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

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                                MCKENNA LONG te
ALDRIDGE LLP

ATTORNEYS ATL.
LOS ANGELES

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LISA L. OBERG (BAR NO. 120139)
DANIEL B. HOYE (BAR NO. 139683)
ALECIA E, COTTON (BAR NO, 252777)

ELECTRONICALLY

MCKENNA LONG & ALDRIDGE LLP FILED
101 California Street Superior Court of California,
Alst Floor County of San Francisco
San Francisco, CA 94111 MAR 03 2010
Telephone: (415) 267-4000 Clerk of the Court
Facsimile: (415) 267-4198 BY: ALISON AGBAY
Deputy Clerk
Attorneys for Defendant
METALCLAD INSULATION CORPORATION
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOYCE JUELCH and CASE No. CGC-09-275212
NORMAN JUELCH, SR.,
EXHIBITS | THROUGH L IN SUPPORT
Plaintiffs, OF DECLARATION OF ALECTA E,
COTTON IN SUPPORT OF DEFENDANT
v. METALCLAD INSULATION
CORPORATION’S MOTION FOR
ASBESTOS DEFENDANTS (BP), ef ai, SUMMARY JUDGMENT OR,
ALTERNATIVELY, SUMMARY
Defendants. ADJUDICATION OF ISSUES
DATE: March 18, 2010
TIME: 9:30 a.m.
Dept: 220
JUDGE: Hon. Harold E. Kahn
Trac DATE: April 5, 2010
J

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28

MEKERNA LONG &
ALDEIDGE LLP
ATTORNEYS ATLAW
SAN FRANCISCO.

LISA L. OBERG (BAR NO. 120139)

D. PAUL BIRD II BAR NO. 202066)
ALECIA E. COTTON (BAR NO, 252777}
MCKENNA LONG & ALDRIDGE LLP
101 California Street

Alst Floor

San Francisco, CA 94111

Telephone: (415) 267-4000

Facsintile: (415) 267-4198

Attorneys for Defendant
METALCLAD INSULATION CORPORATION
SUPERIOR CouRT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

JOYCE JUELCH and NORMAN Case No, 275212
JUELCH, SR.,
METALCLAD INSULATION CORPORATION’S
Plaintiffs, REQUEST FOR PRODUCTION OF DOCUMENTS
v.
ASBESTOS DEFENDANTS, et al.,

Defendants.

PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION
RESPONDING PARTY: Plaintiffs JOYCE JUBLCH & NORMAN JUBLCH, SR.
SET NUMBER: ONE

TO PLAINTIFF AND PLAINTIFE’S ATTORNEY OF RECORD HEREIN:

Defendant METALCLAD INSULATION CORPORATION, hereby requests that plaintiff
respond to the following Request for Production of Documents in accordance with California
Code of Civil Procedure sections 2031.2.10 et seq.; and that responsive documents be produced
within thirty (30) days of the date of this writing at 10:00 a.m. at the law offices of McKenna
Long & Aldridge LLP, 101 California Street, 41" Floor, San Francisco, California 94111.

METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS
SF27379 118.1oO © ee NS DR tH BR Nm

Room

aR & RB DB

MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS ATLAW
SAN FRANCISCO

REQUEST FOR PRODUCTION NO, 1:
Any and all DOCUMENTS identified and/or relied upon in plaintiff's responses to

Defendant METALCLAD INSULATION CORPORATION’s Pre-Trial Interrogatories, Set One,
served herewith.

As used in this Request for Production and throughout these requests, “DOCUMENT”
means a writing, as defined in Evidence Code section 250, and includes the original or a copy of
handwriting, typewriting, printing, photostats, photographs, electronically stored information, and
every other means of recording upon any tangible thing and form of communicating or
representation, including letters, words, pictures, sounds, or symbols, or combinations of them,
Reguest For PRopucTION No, 2:

All Asbestos Bankruptcy Trast Proof of Claim Forms with supporting documents that
YOU have filed with any Bankruptcy Trust for YOUR alleged asbestos-related injury.

As used in this Request for Production and throughout these requests, “YOU” and
“YOUR” refers to the plaintiff, plaintiff's decedent, plaintiff's attorney(s), employee(s), agent(s),
investigator(s), and other person(s) working under the plaintiff's direction or on the plaintiff's
behalf.

Request For PRODUCTION No. 3:

Any and all DOCUMENTS in support of your past, present and future wage loss claim
including but not limited to YOUR W-2 Forms, Profit and Loss statements, and family business
Annual Reports for ten years preceding YOUR asbestos-related injury.

Reouest For PRODUCTION No. 4:
Any and all DOCUMENTS in support of YOUR medical expense claims.

-2-

METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS:
SP:273791 184tm

Cc MW I DH PF WY LY

28

McKenna LONG &
Atpaipge LEP
ATTORNEYS AT LAW
SAN ERANCISCO

REQUEST For PropucTION NO, 5:
Any and all DOCUMENTS in support of YOUR retirement income loss claims including

but not limited to any pension benefit statements, social security retirement and disability income
benefit statements, state disability statements, worker’s compensation statements, and union

benefit statements.

MCKENNA LONG & ALDRIDGE LLP

» he & Ch

“LISA L. OBERG
ALscIA E. COTTON

Dated:

Attorneys for Defendant
METALCLAD INSULATION
CORPORATION

-3-

METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS:
SF:27379118.428

ACKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT Law
Sam FRANCISCO

PROOF OF SERVICE VIA LEXISNEXIS FILE & SERVE

Tam a citizen of the United States and employed in San Francisco County, California. I
am over the age of eighteen years and not a party to the within-entitled action, My business
address is 101 California Street, 41° Floor, San Francisco, California 94111.

On August 18, 2009, I electronically served the document(s) via LexisNexis File & Serve
described as:

METALCLAD INSULATION CORPORATION’S REQUEST
FOR PRODUCTION OF DOCUMENTS

on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve
website, | declare under penalty of perjury pursuant to the laws of the State of California that the

foregoing is tue and correct and was executed on August 18, 2009, at San Francisco, California.

