Exhibit,Appendix: JOYCE JUELCH, ET AL VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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                                Tet. No. (810) B96CGEE
Fax No. (5 1O) 586-0899

Ehenvwine, CaLironn 24606

BisHoP | BARRY | DRATH~
2000 Powat. Strser Suma 425

co SF NN MH

bet
oo

NELSON C. BARRY, [SBN 23933]

MARY MARGARET RYAN, [SBN 127828]
JOHN A. BURKE, [SBN 148385]

BISHOP | BARRY | DRATH

2000 Powell Street, Suite 1425

Emeryville, California 94608

Telephone: (510) 596-0888

Facsimile: (510) 596-0899

Attorneys for Defendant
REDWOOD PLUMBING CO., INC.

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

MAR 04 2010

Clerk of the Court
BY: VANESSA WU
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO (UNLIMITED JURISDICTION)

JOYCE JUELCH and
NORMAN JUELCH, SR., ~

Plaintiffs,
YS,
ASBESTOS DEFENDANTS (B*P) As
Reflected on Exhibits B, B-1, C; and DOES
1-8500, et al.,

Defendants.

Case No. CGC-09-275212

REDWOOD’S PLUMBING CO., INC.’S
APPENDIX OF EXHIBITS IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT OR,
ALTERNATIVELY, SUMMARY
ADJUDICATION

Date: March 18, 2010
Time: 9:30 a.m.

Dept.: 220

Honorable: Harold E, Kahn

Trial date: April 5, 2010
Complaint Filed: May 20, 2009

Defendant, Redwood Plumbing, Co., Inc. hereby submits the following appendix of exhibits in

support of its Motion for Summary Judgment or, alternatively, Summary Adjudication:

EXHIBIT A

Plaintiff Joyce Juelch’s Responses to Standard

Asbestos Case Interrogatories, Set One

EXHIBIT B

EXHIBIT C

Deposition of Joyce Juelch, September 15, 2009

Information published on the California State

License Board's website regarding REDWOOD
PLUMBING CO, INC.’S contractor's license1 EXHIBIT D Plaintiff Joyce Juelch’s Responses to Standard
3 Asbestos Case Interrogatories, Set Two
3 EXHIBIT E Redwood Plumbing, Coa. Inc.'s First Set af Special
Jnterrogatories to Plaintiff Joyce Juelch
4
EXHIBIT F Plaintiff Joyce Juelch’s responses to Redwood
5 : Plumbing, Co. Inc.'s First Set of Special
6 Interrogatories
7 EXHIBIT G Deposition of plaintiff Joyce Juelch, November 19,
2009
8
EXHIBIT H Deposition of plaintiff Norman Juelch, taken on May
9 23, 2008, in his own pending asbestos suit in this
10 Court (CGC-06-457464)
ll EXHIBIT I Deposition of plaintiff Norman Juelch, taken on May
22, 2008, in his own pending asbestos suit in this
12 Court (CGC-06-457464)
A
a .
z 2 2 22 13 EXHIBIT J Deposition of Joyce Juelch, November 16, 2009
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PO BOX 6169
15) 898-1598

NOVATO, CALIFORNIA 94948-6169.

ATTORNEYS ATLAW
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222 RUSH LANDING ROAD.

BRAYTON@PURCELL LLY

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ALAN R, BRAYTON, ESQ., S.B. #73685
ERIC C, SOLOMON, ESQ., $.B. #119131
BRAYTON®PURCELL LLP

Attorneys at Law .

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555

Attorneys for Plaintiffs

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN FRANCISCO
JOYCE JUELCH and ) ASBESTOS
NORMAN JUELCH, 3 No, 275212
Plaintiffs, ) ANSWERS TO INTERROGATORIES
VS,
ASBESTOS DEFENDANTS (BP).

PROPOUNDING PARTY: . STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff JOYCE JUELCH
SET NO: ONE

NSWERS
JOYCE JUANELL JUELCH.

Sepiember 18, 1946.
62 years old.

oP

a. 9

French Camp, California,

19581 Feather Falls Place, Cottonwood, California 96022.
Height: 5'7 1/2"; Weight: 169 Ibs.

369-68-7847,

Bom fe

None.

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None.

None.

RO494625; California.

Joyce Johnson; Joyce Chambers.
Plaintiff completed the 12th grade,
Norman E, Juelch, Sr,

June 13, 1945.

February 14, 1981,

_ 19581 Feather Falls Place, Cottonwood, California 96022.

Retired,
Bruce Johnson; John Chambers.
1963; 1967,

Plaintiff's marriage to Bruce Johnson was dissolved in 1967 due to

infidelity. Plaintiff's marriage to John Chambers was dissolved in 1978 due to infidelity.

72. a.

b.
o
a.

moe

eB PF BP

e

>

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Terresa Reyes,

November 14, 1963.

Natural.

5035 Zuning Avenue, Corning, California 96021.
Housewife. :

Living.

Nina L. Reberson.

December 7, 1964.

Natural.

4809 Montaro Court, #D, Bakersfield, California 93307.
Retired.

Living,Oo oO NA DH BW Nome

10

~ ew NH

a, Jessica Hayes.

b August 17, 2000.

& Granddaughter. Plaintiff has legal custody of this child.

a 19581 Feather Falls Place, Cottonwood, California 96022.

e Child is a minor.
f£ Living.

_ No.
None.

Plaintiff is currently able to recall the following addresses:

12/1981 to 1983: Evergreen, Stockton, California 95205,

1983 to 1984: Post Office Box 515, Sutter Creek, California.

1985 to 1988: McAtce Road, Valley Springs, California.

1988 to 1990: 23522 Shake Ridge Road, unknown city, California.

1990: 5758 Cora Post Road, Lodi, California.

1990; 1955 Emmon Canyon Road, Kila, Montana.

1991 to 1994: 2237 Highway 28, Hot Springs, Montana.

1994 to 2004: Newlin Road, Marion, Montana 59925.

2004: Silver Butte Road, Libby, Montana 59925.

