On May 20, 2009 a Exhibit,Appendix was filed involving a dispute between Juelch, Joyce, Juelch Sr, Norman, and 3M Company, 84 Lumber Company, 84 Lumber Company, A Limited Partnership, All Asbestos Defendants, Allis-Chalmers Corporation Product Liability Trust, Asbestos Defendants, Cbs Corporation, A Delaware Corporation, F K A, Chevron U.S.A. Inc., Consolidated Insulation, Inc., Csk Auto, Inc., Dillingham Construction N.A., Inc., Does 1-8500, Douglass Insulation Company, Inc., Garlock Sealing Technologies, Llc, General Electric Company, Genuine Parts Company, Hamilton Materials, Inc., J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Metalclad Insulation Corporation, Oscar E. Erickson, Inc., Pacific Gas And Electric Company, Pacipic Bell Telephone Company, Parker Hannifin Corporation, Quintec Industries, Inc., Redwood Plumbing Co., Inc., Santa Fe Braun, Inc., Sequoia Ventures Inc., Shell Oil Company, Thomas Dee Engineering Company, Timec Company, Inc., Tosco Refining Company, Inc., Union Carbide Corporation, Union Oil Company Of California, Unocal Corporation, for ASBESTOS in the District Court of San Francisco County.
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DECLARATION OF DAVID A. PERE) COMPANY, INC.'S MOTION FOR SUMMARY JUDGMENT 1 | BUGENE BROWN, JR. (SBN: 079824) | DAVID A. PEREDA (SBNr237982) / 2 | FILICE BROWN EASSA & MCLEOD LLP ; 1999 Harrison Street, Suite 1800 ELECTRONICALLY / 3 | Oakland, California 94612-3520 FILED | Telephone: (310) 444-3131 Superior Court of California, | 4 | Faesimile: ($10) 839-7940 County of San Francisco | 5 | Attorneys for Defendant FEB 24 20 10 TOSCO REFINING COMPANY, INC. perc of the court 6 Deputy Clerk 7 | & SUPERIOR COURT OF THE STATE OF CALIFORNIA : 9 COUNTY OF SAN FRANCISCO i 0 | 1 | JOYCE WUELCH AND. NORMAN CASE NO, CGC09-275212 JUELCH, SR., | 2 EXHIBIT B TO THE DECLARATION OF Plaintiffs, DAVID A, PEREDA IN SUPPORT OF 13 TOSCO. REFINING COMPANY, INC'S : vy MOTION FOR SUMMARY JUDGMENT | ASBESTOS DEFENDANTS. (BP), | Date: March 18,2010 i 5 ‘Time: 9:30 am. | Defendant. | Dept.: 220 | 6 Judge: Hon. Harold. Kahn i Trial Date: April. 5, 2010 | 7 i : We 19 20 i | 21 22 23 24 25 26 a7 | i 27 2 se pet { : IN SUPPORT ©. | !Page 540 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA TN AND FOR THE COUNTY OF SAN PRANCISCO ~ = Q00- ~~ KENNETH GOFORTH, Plaintiff, ve. Ho. 451849 ASBESTOS DEFENDANTS COMPENUED DEPOSITION OF KENNETH GOFORTH Volume 5S - Pages 540 to 669 Taken before JERALI A. SWAGERTY CSR No. SL10 May 22, 2007 Aiken & Welch Court Reporters K. Goforth, V.5 5-22-07 b2bee99b-Sidh-4026-8910-7bab2b3cs6683 Q. Did you get that from the Plant yard, P e insulation yard? Page 651 lant 3 A. It would be brought to the work site, the area 4 I was working in, by apprentices. I would assum e 5 that's where it would come from, but I wouldn't know 6 for sure. 7 Q. You also said the Plant Insulation truc a drive you to your location where you would work a had to go through plant crews that were working. a0 A. Yes. ub QO. When you say Plant crews, do you mean P 12 Insulation crews? A. Yes. i ©. You were in the truck; is that correct? 18 MS. BACCITICH: Overbroad, vague. 16 THE WITNESS: I was in the truck I was a7 in te go to work, yes. 18 I didn't understand that. 19 BY MS. ACEVEDO: 20 Q. Did you observe any refinery people whi k. would and you lant riding. le you arn"""were at the refinery in ‘83 for these few days? a3 Q. I understand you went to the skids. Ts that a 2a different location than the refinery? 25 / A. Yes. That was in Richmond. Aiken & Welch Court Reporters K. Goforth, V.5 5-22-07 b2beeS8b-Sidb-4625-2010-7 beb2bBc56es