CARY ANN ROSKO

METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS
SFQTIOUELPage | of 3

LexisNexis File & Serve Transaction Receipt

Transaction ID: 26658529

Submitted by: Cary Rosko, McKenna Long & Aldridge LLP-San Francisca
Authorized by: Alecia Cotton, McKenna Long & Aldridge LLP-San Francisco
Authorize and file on: Aug 18 2009 3:30PM PDT

Court: CA Superior Court County of San Francisco
Division/Courtroom: NIA

Case Class: Civil

Case Type: Personal Injury-Asbestos

Case Number: 275212

Case Name: Jueich vs Asbestos Defendants (Brayton)
Transaction Option: Serve Only ~ Public

Billing Reference: 28351.5781

Read Status for e-service: Not Purchased

Documents List
4 Document(s)

Attached Document, 9 Pages Document ID: 23732384 POE Format [| Griginal Format
Document Type: Access Statutory Fee: Linked:
Discovery - use for efectronic service only Public $6.00

Document title:
FORM INTERROGATORIES

Attached Document, 26 Pages Document ID: 23732405 BOE. Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery ~ use for elactronic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
Attached Document, 4 Pages Document ID: 23732425 PDE Format | Original Format
Document Type? Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS
Attached Document, 11 Pages Document ID: 23732445 PRE Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
Expand All
El Sending Parties (1)
Party Party Type Attorney Firm Attorney Type
Metalclad Insulation Corp Defendant Oberg, Lisa McKenna Long & Aldridge LLP-San Francisco Attorney in Charge
)_Recipients (58)
£2 Service List (58)
Delivery Attorney
Option Party Party Type Attorney Firm Type Method
Yaron, George * Attorney in E-
Service 84 Lumber Co LP Defendant Yaron & Associates Charge Service
‘ i Attorney in E+
Service Allis Chalmers Corp Defendant Pike, Gregory D Knox Ricksen LLP Charge Service
, Becherer, Becherer Kannett & Attorney in E-
Service © K Auto Inc Defendant Patrick 3 Schweitzer-Emeryville Charge Service

https:/Av3 fileandserve lexisnexis.com/WebServer/WebPages/Fil eAndServe/preReviewSu... 8/18/2009Page 2 of 3

Filice Brown Eassa & Attorney in E-

Service Chevron USA Inc Defendant Brown, EUgeNe ae end LLB-Oakiand Charge Service
Service Chevron USA Inc Defendant Mckeod, Bruce pice Brown Fasea & Choe, 8 OE wice
Service Chevron USA Inc Defendant Ogdie, Susan A fillee Brown Basse & chores’ in vice
Service Chevron USA Inc Defendant —Strotz, Peter re Brown Ean those, ie vice
senice  NAAEEETAUBHCN perngant ete, Andy Pree Decker S Amaro Amey In
Service Consolidated Insulation py sfandant Hillyard, Mary Ce eee Amaro Artorney in © ace
Service Consolidated Insulation pefendant Prindle, Kenneth rene Beach Amaro ee corvice
sevice Dette oer cua, CONE 6 sary secon MUNIN S,
senes nga Cte ouane ee Mcmeammne Money
Service Douglass Insulation Co Defendant course seese Selman Breitman LLP-San apomey in © vce
Service Fe oaies ie Defendant Glaspy, David Glaspy & Glaspy Chore. is Seni ce
Service See ooies Tae Defendant White, David W_ Glaspy & Giaspy craw’ Sonvice
Service Generat Electric Co Defendant ARSON: Derek secant Moran & che” ine vice

Attorney in E-

Service Genuine Parts Co Inc Defendant = Pond, Frank D Pond North LLP Charge Service

Counsel, Walsworth Franklin Bevins Attorney in E-

Service Hamilton Materials Inc Defendant genectos WEBM & McCall-Orange Charge Service
Service JT Thorpe &Son Inc Defendant —_Fadeff, Jeffery 2 Bass) Edie Hue Blum Chores’ in Senice
Service —_Juelch, Joyce Plaintiff Couns Bp nee Purcell LLP Qaee in Service
Service Kaiser Gypsum Co Inc Defendant Fadeff, Jeffery J Bassi Edin tule & Blum epomey in © wie .
Service Kaiser Gypsum Co Inc Defendant Fong, Camille K Lewis Grisbols Bisgeans Ss Ghowwe. Pe wice
cece ater cpsum caine Oenans Samay vem Srey in
Service —_Kalser Gypsum Co Inc Defendant Aber eas. LEWs Bristle gar de ey en ervice
coven owas ae owenane His, Ganges son tomar
service Minnesot Mini & pefendant_FaeKer Thomas Gane E Rees-San Charge, Service
Service Oscar E Erickson Inc Defendant ae Hassard Bonnington LLP howe in Service
Service Oscar E Erickson Inc Defendant ee wrem Seen Bevins Chae. in Soevice
Service Oscar E Erickson Inc Defendant Nelder, Robert Hassard Bonnington Lp Atormey in Ee
Charge Service
Service Pacific Bell Telephone perendant Counsel py AT&T Services Inc choo. ine vice
Service facie Gas & Electric Co Defendant on kucinds Storm, Lucinda L Esq Chores in Swvice
service Patil Gas Electric CO perengant 20h, Derek Sedgwick Detert Moran & Attorney in Ee

Bassi Edlin Hule & Blum = Attorney in E~

https:/Av3 fileandscrve.lexisnexis.com/WebServer/WebPages/FileAndServe/prcReviewSu... 8/18/2009Page 3 of 3

Service Parker Hannifin Corp. Defendant Fadeff, Jeffery } LLP-San Francisco Charge Service
4 5 Bassi Edlin Hute & Blum Attorney in E-
Service Parker Hannifin Carp Defendant Bassi, Matte 3 LLP-San Francisco Charge Service
5, Counsel, Walsworth Franklin Bevins Attorneyin  E-
Service Quintec Industries Inc Defendant pehectos WFAM & McCall-Orange Charge Service
Sonnenschein Nath & ‘
Service Rapid American Corp (Defendant Ratcliffe, Sarah Rosenthal LLP-San Attorney in E-
Fi Charge Service
rancisco
Redwood Plumbing Co Bishop Barry Howe Haney Attorney in E-
Service ine Defendant Barry, Nelson C & Ryder Charge Service
+ Redwood Plumbing Co Bishop Barry Howe Haney Attorney in &-
Service Inc Defendant Ryan, Mary M & Ryder Charge Service
i Morgan Lewis &Bockius Attorneyin &-
Service Santa Fe Braun inc Defendant Talarico, Amy LLP-San Francisco Charge Service
. Hartwell, Morgan Lewis & Backius Attorney in £-
Service Santa Fe Braun Inc Defendant’ saotimer HH -LLP-San Francisco Charge Service
. Hambiett, Attorney in >
Service Sequoia Ventures Inc Defendant Robert M Hassard Bennington LLP Charge Servier
Attorney in E-