2005: 349 Trainer Street, Libby, Montana.

2006: 2090 Loleta-Avenue, Corning, California,

2006 to present: 19581 Feather Falls Place, Cottonwood, California 96022.
Plaintiff completed the 12th grade. .
May 27, 2009.

No.

No.

Excluding plaintiff's expert consultants, plaintiff recalls the following physicians:

4a. Dr, Gills,
b. Redding, California.

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pe teckel
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are continuing.
4d,
e.
£

Plaintiff currently does not recall. Plaintiff's investigation and discovery

January 2009.
Heart attack.
Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a
b.
“.
are continuing,
a

f.

Dr. Luperpio.
Redding, California.”
Plaintiff currently does not recall. Plaintiff's investigation and discovery

January 2009.
Heart attack,
Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a 9

are continuing.
f

- Dr. Hahns.
MD Imaging, Redding, California,
Arterial dopler performed on lower extremities.
February 5, 2009.

Plaintiff currently does not recall. Plaintiff's investigation and discovery

. Plaintiffhas provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a,

Plaintiff currently does not recall.

b. + Open System Imaging, Redding, California.

a

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Dopler performed.TD

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~~

23

22 | are continuing.

d. February 19, 2009.
7 & Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing. .
f Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a. Dr. Balazer.

b. Cottonwood Clinic, Cottonwood, California.

¢. ’ Arterial dopler performed on lower extremities.

d. March 3, 2009. 7

e Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing. .

£ Plaintiff has provided authorizations for the release of medical records to

Berry & Berry, Defendants may obtain copies of records through Berry & Berry.

a, Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing,
ob MD Imaging, Redding, California. .
CT of abdoman and pelvis,
d. March 11, 2009.
e Plaintiff currently does not recall, Plaintiff's investigation and discovery

f° Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry. ,

a Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing.

b. MD Imaging, Redding, California.

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10

CT of chest without contrast,
d, March 12, 2009.
e Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing.
£ Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

a Dr. Dhanuha.

_b Redding, California.
c. Office visit.
d. March 17, 2009.

&, Plaintiff was given the results of her tests. Plaintiff was advised that she
“had cancer.
f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry, Defendants may obtain copies of records through Berry & Berry.

a Dr. Luperpio.
_b. Redding, Califomia,
. Pulmonology.
d. March 18, 2009.
& Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing. - :
f. Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry,
a Dr. Karem. *
db. Redding, California,

ce, Plaintiff currently does not recall, Plaintiff's investigation and discovery

Kitnjyredt 2688 ai secst I.wpd . 6are continuing. -

£ Plaintiff has provided authorizations for the release of medical records to

Berry & Berry. Defendants may obtain copies of records through Berry & Berry,

“a.- Dr, Dhanuha.
b. Redding, California.
. Plaintiff receives chémotherapy.
d. Presently.
e Cancer.

f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
11. Exeluding those used by plaintiff's expert consultants, plaintiff currently recalls
the following hospitals: :
a Mercy Hospital.
b. Redding, California.
c Plaintiff was hospitalized due to heart problems. An angiogram was done,

and 2 stints were put in.
a. December 31, 2008.
a Stroke.

f Plaintiff has provided authorizations for the release of medical records to
‘Berry & Berry. Defendants may obtain copies of records through Berry & Berry.

- 12, Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
following x-rays and CT scans: Please see response to Interrogatory Numbers 10 and 11, above.
This information is as complete as plaintiff can recall at this time and includes all treatment by
plaintiff's healthcare providers. Plaintiff's investigation and discovery are continuing.

13, Excluding any taken by plaintiffs expert consultants, plaintiff recalls the
following pulmonary function tests: Please see response to Interrogatory Numbers 10 and 11,

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above. This information is as complete as plaintiff can recall at this time and includes all
treatment by plaintiff's healthcare providers. Plaintiff's. investigation and discovery are
continuing. .

14. Please see response to Interrogatory No.'s 10 and 11, above. Plaintiff defers to his
medical records as the best source of information for medications prescribed, /

15. Not at this time. Plaintiff's medical records are equally available to defendants
through Berry & Berry, designated defense counsel.

16, Plaintiff has the following complaints from asbestos exposure: breathing
difficulties, fatigue, loss of stamina.

a Plaintiff currently does not recall. Plaintiff's investigation and discovery

“are continuing.

b. No cessation,

a None ‘that plaintiff is aware of.

d. ‘Plaintiff contends that his lungs have primarily been affected. However,
as lung function affects the rest of the body, plaintiff contends that all parts of her body have
been affected. :

& Please refer to Interrogatory No. 10 and 11, above.

£ Please refer to Interrogatory No, 10 and 11, above,

& Plaintiff does not at this time contend that she has lost time from work as
result of her asbestos-related conditions, Plaintiff's investigation and discovery are continuing.

h Not applicabie.

i Plaintiff does not at this time have any documents responsive to this
Interrogatory. Plaintiff's investigation and discovery are continuing.

17. Excluding information protected by either the attorney work-product doctrine or
the attorney-client privilege, no.

18 No. .
19. Plaintiff suffers from shortness of breath.
20. No.

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21. Plaintiff's investigation and discovery are continuing,
22, No.
23. Yes.
a. Plaintiff recalls smoking from approximately 1965 to present.
dB Plaintiff recalls smoking cigarettes.
© Plaintiff recalls smoking 10 to 20 cigarettes per day.
d. - Plaintiff recalls smoking 1/2 to 1 pack of cigarettes per day.
€. Plaintiff recalls smoking Marlboro brand Cigarettes,
£ Yes. :
1. Dr, Dixon,
2. Approximately 1995,
24, Yes.
, a Plaintiff's husband, Norman Jueleh,
db. 1981 to present,
ke Camel and Marlboro brand cigarettes,
a Approximately 1 pack per day.
25, No
26. Plaintiff is currently able to identify the following employment information:
Employer Eeposure® ‘ Job Title Baposure
Foster Freeze Foster Freeze Cook 1963
Stockton, CA / ~ Stockton, CA

Job Duties: Plaintiff worked at a hamburger restaurant. Plaintiff is currently unaware if she was
exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Dameron Hospital Dameron Hospital _ Nurse 1964-1974
Stockton, CA Stockton, CA

Job Duties: Plaintiff performed general nursing duties throughout the intensive care unit, the
emergency units and medical surgery departments. Plaintiff recalls during the early 1970s the
hospital underwent a remodel. Plaintiff recalls walking through a construction site everyday.

