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McKenna LONG &
ALbRIOCE LLP
ATTORNEYS AT Law
LISA L. OBERG (BAR NO. 120139)
DANIEL B. HOYE (BAR NO. 139683)
ALECIA E. 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
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
MAR 03 2010
Clerk of the Court
BY: ALISON AGBAY
Deputy Clerk
METALCLAD INSULATION CORPORATION
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOYCE JUELCH and
NORMAN JUELCH, SR.,
Plaintiffs,
v.
ASBESTOS DEFENDANTS (BP), ef al.,
Defendants.
Los ANCELES
CASE No. CGC-09-275212
EXHIBIT H, PART LIN SUPPORT OF
DECLARATION OF ALECIA E. COTTON
IN SUPPORT OF DEFENDANT
METALCLAD INSULATION
CORPORATION’S MOTION FOR
SUMMARY JUDGMENT OR,
ALTERNATIVELY, SUMMARY
ADJUDICATION OF ISSUES
Date: March 18, 2010
TIME: 9:30 am.
DEPT: 220
JubDGE: Hon. Harold E. Kahn
TRIAL DaTE: April 5, 2010
SE2741d 9
330Exhibit H1 | LISA L, OBERG (BAR NO. 120139)
D. PAUL BIRD IE (BAR NO. 202066)
2 | ALECIA BE. COTTON (BAR NO. 252777)
MCKENNA LONG & ALDRIDGE LLP
3 | 101 California Street
41st Floor
4 | San Francisco, CA 94111
Telephone: (418) 267-4000
5 | Facsimile: {415) 267-4198
6 | Attorneys for Defendant
METALCLAD INSULATION CORPORATION
7
& SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
10
11 | JOYCE JUELCH and NORMAN CASE NO. 275212
JUELCH, SR..
12 METALCLAD INSULATION CORPORATION’S
Plaintiffs, SPECIALLY PREPARED INTERROGATORIES
13
Vv.
14
ASBESTOS DEFENDANTS, et al.
15
Defendants.
16
17
PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION
18
RESPONDING PARTY: Plaintiffs JOYCE JUEBLCH & NORMAN JUELCH, SR.
19
SET NUMBER: ONE
20
2
TO PLAINTIFF AND PLAINTIFE’S ATTORNEY OF RECORD HEREIN:
22
Defendant METALCLAD INSULATION CORPORATION hereby requests that the
23
plaintiff respond to the following interrogatories in accordance with California Code of Civil
24
Procedure sections 2030.210 et seq., in writing and under oath, within thirty (30) days.
25
INTERROGATORY No. 1:
26
Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING
27
PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION.
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MCKENNA LONG &
ALDRIDGE LLP
Aone ara METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SF:27379116.1Cf NW DN A B&B WN
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MCKENNA LONG &
AvpaioGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
As used in this Interrogatory and throughout these Interrogatories, “YOU” and “YOUR”
refers to plaintiff, 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.
As used in this Interrogatory and throughout these Interrogatories, “PLAINTIFF” refers to
the individual who was allegedly exposed to asbestos and is the subject of this lawsuit.
As used in this Interrogatory and throughout these Interrogatories, “EXPOSURE” or
“EXPOSED” includes YOUR use of such product, and YOUR presence in the proximity of such
product being used by others.
As used in this Interrogatory and throughout these Interrogatories, “ASBESTOS-
CONTAINING PRODUCTS” includes asbestos fibers, in whatever form.
As used in this Interrogatory and throughout these Interrogatories, “SUPPLIED” includes
installation, delivery, distribution, sale, brokerage and any other link in the chain of distribution
of a product.
As used in this Interrogatory and throughout these Interrogatories METALCLAD
INSULATION CORPORATION includes any employee or representative thereof.
INTERROG: 0 2s
IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION
CORPORATION.
As used in these Interrogatories, “IDENTIFY” when referring to a location means to
describe by type of facility, street address, and/or physical description, including, but not limited
to, the exact location or description of the exact location within the facility; “IDENTIFY” when
referring to a person means to provide the name, job title, last known address, phone number, and
relationship to plaintiff; “IDENTIFY” when referring to a document means to describe by
physical description, contents, title, page number, bates number, caption, date, and/or other sach
description sufficient to identify such document in a request for production of document.
-2-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
SF:27379316.1Oo MW BR OR RR BD De
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S RRR BBE BB SEAR BDR SESE S
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MCKENNA LONG &
ALDRIDGE LLP
ASTORNEYS AT Law
SAN FRANCISCO
As used in these Interrogatories, “JOBSITE” refers to any physical location, including, but
not limited to the exact address, physical description, and precise area within identified physical
location where YOU performed work or was physically present.
INTERROGATORY NO. 3:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION
CORPORATION, describe each ASBESTOS-CONTAINING PRODUCT that YOU contend
METALCLAD INSULATION CORPORATION SUPPLIED.
INTERROGATORY No. 4:
For each ASBESTOS-CONTAINING PRODUCT that YOU contend METALCLAD
INSULATION CORPORATION SUPPLIED, state the exact dates of PLAINTIFF’s EXPOSURE
to each product at each JOB SITE.
INTERROGATORY No. 5:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION,
IDENTIFY all PERSONS who have testified under oath that METALCLAD INSULATION
CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that JOB SITE.
As used in this Interrogatory and throughout these Interrogatories, 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.
INTERROGATORY NO. 6:
For each PERSON who has testified under oath that METALCLAD INSULATION
CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB
SITE(S), IDENTIPY the transcript, by case name, case number, date, court reporting service and
page/line number where such testimony was given.
INTERROGATORY NO. 7:
For each PERSON who has testified under oath that METALCLAD INSULATION
CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB
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METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
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McKenna LONG &
Acomoce LLP
ATTORNEYS AT LAW
SAN FRANCISCO,
SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that
PERSON’S testimony relates.
InteRrocaTory No. 8:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION
CORPORATION, IDENTIFY all PERSONS who have personally informed YOU that
METALCLAD INSULATION CORPORATION SUPPLIED ASBESTOS-CONTAINING
PRODUCTS to that JOB SITE.
INTERROGATORY NO, 9:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION,
state all facts supporting YOUR contention.
INTERROGATORY NO. 10:
For each fact YOU IDENTIFIED as supporting YOUR contention that PLAINTIFF was
EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD
INSULATION CORPORATION, specify the evidence that YOU contend supports each fact.
INTERROGATORY NO. 11:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION,
IDENTIFY each DOCUMENT YOU possess that supports YOUR contention.
As used in these Interrogatories, “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.
INTERROGATORY NO, 12:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION,
de
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SF27379116.428
MCKENNA LONG &
ALGRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
IDENTIFY each DOCUMENT, of which YOU have actual knowledge, that supports YOUR
contention.
InTERROGATORY NO. 13:
Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING
PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION.
As used in these Interrogatories, “DISTURBED” includes installing, removing, repairing,
cutting, abrading, manipulating, or otherwise coming into contact with.
INTERROGA TORY NO. 14:
IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION.
INTERROGATORY No. 15:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, describe the specific ASBESTOS-CONTAINING PRODUCT that YOU
contend was DISTURBED.
INTERROGATORY NO. 16:
State the exact dates of the EXPOSURE at each JOB SITE for each ASBESTOS-
CONTAINING PRODUCT that YOU contend METALCLAD INSULATION CORPORATION
DISTURBED.
InterroGatory No, 17:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, IDENTIFY all PERSONS who have testified under oath that METALCLAD
INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at
that JOB SITE.
-5-
METALOLAD INSULATION CORPORATION'S SPEGIALLY PREPARED INTERROGATORIES
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MCKENNA LONG &
Aborioce LLP
ATTORNEYS AT LAW
BAN FRANCISCO
INTERROGATORY NO. J8:
For each PERSON who has testified under oath that METALCLAD INSULATION
CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB
SITES, IDENTIFY the transcript by case name, case number, date, court reporting service and
page/line number where such testimony was given.
