On May 20, 2009 a Motion,Ex Parte was filed involving a dispute between Juelch, Joyce, Juelch Sr, Norman, and 3M Company, 84 Lumber Company, 84 Lumber Company, A Limited Partnership, All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, Asbestos Defendants, Cbs Corporation, A Delaware Corporation, F K A, Chevron U.S.A. Inc., Consolidated Insulation, Inc., Csk Auto, Inc., Dillingham Construction N.A., Inc., Does 1-8500, Douglass Insulation Company, Inc., Garlock Sealing Technologies, Llc, General Electric Company, Genuine Parts Company, Hamilton Materials, Inc., J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Metalclad Insulation Corporation, Oscar E. Erickson, Inc., Pacific Gas And Electric Company, Pacipic Bell Telephone Company, Parker Hannifin Corporation, Quintec Industries, Inc., Redwood Plumbing Co., Inc., Santa Fe Braun, Inc., Sequoia Ventures Inc., Shell Oil Company, Thomas Dee Engineering Company, Timec Company, Inc., Tosco Refining Company, Inc., Union Carbide Corporation, Union Oil Company Of California, Unocal Corporation, for ASBESTOS in the District Court of San Francisco County.
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co Oo ND WA BRB WN NR BP RY NY NY KR NNR me es it NDA WwW BW H B&F Sow we AA HA KR BW NH SB Ss 28 McCall, LLP ATIORNETS ATLA | ROBERT M. CHANNEL, State Bar No. 109273 IAN P. DILLON, State Bar No. 203612 WALSWORTH, FRANKLIN, BEVINS & McCALL, LLP ELECTRONICALLY 601 Montgomery Street, Ninth Floor San Francisco, California 94111-2612 8 F I L E D | Telephone: (415) 781-7072 County of san Fran isco Facsimile: (415) 391-6258 APR 01 2010 Attorneys for Defendant Clerk of the Court HAMILTON MATERIALS, INC. BY: CHRISTLE ARR k eputy Cle SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH AND NORMAN JUELCH, Case No. CGC-09-275212 SR., DEFENDANT HAMILTON Plaintiffs, MATERIALS, INC.'S MOTION IN LIMINE #3 TO SEVENTY-TWO HOUR vs. PREDISCLOSURE OF DOCUMENTS AND WITNESSES PRIOR TO ASBESTOS DEFENDANTS, et al., PRESENTATION AT TRIAL Defendants, Trial Date: April 5, 2010 Defendant HAMILTON MATERIALS, INC. requests this Court issue the following Orders in conjunction with trial of the above-entitled matter. 1. That each party advise all other parties, at least seventy-two (72) hours in advance, of each witness that the party will call at trial. 2. That each party designate documents seventy-two (72) hours prior to seeking to admit the documents into evidence or to elicit testimony from a witness concerning the document. 3. That no documents be specifically referred to or quoted by any attorney until the opposing side has had the opportunity to request a hearing on the admissibility, out of the presence of the jury. The above Orders will allow the parties to adequately prepare for this trial. There are thousands of documents and hundreds of potential witnesses available to all parties. Many documents and some testimony should be excluded. Disputed evidence should not be referred to in -1- PIPREDISCLOSURE OF DOCUMENTS AND WIINESSES PRIOK 10 PRESENTATION AT-TRIAL © 897448.) 1155-5.25571 | the presence of the jury until the Court has issued a ruling. Equal application of the Orders 2 | requested would ensure a faster trial and would avoid undue prejudice. 3 ||Dated: March_3©_, 2010 WALSWORTH, FRANKLIN, BEVINS & McCALL, LLP 4 C “4 5 By: Cen Wo \ JAN P. DILLON 6 ROBERT M. CHANNEL Attorneys for Defendant 7 HAMILTON MATERIALS, INC. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 | 24 25 2| 27 28 Walsworth, -2- 2 | RE NO RN arr I 3097448. 1155-5,255728 ‘Watsworth, Franidin, Bevins & McCall, LLP Arronwcrsartaw | PROOF OF SERVICE Iam employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action. My business address is 601 Montgomery Street, Ninth Floor, San Francisco, California 94111-2612. On March 2010, I served the within document(s) described as: DEFENDANT HAMILTON MATERIALS, INC.'S MOTION IN LIMINE #3 TO SEVENTY-TWO HOUR PREDISCLOSURE OF DOCUMENTS AND WITNESSES PRIOR TO PRESENTATION AT TRIAL on the interested parties in this action as stated below: Brayton Purcell 222 Rush Landing Road P.O. Box 2109 Novato CA 94948 X| (BY ELECTRONIC FILING/SERVICE) I provided the document(s) listed above electronically to the LexisNexis File & Serve Website to the parties on the Service List maintained on the LexisNexis File & Serve Website for this case. If the document is provided to LexisNexis electronically by 5:00 p.m., then the document will be deemed served on the date that it was provided to LexisNexis. A copy of the "LexisNexis File & Serve Filing Receipt" page will be maintained with the original document(s) in our office. Executed on March 22010, at San Francisco, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Chery! Lieu (Type or print name) (Signature) -3- DEFENDANT HAMILTON MATERIALS, INC.'S MOTION IN LIMINE #3 TO SEVENTY-TWO HOUR PREDISCLOSURE OF DOCUMENTS AND WITNESSES PRIOR TO PRESENTATION AT TRIAL 8974481 1155-5.2557 .