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. quickly, Plainti:

Plaintiff walked directly adjacent to d ers hanging KAISER GYPSUM COMPANY, INC.
drywall and applying and sanding KAISER GYPSUM COMPANY, INC. asbestos-containing —
joint compo , Plaintiff recalls allers hung up plastic sheets to contain debris, but plainti
recalls dust frequently came thr the sheets, Plaintiff recalls walking adjacent to sheetmetal
workers installing duct work in the ceiling, disturbing asbestos-containing acoustical niaterials
that had been recently applied by drywallers. Plaintiff currently contends she was exposed to

asbestos during this employment. .

- Location of , Exposure
Employer Exposure Job Title Dates
Naval Supply Depot Naval Supply Depot Janitor 1966
Stockton, CA Stockton. CA

Job Duties: Plaintiff cleaned offices and bathrooms throughout the facility. Plaintiff recalls the

offices had asbestos-containing ceiling tiles that were falling apart, and frequently fell onto the
floor. Plaintiff recalls sweeping and cleaning up asbestos acoustical ceiling tiles after they were
on the floor, Plaintiff currently contends she was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure : Job Title Dates
San Joaquin General Hospital San Joaquin General Nurse 1975-1976
French Camp, CA. Hospital

French Camp, CA

4" Floor

Job Duties: Plaintiff worked as a nurse throughout the emergency room. and intensive care units
on the ground fourth floor of this hospital, Plaintiff recalls that the hospital underwent a remodel.
Plaintiff recalls contractors removed and replaced asbestos-containing ceiling tiles. Plaintiff was
in proximity to workers disturbing fireproofing during the construction, Plaintiff recalls there
was debris throughout the site from the removal of the ceiling tile which was not cleaned up very
currently contends she was exposed to asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Unknown Family Doctor Unknown Doctor’s office Nurse 1976-1980
Stockton, CA Stockton, CA .
Job Duties: Plaintiff worked for a family doctor assisting him with patients. Plaintiff is currentl:
unaware if she was exposed to asbestos.during this employment.
Location of Exposure’
Employer . Exposure Job Title © Dates
Plant Insulation Company Tosco Oil, Insulator 1982-1984
Ayon, CA (Apprentice) (2 months)

Job Duties: Plaintiff assisted insulators insulating tanks and removing existing asbestos-
containing pipe insulation when performing repairs. Plaintiff used, and was in proximity to other

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workers using, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. G.B,
FULLER COMPANY) fibrous adhesive, Plaintiff was issued and used a 3M COMPANY _
single- mask, Plaintiff cut and provided pipe insulation to insulators as well as insulation
cements. Plaintiff swept and cleaned up asbestos-containing insulation that was removed by _
insulators in her crew, Plaintiff worked adjacent to TOSCO OIL, laborers sweeping and cleaning
up debris discarded by TOSCO GIL Personnel durin repairs, which was scattered throughout th
facility. Plaintiff worked adjacent to BECHTEL (SEOU A VENTURES INC) pipefitters and
Helders perforin airs to piping and valves. Plaintiff worked in close proximity to
BEC L ( SEQUOIA V: NTORES INC) pipefitters who opened valves and removed interior
packing and gasket material. Plaintiff was able to identify BECHTEL (SEQUOIA VENTURES

ic fitters due to their uniforms. Plaintiff worked in proximity to THE INDUSTRIAL

ANCE ENGINEERING CONTRACTORS contractors who knocked asbestos

insulation from piping and swept up asbestos-containing materials from the floor. Plaintiff
recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP; Hank Freeman, c/o
Brayton**Purcell LLP; John Murphy, c/o Brayton*Purcell LLP; Ken Goforth, c/o
Brayton*Purcell LLP; Larry Sublet, c/o Brayton*Purcell LLP; and Don Bass, c/o
Brayton%Purcell LLP; Steve Steele, Concord, California. Plaintiff currently contends she was
exposed to asbestos during this employment.

Location of Exposure

Employer Exposure . Job Title Dates
Plant Insulation Company Dow Chemical Insulator 1982-1983
Pittsburg, CA (Apprentice) (3 weeks)

Job Duties: Plaintiff assisted insulators insulating tanks, chemical lines and valves, Plaintiff was
adjacent to the disturbance of existing asbestos-containing pipe insulation by pipefitters,
insulators and other tradesmen working in the vicinity, Plaintiff used, and was in h proximity to
other workers using, BENJAMIN FO DIVISION OF AMCHEM PRODUCTS, INC. (H.B.
FULLER COMPANY) fibrous adhesive, Plaintiff was issued and used a 3M COMPANY
sinple-stap mask. Plaintiff recalls dust from the discarded asbestos-containing pipe insulation
that had fallen, or been receritly removed and discarded on the ground where all trades were
walking, and was consequently kicked and disturbed adjacent to plaintiff, Plaintiff was in
proximity to SAFEWAY STEEL PRODUCTS (SCOTT TECHNOLOGIES, INC.) scaffolding
cing dismantled by SAFEWAY employees where they would flip the boards on the scaffolding
and allow all of the asbestos-containing debris to fall to the ground, creating a lot of dust.
Plaintiff worked in proximity to BAY WESTERN INDUS L MAINTENANCE, INC.
{BRAGG INVESTMENT COMPANY, INC.) contractors pulling out asbestos packing while
working on valves. Plaintiff recalls BECH (SEQUOIA VENTURES INC) pipefitters
formed tie-in work to existin; Bipelines, disturbing asbestos-containing pipe insulation.
iaintiff recalis BECHTEL (SEG TAL VENTURES INC) pipefitters cut and installed asbestos-
containing skets and opened valves, removing and replacing interior gasket and packing
material. Plaintiff recalls working adjacent to BEC (SEQUOIA NTURES INC)
employees sweeping and cleaning asbestos-containing debris. Plaintiff recalls the following
coworkers: Norman Juelch, c/o Brayton%+Purcell LLP, Plaintiff currently contends she was

| exposed to asbestos during her employment.