INTERROGATORY No. 19:
For each PERSON who has testified under oath that METALCLAD INSULATION
CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB
SITES, list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that
PERSON’S testimony relates.
INTERROGATORY NO. 20:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, IDENTIFY all PERSONS who have personally informed YOU that
METALCLAD INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING
PRODUCTS at that JOB SITE.
INTERROGATORY No, 21;
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, state all facts supporting YOUR contention.
INTERROGATORY NO. 22:
For each fact supporting YOUR contention that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, specify the evidence that YOU contend supports each fact.
Jnrerrocatory No. 23:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention.
-6-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
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MCKENNA LONG &
Aborioge LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO, 24:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION
CORPORATION, IDENTIFY each DOCUMENT of which YOU have actual knowledge that
supports YOUR contention.
INTERROGATORY NO. 25:
Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING
PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION.
As used in this Interrogatory and throughout these Interrogatories NORTHERN
CALIFORNIA INSULATION includes any employee or representative thereof,
INTERROGATORY NO. 26:
IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA.
INSULATION.
INTERROGATORY No, 27:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA
INSULATION, describe each ASBESTOS-CONTAINING PRODUCT that YOU contend
NORTHERN CALIFORNIA INSULATION SUPPLIED.
InTERROGATORY No. 28:
For each ASBESTOS-CONTAINING PRODUCT that YOU contend NORTHERN
CALIFORNIA INSULATION SUPPLIED, state the exact dates of PLAINTIFF’s EXPOSURE to
each product at each JOB SITE.
INTERROGATORY NO, 29:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA
INSULATION, IDENTIFY all PERSONS who have testified under oath that NORTHERN
Je
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SP:27379116.10 68 WM DR eR B&B Ww Ym
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MCKENNA LONG &
ALORIDGE LLP
ATTORNEYS AT LAW
SAN PRancisco,
CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that
JOB SITE.
INTERROGATORY NO. 30:
For each PERSON who has testified under oath that NORTHERN CALIFORNIA
INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB
SITE(S), IDENTIFY the transcript, by case name, case number, date, court reporting service and
page/line number where such testimony was given.
INTERROGATORY NO, 31:
For each PERSON who has testified under oath that NORTHERN CALIFORNIA
INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB
SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that
PERSON’S testimony relates.
INTERROGATORY NO, 32:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA
INSULATION, IDENTIFY all PERSONS who have personally informed YOU that
NORTHERN CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING
PRODUCTS to that JOB SITE.
InTERROGATORY No, 33:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, state
all facts supporting YOUR contention.
INTERROGATOR: . 34:
For each fact YOU IDENTIFIED as supporting YOUR contention that PLAINTIFF was
EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN
CALIFORNIA INSULATION, specify the evidence that YOU contend supports each fact.
~8-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
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McKenna LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO. 35:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION,
IDENTIFY each DOCUMENT YOU possess that supports YOUR contention.
INTERROGATORY NO, 36:
For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS-
CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION,
IDENTIFY each DOCUMENT, of which YOU have actual knowledge, that supports YOUR
contention.
INTERROGATORY NO, 37:
Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING
PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION.
As used in these Interrogatories, “DISTURBED” includes installing, removing, repairing,
cutting, abrading, manipulating, or otherwise coming into contact with.
INTERROGATO! 38:
IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION.
INTERROGATORY No. 39:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, describe the specific ASBESTOS-CONTAINING PRODUCT that YOU contend
was DISTURBED.
INTERROGATORY NO, 40:
State the exact dates of the EXPOSURE at each JOB SITE for each ASBESTOS-
CONTAINING PRODUCT that YOU contend NORTHERN CALIFORNIA INSULATION
DISTURBED,
9
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SEQTSTONGAoD eM DR Ww RF WY
BOS s = 6
MCKENNA LONG é&
ALORIOGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO.
InTerRocaTory No. 41:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA,
INSULATION, IDENTIFY all PERSONS who have testified under oath thal NORTHERN
CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at that
JOB SITE.
INTERROGATORY No. 42:
For each PERSON who has testified under oath that NORTHERN CALIFORNIA
INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB
SITES, IDENTIFY the transcript by case name, case number, date, court reporting service and
page/line number where such testimony was given.
INTERROGATORY NO. 43:
For each PERSON who has testified under oath that NORTHERN CALIFORNIA
INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB
SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that
PERSON’S testimony relates.
INTERROGATORY No, 44:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, IDENTIFY all PERSONS who have personally informed YOU that
NORTHERN CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING
PRODUCTS at that JOB SITE.
INTERROGATORY No, 45:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, state all facts supporting YOUR contention.
-~16-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
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MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN PRancisco,
INTERROGATORY NO. 46:
For each fact supporting YOUR contention that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, specify the evidence that YOU contend supports each fact.
INTERROGATORY No. 47:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention.
INTERROGATORY No. 48:
For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to
ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA
INSULATION, IDENTIFY each DOCUMENT of which YOU have actual knowledge that
supports YOUR contention.
Interrocarory No. 49:
If PLAINTIFF worked with any ASBESTOS product manufactured, produced, prepared,
distributed or sold by any entity not named as a defendant in this lawsuit, identify the product and
each such entity.
INTERROGATORY NO, 50:
If PLAINTIFF worked with any ASBESTOS product manufactured, produced, prepared,
distributed or sold by any bankrupt party, whether or not such defendant was served with the
; Complaint, IDENTIFY each such party.
INTERROGA TORY No. 51:
Please state whether YOU have completed a Proof of Claim Form for each bankrupt party
that YOU contend manufactured, produced, prepared, distributed or sold ASBESTOS-containing
products with or around which PLAINTIFF worked.
INTERROGATORY No, 52:
List all medical healthcare providers that treated PLAINTIFF for injuries that YOU claim
resulted from PLAINTIFF’s exposure to asbestos.
-li-
METALCLAG INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
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MCKENNA Lows é&
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO. 53:
‘What is the total dollar amount of all medical expenses incurred by YOU for
PLAINTIFP’s injuries that YOU claim resulted from PLAINTIFF’s exposure to asbestos?
INTERROGATORY NO, 54:
Please state the total dollar amounts YOU have paid to each healthcare provider for
injuries that YOU claim resulted from PLAINTIFF’s exposure to asbestos.
INTERROGATORY NO. $5:
Please state the total dollar amounts any insurance company on PLAINTIFF’s behalf has
paid to each healthcare provider for injuries that YOU claim resulted from PLAINTIFF's
exposure to asbestos.
INTERROGATORY NO. 56:
For each medical expense billed to YOU by any healthcare provider for injuries that you
clairn resulted from PLAINTIFF’s alleged exposure to asbestos, please state the amounts not paid
by any healthcare insurance company for which YOU believe YOU are personally obligated to
pay or have paid OUT-OF-POCKET.
As used in this interrogatory and throughout these interrogatories, “OUT-OF POCKET”
means payments made by YOU out of YOUR funds or resources that were not reimbursed by any
insurance company or other third-party.
INTERROGATORY NO. 57:
Please IDENTIFY all DOCUMENTS YOU that support YOUR claim for medical
damages.
IngerRocaTory No. 58:
Please set forth an itemization of any other expenses, damages or OUT-OF-POCKET
payments that YOU incurred as a result of PLAINTIFP’s alleged exposure to asbestos not set
forth in the preceding interrogatories.
INTERROGATORY NO. 59:
Please set forth the total amount of all funds YOU have received in settlement for
damages resulting from PLAINTIFF’s alleged exposure to asbestos.
~12-
METALOLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
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MCKENNA LONG &
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ATTORNEYS AT LAW
San FRANCHISE
INTERROGATORY NO. 60:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for NEGLIGENCE, state all facts and information upon which YOU base this contention.
As used in this Interrogatory and throughout these Interrogatories, “NEGLIGENCE”
refers to negligence as alleged in the Complaint inchiding, but not limited to, negligence,
wrongful death negligence, and survival negligence.
