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

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McKenna LONG &

ALDRIDGE LL
ATTORNEYS ATL
Los ANcELEs

P
aw

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

4ist 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,
y.
ASBESTOS DEFENDANTS (BP), ef ai.

Defendants.

CASE NO. CGC-09-275212

EXHIBIT G IN 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 a.m.

DEPT: 220

JUDGE: Hon. Harold E. Kahn

TRIAL DATE: April 5, 2010

SE:27414119.1
38/10Exhibit GSuperior Court of California, County of San Francisco

LISTEN

Defendants’ Standard Set 2 (Personal Injury)

Plaintiff(s}, NO.

vs.

Defendant(s). DEFENDANTS’ STANDARD
INTERROGATORIES
TO PLAINTIFF (Personal Injury),

f Set2

PROPOUNDING PARTY: Defendants.

RESPONDING PARTY:

SET NUMBER: Two

INTRODUCTION
Pursuant to San Francisco Superior Court General Order No. 129, each plaintiff in the
abovecaptioned asbestos litigation is required to respond to the following standard
interrogatories, Set 2, separately and fully in writing, under oath, pursuant to Code of Civil
Procedure Section 2030 no less than 30 days before commencement of the deposition of the
plaintiff or in the event of notice of the plaintiff's deposition by the plaintiff's attorney,
contemporaneous with plaintiff's service of the notice of deposition. In responding to these
standard interrogatories, Set 2, YOU are required to furnish all information that is available
to YOU, except that where specified YOU are also required to include information available to
YOUR attorney(s). If YOU cannot answer a standard Interrogatory, Set 2, completely, answer
it to the fullest extent possible and specify the reason(s) for YOUR Inability to respond fully.
If any defendant questions the sufficiency of the responses to these standard interragatcries,
Set 2, such defendant may move to compel appropriate responses under the applicable
provisions of the Code of Civil Procedure, after complying with California Rules of Court and
Local Rules of Court.
DEFINITIONS

4. "AREA" means the name of the specific structure, building, building number, floor of the
building, ship compartment, process line, unit, plece of equipment or other specific place
within the WORKSITE.

2. "“ASBESTOSCONTAINING MATERIAL" means a materia! or product which consists of or
contains the mineral asbestos.

3. "CONTROL" means the act(s) of directing the manner and/or methods of conducting the work
at the WORKSITE.

4, "DESCRIBE" as it relates to material means provide a complete description of the material
including but not limited to: the material name, manufacturer, supolier, distributer, color,
texture, consistency, shape, size and any markings; a description of the material's containerincluding size, color and ail writing on that container; and a description of how the material
was used,

5. "DOCUMENTS" means any writing as defined in Evidence Code Section 250 and includes the
original or a copy of handwriting, typewriting, printing, photostating, photographing,
computer printout, and every other means of recording upon any tangible thing or form of
communication or representation including letters, words, pictures, sounds or symbols or
combinations of them.

6. "IDENTIFY" as it relates to a DOCUMENT means provide the title of the DOCUMENT, the date
the DOCUMENT was generated, the name of the author of the DOCUMENT, a description of
the DOCUMENT (e.g., letter, memorandum, report, book, photograph, etc.) And any other
information which would be required to specify the DOCUMENT In a request for production of
DOCUMENTS issued pursuant to Code of Civil Procedure Section 2031.

7. "IDENTIFY" as it relates to an employer means to state the employer's name, address and
telephone number.

8. “IDENTIFY" as it relates to a person means to provide the name, place of employment,
address and telephone number for each person.

9. "IDENTIFY" as it relates to a ship means to state the name of the ship, the owner of the ship,
the operator of the ship, the type of ship and the hull number of the ship.

LO. LOCATION" means the city, state, country, street address, intersection or shipyard. For work
aboard ship, please IDENTIFY the ship and where it was located during the time YOU worked
on board.

Li. "OCCASION" refers to a day, any part of a day, or a series of day(s), week(s), month(s) or
year(s) during which YOU worked continuously at a WORKSITE.

12. "RAW ASBESTOS" means asbestos fiber mined or milled, either packaged or in bulk, not
compounded with other substances and essentially pure with the exception of naturally
occurring trace amounts of other substances.

13, "RESPONSIBLE PARTY” means any person, business organization or enterprise, including but
not limited to the defendants in this action.

(4, "SAFETY PRECAUTION" means respirators, masks, fans, air blowers, tarps, wetdown
procedures, isolation and any other equipment and/or methods used to limit or prevent
exposure to dust.

L5. "WORKSITE" means any LOCATION where YOU worked at any time.

16. "YOU" and "YOUR" refer to the person whose claimed exposure to asbestos is the basis of
this action..