Location of Exposure
Emplover Exposure Job Title Dates
Plant Insulation Company Shei Oi Insulator «1983-1984

1300 - 64" St. Martinez, CA . (Apprentice) 1 month
Emeryville, CA 94662 , pre e )

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BR RR SR ES SERRE ESB US ow wa emo wm
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Job Duties: Plaintiff assisted insulators applying insulation to piping, and insulating large pipe
racks, Plaintiff assisted insulators removing asbestos-containing pipe insulation on existing
piping. Plaintiff was issued and used a 3M COMPANY single-strap mask. Plaintiff was

jacent to pipefitters employed by DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A.,

iC.) who were removing and installing new asbestos-containing valves, disturbing interior
asbestos containing gasket and packing material and cutting and installing GARLOCK
(GARLOCK SEALING TECHNOLOGIES, LLC) flange gaskets. Plaintiff recails the following
coworkers: Hank Freeman; c/o Brayton%+Purcell LLP; Norman Juelch, c/o Brayton*Purcell
LLP, Plaintiff currently contends she was exposed to asbestos during this employment.

: Locationof —- Exposure
Employer Exposure Job Title Dates .
Northern California. Pacific Bell Insulator 1983-1984
Insulation aka Metalclad Stockton, CA @ weeks,

insulation Corporation

Job Duties: Plaintiff applied fiberglass insulation, mastic to piping and valves at a Pacific Bell
Telephone building located a few blocks north of downtown Stockton. Plaintiff insulated the
valves. Plaintiff recalls coworker: Norman Juelch, c/o Brayton Purcell, LLP. Plaintiff is
currently unaware if she was exposed to asbestos during this employment. ‘

Location of Exposure
Employer Exposure Job Title Dates
Norther California Shell Oi Insulator 1983-1984
Insulation aka Metalelad Martinez, CA ‘ (2 months)
Insulation Corporation

Job Duties: Plaintiff applied calcium silicate Pipecovering, fiberglass  Fipscoverin , insulation
cement, black mastic and insulation pads to piping and valves. Plaintiff was issued and used a
3M COMPANY single-strap mask. Plaintiff removed asbestos-containing pipe insulation on
existing piping. Plaintiff was adjacent to pipefitters removing and replacing asbestos-containing
valves, ing interior gasket and pac! ing material, and cutting and installing GARLOCK
(GARLOCK SEALING HNOLOGIES, LLC) flange gaskets. Plaintiff recalls the following
co-worker: Norman Juelch, c/o Brayton @Purcell, LLP. Plaintiff currently contends she was
exposed to asbestos during this employment. :

Location of Exposure
Employer Exposure lob Title Dates
Northern California Sutter Memorial Hospital Insulator 1984
Insulation aka Metalclad Sacramento, CA (Apprentice) (1 -2 weeks)

Insulation Corporation

Job Duties: Plaintiff worked in steam tunnels re-insulating pipes. Plaintiff disturbed and
removed existing asbesios-containing pipe covering on piping. Plaintiff worked adjacent to
pipefitters removing and installing new piping, and disturbing existing pipe insulation. Plaintiff
currently contends she was exposed to asbestos during this employment. :

Location of Exposure

Employer Exposure : Job Title Dates -

KAtajured\08688.a-sac wpe 12Om OO mR wR

Northem California

Campbell Soup Insulator 1984
Insulation aka Metalclad Sacramento, CA (1 month)
Insulation Corporation

Job Duties: Plaintiff removed existing asbestos-containing pipe insulation from pipelines,
Plaintiff was adjacent to pipefitters removing piping and disturbing ashestos-coniaining pipe
insulation, Plaintiff worked adjacent to pipetitters removing valves, disturbing interior gasket and|
packing material as well as cleaning and repairing gaskets, Plaintiff insulated tanks and repaired
patches on existing asbestos-containing pipe insulation. Plaintiff recalls the following co-
workers: Norman Juelch, c/o Brayton* Purcell, LLP; Mel Swanson, c/o Brayton%Purcell LLP;
Maurice Lawrence, c/o Brayton#Purcell LLP, Plaintiff worked adjacent to CAMBELL SOUP
employees, sweeping up asbestos-containing debris, and repairing machinery. Plaintiff currently
contends she was exposed to asbestos during this employment.

Location of . Exposure
Employer Exposure Job Title Dates
Unknown Slaughterhouse Insulator 1984 (3 weeks)

Sacramento, CA

Job Duties: Plaintiff insulated a tank, Plaintiff recalls disturbing discarded asbestos-containing
cement pipe and pipe insulation debris that was lying on the ground from a recent removal.
Plaintiff currently contends she was exposed to asbestos during this employment,

Location of . Exposure
Employer osure Job Title Dates
Northern California Cheese Factory Insulator 1984
Insulation aka Metalclad South Sacramento, CA (3-4 weeks)
Insulation Corporation :

Job Duties: Plaintiff performed duct work, Plaintiff applied calcium silicate pipecoveri
fiberglass pipecovering, insulation cement, black mastic and insulation pads to piping and valves]
Plaintiff assisted insulators using fiberglass to cover pipes. Plaintiff recalls being adjacent to
plumbers and pipefitters removin distrubing a large piece of existing asbestos-containing
sheetrock. Plaintiff recalls the following co-worker: Norman Juelch, Brayton #Purcell, LLP;
Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos during her
employment.