INTERROGATORY NO. 61:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for NEGLIGENCE, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY NO. 62:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for NEGLIGENCE, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NO. 63:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for STRICT LIABILITY, state all facts and information upon which YOU base this contention.
As used in this Interrogatory and throughout these Interrogatories, “STRICT LIABILITY”
refers to strict liability as alleged in the Complaint including, but not limited to, strict liability,
wrongful death strict liability, and survival strict liability.
INTERROGATORY NO. 64:
if YOU contend that METALCLAD INSULATION CORPORATION is Hable to YOU
for STRICT LIABILITY, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 65:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for STRICT LIABILITY, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
~13-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
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MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT Law
INTERROGATORY NO. 66:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for False Representation, state all facts and information upon which YOU base this contention.
INTERROGATORY No. 67:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for False Representation, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 68:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for False Representation, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
INTERROGATORY NO, 69:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Intentional Tort, state all facts and information upon which YOU base this contention.
InTeRROGATORY No. 70:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Intentional Tort, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGAT! QO. 74:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Intentional Tort, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NO, 72:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Loss of Consortium, state all facts and information upon which YOU base this contention.
~14-
SAN FRANCISCO
METALCLAG INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SEQTS7OUIG.LA Ww & wioN
28
MCKENNA LONG é
ALORIOGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO, 73:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Loss of Consortium, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
INTERROGATO! 0. 74:
1€ YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Loss of Consortium, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
INTERROGATORY No. 75:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Failure to War, state all facts and information upon which YOU base this contention.
INTERROGATORY No. 76:
If YOU contend that METALCLAD INSULATION CORPORATION is Hable to YOU
for Failure to Warn, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY NO. 77:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Failure to Warn, {DENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY No. 78:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Fraud, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 79:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Fraud, IDENTIFY by name, address and telephone number of each PERSON who has
knowledge of the facts or information upon which YOU base this contention.
-15-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SF2737916.1Oo OD WY KR WA B&B BW YN om
ee
A RW & &B Nm ©
V7
28
MCKENNA LONG &
ALDaipee LLP
ATTORNEYS AT LAW
BAN FRANCISCO
INTERROGATORY NO. 80:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Fraud, IDENTIFY all DOCUMENTS which support the facts or information upon which
YOU base this contention.
INTERROGATORY NO. 81:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Conspiracy, state all facts and information upon which YOU base this contention.
INTERROGATORY NO, 82:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Conspiracy, IDENTIFY by name, address and telephone number of each PERSON who has
knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 83:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Conspiracy, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NO. 84:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Enterprise Liability, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 85:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Enterprise Liability, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
INTERROGA’ N
if YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Enterprise Liability, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
-16-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SE:27379 116.328
McKENNA LONG &
ALORIDGE LLP
ATTORNEYS AT LAW
San FRANCISCO.
INTERROGATORY NO. 87:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Concert-of-Action, state all facts and information upon which YOU base this contention.
INTERROGATORY No. 88:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Concert-of-Action, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 89:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Concert-of-Action, IDENTIFY all DOCUMENTS which support the facts or information,
upon which YOU base this contention.
INTERROGATORY No. 90:
if YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Breach of Warranty, state all facts and information upon which YOU base this contention.
INTERROGATORY No. 91;
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Breach of Warranty, IDENTIFY by name, address and telephone number of each PERSON
who has knowledge of the facts or information upon which YOU base this contention.
InTERROGATORY No. 92:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Breach of Warranty, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
INTERROGATORY NO. 93:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Premises Owner/Contractor Liability, state all facts and information upon which YOU base
this contention.
-UT-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES,
SPI7379 16.1oe GO MN KD HW B&B WY WY
10
28
McKenna LONG &
AborioGe LLP
ATTORNEYS AT LAW
BAN FRANCISCO
INTERROGATORY NO. 94:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Premises Owner/Contractor Liability, IDENTIFY by name, address and telephone number
each PERSON who has knowledge of the facts or information supporting this contention.
INTERROGATORY NO. 95:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for Premises Owner/Contractor Liability, IDENTIFY all DOCUMENTS that support this
contention.
INTERROGATORY NO. 96:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for exemplary or punitive damages, state all facts and information upon which YOU base this
contention.
INTERROGATORY NO. 97;
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for exemplary or punitive damages, IDENTIFY by name, address and telephone number each
PERSON who has knowledge of the facts or information supporting this contention.
INTERROGATORY NO. 98:
If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU
for exemplary or punitive damages, IDENTIFY all DOCUMENTS that support this contention.
INTERROGATO! . 99:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
NEGLIGENCE, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 100:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
NEGLIGENCE, IDENTIFY by name, address and telephone number of each PERSON whe has
knowledge of the facts or information upon which YOU base this contention.
~18-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SF:27379116.1oO YW DA WH PB BW YM we
ph het
PN = ©
28
MCKENNA LONG é
ALORIDGE LEP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO. 101:
If YOU contend that NORTHERN CALIPORNIA INSULATION is liable to YOU for
NEGLIGENCE, IDENTIFY ali DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NO. 102:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
STRICT LIABILITY, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 103: .
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
STRICT LIABILITY, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY NO. 104:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
STRICT LIABILITY, IDENTIFY all DOCUMENTS which support the facts or information
upon which YOU base this contention.
INTERRO! y No. 105:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
False Representation, state all facts and information upon which YOU base this contention.
INTERROGATORY NO, 106:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
False Representation, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information wpon which YOU base this contention.
INTERROGATORY NO. 107:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
False Representation, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
~19-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SFQ7379 6.1ow Mwy DH HW B® WY
10
28
MCKENNA LONG &
ALDRIOGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO. 108:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Intentional Tort, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 109:
Jf YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Intentional Tort, IDENTIFY by name, address and telephone number of each PERSON who has
knowledge of the facts or information upoi which YOU base this contention.
INTERROGATORY NO. 110; .
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Intentional Tort, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY No, £11:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Loss of Consortium, state all facts and information upon which YOU base this contention.
INTERROGATOR 112:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Loss of Consortium, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 113:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Loss of Consortium, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY No, 114:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Failure to Warn, state all facts and information upon which YOU base this contention.
-20-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
SFQ737OL16.EOO SB a KR ww BR BH
28
MCKENNA LONG &
ALORIOGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO. 115:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Failure to Warn, IDENTIFY by name, address and telephone number of each PERSON who has
knowledge of the facts or information upon which YOU base this contention.
IntERROGATORY No. 116:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Failure to Warn, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
InrerRocaTorY No, 117:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Fraud, state all facts and information upon which YOU base this contention.
INTERROGATORY No, 118:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Fraud, IDENTIFY by name, address and telephone number of each PERSON who has knowledge
of the facts or information upon which YOU base this contention.
INTERROGATORY NO, 119:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Fraud, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU
base this contention.
INTERROGATORY No. 120:
t€ YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Conspiracy, state all facts and information upon which YOU base this contention.
INTERROGATORY NO, 121:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Conspiracy, IDENTIFY by name, address and telephone number of each PERSON who has
knowledge of the facts or information upon which YOU base this contention.
-21-
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES
SE:27379316.2Oo OM WM A WwW RB Ww Bm
pt etka tthe
© 6 OU A A BF OH = S
20 |
MCKENNA LONG &
ALDRIOGE LLP
ATTORNEYS AT LAW
InTERROGATORY No. 122:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Conspiracy, IDENTIPY all DOCUMENTS which support the facts or information upon which
YOU base this contention.
INTERROGATORY NO, 123:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Enterprise Liability, state all facts and information upon which YOU base this contention.
INTERROGATOR z
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Enterprise Liability, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATO) 25:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Enterprise Liability, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NO. 126:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Concert-of-Action, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 127:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Concert-of-Action, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No. 128:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Concert-of-Action, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
~22-
SAN FRANCISCO,
METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
SE23701164Co 6B WN DN Hw BR WH
Bb oS
13
28
MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN FRANCISCO
INTERROGATORY NO, 129:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Breach of Warranty, state all facts and information upon which YOU base this contention.
