Exhibit,Appendix: CHARLES HUSBAND VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS

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Dean Pollack, State Bar No. 176440
Nicholas Burke, State Bar No. 256660
BURNHAM BROWN

A Professional Law Corporation.

P.O. Box 119

Oakland, California 94604

1901 Harrison Street, 11th Fleer
Oakland, California 94612

Telephone: (510) 444-6800
Facsimile: (510) 835-6666
Attorneys for Defendant

YORK INTERNATIONAL CORPORATION

ELECTRONICALLY
FILED

Superior Court of California,
County of San Francisco

JUL 28 2011

Clerk of the Court
BY: JUDITH NUNEZ
Deputy Clerk

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO

UNLIMITED JURISDICTION

CHARLES HUSBAND,
Plaintiff,
v.
ASBESTOS DEFENDANTS (B“P),

Defendants.

M
ul
Mt
lil
it
uy
ui
tit
it

No. CGC-09-275098

DEFENDANT YORK
INTERNATIONAL CORPORATION’S
EXHIBITS A-C IN SUPPORT OF ITS
MOTION FOR SUMMARY
JUDGMENT

Date: October 13, 2011
Time: 9:30 a.m.

Dept.: 220

Judge: Hon. Harold E. Kahn

Complaint Filed: March 2, 2009

f
DEF. YORK INTERNATIONAL CORPORATION'S EXHIBITS A-C IN SUPPORT OF

ITS MOTION FOR SUMMARY JUDGMENT

CGC-09-275098EXHIBIT ASUM-100

Sy MONS FOR COURT USE ONLY
(CITA JN JUDICIAL) 1800 PARA USO DE LA CORTE)
NOTICE TO DEFENDANT:

(AVISO AL DEMANDADO):

ASBESTOS DEFENDANTS (BYP}
As Reflected on Exhibits B, 8-1, C; and DOES 1-8500;
and SEF ATTACHED List.

YOU ARE BEING SUED BY PLAINTIFF;
(LO ESTA DEMANDANDO EL DEMANDANTE):

CHARLES HUSBAND

You hava 20 CALENDAR

DAYS after this summons and teyat papers are served on you to jiie written response at this court and have 5
copy served on the plaintiff. A letter or phone cait will not protect you. Your written response must be in proper iegal form if you want tha
court to hear your cas. There may be a court farm that you can use for your response. You can find these court forms and more
information at the Catitornla Courts Online Self-Help Center {www.courtinfo.ca.gov/setfetp}. your county faw library, or the courthouse
nearest you, ff you cannot pay the fillng fee, ask the court clerk for 2 feo walver form. If you do not file your response on time, you may
lose the case by default, and your wages, money, and property may be taken without further warning from the court.

There are other legal requirements. You may want to call an attomay right away. If you do not know an attorney, you may want to call an
attorney referral service, If you cannot afford an attornay, you may be eligible far free legal services from a nonprofit legal services
program. You can locate these nonprofit groups at the Californts Legal Services Web site {www .jawhelpcalifornia.org}, the California
Courts Ontine Self-Help Center (www.courtinfo.ca.gov/selthelp), or by contacting your locat court or county bar association.

Tiene 30 DIAS DE CALENDARIO después de que le entrequen esta citacién y papeles legates para presentar una respuesta por escrito
en esta corte y hacer qué se entregua una copia af demandante. Una carta o una Hamada tofefénica no fo protegen. Su respuesta por
escrito tiene que estar en formato fegal correcto sf desea que procesen su caso en ia corte. Es posible que haya un formulario que usted
pueda usar pare su respuesta, Puede encontrar estos formularios ve ta corta y m3s informaciéa en et Centro de Ayuda de fas Cortes de
California (www,courtinfa.ca.gov/selfheip/espanot}, en I2 biblioteca de feyes de su cortdado a en ja carte que le quede mas cerca. Sino
Puede pagar fa cuota de presentacién, pida al secretaric cle la corte que fe dé un formulario de exencién de page de cuotas, SI no presenta
su respuesta a tiempo, puede perder ef caso por incumpiimienta y la corte te podré quitar su sueldo, dinero y bienes sin mas advertencia,

Hay ofros requisitos fegales. Es recomendable que fame a un abogade inmediatamente, Si no conoce a un abogado, puede Hamar aun
servicio de remisién a abogados. SI no pueda pagar a un abogado, e3 posible que cumpla con los requisites para obtener servicios
Jegales gratuitos de un programa de servicios iegales sin fines da lucro. Puede encontrar estos grupos sin fines de iucro en ef sitio web de
California Legal Services, (www.lawhelpcaiifornia.org), en ef Centro de Ayuda de ies Cortes de California,
(www.courtinfo.ca.gov/selfhelp/esp2not) o ponléndose en contacto con ia corte o ef colegio de abogados locales.

The name and address of the court is: anys
(Et nombre y direccién de la corte es): gr u
SAN FRANCISCO COUNTY SUPERIOR COURT ‘Beet09 275598
400 McAllister Street
San Francisco, CA 94102

The name, address, and telephone number of plaintiffs attomey, or plaintiff without an attomey, is:

(El nombre, la direccién de teléfono del abogado del demandante, o det demandante que no tien ‘abogado, 8s)
DAVID R. BONADIO, ESQ., STATE BAR NO. 154436

BRAYTON-PURCELL LLP

222 Rush Landing Road, Novato, CA oe nt +0 nape a0 888 &

DATE - png TOU ead % toatl Depul
ona MAR 2 ~ 2009 “il i

(For proof of service of this summons, use Proof of Service of Summons {fom 070}. “

{Para prueba de entrega de esta citation use el formutario Prool of Service of Summons. 4P08-010).
NOTICE TO PERSON SERVED: You are served

A. a as.an Individual defendant... ~ -
2. O as the person sued under the fictitious name of (specify:
3. O on behalf of (specify:

under:L_] CCP 416.10 ¢corperation) 1 cep at6.so(minor)
CCP 416.20 (defunct corporation) cer 416.70 {conservatee)
CCP 416.40 (association of partnership) oO CCP 416.90 (authorized person)
other {specify}:

4, Oo by personal delivery on (date):

P: toft
Juxicial Counc ST Caitorea SUMMONS
SUM-100 [Revtanuary 1, 2008)4 g

2
338 a
gezssd

Baa
ou
z°8 é

i SR SO SE

BUCYRUS INTERNATIONAL, INC,
GARLOCK SEALING TECHNOLOGIES, LLC
GEORGIA-PACIFIC CORPORATION

HANSON PERMANENTE CEMENT, INC, FORMERLY KNOWN AS KAISER CEMENT CORPORATION

KAISER GYPSUM COMPANY, INC,
PARKER-HANNIFIN CORPORATION
PLANT INSULATION COMPANY
QUINTEC INDUSTRIES, INC,
VIACOM, INC,

WESTERN MacARTHUR COMPANY
MacARTHUR COMPANY

WESTERN ASBESTOS COMPANY
HONEYWELL INTERNATIONAL, INC.
CHRYSLER LLC

TEMPORARY PLANT CLEANERS, INC,
1. THORPE, INC.