INTERROGATORIES

1. For each of YOUR WORKSITES, please state:

A. The name of the WORKSITE;

B. The LOCATION of the WORKSITE;

C. As precisely as possible, the time period you worked at the WORKSITE, including the total
number of days you worked at the WORKSITE;

D. The name and address of each of YOUR employers;

E. YOUR job title(s);

F. Each kind of work YOU performed at the WORKSITE;

G. Whether there was one or more OCCASIONS when YOU worked with or around RAWlo.

ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) at the WORKSITE. For subsequent
OCCASIONS at a given WORKSITE, information which Is unchanged need not be repeated. If
"yes", for each OCCASION, please state:

The specific AREA within the WORKSITE where YOU worked with or around RAW ASBESTOS
or ASBESTOSCONTAINING MATERIAL(S);

. As precisely as possible, the time period of each such OCCASION, including the total number

of days of each such OCCASION;

IDENTIFY all person(s) who directed YOUR daytoday work activity and that person(s)’
employer;

IDENTIFY all persons who were YOUR coworkers on this OCCASION;

IDENTIFY all persons who have information regarding YOUR work with or around RAW
ASBESTOS or ASBESTCSCONTAINING MATERIAL(S) on this OCCASION;

List each contractor YOU and/or YOUR attorney allege installed and/or removed RAW
ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) during YOUR work at that site;

List each contractor YOU and/or YOUR attorney allege installed and/or removed RAW
ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) prior to YOUR work at that site;
IDENTIFY all documents in YOUR possession or under YOUR control relating to YOUR work on
this OCCASION, including but not limited to travel logs, diaries, work logs, calendars, time
sheets, photographs, drawings and union logs or summaries.

IDENTIFY all other DOCUMENTS of which YOU or YOUR attorneys are aware relating to YOUR
work on this OCCASION, including but not limited to time sheets, invoices, purchase orders,
contracts, specifications, photographs, drawings, job logs, work requests and union dispatch
slips.

Whether YOU installed, removed, disturbed or handled RAW ASBESTOS or
ASBESTOSCONTAINING MATERIAL(S) during the OCCASION. if "yes":

DESCRIBE each RAW ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) YOU installed,
removed, disturbed or handled during the OCCASION;

DESCRIBE specifically the work YOU performed regarding each RAW ASBESTOS or
ASBESTOSCONTAINING MATERIAL including whether the work was performed Indoors or
outdoors;

State whether YOUR employer took any SAFETY PRECAUTIONS to protect YOU from
breathing dust. If "yes", describe each SAFETY PRECAUTION taken;

. State whether YOUR union or employee association took any SAFETY PRECAUTIONS to

protect YOU from breathing dust. If "yes", describe each SAFETY PRECAUTION taken; and
State whether YOU took any SAFETY PRECAUTIONS to protect YOU from breathing dust. If
"yes", describe each SAFETY PRECAUTION taken,

. Whether YOU allege any exposure to asbestos from RAW ASBESTOS or

ASBESTOSCONTAINING MATERIAL(S) other than those YOU personally installed, removed,
disturbed or handled YOURself during the OCCASION. If “yes":

Describe specifically the work YOU performed during the OCCASION, including whether the
work was performed indoors or outdoors;

DESCRIBE each RAW ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) that released the
asbestos fibers to which YOU allege exposure;

List the trade(s) using the RAW ASBESTOS or ASBESTOSCONTAINING MATERIAL(S) andIDENTIFY the employer of each trade;

Describe the manner in which each trade used the RAW ASBESTOS or
ASBESTOSCONTAINING MATERIAL(S), (for example: installed, removed, disturbed or
handled);

Describe:

The AREA where the trades using the RAW ASBESTOS or ASBESTOSCONTAINING MATERIAL
(S} worked, and;

The approximate distance from that AREA to the AREA where YOU worked;

State whether YOUR employer took any SAFETY PRECAUTIONS to protect YOU from
breathing dust (for example: work segregation, ventilation, wetdown, hazard education,
working signs, respiratory protection), If "yes", describe each SAFETY PRECAUTION taken;
State whether YOUR union or employee association took any SAFETY PRECAUTIONS to
protect YOU from breathing dust. If “yes", describe each SAFETY PRECAUTION taken; and
State whether YOU took any SAFETY PRECAUTIONS to protect YOU from breathing dust. If
"yes", describe each SAFETY PRECAUTION taken.

If you are aware that any person YOU have identified in the preceding Interrogatory No. 1
has had his or her deposition taken, IDENTIFY the deposition by the name of the deponent,
the date the deposition was taken, the caption and number of the action in which it was
taken, the court which had jurisdiction over the action in which it was taken (including state
and county) and either the name and address of the court reporting agency which took the
deposition or the name and address of deponent's counsel of record.

Either (1) attach all DOCUMENTS evidencing the information sought in these interrogatories
and their subparts to your answers to these interrogatories, or (2) attach disks containing
such data, or (3) describe such DOCUMENTS with sufficient particularity that they may be
made the subject of a request for production of documents.BRAYTON@PURCELL LLP

ATUORNEYS AT LAW
22 RUSH LANDING ROAD.

{015 99841555,

Om NA mR ON

Qa BGS = Ss

ALAN R. BRAYTON, ESQ., S.B. #73685
ERIC C. SOLOMON, ESQ., 8.B. #119131

BRAYTON PURCELL LLP
Attorneys at Law
222 Rush Landing Road
P.O. Box 6169
Novato, California 94948-6169
(415) 898-1555
Attorneys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOYCE JUELCH and , ) ASBESTOS
NORMAN JUELCH, SR., } No. 275212
. ) VERIFIED
Plaintiffs, } ANSWERS TO INTERROGATORIES
VS. ;
ASBESTOS DEFENDANTS (BP)

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff JOYCE JUELCH
SETNO: TWO

1 A-B. Fox Theatre, Stockton, California.

. Approximately 1966, Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing. .

D. Fox West Coast Theatres, Corporation, Los Angeles, California.

E. Usherette.

F Plaintiff escorted patrons to their seats. Plaintiff assisted in cleaning the
theaters after movies.