INTERROGATORY NO. 130:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Breach of Warranty, IDENTIFY by name, address and telephone number of each PERSON who
has knowledge of the facts or information upon which YOU base this contention.
INTERROGATORY No, 131:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Breach of Warranty, IDENTIFY all DOCUMENTS which support the facts or information upon
which YOU base this contention.
INTERROGATORY NQ, 132:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Premises Owner/Contractor Liability, state all facts and information upon which YOU base this
contention.
INTERROGATORY No. 133:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Premises Owner/Contractor Liability, IDENTIFY by name, address and telephone number each
PERSON who has knowledge of the facts or information supporting this contention.
INTERROGATORY No. 134:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
Premises Owner/Contractor Liability, IDENTIFY all DOCUMENTS that support this contention.
INTERROGATORY No. 135:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
exemplary or punitive damages, state all facts and information upon which YOU base this
contention.
3 ~
METALOLAD INSULATION CORPORATION'S SPECIALLY PREPAREO INTERROGATORIES
SP:27379116.)0 ON KD A Be BY HN
pet tek mt
nw RW NY & Oo
28
MCKENNA LONG &
ALDMDGE LLP
ATTORNEYS AT LAW
BAN FRANCISCO
INTERROGATORY NO. 136:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
exemplary or punitive damages, IDENTIFY by name, address and telephone number each
PERSON who has knowledge of the facts or information supporting this contention.
INTERROGATORY NO. 137:
If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for
exemplary or punitive damages, IDENTIFY all DOCUMENTS that support this contention.
MCKENNA LONG & ALDRIDGE LLP
by lhe o bb.
Dated:
“LISA L. OBERG
ALECIA E, COTTON
Attorneys for Defendant
METALCLAD INSULATION
CORPORATION
-24-
METALOLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
SF:27379 116.1Cwm WD A BF
28
MCKENNA LONG &
ALDRIDGE LLP
ATTORNEYS AT LAW
SAN Francisco:
DECLARATION OF ALECIA E, COTTON
In SUPPORT OF ADDITIONAL DISCOVERY
I, Alecia EB. Cotton, declare:
L | am an attomey 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 special interrogatories.
3. This set of interrogatories will cause the total number of specially prepared
interrogatories propounded to the party to whom they are directed to exceed the number of
specially prepared interrogatories permitted by section 2030,030 of the Code of Civil Procedure.
4, This set of interrogatories contains a total of 137 special interrogatories.
, 5. tam familiar with the issues and the previous discovery conducted by all of the
parties in the case.
6. L have personally examined each of the questions in this set of interrogatories.
7. This number of questions is warranted under section 2030.040 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 conduet an inquiry, investigation or search of files or records to supply the information sought.
8. None of the questions in this set of interrogatories is being propounded for any
improper purpose, such as to harass the party, of the attorney for the party, to whom it is directed,
or to cause unnecessary delay or needless increase in the cost of litigation.
I declare under penalty of perjury under the laws of the State of California hat the
fi
foregoing is true and correct and that this declaration was executed on this _/ = day of August,
Lh S (
ALECIA E. COTTON
2009, at San Francisco, California.
~25-
METALGLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES:
SF:Z7I79( 16.228
ACKENNA LONG &
ALDDGE LLP
ATTORNEYS AT LAW
BAM FRANCISCO
PROOF OF SERVICE ViA LEXISNEXIS Fite & SERVE
lam a citizen of the United States and employed in San Francisco County, California. 1
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, [ electronically served the document(s} via LexisNexis File & Serve
described as:
METALCLAD INSULATION CORPORATION’S REQUEST
FOR ADMISSIONS
on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve
website. 1 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.
~— Ce Wiel
METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS
SE:27379144.4Page 1 of 3
LexisNexis File & Serve Transaction Receipt
Transaction ID: 26658528
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 POT
Court: CA Superior Court County of San Francisco
Division /Courtroom: N/A
Case Class: Civil
Case Type: Personal Injury-Asbestos
Case Number: 278212
Case Name: Jueich vs Asbestos Defendants (Brayton)
Transaction Option: Serve Only + Public
Billing Reference: 28351.5781
Read Status for e-services Not Purchased
Documents List
4 Document(s)
Attached Document, 9 Pages Document ID: 23732384 PDE Format {| Original Format
Document Type: Access Statutory Fee: Linked:
Discovery ~ use for electronic service only Public $0.00
Document title:
FORM INTERROGATORIES
Attached Document, 26 Pages Document ID: 23732405 POE Format | Original Format
Document Type: Access: Statutory Fee: Linked:
Discovery - use fer electronic 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 $6.00
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 electranic service only Public $0.00
Document title:
METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS:
Expand All
E] Sending Parties (1)
Party Party Type Attorney Firm Attorney Type
Metatclad Insulation Corp Defendant Oberg, Lisa McKenna Long & Aldridge LLP-San Francisco Attorney in Charge
El Recipients (58)
El Service List (58)
Delivery “, Attorney
Option Party Party Type Attorney Firm Type Method
Yaron, George Attorney in E+
Service 84 Lumber Ca LP Defendant Yaron & Associates Charge Service
. Attorney In E+
Service Allis Chalmers Corp Oefendant Pike, Gregory D Knox Ricksen LLP Charge Service
Becherer, Becherer Kannett & Attorney in E+
Service CS K Auta Inc Defendant patrick J Schweitzer-Emeryville Charge Service
https://w3 fileandserve.lexisnexis.com/WebServer/W' ebPages/FileAndServe/preReviewSu... 8/18/2009Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Service
Serve
Service
Service
Service
Service
Service
Service
Service
Service
Chevron USA Inc Defendant
Chevron USA Inc Defendant
Chevron USA Inc Defendant
Chevron USA Inc Defendant
Fonsolidated Insulation Defendant
fonsolidated Insulation orendant
ponsolidated Insulation 5 -rendant
Designated Defense Courtesy
Counsel Recipient
Dillingham Construction 5 rondant
NA Inc
Douglass Insulation Co
Inc Defendant
Garlock Seating
Technologies Inc Defendant
Garlock Sealing Defendant
Technotogies Inc
General Electric Ca Defendant
Genuine Parts Colnc Defendant
Hamijton Matertais Inc Defendant
37 Thorpe & Son Inc Defendant
Juelch, Joyce Plaintift
Kaiser Gypsum Colne Defendant
Kaiser Gypsum Co inc Defendant
Kaiser Gypsum Co Inc Defendant
Kaiser Gypsum CoiInc Defendant
Minnesota Mining &
Manufacturing Co(3m) Defendant
Minnesota Mining &
Manufacturing Ca(amy Pefendant
Minnesota Mining & Defendant
Manufacturing Co(3M)
Oscar E Erickson Inc — Defendant
Oscar E Erickson Inc Defendant
Oscar E 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
Strotz, Peter
Goetz, Andy}
Hillyard, Mary
Prindie, Kenneth
Counsel,
Asbestos B&b
Becherer,
Patrick 3
Counsel,
Asbestos SB-SF
Glaspy, David
White, David W
Jobnson, Derek
Ss
Pond, Frank D
Counsel,
Asbestos WFEM
Fadeff, Jeffery J
Counsel,
Asbestos Bp
Fadeff, Jeffery J
Fong, Camille K
Granahan,
Conor D
Counsel,
Asbestos LBBS-
SF
Killelea,
Timothy K
Packer, Thomas
Moroney, Linda
M
Hamblett,
Robert M
Counsel,
Asbestos WFBM
Nelder, Robert
Counsel,
Asbestos ATT
Storm, Lucinda
L
Johnson, Derek
s
Filice Brown Eassa 8
McLeod LLP-Oakland
Filice Brown Eassa &
McLeod LLP-Oakland
Filice Brown Eassa &
McLeod LLP-Oakland
Filice Brown Eassa &
McLeod LLP-Oakland
Prindie 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 ULP-San
Francisco
Glaspy & Glaspy
Glaspy & Glaspy
Sedgwick Detert Moran &
Arnold LLP
Pond North LLP
Walsworth Franklin Bevins
& McCali-Orange
Bassi Ediin Huie & Blum
LLP-San Francisco
Brayton Purcell LLP-
Novato
Bassi Edlin Hula & Blum
LLP-San Francisco
Lewis Brisbois Bisgaard &
Smith LLP-San Francisco
Lewis Brisbois Bisgaard &
Smith LLP-San Francisco
Lewis Brisbois 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 Esq
Sedgwick Detert Moran &
Arnold LLP
Basst Edlin Huie & Blum