Location of Exposure
Employer Exposure . Job Title Dates
NPS Energy Services Rancho Seco Nuclear Insulator 1984-1992

Powerhouse

Herald, CA

Job Duties: Plaintiff installed pipecovering, insulation cement, black mastic and insulation pads
on piping and valves. Plaintiff removed and replaced insulation on generators and inside
pipelines. Plaintiff worked throughout the facility, in the reactor room. Plaintiff was issued and
used a 3M COMPANY single-strap mask. Plaintiff patched holes on asbestos-containing
insulation on Pipi Plaintiff removed existing asbestos-containing insulation on piping and
equipment. Plaintiff recalis that BECHTEL (SEQUOIA VENT! S INC.) employees did the

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ec
night for the BECHTEL (SEQUOIA laborers to clean up the next day.
Plaintiff worked adjacent to BECHTEL (SEQUOIA TURES ING) pipetitiers, one of the
main contractors on the job, Plaintiff recalls BECHTEL (SEQUOIA NTURES INC)
employees removing an lacing ashestos-containing gaskets and packing in valves, Plaintiff
recalls that these were BI L smployees because she saw them in their trademark white
hats. Plaintiff recalls RANCHO SECO employees swept and cleaned asbestos-containing debris
including recently removed asbestes-containing Pipecovering. Plaintiff recalls the following
supervisors: Rick Bariel, address unknown; Ron Vandemeer, address unknown. Plaintiff recalls
the following co-workers: Wiley Utterback, c/o Brayton¢*Purcell LLP; Phil Black, address
unknown; Robert Calvillo, e/a Brayion Purcell LLP; Thomas Begley c/o Brayton Purcell,

tear-outs of pipes and other - es of equipment at ight and they would leave the debris over
, .

LLP, Plaintiff currently contends she was exposed to asbestos during. this employment.

Location of Exposure
Employer Exposure * Job Title . Dates
Northern California Lassen College Insulator 1985
Insulation aka Metalelad Waste Incinerator (6 months)
Insulation Corporation Susanville, CA, .

Job Duties: Plaintiff worked on new construction. Plaintiff applied thermal insulation to piping.
Plaintiff recalls Lassen College was constructing anew garbage burning power plant used to
create electricity. During the construction, the plant had Various tests known as the “blowdown”
and “fire up” process. Plaintiff recalls that new CRANE CO. valves were installed prior to each
test, and removed. New CRANE CO. valves were always installed before each test. Plaintiff
recalls working adjacent to ) ipefitters removing and replacing GARLOCK (GARLOCK.
SEALING TECHNOLOGIES, LLC) gaskets and packing on new CRANE CO. valves Guring
‘these tests, Plaintiff recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP.;

|. Gene Cosby, deceased; Dean White, deceased; Steve Bass, c/o Brayton Purcell, LLP. Plaintiff

currently contends she was exposed to asbestos as result of her employment.
Location of . Exposure
Employer Exposure Job Title Dates
Northern California WalMart Insulator 1985; 1986
Insulation aka Metalclad Hammer Lane
Insulation Corporation Stockton, CA.
Job Duties: Plaintiff worked on new construction. Plaintiff installed pipecovering on pipelines.
Plaintiff is currently unaware if she was exposed to asbestos during this employment.
Location of Exposure
Emplover Exposure Job Title Dates
Northem California WalMart Insulator 1985; 1986
Insulation aka Metalclad Fresno, CA
Insulation Corporation :

Job Duties: Plaintiff worked on new construction. Plaintiff installed pipecovering on pipelines.
Plaintiff is currently unaware if she was exposed to asbestos during this employment. .

Location of Exposure
Employer Exposure JobTitle’ . Dates

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Northern California . Corn Products Insulator 1985
Insulation aka Metalelad Stockton, CA (2-3 months)
Insulation Corporation .

Job Duties: Plaintiff insulated fanks. Plaintiff removed existing asbestos-containing sntiff
ipecovering, Plaintiff replaced pipecovering wi cium silicate pipecovering. Plaint
Emoved replaced inaulation on pipelines going to and from an ALLIS-CHALMERS
generator. Plaintiff worked adjacent to other insulators tearing out pre-existing asbestos-
containing insulation manufactured by OWENS CORNING FIBERGLAS Kaylo that had been
installed by Northern California Insulation aka Metalclad Insulation Corporation insulators on a
prior job. Plaintiff worked adjacent to pipefitters removing and replacing valves on the piping
joing to the generator, Plaintiff recalls ALLIS-CHALMERS (ALLIS-CHALMERS
ORATION PRODUCT LIABILITY TRUST enerator technicians repairing the
generator. Plaintiff worked adjacent to a large JO! -MANVILLE transite pipe that had been
recently removed by CORN PRODUCTS, employees and discarded in the middle of the jobsite
between the tanks were insulating. Plaintiff recalls that the JOHNS-MANVILLE asbestos-
containing pipe was regularly disturbed by all contractors on the site because it was in the middle
of the construction area. Plaintiff worked adjacent to CORN PRODUCTS employees sweeping
and cleaning asbestos-containing debris. Plaintiff recalls the following co-workers: Norman
Juelch, c/o Brayton & Purcell, ; Bob Wadley, deceased; Gene Cosby, deceased; Steve Bass,
c/o Brayton*Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of
this employment.

Location of Exposure
Employer Exposure Job Title Dates
Northern California Modules Alaska Insulator 1985
Insulation aka Metalclad Stockton, CA (Apprentice) (4-3 months)

Insulation Corporation .

Job Duties: Plaintiff provided pipecovering, fiberglass, foam glass, and mastics to insulators.
Plaintiff was adjacent to pipefitters cutting end ‘iat GARLOCK gaskets, and installin
asbesios-containing cking in valves. Plaintiff recalls the following coworkers: Norman Juelch,
Brayton Purcell, LLP; “Scotty,” Steve Bass; Brayton Purcell, LLP; Gene Crosby, deceased;
Bob Wadley, deceased. Plaintiff currently contends she was exposed to asbestos during this
employment, .