J.T. THORPE & SON, INC.
CONOCOPHILLIPS COMPANY
PACIFIC GAS & ELECTRIC COMPANY
SHELL OIL COMPANY

and DOES 1-8500,

Defendants.

Charles Husband vs. Asbestos Defendants (RP)

San Francisco Superior CourtATTORNEY OR PARTY WITINOUT ATTORNEY (_. sate bar number, and address
DAVID R. DONADIO, ESQ., STATE BAR NO. 154436
BRAYTON*PURCELL LLP

222 Rush my Road

Novato, Califia 94048.6169 F
* (415) 898-1555 FASSO (aisysog.iza7 A
ATTORNEY FOR(NAME)_PlaintiffUs)

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
STREET ADDRESS: 400 McAlister Street

MAILING ADNRFSS: CA 94102 ap

CITY AND ZIP CODE: San Francisco, Mig:

RRANCHINAM! p

CIVIL CASE COVER SHEET
Untimited (1 Limited

Complex Case Designation
C1 counter Ci Joinder

vil
(Amount [Amount Filed with first nce by defendant
demanded jemanded is (Cat, Rules of Court, rule 3.402)
execeds $25,000) $25,010 or tess)|

Jrems 1-6 below must he completed (sce instructions on
1. Check one box below of the case type that best describes this case:

* Auto Tort Contract Provisionafly Complex Civil Litigation
Auto (22) Ty aveach of contract arom (065 {ay Rules of Court, rules 3.400-3,403)
Lininsured motoris (36) (ute 3.240 cottetions 109) Antirust Trade regulition (03)
Other PIPDAVD (Personal Injury/Property Doiter Coltcetions 07) i conctruction defect (10)

Image/Wrongful Death) Tart Insurance coverage (18) . LET stees ton (20

Ashestns (04) Other contract (37 ‘Sceutities fitization (28)

Product {iability (24) Real Propeny Environmental / Toxic tort {30}

‘Medical malpractice (48) Eminent dornpte tnverse Insurance coverave claims arising ftom the

Other PLPRAWD (23) . condemnation (14} shove fisted provisionatly complex esse pes (41)
Non-PLPDAVD (Other) Tort, ag Wrongful eviction (33) Enforcement of Judgment

Business torvuntair business practice {07} Orher reat propery (26) Enforcement of judymers (20}
Oeins Fights (08) Untawful Detainer Miscellancous Civil Complaint

efamation (13) Commorciat (31)

Froud (16) Residentiat (32) D acoen

‘Chher comptaint (uot specificd abow} (429

TateHlectual property (19) Dros (38)
Professional neyligencet25) Judicial Review Miscetlancous Civil Petition
Orher non P PAWD tort £35) Asset forfeiture (08) [Fy panncesbip and corporate governance (24)
Employment Potion re: arbitration award (11) Caer petition (nor speifod abowe) (43)
‘Wrongfl termination (36) ‘Writ of mandate (02)
Other employment (15) Cider joaicial review (39)

2. Thiscase Dis & isnot complex under rule 3.400 of the California Rutes of Court. If the case is complex, mark the factors
Tequiring exceptional judicial management:
a Large number of separately represented parties 40 Large number of witnesses
v. Extensive motion practice raising difficult or novel e ‘Coordination and related actions pending in one or more cours
issues that will be time-consuming to resolve in other counties, states or countries, or in a federal court
c. C1 Substantial amount of documentary evidence £. C1 substantial post judgment judicial supervision

3. Remedies sought (check all that apply): a. & monetary oO nonmonetary; declaratory or injunctive relief c R Punitive

~4, Number of causes of agtion (specify): 7

5. This case is isnot aclass action suit,
there 6 any known related cases, file and serve a notice of related case. {You may,

P2 , id R, Don:

CLYPE OR PRINT NAMED

‘OF PARTY OR ATTORNEY FOR PARTY)

NOTICE
+ Plaintiff must file this cover sheet with the fist paper {ited in the ation or preceedin mall claims eases ot cases filed under the Probsie Code,
Family Code, or Welfare and lnstiutions Couch, {Ca. Rutes Of Coun, we 1250) Fakan otic meh eee eee

+ File this cover sheet in addition to any cover shect required by focat court rie.

+ IT this case is complex under rule 3.400 et seq, of the California Rules of Court, you must serve a copy of this cover shect on all other panties to

the action or proceeding,
+ Unless this is a collections case under rule 3.740 of a complex case, this cover sheet shall be used for sta

tistical purposes only.

Form Adopied for Mandatory Use CIVIL CASE COVER SHEET (Cad Rakes of Comm tol? 50,3728 3 400.5 003 9440,
dnd Comal Calta Ca Sem f hcl Adwistnon ud 310
CatofRe tay 12007, , ‘Sn conn ca pa

Bes Aneh Aerated Calon Pll Comet Fars(ANS) BORISSS

BRAYTON@PURCELL LLP
NOVATO. CALIFORNIA 94948-6169"

¢ C

DAVID R, DONADIO, ESQ., S.B. #154436
EFFAT R. HUSSAIN, ESQ., S.B. #255847
RRAYVTONS*PHIRCELE LEP

Attomeys at Law

222 Rush Landing Road

P.O. Box 6169

Novato, California 94948-6169

(415) 898-1555 : By.