. See Exhibit No. 1, attached.

2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B. Unknown site and location.
C. Approximately 1966. Plaintiff currently cannot be more specific as to the

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start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing.
: dD US Eagle, Inc., c/o Jand] Dierst & Hales, Vacaville, Califomia.
E. Unknown,
F. Plaintiff currently does not recall the specifics of this employment.

Plaintiff's investigation and discovery are continuing.
G. See Exhibit No. 1, attached.
2. . See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B. Naval Supply Depot, Stockton, California.

c. Approximately 1966. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

D, Naval Supply Depot, Stockton, California.

E, Janitor,

B Plaintiff cleaned offices and bathrooms throughout the facility. Plaintiff
recalls the offices had asbestos-containing ceiling tiles that were falling apart, and frequently fell
onto the floor. Plaintiff recalls sweeping and cleaning up the asbestos acoustical ceiling tiles

after they were on the floor.
G. Yes. .
lL, L. Plaintiff recalls working in various areas.
2. Please see response to Interrogatory No. 1C, above.
3. See Exhibit No, 2, attached.
4. See Exhibit No. 3, attached.
5. See Exhibit No. 4, attached,
6. See Exhibit No. 5, attached.
7 See Exhibit No, 6, attached.
8.-9, See Exhibit No, 7, attached.
10. Yes.
a. Plaintiff believes she was exposed to raw asbestos or

asbestos-containing materials at this worksite, including but not limited to: acoustical ceiling
tiles. Plaintiff currently cannot identify the manufacturer of each asbestos-containing product.
Plaintiff performed her work indoors and outdoors. Plaintifi’s investigation and discovery are
continuing.

8 b. Please see response to Interrogatory No. IF, above.

ce. Plaintiff does not recall any safety precautions to protect
her from breathing dust.

i. Yes.

a. Please refer to Interrogatory No. IF, above.

b. Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff may have been in close proximity to
asbestos-containing products not known to her at this time. Plaintiff's investigation and
discovery are continuing.

, ©. Plaintiffis not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to various other trades at this
worksite. Plaintiffs investigation and discovery are continuing.

. . The trades were installing, disturbing and/or handling the
asbestos products, Plaintiff, at this time, does not recall the specific manner in which each trade
used the asbestos-containing materials, Plaintiff's investigation and discovery are continuing.

efi) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

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f-h. Plaintiff does not recall any safety precautions to protect
her from breathing dust.
See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

L A-B. Foster Freeze, Stockton, California.
C.. Approximately 1967, Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing.
8 Ruben Ruff, Jetry’s Freeze No. 142, Stockton, California.
kk.

ook.

Plaintiff worked at a hamburger restaurant.
. See Exhibit No, |, attached,

See Exhibit No. 8, attached.

See Exhibit No, 9, attached.

Dd.
E.
B

G

ee

1 A-B, Dameron Hospital, Stockton, California. : .
C. Approximately 1969; and 1974 to 1977. Plaintiff, currently cannot be
more specific as to the start date, ond date and total number of days. Plaintiff's investigation and

discovery are continuing. a,
DB. Dameron Hospital, Stockton, California.

E. Nurse. . .

F. Plaintiff performed genera! nursing duties throughout the intensive care
unit, the emergency units and medical surgery departments. Plaintiff recalls that during the early
1970's, the hospita underwent a remodel.

as es.

Plaintiff recalls working in various areas.
Please see response to Interragatory No. 1C, above.
See Exhibit No. 2, attached.
See Exhibit No. 3, attached.
See Exhibit No. 4, attached.
See Exhibit No. 5, attached.
See Exhibit No. 6, attached,

-9, See Exhibit No. 7, attached.

es.

BePaveenrd

2

a Plaintiff believes she was exposed to taw asbestos or

asbestos-containing materials at this worksite. Plaintiff currently cannot identify the

manufacturer of each asbesios-containing product. Plaintiff performed her work indoors and

outdoors, Plaintiff's investigation and discovery are continuing.
b. Please see response to Interrogatory No. 1F, above.

e-e. Plaintiff does not recall any safety precautions to protect

Yes. -

. lease refer to Imerrogatory No, 1F, above.
db. laintiff believes she was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, including but not limited to: KAISER
GYPSUM COMPANY, INC. drywall, KAISER GYPSUM COMPANY, INC. joint compound,
ductwork, and acoustical materials. Plaintiff currently cannot identify the manuisecturer of each
asbestos-containing product. Plaintiff may have been in close proximity to asbestos-containing
products not known to her at this time, Plaintiff's investigation and discovery are continuing.

. c. laintiff is not an expert in the identification of trades,

however plaintiff currently recalls working in close proximity to drywallers, sheet metal workers,
and various other trades at this worksite. Plaintiff's investigation and discovery are continuing.

her from breathing dust. :

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d. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff recalis working at the hospital during the early 1970's while the
remode! was taking place. Plaintiff recalls walking through a construction sie everyday. Plaintiff
walked directly adjacent to drywallers panging KAISER GYPSUM COMPANY, INC, drywall,
and applying and sanding KAISER GYPSUM COMPANY, INC. asbestos-containing joint
compounds. Plaintiff recalls drywallers hung up plastic sheets to contain debris, but pl aintiff
recalls dust frequently came through the sheets. Plaintiff recalls walking adjacent to sheet metal
workers installing duct work in the ceiling, disturbing asbestos-containing acoustical materials
that had been recently applied by drywallers. Plaintiff, at this time, does not recall the specific
manner in which each-tade used the asbestos-containing materials, Plaintiff's investigation and
discovery are continuing. . .

eed) The trades were located in and around all areas of this
worksite in close proximity to p laintiffs work area, Plaintiff's investigation and discovery are
continuing. .
® f-h, Plaintiff does not recall any safety precautions to protect |
her from breathing dust. “

2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B, Wine Country Care Center, Ledi, California.
_ & Approximately 1970 to 1972; and 1977. Plaintiff currently cannot be
more specific as to the start date, end date and total number of days, Plaintiff's investigation and

discovery are continuing.
. D. ‘oss Convalescent Hospital, Inc., Wine country Care Center, Lodi,
California. .