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124 13 14 is | 28 McKenna LONG & ALbRIOCE LLP ATTORNEYS AT Law LISA L. OBERG (BAR NO. 120139) DANIEL B. HOYE (BAR NO. 139683) ALECIA E. 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 ELECTRONICALLY FILED Superior Court of California, County of San Francisco MAR 03 2010 Clerk of the Court BY: ALISON AGBAY Deputy Clerk METALCLAD INSULATION CORPORATION SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH and NORMAN JUELCH, SR., Plaintiffs, v. ASBESTOS DEFENDANTS (BP), ef al., Defendants. Los ANCELES CASE No. CGC-09-275212 EXHIBIT H, PART LIN SUPPORT OF DECLARATION OF ALECIA E. COTTON IN SUPPORT OF DEFENDANT METALCLAD INSULATION CORPORATION’S MOTION FOR SUMMARY JUDGMENT OR, ALTERNATIVELY, SUMMARY ADJUDICATION OF ISSUES Date: March 18, 2010 TIME: 9:30 am. DEPT: 220 JubDGE: Hon. Harold E. Kahn TRIAL DaTE: April 5, 2010 SE2741d 9 330Exhibit H1 | LISA L, OBERG (BAR NO. 120139) D. PAUL BIRD IE (BAR NO. 202066) 2 | ALECIA BE. COTTON (BAR NO. 252777) MCKENNA LONG & ALDRIDGE LLP 3 | 101 California Street 41st Floor 4 | San Francisco, CA 94111 Telephone: (418) 267-4000 5 | Facsimile: {415) 267-4198 6 | Attorneys for Defendant METALCLAD INSULATION CORPORATION 7 & SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 | JOYCE JUELCH and NORMAN CASE NO. 275212 JUELCH, SR.. 12 METALCLAD INSULATION CORPORATION’S Plaintiffs, SPECIALLY PREPARED INTERROGATORIES 13 Vv. 14 ASBESTOS DEFENDANTS, et al. 15 Defendants. 16 17 PROPOUNDING PARTY: Defendant METALCLAD INSULATION CORPORATION 18 RESPONDING PARTY: Plaintiffs JOYCE JUEBLCH & NORMAN JUELCH, SR. 19 SET NUMBER: ONE 20 2 TO PLAINTIFF AND PLAINTIFE’S ATTORNEY OF RECORD HEREIN: 22 Defendant METALCLAD INSULATION CORPORATION hereby requests that the 23 plaintiff respond to the following interrogatories in accordance with California Code of Civil 24 Procedure sections 2030.210 et seq., in writing and under oath, within thirty (30) days. 25 INTERROGATORY No. 1: 26 Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING 27 PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION. 28 MCKENNA LONG & ALDRIDGE LLP Aone ara METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF:27379116.1Cf NW DN A B&B WN 28 MCKENNA LONG & AvpaioGE LLP ATTORNEYS AT LAW SAN FRANCISCO As used in this Interrogatory and throughout these Interrogatories, “YOU” and “YOUR” refers to plaintiff, 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. As used in this Interrogatory and throughout these Interrogatories, “PLAINTIFF” refers to the individual who was allegedly exposed to asbestos and is the subject of this lawsuit. As used in this Interrogatory and throughout these Interrogatories, “EXPOSURE” or “EXPOSED” includes YOUR use of such product, and YOUR presence in the proximity of such product being used by others. As used in this Interrogatory and throughout these Interrogatories, “ASBESTOS- CONTAINING PRODUCTS” includes asbestos fibers, in whatever form. As used in this Interrogatory and throughout these Interrogatories, “SUPPLIED” includes installation, delivery, distribution, sale, brokerage and any other link in the chain of distribution of a product. As used in this Interrogatory and throughout these Interrogatories METALCLAD INSULATION CORPORATION includes any employee or representative thereof. INTERROG: 0 2s IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION. As used in these Interrogatories, “IDENTIFY” when referring to a location means to describe by type of facility, street address, and/or physical description, including, but not limited to, the exact location or description of the exact location within the facility; “IDENTIFY” when referring to a person means to provide the name, job title, last known address, phone number, and relationship to plaintiff; “IDENTIFY” when referring to a document means to describe by physical description, contents, title, page number, bates number, caption, date, and/or other sach description sufficient to identify such document in a request for production of document. -2- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SF:27379316.1Oo MW BR OR RR BD De RR N RR DO meme eet S RRR BBE BB SEAR BDR SESE S 28 MCKENNA LONG & ALDRIDGE LLP ASTORNEYS AT Law SAN FRANCISCO As used in these Interrogatories, “JOBSITE” refers to any physical location, including, but not limited to the exact address, physical description, and precise area within identified physical location where YOU performed work or was physically present. INTERROGATORY NO. 3: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, describe each ASBESTOS-CONTAINING PRODUCT that YOU contend METALCLAD INSULATION CORPORATION SUPPLIED. INTERROGATORY No. 4: For each ASBESTOS-CONTAINING PRODUCT that YOU contend METALCLAD INSULATION CORPORATION SUPPLIED, state the exact dates of PLAINTIFF’s EXPOSURE to each product at each JOB SITE. INTERROGATORY No. 5: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, IDENTIFY all PERSONS who have testified under oath that METALCLAD INSULATION CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that JOB SITE. As used in this Interrogatory and throughout these Interrogatories, 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. INTERROGATORY NO. 6: For each PERSON who has testified under oath that METALCLAD INSULATION CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB SITE(S), IDENTIPY the transcript, by case name, case number, date, court reporting service and page/line number where such testimony was given. INTERROGATORY NO. 7: For each PERSON who has testified under oath that METALCLAD INSULATION CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB -3- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF-27379116.1oC OM WY DH FF WwW NY 28 McKenna LONG & Acomoce LLP ATTORNEYS AT LAW SAN FRANCISCO, SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that PERSON’S testimony relates. InteRrocaTory No. 8: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, IDENTIFY all PERSONS who have personally informed YOU that METALCLAD INSULATION CORPORATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that JOB SITE. INTERROGATORY NO, 9: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, state all facts supporting YOUR contention. INTERROGATORY NO. 10: For each fact YOU IDENTIFIED as supporting YOUR contention that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, specify the evidence that YOU contend supports each fact. INTERROGATORY NO. 11: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention. As used in these Interrogatories, “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. INTERROGATORY NO, 12: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by METALCLAD INSULATION CORPORATION, de METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF27379116.428 MCKENNA LONG & ALGRIDGE LLP ATTORNEYS AT LAW SAN FRANCISCO IDENTIFY each DOCUMENT, of which YOU have actual knowledge, that supports YOUR contention. InTERROGATORY NO. 13: Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION. As used in these Interrogatories, “DISTURBED” includes installing, removing, repairing, cutting, abrading, manipulating, or otherwise coming into contact with. INTERROGA TORY NO. 14: IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION. INTERROGATORY No. 15: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, describe the specific ASBESTOS-CONTAINING PRODUCT that YOU contend was DISTURBED. INTERROGATORY NO. 16: State the exact dates of the EXPOSURE at each JOB SITE for each ASBESTOS- CONTAINING PRODUCT that YOU contend METALCLAD INSULATION CORPORATION DISTURBED. InterroGatory No, 17: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, IDENTIFY all PERSONS who have testified under oath that METALCLAD INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at that JOB SITE. -5- METALOLAD INSULATION CORPORATION'S SPEGIALLY PREPARED INTERROGATORIES SFITTPOLGLA ws WwW we 28 MCKENNA LONG & Aborioce LLP ATTORNEYS AT LAW BAN FRANCISCO INTERROGATORY NO. J8: For each PERSON who has testified under oath that METALCLAD INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB SITES, IDENTIFY the transcript by case name, case number, date, court reporting service and page/line number where such testimony was given. INTERROGATORY No. 19: For each PERSON who has testified under oath that METALCLAD INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB SITES, list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that PERSON’S testimony relates. INTERROGATORY NO. 20: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, IDENTIFY all PERSONS who have personally informed YOU that METALCLAD INSULATION CORPORATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at that JOB SITE. INTERROGATORY No, 21; For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, state all facts supporting YOUR contention. INTERROGATORY NO. 22: For each fact supporting YOUR contention that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, specify the evidence that YOU contend supports each fact. Jnrerrocatory No. 23: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention. -6- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF27379 16.)an yw MB WH 28 MCKENNA LONG & Aborioge LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO, 24: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by METALCLAD INSULATION CORPORATION, IDENTIFY each DOCUMENT of which YOU have actual knowledge that supports YOUR contention. INTERROGATORY NO. 25: Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION. As used in this Interrogatory and throughout these Interrogatories NORTHERN CALIFORNIA INSULATION includes any employee or representative thereof, INTERROGATORY NO. 26: IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA. INSULATION. INTERROGATORY No, 27: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, describe each ASBESTOS-CONTAINING PRODUCT that YOU contend NORTHERN CALIFORNIA INSULATION SUPPLIED. InTERROGATORY No. 28: For each ASBESTOS-CONTAINING PRODUCT that YOU contend NORTHERN CALIFORNIA INSULATION SUPPLIED, state the exact dates of PLAINTIFF’s EXPOSURE to each product at each JOB SITE. INTERROGATORY NO, 29: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, IDENTIFY all PERSONS who have testified under oath that NORTHERN Je METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SP:27379116.10 68 WM DR eR B&B Ww Ym eet wm & BW NW = OD 28 MCKENNA LONG & ALORIDGE LLP ATTORNEYS AT LAW SAN PRancisco, CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that JOB SITE. INTERROGATORY NO. 30: For each PERSON who has testified under oath that NORTHERN CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB SITE(S), IDENTIFY the transcript, by case name, case number, date, court reporting service and page/line number where such testimony was given. INTERROGATORY NO, 31: For each PERSON who has testified under oath that NORTHERN CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to PLAINTIFF’s JOB SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that PERSON’S testimony relates. INTERROGATORY NO, 32: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, IDENTIFY all PERSONS who have personally informed YOU that NORTHERN CALIFORNIA INSULATION SUPPLIED ASBESTOS-CONTAINING PRODUCTS to that JOB SITE. InTERROGATORY No, 33: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, state all facts supporting YOUR contention. INTERROGATOR: . 