Attomeys for Plain¥ AiG GAGE IS SUBJECT 16
MANDATORY ELECTRONIG FLING OEE
PURSUANT TG AMENDED G.0. 158 -

SUPERIOR COURT OF CALIFORNIA frp,
COUNTY OF SAN FRANCISCO 8 2614 By

SURES Heo Fee,
: 5 UR mere
gee 9 275098

COMPLAINT FOR PERSONAL INJURY :
ASBESTOS .

CHARLES HUSBAND,
Plaintiff,

VS.

ASBESTOS DEFENDANTS (B“*P)
As Reflected on Exhibits B, B-1, C;
and DOES 1-8500; and SEE ATTACHED

Nee Set et el St

1. Plaintiff CHARLES HUSBAND was bom February 10, 1948.

2. The Brayton Purcell Master Comptaint for Personal Injury [and Loss of
Consortium]- Asbestes (hereinafter "Master Complaint”) was filed January 2, 2003, in San
Francisco Superior Court. A copy of the Master Complaint and General Order No. 55 may be
obtained upon request from Brayton“*Purcell, and designated portions of the Master Complaint
are incorporated by reference herein pursuant to the authority conferred by General Order No. 55.
Plaintiff's claims are as set forth in said Master Complaint against defendants herein as follows:
ut
ut
it

COMP! FOR NAL ENJUI ~ ASB)2

3] Bucyrus INTERNATIONAL, INC,

4]| GARLOCK SEALING TECINOLUG
GEORGIA-PACIFIC CORPORATION

|| HANSON PERMANENTE CEMENT, INC, FORMERLY KNOWN AS KAISER CEMENT CORPORATION
KAISER GYPSUM COMPANY, INC.

6 {| PARKER-HANNIFIN CORPORATION

7

8

9

0

ES, LLC

PLANT INSULATION COMPANY
QUINTEC INDIISTRIES, INC,
VIACOM, INC.
WESTERN MacARTHUR COMPANY
MscARTHUR COMPANY
WESTERN ASBESTOS COMPANY
HONEYWELL INTERNATIONAL, INC.
CHRYSLER LLC
TEMPORARY PLANT CLEANERS, INC.
Wi yr. THORPE, INC.
IT. THORPE & SON, INC.
121 ConocopHILLirs COMPANY
13 || PactricGas & ELECTRIC COMPANY
SHELL OIL COMPANY
14|] and DOES 1.8500,

15 Defendants.

BRAYTON SPURCEEL LLP

Charles Husband ys. Asbestos Defendants (BP)

San Francisco Superior Court: Seventeenth,

DEFENDANTS* ON EXHIBITS:

Cause of Action
First (Negligenze)

mr

Second (Strict Liability)

Third (False
Representation)

Fourth (Loss of
Consortium)

Oo

oor
OOF

0
Oo
Oo

QD
Fred (Pretnises Owner!
Contractor Liat ility) & &

Sixth, Seventh, Eighth &
‘Unseaworthiness, Negligence
Jones Act],Ma ntenance and Cure)

Ninth (Longshore and Harbor Workers QO
Comaensation Act [LHWCA])

Tenth, Eleventh (F.E.L.A.) Oo

Twelfih, Thirtecnth (Resp:ratory
Safety Devices)

Oo

Sixteenth (Concert of Action)

ghteenth (Fraud, DeceiNegligent
Misrepresentation/Concealment)

Nineteenth (Fraud/Deccil/
Intentional Misrepresentation)

Twentieth (Fraud/Deccit - Kent)
Twenty-First (Aiding/Abetting Battery - Met Life)

*and their alternate entities as set forth in the Master Complaint or on any Exhibit.

Ok3. Plaintiff's asbestos-related injury, date of diagnosis, cmployment status, and

history of exposure to asbestos are as ctated on Fxhihit A

4 Plaintiff's claims against defendant VIACOM, INC. (successor by merger to
CBS CORPORATION which is successor-in-interest to WESTINGHOUSE ELECTRIC

CORPQRATION) exclude military and federal government jobsites.
Dated: S| 2U8 BRAYTON“*PURCELL LLP

» Oz

David R. Donadio _
Attorneys for PlaintiffEXHIBIT A2 i('s exposure to ashestos and ashestos-containing products accurred at various
3 locations both inside and outside the State of Califomia, including but not limited to;
4 Location of Exposure
Employer Exposure dob Title Dates
5
US Army US Amy- Mechanic 1967-1970
6 Fort Lewis
7 Tacoma, WA
US-Amy 1968-1969
8 Vietnam
9) US Navy Naval Weapons Station Rigger 1970
US Weapons Station Concord, CA (3-6 months)
10] Concord, CA
11 }] Triple A Machine Shop Inc. Triple A Machine Shop Mechanic 1971
Richmond, CA Richmond, CA
Matson Terminals Inc. Various Matson Navigation Carpenter 1971-1973
13 || Oakland, CA Line Ships
Matson Terminals
14 Oakland, CA
15} Fluor Products Company Inc. PG & E Carpenter 1972
6 Santa Rosa, CA Pittsburg, CA
Ronald Jean Bohm Various residential Carpenter 1972
17] Pro-Duction Co Quality jocations throughout Contra
Construction Costa County, CA
18 | Oakland, CA
19} Oscar E. Erickson Inc. Exxon Refinery Carpenter 1972
0 Richmond, CA Benicia, CA.
Foley-PMI Inc. Shell Oi Carpenter 1972
21] Chantilly VA Martinez, CA
22] RL Chaides Construction Co. Various Residential Drywall 1972
Tne. Locations throughout Carpenter
23) Fremont, CA Contra Costa County, CA
24|| KB Home North Bay Inc. Various Locations Drywall 1972
- Los Angeles, CA throughout the San Carpenter-
25 Francisco North Bay
96 San Francisco, CA
Califomia Delta Homes Inc. Various Locations Drywall 1972
27) Byron, CA throughout Carpenter
Contra Costa County, CA
28] a EXHIBIT A€
!
Emplover
|

SBI Inc.

2
3
4]| San Jose, CA
5
6

Christensen Contracting Co.