Service Sequoia Ventures Inc Defendant elder, Robert Hassard Bonnington LLP Charge Service

Service Shell Oil Company Defendant Petty, Ross —=«sNixon Peabody LLP Attorney in E-

Charge Service
Service Shell Oi Company Defendant porinae. Hixon Peabody Lup-San onone” ne vice
Service Enyineering Co inc efenidant FShestos Week a ueesihornge Bevins Charge. 1 Service
Service Timee Co Inc Defendant PUM FAMES sinunu Bruni Cree Sorvice
Service Time Co Inc Defendant COUNSEL, sinunu Bruni Sree OS evice
Service Tosco Refining CaInc Defendant Brown, Eugene er te ona Chawe” in Sorvice
Service Tasco Refining Co Inc §=Defendant McLeod, Bruce nee gute ease & Choae. in Soni ce
Service Tasca Refining Co Inc Defendant Ogdle, Susan A Hue Grown Fossa Aomey In Service
Service Tosco Refining Co Inc Defendant —Strotz, Peter weed Ochi e aan” in Service
Service Union Carbide Carp Defendant Counsel, Brydon Hugo & Parker-San chaos’ 0 ewice
Service Unocal Corp Defendant Brown, Eugene Bee roe eee cheney in & vice
Service Unocal Corp Defendant  Strotz, Peter mee. Brome Fossa hee” in Sok ce
Service Unocal Corp Defendant Ogdie, Susan A meee te Ontend anmey in Servs ce
Service Unocal Corp Defendant MeLeod, Bruce Se oo Genie one in & wvice
Service Viacom Inc Defendant Pond, Frank Pond North LLP came’ Oe wice
El Additional Recipients (0)

Case Parties

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222 RUSH LANDING ROAD
NOVATO, CALIFORNIA 94948-6169
435-898-1555

BRAYTON@PURCELL LLP
ATTORNEYS AT LAW

Oo OR MN HW BR BW Nm

Rasp = Ss

ALAN R. BRAYTON, ESQ., S.B. #73685
DAVID R. DONADIO, ESQ., 8.B. #154436
RON G. ARCHER, ESQ., S.B. #189429
BRAYTONSPURCELL 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, SR., 3 No. 275212
Plaintiffs, ) PLAINTIFFS’ RESPONSES TO

} DEFENDANT METALCLAD

vs. ; INSULATION CORPORATION’S
REQUEST FOR PRODUCTION OF

ASBESTOS DEFENDANTS (B#P) ) DOCUMENTS, SET NO. ONE

)

PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION

RESPONDING PARTIES: _ Plaintiffs JOYCE JUELCH and NORMAN JUELCH, SR.
(hereafter “Plaintiff’)

SET NO: ONE (1)

f CTI : Defendant has failed to provide
meaningful, substantive responses to Court-ordered General Order 129s Standard Asbestos
Case Ihterrogatories. Therefore the information available to plaintiff regarding defendant
METALC INSULATION CORPORATION is incomplete. In good faith, plaintiff
responds to these Requests despite defendant's actions which are contrary to the policy of the
General Order 129s which is to promote the expeditious exchange of necessary and relevant
information in order to facilitate the prompt and intelligent evaluation of liability and damage
aspects wherever possible. Plaintiff requests defendant provide complete responses to General
Order 129s without the need for court intervention. Subject to the limitations placed upon it by
the defendant’s lack of diligence and good faith, plaintiff responds as follows: Defendant
already possesses the documents responsive to this request or such documentation is equally
available. Plaintiff's investigation and discovery are continuing.

Mit

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RESPONSE TO REQUES LFOR PRODUCTION NO. 2: Defendant has failed to provide
meaningful, substantive responses to Court-ordered General Order 129s Standard Asbestos
Case Interrogatories, Therefore the information available to plaintiff regarding defendant
METALCLAD INSULATION CORPORATION is incomplete, In good faith, plaintiff
responds to these Requests despite defendant's actions which are contrary to the policy of the
General Order 129s which is to promote the expeditious exchange of necessary and relevant
information in order to facilitate the prompt and intelligent evaluation of ability and damage
aspects wherever possible. Plaintiff requests defendant provide complete responses to General
Order 129s without the need for court intervention. Subject ta the limitations placed upon it by
the defendant’s lack of diligence and good faith, plaintiff responds as follows: Defendant
already possesses the documents responsive to this request or such documentation is equally
available. Plaintiff's investigation and discovery are continuing.

RESPONSE 10 REQUEST FOR PRODUCTION NO. 3: Defendant hs failed o provide
meaningful, substantive responses to Court-order eneral Order 129s Standard Asbestos
Case Interrogatories, Therefore the information available to plaintiff regarding defendant
METALC INSULATION CORPORATION is incomplete. In good faith, plaintiff
responds to these Requests despite defendant's actions which are contrary to the policy of the
General Order 129s which is to promote the expeditious exchange of necessary and relevant
information in order to facilitate the prompt and intelligent evaluation of liability and damage
aspects wherever possible. Plaintiff requests defendant provide complete responses to General
Order 129s without the need for court intervention, Subject to the limitations placed upon it by
the defendant’s lack of diligence and good faith, plaintiff responds as follows: Defendant

already possesses the documents responsive to this request or such documentation is equally
available. Plaintiff's investigation and discovery are continuing.

