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GEORGE D. YARON, ESQ. (State Bar #96246) .
KEITH E. PATTERSON, ESQ. (State Bar #225753)
MICHAEL J. PENG, ESQ. (State Bar #260852)
YARON & ASSOCIATES
601 California Street, 21" Floor
San Francisco, California 94108-2281
Telephone: (415) 658-2929
Facsimile: (415) 658-2930
Attorneys for Defendant
84 LUMBER COMPANY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOYCE JUELCH and NORMAN JUELCH,
SR.,
Plaintiffs,
v.
DOES 1-8500,
)
)
)
)
)
:
ASBESTOS DEFENDANTS (BP) and )
)
)
)
Defendants. )
)
)
)
ELECTRONICALLY
FILED
Superior Court of Califor pe
County of San Francis
DEC 07 2009.
GORDON PARK-LI, Clerk
BY: ALISON AGBAY
Deputy Plerk
CASE NO. CGC-09-275212
EXHIBIT C THROUGH
GTO DECLARATION OF MICHAEL J.
PENG IN SUPPORT OF 84 LUMBER
COMPANY’S OPPOSITION TO
PLAINTIFFS’ MOTION FOR TRIAL
PREFERENCE
Date: December 22, 2009
Time: 9:30 a.m.
Room: 206
Judge: ° Hon. James J. McBride
Action Filed: May 20, 2009
Trial Date: Not AssignedEXHIBIT CBRAYTON®PURCELL LLP
ATTORNEYS ATLAW
222 RUSH LANDING ROAD
PO BOX 6169
NOVATO, CALIFORNTA 94948-6169
(415) 898-1555
Ce Wa Aw fF WD
ALAN R. BRAYTON, ESQ,, S.B. #73685
ERIC C. SOLOMON, ESQ., S.B. #119131
BRAYTON*®*PURCELL LLP
Attorneys at Law
222 Rush Landing Road
P.O. Box 6169
Novato, California 94948-6169
(415) 858-1555
Attorneys for Plaintiffs
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JOYCE JUELCH and ) ASBESTOS
NORMAN JUELCH, } No. 275212
Plaintiffs, ANSWERS TO INTERROGATORIES
vs.
ASBESTOS DEFENDANTS (BP).
PROPOUNDING PARTY: . STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff JOYCE JUELCH
SET NO; ONE
ANSWERS
JOYCE JUANELL JUBLCH.
September 18, 1946,
62 years old,
SB of oF Pp
French Camp, California.
e 19581 Feather Falls Place, Cottonwood, California 96022.
£ Height: 5'7 1/2"; Weight: 169 Ibs.
g 569-68-7847,
h. None.
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u
None.
None,
RO494625; California.
Joyce Johnson; Joyce Chambers.
Plaintiff completed the 12th grade,
Norman E. Juelch, Sr.
June 13, 1945.
February 14, 1981.
_ 19581 Feather Falls Place, Cottonwood, California 96022.
Retired.
Bruce Johnson; John Chambers.
1963; 1967.
Plaintiff's marriage to Bruce Johnson was dissolved in 1967 due to
infidelity. Plaintiff's marriage to John Chambers was dissolved in 1978 due to infidelity.
2,
s PF
m Ff & ©
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Terresa Reyes,
November 14, 1963.
Natural.
5035 Zuning Avenue, Corning, California 96021,
Housewife,
Living.
Nina L. Reberson.
December 7, 1964,
Natural.
4809 Montaro Court, #D, Bakersfield, California 93307.
Retired,
Living.wow oN AW FF WN
aD OK FS
16
ren
" Jessica Hayes,
August 17, 2000.
c Granddaughter, Plaintiff has legal custody of this child.
da 19581 Feather Falls Place, Cottonwood, California 96022.
, P
e Child is aminor,
£ Living.
No.
None.
Plaintiff is currently able to recall the following addresses:
12/1981 to 1983: Evergreen, Stockton, California 95205.
1983 to 1984: Post Office Box 515, Sutter Creek, California,
1985 to 1988: McAtee Road, Valley Springs, California.
1988 to 1990; 23522 Shake Ridge Road, unknown city, California,
1990: 5758 Cora Post Road, Lodi, California.
1990: 1955 Emmon Canyon Road, Kila, Montana.
1991 to 1994: 2237 Highway 28, Hot Springs, Montana.
1994 to 2004: Newlin Road, Marion, Montana 59925,
2004: Silver Butte Road, Libby, Montana 39925, .
2005: 349 Trainer Street, Libby, Montana.
2006: 2090 Loleta Avenue, Corning, California.
2006 to present: 19581 Feather Falls Place, Cottonwood, California 96022.
Plaintiff completed the 12th grade.
May 27, 2009.
No.
No.
Excluding plaintiff's expert consultants, plaintiff recalls the following physicians:
a. Dr. Gills.
b, Redding, California.
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G Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing.
d, January 2009.
&, Heart attack,
f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
Dr. Luperpio.
b. Redding, California,
&. Plaintiff currently does not recall, Plaintiff's investigation and discovery ,
are continuing,
d.- January 2009.
e Heart attack.
fi Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a, - Dr. Hahns.
b. MD Imaging, Redding, California,
c Arterial dopler performed on lower extremities.
d. February 5, 2009. .
e, Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing, : :
£ Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a Plaintiff currently does not recall.
b, + Open System Imaging, Redding, California.
c, .Dopler performed.
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d. February 19, 2009.
. & Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing.
£ Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a Dr. Balazer.
b. Cottonwood Clinic, Cottonwood, California.
c.
Arterial dopler performed on lower extremities.
d. March 3, 2009. .
€. Plaintiff currently does not recall, Plaintiffs investigation and discovery
are continuing. :
f£ Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a Plaintiff currently does not recall, Plaintiff's investigation and discovery
are continuing,
b. MD Imaging, Redding, California.
CT of abdoman and pelvis.
d, March 11, 2009,
e. Plaintiff currently does not recall, Plaintiff's investigation and discovery
are continuing.
f. - Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry. ,
a Plaintiff currently does not recall. Plaintiffs investigation and discovery
are continuing,
b. MD Imaging, Redding, California.
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© , CT of chest without contrast,
d. March 12, 2009.
e Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing.
f Plaintiff has provided. authorizations for the release of medical records to
Berry & Berry, Defendants may obtain copies of records through Berry & Berry.
a. Dr. Dhanuha.
_ be Redding, California.
c. Office visit.
d. March 17, 2009,
a Plaintiff was given the results of her tests. Plaintiff was advised that she
‘had cancer.
£. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry, Defendants may obtain copies of records through Berry & Berry.
a Dr, Luperpio.
b, Redding, California,
¢. Pulmonology.
d March 18, 2009,
& Plaintiff currently does not recall. Plaintiff's investigation and discovery
are continuing. - :
fi Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a Dr, Karem.
b. Redding, California.
c-e. Plaintiff currently does not recall. Plaintiff's investigation and discovery
KAlnjytod\l O8688\ni-snesf lLwed 6oon aA uw BR WN
are continuing.
f. Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
a: Dr, Dhanuha,
b. Redding, California. ‘
ce Plaintiff receives chemotherapy.
d. Presently,
e Cancer.
£ Plaintiff has provided authorizations for the release of medical records to
Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
11, Excluding those used by plaintiff's expert consultants, plaintiff currently recalls
the following hospitals:
a. Mercy Hospital.
b. Redding, California.
G Plaintiff was hospitalized due to heart problems. An angiogram was done,
and 2 stints were put in,
d. December 31, 2008.
@ Stroke,
f, Plaintiff has provided authorizations for the release of medical records to
‘Berry & Berry. Defendants may obtain copies of records through Berry & Berry.
12. Excluding any taken by plaintiff's expert consultants, plaintiff recalls the
following x-rays and CT scans: Please see response to Interrogatory Numbers 10 and 11, above.
This information is as complete as plaintiff can recall at this time and includes all treatment by
plaintiff's healthcare providers. Plaintiff's investigation and discovery are continuing.
13. Excluding anny taken by plaintiff's expert consultants, plaintiff recalls the
following pulmonary function tests: Please see response to Interrogatory Numbers 10 and 11,
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a. Plaintiff currently does not recall. Plaintiff's investigation and discovery
“are continuing.
b. No cessation.
e None that plaintiff is aware of.
d. ~_ Plaintiff contends that his lungs have primarily been affected. However,
above. This information is as complete as plaintiff can recall at this time and includes all
treatment by plaintiff's healthcare providers. Plaintiff's investigation and discovery are
continuing. .
14, Please see response to Interrogatory No.'s 10 and 11, above. Plaintiff defers to his
medical records as the best source of information for medications prescribed,
15. Notat this time. Plaintiff's medical records are equally available to defendants
through Berry & Berry, designated defense counsel.
16, Plaintiff has the following complaints from asbestos exposure: breathing
difficulties, fatigue, loss of stamina.
as lung function affects the rest of the body, plaintiff contends that all parts of her body have
been affected, ,
~ & Please refer to Interrogatory No. 10 and 11, above.
f Please refer to Interrogatory No, 10 and 11, above,
2 Plaintiff does not at this time contend that she has lost time from work as a|
result of her asbestos-related conditions. Plaintiff's investigation and discovery are continuing.
h. Not applicable. :
i, Plaintiff does not at this time have any documents responsive to this
Interrogatory. Plaintiff's investigation and discovery are continuing.
17. Excluding information protected by either the attorney work-product doctrine or
the attorney-client privilege, no.
18. No.
19. Plaintiff suffers from shortness of breath.
20. No.
KAlnjurcd\08688\ai-sacsP ).wpd 8wo em WAH BW Wm
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14
21. Plaintiff's investigation and discovery are continuing.
22. No.
23. Yes,
a. Plaintiff recalls smoking from approximately 1965 to present.
db Plaintiff recalls smoking cigarettes.
c Plaintiff recalls smoking 10 to 20 cigarettes per day.
d Plaintiff recalls smoking 1/2 to 1 pack of cigarettes per day.
e Plaintiff recalls smoking Marlboro brand cigarettes.
f. Yes, :
1. Dr. Dixon.
2. Approximately 1995,
24. Yes,
a. Plaintiff's husband, Norman Juelch.
b, 1981 to present.
2
Camel and Marlboro brand cigarettes,
a Approximately 1 pack per day.
25. No. : ,
26. Plaintiff is currently able to identify the following employment information:
Location of Exposure
Employer Exposure Job Title Dates .
Foster Freeze Foster Freeze Cook 1963
Stockton, CA * Stockton, CA
Job Duties: Plaintiff worked at a hamburger restaurant. Plaintiff is currently unaware if she was
exposed to asbestos during this employment.
Location of Exposure
Employer Exposure Job Title Dates
Dameron Hospital Dameron Hospital Nurse 1964-1974
Stockton, CA Stockton, CA
Job Duties: Plaintiff performed general nursing duties throughout the intensive care unit, the
emergency units and medical surgery departments. Plaintiff recalls during the early 1970s the
hospital underwent a remodel, Plaintiff recalls walking through a construction site everyday.
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10
Plaintiff walked directly adjacent to drywallers hanging KAISER GYPSUM COMPANY, INC.
drywall and applying and sanding KAISER GYPSUM COMPANY, INC. asbestos-containing
joint compounds. Plaintiff recalls drywallers hung up plastic shects to contain debris, but plainti
recalls dust frequently came through the sheets. Plaintiff recalls walking adjacent to sheetmetal
workers installing duct work in the ceiling, disturbing asbestos-containing acoustical materials
that had been recently applied by drywallers. Plaintiff currently contends she was exposed to
asbestos during this employment.
Location of , Exposure
Employer Exposure Job Title Dates
Naval Supply Depot Naval Supply Depot Janitor 1966
Stockton, C Stockton, CA .