8 || Santa Rosa, CA

DL Nelson Corp
10} Oakland, CA

United States Army Reserves

11] Biltwell Development Co. A

Corp
12] San Francisco, CA

Floyd Raynor Const. Inc.
14]] San Jose, CA

16 || Dillingham Corporation
Walnut Creek,

Bechtel Inc.
18 jj San Francisco, CA
Albay Construction Co.
204 Martinez, CA

21) Hayman Homes Inc.
Los Altos, CA

Cahill Construction Co,
24]) San Francisco, CA

EXUIBIT A {cont'd}

Toeation of

Exposure

Various residential
locations throughout the
San Jose Area, CA

Angel Island Immigration

Station
San Francisco, CA

Various Residential
locations throughout the

San Francisco, North Bay

Unknown

Various Residential
locations throughout the
am Francisco Bay Area,

Various Residential and
Commercial locations
throughout the San
Francisco Bay Area, CA

Shell Oil
Martinez, CA.

Phillips Petroleum
Company
Avon, CA

Shell Oi

- Martinez, CA

25 || Moseman Construction Co. A

Corp
26} Englewood, CO

28] a

K unhurt 105m ‘

MPLAT

Various residential and
commercial locations
throughout the San
Francisco Bay Area, CA

Unknown location
San Francisco, CA

Various commercial and
residential locations

throughout the San
Francisco Bay Area, CA

Job Title
Drywall
Carpenter

Reservist

Drywall
Carpenter

Carpenter

Carpenter

Carpenter

Carpenter

Carpenter

Carpenter

Equipment
Operator

Carpenter

Equipment
Operator

Exposure

Dates
1973

1973

1973-1974

1973

1973

1973-1974

1974; 1978

1975-1976

1975-1977

1975

1978

1982-1983

EXHIBIT AEXHIBIT A {cont'd}

Location af Eypasure
Employer Exposure Job Title Dates
Eugene G. Alves Unknown Shop Equipment 1983
Construction Co. Inc, Operator
Pittsburg, CA
Ferma Corporation Unknown Operator- 1983
Mountain View, CA F Mechanic
Jamieson Company Jamieson Company Shop = Mechanic 1984-1985
Pleasanton, CA Pleasanton, CA.

NON. IPATIONAL EXP: : !

Plaintiff removed and replaced clutches and brakes on his own vehicles from 1963- present.
When performing brake jobs, plaintiffused the same routine on each occasion. Plaintiff
removed the existing dnim brakes, cleaned the brake assemblies and drums by blowing on them
with an air compressor, and installed new drum brakes. Plaintiff used sandpaper to sand the
brake shoes to fit the drums and the brake hub. When performing clutch jobs, plaintiff disturbed
friction disks during the removal and installation process. When performing engine overhauls,
plaintiff scraped and chipped existing burned out gaskets off exhaust manifolds and engine head
gaskets.

Plaintiff recalls purchasing BENDIX replacement brake shoes and asbestos-containing gaskets
from the following suppliers:

GRAND AUTO, Lafayette, California and Pleasant Hill, California.
FOUR CORNERS, Pacheco and Concord, California.

Plaintiff recalls performing the following work on his own vehicles:

1953 FORD, acquired between 1964-1965. Plaintiff recalls pulling off the head gaskets and
tearing the engine out.

1948 GMC truck. Plaintiff pulled out the engine scraped off intake manifold gaskets, replaced
tim ing shave covers, and overhauled the engine. Plaintiff replaced the brakes and the clutch on
this vehicle.

1949 FORD MERCURY, acquired in 1964, Plaintiff replaced the brakes, pulled ont the engine.
Plaintiff replaced the pan gasket, the valve cover gaskets ant the manifold gasket.

1953 FORD PICK UP, acquired in 1960s. Plaintiff recalls this car was owned by his brother,
Plaintiff replaced the brakes and the clutch.

1965 VOLKSWAGEN Beetle acquired in the late- 1960s by his father, Plaintiffreplaced-the
brakes and the clutch.

ut
a
au EXHIBITA

K Mpdured 10551;
MPLAINT FOR PER: JURY - ASBEa wv bw NK

EXHIBIT A (cont'd)

Plaintiff's exposure to asbestos and asbestos-containing products caused severe and
permanent injury to the plaintiff, including, but not limited to breathing difficulties, asbestosis,
and/or other lung damage, and increased risk and fear of developing mesothelioma, lung cancer
and various other cancers, Plaintiff was diagnosed with asbestosis on or about July 2007.

Plaintiff retired fron tris fast place of employment at regular retirement age. He has
therefore suffered no disability from his asbestos-related disease as “disability” is defined in

Califomia Code of Civil Procedure § 340.2.

EXHIBIT AEXHIBIT BEXHIBITR
2} DEFENDANTS
3 || BUCYRUS INTERNATIONAL, INC. QUINTEC INDUSTRIES, INC.
| GARLOCK SEALING TECHNOLOGIES, LLC VIACOM, INC.
4 | GEORGIA. PACIFIC CORPORATION WESTERN MacARTHUR COMPANY
HANSON PERMANENTE CEMENT, INC, MacARTHUR COMPANY
5]} FORMERLY KNOWN AS KAISER CEMENT WESTERN ASBESTOS COMPANY
CORPORATION HONEYWELL INTERNATIONAL, INC.
6] KAISER GYPSUM COMPANY, INC. CHRYSLER LLC
PARKER-HANNIFIN CORPORATION DOES 1-2
7/|| PLANT INSULATION COMPANY
8 ALTERNATE ENTITY
9]] BUCYRUS INTERNATIONAL, INC. BUCYRUS-ERIE
MARION POWER SHOVEL COMPANY, THE
10 OSGOOD COMPANY
i" GENERAL EXCAVATOR COMPANY
GARLOCK SEALING GARLOCK, INC.
12|| TECHNOLOGIES, LLC COLTEC INDUSTRIES, INC.
FAIRBANKS-MORSE
13 FAIRBANKS MORSE ENGINES
BELMONT PACKING & RUBBER CO,
14 GARLOCK PACKING CO.
US. GASKET CO.
15 GOODRICH CORPORATION
16 ENPRO INDUSTRIES, INC.
GEORGIA-PACIFIC CORPORATION BESTWALL GYPSUM COMPANY
7 CALIFORNIA WESTERN RAILROAD

18 | PARKER-HANNIFIN CORPORATION

SACOMA-SIERRA, INC,
SACOMA MANUFACTURING COMPANY

19 E.LS. AUTOMOTIVE CORPORATION

CONDREN CORPORATION, THE

20 PARKER SEAL COMPANY

21] VIACOM, INC.