. Nurse,
F Plaintiff provided patient care.
G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, attached.
3. See Exhibit No, 9, attached.

i. A-B. | Elmhaven Convalescent Hospital, Inc., Stockton, California.

c. Approximately 1973. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

Elmhaven Convalescent Hospital, Inc., Stockton, California.

E. Nurse, :

F. Plaintiff provided patient care.

G. See Exhibit No. 1, attached.

2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

4 A-B. Oak Park Community Hospital of Northern. California, Stockton,
California. .
Cc. Approximately 1973. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing,
oo D. Oak Park Community Hospital of Northern California, Stockton,
California.
g. Nurse,
FB Plaintiff provided patient care.
G. See Exhibit No. |, attached.

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2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

L. A-B. James D. Baker, Ir., M.D., Inc., Stockton, California. .
C, Approximately 1978 to 1980. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing. cee ot
D. James 1D. Baker, Jr, M.D., ‘Ine., Stockton, California.
E. Nurse. . oe,
PF, Plaintiff worked for a family doctor assisting him with patients.

G. See Exhibit No. 1; attached,
2, See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

1. A-B. Unknown site and location. ,

Cc. Aj proximercly 1977 to 1978. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing. .

Dd. Consolidated Liberty, Inc., Hy-Lond Enterprises, Fresno, California.

E. Unknown.

F, Plaintiff currently does-not recall the specifics of this employment.

Plaintiff's investigation and discovery are continuing.
G. See Exhibit No. 1, aitached.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached,

1. A-B. San Joaquin General Hospital, French Camp, California,

c. Approximately 1980. Plaintift currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

dD. County of San Joaquin, Stockton, California.

E. Nurse.

F. Plaintiff worked as a nurse throughout the emergency room and intensive
care units on the ground fourth floor of this hospital. Plaintiff recalls that the hospital underwent
aremodel during this time period.

. Yes. .

Plaintiff recalls working in various areas.
Please see response to Interrogatory No. 1C, above.
See Exhibit No, 2, attached.
See Exhibit No, 3, attached.
See Exhibit No, 4, attached.
See Exhibit No. 5, attached.
. See Exhibit No. 6, attached.

8.-9. See Exhibit No. 7, attached.

10. Yes.

. 8 Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff performed her work indoors and
outdoors. Plaintiff's investigation and discovery are continuing.

b. Please see response to Interrogatory No. IF, above.
c-e. Plaintiff does not recall any safety precautions to protect

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her from breathing dust.

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ll, Yes.

a. Please refer to Interrogatory No. 1F, above.

b. Plaintiff believes she was cxposed 10 raw asbestos or
asbestos-containing materials by others at this worksite, including but not limited to: asbestos-
containing ceiling files and fireproofing, Plaintiff currently cannot identify the manufacturer of
each asbestos-containing product. Plaintiff may have been in close proximity to asbestos-
containing products not known to her at this time. Plaintiff's investigation and discovery are
continuing.

Ge Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to contractors, workers, and
various other trades at this worksite, Plaintiff's investigation and discovery are continuing.

d, The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff recalls contractors removed and replaced asbestos-containing ceiling
les during the remodel of this hospital. Plaintiff was in proximity to workers disturbing
fireproofing during the construction. Plaintiff, at this time, does not recall the specific manner in
which each trade used the asbestos-containing materials. Plaintiff's investigation and discovery
are continuing.

e.(i-ii) The trades were located in and around all areas of this
worksite in close proximity to plaintif’s work area, Plaintiff's investigation and discovery are
continuing.
f-h. Plaintiff does not recall any safety precautions to protect
her from breathing dust. :

2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

L A-B.  Lasalette Rehabilitation & Convalescent Hospital, Phoenix, Arizona.

c. /prrondinate! 980 to 1981. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiffs investigation and discovery are
continuing. .

Dd. Samaritati Senior Services of California, Inc., Lasalette Rehabilitation &
Convalescent Hospital, Phoenix, Arizona. <

“ EL Nurse,
EL Plaintiff assisted in the treatment and care of patients.

G. See Exhibit No. 1, attached.
2. See Exhibit No. 8, atlached.
3. See Exhibit No. 9, attached.

1. A-B. Unknown site aiid location. oo
c. Approximately 1981 to 1982. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

dD. Premier Health Services of Central California, Sausalito, California.
E. Unknown.
RF, Plaintiff currently does not recall the specifics of this employment.