34: For each fact YOU IDENTIFIED as supporting YOUR contention that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, specify the evidence that YOU contend supports each fact. ~8- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SRQTS7SHGAOo wm 2 DA WH BR WB Ym fet kek BR W Ne Oo 28 McKenna LONG & ALDRIDGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO. 35: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention. INTERROGATORY NO, 36: For each JOB SITE at which YOU contend PLAINTIFF was EXPOSED to ASBESTOS- CONTAINING PRODUCTS SUPPLIED by NORTHERN CALIFORNIA INSULATION, IDENTIFY each DOCUMENT, of which YOU have actual knowledge, that supports YOUR contention. INTERROGATORY NO, 37: Do YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION. As used in these Interrogatories, “DISTURBED” includes installing, removing, repairing, cutting, abrading, manipulating, or otherwise coming into contact with. INTERROGATO! 38: IDENTIFY each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION. INTERROGATORY No. 39: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, describe the specific ASBESTOS-CONTAINING PRODUCT that YOU contend was DISTURBED. INTERROGATORY NO, 40: State the exact dates of the EXPOSURE at each JOB SITE for each ASBESTOS- CONTAINING PRODUCT that YOU contend NORTHERN CALIFORNIA INSULATION DISTURBED, 9 METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SEQTSTONGAoD eM DR Ww RF WY BOS s = 6 MCKENNA LONG é& ALORIOGE LLP ATTORNEYS AT LAW SAN FRANCISCO. InTerRocaTory No. 41: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA, INSULATION, IDENTIFY all PERSONS who have testified under oath thal NORTHERN CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at that JOB SITE. INTERROGATORY No. 42: For each PERSON who has testified under oath that NORTHERN CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB SITES, IDENTIFY the transcript by case name, case number, date, court reporting service and page/line number where such testimony was given. INTERROGATORY NO. 43: For each PERSON who has testified under oath that NORTHERN CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at PLAINTIFF’s JOB SITE(S), list the exact dates and JOB SITES of PLAINTIFF’s alleged exposure to which that PERSON’S testimony relates. INTERROGATORY No, 44: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, IDENTIFY all PERSONS who have personally informed YOU that NORTHERN CALIFORNIA INSULATION DISTURBED ASBESTOS-CONTAINING PRODUCTS at that JOB SITE. INTERROGATORY No, 45: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, state all facts supporting YOUR contention. -~16- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SEIU37OH16.1Oo OO SD Hw SB BW 28 MCKENNA LONG & ALDRIDGE LLP ATTORNEYS AT LAW SAN PRancisco, INTERROGATORY NO. 46: For each fact supporting YOUR contention that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, specify the evidence that YOU contend supports each fact. INTERROGATORY No. 47: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, IDENTIFY each DOCUMENT YOU possess that supports YOUR contention. INTERROGATORY No. 48: For each JOB SITE at which YOU contend that PLAINTIFF was EXPOSED to ASBESTOS-CONTAINING PRODUCTS DISTURBED by NORTHERN CALIFORNIA INSULATION, IDENTIFY each DOCUMENT of which YOU have actual knowledge that supports YOUR contention. Interrocarory No. 49: If PLAINTIFF worked with any ASBESTOS product manufactured, produced, prepared, distributed or sold by any entity not named as a defendant in this lawsuit, identify the product and each such entity. INTERROGATORY NO, 50: If PLAINTIFF worked with any ASBESTOS product manufactured, produced, prepared, distributed or sold by any bankrupt party, whether or not such defendant was served with the ; Complaint, IDENTIFY each such party. INTERROGA TORY No. 51: Please state whether YOU have completed a Proof of Claim Form for each bankrupt party that YOU contend manufactured, produced, prepared, distributed or sold ASBESTOS-containing products with or around which PLAINTIFF worked. INTERROGATORY No, 52: List all medical healthcare providers that treated PLAINTIFF for injuries that YOU claim resulted from PLAINTIFF’s exposure to asbestos. -li- METALCLAG INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SF:273791 16.1be 28 MCKENNA Lows é& ALDRIDGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO. 53: ‘What is the total dollar amount of all medical expenses incurred by YOU for PLAINTIFP’s injuries that YOU claim resulted from PLAINTIFF’s exposure to asbestos? INTERROGATORY NO, 54: Please state the total dollar amounts YOU have paid to each healthcare provider for injuries that YOU claim resulted from PLAINTIFF’s exposure to asbestos. INTERROGATORY NO. $5: Please state the total dollar amounts any insurance company on PLAINTIFF’s behalf has paid to each healthcare provider for injuries that YOU claim resulted from PLAINTIFF's exposure to asbestos. INTERROGATORY NO. 56: For each medical expense billed to YOU by any healthcare provider for injuries that you clairn resulted from PLAINTIFF’s alleged exposure to asbestos, please state the amounts not paid by any healthcare insurance company for which YOU believe YOU are personally obligated to pay or have paid OUT-OF-POCKET. As used in this interrogatory and throughout these interrogatories, “OUT-OF POCKET” means payments made by YOU out of YOUR funds or resources that were not reimbursed by any insurance company or other third-party. INTERROGATORY NO. 57: Please IDENTIFY all DOCUMENTS YOU that support YOUR claim for medical damages. IngerRocaTory No. 58: Please set forth an itemization of any other expenses, damages or OUT-OF-POCKET payments that YOU incurred as a result of PLAINTIFP’s alleged exposure to asbestos not set forth in the preceding interrogatories. INTERROGATORY NO. 59: Please set forth the total amount of all funds YOU have received in settlement for damages resulting from PLAINTIFF’s alleged exposure to asbestos. ~12- METALOLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SEQISTOLIOLtne 2 tO ND HW RB BW 10 28 MCKENNA LONG & ALDRIDGE LLE ATTORNEYS AT LAW San FRANCHISE INTERROGATORY NO. 60: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for NEGLIGENCE, state all facts and information upon which YOU base this contention. As used in this Interrogatory and throughout these Interrogatories, “NEGLIGENCE” refers to negligence as alleged in the Complaint inchiding, but not limited to, negligence, wrongful death negligence, and survival negligence. INTERROGATORY NO. 61: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for NEGLIGENCE, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY NO. 62: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for NEGLIGENCE, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 63: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for STRICT LIABILITY, state all facts and information upon which YOU base this contention. As used in this Interrogatory and throughout these Interrogatories, “STRICT LIABILITY” refers to strict liability as alleged in the Complaint including, but not limited to, strict liability, wrongful death strict liability, and survival strict liability. INTERROGATORY NO. 64: if YOU contend that METALCLAD INSULATION CORPORATION is Hable to YOU for STRICT LIABILITY, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 65: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for STRICT LIABILITY, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. ~13- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF27379 116.4he 28 MCKENNA LONG & ALDRIDGE LLP ATTORNEYS AT Law INTERROGATORY NO. 66: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for False Representation, state all facts and information upon which YOU base this contention. INTERROGATORY No. 67: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for False Representation, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 68: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for False Representation, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO, 69: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Intentional Tort, state all facts and information upon which YOU base this contention. InTeRROGATORY No. 70: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Intentional Tort, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGAT! QO. 74: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Intentional Tort, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO, 72: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Loss of Consortium, state all facts and information upon which YOU base this contention. ~14- SAN FRANCISCO METALCLAG INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SEQTS7OUIG.LA Ww & wioN 28 MCKENNA LONG é ALORIOGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO, 73: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Loss of Consortium, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATO! 0. 