CBS CORPORATION
WESTINGHOUSE ELECTRIC CORPORATION

22 WESTINGHOUSE ELECTRIC AND
MANUFACTURING COMPANY
23 BF, STURTEVANT
KPIX TELEVISION STATION
24 PARAMOUNT COMMUNICATIONS, INC.
GULF & WESTERN INDUSTRIES, INC,
25 NORTH & JUDD MANUFACTURING COMPANY
26 |) WESTERN MacARTHUR WESTERN ASBESTOS CO,
COMPANY MAC ARTHUR COMPANY
27 BAY CITIES ASBESTOS COMPANY
F.K, PINNEY, INC.
28] EXHIBIT B

Alpluren 10581 emi 10
SOMPLAING FOR PERSONAL INJURY = ASHES TOSEXHINIT 8 (contd)
ALTERNATE ENTITY.

NONEYWELE INTERNATIONAL, INC, HONEYWELL, INC.
HONEYWELL CONTROLS
ALLIEDSIGNAL, INC,
ALLIED-SIGNAL, INC,
THE BENDIX CORPORATION
BENDIX PRODUCTS AUTOMOTIVE DIVISION
BENDIX PRODUCTS DIVISION, BENDIX AVIATION CORP.
BENDIX HOME SYSTEMS
ALLIED CORPORATION
ALLIED CHEMICAL CORPORATION
GENERAL CHEMICAL CORPORATION
FRAM
FRICTION MATERIALS OF LOS ANGELES
NORTH AMERICAN REFRACTORIES COMPANY
EM SECTOR HOLDINGS INC.
UNIVERSAL OIL PRODUCTS COMPANY
BOYLSTON CORPORATION
ENRHART & ASSOCIATES, INC.
ENMRHART & ARTHUR, INC.
GARRETT AIR RESEARCH CORP.
STANLEY G. FLAGG & CO.
MERGENTHALER LINOTYPE COMPANY
ELTRA CORPORATION
BUNKER RAMO-ELTRA CORPORATION
UNION TEXAS NATURAL GAS CORPORATION
UNION OIL AND GAS OF LOUISIANA
UNION SULPHUR AND OIL CORPORATION
UNION SULPHUR COMPANY, INC., THE
MINNEAPOLIS-HONEYWELL REGULATOR COMPANY
SIGNAL COMPANIES, INC., THE
HANCOCK OIL COMPANY
BARRETT DIVISION, ALLIED CHEMICAL & DYE
CORPORATION

EXHIBIT B

it

Kclojuredt osmEXHIBIT B-1Oo wr XQ AW PY =

o
o

SS SS SS SSS

12

EXHIBIT Bel
DEF ANTS
TEMPORARY PLANT CLEANERS, INC,
J.T. THORPE, INC.
J.T. THORPE & SON, INC.
DOES 1-800; DOES 1001-2000
ALTERNATE ENTITY
TEMPORARY PLANT CLEANERS, INC. PLANT MAINTENANCE, INC. OF CALIFORNIA
J.T. THORPE & SON, INC, THE THORPE COMPANY
THORPE PRODUCTS CO,
LT. THORPE NORTHWEST

EXHIBIT B-1

KipsEXHIBIT C3
4

|

EXHIBIT C

CONOCOPHILLIPS COMPANY PLANT INSULATION COMPANY
PACIFIC GAS & ELECTRIC COMPANY WESTERN MacARTHUR COMPANY
SHELTON COMPANY MacARTHUR COMPANY
TEMPORARY PLANT CLEANERS, INC. WESTERN ASBESTOS COMPANY
41.7, THORPE, INC, DOES 1001-2000
J.T. THORPE & SON, INC.

ALTERNATE ENTITY
CONOCOPHILLIPS COMPANY CONOCO, INC,

DOUGLAS OIL CO. OF CALIFORNIA

CONTINENTAL OIL COMPANY

PHILLIPS PETROLEUM COMPANY

PHILLIPS OIL COMPANY

GENERAL AMERICAN OIL COMPANY OF TEXAS

GENERAL AMERICAN OIL COMPANY

AMINOIL, INC,

AMERICAN INDEPENDENT OIL COMPANY

SEASIDE OIL COMPANY
PREMISES OWNER
DEFENDANTS. LOCATK TIME PERIOD
CONOCOPHILLIPS COMPANY Phillips Petroleum Company, 1975-1976

Avon, CA
PACIFIC GAS & ELECTRIC COMPANY = PGE, Pittsburg, CA 972
SHELL OIL COMPANY Shell Oil, Martinez, CA. 1972; 1974-1978
CONTRACTOR
DEFENDANTS _ LOCATION TIME PERIOD
TEMPORARY PLANT CLEANERS, INC. _ Exxon Refinery, Benicia, CA 1972
Sheil Oil, Martinez, CA 1975-1977
J.T, THORPE, INC, Various Various
4.1. THORPE & SON, INC. Various Various
PLANT INSULATION COMPANY ‘Various “Various
WESTERN MacARTHUR. Various Various
COMPANY/MacARTHUR
COMPANY/WESTERN ASBESTOS
COMPANY
EXHIBIT C

KAlejured toSt1 Sere 15
MiEXHIBIT BBRAYTON@PURCELL LLP

ATTORNEYS AT LAW
222 RUSH LANDING ROAD

PO BOX 6169

NOVATO, CALIFORNIA 94948-6169

(645) 898-1555

Nor

we

DAVID R. DONADIO, ESQ., S.B. #154436
BRAYTON“*PURCELL LE

Attorneys at Law

222 Rush Landing Road

P.O, Box 6169

Novato, California 94948-6169

(415) 898-1555

Attomeys for Plaintiff

ELECTRONICALLY
FILED

Superior Court of Califomia,
County of San Francisco

SEP 23 2010

Clerk of the Court

BY: JUDITH NUNEZ”
Deputy Cle

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO

CHARLES HUSBAND, }
Plaintiff, . 3

vs. }
)

)

ASBESTOS DEFENDANTS (BP)

ASBESTOS
No. CGC-09-275098

AMENDMENT TO COMPLAINT TO
SUBSTITUTE DEFENDANTS’ TRUE
NAMES FOR DOES 3-13 AND 1001-1007

[C.C.P. Section 474]

+ Plaintiff amends the complaint in this action as follows:

Plaintiff has learned the true names of the defendants designated in the complaint as

fictitious DOES as:set forth below:

TRUE NAME

ALBAY CONSTRUCTION COMPANY
[Various refinery locations, Various dates]

BIGGE CRANE AND RIGGING CO,

Alternate Entities:

BIGGE DRAYAGE CO.