PARA- OCCUPATIONAL EXPOSURE:

Plaintiff resided with her first husband John Chambers. Plaintiff's ex-husband regularly returned
home with asbestos-containing debris on his clothing. Plaintiff recalls shaking out and washing
his work clothes in the garage.

Plaintiff's husband’s work history is as follows:

Location of : Exposure
Employer Exposure Job Title Dates
Dinuba Distributing Dinuba Distributin; Mechanic 1971-1977 :
Stockton, CA Stockton, CA 8

Job Duties: Plaintiffs ex-husband performed brake and engine repairs on fleet trucks, Plaintiff
currently contends she was exposed to asbestos as a result of her ex-husband’s employment.

K AnjuresR OR68Biai-se05F I wpd 15Plaintiff has resided with her husband Norman Juelch Sr., local 16 insulator since 1981, Plaintiff
Was exposed to asbestos-containing materials by washing her husband’s laundry after work.
Plaintiff recalls her husband frequently returned home with asbestos-containing debris and dust
on his clothes from the jobsite. Plaintiff shook out her husband’s dusty clothes before washing
them in the . Plaintiff recalls vacuuming her husband’s car which he drove to and from
work on a daily basis. * :

Plaintiff's husband’s work history is as follows:

Location of . Exposure
Employer . "Exposure Job Title Dates
Plant Insulation Company Various commercial and —_ Insulator 1981-1983,
. industrial buildings 1985
including:

Job Duties: Plaintiff's husband applied Pipecovering, insulation cements, fiberglass .
pipecovering, and Zeston plastic fittings to piping, Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation strewn on the ground in his work area.

Plaintiff's husband recalls working with the following co-workers throughout his employment
with Plant Insulation: Steve Steele, Concord, California; and Carl Ramsey, c/o Brayton Purcell
TLP. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment, .

. Location of Exposure
Employer | Exposure Job Title Dates
Owens Corning World Various locations Insulator 1981-1985
Headquarters including: : (6-7 months)
1 Owens Corning Pkwy Sierra Pacific Power Co.
Toledo, OH 43659 Vaieay Power Station
EY,

Job Duties: Plaintiff's husband applied thermal insulation during construction of Unit | of the
Valmy Powerhouse, While working at the Valmy Powerhouse, plaintiffs husband insulated
pipes with board glass and pipecovering, Plaintiff's husband recalls working near laborers
sweeping up the site and near ironworkers, carpenters and pipefitters who were installing valves,
gaskets and pipes. Plaintiff's husband worked alongside technicians who were disassembling,
and repairing a GENERAL ELECTRIC (GENERAL ELECTRIC COMPANY) generator,
Plaintiff's husband worked near others who were installing, new CRANE CO. valves and
checking packing. Plaintiff's husband observed these pipefitters installing and removing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets on the CRANE CO.
valve Ranges. Plaintiff's husband recalls the following supervisor: Carl Ramsey c/o

Brayton’ Purcell LLP. Plaintiff's husband recalls the following co-worker: Gene Cosby
deceased, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment.

Location of Exposure
Employer Exposure Job Title Dates
Pioneer Insulation Contractor Unknown Insulator 1981
Inc - (1 week)

2085 Boxwood Way
Fremont, CA 9453!

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Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plamntiff’s husband disturbed previously
removed as! esios-containing pipe insulation that was strewn on the ground in his work area.

Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment, .
Location of Exposure
Employer Exposure Job Title
Plant Insulation Company PG&E, Unit i Insulator 1982
Pittsburg, CA (3 weeks)

Job Duties: Plaintiff's husband applied | pipecovering, insulation cements, and black mastic to
boiler piping. Plaintiff's husband worked near boilermakers who were rebuilding a boiler.
s

Plai husband recalls working adjacent to pipefitters who were tearing out pipes and
installing new Pipes and valves, Plaintiff's husband observed ‘tradesmen removing brick and
refractory from the Unit 1 boiler. PG&E (PACIFIC GAS & ELECTRIC COMPAN mnel

gs and cleaned asbestos-laden debris in his presence. PG&E (PACIFIC GAS & ELECTRIC
COMPANY) personnel inspected and approved plaintifi’s husband insulation work. Plaintiff's
husband insulated the fittings with insulating cement, Plaintiff currently contends she was
exposed to asbestos as a result of her husband’s employment.

. Locationof — : Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Tosco Oil, Insulator 1982-1984

- Avon, CA (2 months)

Job Duties: Plaintiff’s husband appliod calcium silicate pipecovering to steam and process
piping and valves throughout the refinery. Plaintiff's husband applied insulation cements,
CHEVRON (CHEVRON U.S.A. INC.) covercote (G-I HOLDINGS, INC.) black mastic, Zeston
fittings and adhesives. Plaintiff's husband was provided with insulation from old boxes obtained
from stocks on the TOSCO (TOSCO IG COMPANY, INC.) premises, Plaintiff's
husband tied into existing asbestos insulation. Plaintiff's husband observed TOSCO (TOSCO
REFINING COMPANY, INC.) personnel sweeping, blowing, and cleaning asbestos-laden
pipecovering gasket scraps and other debris in his work areas. Plaintiff’s husband recalls co-
workers: Hank Freeman, c/o Brayton%Purcell LLP; John Murphy, c/o Brayton**Purcell LLP;
Ken Goforth, c/o Brayton“*Purcell LLP; Larry Sublet, c/o Brayton**Purcell LLP; and Don
Bass, c/o Brayton’ Purcell LLP. Plaintiff's husband worked alongside pipefitters employed by
BECHTEL (SEQUOIA VENTURES INC) who were removing and inst ing valves and gasket
in his work areas. Plaintiff's husband recalls the following supervisor: Steve Steele, Concord,
California. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment.

20 Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Union Oil Insulator 1982-1983
Oleum/Rodeo, CA. . :

Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass

pipecovering, and Zeston plastic fittings to piping. laintiff’s husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area,

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Plaintiff's husband insulated oil tanks and pipes, Plaintiff currently contends she was exposed to
asbestos as a result of her husband’s employment.