.Job Duties: Plaintiff cleaned offices and bathrooms throughout the facility. Plaintiff recalls the
offices had asbestos-containing ceiling tiles that were falling apart, and frequently feli onto the
floor, Plaintiff recalls sweeping and eleaning up asbestos acoustical ceiling tiles after they were
on the floor. Plaintiff currently contends she was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure Job Tit! Dates
San Joaquin General Hospital San Joaquin General Nurse 1975-1976
French Camp, CA Hospital
French Camp, CA
4" Bloor
Job Duties: Plaintiff worked as a nurse throughout the emergency room and intensive care units
on the pround fourth floor of this hospital. Plaintiff recalls that the hospital underwent a remodel.
Plaintiff recalls contractors removed and replaced asbestos-containing ceiling tiles. Plaintiff was
in proximity to workers disturbing fireproofing during the construction, Plaintiff recalls there
was debris ihroupghout the site from the removal of the ceiling tile which was not cleaned up very
quickly, Plaintiff currently contends she was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure Job Title Dates
Unknown Family Doctor Unknown Doctor’s office Nurse 1976-1980
Stockton, CA Stockton, CA - :
Job Duties: Plaintiff worked for a family doctor assisting him with patients. Plaintiff is currenth
unaware if she was exposed to asbestos. during this employment.
Location of : Exposure’
Employer Exposurt Job Title Dates
Plant Insulation Company Tosco Oil, Insulator 1982-1984
Avon, CA (Apprentice) {2 months) .
Job Duties: Plaintiff assisted insulators insulating tanks and removing existing asbestos-
containing pipe insulation when performing repairs. Plaintiff used, and was in proximity to other
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10
workers using, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B.
FULLER COMPANY) fibrous adhesive. Plaintiff was issued and used a 3M COMPANY
single-strap mask. Plaintiff cut and provided pipe insulation to insulators as well as insulation
cements. Plaintiff swept and cleaned op asbestos-containing insulation that was removed by _
insulators in her crew. Plaintiff worked adjacent to TOSCO OIL, laborers sweeping and cleaning
up debris discarded by TOSCO OIL personnel during repairs, which was scattered throughout the|
facility, Plaintiff worked adjacent to BECHTEL GE UOIA 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) pipefitiers due to their uniforms. Plaintiff worked in proximity te THE INDUSTRIAL
MAINTENANCE ENGINEERING CONTRACTORS contractors who knocked asbestos
insulation from piping and swept up asbestos-containing materials from the floor. Plaintiff
recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP; Hank Freeman, c/o
Brayton*Purcell LLP; John Murphy, c/o Brayton#*Purcell LLP; Ken Goforth, ¢/o
Brayton#*Purcell LLP; Larry Sublet, c/o Brayton*Purcell LLP; and Don Bass, c/o
Brayton%Purcell LLP; Steve Steele, Concord, California. Plaintiff currently contends she was:
exposed to asbestos during this employment.
Location of . Exposure
Employer Exposure . Job Title
Plant Insulation Company Dow Chemical Insulator 1982-1983
Pittsburg, CA (Apprentice) (3 weeks)
Job Duties: Plaintiff assisted insulators insulating tanks, chemical lines and valves. Plaintiff was
adjacent to the disturbance of existing asbestos-containing pipe insulation by pipefitters,
insulators and other tradesmen working in the vicinity. Plaintiff used, and was in b proximity to
other workers using, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B.
FULLER COMPANY) fibrous adhesive. Plaintiff was issued and used a 3M COMPANY
single-strap mask. 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 plaintiff, Plaintiff was in
proximity to SAFEWAY STEEL PRODUCTS (SCOTT TECHNOLOGIES, INC.) scaffolding
cing dismantled by SAFEWAY employees where they would flip the boards on the scaffolding
and allow all of the asbestos-containing debris to fall to the ground, creating a lot of dust.
Plaintiff worked in proximity to BAY WESTERN INDUSTRIAL MAINTENANCE, INC,
(BRAGG INVESTMENT COMPANY, INC.) contractors pulling out asbestos packing while
working on valves. Plaintiff recalls BECHTEL (SEQUOIA VENTURES INC) pipefitters
performed tie-in work to existin pipelines, Gisturbing asbestos-containing pipe insulation,
laintiff recalls BECHTEL (SEG 1A VENTURES INC) pipefitters cut and installed asbestos-
containing gaskets and opened valves, removing and replacing interior gasket and packing
material. Plaintiff recalls working adjacent to BECH’ {SEQUOIA. RES INC)
employees sweeping and cleaning asbestos-containing debris. Plaintiff recalls the following
coworkers: Norman Juelch, c/o Brayton" Parcel LLP. Plaintiff currently contends she was
| exposed to asbestos during her employment.
Location of Exposure
loyer Exposure Job Title Dates
Plant Insulation Company Shell Oil Insulator =——:1983-1984
1300 - 64" St Martinez, CA _ (Apprentice) (1 month)
Emeryville, CA 94662
“KNnjured\108888\ni-saesf I.wpd . 11Cm IN KAR PB Ww HN
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exposed to asbestos during this employment.
Job Duties: Plaintiff assisted insulators applying insulation to piping, and insulating large pipe
racks, Plaintiff assisted insulators removing asbestos-containing pipe insulation on existing
piping. Plaintiff was issued and used a 3M COMPANY single-strap mask. Plaintiff was
aacent to pipefitters employed by DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A.,
IC.) who were removing and installing new asbestos-containing valves, disturbing interior
asbestos containing gasket and ing material and cutting and installing GARLOCK
(GARLOCK SEAL G TECHNOLOGIES, LLG) fange gaskets. Plaintiff recalls the following
coworkers: Hank Freeman; c/o Brayton¢*Purcell LLP; Norman Juelch, c/o Brayton+Purcell
LLP, Plaintiff currently contends she was exposed to asbestos during this employment.
: - Location of Exposure
Employer Exposure Job Title Dates .
Northern California. Pacific Bell Insulator 1983-1984
Insulation aka Metalclad Stockton, CA (3 weeks)
Insulation Corporation
Job Duties: Plaintiff applied fiberglass insulation, mastic to piping and valves at a Pacific Bell
Telephone building located a few blocks north of downtown Stockton. Plaintiff insulated the
valves. Plaintiff recalls coworker: Norman Juelch, c/o Brayton ¢Purcell, LLP. Plaintiff is
currently unaware if she was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure b Title Dates
Northern California Shell Oil Insulator 1983-1984
Insulation aka Metalclad Martinez, CA . (2 months)
Insulation Corporation
Job Duties: Plaintiff applied calcium silicate pipecovering, Rberplass pipecoverin , insulation
cement, black mastic and insulation pads to piping and valves. Plaintiff was issued and used a
3M. COMPANY single-strap mask. Plaintiff removed asbestos-containing pipe insulation on |
existing piping. Plaintiff was adjacent to pipefitters removing and replacing asbestos-containing
valves, disturbiny interior gasket and packing material, and cutting and installing GARLOCK
(GARLOCK SEALING ‘HNOLOGIES, LLC) flange gaskets, laintiff recalls the following
co-worker; Norman Juelch, c/o Brayton Purcell, LLP. Plaintiff currently contends she was
Location of Exposure
Employer Exposure Job Title Dates
Northern California Sutter Memorial Hospital Insulator 1984
Insulation aka Metalclad Sacramento, CA (Apprentice) (1 -2 weeks)
Insulation Corporation
Job Duties: Plaintiff worked in steam tumels re-insulating pipes. Plaintiff disturbed and
removed existing asbestos-containing pipe covering on piping, Plaintiff worked adjacent to
pipefitters removing and installing new piping, and disturbing existing pipe insulation. Plaintiff
currently contends she was exposed to asbestos during this employment.
Location of Exposure
Employer Exposure : Job Title
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Northern California Campbell Soup Insulator 1984
Tnsulation aka Metalclad Sacramento, CA (1 month)
Insulation Corporation
Job Duties: Plaintiff removed existing asbestos-containing pipe insulation from pipelines.
Plaintiff was adjacent to pipefitters removing piping and disturbing asbestos-containing pipe
insulation. Plaintiff worked | adjacent to pipefitters removing valves, disturbing interior gasket anc
packing material as well as cleaning an repairing gaskets. Plaintiff insulated tanks and repaired
patches on existing asbestos-containing pipe insulation. Plaintiff recalls the following co-
workers: Norman Juelch, c/o Brayton’ Purcell, LLP; Mel Swanson, c/o Bra on**Purcell LLP;
Maurice Lawrence, c/o Brayton**Purcell LLP, Plaintiff worked adjacent to CAMBELL SOUP
employees, sweeping up asbestos-containing debris, and repairing machinery. Plaintiff currently
contends she was exposed to asbestos during this employment.
Location of Exposure
Employer Exposute lob Title Dates
Unknown Slaughterhouse Insulator 1984 (3 weeks)
Sacramento, CA
Job Duties: Plaintiff insulated a tank, Plaintiff recalls disturbing discarded asbestos-containing
cement pipe and pipe insulation debris that was lying on the ground from a recent removal.
Plaintiff currently contends she was exposed to asbestos during this employment.
Lo Location of . Exposure
Employer Exposure Job Title Dates
Northern California Cheese Factory Insulator 1984
Insulation aka Metalclad South Sacramento, CA (3-4 weeks)
Insulation Corporation :
Job Duties: Plaintiff performed duct work. Plaintiff applied calcium silicate pipecovering,
fiberglass pipecovering, insulation cement, black mastic and insulation pads to piping and valves|
Plaintiff assisted insulators using {iberglass to cover pipes. Plaintiff recalls being adjacent to
plumbers and pipefitters removing and distrubing a large piece of existing asbestos-containing
sheetrock, Plaintiff recalls the following co-worker: Norman Jueich, Brayton 4Purcell, LLP;
Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos during her
employment.
Location of Exposure
Employer Exposure . Job Title Dates
NPS Energy Services Rancho Seco Nuclear Insulator 1984-1992
Powerhouse
Herald, CA
Job Duties: Plaintiff installed pipecovering, insulation cement, black mastic and insulation pads
on piping and valves, Plaintiff removed and replaced insulation on generators and inside
pipelines. Plaintiff worked throughout the facility, in the reactor room, Plaintiff was issued and
used a 3M COMPANY single-sirap mask. Plaintiff patched holes on asbestos-containing
insulation on Pipin . Plaintiff removed existing asbestos-containing insulation on piping and
equipment, Plaintiff recalis that BECHTEL (SEQUOJA VENTUI INC.) employees did the
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tear-outs of pipes and other pieces of equipment at night and they would leave the debris over
ec ENTURES INC.
night for the BECHTEL (S.
employees removing and zeplacing
recalls that these were BEC.
QUOIA V!
.) laborers to clean up the next day,
Plaintiff worked adjacent to BECHTEL (SEQUOIA VENTURES INC)
main contractors on the job, Plaintiff recalis BECHTEL (SEQUOIA V!
asbestos-containing gaskets and packing in valves, Plaintiff
employees because she saw them in their trademark white
ipefitters, one of the
TURES INC .
hats. Plaintiff recalls RANCHO SECO employees swept'and cleaned asbestos-containing debris
including récently removed asbestos-containing pipecovering, Plaintiff recalls the following
supervisors: Rick Bartel, address unknown; Ron Vandemeer, address unknown. Plaintiff recalls
the following co-workers: Wiley Utterback, c/o Brayton%*Purcell LLP; Phil Black, address
unknown; Robert Calvillo, c/o Brayton Purcell LLP; Thomas Begley c/o Brayton “Purcell,
LLP, Plaintiff currently contends she was exposed to asbestos during: this employment.
Employer
Northern California
Insulation aka Metalclad
Insulation Corporation
Location of
Exposure
Lassen College
Waste Incinerator
Susanville, CA.