Plaintiff's investigation and discovery are continuing.
a. See Exhibit No. |, attached.
2. See Exhibit No. 8, atlached.
3. See Exhibit No. 9, attached.

i. A-B. Crestwood Hospitals, Inc., Stockton, California.
Cc. Approximately 1982. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are

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continuing.
D. Crestwood Hespitais, Inc., Stockton, California.
E. Nurse,
F. Plaintiff assisted in the treatment and care of patients.
G. See Exhibit No. |, attached.
2. See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

1 A-B. Toseo Oil, Avon, California.

c. Ay proximately 1982 to 1984. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

Dd. Plant Insulation Company, Emeryville, California.

E. Insulator (Apprentice.

F. Plaintiff assisted insulators insulating tanks and removing existin,
asbestos, containing pipe insulation when performing repairs. Plaintiff used BENJAM.
FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B. FULLER COMPANY) fibrous
adhesive. Plaintiff was issued and used a 3M COMPANY single-strap mask. Plaintiff out and
provided pipe insulation to insulators as well as insulation cements. Plaintiff swept and cleaned
‘up asbestos-containing : insulation that was removed by insulators in her crew,

- es.

i, Plaintiff recalls working in various areas.

2. Please see response to Interrogatory No. 1C, above.

3. See Exhibit No. 2, attached.

4. Plaintiff recalls the following co-workers: Norman Juelch, o/o

Brayton Purcell, LLP; Hank Freeman, c/o Brayton¢’Purcell LLP; John Murphy, ¢/o

Brayton? Purcell LLP; Ken Goforth, ofo Brayton+Purcell LLP; Larry Sublet, o/o

Brayton’ Parcel LLP; Don Bass, c/o Brayton%*Purcell LLP; and Steve Steele, Concord,
alifornia.

Ss. See Exhibit No. 4, attached.
6. See Exhibit No. 5, attached.
7. See Exhibit No. 6, attached.
8-9. See Exhibit No. 7, attached.
10. Yes.

a Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite, including but not limited to: pipe insulation, tanks,
pipes, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B. FULLER
COMPANY) fibrous adhesive, and insulation cements. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff performed her work indoors and
outdoors. Plaintiff's investigation and discovery are continuing.

b Please see response to Interrogatory No. tF, above.

. ce. Plaintiff was issued and used a 3M COMPANY single-
strap mask. Plaintiff's investigation and discovery are continuing.
: es. :

. Please refer to Interrogatory No. IF, above,
b. Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, including but not limited to:
BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, C. (H.B. FULLER
COMPANY) fibrous adhesive, pipe insulation, insulation cements, piping, valves, packing
materials, and gasket materials. Pls intiff currently cannot identify the manufacturer of each
asbestos-contaiming product. Plaintiff may have been in close proximity to asbestos-containing
products not known to her at this time, Plaintiff's investigation and discovery are continuing.

c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to insulators, pipefitters, welders,

a

Kitlnjured GB688\pIdiel-sacsf? VERIFIED. wpd 7Oo 8 © VY A UW Bw NN

GQ 'O HO 8S

16

contractors, laborers, and various other trades at this worksite. Plaintiff's mvestigation and
discovery are continuing.

. d. ‘The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff recalls insulators insulating’tanks and removing existing asbestos-
containing pipe insulation when performing repairs. Plaintiff was in rocinnity to workers using
BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (1.8. FULLER
COMPANY) fibrous adhesive. Plaintiff recalls insulators were insulating pipes and usin;
insulation cements. Plaintiff recalls insulators removing asbestos-containing insulation, Plaintiff
worked adjacent to TOSCO OIL laborers sweeping and cleaning up debris discarded by TOSCO
OIL personnel during repairs, which was scattered throughout the facility, Plaintiff worked
adjacent to BECHTEL (SEQUOIA VENTURES INC) pipefitters and welders performing repairs
to piping and valves. Plaintiff worked in close proximity to BECHTEL ( SEQUOIA
VENTURES INC) pipefitters who opened valves and removed interior packing and gasket
material, Plaintiff was able to identify BECHTEL (SEQUOIA VENTURES INC) pipefitters due
to their uniforms. Plaintiff worked in proximity to THE INDUSTRIAL MAINTENANCE
ENGINEERING contractors who knocked asbestos insulation from piping and swept up
asbestos-containing materials from the floor, :

eid} The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are

continuing.
: fi-h. Plaintiff was issued and used a 3M COMPANY single-
strap mask, Plaintiff's investigation and discovery are continuing.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached,

I. A-B. Dow Chemical, Fitisburg, California.

Cc, Approximately 1982 to 1983. Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing,

D. Plant Insulation Company, San Francisco, California.

E. Insulator (Apprentice).

- FR Plaintiff assisted insulators Insulating tanks, chemical lines and valves.
Plaintiff used BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B.
FULLER COMPANY) fibrous adhesive. Plaintiff was issued and used a 3M COMPANY
single-strap mask. ¥ : :
“Gi. es.

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. IC, above.

See Exhibit No, 2, attached. .
Plaintiff recalls the following co-worker: Norman Juelch, c/o

See Exhibit No. 4, attached.
See Exhibit No. 5, attached.
See Exhibit No. 6, attached.
-9. See Exhibit No. 7, attached.

BraytonPurcell LLP.