Location of . Exposure
Employer Exposure Job Title Dates
Plant Insulation Company El Dupont de Nemours & — Insulator 1982-1985
, Antioch, CA

Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass _
pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation ‘was strewn on the ground in his work area,
Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment,

. Location of . Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Dow Chemical Insulator 1982-1985

Pittsburg, CA

Job Duties: Plaintiff's husband applied Pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping, Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area.
Plaintitt currently contends she was exposed to asbestos as a result of her husband’s
employment.

Location of Exposure
Employer Exposure Job Title * Dates
Plant Insulation Company Shell Oil Insulator 1983-1984
1300 - 64” Si, Martinez, CA © . (1 month)

Emeryville, CA 94662

Job Duties: Plaintiff's husband applied pipecovering insulation to piping. Plaintiff's husband
worked alongside various trades, including welders, laborers, crane operators, and stage ri; gers.
Plaintiff's husband worked alongside DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A.
INC.) pipefitters who were installing 8 to 10 new CRANE CO, valves along with GARLOCK
G. CK SEALING TECHNOLOGIES, LLC) flange gaskets, which were wired onto those
valves when delivered. Plaintiff currently contends she was exposed to asbestos as a result of her
husband’s employment.

Location of Exposure

Employer Exposure Job Title ~ Dates
Fruin-Colnon Crop. Procter & Gamble, Insulator * 1982
1259 Clayton Road W. Sacramento, CA. (1. month)
Ballwin, MO . . .

Job Duties: Plaintiff's husband recalls performing maintenance and repairs. Plaintiff's husband
tecalls working with and around old insulation. Plaintiff's husband recails the site was very

KAnjuredi} 9868 ai-soost LLwpd 18. -dusty.. Plaintiff recalls the following co-worker: Robert Calvillo, c/o Bray one Purcell LLP.
Plaintiff currently contends she was exposed to asbestos as a result of her husband’s

employment.

Location of . . Exposure
Employer: Exposure . Job Title Dates

Fruin-Colnon Crop, Louisiana Pacific Insulator 1983
1299 Clayton Road W. pulp mill (6 weeks)
Ballwin, . amoa, CA.

Job Duties: Plaintiffs husband applied pipecovering, insulation cements, and black mastic
while completing remodel work started by a non-union crew, Plaintiff’ 3 husband observed _
previously removed asbestos-containing pipe insulation that had been piled up in boxes in his
work areas. Plaintiff's husband worked alongside various trades, including mullwrights,
machinists, laborers, and maintenance people employed by LOUISIANA PACIFIC
QUISIANA PACIFIC CORPORATION) who were handling and/or cleaning up asbestos-
laden dust and debris. Plaintiff's husband also worked near  pipefitters who were employed by
an outside mechanical contractor, Piaintiff currently contends she was exposed to asbestos as a

result of her husband’s employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Roman Meal Bread Factory Insulator 1983

South San Francisco, CA (approx. 1 week)

Job Duties; Plaintiff’'s husband worked near employees taking insulation off of the ovens and
recalls the insulation falling and hitting the floor and kicking up dust clouds, Plaintiff’s husband
recails that the debris was picked up and disposed of in a dumpster outside, Plaintiff's husband
recails that it was very dusty despite use of wet-down techniques. Plaintiff currently contends
she was exposed to ashestos as a result of her husband’s employment,

. Location of Exposure
Emplover Exposure Job Title Dates
Metalclad Insulation Campbell Soup Insulator 1983-1985
ion . Sacramento, CA
2198 S Dupont Dr :
P.O. Box 61024
Anaheim, CA 92803

Job Duties: Plaintiff's husband worked at Campbell Soup multiple times. Plaintiff's husband
recalls insulating tanks. Plaintiff's husband performed patches to pipes that had existin;
insulation, Plaintiff's husband recalls working néar welders who were using welding ‘blankets,
Plaintiff's husband recalls the followi co-workers: Mel Swanson, c/o Brayton*Purcell LLP;
Maurice Lawrence, c/o Brayton+Purcell LLP. Plaintiff currently contends she was exposed to

asbestos as a result of her husband’s employment.
Location of Exposure
Employer Exposure ~ Job Title Dates

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Metalclad Insulation Corp. —_-Pacifie Bell Insulator. 1983-1985
2198 S. Dupont Drive Stockton, CA . (3 weeks)
P.O. Box 61024 :

Anaheim, CA 92803 -

Job Duties: Plaintiff's husband applied fiberglass insulation to Pipiny and valves at a Pacific
Bell Telephone building located a few blocks north of downtown Stockton. Plaintiff currently
contends she was exposed to asbestos as a result of her husband’s employment.

. Location of : Exposure
Em r - Exposure Job Title Dates
Metalclad Insulation Corp. Lassen College Insulator 1983-1984
2198 South nt Drive Waste Incinerator (6 months)
P.O, Box 6102: Susanville, CA :
Anaheim, CA :

Job Duties: Plaintiffs husband applied new thermal insulation to piping, valves and fittings
during new constraction of a garbage burning power plant alongside Lassen College, near
Susanville, California, During the “blowdown” process, when an attempt was made to “fire up”
the new power plant, plaintiff observed pipefitters removing Original Equipment Manufacturer
flange ts from E CC, valves. gaskets were thereafter re-installed after the
“blowdown” test was completed. Plaintiff's husband observed various new CRANE CO. valves
being delivered on pallets, with the flange gaskets already wired to the CRANE CO. valves.
Plaintiffs husband recalls coworkers: Gene Cosby, address unknown; and Dean White, address
unk wn, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment. : .