RESTONSE TO REQUEST FOR PRODUCTION Be. 4: Defendant has failed to provide
meaningful, substantive responses to Court-ordered General Order 129s Standard Asbestos
Case Interrogatorics, Therefore the information available to plaintiff regarding defendant
METALCLAD INSULATION CORPORATION is incomplete. In good faith, plaintiff
responds to these Requests despite defendant's actions which are contrary to the policy of the
General Order 129s which is to promote the expeditious exchange of necessary and relevant
information in order to facilitate the prompt and intelligent evaluation of liability and damage
aspects wherever possible. Plaintiff requests defendant provide complete responses to General
Order 129s without the need for court intervention. Subject to the limitations placed upon it by
the defendant’s lack of diligence and good faith, plaintiff responds as follows: Defendant
already possesses the documents responsive to this request or such documentation is equally
available. Plaintiff's investigation and discovery are continuing.

il

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KAlnjured\ 08688\pldufp-rap-METALC. wpd 2 ROA1 || RESPONSE TO FOR PRODUCTION NO. 5; Defendant has failed to provide
|| meaningful, substantive responses to Court-or General Order 129s Standard Asbestos
2|| Case Interrogatories, Therefore the information ayailable to plaintiff regarding defendant
| METALCLAD INSULATION CORPORATION is incomplete, In good faith, plaintiff
3 || responds to these Requests despite defendant's actions which are contrary to the policy of the
General Order 129s which is to promote the expeditious exchange of necessary and relevant
4] information in order to facilitate'the prompt and intelligent evaluation of liability and damage
aspects wherever possible, Plaintiff requests defendant provide complete responses to General
5 Order 129s without the need for court intervention, Subject to the limitations placed upon it by
|| the defendant's lack of diligence and good faith, plaintiff responds as follows: Defendant
6 || already possesses the documents responsive to this request or such documentation is equally
| available. Plaintift’s investigation and discovery are continuing.

BRAYTON“PURCELL LLP

91 oP o

| By: FE. f ul, hs

10 Ron G. Archer, Esq.
Attomeys for Plaintiffs

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PROOF OF SERVICE BY MAIL

1 am employed in the County of Sonoma, State of California. | am over the age of 18
years and am not a party to the within action. My business address is 1009 Clege Court,
Suite G, Petaluma, California 94954.

On SEP 18 2009 _, J served the within:
PLAINTIFFS’ RESPONSES TO DEFENDANT METALCLAD INSULATION

CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET NO.

on the interested party(ies) in this action by transmitting a true copy thereof in the following
manner.

I placed in a sealed envelope, postage thereon prepaid, addressed and served as follows:

METALCLAD INSULATION CORPORATION
McKenna Long & Aldridge

101 California Street

41* Floor

San Francisco, CA $4111

BY MAIL SERVICE: [am readily familiar with the business practice at my
place of business for collection and processing of
correspondence for delivery by mail. Correspondence so
collected and processed is deposited with the United
States Postal Service on the same day in the ordinary
course of business. On the above date the said envelope
was collected for the United States Postal Service
following ordinary business practices.

Executed SEP 18 2008 , at Petaluma, California.

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

Jovee Jueich and Norman Juelch, Sr. v. Asbestos Defendants (BYP)
San Francisco Superior Court Case No. 275212

PROOF OF SERVICE BY MAILwt CO DO © SW DW RF YW YD

{415} 898-1555

ATTORNEYS ATLAW
222 RUSG LANDING ROAD

BRAYPON@PURCELL LLP
NOVATO, CALIFGRNIA 94948-6169,

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y
o

VERIFICATION

Joyce Juelch and Norman Jueich, St

San Francisco Superior Court Case ‘No. 275212

1, Joyce Juelch and Norman Juelch SK, declare:
Tam the plaintiff in the above-entitled action. The foregoing Plaintiff's Response to
Defendant, Metalclad Insulation Corporation’s Request for Production of Documents Set One,

propounded by Metalclad Insulation Corporation, are true and correct as to those statements for
which I have personal knowledge. As to those matters which are therein stated on my
information and belief and, as to those matters, I believe them true.

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

foregoing is true and correct.

Dated: 221/72 OG

Signed:

Dated: (Aa-fG 2 DG

Signed:

Please do not write below this line. If you have any changes, please submit them on a

separate sheet of paper. Thank you.5
a
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BAocs
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PROOF OF SERVICE BY MAIL

Tam employed in the County of Sonoma, State of California. 1 am over the age of 18
ears and am not a party to the within action. My business address is 1324 Rand Sireet,
etaluma, California 94954,

On Gee 2 1 2008 > Lserved the within:

VERIFICATION(S) for Plaintiff's Resoanse to Defendant Metalclad Insulation
Corporation’s Request for Production of Documents , Set One propounded by Metalclad
Insulation Corporation on the interested parties in this action by transmitting a true copy
thereof in the following manner.

I placed in a sealed envelope, postage thereon prepaid, addressed and served as follows:

McKenna Long & Aldridge

101 California Street 41% Floor

San Francisco, CA 94111

Atiomeys for Metalclad Insulation Corporation

BY MAIL SERVICE: Lam readily familiar with the business practice at
my place of business for collection and processing
of correspondence for delivery by mail.
Correspondence so collected and processed is
deposited with the United States Postal Service on
the same day in the ordinary course of business.
On the above date the said envelope was collected
for the United States Postal Service following
ordinary business practices.

Executed on DEC 2 1 2009 , at Petaluma, California.
I declare under pénalty of perjury under the laws of the State of California that
the foregoing is true and correct. ve
CB)
‘CoA OWFPLAISTR

Joyce Juelch and Norman Jueteh OR
San Francisco Superior Court Case No. 275212

PROOF OF SERVICE BY MAILExhibit JDo 6 NY A HN RB WN

28

MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO

LISA L. OBERG (BAR NO. 120139)

D. PAUL BIRD If (BAR NO. 202066)
ALECIA BE, COTTON (BAR NO. 252777)
MCKENNA LONG & ALDRIDGE LLP
101 California Street

41st Floor

San Francisco, CA 94111

Telephone: (415) 267-4000

Facsimile: (415) 267-4198

Attorneys for Defendant
METALCLAD INSULATION CORPORATION
SUPERIOR CouRT OF THE STATE OF CALIFORNIA
CouNTY OF SAN FRANCISCO

JOYCE NUELCH and NORMAN CASE NO. 275212
JUBLCH, SR.,
METALCLAD INSULATION CORPORATION’S
Plaintiffs, REQUEST FOR ADMISSIONS
Vv.
ASBESTOS DEFENDANTS, et al.,

Defendants.

PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION
RESPONDING PARTY: Plaintiffs JOYCE JUELCH & NORMAN JUELCH SR.
SET NUMBER: ONE

TO PLAINTIFE AND PLAINTIFF’S ATTORNEY OF RECORD BEREIN:
‘Defendant METALCLAD INSULATION CORPORATION hereby requests that the
plaintiff respond to the following requests for admission in accordance with California Code of

Civil Procedure sections 2033.210 et seq., in writing and under oath, within thirty G0) days.