BIGGE CRANE & RIGGING CORPORATION
[Phillips Petroleum Co., Avon, CA; 1975-1976]

CARONE BROTHERS, INC.
[Exxon Refinery, Benicia, CA; 1972}

SANTA FE BRAUN, INC. AS SUCCESSOR-IN-INTEREST

TO C.F..BRAUN, INC.
[Yarious refinery locations, Various dates}

Injured 19581 Stol4oes3-138 500-1007. i

1~1007

FICTITIOUS N
DOE 3 and 1001

DOE 4 and 1002

DOE 5 and 1003

DOE 6 and 1004

x
AMENDBIEN TO COMPLAINT TO SUBSTITUTE DEFENDANTS TRUE NAMES FOR DOES 3-13 ANDowe Ww Aw BF Ww NM

RN YPN WN NM YN BE ee eR Se ee ee oS
& YA GA EOD & SF oO wD DHF YN SH DO

CHICAGO BRIDGE & IRON COMPANY DOE 7 and 1005
[PG&E, Pittsburg, CA; 1972]

DILLINGHAM CONSTRUCTION, N.A., INC. DOE 8 and 1006

Alternate Entities:

DILLINGHAM CONSTRUCTION
INTERNATIONAL, INC.

DILLINGHAM CONSTRUCTION
CORPORATION

DILLINGHAM CONSTRUCTION, INC.

DILLINGHAM HEAVY CONSTRUCTION

GORDON H. BALL FNC.

BASALT ROCK

BASALT ROCK CO., INC.

BASALT SHIPYARD

BASALT PRECAST DIVISION

DILLINGHAM CONSTRUCTION
PACIFIC LTD.

DILLINGHAM CONSTRUCTION GUAM, LID.

HD&C INTERIORS, LTD.

|| HAWAIIAN BITUMULS & PAVING COMPANY

HAWAIIAN CONCRETE & ROCK COMPANY

HAWAIIAN DREDGING & CONSTRUCTION COMPANY

WATKINS ENGINEERS & CONSTRUCTORS, INC,

INLAND INDUSTRIAL CONTRACTORS,
INCORPORATED

C. NORMAN PETERSON

ALBINA ENGINE & MACHINE WORKS

ALASKA STEAMSHIP.COMPANY

BEACON GASOLINE COMPANY

BEACON PETROLEUM COMPANY

FOSS TUG & LAUNCH

SIMPSON CONSTRUCTION

WILLAMETTE IRON & STEEL COMPANY

PETERSON-SIMPSON DIVISION

BASALT ROCK COMPANY, INC.

DILLINGHAM CONSTRUCTION HOLDING, INC.

WATKINS ENGINEERS & CONSTRUCTORS,

[Various locations, Various dates}

THOMAS DEE ENGINEERING COMPANY : DOE 9 and 1007
Al ities: .
THOMAS DEE ENGINEERING CO., INC.

DEE ENGINEERING COMPANY

[Shell Oi, Martinez, CA; 1972, 1974-1978]

INGERSOLL-RAND COMPANY ‘DOE 10

Altermate Entities:
INGERSOLL-DRESSER PUMP
DRESSER-RAND CO.

PACIFIC PUMP WORKS
FLOWSERVE CORPORATION
INGERSOLL ROCK DRILL COMPANY
TERRY STEAM TURBINE CO.
WHITON MACHINE COMPANYRow

CoO em IN

RAND DRILL COMPANY

RAND & WARING DRILL AND COMPRESSOR COMPANY
TNGERSOLL-SERGEANT

SCHLAGE LOCK COMPANY

VON DUPRIN: .

THE TORRINGTON COMPANY

BLAW-KNOX COMPANY

ALDRICH PUMPS

HUSSMANN CORPORATION

CLEAVER-BROOKS, INC. DOE if
Alternate Entities:

CLEAVER-BROOKS, A DIVISION OF AQUA-CHEM, INC,

AQUA-CHEM, INC.

CLEAVER BROOKS

SPRINGFIELD BOILER CO.

CERTAINTEED CORPORATION DOE 12

YORK INTERNATIONAL CORPORATION DOE 13

Alternate Entities:

YORK OPERATING COMPANY

YORK HOLDINGS

YORK HOLDING CORPORATION

CENTRAL ENVIRONMENTAL SYSTEMS

BORG-WARNER AIR CONDITIONING, INC.

BORG-WARNER CENTRAL ENVIRONMENTAL SYSTEMS

YORK DIVISION, BORG-WARNER

YORK AIR CONDITIONING DIVISION, BORG WARNER

YORK-LUXAIRE, INC.

YORK CORPORATION

LUXAIRE

YORK CORPORATION

YORK ICE MACHINERY

YORK MANUFACTURING

FRICK COMPANY

YORK ACQUISITION CORPORATION

LILCO, INC.

WATKIN SERVICE

YIC HOLDINGS CORPORATION

YORK HEATING AND AIR CONDITIONING

NORTHFIELD FREEZING SYSTEMS

UNITED MECHANICAL SERVICES, FNC.

JOHNSON SUPPLY & EQUIPMENT CORPORATION

YORK INTERNATIONAL CORPORATION CES
(CENTRAL SYSTEMS)

YORK INTERNATIONAL SALES & SERVICE

APPLIED SYSTEMS

FRASER JOHNSTON

Ww
w
Ww

KAdrjured tOSB15% 3-1 MA1OOL100T. od 3
AMEND ENT 10 COMPLAINT TO SUBSTITUTE DEFENDANTS’ TRUE NAMES FOR DOES 3-13 ANDoO TD A RB YW

Plaintiff hereby substitutes such true names for the fictitious names as set forth above

wherever said names appear in the complaint.
Dated: i oll . BRAYTON’®PURCELL LLP
David R. Donadio
Attoreys for Plaintiff
KcOnjyred\ 1058) Sipidoes}-1321001-1007. 4
ENT TO COMPLAINT TO SUBSTT ENDANT: A ES 3-13 AND

TOU?BRAYTON®@PURCELL LLP

ATTORNEYS AT LAW.