* Job Title
Insulator
Exposure
. Dates
1985
(6 months)
Job Duties: Plaintiff worked on new construction. Plaintiff applied thermal insulation to piping,
Plaintiff recalls Lassen College was constructing a new garbag
e burning power plant used to
create electricity. During the construction, the plant had various tests known as the “blowdown’
and “fire up” process. Plaintiff recalls that new CRANE CO. valves were installed prior to each
test, and removed. New CRANE CO. valves were always installed before each test. Plaintiff
recalls working adjacent to pi
SEALING TECHNOLOGIES,
efitters removing and replacing GARLOCK
LLC) gaskets and packing on new CRANE
GARLOCK
‘O. valves durin;
‘these tests. Plaintiff recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP;
Gene Cosby, deceased; Dean White, deceased; Steve Bass, c/o Brayton Purcell, LLP, Plaintiff
currently contends she was exposed to asbestos as result of her employment.
Employer
Northern California
Insulation aka Metalclad
Insulation Corporation
Location of
Exposure
WalMart
Hammer Lane
Stockton, CA
Job Title
Insulator
Exposure
Dates
1985; 1986
Job Duties; Plaintiff worked on new construction, Plaintiff installed pipecovering on pipelines.
Plaintiff is currently unaware if she was exposed to asbestos during this employment,
Employer
Northern California
Insulation aka Metalclad
Insulation Corporation
Location of
Exposure Job Title
WalMart Insulator
Fresno, CA
Exposure
1985; 1986
Job Duties: Plaintiff worked on new construction. Plaintiff installed pipecovering on pipelines.
Plaintiff is currently unaware if she was exposed to asbestos during this employment.
Employer
KAlnjured\] O86888i-sacsf Lwpd
Location of
Exposure Job Title
14
Exposure
DatesoD Oe NDA B® WN
LN
33
Northern California Corn Products Insulator 1985
Insulation aka Metalclad Stockton, CA (2-3 months)
Insulation Corporation
Job Duties: Plaintiff insulated tanks. Plaintiff removed existing asbestos-containing
pipecovering. Plaintiff replaced pipecovering with calcium silicate pipecovering. Plaintiff
removed and replaced insulation on pipelines going to and from an ALLIS-CHALMERS
generator. Plaintiff worked adjacent to other insulators tearing out pre-existing asbestos-
containing insulation manufactured by OWENS CORNING FIBERGLAS Kaylo that had been
installed & Northern California Insulation aka Metalclad Insulation Corporation insulators on a
prior job. Plaintiff worked adjacent to pipefitters gemoving and replacing valves on the piping
oing to the generator, Plaintiff recalls ALLIS-CHALMERS (ALLIS-CHALMERS
CORPORA’ ION PRODUCT LIABILITY TRUST) generator technicians repairing the
generator. Plaintiff worked adjacent to a large JOHNS-MANVILLE transite pipe that had been
recently removed by CORN PRODUCTS, employces and discarded in the mi idle of the jobsite
between the tanks they were insulating, Plaintiff recalls that the JOHNS-MANVILLE asbestos-
containing pipe was regularly disturbed by all contractors on the site because it was in the middle,
of the construction area. Plaintiff worked adjacent to CORN PRODUCTS employees sweeping
and cleaning asbestos-containing debris, Plaintiff recalls the following co-workers; Norman
Juelch, c/o Brayton + Purcell, LLP; Bob Wadley, deceased; Gene Cosby, deceased; Steve Bass,
c/o Brayton*Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of
this employment.
Location of Exposure
Employer Exposure Job Title Dates
Northern California Modules Alaska Insulator 1985
Insulation aka Metalelad Stockton, CA (Apprentice) (4-5 months)
Insulation Corporation
Job Duties: Plaintiff provided pipecovering, fiberglass, foam Blass, and mastics to insulators.
Plaintiff was adjacent to pipefitters cutting and installing GARLOCK gaskets, and installing
asbestos-containing packing in valves. Plaintiff recalls the following coworkers: Norman Juelch,
Brayton “Purcell, LLP; “Scotty,” Steve Bass; Brayton Purcell, LLP; Gene Crosby, deceased;
Bob Wadley, deceased. Plaintiff currently contends she was exposed to asbestos during this
employment. .
PARA- OCCUPATIONAL EXPOSURE:
Plaintiff resided with her first husband John Chambers. Plaintiff's ex-husband regularly returned
home with asbestos-containing debris on his clothing, Plaintiff recalls shaking out and washing
his work clothes in the garage.
Plaintiff's husband’s work history is as follows:
Location of Exposure
Employer Exposure Job Title Dates
Dinuba Distributing Dinuba Distributing Mechanic 1971-1977 :
Stockton, CA Stockton, CA
Job Duties; Plaintiff's ex-husband performed brake and engine repairs on fleet trucks. Plaintiff
currently contends she was exposed to asbestos as a result of her ex-husband’s employment.
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Plaintiff has resided with her husband Norman Juelch Sr., local 16 insulator since 1981. Plaintiff
was exposed to asbestos-containing materials by washing her husband's laundry after work.
aintiff recalls her husband frequently returned home with asbostos-containing debris and dust
on his clothes from the jobsite. Plaintiff shook out her husband’s dusty clothes before washing
em in the garage. Plaintiff recalls vacuuming her husband’s car which he drove to and from
work on a daily basis. :
ow
Plaintiff's husband’s work history is as follows:
Location of Exposure
Employer | ’ Exposure Job Title
lant Insulation Company Various commercial and Insulator 1981-1983,
industrial buildings 1985
including:
ow
Job Duties: Plaintiffs husband applied pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation strewn on the ground in his work area,
aintiff’s husband recalls working with the following co-workers throughout his employment
with Plant Insulation: Steve Steele, Concord, California; and Carl Ramsey, c/o Brayton%Purcell
LLP. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment,
7
Location of Exposure
Employer, Exposure lob Title Dates
Owens Coming World Various locations Insulator 1981-1985
Headquarters including: . (6-7 months)
1 Owens Coming Pkwy Sierra Pacific Power Co.
Toledo, OH 43659 Valmy Power Station
Valmy, NV
Job Duties: _ Plaintiff's husband applied thermal insulation during construction of Unit J of the
Valmy Powerhouse, While working at the valiny, Powerhouse, plaintiff's husband insulated
pipes with board glass and pipecovering. Plaintiff's husband recalis working near laborers
sweeping up the site and near ironworkers, carpenters and pipefitters who were installing valves,
gaskets and pipes. Plaintiff's husband worked alongside technicians who were disassembling,
and repairing a GENERAL ELECTRIC (GENERAL ELECTRIC COMPANY) generator,
Plaintiff's husband worked near others who were installing, new CRANE CO, valves and
checking packing. Plaintiff's husband observed these pipe itters installing and removing
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets on the CRANE CO.
valve flanges. Plaintiff's husband recalls the following supervisor: Car! Ramsey c/o
Brayton%*Purcell LLP. Plaintiff's husband recalls the following co-worker: Gene Cosby,
deceased. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment.
Location of . Exposure
Employer Exposure Job Title Dates
Pioneer Insulation Contractor Unknown Insulator 1981
c (1 week)
2085 Boxwood Wa
Fremont, CA 9453
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Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area.
Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment. .
Location of Exposure
Emplover Exposure Job Title Dates
Plant Insulation Company PG&E, Unit 1 Insulator 1982
Pittsburg, CA (3 weeks)
Job Duties: Plaintiff's husband applied | pipecovering, insulation cements, and black mastic to
boiler piping, Plaintiff's husband worked near boilermakers who were rebuilding a boiler.
Plaintiff's husband recalls working adjacent to pipefitters who were tearing out pipes and
installing new pipes and valves. Plaintiff's husband observed tradesmen removing brick and
refractory from the Unit 1 boiler. PG&E (PACIFIC GAS & ELECTRIC COMPANY) personnel
sycpt and cleaned asbestos-laden debris in his presence. PG&E (PACIFIC GAS & ELECTRIC
COMPANY) personne! inspected and approv plaintiff's husband insulation work. Plaintiff's
husband insulated the fittings with insulating cement. Plaintiff currently contends she was
exposed to asbestos as a result of her husband’s employment.
. Locationof Exposure
Employer Exposure Job Title Dates
Plant insulation Company Tosco Oil, Insulator 1982-1984
. Avon, CA (2 months)
Job Duties: Plaintiffs husband applied calcium silicate pipgcoverin io steam and process
piping and valves throughout the refinery. Plaintiffs husband applied insulation cements,
¢ RON (CHEVRON U.S.A. INC.) covercote (G-I HOLDINGS, INC.) black mastic, Zeston
fittings and adhesives. Plaintiffs husband was provided with insulation from old boxes obtained
from stocks on the TOSCO (TOSCO REFINING COMPANY, INC.) premises. Plaintiff's
husband tied into existing asbestos insulation. Plaintiff's husband observed TOSCO (TOSCO
REFINING COMPANY, INC.) personnel sweeping, blowing, and cleaning asbestos-laden
pipecovering gasket scraps and other debris in his work areas. Plaintiffs husband recalls co-
workers: Hank Freeman, c/o Brayton®*Purcell LLP; John Murphy, c/o Brayton%+Purcell LLP;
Ken Goforth, c/o Brayton¢Purcell LLP; Larry Sublet, c/o Brayton%*Purcell LLP; and Don
Bass, c/o Brayton%Purcell LLP. Plaintiff's husband worked alongside Pipefitters employed by
BECHTEL (SEQUOIA VENTURES INC? who were removing and installing valves and gasket
in his work areas. Plaintiff's husband recalls the following su isor: Steve Steele, Concord,
California. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment.
Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company —_ Union Oil Insulator 1982-1983
Oleun/Rodeo, CA :
Job Duties: Plaintiff's husband applied Pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plaintiffs husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area.
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Plaintiff's husband insulated oil tanks and pipes, Plaintiff currently contends she was exposed to
asbestos as a result of her husband’s employment.
Location of Exposure
Employer : Exposure Job Title Dates
Plant Insulation Company El Dupont de Nemours & Insulator 1982-1985
. 0. .
Antioch, CA
Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area,
Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment.
. Location of . Exposure
Employer : Exposure Job Title Dates
Plant Insulation Company Dow Chemical Insulator 1982-1985
Pittsburg, CA
Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass
pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously
removed asbestos-containing pipe insulation that was strewn on the ground in his work area,
Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment,
Location of Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Shell Oil Insulator 1983-1984
1300 - 64" St. Martinez, CA (1 month}
Emeryville, CA 94662
Job Duties; Plaintiff's husband applied pipecovering insulation to piping. Plaintiff's husband
worked alongside various trades, including welders, laborers, crane operators, and stage riggers.
Plaintiff's husband worked alongside DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A.
INC.) pipefitters who were installing 8 to 10 new CRANE CO. valves along with GARLOCK
G. CK SEALING TECHNOLOGIES, tLe flange gaskets, which were wired onto those
valves when delivered. Plaintiff currently contends she was exposed to asbestos as a result of her
husband’s employment.
Location of Exposure
Employer Exposure Job Title Dates
Fruin-Colnon Crop. Procter & Gamble, . Insulator * 4982
1299 Clayton Road W. Sacramento, CA (1 month)
Ballwin, MO
Job Duties: Plaintiffs husband recalls performing maintenance and repairs. Plaintiff's husband
recalls working with and around old insulation. Plaintiff's husband recalls the site was very
KAlnjured\OB6RB\0i-saosf I.wpd 18ww ON A PBN
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BNRRRBBEREBSEeETDABEBHE S
. Plaintiff recalls the following co-worker; Robert Calvillo, efo Brayton**Purcell LLP.