SONI RO
eens Pebr

es,
8 Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite, including but not limited to; insulation, tanks,
chemical lines, valves, and BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC.
(H.B. FULLER COMPANY) fibrous adhesive. Plaintiff currently cannot identify the
manufacturer of each asbestos-containing product. Plaintiff performed her work indoors and
outdoors. Plaintiff's investigation and discovery are continuing.

be Please see response to Interrogatory No. IF, above.

c-e. Plaintiff was issued and used a 3M COMPANY single-

KAlnjuredO8S8ipldial-ancsf 2 VERIFIED. wpd 8oe RN DW Bw! HY

strap mask. Plaintiff 5 favesti ation and discovery are continuing.
i. es.

a Please refer to Interrogatory No. 1F, above.

b. Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, including but not limited to: insulation,
tanks, chemical lines, valves, PRs BENJAMIN FOSTER DIVISION OF AMCHEM
PRODUCTS, INC, (1.8. FULLER COMPANY) fibrous adhesive, pipe insulation, SAFEWAY
STEEL PRODUCTS (SCOTT TECHNOLOGIES, INC.) scaffolding, packing materials,
pipelines, and gaskets. Plaintiff currently cannot identify the manufacturer o each asbestos-
containing product. Plaintiff may have been in close proximity to asbestos-containing products
not known to her at this time. Plaintiff's investigation and discovery are continuing.

c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to insulators, pipefitters,
contractors, laborers, and various other trades at this worksite. Plaintiff's investigation and
discovery are continuing.

. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff worked in close proximity to insulators insulating tanks, chemical
lines and valves. Plaintiff was adjacent to the disturbance of existing asbestos-containing pipe
insulation by pipefitters, insulators and other tradesmen workin; in the vicinity, Plaintiff was in
peosimtt 6 other workers using BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS.

iC. (HB. FULLER COMPANY) fibrous adhesive. Plaintiff recalls dust from the discarded
asbestos-containing pipe insulation that had fallen, or been recently removed and discarded on
the ground where all trades were walking, and was consequently kicked and disturbed adjacent to]
plaint f Plaintiff was in proximity to SAFEWAY STEEL PRODUCTS (SCOTT

ICHNOLOGIES, INC.) scaffolding being dismantled by SAFEWAY employees where the!
would flip the boards on the scaffolding and allow all of the asbestos-containin; debris to fall to
the ground, creating a lot of dust. Plaintiff worked in proximity to BAY WESTERN
INDUSTRIAL MAINTENANCE, INC. (BRAGG INVESTMENT COMPANY, INC}
contractors pulling oe asbestos packing while working on valves. Plaintiff recalls BECHTEL
(SEQUOIA VENTURES INC) pipefitters performed tle-in work to existing pipelines, disturbing
asbestos-containing pipe insulation. Plaintiff recalls BECHTEL (SEQUOTA RES INC)
pipefitters cut and installed asbestos-containing gaskets and opened valves, removing and
replacin interior gasket and packing material. Plaintiff recalls working adjacent to ECHTEL
‘ QUOIA VENTURES INC) em lovers sweeping and cleaning asbestos-containing debris.

laintiff, at this time, does not recall the specific manner in which each trade used the asbestos-
containing materials, Plaintiff's investigation and discovery are continuing,
. ¢.(4i) The trades were located in and around all areas of this

worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are

continuing. .
f-h. Plaintiff was issued and used a 3M COMPANY single-
strap mask. Plaintiff's investigation and discovery are continuing. tO
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

L. A-B. Shell Oil, Martinez, California.

c Approximatel 1983 to 1984, Plaintiff currently cannot be more specific
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

D. Plant Insulation Company, Emeryville, California.

E. Insulator (Apprentice).

F. Plaintiff assisted insulators applying insulation to piping, and insulating
large pipe racks. Plaintiff assisted insulators removing as! estos-containing pipe insulation on

existing piping, Plain was issued and used a 3M COMPANY single-strap mask.
ao es.

KAbyjoredl0g68aipidiabsacsf 2 VERIFIED wad 91, Plaintiff recalls working in various areas.

2. Please see response to Interrogatory No. 1C, above.

3. See Exhibit No. 2, attached.

4. Plaintiff recalls the following co-workers: Hank Freeman; c/o

Brayton*Purcell LLP; and Norman Juelch, c/o Brayton** Purcell LLP,

5. See Exhibit No. 4, attached.

6. See Exhibit No. 5, attached.

7. See Exhibit Ne. 6, attached.

8.-9. See Exhibit No. 7, attached.

OD wm WM DH YW B wh

10

10. Yes,
a.

“o

asbestos-containing materials at this worksite, includi

piping, and pipe racks, Plaintiff current
containing product,
and discovery are continuing, b

aintiff believes she was exposed to raw asbestos or
cluding but not limited to: pipe insulation,
'y cannot identify the manufacturer of each asbestos-

Plaintiff performed her work indoors and outdoors. Plaintiff's investigation

. Please see response to Interrogato No. IF, above.
ce, Plaintiff was issued and used a 3M COMPANY single-
strap mask. Plaintiff's investigation and discovery are continuing,
es.
a Please refer to Interrogatory No, IF, above.
b. Plaintiff believes she was exposed to raw asbestos or

asbestos-containing materials by others
insulation,

i
(GARLOCK SEALING TECHNOLO

ping, pipe racks, valves, gasket and packing materials, and GARLOCK

at this worksite, including but not limited to: pipe

IES, LLC) flange gaskets. Plainuff currently cannot

identify the manufacturer of each asbestos-containing product. Plaintiff may have been in close
proximity to asbestos-containing products not known to her at this time. Plaintiff's investigation

and discovery are continuing.

c. P

aintiff is not an expert in the identification of trades,

however plaintiff currently recalls working in close proximity to insulators, pipefitters, and
various other trades at this worksite. Plaintiff's investigation and discovery are continuing.

. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff assisted insulators applying insulation to piping, and insulating large
pipe racks. Plaintiff assisted insulators removing asbestos-containing pipe insulation on existing

Bae

Plaintiff was adjacent to pipefitters employed by DILLING:
TRUCTION, N.A., INC.) who were removing and installing new asbestos-containing

M (DILLINGHAM

valves, disturbing interior asbestos containing gasket and packn material, and cutting and

installing GARL!

CK (GARLOCK SEALING TECHNO:

OGIES, LLC) flange gaskets.

Plaintiff, at this time, does not recall the specific manner in which each trade used the asbestos-
containing materials. Plaintiff's investigation and discovery are continuing.
ee) The trades were located in and around all areas of this

worksite in close proximity to plaintiff's
Plaintiff was issued and used a 3M COMPANY single- -

continuing. fh

work area. Plaintiff's investigation and discovery are

strap mask, Plaintiff's investigation and discovery are continuing.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1 A-B. Pacific Bell Tele;
Approximately |

phone Company, Stockton, California.
983 to 1984. Plaintiff currently cannot be more specific

Cc.
as to the start date, end date and total number of days. Plaintiff's investigation and discovery are

continuing.
D.
E. Insulator.
F

Plaintiff applied

Killejuredi108688\ptdhai-sacst 2 VERIFIED wed

Northern California Insulation, Inc., Sacramento, California,

fiberglass insulation and mastic to piping and valves at a

10i
‘
i

oe

ao 2 BI DA HW Be

s
t

Pacific Bell Telephone building located a few blocks north of downtown Stockton. Plaintiff

insulated the valves.

ase ° G. See Exhibit No. |, attached.

2. See Exhibit No. 8, attached.

3. See Exhibit No. 9, attached.

1, A-B. Shell Oil, Martinez, California, .
c. Approximately 1983 to 1984, Plaintiff currently cannot be more specific
as to the start date, end dhe and total number of days. Plaintiffs investigation and discovery are

tinuing, ys .
continuing. D. Northern California Insulation, aka Metalclad Insulation Corporation,
E. Tnsulator. . as : . . i
& __ Plaintiff applied calcium silicate pipecovering, fiberglass pipecovering,

insulation cement, black mastic, and insulation pads to piping and valves, Plaintiff was issued
and used a 3M COMPANY single-strap mask. Plaintiff removed asbestos-containing pipe
insulation on existing Riping.

. cs.

1. Plaintiff recalls working in various areas.

2. Please see response to Interrogatory No. 1C, above.

3. See Exhibit No. 2, attached.

4, Plaintiff recalls the following co-worker: Norman Juelch, c/o

Brayton Purcell, LLP,

5. See Exhibit No. 4, attached.
6. See Exhibit No, 5, ailached,
7 See Exhibit No. 6, attached.
5-9. See Exhibit No. 7, attached.
16.

es,

a Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite, including but not limited to: calcium silicate
Pipecovering, fiberglass pipecovering, insulation cement, black mastic, insulation pads, piping,
and valves. Plaintiff currently cannot identify the manufacturer of each asbestos-containing
product, Plaintiff performed her work indoors and outdoors. Plaintiff's investigation and
discovery are continuing.

b. Please see response 10 Interrogatory No. IF, above.

c-e. Plaintiff was issued and used a 3M COMPANY single-
strap mask, Plaintiff's investigation and discovery ate continuing.

. es,

a Please refer to Interrogatory No. 1F, above.

. b. Plaintiff believes she was exposed to raw asbestos or
asbéstos-containing materials by others at this worksite, including but not limited to: valves,
gaskeis, packing materials, and GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC)
ange gaskets, Plaintiff currently cannot identify the manufacturer of each asbestos-containing
product. Plaintiff may have been in close proximity to asbestos-containing products not known
to her at this time. Plaintiff's investigation and discovery are continuing.

. c. Plaintiff is not an expert in the identification of trades,
however plaintiff currently recalls working in close proximity to pipefitters and various other
trades at this worksite. Plaintiff's investigation and discovery are continuing.

. : The trades were installing, disturbing and/or handling the
asbestos ptoducts. Plaintiff worked adjacent to pipefitters removing and replacing asbestos-
containing valves, disturbing interior gasket and packing material, and cutting and installing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) flange gaskets. Plaintiff, at this
time, does not recall the specific manner in which each trade used the asbestos-containing
materials. Plaintiff's investigation and discovery are continuing.

e(i-ii) The trades were located in and around all areas of this

KMnjured\ 108682\pldei-sacef'? VERIFIED. wed YHshim from breathing dust

worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are

continuing.
f.-h. Plaintiff was issued and used a 3M COMPANY single-
strap mask, Plaintiff's investigation and discovery are continuing.
2. See Exhibit No. 8, attached.
3. See Exhibit No. 9, attached.

1. A-B. Sutter Memorial Hospital, Sacramento, California.

Cc. Approximately 1984. Plaintiff ourrently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

. Northern California Insulation, aka Metalclad Insulation Corporation.

E. Insulator (Apprentice).

F, Plaintiff worked in steam tunnels re-insulating pipes. Plaintiff disturbed
and removed existing asbestos-containing pipecovering on piping.

- ‘es.

Plaintiff recalls working in various areas.