Location of Exposure
Emplover Exposure Job Title Dates
Metalelad Insulation Corp. Shell Oil Insulator 1984-1985
2198 S. Dupont Drive Martinez, CA (2 months)
P.O, Box 61024
Anaheim, CA 92803

Job Duties: Plaintiff's husband applied KAYLO (OWENS CORNIN G FIBERGLAS) caleium
silicate pipecovering, fiberglass Pipecovering, insulation cement, black mastic and insulation
nm s

pads to piping and valves, husband re-installed asbestos-containing insulation pads
that had previously been removed by other workers. Plaintiff currently contends she was exposed
to asbestos as a result of her husband’s employment. °

: . Location of : "Exposure
Employer Exposure . Job Title Dates
Metalclad Insulation Corp. Corn Products Tnsulator 1984-1985
2198 S, Dupont Drive Stockton, CA (3-4 months)
P.O. Box 61024
Anaheim, CA 92803

Job Duties: _ Plaintiff's husband applied calcium silicate pipecovering, boardglass, white
adhesive, fabglass, black mastic, insulation cements, and aluminum jacketing to piping and
tanks. Plaintif’s husband repaired existing damaged asbestos-containing insulation. Plaintiff's
husband worked in close proximity to other trades, including welders, pipefitters, generator

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technicians, sheetmetal workers, electricians, and laborers. The laborers were dismantling
scaffolding that was laden with debris from the removed ashestos-containing ipecovering.
Plaintiff's husband observed ALLIS CHALMERS (ALLIS-CHALMERS C RATI
PRODUCT LIABILITY TRUS foncrator technicians repairing an existing ALLIS
CHALMERS (ALLIS-CHALMERS CORPORATION PRODUCT LIABILITY TRUST)

enerator. ALLIS CHALMERS (ALLIS-CHALMERS CORPORATION PRODUCT
EYABILITY TRUST) pipefitters were installing new CRANE CO, valves in plaintiff's husband
work areas. Plaintiff's husband recalls the following co-workers; Bob Wadley, deceased; and
Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos as a,result of he
husband’s employment. :

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Hormel Meat Packing “Insulator 1984

Stockton, CA @ weeks)

Job Duties: Plaintiff's husband removed asbestos insulation from pipes and then re-insulated the
pipes with cal sil insulation. Plaintiff's husband recalls that the site was very dusty. Plaintiff
currently contends she was exposed to asbestos as a result of her husband’s employment.

Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Sequoia Hospital Insulator 1984
iwoad City, CA. .

Job Duties: Plaintiff's husband applied calcium silicate pipecovering to new piping in an
existing hospital. Plaintiff's husband observed other trades employed by REDWOOD
PLUMBING (RED WOOD PLUMBING CO., INC.) removing asbestos-containing pipecovering
and insulated piping which created large amounts of visible dust, which plaintiff's husband
reported to Local No, 16 Business Agent Ed Story, deceased. Plaintiff currently contends she
‘was exposed to asbestos as a result of her husband's employment,

: Location of Exposure
Employer Exposure Job Title Dates
Metalclad Insulation Corp. Modules - Alaska Insulator 1985
2198 S, Dupont Drive Stockton, CA ‘ (4-5 months)
P.O, Box 61024
Anaheim, CA 92803

Job Duties; Plaintiff's husband appliéd urethane, fiberglass, insulation cements, Zeston fittings,
and aluminum jacketing to piping of portable, pre-fabricated dwellings and equipment.
Plaintiff's husband ed alongside various trades, including laborers who were sweeping and
cleaning dust and debris created by all the other trades, pipefitters who were fabricatin g In
and handling CRANE CO. valves and GARLOCK (GARLOCK SEALING TECHNOL GIES,
LLC) gaskets, carpenters, electricians who were handling electrical boxes and insulated wire,
sheetmetal workers, welders, ironworkers, and concrete workers, Plaintiff currently contends she
was exposed to asbestos as a result of her husband’s employment.

Location of Exposure

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Employer Exposure Job Title Dates
N.P.S. En Services Inc.; Rancho Seco Nuclear Insulator 1986-1988

Dravo Co: ctors Ine, Powerhouse
11 Stanwix St. Herald, CA
Pittsburg, PA : .

Job Duties: Plaintiff's husband removed Pi covering to make repairs to the insulation.
Plaintiff's husband recalls that BECHTEL (SEQUOIA VENTURES INC.) employees did the
tear-outs of pipes and other pieces of equipment at night and they would leave the debris over _
night for the BECHTEL (SEQUOIA V. IRES INC.) laborers to clean up the next day. This
debris included asbestos-containing KAYLO (OWENS CORNING FIBERGLAS) pipecovering,
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gasket debris, electrical boxes
and associated wiring and switches, piping scraps, and other debris. Plaintiff's husband recalis
sweeping up debris, Plaintiffs husband worked alongside mechanics who were rebuilding two
CATERPILLAR (CATERPILLAR, INC.) diesel engines, which involved replacement of the
engine gaskets. Plaintiff's husband recalfs the following supervisors: Rick Bartel, address

own; Ron Vandemeer, address unknown. Plaintiff's husband recalls the following co-
workers: Wiley Utterback, Sacramento, California; Phil Black, address unknown; Tom Begley,
c/o Brayton Purcell LLP; Robert Calvillo, c/o Brayton¢Purcell LLP. Plaintiff currently
contends she was exposed to asbestos as a result of her husband’s employment.

NON-OCCUPATIONAL EXPOSURE:

Plaintiff recalls assisting her first husband John Chambers, building a house in Stockton,
California in the early 1970s. Plaintiff recalls mixing, apolyin an sanding asbestos containing
KAISER GYPSUM COMPANY, INC, and HAMILTON MATERIALS, INC. all-purpose joint
and taping compounds purchased from 84 LUMBER in Stockton, California. |
Plaintiff recalls assisting, and being in proximity to, her first husband, John Chambers, while he
worked on an early 1970's FORD MOTOR COMPANY Mustang re lacing brake drums and
VICTOR (DANA COMPANIES; LLC (FKA DANA CORPORATI ND kets purchased at
NAPA AUTO PARTS and CHECKER AUTO PARTS, INC. (CSK AUTO, INC.) which are
both located in Stockton, California. |

Plaintiff recalls assisting her second husband Norman Juelch, $t., remove and replace brakes on
used 1977 PORD F-250, in t