Pai currently contends she was exposed to asbestos as a result of her husband's
employment. :
Location of . Exposure
Employer: Exposure _ Job Title Dates
Fruin-Colnon Crop. Louisiana Pacific Insulator 1983
1299 Clayton Road W. gp mill (6 weeks)
Ballwin, MO amoa, CA
Job Duties: Plaintiff's husband applied pipecovering, insulation cements, and black mastic
while completing remodel work stanled by.a non-union crew. Plaintiff's husband observed
previously removed asbestos-containing ipe insulation that had been piled up in boxes in his
work areas, Plaintiff's husband worked alongside various trades, includin, millwrights,
machinists, laborers, and maintenance Pee Je employed by LOUISIANA PACIFIC
UISIANA PACIFIC CORPORAT: ON) who were handling and/or cleaning up asbestos-
aden dust and debris. Plaintiff's husband also worked near pipefitters who were employed by
an outside mechanical contractor, Plaintiff currently contends she was exposed to asbestos as a
result of her husband’s employment. .
Location of Exposure
Employer Exposure b Title Dates
Plant Insulation Company Roman Meal Bread Factory Insulator 1983
South San Francisco, CA (approx. 1 week)
Job Duties: Plaintiff's husband worked near employees taking insulation off of the ovens and
recalls the insulation falling and hitting the floor and kicking up dust clouds. Plaintiff's husband
recalls that the debris was picked up and disposed of in a dumpster outside, Plaintiff's husband
recalls that it was very dusty despite use of wet-down techniques. Plaintiff currently contends
she was exposed to asbestos as a result of her husband’s employment.
Location of Exposure
Employer Exposure Job Title Dates
Metalclad Insulation Campbell Soup Insulator 1983-1985
Corporation . Sacramento, CA
2198 S Dupont Dr
P.O, Box 61024
Anaheim, CA 92803
Job Duties: Plaintiff's husband worked at Campbell Soup multiple times. Plaintiff's husband
recalls insulating tanks. Plaintiff's husband performed paiches to pipes that had existing
insulation. Plaintiff's husband recalls working near welders who were using welding blankets.
Plaintiff's husband recalls the following co-workers: Mel Swanson, c/o Brayton*Purcell LLP;
Maurice Lawrence, c/o Brayton¢+Purcell LLP. Plaintiff currently contends she was exposed to
asbestos as a result of her husband’s employment. :
Empl Location of _ . Exposure
mployer Exposure Job Title Dates
KAMnjured O868Btai-saosf Vwpd 19eo oe WN DA HH WN
10
Metalclad insulation Corp. _— Pacific Bell Insulator 1983-1985
2198 S, Dupont Drive Stockton, CA . (3 weeks)
P.O. Box 61024 :
Anaheim, CA 92803 .
Job Duties: Plaintiff's husband applied fiberglass insulation to piping and valves at a Pacific
Bell Telephone building located a few blocks north of downtown Stockton. Plaintiff currently
contends she was exposed to asbestos as a result of her husband's employment.
: Location of . . Exposure
Employer - Exposure Job Title Dates
Metalclad Insulation Corp, Lassen College Insulator 1983-1984
2198 South Dupont Drive Waste Incinerator (6 months)
P.O, Box 61024 Susanville, CA
Anaheim, CA .
Job Duties: Plaintiff's husband applied new thermal insulation to piping, valves and fittings
during new construction of a garbage burning power plant alongside Lassen College, near
Susanville, California, During the “blowdown” process, when an attempt was made to “fire up”
the new power plant, plaintiff observed pipefitters removing Original Equipment Manufacturer
flange gaskets from CRANE CO, valves. The gaskets were thereafter re-installed after the
“blowdown” test was completed, Plaintiff’s husband observed various new CRANE CO, valves
being delivered on pallets, with the flange gaskets already wired to the CRANE CO. valves.
Plaintiff's husband recalls coworkers: Gene Cosby, address unknown; and Dean White, address
unknown, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s
employment. ..
Location of Exposure
Employer Exposure Job Title Dates
Metalclad Insulation Corp. Shell Oil Insulator 1984-1985
2198 S. Dupont Drive Martinez, CA (2 months)
P.O, Box 61024
Anaheim, CA 92803
Job Duties: Plaintiff's husband applied KAYLO (OWENS CORNING FIBERGLAS) calcium
silicate pipecovering, fiberglass pipecovering, insulation cement, black mastic and insulation
pads to piping and valves. Plaintiff's husband re-installed asbestos-containing insulation pads
that had previously been removed by other workers. Plaintiff currently contends she was exposed
to asbestos as a result of her husband’s employment. .
oo Location of Exposure
Employer Exposure . Job Title Dates
Metalclad Insulation Corp. Corn Products Insulator 1984-1985
2198 S. Dupont Drive Stockton, CA . (3-4 months)
P.O, Box 61024
Anaheim, CA 92803
Job Duties: Plaintiff's husband applied calcium silicate pipecovering, boardglass, white
adhesive, fabglass, black mastic, insulation cements, and aluminum jacketing to piping and
tanks. Plaintiff s husband repaired existing damaged asbestos-contai ning insulation, Plaintiff's
husband worked in close proximity to other trades, including welders, pipefitters, generator
KAlnjured FOS688\ai-snest J .wpd - 20Om WD hh BW Ww
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11
technicians, sheetmetal workers, electricians, and laborers. The laborers were dismantling
scaffolding that was laden with debris from the removed asbestos-containing ipecovering.
Plaintiff's husband observed ALLIS CHALMERS (ALLIS-CHALMERS C ORATIO
PRODUCT LIABILITY TRUST) generator technicians repairing an existing ALLIS
CHALMERS (ALLIS. CHALMERS CORPORATION PRODUCT LIABILITY TRUST)
generator. ALLIS CHALMERS (ALLIS-CHALMERS CORPORATION PRODUCT
LIABILITY aRus pipefitters were installing new CRANE CO, valves in plaintiff's husband
work areas, Plaintiff's husband recalls the following co-workers: Bob Wadley, deceased; and
Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos as a result of hey
husband’s employment. :
Location of : Exposure
Employer Exposure Job Title Dates
Plant Insulation Company Hormel Meat Packing Insulator 1984
Stockton, CA (2 weeks)
Job Duties: Plaintiff's husband removed asbestos insulation from pipes and then re-insulated the
pipes with cal sil insulation. Plaintiff's husband recalls that the site was very dusty. Plaintiff
currently contends she was exposed to asbestos as a result of her husband’s employment,
. Location of Exposure
Employer Exposure Job Tile Dates
Plant Insulation Company Sequoia Hospital Insulator 1984
Reawood City, CA :
Job Duties: Plaintiff's husband applied calcium silicate pipecovering to new biping in an
existing hospital. Plaintiff's husband observed other trades employed by REDWOOD
PLUMBING (RED WOOD PLUMBING CO., INC.) removing asbestos-containing pipecovering
and insulated piping which created large amounts of visible dust, which plaintiff's husband
reported to Local No. 16 Business Agent Ed Story, deceased. Plaintiff currently contends she
was exposed to asbestos as a result of her husband’s employment.
Location of Exposure
Employer Exposure Job Title Dates
Metalclad Insulation Corp. | Modules - Alaska Insulator 1985
2198 S. Dupont Drive Stockton, CA “ (4-5 months)
P.O, Box 61024 :
Anaheim, CA 92803
Job Duties: Plaintiff's husband applied urethane, fiberglass, insulation cements, Zeston fittings,
and aluminum jacketing to piping of portable, pre-fabricated dwellings and equipment.
Plaintiff's husband worked al ongside various trades, including laborers who were sweeping and
cleaning dust and debris created by all the other trades, pipefitters whe were fabricatin & Ns
and handling CRANE CO. valves and GARLOCK (GARLOCK SEALING TECHN OL GIES,
LLC) gaskets, carpenters, electricians who were handling electrical boxes and insulated wire,
sheetmetal workers, welders, ironworkers, and concrete workers, Plaintiff currently contends she
was exposed to asbestos as a result of her husband’s employment.
Location of Exposure
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Employer Exposure Job Title Dates
N.P.S. Energy Services Inc.; Rancho Seco Nuclear Insulator 1986-1988
Dravo Constructors Inc. Powerhouse
11 Stanwix St. Herald, CA.
Pittsburg, PA
Job Duties: Plaintiff's husband removed Pi ccovering to make repairs to the insulation.
Plaintiff's husband recalls that BECHTE! SEQUOL VENTURES INC.) employees did the
tear-outs of pipes and other pices of equipment at night and they would leave the debris over
night for the BECHTEL (SEQUOIA VENTURES INC.) laborers to clean up the next day. This
debris included asbestos-containing KAYLO (owens CORNING FIBERGLAS) pipecovering,
GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gasket debris, electrical boxes
and associated wiring and switches, piping scraps, and other debris. Plaintiff's husband recalls
sweeping up debris. Plaintiff's husband worked alongside mechanics who were rebuilding two
CATERPILLAR (CATERPILLAR, INC) diesel engines, which involved replacement of the
engine gaskets. Plaintiff's husband recalls the following supervisors: Rick Bartel, address
own; Ron Yandemeer, address unknown. Plaintiff's husband recalls the following co-
workers: Wiley Utterback, Sacramento, California; Phil Black, address unknown; Tom Begley,
clo Brayton’ Purcell LLP; Robert Calvillo, c/o Brayton%+Purcell LLP. Plaintiff currently
contends she was exposed to asbestos as a result of her husband’s employment.
NON-OCCUPATIONAL EXPOSURE!
Plaintiff recalls assisting her first husband John Chambers, building a house in Stockton,
California in the early 1970s, Plaintiff recalls rabcing. applying and sanding asbestos containing
KAISER GYPSUM COMPANY, INC, and HAMILTON MATERIALS, INC. all-purpose joint
and taping compounds purchased from 84 LUMBER in Stockton, California.
Plaintiff recalis assisting, and being in proximity to, her first husband, John Chambers, while he
worked on an early 1970's FORD MOTOR COMPANY Mustang replacing brake drums and
VICTOR (DANA COMPANIES, LLC (FKA DANA CORPORATI ™) askets purchased at
NAPA AUTO PARTS and CHECKER AUTO PARTS, INC. (CSK' Al 5: INC.) which are
both located in Stockton, California.
Plaintiff recalls assisting her second husband Norman Juelch, Sr., remove and replace brakes on
used.1977 FORD F-250, in the early 1980s. Plaintiff recalls purchasing the brake pads at NAPA
AUTO PARTS, Kalispell, Montana,
Plaintiff currently contends she was exposed to asbestos during these activities.
Plaintiffs investigation and discovery are continuing.
27: Yes.
a-b, Asbestos Workers Local #16, 1320 Harbor Bay Parkway, Suite 220,
Alameda, California 94502. u
28. Plaintiff recalls first learning exposure to asbestos was a potential health hazard in
approximaterly 1983,
29, Plaintiff recalls first learning exposure to asbestos was a potential health hazard
when she read material regarding asbestos, and was taught at School for Insulation.