74: 1€ YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Loss of Consortium, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY No. 75: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Failure to War, state all facts and information upon which YOU base this contention. INTERROGATORY No. 76: If YOU contend that METALCLAD INSULATION CORPORATION is Hable to YOU for Failure to Warn, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY NO. 77: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Failure to Warn, {DENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY No. 78: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Fraud, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 79: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Fraud, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. -15- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF2737916.1Oo OD WY KR WA B&B BW YN om ee A RW & &B Nm © V7 28 MCKENNA LONG & ALDaipee LLP ATTORNEYS AT LAW BAN FRANCISCO INTERROGATORY NO. 80: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Fraud, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 81: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Conspiracy, state all facts and information upon which YOU base this contention. INTERROGATORY NO, 82: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Conspiracy, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 83: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Conspiracy, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 84: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Enterprise Liability, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 85: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Enterprise Liability, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGA’ N if YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Enterprise Liability, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. -16- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SE:27379 116.328 McKENNA LONG & ALORIDGE LLP ATTORNEYS AT LAW San FRANCISCO. INTERROGATORY NO. 87: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Concert-of-Action, state all facts and information upon which YOU base this contention. INTERROGATORY No. 88: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Concert-of-Action, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 89: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Concert-of-Action, IDENTIFY all DOCUMENTS which support the facts or information, upon which YOU base this contention. INTERROGATORY No. 90: if YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Breach of Warranty, state all facts and information upon which YOU base this contention. INTERROGATORY No. 91; If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Breach of Warranty, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. InTERROGATORY No. 92: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Breach of Warranty, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 93: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Premises Owner/Contractor Liability, state all facts and information upon which YOU base this contention. -UT- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES, SPI7379 16.1oe GO MN KD HW B&B WY WY 10 28 McKenna LONG & AborioGe LLP ATTORNEYS AT LAW BAN FRANCISCO INTERROGATORY NO. 94: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Premises Owner/Contractor Liability, IDENTIFY by name, address and telephone number each PERSON who has knowledge of the facts or information supporting this contention. INTERROGATORY NO. 95: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for Premises Owner/Contractor Liability, IDENTIFY all DOCUMENTS that support this contention. INTERROGATORY NO. 96: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for exemplary or punitive damages, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 97; If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for exemplary or punitive damages, IDENTIFY by name, address and telephone number each PERSON who has knowledge of the facts or information supporting this contention. INTERROGATORY NO. 98: If YOU contend that METALCLAD INSULATION CORPORATION is liable to YOU for exemplary or punitive damages, IDENTIFY all DOCUMENTS that support this contention. INTERROGATO! . 99: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for NEGLIGENCE, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 100: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for NEGLIGENCE, IDENTIFY by name, address and telephone number of each PERSON whe has knowledge of the facts or information upon which YOU base this contention. ~18- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SF:27379116.1oO YW DA WH PB BW YM we ph het PN = © 28 MCKENNA LONG é ALORIDGE LEP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO. 101: If YOU contend that NORTHERN CALIPORNIA INSULATION is liable to YOU for NEGLIGENCE, IDENTIFY ali DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 102: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for STRICT LIABILITY, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 103: . If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for STRICT LIABILITY, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY NO. 104: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for STRICT LIABILITY, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERRO! y No. 105: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for False Representation, state all facts and information upon which YOU base this contention. INTERROGATORY NO, 106: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for False Representation, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information wpon which YOU base this contention. INTERROGATORY NO. 107: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for False Representation, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. ~19- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SFQ7379 6.1ow Mwy DH HW B® WY 10 28 MCKENNA LONG & ALDRIOGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO. 108: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Intentional Tort, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 109: Jf YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Intentional Tort, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upoi which YOU base this contention. INTERROGATORY NO. 110; . If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Intentional Tort, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY No, £11: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Loss of Consortium, state all facts and information upon which YOU base this contention. INTERROGATOR 112: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Loss of Consortium, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 113: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Loss of Consortium, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY No, 114: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Failure to Warn, state all facts and information upon which YOU base this contention. -20- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SFQ737OL16.EOO SB a KR ww BR BH 28 MCKENNA LONG & ALORIOGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO. 115: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Failure to Warn, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. IntERROGATORY No. 116: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Failure to Warn, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. InrerRocaTorY No, 117: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Fraud, state all facts and information upon which YOU base this contention. INTERROGATORY No, 118: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Fraud, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY NO, 119: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Fraud, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY No. 120: t€ YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Conspiracy, state all facts and information upon which YOU base this contention. INTERROGATORY NO, 121: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Conspiracy, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. -21- METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES SE:27379316.2Oo OM WM A WwW RB Ww Bm pt etka tthe © 6 OU A A BF OH = S 20 | MCKENNA LONG & ALDRIOGE LLP ATTORNEYS AT LAW InTERROGATORY No. 122: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Conspiracy, IDENTIPY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO, 123: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Enterprise Liability, state all facts and information upon which YOU base this contention. INTERROGATOR z If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Enterprise Liability, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATO) 