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS |
SE:27379144.1Oo PB HS RH KH

28

MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS ATLAW
BAN FRANCISCO

REQUEST FOR ADMISSION No. 1:
Admit that neither YOU nor anyone acting on YOUR behalf have any evidence that

Metalclad Insulation Corporation ever manufactured any ASBESTOS-CONTAINING
PRODUCTS.

As used in this Request for Admission and throughout these Requests for Admission,
“YOU” and “YOUR?” refers to the plaintiff, plaintiff's attorney(s), employee(s), agent(s),
investigator(s), and other person(s) working under plaintiff"s direction or on plaintiff's behalf.

As used in this Request for Admission and throughout these Requests for Admission,
“ASBESTOS-CONTAINING PRODUCTS” include asbestos fibers, in whatever form.
REQUEST FOR ADMISSION No. 2:

Admit that YOU are not alleging that PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by Metalclad Insulation Corporation at any time,
excluding any period PLAINTIFF was employed by Metalclad Insulation Corporation.

As used in this Request for Admission and throughout these Requests for Admission,
“PLAINTIFE” refers to the individual who was allegedly exposed to asbestos and is the subject of
this lawsuit.

As used in this Request for Admission and throughout these Requests for Admission,
“EXPOSURE” or “EXPOSED” includes PLAINTIFF’s use of such product and PLAINTIFP’s
presence in the proximity of such product.

As used in this Request for Admission and throughout these Requests for Admission,
“SUPPLIED” includes installation, delivery, distribution, sale, brokerage and any other link in the
chain of distribution of a product.

ReQugst FoR ADMISSION No. 3:

Admit that YOU have no personal recollection of PLAINTIFF ever being EXPOSED to

any ASBESTOS-CONTAINING PRODUCTS which YOU know were SUPPLIED by Metalclad

Insulation Corporation.

-2-

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SF:27379144.1oO Oo © YN DR B&B WN

28

MCKENNA LONG &
ALogipes LLP
ATTORNEYS AT LAW
SAN FRANCISCO

REQUEST FOR ADMISSION NO. 4:
Admit that neither YOU nor anyone acting on YOUR behalf has been told by any

PERSON that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS
SUPPLIED by Metalclad Insulation Corporation.

As used in this Request for Admission and throughout these Requests for Admission, the
term “PERSON” includes any natural person, custodian of records, firm, association, partnership,
joint venture, corporation, related or associated company, trust, or other form of legal entity.
Reovgst For ADMISSION No, 3:

Admit neither YOU nor anyone acting on YOUR behalf have been told by any PERSON
that Metalclad Insulation Corporation SUPPLIED any ASBESTOS CONTAINING PRODUCTS
to any of PLAINTIFF’s JOB SITES.

As used in this Request for Admission and throughout these Requests for Admission,
“JOB SITE” refers to any physical location where PLAINTIFF performed work or was physically
present.

REQUEST FOR ADMISSION NO. 6:

Admit that neither YOU nor anyone acting on YOUR behalf possesses any
DOCUMENTS supporting YOUR contention that Metalclad Insulation Corporation supplied any
ASBESTOS-CONTAINING PRODUCTS to any of PLAINTIPF’s JOB SITES.

As used in this Request for Admission and throughout these Requests for Admission,
“DOCUMENT” means a writing, as defined in Evidence Code section 250, and includes the
original or a copy of handwriting, typewriting, printing, photostats, photographs, electronically
stored information, and every other means of recording upon any tangible thing and form of
communicating or representation, including letters, words, pictures, sounds, or symbols, or
combinations of them.

REQUEST FOR ADMISSION NO, 7:

Admit that neither YOU nor anyone acting on YOUR behalf has knowledge of any
DOCUMENTS which support YOUR contention that Metalclad Insulation Corporation supplied

any ASBESTOS-CONTAINING PRODUCTS to any of PLAINTIFF’s JOB SITES.
~3-

METALCLAO INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SF27379 144528

McKenna Lon
Aupringe LLP

ANTORNEYS ATLAW |

SAN FRANCISCO

oe OY A KH ® YW

&

REQUEST FoR ADMISSION No. 8:
Admit that neither YOU nor anyone acting on YOUR behalf possesses any evidence

supporting YOUR contention that Metaiclad Insulation Corporation supplied any ASBESTOS-
CONTAINING PRODUCTS to any of PLAINTIFF’s JOB SITES.
Reourst For ADMISSION No. 9:

Admit that neither YOU nor anyone. acting on YOUR behalf has any evidence that
Metalclad Insulation Corporation SUPPLIED any ASBESTOS-CONTAINING PRODUCTS to
any of PLAINTIFF’s employers.

REQUEST FOR ADMISSION NO, 10:

Admit that YOU have no personal recollection of Metalclad Insulation Corporation
SUPPLYING any ASBESTOS-CONTAINING PRODUCTS at any work sites where
PLAINTIFF was employed.

REQuEST For ADMISSION NO. 11:

Admit that neither YOU nor anyone acting on YOUR behalf has any evidence that
Northern California Insulation ever manufactured any ASBESTOS-CONTAINING PRODUCTS.
REQUEST FOR ADMISSION NO. 12:

Admit that YOU are not alleging that PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by Northern California Insulation at any time,
excluding any period PLAINTIFF was employed by Northern California Insulation.

REQUEST FoR ADMISSION No. 13:

Admit that YOU have no personal recollection of PLAINTIFF ever being EXPOSED to
any ASBESTOS-CONTAINING PRODUCTS which YOU know were SUPPLIED by Northern
California Insulation.

REQUEST For ADMISSION No. 14:

Adrmit that neither YOU nor anyone acting on YOUR behalf has been told by any
PERSON that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS
SUPPLIED by Northern California Insulation.