KAlnjured\08638ai-suosf I_wpd 22Co oe UN A AW Pe HN
30, Plaintiff recalls first observing others using safety precautions when working
around asbestos or asbestos-containing materials in approximately 1984,
31, _ - Plaintiff recalls first using safety precautions when working around asbestos or
asbestos-con
Preview
27 28 GEORGE D. YARON, ESQ. (State Bar #96246) . KEITH E. PATTERSON, ESQ. (State Bar #225753) MICHAEL J. PENG, ESQ. (State Bar #260852) YARON & ASSOCIATES 601 California Street, 21" Floor San Francisco, California 94108-2281 Telephone: (415) 658-2929 Facsimile: (415) 658-2930 Attorneys for Defendant 84 LUMBER COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH and NORMAN JUELCH, SR., Plaintiffs, v. DOES 1-8500, ) ) ) ) ) : ASBESTOS DEFENDANTS (BP) and ) ) ) ) Defendants. ) ) ) ) ELECTRONICALLY FILED Superior Court of Califor pe County of San Francis DEC 07 2009. GORDON PARK-LI, Clerk BY: ALISON AGBAY Deputy Plerk CASE NO. CGC-09-275212 EXHIBIT C THROUGH GTO DECLARATION OF MICHAEL J. PENG IN SUPPORT OF 84 LUMBER COMPANY’S OPPOSITION TO PLAINTIFFS’ MOTION FOR TRIAL PREFERENCE Date: December 22, 2009 Time: 9:30 a.m. Room: 206 Judge: ° Hon. James J. McBride Action Filed: May 20, 2009 Trial Date: Not AssignedEXHIBIT CBRAYTON®PURCELL LLP ATTORNEYS ATLAW 222 RUSH LANDING ROAD PO BOX 6169 NOVATO, CALIFORNTA 94948-6169 (415) 898-1555 Ce Wa Aw fF WD ALAN R. BRAYTON, ESQ,, S.B. #73685 ERIC C. SOLOMON, ESQ., S.B. #119131 BRAYTON*®*PURCELL LLP Attorneys at Law 222 Rush Landing Road P.O. Box 6169 Novato, California 94948-6169 (415) 858-1555 Attorneys for Plaintiffs SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO JOYCE JUELCH and ) ASBESTOS NORMAN JUELCH, } No. 275212 Plaintiffs, ANSWERS TO INTERROGATORIES vs. ASBESTOS DEFENDANTS (BP). PROPOUNDING PARTY: . STANDARD ASBESTOS CASE INTERROGATORIES RESPONDING PARTY: Plaintiff JOYCE JUELCH SET NO; ONE ANSWERS JOYCE JUANELL JUBLCH. September 18, 1946, 62 years old, SB of oF Pp French Camp, California. e 19581 Feather Falls Place, Cottonwood, California 96022. £ Height: 5'7 1/2"; Weight: 169 Ibs. g 569-68-7847, h. None. KAnjured\] 08688\01-sacsf Lwpd 1CON Dw Bw wD Se ee WN es & 14 u None. None, RO494625; California. Joyce Johnson; Joyce Chambers. Plaintiff completed the 12th grade, Norman E. Juelch, Sr. June 13, 1945. February 14, 1981. _ 19581 Feather Falls Place, Cottonwood, California 96022. Retired. Bruce Johnson; John Chambers. 1963; 1967. Plaintiff's marriage to Bruce Johnson was dissolved in 1967 due to infidelity. Plaintiff's marriage to John Chambers was dissolved in 1978 due to infidelity. 2, s PF m Ff & © K:Ainjured\! 08688lai-su0sf Lwpd Terresa Reyes, November 14, 1963. Natural. 5035 Zuning Avenue, Corning, California 96021, Housewife, Living. Nina L. Reberson. December 7, 1964, Natural. 4809 Montaro Court, #D, Bakersfield, California 93307. Retired, Living.wow oN AW FF WN aD OK FS 16 ren " Jessica Hayes, August 17, 2000. c Granddaughter, Plaintiff has legal custody of this child. da 19581 Feather Falls Place, Cottonwood, California 96022. , P e Child is aminor, £ Living. No. None. Plaintiff is currently able to recall the following addresses: 12/1981 to 1983: Evergreen, Stockton, California 95205. 1983 to 1984: Post Office Box 515, Sutter Creek, California, 1985 to 1988: McAtee Road, Valley Springs, California. 1988 to 1990; 23522 Shake Ridge Road, unknown city, California, 1990: 5758 Cora Post Road, Lodi, California. 1990: 1955 Emmon Canyon Road, Kila, Montana. 1991 to 1994: 2237 Highway 28, Hot Springs, Montana. 1994 to 2004: Newlin Road, Marion, Montana 59925, 2004: Silver Butte Road, Libby, Montana 39925, . 2005: 349 Trainer Street, Libby, Montana. 2006: 2090 Loleta Avenue, Corning, California. 2006 to present: 19581 Feather Falls Place, Cottonwood, California 96022. Plaintiff completed the 12th grade. May 27, 2009. No. No. Excluding plaintiff's expert consultants, plaintiff recalls the following physicians: a. Dr. Gills. b, Redding, California. KAlnjured\0B68B\ai-sacst b.wpd. 3eC Oe TY DA A ek YN me a 0 6 ADA A PR WN | SD G Plaintiff currently does not recall. Plaintiff's investigation and discovery are continuing. d, January 2009. &, Heart attack, f. Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. Dr. Luperpio. b. Redding, California, &. Plaintiff currently does not recall, Plaintiff's investigation and discovery , are continuing, d.- January 2009. e Heart attack. fi Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a, - Dr. Hahns. b. MD Imaging, Redding, California, c Arterial dopler performed on lower extremities. d. February 5, 2009. . e, Plaintiff currently does not recall. Plaintiff's investigation and discovery are continuing, : : £ Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a Plaintiff currently does not recall. b, + Open System Imaging, Redding, California. c, .Dopler performed. KAlnjured\08688\ai-sacs? | wpd 4Oo wo DW Aw B® WY NY YN N NR YM YN Pe Be ee Se ee Be Se amd A A BE HD & SO we ww HA HA FB WY = DO d. February 19, 2009. . & Plaintiff currently does not recall. Plaintiff's investigation and discovery are continuing. £ Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a Dr. Balazer. b. Cottonwood Clinic, Cottonwood, California. c. Arterial dopler performed on lower extremities. d. March 3, 2009. . €. Plaintiff currently does not recall, Plaintiffs investigation and discovery are continuing. : f£ Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a Plaintiff currently does not recall, Plaintiff's investigation and discovery are continuing, b. MD Imaging, Redding, California. CT of abdoman and pelvis. d, March 11, 2009, e. Plaintiff currently does not recall, Plaintiff's investigation and discovery are continuing. f. - Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. , a Plaintiff currently does not recall. Plaintiffs investigation and discovery are continuing, b. MD Imaging, Redding, California. KAlnjured WOBGERzisa0sf Iwpd 5ew oN A wm BY N © , CT of chest without contrast, d. March 12, 2009. e Plaintiff currently does not recall. Plaintiff's investigation and discovery are continuing. f Plaintiff has provided. authorizations for the release of medical records to Berry & Berry, Defendants may obtain copies of records through Berry & Berry. a. Dr. Dhanuha. _ be Redding, California. c. Office visit. d. March 17, 2009, a Plaintiff was given the results of her tests. Plaintiff was advised that she ‘had cancer. £. Plaintiff has provided authorizations for the release of medical records to Berry & Berry, Defendants may obtain copies of records through Berry & Berry. a Dr, Luperpio. b, Redding, California, ¢. Pulmonology. d March 18, 2009, & Plaintiff currently does not recall. Plaintiff's investigation and discovery are continuing. - : fi Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a Dr, Karem. b. Redding, California. c-e. Plaintiff currently does not recall. Plaintiff's investigation and discovery KAlnjytod\l O8688\ni-snesf lLwed 6oon aA uw BR WN are continuing. f. Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. a: Dr, Dhanuha, b. Redding, California. ‘ ce Plaintiff receives chemotherapy. d. Presently, e Cancer. £ Plaintiff has provided authorizations for the release of medical records to Berry & Berry. Defendants may obtain copies of records through Berry & Berry. 11, Excluding those used by plaintiff's expert consultants, plaintiff currently recalls the following hospitals: a. Mercy Hospital. b. Redding, California. G Plaintiff was hospitalized due to heart problems. An angiogram was done, and 2 stints were put in, d. December 31, 2008. @ Stroke, f, Plaintiff has provided authorizations for the release of medical records to ‘Berry & Berry. Defendants may obtain copies of records through Berry & Berry. 12. Excluding any taken by plaintiff's expert consultants, plaintiff recalls the following x-rays and CT scans: Please see response to Interrogatory Numbers 10 and 11, above. This information is as complete as plaintiff can recall at this time and includes all treatment by plaintiff's healthcare providers. Plaintiff's investigation and discovery are continuing. 13. Excluding anny taken by plaintiff's expert consultants, plaintiff recalls the following pulmonary function tests: Please see response to Interrogatory Numbers 10 and 11, KAlnjurecMOB68B\xi-sacsf Lwpd 7oO DD A Be WwW a. Plaintiff currently does not recall. Plaintiff's investigation and discovery “are continuing. b. No cessation. e None that plaintiff is aware of. d. ~_ Plaintiff contends that his lungs have primarily been affected. However, above. This information is as complete as plaintiff can recall at this time and includes all treatment by plaintiff's healthcare providers. Plaintiff's investigation and discovery are continuing. . 14, Please see response to Interrogatory No.'s 10 and 11, above. Plaintiff defers to his medical records as the best source of information for medications prescribed, 15. Notat this time. Plaintiff's medical records are equally available to defendants through Berry & Berry, designated defense counsel. 16, Plaintiff has the following complaints from asbestos exposure: breathing difficulties, fatigue, loss of stamina. as lung function affects the rest of the body, plaintiff contends that all parts of her body have been affected, , ~ & Please refer to Interrogatory No. 10 and 11, above. f Please refer to Interrogatory No, 10 and 11, above, 2 Plaintiff does not at this time contend that she has lost time from work as a| result of her asbestos-related conditions. Plaintiff's investigation and discovery are continuing. h. Not applicable. : i, Plaintiff does not at this time have any documents responsive to this Interrogatory. Plaintiff's investigation and discovery are continuing. 17. Excluding information protected by either the attorney work-product doctrine or the attorney-client privilege, no. 18. No. 19. Plaintiff suffers from shortness of breath. 20. No. KAlnjurcd\08688\ai-sacsP ).wpd 8wo em WAH BW Wm Ww Ne S 14 21. Plaintiff's investigation and discovery are continuing. 22. No. 23. Yes, a. Plaintiff recalls smoking from approximately 1965 to present. db Plaintiff recalls smoking cigarettes. c Plaintiff recalls smoking 10 to 20 cigarettes per day. d Plaintiff recalls smoking 1/2 to 1 pack of cigarettes per day. e Plaintiff recalls smoking Marlboro brand cigarettes. f. Yes, : 1. Dr. Dixon. 2. Approximately 1995, 24. Yes, a. Plaintiff's husband, Norman Juelch. b, 1981 to present. 