25: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Enterprise Liability, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NO. 126: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Concert-of-Action, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 127: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Concert-of-Action, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No. 128: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Concert-of-Action, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. ~22- SAN FRANCISCO, METALCLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SE23701164Co 6B WN DN Hw BR WH Bb oS 13 28 MCKENNA LONG & ALDRIDGE LLP ATTORNEYS AT LAW SAN FRANCISCO INTERROGATORY NO, 129: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Breach of Warranty, state all facts and information upon which YOU base this contention. INTERROGATORY NO. 130: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Breach of Warranty, IDENTIFY by name, address and telephone number of each PERSON who has knowledge of the facts or information upon which YOU base this contention. INTERROGATORY No, 131: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Breach of Warranty, IDENTIFY all DOCUMENTS which support the facts or information upon which YOU base this contention. INTERROGATORY NQ, 132: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Premises Owner/Contractor Liability, state all facts and information upon which YOU base this contention. INTERROGATORY No. 133: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Premises Owner/Contractor Liability, IDENTIFY by name, address and telephone number each PERSON who has knowledge of the facts or information supporting this contention. INTERROGATORY No. 134: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for Premises Owner/Contractor Liability, IDENTIFY all DOCUMENTS that support this contention. INTERROGATORY No. 135: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for exemplary or punitive damages, state all facts and information upon which YOU base this contention. 3 ~ METALOLAD INSULATION CORPORATION'S SPECIALLY PREPAREO INTERROGATORIES SP:27379116.)0 ON KD A Be BY HN pet tek mt nw RW NY & Oo 28 MCKENNA LONG & ALDMDGE LLP ATTORNEYS AT LAW BAN FRANCISCO INTERROGATORY NO. 136: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for exemplary or punitive damages, IDENTIFY by name, address and telephone number each PERSON who has knowledge of the facts or information supporting this contention. INTERROGATORY NO. 137: If YOU contend that NORTHERN CALIFORNIA INSULATION is liable to YOU for exemplary or punitive damages, IDENTIFY all DOCUMENTS that support this contention. MCKENNA LONG & ALDRIDGE LLP by lhe o bb. Dated: “LISA L. OBERG ALECIA E, COTTON Attorneys for Defendant METALCLAD INSULATION CORPORATION -24- METALOLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SF:27379 116.1Cwm WD A BF 28 MCKENNA LONG & ALDRIDGE LLP ATTORNEYS AT LAW SAN Francisco: DECLARATION OF ALECIA E, COTTON In SUPPORT OF ADDITIONAL DISCOVERY I, Alecia EB. Cotton, declare: L | am an attomey 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 special interrogatories. 3. This set of interrogatories will cause the total number of specially prepared interrogatories propounded to the party to whom they are directed to exceed the number of specially prepared interrogatories permitted by section 2030,030 of the Code of Civil Procedure. 4, This set of interrogatories contains a total of 137 special interrogatories. , 5. tam familiar with the issues and the previous discovery conducted by all of the parties in the case. 6. L have personally examined each of the questions in this set of interrogatories. 7. This number of questions is warranted under section 2030.040 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 conduet an inquiry, investigation or search of files or records to supply the information sought. 8. None of the questions in this set of interrogatories is being propounded for any improper purpose, such as to harass the party, of the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation. I declare under penalty of perjury under the laws of the State of California hat the fi foregoing is true and correct and that this declaration was executed on this _/ = day of August, Lh S ( ALECIA E. COTTON 2009, at San Francisco, California. ~25- METALGLAD INSULATION CORPORATION'S SPECIALLY PREPARED INTERROGATORIES: SF:Z7I79( 16.228 ACKENNA LONG & ALDDGE LLP ATTORNEYS AT LAW BAM FRANCISCO PROOF OF SERVICE ViA LEXISNEXIS Fite & SERVE lam a citizen of the United States and employed in San Francisco County, California. 1 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, [ electronically served the document(s} via LexisNexis File & Serve described as: METALCLAD INSULATION CORPORATION’S REQUEST FOR ADMISSIONS on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website. 1 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. ~— Ce Wiel METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS SE:27379144.4Page 1 of 3 LexisNexis File & Serve Transaction Receipt Transaction ID: 26658528 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 POT Court: CA Superior Court County of San Francisco Division /Courtroom: N/A Case Class: Civil Case Type: Personal Injury-Asbestos Case Number: 278212 Case Name: Jueich vs Asbestos Defendants (Brayton) Transaction Option: Serve Only + Public Billing Reference: 28351.5781 Read Status for e-services Not Purchased Documents List 4 Document(s) Attached Document, 9 Pages Document ID: 23732384 PDE Format {| Original Format Document Type: Access Statutory Fee: Linked: Discovery ~ use for electronic service only Public $0.00 Document title: FORM INTERROGATORIES Attached Document, 26 Pages Document ID: 23732405 POE Format | Original Format Document Type: Access: Statutory Fee: Linked: Discovery - use fer electronic 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 $6.00 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 electranic service only Public $0.00 Document title: METALCLAD INSULATION CORPORATION'S REQUEST FOR ADMISSIONS: Expand All E] Sending Parties (1) Party Party Type Attorney Firm Attorney Type Metatclad Insulation Corp Defendant Oberg, Lisa McKenna Long & Aldridge LLP-San Francisco Attorney in Charge El Recipients (58) El Service List (58) Delivery “, Attorney Option Party Party Type Attorney Firm Type Method Yaron, George Attorney in E+ Service 84 Lumber Ca LP Defendant Yaron & Associates Charge Service . Attorney In E+ Service Allis Chalmers Corp Oefendant Pike, Gregory D Knox Ricksen LLP Charge Service Becherer, Becherer Kannett & Attorney in E+ Service CS K Auta Inc Defendant patrick J Schweitzer-Emeryville Charge Service https://w3 fileandserve.lexisnexis.com/WebServer/W' ebPages/FileAndServe/preReviewSu... 8/18/2009Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Service Serve Service Service Service Service Service Service Service Service Chevron USA Inc Defendant Chevron USA Inc Defendant Chevron USA Inc Defendant Chevron USA Inc Defendant Fonsolidated Insulation Defendant fonsolidated Insulation orendant ponsolidated Insulation 5 -rendant Designated Defense Courtesy Counsel Recipient Dillingham Construction 5 rondant NA Inc Douglass Insulation Co Inc Defendant Garlock Seating Technologies Inc Defendant Garlock Sealing Defendant Technotogies Inc General Electric Ca Defendant Genuine Parts Colnc Defendant Hamijton Matertais Inc Defendant 37 Thorpe & Son Inc Defendant Juelch, Joyce Plaintift Kaiser Gypsum Colne Defendant Kaiser Gypsum Co inc Defendant Kaiser Gypsum Co Inc Defendant Kaiser Gypsum CoiInc Defendant Minnesota Mining & Manufacturing Co(3m) Defendant Minnesota Mining & Manufacturing Ca(amy Pefendant Minnesota Mining & Defendant Manufacturing Co(3M) Oscar E Erickson Inc — Defendant Oscar E Erickson Inc Defendant Oscar E 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 Strotz, Peter Goetz, Andy} Hillyard, Mary Prindie, Kenneth Counsel, Asbestos B&b Becherer, Patrick 3 Counsel, Asbestos SB-SF Glaspy, David White, David W Jobnson, Derek Ss Pond, Frank D Counsel, Asbestos WFEM Fadeff, Jeffery J Counsel, Asbestos Bp Fadeff, Jeffery J Fong, Camille K Granahan, Conor D Counsel, Asbestos LBBS- SF Killelea, Timothy K Packer, Thomas Moroney, Linda M Hamblett, Robert M Counsel, Asbestos WFBM Nelder, Robert Counsel, Asbestos ATT Storm, Lucinda L Johnson, Derek s Filice Brown Eassa 8 McLeod LLP-Oakland Filice Brown Eassa & McLeod LLP-Oakland Filice Brown Eassa & McLeod LLP-Oakland Filice Brown Eassa & McLeod LLP-Oakland Prindie 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 ULP-San Francisco Glaspy & Glaspy Glaspy & Glaspy Sedgwick Detert Moran & Arnold LLP Pond North LLP Walsworth Franklin Bevins & McCali-Orange Bassi Ediin Huie & Blum LLP-San Francisco Brayton Purcell LLP- Novato Bassi Edlin Hula & Blum LLP-San Francisco Lewis Brisbois Bisgaard & Smith LLP-San Francisco Lewis Brisbois Bisgaard & Smith LLP-San Francisco Lewis Brisbois 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 Esq Sedgwick Detert Moran & Arnold LLP Basst Edlin Huie & Blum Page 2 of 3 Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney In Charge Attorney in Charge Attorney tn Charge Attorney in Charge Attorney In Charge Atterney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney In Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge Attorney in Charge A