On March 02, 2009 a Motion,Ex Parte was filed involving a dispute between Husband, Charles, and Albay Construction Company, All Asbestos Defendants See Scanned Documents, American Conference Of Governmental Industrial, Asbestos Defendants, Asbestos Manufacturing Company, Auto Friction Corporation, Auto Specialties Manufacturing Company, Bell Asbestos Mines Ltd., Bigge Crane And Rigging Co., Borgwarner Morse Tec, Inc., Brassbestos Brake Lining Company, Bridgestone Firestone North American Tire, Llc, Bucyrus International Inc, Carone Brothers, Inc., Cbs Corporation,, Certainteed Corporation, Chicago Bridge & Iron Company,, Cleaver-Brooks, Inc., Conocophillips Company, Csk Auto, Inc., Daimlerchrysler Corporation, Daimlerchrysler Corporation (And Not The Claims, Dillingham Construction, N.A., Inc., Does 1-8500, Emsco Asbestos Company, Fibre & Metal Products Company, Forcee Manufacturing Corporation, Garlock Sealing Technologies Llc, Gatke Corporation, Georgia-Pacific Corporation, Georgia-Pacific Llc,, Hamilton Materials, Inc, Hanson Permanente Cement, Inc. Fka Kaiser Cement, H. Krasne Manufacturing Company, Honeywell International Inc.,, Ingersoll-Rand Company, J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Lasco Brake Products, Lear Siegler Diversified Holdings Corp., L.J. Miley Company, Maremont Corporation, Marine Engineering And Supply Company, Metropolitan Life Insurance Company, Molded Industrial Friction Corporation, Morton International, Inc., National Transport Supply, Inc., Owens-Illinois, Inc., Pacific Gas And Electric Company, Parker Hannifin Corporation, Plant Insulation Company, Pneumo Abex Llc, Quintec Industries, Inc., Riteset Manufacturing Company, Rossendale-Ruboil Company, Santa Fe Braun, Inc. As Successor-In-Interest To, Shell Oil Company, Silver Line Products, Inc., Southern Friction Materials Company, Standard Motor Products, Inc., Standco, Inc., Stuart-Western, Inc., Temporary Plant Cleaners, Inc., The Budd Company, Thomas Dee Engineering Company, Underwriters Laboratories, Inc., Union Carbide Corporation, Universal Friction Materials Company, U.S. Spring & Bumper Company, Wheeling Brake Block Manufacturing Company, York International Corporation, for civil in the District Court of San Francisco County.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
LLP KNOX RICKSEN 1 || Kenneth J. McCarthy - SBN 120875 Gregory D. Pike - SBN 124847 2 || KNOX RICKSEN LLP ELECTRONICALLY 1300 Clay Street, Suite 500 3 || Oakland, CA 94612-1427 sopeh tilt ED oe pelephone: (Bio, Fee 38 County of San Francisco ‘ 4 acsimile: = NOV 09 2011 5 || Attorneys for Defendant Clerk of the Court BIGGE CRANE AND RIGGING CO. BY: JUDITH NUNEZ 6 eputy Clerk 7 8 SUPERIOR COURT OF CALIFORNIA - COUNTY OF SAN FRANCISCO 9 10 | CHARLES HUSBAND, No. CGC-09-275098 44 Plaintiff, DEFENDANT BIGGE CRANE AND RIGGING CO.’S INDEX OF MOTIONS 12 v. IN LIMENE 413 | ASBESTOS DEFENDANTS (BP). et al., Trial Date: November 14, 2011 Dept. : 206 14 Defendants, Time; 11:15 am, Judge: TBD 15 Action Filed: March 2, 2009 16 Comes now defendant BIGGE CRANE AND RIGGING COMPANY and submits 7 this index of motions in limine that it requests be heard and ruled on prior to jury voir dire: 18 1. DEFENDANT BIGGE CRANE AND RIGGING COMPANY’S MOTION IN 19 LIMINE TO EXCLUDE USE OF DEPOSITIONS TAKEN IN OTHER ACTIONS. 20 2. DEFENDANT BIGGE CRANE AND RIGGING COMPANY’S MOTION IN LIMINE TO EXCLUDE CO-WORKER WITNESSES NOT DISCLOSED IN 24 DISCOVERY. 22 3. DEFENDANT BIGGE CRANE AND RIGGING COMPANY’S MOTION IN LIMINE TO LIMIT THE TESTIMONY OF CHARLES AY AND REQUEST FOR 23 EVIDENCE CODE §§ 402 AND 403 HEARING 24 4, DEFENDANT BIGGE CRANE AND RIGGING COMPANY’S MOTION IN LIMINE TO PRECLUDE ANY CLAIM BY PLAINTIFF BASED ON A STRICT 25 LIABILITY THEORY 26 5. DEFENDANT BIGGE CRANE AND RIGGING COMPANY’S MOTION IN LIMINE TO PRECLUDE LAY WITNESS TESTIMONY REGARDING 27 PRODUCT COMPOSITION 28 6. DEFENDANT BIGGE CRANE AND RIGGING COMPANY'S JOINDER IN -1- BIGGE CRANE AND RIGGING CO’s INDEX OF MOTIONS IN LIMINELLP KNOX RICKSEN 27 28 OTHER DEFENDANTS’ MOTIONS IN LIMINE DATED: November 4, 2011 -2- KNOX RICKSEN LLP By:_/s/ Gregory D. Pike Gregory D. Pike Attorneys for Defendant BIGGE CRANE AND RIGGING CO. BIGGE CRANE AND RIGGING CO’s INDEX OF MOTIONS IN LIMINELLP KNOX RICKSEN 27 28 Re: Husband v. Asbestos Defendants (BP), et al. San Francisco Superior Court No. CGC-09-275098 PROOF OF SERVICE BY ELECTRONIC TRANSMISSION 1, the undersigned, declare: that | am and was at the time of service of the documents herein referred to, over the age of 18 years, and not a party to the action; and | am employed in the County of Alameda, California, My business address is 1300 Clay Street, Suite 500, Oakland, California 94612-1427. On the date executed below, ! electronically served the document(s) via LexisNexis File & Serve described as: DEFENDANT BIGGE CRANE AND RIGGING CO.’S INDEX OF MOTIONS IN LIMINE on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website. | declare under penalty of perjury pursuant to the laws of the State of California that the foregoing is true and correct and was executed on November 9, 2011 at Oakland, California. /s/ Nicholas J, Bertolino Nicholas J, Bertolino -3- BIGGE CRANE AND RIGGING CO’s INDEX OF MOTIONS IN LIMINE