2 Camel and Marlboro brand cigarettes, a Approximately 1 pack per day. 25. No. : , 26. Plaintiff is currently able to identify the following employment information: Location of Exposure Employer Exposure Job Title Dates . Foster Freeze Foster Freeze Cook 1963 Stockton, CA * Stockton, CA Job Duties: Plaintiff worked at a hamburger restaurant. Plaintiff is currently unaware if she was exposed to asbestos during this employment. Location of Exposure Employer Exposure Job Title Dates Dameron Hospital Dameron Hospital Nurse 1964-1974 Stockton, CA Stockton, CA Job Duties: Plaintiff performed general nursing duties throughout the intensive care unit, the emergency units and medical surgery departments. Plaintiff recalls during the early 1970s the hospital underwent a remodel, Plaintiff recalls walking through a construction site everyday. KAlnjured\08688\ei-sa0sf I.wpd 9oOo wT TDA Re WwW LY 10 Plaintiff walked directly adjacent to drywallers hanging KAISER GYPSUM COMPANY, INC. drywall and applying and sanding KAISER GYPSUM COMPANY, INC. asbestos-containing joint compounds. Plaintiff recalls drywallers hung up plastic shects to contain debris, but plainti recalls dust frequently came through the sheets. Plaintiff recalls walking adjacent to sheetmetal workers installing duct work in the ceiling, disturbing asbestos-containing acoustical materials that had been recently applied by drywallers. Plaintiff currently contends she was exposed to asbestos during this employment. Location of , Exposure Employer Exposure Job Title Dates Naval Supply Depot Naval Supply Depot Janitor 1966 Stockton, C Stockton, CA . .Job Duties: Plaintiff cleaned offices and bathrooms throughout the facility. Plaintiff recalls the offices had asbestos-containing ceiling tiles that were falling apart, and frequently feli onto the floor, Plaintiff recalls sweeping and eleaning up asbestos acoustical ceiling tiles after they were on the floor. Plaintiff currently contends she was exposed to asbestos during this employment. Location of Exposure Employer Exposure Job Tit! Dates San Joaquin General Hospital San Joaquin General Nurse 1975-1976 French Camp, CA Hospital French Camp, CA 4" Bloor Job Duties: Plaintiff worked as a nurse throughout the emergency room and intensive care units on the pround fourth floor of this hospital. Plaintiff recalls that the hospital underwent a remodel. Plaintiff recalls contractors removed and replaced asbestos-containing ceiling tiles. Plaintiff was in proximity to workers disturbing fireproofing during the construction, Plaintiff recalls there was debris ihroupghout the site from the removal of the ceiling tile which was not cleaned up very quickly, Plaintiff currently contends she was exposed to asbestos during this employment. Location of Exposure Employer Exposure Job Title Dates Unknown Family Doctor Unknown Doctor’s office Nurse 1976-1980 Stockton, CA Stockton, CA - : Job Duties: Plaintiff worked for a family doctor assisting him with patients. Plaintiff is currenth unaware if she was exposed to asbestos. during this employment. Location of : Exposure’ Employer Exposurt Job Title Dates Plant Insulation Company Tosco Oil, Insulator 1982-1984 Avon, CA (Apprentice) {2 months) . Job Duties: Plaintiff assisted insulators insulating tanks and removing existing asbestos- containing pipe insulation when performing repairs. Plaintiff used, and was in proximity to other KAInjured\O86B8\ab-snosf V.wpd 10Co OWA HW Bw 10 workers using, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B. FULLER COMPANY) fibrous adhesive. Plaintiff was issued and used a 3M COMPANY single-strap mask. Plaintiff cut and provided pipe insulation to insulators as well as insulation cements. Plaintiff swept and cleaned op asbestos-containing insulation that was removed by _ insulators in her crew. Plaintiff worked adjacent to TOSCO OIL, laborers sweeping and cleaning up debris discarded by TOSCO OIL personnel during repairs, which was scattered throughout the| facility, Plaintiff worked adjacent to BECHTEL GE UOIA 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) pipefitiers due to their uniforms. Plaintiff worked in proximity te THE INDUSTRIAL MAINTENANCE ENGINEERING CONTRACTORS contractors who knocked asbestos insulation from piping and swept up asbestos-containing materials from the floor. Plaintiff recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP; Hank Freeman, c/o Brayton*Purcell LLP; John Murphy, c/o Brayton#*Purcell LLP; Ken Goforth, ¢/o Brayton#*Purcell LLP; Larry Sublet, c/o Brayton*Purcell LLP; and Don Bass, c/o Brayton%Purcell LLP; Steve Steele, Concord, California. Plaintiff currently contends she was: exposed to asbestos during this employment. Location of . Exposure Employer Exposure . Job Title Plant Insulation Company Dow Chemical Insulator 1982-1983 Pittsburg, CA (Apprentice) (3 weeks) Job Duties: Plaintiff assisted insulators insulating tanks, chemical lines and valves. Plaintiff was adjacent to the disturbance of existing asbestos-containing pipe insulation by pipefitters, insulators and other tradesmen working in the vicinity. Plaintiff used, and was in b proximity to other workers using, BENJAMIN FOSTER DIVISION OF AMCHEM PRODUCTS, INC. (H.B. FULLER COMPANY) fibrous adhesive. Plaintiff was issued and used a 3M COMPANY single-strap mask. 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 plaintiff, Plaintiff was in proximity to SAFEWAY STEEL PRODUCTS (SCOTT TECHNOLOGIES, INC.) scaffolding cing dismantled by SAFEWAY employees where they would flip the boards on the scaffolding and allow all of the asbestos-containing debris to fall to the ground, creating a lot of dust. Plaintiff worked in proximity to BAY WESTERN INDUSTRIAL MAINTENANCE, INC, (BRAGG INVESTMENT COMPANY, INC.) contractors pulling out asbestos packing while working on valves. Plaintiff recalls BECHTEL (SEQUOIA VENTURES INC) pipefitters performed tie-in work to existin pipelines, Gisturbing asbestos-containing pipe insulation, laintiff recalls BECHTEL (SEG 1A VENTURES INC) pipefitters cut and installed asbestos- containing gaskets and opened valves, removing and replacing interior gasket and packing material. Plaintiff recalls working adjacent to BECH’ {SEQUOIA. RES INC) employees sweeping and cleaning asbestos-containing debris. Plaintiff recalls the following coworkers: Norman Juelch, c/o Brayton" Parcel LLP. Plaintiff currently contends she was | exposed to asbestos during her employment. Location of Exposure loyer Exposure Job Title Dates Plant Insulation Company Shell Oil Insulator =——:1983-1984 1300 - 64" St Martinez, CA _ (Apprentice) (1 month) Emeryville, CA 94662 “KNnjured\108888\ni-saesf I.wpd . 11Cm IN KAR PB Ww HN wo wy See ea eo BRRRRBRE ES FSeVURGEEBHR SS exposed to asbestos during this employment. Job Duties: Plaintiff assisted insulators applying insulation to piping, and insulating large pipe racks, Plaintiff assisted insulators removing asbestos-containing pipe insulation on existing piping. Plaintiff was issued and used a 3M COMPANY single-strap mask. Plaintiff was aacent to pipefitters employed by DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A., IC.) who were removing and installing new asbestos-containing valves, disturbing interior asbestos containing gasket and ing material and cutting and installing GARLOCK (GARLOCK SEAL G TECHNOLOGIES, LLG) fange gaskets. Plaintiff recalls the following coworkers: Hank Freeman; c/o Brayton¢*Purcell LLP; Norman Juelch, c/o Brayton+Purcell LLP, Plaintiff currently contends she was exposed to asbestos during this employment. : - Location of Exposure Employer Exposure Job Title Dates . Northern California. Pacific Bell Insulator 1983-1984 Insulation aka Metalclad Stockton, CA (3 weeks) Insulation Corporation Job Duties: Plaintiff applied fiberglass insulation, mastic to piping and valves at a Pacific Bell Telephone building located a few blocks north of downtown Stockton. Plaintiff insulated the valves. Plaintiff recalls coworker: Norman Juelch, c/o Brayton ¢Purcell, LLP. Plaintiff is currently unaware if she was exposed to asbestos during this employment. Location of Exposure Employer Exposure b Title Dates Northern California Shell Oil Insulator 1983-1984 Insulation aka Metalclad Martinez, CA . (2 months) Insulation Corporation Job Duties: Plaintiff applied calcium silicate pipecovering, Rberplass pipecoverin , insulation cement, black mastic and insulation pads to piping and valves. Plaintiff was issued and used a 3M. COMPANY single-strap mask. Plaintiff removed asbestos-containing pipe insulation on | existing piping. Plaintiff was adjacent to pipefitters removing and replacing asbestos-containing valves, disturbiny interior gasket and packing material, and cutting and installing GARLOCK (GARLOCK SEALING ‘HNOLOGIES, LLC) flange gaskets, laintiff recalls the following co-worker; Norman Juelch, c/o Brayton Purcell, LLP. Plaintiff currently contends she was Location of Exposure Employer Exposure Job Title Dates Northern California Sutter Memorial Hospital Insulator 1984 Insulation aka Metalclad Sacramento, CA (Apprentice) (1 -2 weeks) Insulation Corporation Job Duties: Plaintiff worked in steam tumels re-insulating pipes. Plaintiff disturbed and removed existing asbestos-containing pipe covering on piping, Plaintiff worked adjacent to pipefitters removing and installing new piping, and disturbing existing pipe insulation. Plaintiff currently contends she was exposed to asbestos during this employment. Location of Exposure Employer Exposure : Job Title K Majured\08688lai-sacsf Lwpd 12SoU wm IDNA FR YN Dy NM NM NY RNY NN NY Be es Be Be eB Be ew Be Be aa nw se ON |= Sb weHIA A BW NH | Northern California Campbell Soup Insulator 1984 Tnsulation aka Metalclad Sacramento, CA (1 month) Insulation Corporation Job Duties: Plaintiff removed existing asbestos-containing pipe insulation from pipelines. Plaintiff was adjacent to pipefitters removing piping and disturbing asbestos-containing pipe insulation. Plaintiff worked | adjacent to pipefitters removing valves, disturbing interior gasket anc packing material as well as cleaning an repairing gaskets. Plaintiff insulated tanks and repaired patches on existing asbestos-containing pipe insulation. Plaintiff recalls the following co- workers: Norman Juelch, c/o Brayton’ Purcell, LLP; Mel Swanson, c/o Bra on**Purcell LLP; Maurice Lawrence, c/o Brayton**Purcell LLP, Plaintiff worked adjacent to CAMBELL SOUP employees, sweeping up asbestos-containing debris, and repairing machinery. Plaintiff currently contends she was exposed to asbestos during this employment. Location of Exposure Employer Exposute lob Title Dates Unknown Slaughterhouse Insulator 1984 (3 weeks) Sacramento, CA Job Duties: Plaintiff insulated a tank, Plaintiff recalls disturbing discarded asbestos-containing cement pipe and pipe insulation debris that was lying on the ground from a recent removal. Plaintiff currently contends she was exposed to asbestos during this employment. Lo Location of . Exposure Employer Exposure Job Title Dates Northern California Cheese Factory Insulator 1984 Insulation aka Metalclad South Sacramento, CA (3-4 weeks) Insulation Corporation : Job Duties: Plaintiff performed duct work. Plaintiff applied calcium silicate pipecovering, fiberglass pipecovering, insulation cement, black mastic and insulation pads to piping and valves| Plaintiff assisted insulators using {iberglass to cover pipes. Plaintiff recalls being adjacent to plumbers and pipefitters removing and distrubing a large piece of existing asbestos-containing sheetrock, Plaintiff recalls the following co-worker: Norman Jueich, Brayton 4Purcell, LLP; Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos during her employment. Location of Exposure Employer Exposure . Job Title Dates NPS Energy Services Rancho Seco Nuclear Insulator 1984-1992 Powerhouse Herald, CA Job Duties: Plaintiff installed pipecovering, insulation cement, black mastic and insulation pads on piping and valves, Plaintiff removed and replaced insulation on generators and inside pipelines. Plaintiff worked throughout the facility, in the reactor room, Plaintiff was issued and used a 3M COMPANY single-sirap mask. Plaintiff patched holes on asbestos-containing insulation on Pipin . Plaintiff removed existing asbestos-containing insulation on piping and equipment, Plaintiff recalis that BECHTEL (SEQUOJA VENTUI INC.) employees did the KAlnjured\0B6BB\si-zacsf Iwpd 13wa Nn HU Bw N NVM YN NY RN DB Dm SAA AB GOH H SO MPI HAH Fw NHN = tear-outs of pipes and other pieces of equipment at night and they would leave the debris over ec ENTURES INC. night for the BECHTEL (S. employees removing and zeplacing recalls that these were BEC. QUOIA V! .) laborers to clean up the next day, Plaintiff worked adjacent to BECHTEL (SEQUOIA VENTURES INC) main contractors on the job, Plaintiff recalis BECHTEL (SEQUOIA V! asbestos-containing gaskets and packing in valves, Plaintiff employees because she saw them in their trademark white ipefitters, one of the TURES INC . hats. Plaintiff recalls RANCHO SECO employees swept'and cleaned asbestos-containing debris including récently removed asbestos-containing pipecovering, Plaintiff