-4-

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SF:27379144.10 CO HM RW BR DN

Nye Nw NM BY N LY i emt ph ame tent
RR RRR BRB SER REE GSES

28

McKEwna LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO

REQUEST FOR ADMISSION No. 15:
Admit neither YOU nor anyone acting on YOUR behalf has been told by any PERSON

that Northern California Insulation SUPPLIED any ASBESTOS-CONTAINING PRODUCTS to
any of PLAINTIFF’s JOB SITES.
T FOR ADMISSION No. 16:

Admit that neither YOU nor anyone acting on YOUR behalf possesses any
DOCUMENTS supporting YOUR contention that Northern California Insulation supplied any
ASBESTOS-CONTAINING PRODUCTS to any of PLAINTIFF’s JOB SITES.

REQUEST FOR ADMISSION No. 17:

Admit that neither YOU nor anyone acting on YOUR behalf has knowledge of any
DOCUMENTS which support YOUR contention that Northern California Insulation supplied any
ASBESTOS-CONTAINING PRODUCTS to any of PLAINTIFF’s JOB SITES.

REQUEST FOR ADMISSION No. 18:

Admit that neither YOU nor anyone acting on YOUR behalf possesses any evidence
supporting YOUR contention that Northern California Insulation supplied any ASBESTOS-
CONTAINING PRODUCTS to any of PLAINTIFF’s JOB SITES.

REQUEST FOR ADMISSION No. 19:

Admit that neither YOU nor anyone acting on YOUR behalf has any evidence that
Northern California Insulation SUPPLIED any ASBESTOS-CONTAINING PRODUCTS to any
of PLAINTIFF’s employers.

REQUEST FOR ADMISSION NO. 20:

Admit that YOU have no personal recollection of Northern California Insulation
SUPPLYING any ASBESTOS-CONTAINING PRODUCTS at any work sites where
PLAINTIFF was employed.

REQUEST FoR ADMISSION NO. 21:

Admit that Metalclad Insulation Corporation is not liable to YOU for Negligence.

REQUEST FOR ADMISSION NO. 22:
Admit that Metalclad Insulation Corporation is not liable to YOU for Strict Liability.
~5-

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SF:27379144.11 | Request FoR ADMISSION No. 23:

2 Admit that Metaiclad Insulation Corporation is not Hable to YOU for False
Representation.

Request For ApMission No, 24:
Admit that Metalelad Insulation Corporation is not liable to YOU for Intentional Tort.

Admit that Metalclad Insulation Corporation is not liable to YOU for Loss of Consortium.

REQUEST FOR ADMISSION NO. 26:

3
4
5
6 | REQUEST FoR ADMISSION No. 25:
7
8
9

Admit that Metalclad Insulation Corporation is not liable to YOU for Failure to Warn.

10 4 B T FoR ADMISSIO’ 27:

ll Admit that Metalclad Insulation Corporation is not liable to YOU for Fraud.
12 | Request FOR ADMISSION NO. 28:

13 Admit that Metalclad Insulation Corporation is not liable to YOU for Conspiracy.

14 | REQUEST FOR ADMISSION No. 29:

1s Admit that Metalclad Insulation Corporation is not liable to YOU for Enterprise Liability.
16 | Request For ADMISSION No. 36:
17 Admit that Metalclad Insulation Corporation is not liable to YOU for Concert-of-Action.

18 | Request For ADMISSION NO. 31:

19 Admit that Metalclad Insulation Corporation is not liable to YOU for Breach of Warranty.

20 | REQUEST FOR ADMISSION NO. 32:

21 Admit that Metalclad Insulation Corporation is not liable to YOU for Premises
22 | Owner/Contractor Liability.
23 | RE T FoR ADMISSIO) 33:

24 Admit that Metalclad Insulation Corporation is not liable to YOU for Exemplary or
25 | Punitive Damages.

26 | REQUEST FOR ADMISSION No. 34:

27 Admit that Northern California Insulation is not liable to YOU for Negligence.
28
MCKENNA LONG & 6
ALDRIDGE LLP 2
ATTORNENS AT LAW METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS:

SAN FRANCISCO
SF:273791 44.428

McKenwa Long &
Aupringe LLP
ATTORNEYS AT Lai
SAN FRANEISCO

Request FOR ADMISSION NO. 35:

Admit that Northern California Insulation is not liable to YOU for Strict Liability.

REQUEST FOR ADMISSION NO. 36:

Admit that Northern California Insulation is not liable to YOU for False Representation.

REQUEST FOR ADMISSION NO, 37:

Admit that Northern California Insulation is not liable to YOU for Intentional Tort.

ReEQuEst FOR ADMISSION No. 38:

Admit that Northern California Insulation is not liable to YOU for Loss of Consortium.

Reouest For ADMISSION No. 39:

Admit that Northern California Insulation is not liable to YOU for Failure to Warn.

REQUEST FOR ADMISSION No. 40:

Admit that Northern California Insulation is not liable to YOU for Fraud.

Request For ADMISSION No. 41:

Admit that Northern California Insulation is not liable to YOU for Conspiracy.

Reouest For ADMISSION No. 42:

Admit that Northern California Insulation is not liable to YOU for Enterprise Liability.

Request For ADMISSION No. 43:

Admit that Northern California Insulation is not Hable to YOU for Concert-of-Action.

REQUEST FoR ADMISSION NO. 44:

Admit that Northern California Insulation is not liable to YOU for Breach of Warranty.

REQUEST FoR ADMISSION No. 45:

Admit that Northern California Insulation is not liable to YOU for Premises

Owner/Contractor Liability.
“
if
u
i
“u

-7-

SF:27379144.1

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONSCo Bw DW HD A BR WB HN

3

28

McKenna Lona &
ALDRIOGE LLP
ATTORNEYS ATLAW,
SAN FRANCISCO

REQUEST FoR ADMISSION No. 46:
Admit that Northern California Insulation is not liable to YOU for Exemplary or Punitive

Damages.

Dated: MCKENNA LONG & ALDRIDGE LLP

A

By: i! | ua S. ban

“7 Tiss L. OBERG
ALECIA E. COTTON

Attorneys for Defendant
METALCLAD INSULATION
CORPORATION

-8-

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SF:27379144, 128

MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN PRANCISCO

DECLARATION OF ALECIA E, COTTON
In SuprorT OF ADDITIONAL DISCOVERY

I, ALECIA E. Corron, declare:

L. Lam an attorney of record for defendant, METALCLAD INSULATION
CORPORATION, a party to this action.

2. Defendant METALCLAD INSULATION CORPORATION is propounding to
plaintiff the attached set of request for admissions.

3. ‘This set of request for admissions will cause the total number of admission
requests propounded to the party to whom they are directed to exceed the number of admission
requests permitted by section 2033.030 of the Code of Civil Procedure.

