases): I caused a copy of each Document Served to
be electronically served via LexisNexis File & Serve pursuant to San Francisco Superior Court
Amended Asbestos General Order 158 (Order Mandating Electronic Filing and Service of
Asbestos Pleadings, dated July 14, 2006) on the recipients designated on the Transaction
Receipt located on the LexisNexis File & Serve website.

Document Served:

DECLARATION OF GEORGES A. HADDAD IN SUPPORT OF DEFENDANT PRIBUSS
ENGINEERING, INC.’S OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE

Manner of Service:

Mail: I am readily familiar with my employer's practice for the collection and processing of
correspondence for mailing with the United States Postal Service: such correspondence is
deposited with the United States Postal Service on the same day in the ordinary course of
business in the county where I work. On the date set forth below, at my place of business,
following ordinary business practices, 1 placed for collection and mailing by deposit in the
United States Postal Service a copy of each Document Served, enclosed in a sealed envelope,
with the postage thereon fully prepaid, each envelope being addressed to one of the Person(s)
Served, in accordance with Code of Civil Procedure 1013(a).

Facsimile: I transmitted by facsimile a copy of each Document Served mentioned above to each
Person Served mentioned above pursuant to Code of Civil Procedure 1013(e).

Personal service: I caused a copy of each Document Served to be hand delivered to each
Person Served pursuant to Code of Civil Procedure 1011. If required, the actual server’s
original proof of personal service will be filed with the court.

Express Mail (U.S. Post Office): I deposited in a post office, mailbox, or other like facility
regularly maintained by the United States Postal Service for receipt of Express Mail a copy of
each Document Served in a sealed envelope with Express Mail postage paid, each envelope
being addressed to each Person Served as mentioned above in accordance with Code of Civil
Procedure 1013(c).

Express Mail (other express service carrier): I deposited in a box or other like facility
regularly maintained by an express service carrier, or delivered to an authorized courier or
driver authorized by the express service carrier to receive documents, a copy of each Document
Served in an envelope or package designated by the express service carrier with delivery fees
paid or provided for, each envelope being addressed to each Person Served in accordance with
Code of Civil Procedure 1013 (c).

3

DECLARATION OF GEORGES A. HADDAD IN SUPPORT OF DEFENDANT
PRIBUSS ENGINEERING, INC.’S OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATEYN Dn wef WN

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and
correct,

Dated: August 17, 2015 CRecthines Nee
Christine Thomas

4

DECLARATION OF GEORGES A. HADDAD EN SUPPORT OF DEFENDANT
PRIBUSS ENGINEERING, INC.’S OPPOSITION TO PLAINTIFFS’ MOTION TO CONSOLIDATE