recalls the following supervisors: Rick Bartel, address unknown; Ron Vandemeer, address unknown. Plaintiff recalls the following co-workers: Wiley Utterback, c/o Brayton%*Purcell LLP; Phil Black, address unknown; Robert Calvillo, c/o Brayton Purcell LLP; Thomas Begley c/o Brayton “Purcell, LLP, Plaintiff currently contends she was exposed to asbestos during: this employment. Employer Northern California Insulation aka Metalclad Insulation Corporation Location of Exposure Lassen College Waste Incinerator Susanville, CA. * Job Title Insulator Exposure . Dates 1985 (6 months) Job Duties: Plaintiff worked on new construction. Plaintiff applied thermal insulation to piping, Plaintiff recalls Lassen College was constructing a new garbag e burning power plant used to create electricity. During the construction, the plant had various tests known as the “blowdown’ and “fire up” process. Plaintiff recalls that new CRANE CO. valves were installed prior to each test, and removed. New CRANE CO. valves were always installed before each test. Plaintiff recalls working adjacent to pi SEALING TECHNOLOGIES, efitters removing and replacing GARLOCK LLC) gaskets and packing on new CRANE GARLOCK ‘O. valves durin; ‘these tests. Plaintiff recalls the following coworkers: Norman Juelch, c/o Brayton Purcell, LLP; Gene Cosby, deceased; Dean White, deceased; Steve Bass, c/o Brayton Purcell, LLP, Plaintiff currently contends she was exposed to asbestos as result of her employment. Employer Northern California Insulation aka Metalclad Insulation Corporation Location of Exposure WalMart Hammer Lane Stockton, CA Job Title Insulator Exposure Dates 1985; 1986 Job Duties; Plaintiff worked on new construction, Plaintiff installed pipecovering on pipelines. Plaintiff is currently unaware if she was exposed to asbestos during this employment, Employer Northern California Insulation aka Metalclad Insulation Corporation Location of Exposure Job Title WalMart Insulator Fresno, CA Exposure 1985; 1986 Job Duties: Plaintiff worked on new construction. Plaintiff installed pipecovering on pipelines. Plaintiff is currently unaware if she was exposed to asbestos during this employment. Employer KAlnjured\] O86888i-sacsf Lwpd Location of Exposure Job Title 14 Exposure DatesoD Oe NDA B® WN LN 33 Northern California Corn Products Insulator 1985 Insulation aka Metalclad Stockton, CA (2-3 months) Insulation Corporation Job Duties: Plaintiff insulated tanks. Plaintiff removed existing asbestos-containing pipecovering. Plaintiff replaced pipecovering with calcium silicate pipecovering. Plaintiff removed and replaced insulation on pipelines going to and from an ALLIS-CHALMERS generator. Plaintiff worked adjacent to other insulators tearing out pre-existing asbestos- containing insulation manufactured by OWENS CORNING FIBERGLAS Kaylo that had been installed & Northern California Insulation aka Metalclad Insulation Corporation insulators on a prior job. Plaintiff worked adjacent to pipefitters gemoving and replacing valves on the piping oing to the generator, Plaintiff recalls ALLIS-CHALMERS (ALLIS-CHALMERS CORPORA’ ION PRODUCT LIABILITY TRUST) generator technicians repairing the generator. Plaintiff worked adjacent to a large JOHNS-MANVILLE transite pipe that had been recently removed by CORN PRODUCTS, employces and discarded in the mi idle of the jobsite between the tanks they were insulating, Plaintiff recalls that the JOHNS-MANVILLE asbestos- containing pipe was regularly disturbed by all contractors on the site because it was in the middle, of the construction area. Plaintiff worked adjacent to CORN PRODUCTS employees sweeping and cleaning asbestos-containing debris, Plaintiff recalls the following co-workers; Norman Juelch, c/o Brayton + Purcell, LLP; Bob Wadley, deceased; Gene Cosby, deceased; Steve Bass, c/o Brayton*Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of this employment. Location of Exposure Employer Exposure Job Title Dates Northern California Modules Alaska Insulator 1985 Insulation aka Metalelad Stockton, CA (Apprentice) (4-5 months) Insulation Corporation Job Duties: Plaintiff provided pipecovering, fiberglass, foam Blass, and mastics to insulators. Plaintiff was adjacent to pipefitters cutting and installing GARLOCK gaskets, and installing asbestos-containing packing in valves. Plaintiff recalls the following coworkers: Norman Juelch, Brayton “Purcell, LLP; “Scotty,” Steve Bass; Brayton Purcell, LLP; Gene Crosby, deceased; Bob Wadley, deceased. Plaintiff currently contends she was exposed to asbestos during this employment. . PARA- OCCUPATIONAL EXPOSURE: Plaintiff resided with her first husband John Chambers. Plaintiff's ex-husband regularly returned home with asbestos-containing debris on his clothing, Plaintiff recalls shaking out and washing his work clothes in the garage. Plaintiff's husband’s work history is as follows: Location of Exposure Employer Exposure Job Title Dates Dinuba Distributing Dinuba Distributing Mechanic 1971-1977 : Stockton, CA Stockton, CA Job Duties; Plaintiff's ex-husband performed brake and engine repairs on fleet trucks. Plaintiff currently contends she was exposed to asbestos as a result of her ex-husband’s employment. KAinjured\10868Bui-saesP V.wpd 15Co mid Anew NY NM WM NM NR MN ND RD me aaa ae exryan Ff ON |= SO MwA AWRY Ye DS Plaintiff has resided with her husband Norman Juelch Sr., local 16 insulator since 1981. Plaintiff was exposed to asbestos-containing materials by washing her husband's laundry after work. aintiff recalls her husband frequently returned home with asbostos-containing debris and dust on his clothes from the jobsite. Plaintiff shook out her husband’s dusty clothes before washing em in the garage. Plaintiff recalls vacuuming her husband’s car which he drove to and from work on a daily basis. : ow Plaintiff's husband’s work history is as follows: Location of Exposure Employer | ’ Exposure Job Title lant Insulation Company Various commercial and Insulator 1981-1983, industrial buildings 1985 including: ow Job Duties: Plaintiffs husband applied pipecovering, insulation cements, fiberglass pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously removed asbestos-containing pipe insulation strewn on the ground in his work area, aintiff’s husband recalls working with the following co-workers throughout his employment with Plant Insulation: Steve Steele, Concord, California; and Carl Ramsey, c/o Brayton%Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment, 7 Location of Exposure Employer, Exposure lob Title Dates Owens Coming World Various locations Insulator 1981-1985 Headquarters including: . (6-7 months) 1 Owens Coming Pkwy Sierra Pacific Power Co. Toledo, OH 43659 Valmy Power Station Valmy, NV Job Duties: _ Plaintiff's husband applied thermal insulation during construction of Unit J of the Valmy Powerhouse, While working at the valiny, Powerhouse, plaintiff's husband insulated pipes with board glass and pipecovering. Plaintiff's husband recalis working near laborers sweeping up the site and near ironworkers, carpenters and pipefitters who were installing valves, gaskets and pipes. Plaintiff's husband worked alongside technicians who were disassembling, and repairing a GENERAL ELECTRIC (GENERAL ELECTRIC COMPANY) generator, Plaintiff's husband worked near others who were installing, new CRANE CO, valves and checking packing. Plaintiff's husband observed these pipe itters installing and removing GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gaskets on the CRANE CO. valve flanges. Plaintiff's husband recalls the following supervisor: Car! Ramsey c/o Brayton%*Purcell LLP. Plaintiff's husband recalls the following co-worker: Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of . Exposure Employer Exposure Job Title Dates Pioneer Insulation Contractor Unknown Insulator 1981 c (1 week) 2085 Boxwood Wa Fremont, CA 9453 KAinjurod\O8688\ai-sa0sF L.wpd : 16oe YAW Bw HN Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously removed asbestos-containing pipe insulation that was strewn on the ground in his work area. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. . Location of Exposure Emplover Exposure Job Title Dates Plant Insulation Company PG&E, Unit 1 Insulator 1982 Pittsburg, CA (3 weeks) Job Duties: Plaintiff's husband applied | pipecovering, insulation cements, and black mastic to boiler piping, Plaintiff's husband worked near boilermakers who were rebuilding a boiler. Plaintiff's husband recalls working adjacent to pipefitters who were tearing out pipes and installing new pipes and valves. Plaintiff's husband observed tradesmen removing brick and refractory from the Unit 1 boiler. PG&E (PACIFIC GAS & ELECTRIC COMPANY) personnel sycpt and cleaned asbestos-laden debris in his presence. PG&E (PACIFIC GAS & ELECTRIC COMPANY) personne! inspected and approv plaintiff's husband insulation work. Plaintiff's husband insulated the fittings with insulating cement. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. . Locationof Exposure Employer Exposure Job Title Dates Plant insulation Company Tosco Oil, Insulator 1982-1984 . Avon, CA (2 months) Job Duties: Plaintiffs husband applied calcium silicate pipgcoverin io steam and process piping and valves throughout the refinery. Plaintiffs husband applied insulation cements, ¢ RON (CHEVRON U.S.A. INC.) covercote (G-I HOLDINGS, INC.) black mastic, Zeston fittings and adhesives. Plaintiffs husband was provided with insulation from old boxes obtained from stocks on the TOSCO (TOSCO REFINING COMPANY, INC.) premises. Plaintiff's husband tied into existing asbestos insulation. Plaintiff's husband observed TOSCO (TOSCO REFINING COMPANY, INC.) personnel sweeping, blowing, and cleaning asbestos-laden pipecovering gasket scraps and other debris in his work areas. Plaintiffs husband recalls co- workers: Hank Freeman, c/o Brayton®*Purcell LLP; John Murphy, c/o Brayton%+Purcell LLP; Ken Goforth, c/o Brayton¢Purcell LLP; Larry Sublet, c/o Brayton%*Purcell LLP; and Don Bass, c/o Brayton%Purcell LLP. Plaintiff's husband worked alongside Pipefitters employed by BECHTEL (SEQUOIA VENTURES INC? who were removing and installing valves and gasket in his work areas. Plaintiff's husband recalls the following su isor: Steve Steele, Concord, California. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure Employer Exposure Job Title Dates Plant Insulation Company —_ Union Oil Insulator 1982-1983 Oleun/Rodeo, CA : Job Duties: Plaintiff's husband applied Pipecovering, insulation cements, fiberglass pipecovering, and Zeston plastic fittings to piping. Plaintiffs husband disturbed previously removed asbestos-containing pipe insulation that was strewn on the ground in his work area. KAlnjured\MO8688lal-saesf Iwpd . 170 wo WA DR HW Bw wD NN YN YN KR De eB Be se eB ew ee ea AGE OS = SF Car Aa EH AS Plaintiff's husband insulated oil tanks and pipes, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure Employer : Exposure Job Title Dates Plant Insulation Company El Dupont de Nemours & Insulator 1982-1985 . 0. . Antioch, CA Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously removed asbestos-containing pipe insulation that was strewn on the ground in his work area, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. . Location of . Exposure Employer : Exposure Job Title Dates Plant Insulation Company Dow Chemical Insulator 1982-1985 Pittsburg, CA Job Duties: Plaintiff's husband applied pipecovering, insulation cements, fiberglass pipecovering, and Zeston plastic fittings to piping. Plaintiff's husband disturbed previously removed asbestos-containing pipe insulation that was strewn on the ground in his work area, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment, Location of Exposure Employer Exposure Job Title Dates Plant Insulation Company Shell Oil Insulator 1983-1984 1300 - 64" St. Martinez, CA (1 month} Emeryville, CA 94662 Job Duties; Plaintiff's husband applied pipecovering insulation to piping. Plaintiff's husband worked alongside various trades, including welders, laborers, crane operators, and stage riggers. Plaintiff's husband worked alongside DILLINGHAM (DILLINGHAM CONSTRUCTION, N.A. INC.) pipefitters who were installing 8 to 10 new CRANE CO. valves along with GARLOCK G. CK SEALING TECHNOLOGIES, tLe flange gaskets, which were wired onto those valves when delivered. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure Employer Exposure Job Title Dates Fruin-Colnon Crop. Procter & Gamble, . Insulator * 4982 1299 Clayton Road W. Sacramento, CA (1 month) Ballwin, MO Job Duties: Plaintiffs husband recalls performing maintenance and repairs. Plaintiff's husband recalls working with and around old insulation. Plaintiff's husband recalls the site was very KAlnjured\OB6RB\0i-saosf I.wpd 18ww ON A PBN pM YN Wy wv ae BNRRRBBEREBSEeETDABEBHE S . Plaintiff recalls the following co-worker; Robert Calvillo, efo Brayton**Purcell LLP. Pai currently contends she was exposed to asbestos as a result of her husband's employment. : Location of . Exposure Employer: Exposure _ Job Title Dates Fruin-Colnon Crop. Louisiana Pacific Insulator 1983 1299 Clayton Road W. gp mill (6 weeks) Ballwin, MO amoa, CA Job Duties: Plaintiff's husband applied pipecovering, insulation cements, and black mastic while completing remodel work stanled by.a non-union crew. Plaintiff's husband observed previously removed asbestos-containing ipe insulation that had been piled up in boxes in his work areas, Plaintiff's husband worked alongside various trades, includin, millwrights, machinists, laborers, and maintenance Pee Je employed by LOUISIANA PACIFIC UISIANA PACIFIC CORPORAT: ON) who were handling and/or cleaning up asbestos- aden dust and debris. Plaintiff's husband also worked near pipefitters who were employed by an outside mechanical contractor, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. . Location of Exposure Employer Exposure b Title Dates Plant Insulation Company Roman Meal Bread Factory Insulator 1983 South San Francisco, CA (approx. 1 week) Job Duties: Plaintiff's husband worked near employees taking insulation off of the ovens and recalls the insulation falling and hitting the floor and kicking up dust clouds. Plaintiff's husband recalls that the debris was picked up and disposed of in a dumpster outside, Plaintiff's husband recalls that it was very dusty despite use of wet-down techniques. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure Employer Exposure Job Title Dates Metalclad Insulation Campbell Soup Insulator 1983-1985 Corporation . Sacramento, CA 2198 S Dupont Dr P.O, Box 61024 Anaheim, CA 92803 Job Duties: Plaintiff's husband worked at Campbell Soup multiple times. Plaintiff's husband recalls insulating tanks. Plaintiff's husband performed paiches to pipes that had existing insulation. Plaintiff's husband recalls working near welders who were using welding blankets. Plaintiff's husband recalls the following co-workers: Mel Swanson, c/o Brayton*Purcell LLP; Maurice Lawrence, c/o Brayton¢+Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. : Empl Location of _ . Exposure mployer Exposure Job Title Dates KAMnjured O868Btai-saosf Vwpd 19eo oe WN DA HH WN 10 Metalclad insulation Corp. _— Pacific Bell Insulator 1983-1985 2198 S, Dupont Drive Stockton, CA . (3 weeks) P.O. Box 61024 : Anaheim, CA 92803 . Job Duties: Plaintiff's husband applied fiberglass insulation to piping and valves at a Pacific Bell Telephone building located a few blocks north of downtown Stockton. Plaintiff currently contends she was exposed to asbestos as a result of her husband's employment. : Location of . . Exposure Employer - Exposure Job Title Dates Metalclad Insulation Corp, Lassen College Insulator 1983-1984 2198 South Dupont Drive Waste Incinerator (6 months) P.O, Box 61024 Susanville, CA Anaheim, CA . Job Duties: Plaintiff's husband applied new thermal insulation to piping, valves and fittings during new construction of a garbage burning power plant alongside Lassen College, near Susanville, California, During the “blowdown” process, when an attempt was made to “fire up” the new power plant, plaintiff observed pipefitters removing Original Equipment Manufacturer flange gaskets from CRANE CO, valves. The gaskets were thereafter re-installed after the “blowdown” test was completed, Plaintiff’s husband observed various new CRANE CO, valves being delivered on pallets, with the flange gaskets already wired to the CRANE CO. valves. Plaintiff's husband recalls coworkers: Gene Cosby, address unknown; and Dean White, address unknown, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. .. Location of Exposure Employer Exposure Job Title Dates Metalclad Insulation Corp. Shell Oil Insulator 1984-1985 2198 S. Dupont Drive Martinez, CA (2 months) P.O, Box 61024 Anaheim, CA 92803 Job Duties: Plaintiff's husband applied KAYLO (OWENS CORNING FIBERGLAS) calcium silicate pipecovering, fiberglass pipecovering, insulation cement, black mastic and insulation pads to piping and valves. Plaintiff's husband re-installed asbestos-containing insulation pads that had previously been removed by other workers. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. . oo Location of Exposure Employer Exposure . Job Title Dates Metalclad Insulation Corp. Corn Products Insulator 1984-1985 2198 S. Dupont Drive Stockton, CA . (3-4 months) P.O, Box 61024 Anaheim, CA 92803 Job Duties: Plaintiff's husband applied calcium silicate pipecovering, boardglass, white adhesive, fabglass, black mastic, insulation cements, and aluminum jacketing to piping and tanks. Plaintiff s husband repaired existing damaged asbestos-contai ning insulation, Plaintiff's husband worked in close proximity to other trades, including welders, pipefitters, generator KAlnjured FOS688\ai-snest J .wpd - 20Om WD hh BW Ww ° 11 technicians, sheetmetal workers, electricians, and laborers. The laborers were dismantling scaffolding that was laden with debris from the removed asbestos-containing ipecovering. Plaintiff's husband observed ALLIS CHALMERS (ALLIS-CHALMERS C ORATIO PRODUCT LIABILITY TRUST) generator technicians repairing an existing ALLIS CHALMERS (ALLIS. CHALMERS CORPORATION PRODUCT LIABILITY TRUST) generator. ALLIS CHALMERS (ALLIS-CHALMERS CORPORATION PRODUCT LIABILITY aRus pipefitters were installing new CRANE CO, valves in plaintiff's husband work areas, Plaintiff's husband recalls the following co-workers: Bob Wadley, deceased; and Gene Cosby, deceased. Plaintiff currently contends she was exposed to asbestos as a result of hey husband’s employment. : Location of : Exposure Employer Exposure Job Title Dates Plant Insulation Company Hormel Meat Packing Insulator 1984 Stockton, CA (2 weeks) Job Duties: Plaintiff's husband removed asbestos insulation from pipes and then re-insulated the pipes with cal sil insulation. Plaintiff's husband recalls that the site was very dusty. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment, . Location of Exposure Employer Exposure Job Tile Dates Plant Insulation Company Sequoia Hospital Insulator 1984 Reawood City, CA : Job Duties: Plaintiff's husband applied calcium silicate pipecovering to new biping in an existing hospital. Plaintiff's husband observed other trades employed by REDWOOD PLUMBING (RED WOOD PLUMBING CO., INC.) removing asbestos-containing pipecovering and insulated piping which created large amounts of visible dust, which plaintiff's husband reported to Local No. 16 Business Agent Ed Story, deceased. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure Employer Exposure Job Title Dates Metalclad Insulation Corp. | Modules - Alaska Insulator 1985 2198 S. Dupont Drive Stockton, CA “ (4-5 months) P.O, Box 61024 : Anaheim, CA 92803 Job Duties: Plaintiff's husband applied urethane, fiberglass, insulation cements, Zeston fittings, and aluminum jacketing to piping of portable, pre-fabricated dwellings and equipment. Plaintiff's husband worked al ongside various trades, including laborers who were sweeping and cleaning dust and debris created by all the other trades, pipefitters whe were fabricatin & Ns and handling CRANE CO. valves and GARLOCK (GARLOCK SEALING TECHN OL GIES, LLC) gaskets, carpenters, electricians who were handling electrical boxes and insulated wire, sheetmetal workers, welders, ironworkers, and concrete workers, Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. Location of Exposure KNnjured\O8688\ai-sacsf l.wpd 21CO NY A Ww be YN YN MM NY NY NR NR Rm me em eA AA fF ON &§ SO em IY AH RH HB HE GS Employer Exposure Job Title Dates N.P.S. Energy Services Inc.; Rancho Seco Nuclear Insulator 1986-1988 Dravo Constructors Inc. Powerhouse 11 Stanwix St. Herald, CA. Pittsburg, PA Job Duties: Plaintiff's husband removed Pi ccovering to make repairs to the insulation. Plaintiff's husband recalls that BECHTE! SEQUOL VENTURES INC.) employees did the tear-outs of pipes and other pices of equipment at night and they would leave the debris over night for the BECHTEL (SEQUOIA VENTURES INC.) laborers to clean up the next day. This debris included asbestos-containing KAYLO (owens CORNING FIBERGLAS) pipecovering, GARLOCK (GARLOCK SEALING TECHNOLOGIES, LLC) gasket debris, electrical boxes and associated wiring and switches, piping scraps, and other debris. Plaintiff's husband recalls sweeping up debris. Plaintiff's husband worked alongside mechanics who were rebuilding two CATERPILLAR (CATERPILLAR, INC) diesel engines, which involved replacement of the engine gaskets. Plaintiff's husband recalls the following supervisors: Rick Bartel, address own; Ron Yandemeer, address unknown. Plaintiff's husband recalls the following co- workers: Wiley Utterback, Sacramento, California; Phil Black, address unknown; Tom Begley, clo Brayton’ Purcell LLP; Robert Calvillo, c/o Brayton%+Purcell LLP. Plaintiff currently contends she was exposed to asbestos as a result of her husband’s employment. NON-OCCUPATIONAL EXPOSURE! Plaintiff recalls assisting her first husband John Chambers, building a house in Stockton, California in the early 1970s, Plaintiff recalls rabcing. applying and sanding asbestos containing KAISER GYPSUM COMPANY, INC, and HAMILTON MATERIALS, INC. all-purpose joint and taping compounds purchased from 84 LUMBER in Stockton, California. Plaintiff recalis assisting, and being in proximity to, her first husband, John Chambers, while he worked on an early 1970's FORD MOTOR COMPANY Mustang replacing brake drums and VICTOR (DANA COMPANIES, LLC (FKA DANA CORPORATI ™) askets purchased at NAPA AUTO PARTS and CHECKER AUTO PARTS, INC. (CSK' Al 5: INC.) which are both located in Stockton, California. Plaintiff recalls assisting her second husband Norman Juelch, Sr., remove and replace brakes on used.1977 FORD F-250, in the early 1980s. Plaintiff recalls purchasing the brake pads at NAPA AUTO PARTS, Kalispell, Montana, Plaintiff currently contends she was exposed to asbestos during these activities. Plaintiffs investigation and discovery are continuing. 27: Yes. a-b, Asbestos Workers Local #16, 1320 Harbor Bay Parkway, Suite 220, Alameda, California 94502. u 28. Plaintiff recalls first learning exposure to asbestos was a potential health hazard in approximaterly 1983, 29, Plaintiff recalls first learning exposure to asbestos was a potential health hazard when she read material regarding asbestos, and was taught at School for Insulation. KAlnjured\08638ai-suosf I_wpd 22Co oe UN A AW Pe HN 30, Plaintiff recalls first observing others using safety precautions when working around asbestos or asbestos-containing materials in approximately 1984, 31, _ - Plaintiff recalls first using safety precautions when working around asbestos or asbestos-con