4. This set of request for admissions contains a total of 46 admission requests.

3. I am familiar with the issues and the previous discovery conducted by all of the

parties in the case.

6. [have personally examined each of the questions in this set of request for
admissions.
7. This number of request for admissions is warranted under section 2033.040 of the

Code of Civil Procedure due to the complexity or quantity of the existing or potential issues in
this case and the expedience of using this method of discovery is to provide to the responding
party the opportunity to conduct an inguiry, investigation or search of files or records to supply
the information sought.

8. None of the requests in this set of request for admissions is being propounded for
any improper purpose, such as to harass the party, or the attomey for the party, to whom itis -

directed, or to cause unnecessary delay or needless increase in the cost of litigation.

-9-

METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SE:27379 144.11 { declare under penalty of perjury under the laws of the State of California that the

2 | foregoing is true and correct and that this declaration was executed on this | day of August,

[ he c bu

ALECIA EB. COTTON

3 | 2009, at San Francisco, California.

28

McKennia LONG & 10
ALORIDGE LLE cote
ATTORNEYS AT Law METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS

SAN PRaNcisco,
SPQ73791G4.EOo OW NY Dw BR BH Nm

2

28

ACKENNA LONG &
ALbRIOGE LLP
ATTORNEYS AT Law
SAN FRANCISCO

PROOF OF SERVICE VIA LEXISNEXIS FILE & SERVE

lam a citizen of the United States and employed in San Francisco County, California. I
am over the age of eighteen years and not a party to the within-entitled action. My business
address is 101 California Street, 41" Floor, San Francisco, California 94111.

On August 18, 2009, I electronically served the document(s) via LexisNexis File & Serve
described as:

METALCLAD INSULATION CORPORATION'S
SPECIALLY PREPARED INTERROGATORIES

on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve
website. | declare under penalty of perjury pursuant to the laws of the State of California that the

foregoing is true and correct and was executed on August 18, 2009, at San Francisco, California.

\CARY ANNROSKO

METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES.
SP:27379116.1Page 1 of 3

LexisNexis File & Serve Transaction Receipt

Transaction ID: 26658529
Submitted by: Cary Rosko, McKenna Long & Aldridge LLP-San Francisco
Authorized by: Alecia Cotton, McKenna Long & Aldridge LLP-San Francisco

Authorize and file on: Aug 18 2009 3:30PM PDT

Court: CA Superlor Court County of San Francisco
Division/ Courtroom: N/A

Case Class: Civil

Case Type: Personal Iniury-Asbestas:

Case Number: 275212

Case Name: Juelch vs Asbestas Defendants (Brayton)
Transaction Option: Serve Only ~ Public

Billing Reference: 28351.5781

Read Status for e-service: Not Purchased

Documents List
4 Document(s)

Attached Document, 9 Pages Document ID: 23732384 PDF Format | Original format
Document Type: Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $9.00

Document title:

FORM INTERROGATORIES

Attached Document, 26 Pages Document ED: 23732405 PRE Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery ~ use for electronic service only Public $0.00

Document title:
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES

Attached Document, 4 Pages Document ID: 23732425 PDF Format { Original Format
Document Type: Access? Statutory Fee: Linked:
Discovery ~ use for electronic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S REQUEST FOR PRODUCTION OF DOCUMENTS
Attached Document, 11 Pages Document ID: 23732445 POF Format | Original Format
Document Type: Access! Statutory Fee: Linked:
Discovery ~ use for electronic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
Expand All
2] Sending Parties (1)
Party Party Type Attorney Firm Attorney Type
Metalciad Ineulation Corp Defendant Oberg, Lisa McKenna Long & Aldridge LLP-San Francisco Attorney in Charge
©) Recipients (58)
E] Service Lst (58)
Delivery , Attorney
‘Option Party Party Type Attorney Firm Type. Method
Yaron, Gearge ; Attorney in E+
Service 84 Lumber Co LP Defendant ’ Yaron & Associates Charge Service
, Attorney in E-
Service Allis Chalmers Corp Defendant Pike, Gregory D Knox Ricksen LLP Charge Service
Becherer, Becherer Kannett & Attorney in E+
Service CS K Auto ine Defendant patrick J Schweltzer-Emeryvilie Charge Service

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Chevron USA Inc Defendant
Chevron USA Inc Defendant
Chevron USA Inc Defendant
Chevron USA Inc Defendant
fonsolidated insulation pb rendant
Fonsalidated Insulation perondant
Consolidated Trsulation Ketendant
Designated Defense Courtesy
Counsel Recipient
Dillingham Construction
NA Ine Defendant
Douglass Insulation Co Defendant
BC
Garlock Sealing
Technologies inc Defendant
Garlock Sealing
Technologies inc Defendant
General Electric Co Defendant

Genuine Parts Co Inc Defendant
Hamilton Materials Inc Oefendant
JT Thorpe & Son Inc Defendant
Juelch, Jayce Plaintiff

Kaiser Gypsum Co Ine Defendant
Kalser Gypsum CoInc Defendant

Kaiser Gypsum Co Inc Defendant

Kaiser Gypsum Co Inc Defendant

Minnesota Mining &

Manufacturing Co(am) Defendant
Minnesota Mining &

Manufacturing Co(3M) Defendant
Minnesota Mining & Defendant

Manufacturing Co(3M)

Oscar E Erickson Inc Defendant
Oscar E Erickson Inc Defendant

Oscar € Erickson Inc Defendant

Pacific Bell Telephone
Co

Pacific Gas & Electric Co
Inc

Pacific Gas & Electric Co
Inc

Defendant

Defendant

Defendant

Brown, Eugene
McLeod, Bruce
Ogdie, Susan A
Stratz, Peter
Goetz, Andy J
Hillyard, Mary