Please see response to Interrogatory No. 1C, above.
See Exhibit No. 2, attached.

See Exhibit No, 3, attached.

See Exhibit No. 4, attached. -

See Exhibit No. 5, attached.

See Exhibit No. 6, attached.

+9, See Exhibit No. 7, attached.

OO IA BRN ee nt

Yes,
a Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite, including but not limited to: steam tunnels,
pipecovering, insulation, ahd piping, Plaintiff currently cannot identify the manufacturer of each
asbestos-contaifting product. Dinntt performed her work indoors and outdoors. Plaintiff's
investigation and discovery are continuing,

b Please see response to Interrogatory No. IF, above.
ce. Plaintiff does not recall any safety precautions to protect

Yes.
a, Please refer to Interrogatory No. IF, above.
b Plaintiff believes she was exposed to raw asbestos or

asbestos-containing materials by others at this worksite, including but not limited to: piping and
insulation. Plaintiff currently cannot identify the manufacturer of each asbestos-containing
product. Plaintiff may have been in close proximity to asbestos-containing products not known
to her at this time. Plaintiff's investigation and discovery are continuing. .

. Plaintiff is not an éxpert in the identification of trades,
however plaintiff carrently recalls working in close proximity to pipefitters and various other
trades at this worksite, Plaintiff's investigation and discovery are continuing.

d. ‘The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff worked adjacent to pipefitters removing and installing new piping,
and disturbing existing pipe insulation. Plaintiff, at this time, does not recall the specific manner
in which each trade used the asbestos-containing materials. Plaintiff's investigation and
discovery are continuing.

e.(i-ti) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area. Plaintiff's investigation and discovery are
continuing.

f-h. Plaintiff does not recall any safety precautions to protect
her from breathing dust. .

2. See Exhibit No, 8, attached.

KAnjured\LO8688\pidai-sacst2 VERIFIED wpd 12OC 2m VW A Wh Be WN

3. See Exhibit No. 9, attached.

1. A-B. Campbell Soup Company, Sacramento, California. .
Cc. Approximately 1984. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days, Plaintiff's investigation and discovery are
mtinuing.
cont & D. Northern California Insulation, aka Metalclad Insulation Corporation.
E, Insulator. oo, .
PF. Plaintiff removed existing asbestos-containing pipe insulation from.
ipelines. Plaintiff insulated tanks and repaired patches on existing asbestos-containing pipe
insulation.

Yes.

1. Plaintiff recalls working in various areas.

2. Please see response to Interrogatory No. 1C, above.

3. See Exhibit No, 2, attached.

4, Plaintiff recalls the following co-workers: Norman Juelch, c/o

Brayton Purcell, LLP; Mel Swanson, c/o Brayton Purcell LLP; Maurice Lawrence, c/o

Brayton‘? Purcell LLP. .

. See Exhibit No. 4, attached.
. See Exhibit No. 5, attached.
. See Exhibit No. 6, attached.
9. See Exhibit No. 7, attached.

8. 28,

a. Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials at this worksite, including but not limited to: pipe insulation,
pipelines, and tanks, Plaintiff currently cannot identify the manufacturer of each asbestos-
containing product. Plaintiff performed her work indoors and outdoors. Plaintiff's investigation
and discovery are continuing. b

5
6
7
&
!

. Please see response to Interrogatory No. IF, above.
c-e. Plaintiff does not recall any safety precautions to protect

Yes.
a. Please refer to Interrogatory No. 1F, above.

b. ._ Plaintiff believes she was exposed to raw asbestos or
asbestos-containing materials by others at this worksite, including but not limited to: valves,
gasket and packing materials, piping, insulation, gaskets, and machinery. Plaintiff currently
cannot identify the manufacturer of each asbestos-containing product, Plaintiff may have been in
close proximity to asbestos-containing products not known to her at this Ume. Plaintiff's
invesiigation and discovery are continuing. .

c. Plaintiff is not an expert in the identification of trades,
however Plaintiff currently recalls working in close proximity to pipefitters, laborers, and various
other trades at this worksite. Plaintiff's investigation and discovery are continuing.

. The trades were installing, disturbing and/or handling the
asbestos products. Plaintiff worked adjacent to pipefitters removing piping and disturbing
asbestos-containing pipe insulation, Plaintiff worked in close proximity to pipefitters removing
valves, disturbing interior gasket and packing materials, as well as cleaning and repairing
gaskets, Plaintiff worked adjacent to CAMPBELL SOUP employees, sweeping up asbestos-
containing debris, and repairing machinery. Plaintiff, at this time, does not recall the specific
manner in which each trade used the asbestos-containing materials. Plaintiff's investigation and
discovery are continuing.

her from breathing dust,

. ___, &.i-ti) The trades were located in and around all areas of this
worksite in close proximity to plaintiff's work area, Plaintiff's investigation and discovery are
continuing,

f-h. Plaintiff does not recall any safety precautions to protect

K Mnjured\ }O868Sipldtei-seosf 2 VERIFIED. wpd . 3i
i
|
|
i
{
i
|
i

CS oO YW A wb wo

her from breathing dust.
2, See Exhibit No. 8, attached,
3. See Exhibit No. 9, attached.

1. A-B. Slaughterhouse, Sacramento, California.

c. Approximately 1984. Plaintiff currently cannot be more specific as to the
start date, end date and total number of days. Plaintiff's investigation and discovery are
continuing.

. Unknown.