On December 17, 2010 a Trial Materials 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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LAW OFFICES IMAI, TADLOCK, KEENEY & CORDERY, LLP SUITE 1300 100 BUSH STREET SAN FR. Theodore T. Cordery, Esq. (Bar No. 114730) tcordery@itke.com Michael J. Boland, Esq. (Bar No. 98343) mboland@itke.com ELECTRONICALLY Stephen E. Carlson, Esq. (Bar No. 104279) FILED scarlson@itke.com Superior Court of Califomia, IMAI, TADLOCK, KEENEY & CORDERY, LLP County of San Francisco 100 BUSH STREET, SUITE 1300 08/13/2015 SAN FRANCISCO, CA 94104 Clerk of the Court Telephone: (415) 675-7000 pxavorranames || || Facsimile: (415) 675-7008 Deputy Attorneys for Defendant CLAUSEN-PATTEN, INC., A DISSOLVED CORPORATION IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION ROBERT ROSS and JEAN ROSS, CASE NO.: CGC-10-275731 (ASBESTOS) Plaintiff, WITNESS LIST OF DEFENDANT v. CLAUSSEN-PATTEN, INC., A DISSOLVED CORPORATION C.C. MOORE & CO. ENGINEERS; Complaint Filed: December 17, 2010 Defendants as Reflected on Exhibit attached to | Trial Date: August 10, 2015 the Sumary Complaint herein; and DOES 1- 8500, Defendant. Defendant CLAUSEN--PATTEN, INC., A DISSOLVED CORPORATION may call the following witnesses at trial: 1. Thomas Anderson — Mr. Anderson is a general contractor expert, whose primary focus of testimony may be the standard of care of contractors and premises owners with respect to jobsite protocol and procedures. The expected time of direct examination: one hour 2. Jeffrey Birkner, Ph.D. — Dr. Birkner is a certified industrial hygienist who may provide opinions regarding the application of industrial hygiene principals to the facts of this -l- WITNESS LIST OF DEFENDANT CLAUSSEN-PATTEN, INC., A DISSOLVED CORPORATIONLAW OFFICES IMAI, TADLOCK, KEENEY & CORDERY, LLP SUITE 1300 100 BUSH STREET SAN FRANCISCO, CA 94104 (415) 675-7000 case. He may also testify specifically as to the allegations made against San Francisco Gravel Company, Inc. The expected time of direct examination: two hours 3. Laura Dolan, MBA. Ms. Dolan is an expert in the field of economics and economic loss evaluation. She may testify concerning the appropriate calculation of damages in this case. Additionally, she may offer criticism of the plaintiff's proposed calculation of damages in this case. Lastly, she may offer alternative methods to evaluate the claimed economic loss by plaintiff. The expected time of direct examination: one hour 4. Gerald Meyers, M.D. Dr. Meyers is a pulmonologist who may testify concerning his knowledge of lungs and thoracic organ functions. He may discuss Plaintiff's medical condition, his smoking history and explain asbestos-related markers found in the lings including pleural plaques or diffuse interstitial lung disease. He may also testify concerning the Plaintiff's medical treatment, cost of his medical care, and the medical damages allegedly suffered by Plaintiff. He may testify regarding issues of alternative causation and life-shortening problems unrelated to Plaintiff's alleged asbestos exposure. The expected time of direct examination: three hours 5. Norman Moscow, M.D. Dr. Moscow is a radiologist who may testify to explain the radiographic evidence taken of Plaintiff's lungs including but not limited to x-rays and CT scans. He may also opine concerning Decedent's history of smoking and alcohol consumption and the effects there from. The expected time of direct examination: two hours 6. Samuel Spivack, M.D. Dr. Spivack is an oncologist. He may testify regarding the alleged connection between plaintiff's medical condition and any asbestos exposure, the treatment of and prognosis for plaintiff's medical condition, and issues regarding causation. The expected time of direct examination: two hours 7. Khalil Sheibani, M.D. Dr. Sheibani is a pathologist. He may testify as to medical issues relative to asbestos exposure and the pathological aspects of plaintiff's case, 2- WITNESS LIST OF DEFENDANT CLAUSSEN-PATTEN, INC., A DISSOLVED CORPORATIONLAW OFFICES IMAI, TADLOCK, KEE) me a a > m a a mm ° o 3S b surn SAN FRANCISCO, CA 94104 (415) 675-7000 including Plaintiff's medical condition, issues, and alternative causation, as well as life- shortening health problems of Plaintiff not related to alleged asbestos exposure. The expected time of direct examination: two hours 8. Noel Weiss, M.D. Dr. Weiss is an epidemiologist. He may be called to testify as to epidemiological issues relating to Plaintiff's physical condition, the relationship between asbestos exposure and any increased risk of cancer, medical causation and life shortening problems not related to alleged asbestos exposure. He may also testify as to the "state of the art" based upon his review of the medical literature. His areas of expertise are epidemiology and biostatistics, with an emphasis on the study of cancer. The expected time of direct examination: three hours 9. Corporated Representative Defendant Clausen-Patten, Inc., a Dissolved Corporation may present a corporate representative to testify about its history, business operations/protocol, and related subjects. The testimony may also include the plaintiff's jobsites alleged to be managed or visited by Clausen--Patten, Inc., a Dissolved Corporation. The expected time of direct examination: two hours Defendant hereby joins in the Witness List of each and every other defendant in this case. Defendant reserves the right to amend this list as the evidence may require during Trial. Defendant reserves the right to call unlisted witnesses from the Expert Witness Designation by designated defense counsel, the law offices of Berry & Berry. Defendant reserves the right to call unlisted witnesses in rebuttal. Defendant reserves the right to call any of plaintiff’s treating physicians, examiners, and custodian of records from any medical treatment facility which was the source of examination or treatment. Dated: August 12, 2015 IMAI, TADLOCK, KEENEY & CORDERY, LLP By: /s/ Stephen E. Carlson Stephen E. Carlson Attorneys for Defendant CLAUSEN-PATTEN, INC., A DISSOLVED CORPORATION 3. WITNESS LIST OF DEFENDANT CLAUSSEN-PATTEN, INC., A DISSOLVED CORPORATION& CORDERY, LLP IMAI, TADLOCK, & S c -7000 oe I NA PROOF OF SERVICE USING LEXISNEXIS I, Carol Levine, declare: 1am a resident of the State of California and over the age of eighteen years, and not a party to the within action; my business address is 100 Bush Street, Suite 1300, San Francisco, California 94104. On the date of execution below, I electronically served the document via LexisNexis File & Serve described as: WITNESS LIST OF DEFENDANT CLAUSSEN-PATTEN, INC., A DISSOLVED CORPORATION on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve Web site. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on August 15, 2015, at San Francisco, California KG A brn —— ‘rol Levine’ “WITNESS LIST OF DI