Prindle, Kenneth
Counsel,
Asbestos B&b

Becherer,
Patrick J
Counsel,
Asbestos SB-SF

Glaspy, David

white, David W

Johnson, Derek
$

Pond, Frank D

Counsel,
Asbestos WFEM

Fadeff, Jeffery 3

Counsel,
Asbestos Bp

Fadeff, Jeffery J

Fong, Camille K

Granahan,
Conor D

Counsel,
Asbestos LEBS~
SF

Kilielea,
Timothy K

Packer, Thomas
A

Moroney, Linda
M

Hambiett,
Robert M

Counsel,
Asbestos WFBM

Nelder, Robert
Counsel,

Asbestos ATT
Storm, Lucinda
4

Johnson, Derek
$s

Filice Brown Eassa &
McLeod LLP-Oakland

Filice Brown Eassa &
McLeod LLP-Cakland

Filice Brown Eassa &
McLeod LLP-Oakdand

Filice Brown Eassa &
McLeod LLP-Oakland

Prindle Decker & Amaro
LLP-Long Beach

Prindle Decker & Amaro:
LLP-Long Beach
Prindle Decker & Amaro:
LLP-Long Beach

Berry & Berry-Oakland
Becherer Kannett &
Schweitzer-Emeryville
Selman Breitman LLP-San
Francisco

Glaspy & Glaspy

Glaspy & Glaspy

Sedgwick Getert Moran &
Arnold LLP

Pond North LLP

Walsworth Franklin Bevins
& McCall-Orange

Bass! Ediin Huie & Blum
LLP-San Francisco

Brayton Purcell LLP+
Novato

Bassi Edlin Huie & Blum
LLP-San Francisco

Lewis Brisbois Bisgaard &
Smith LLP-San Francisco

Lewis Grisbois Bisgaard &
Smith LLP-San Francisco

Lewis Brishois Bisgaard &
Smith LLP-San Francisco:

Gordon & Rees-San
Francisco

Gordon & Rees-San
Francisco

Gordon & Rees-San
Francisco

Hassard Bonnington LLP

Walsworth Franklin Bevins
& McCall-Orange

Hassard Bonnington LLP
AT &T Services Inc

Storm, Lucinda L Esq

Sedgwick Detert Moran &
Arnold LLP

Bassi Edlin Huie & Blum

Page 2 of 3

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8/18/2009Page 3 of 3

Service Parker Hannifin Corp Defendant Fadeff, Jeffery J LLP-San Francisco Charge Service
‘i + Basst Edlin Hule & Blum = Attorney in E-
Service Parker Hannifin Corp Defendant Bassi, Marte J LUP-San Francisco Charge Service
“ . Counsel, Walsworth Franklin Bevins Attorney in E-
Service Quintec Industries Inc Defendant pon octoe WFBM & McCall-Orange Charge Service

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Service Redwood Plumbing Co Defendant Barry, Nelson C Raver Howe Haney rome’ in ccmvice
Service Redwood Plumbing Co Defendant yar, Mary M ater Howe Haney chawe in Sonvice
Service Santa Fe Braun inc Defendant Talarico, Amy Morgan Low's Bockius Chomwe 8 Oe evice
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Service Sequoia Ventures Inc Defendant cere Hassard Bonnington LLP ChomeY in Sic
Service Sequoia Ventures Inc Defendant elder, Robert Hassard Bonnington LLP thoes. in cert ce
Service Shell Oif Company Defendant Petty, Ross Nixon Peabody LLP Choe in Sowvies °
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Service Tosco Refining Co Inc Defendant Brown, Eugene fitlce Brown Bassa & Crome’ in eee
Service Tosco Refining Co Inc Defendant McLeod, Bruce pce Brown Basse Attorney in & wee
Service Tosco Refining Co Inc Defendant —Ogdie, Susan A Tee ase Attorney in © ee
Service Tosca Refining Co Ine Defendant Strotz, Peter flee Brown Fase & attorney tn Eee
Service Union Carbide Corp Defendant couse sup Brydon Hugo & Parker-San attorney in eee
Service Unocal Corp Defendant Brown, Eugene Bilice Brown Fase & prtorney In © lee
Service Unocal Corp Defendant — Strotz, Peter Fee aoe oe attorney in & vice
Service Unocal Corp Defendant Ogdie, Susan A nee eee sasse & Atomey in & vies
Service Unocal Corp Defendant MeLeod, Bruce yee Brown Fasea & Aovmey in © ce
Service Viacom Inc Defendant Pond, Frank D Pond North LLP chee” in Service
[5 Adaltional Recipients (0)
case Parties

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https://w3.fileandserve. lexisnexis.com/WebServer/WebPages/FileAndServe/prcReviewSu... 8/18/2009BRAYTON@PURCELL LLP

ATTORNEYS ATLAW.
222 RUSH LANDING ROAD

PO BOX 6169
NOVATO, CALIFORNIA 94948-6169

(45) 898-4555

Oo Oe ND A Bw ND me

fe hhh it
OA FB Oo NY = oS

16

ALAN R. BRAYTON, ESQ., S.B. #73685
DAVID R, DONADIO, ESQ., S.B. #154436
RON G. ARCHER, ESQ., S.B. #189429
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 SUELCH AND ASBESTOS
NORMAN JUELCH, SR., No. 275212
Plaintiffs, ) PLAINTIFFS’ RESPONSES TO
DEFENDANT METALCLAD
vs. INSULATION CORPORATION’S
} REQUEST FOR ADMISSION
ASBESTOS DEFENDANTS (BYP) }
)

PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION

RESPONDING PARTIES: Plaintiffs JOYCE JUBLCH and NORMAN JUELCH, SR.
(hereafter “Plaintiff*)

SET NUMBER: ONE

RESPONSE TO REQUEST FOR ADMISSION NO. 1: Plaintiff objects to this Request upon
the ground that defendant improperly seeks information protected from disclosure by the
attorney-client privilege, and work-product privilege, Code of Civil Procedure § 2018.030.
Subject to and without waiving said objections, plaintiff presently responds as follows:

Denied.

RESPONSE TO REQUEST FOR ADMISSION NO. 2: Plaintiff objects to this Request upon
the ground that defendant improperly seeks information protected from disclosure by the
attorney-client privilege, and work-product privilege, Code of Civil Procedure § 2018.030.
Subject to and without waiving said objections, plaintiff presently responds as follows:

Denied.
Mt

KNlnjored\ O86 88tpldvfa-rsp-METALC.wpd i RGABw MRM m= BD 0 WN DH HW RB BN

a a

RESPONSE TO REQUEST FOR ADMISSION NO. 3: Plaintiff objects to this Request upon

the ground that defenda