222 RUSH LANDING ROAD

PO BOX 6169

NOVATO, CALIFORNIA 95948-6169

1588

@

Oo oe MW DH HW Bw

10

PROOF OF SERVICE BY LEXIS-NEXIS E-SERVICE

1 am employed in the County of Marin, State of California. J am over the age of 18
years and am not a party to the within action. My business address is 222 Rush Landing Road,
P.O. Box 6169, Novato, California, 94948-6169.

On September 22, 2010, I electronically served (E-Service), pursuant to General Order
No, 158, the following documents:

AMENDMENT TO COMPLAINT TO SUBSTITUTE DEFENDANTS' TRUE
NAMES FOR DOES 3-13 AND 1001-1007

on the interested parties in this action by causing Lexis-Nexis E-service program pursuant to
General Order No. 158, to transmit a true copy thereof io the following party(ies):

SEE ATTACHED LIST

The above document was transmitted by Lexis-Nexis E-Service and the transmission
was reported as complete and without error.

Executed on September 22, 2016, at Novato, California.

I declare under penaity of perjury
foregoing is true and correct.

Charles Husband v. Asbestos Defendants (BP)
San Francisco Superior Court Case No. CGC-09-275098

PROOF OF SERVICE BY E-SERVICEBrayton-Purcell service List

Date Created: 9/22/2010-11:51:17. AM Ran By : Harwood, Jennifer Ss.
(asa)

Created by: LitSupport - Servicelist - Reporting

Matter Number: 105815.001 - Charles Husband

Bassi, Edliu, Huie & Blum LLP Berry & Ber n Hugo Parker
351 California Seset Suite 200 P.O. Box 160: ‘Sa Seat 2 Floor
San Francisco, Cy 104 2930 Lakeshore: jayente & Francisco, CA
415-397-9006 AS 207. 1339 (fax) Oakland, CA 9 415-808-0300 AS-808-0333 (fax)
Defendants: 910-839-8330 *10-835-$1 17 fax) Defendants:
J.T. Thorpe & Son, inc. (THORPE, Defenda: Union Carbide Corporation (UNIONC)
Parker-Hannifin Corporation (PAI Berry & Geny (B&B) -
Cooley, Manion, Jones, Hake, & Karowski Hassard Bonnington LLP Law Offices of ks Lucinda L. Storm, Esq,
LLP . Two Embarcadero Center 610A Third
201 Spear Street Suite 1800 San eanelon CA CA 94107
Suite 1800 San Francisco, CA 94111 $s. FHT-6990 415-777-6992 (fax)
San Francisco, CA 94105 415-288-9800 415-288-9802 (fax) fendants:
415-512-4381 415-512-6791 (fax) Defendants: eae Gas & Electric Company (PGRE)
Defendants: Honeywell Intemational, Inc. (HONEYW)

‘Ternporary Plant Cleaners, Inc. (TEMPLA)

Nixon Peabody LLP Perkins Coie LLP Sedgwick, Detert, Moran & Arnold
One Embarcadero Four Embarcadero Center, Suite 2400 One et Plaza
18" Floor San Franciseo, CA 94111 Steuart Tower, 8" Floor
Sen Francisco, CA 941 415-344-7000 415-344-7288 (fax San Francisco, CA 94105
415- 984-8200 866- saz. 1538 (fax) Defendants: $15. 781-7300 415-783-2635 (fax)
Defen Honeywell international, Inc. (HONEYW) Defendant
sel oN ‘Company (SHLOIL) Pacific "as & Electric Company (PGXE)

Walsworth, Franklin, Bevins & McCall
601 Montgamer Strect, 9° Floo
San Francisco, CA 94111
415-781-7072 Ae 391-6258 (fax)
Defendants:

Hamilton Materials, inc. (HAM-M)EXHIBIT Cec em aH HM RB Ww DR

BoP NY Be Be ew me ee oe eB oe eB
n fF Ss © &e WY RH BF Bw NY SF SG

Dean Pollack, State Bar No. 176440
Bina Ghanaat, State Bar No. 264826
BURNHAM BROWN

A Professional Law Corporation
P.O, Box 119

Oakland, California 94604

1901 Harrison Street, 11th Floor
Oakland, California 94612
Telephone: (510) 444-6800
Facsimile: (510) 835-6666

Attorneys for Defendant
YORK INTERNATIONAL CORPORATION

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO

UNLIMITED JURISDICTION
CHARLES HUSBAND, No. 275698
Plaintiff, DEFENDANT YORK
INTERNATIONAL CORPORATION’S
ve SPECIAL INTERROGATORIES TO
PLAINTIFF CHARLES HUSBAND,
ASBESTOS DEFENDANTS (BP), SET ONE .
Defendants. Complaint Filed: March 2, 2009

‘Frial Date: May 16, 2011

PROPOUNDING PARTY Defendant YORK INTERNATIONAL CORPORATION
RESPONDING PARTY: Plaintiff CHARLES HUSBAND
SET NO.: ONE (1)
INSTRUCTIONS

Pursuant to California Civil Procedure Code section 2030.010(a), within thirty (30) days
after you are served with these interrogatories, you must serve your responses on this asking
party and’serve copies of your responses ‘on all other parties tothe action who have appeared:

Each answer must be complete and as straightforward as the information reasonably
available to you permits. Hf an interrogatory cannot be answered completely, answer it to be the
extent possible. :

If you do net have enough personal knowledge to fully answer an interrogatory, say so,

but a reasonable and good faith effort to get the information by asking other persons or

1
DEF, YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONEwine

wo em UAH

organizations is required, unless the information is equally available to the asking party.

Whenever an interrogatory may be answered by referring to a document, the document
may be attached as an exhibit to the response and referred to in the response. If the document
has more than one page, refer to the page and section where the answer to the interrogatory can
be found. :

Whenever an address and telephone number for the same person are requested in more
than one interrogatory, you are required to furnish them in answering only the first interrogatory
asking for that information.

: INTERROGATORIES
SPECIAL INTERROGATORY NO. 1:

Do YOU (YOU and YOUR as used in these special interrogatories includes Plaintiff
CHARLES HUSBAND, his employees, representatives, attomeys, agents, and investigators, and
anyone else acting on his behalf) contend that YOU were exposed to asbestos-containing products
manufactured by YORK (YORK as used in these special interrogatories includes YORK
INTERNATIONAL CORPORATION or any related corporate entity, division, subsidiary, affiliate
or predecessor of YORK INTERNATIONAL CORPORATION).

SPECIAL INTERROGATORY NO. 2:

To what asbestos-containing products manufactured by YORK do YOU allege YOU
were exposed?

SPECIAL INTERROGATORY NO. 3:

If YOU contend that YOU were exposed to asbestos-containing products manufactured
by YORK, please state for each product each fact that supports YOUR contention.
SPECIAL INTERROGATORY NO. 4:

For each fact that supports YOUR contention that YOU were exposed to asbestos-
containing products manufactured by YORK, for each product please identify by name,
ADDRESS (ADDRESS as used in these special interrogatories means the street address,
including the city, state and zip code) and telephone number of each PERSON (PERSON

includes natural person, firm, association, organization, partnership, business, trust, corporation, |

2
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO Wo. 275098
PLAINTIFF CHARLES HUSBAND, SET ONE

i
tcr m7n ra nn bk WwW N mm

YB Be ee es Be ee ee
ee 6 TAH FB BW YP FS CS

or public entity) who corroborates that fact.

SPECIAL INTERROGATORY NO. 5:

For each fact which supports YOUR contention that YOU were exposed to asbestos-
containing products manufactured by YORK, for each product please identify by date, subject
matter, author and addressee, each DOCUMENT (DOCUMENT means writing, as defined in
Evidence Code section 250, and includes the original or a copy of handwriting, typewriting,
printing, photostating, photographing, and every other means and recording upon any tangible
thing and form of communication and representation, including letters, words, pictures, sounds,
or symbols, or combinations of them) which supports that fact.

SPECIAL INYERROGATORY NO. 6:

If you contend that YOU were exposed to asbestos-containing products manufactured
by YORK, for each product, please identify by name and ADDRESS each location where YOU
allege YOU were exposed.

SPECIAL INTERROGATORY NO. 7:

Please state the manner in which VOU were allegedly exposed .to each asbestos-
containing product manufactured by VORK at each of the locations at which YOU claim such
exposure occurred.

SPECIAL INTERROGATORY NO. 8:

For each location where YOU allege YOU were exposed to asbestos-containing products
manufactured by YORK, please identify for each product whether the exposure was to products
being installed. :

SPECIAL INTERROGATORY NO. 9:

For each location where YOU allege that YOU were exposed to asbestos-containing
products manufactured by YORK during installation, please describe, by type, the specific
asbestos-containing product manufactured by YORK to which YOU contend that YOU were
exposed.

MW
MW

3 :
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONEeo ea ADH Rw NH

wm oNM MY RP RN NY NY RD EF Be ee Be oe RB oe Be oe
So Wa A A F&F BY BP KF SF Be Be DN HR KH FF BSB BY FEF S&S

SPECIAL INTERROGATORY NO. 10:

For each location where YOU allege that YOU were exposed to asbestos-containing
products manufactured by YORK, please specify for each product whether the exposure was to
products being removed.

SPECIAL INTERROGATORY NO. 11:

For each location where YOU allege that YOU were exposed to asbestos-containing
products manufactured by YORK during removal, please describe, by type, the specific
asbestos-containing product manufactured by YORK to which YOU contend YOU were
exposed. - :

SPECIAL INTERROGATORY NO. 12:

For each location where YOU allege YOU were exposed to ashestos-containing products
manufactured by YORK, please identify by name and ADDRESS, each supplier from whom
each of the asbestos-containing products manufactured by YORK was obtained.

SPECIAL INTERROGATORY NO. 13:

Do YOU contend that YOU were exposed te asbestos-containing products sold by
YORK?
SPECIAL INTERROGATORY NO. 14:

To what asbestos-containing products sold by YORK do YOU allege YOU were
exposed? :

SPECIAL INTERROGATORY NO. 15:

If YOU contend that YOU were exposed to asbestes-containing products sold by YORK,
please state for cach product each fact that supports YOUR contention.

SPECIAL INTERROGATORY NO. 16:

For each fact that supports YOUR contention that YOU were exposed to asbestos-
containing products sold by YORK, for each product please identify by name, address and
telephone number, each PERSON who corroborates that fact.

Ml
Mh

DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No, 275098
PLAINTIFF CHARLES HUSBAND, SET ONEee NA HW RW NY eK

Boe ee Pe Be Be es eB
Se Aaah O&O PB S

SPECIAL INTERROGATORY NO. 17:

For cach fact which supports YOUR contention that YOU were exposed to asbestos-
containing products sold by YORK, for each product please identify by date, subject matter,
author, and addressee, each DOCUMENT which supports that fact.

SPECIAL INTERROGATORY NO. 18:

If YOU contend that YOU were exposed to asbestos-containing preducts sold by YORK,
for cach product please identify by name and ADDRESS each location where YOU allege YOU
were exposed.

SPECIAL INTERROGATORY NO. 19:

Please state the manner in which YOU were allegedly exposed to cach asbestos-
containing product sold by YORK at each of the locations at which YOU claim such exposure
occurred,

SPECIAL INTERROGATORY NO, 20:

For each location where YOU allege YOU were exposed io asbestos-containing products
sold by YORK, please specify for each product whether the exposure was to products being
installed.

SPECIAL INTERROGATORY NO. 21:

For each location where YOU allege that YOU were exposed to asbestos-containing
products sold by YORK during installation, please describe, by type, the specific asbestos-
containing product sold by YORK to which YOU contend YOU were exposed.

SPECIAL INTERROGATORY NO. 22:

For each location where YOU allege YOU were exposed to asbestos-containing products
sold by YORK, please specify for each product whether the exposure was to products being
removed.

SPECIAL INTERROGATORY NO. 23:

For each location where YOU allege that YOU were exposed to asbestos-containing
products sold by YORK during removal, please describe, by type, the specific asbestos-
containing products sold by YORK to which YOU contend YOU were exposed.

5
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONEPoy owe ye NY RP R NR YE Be Be Be ee BR ee
BRR RR BSF SF S&B eB A AH BH YD FS

ce WA HA e ON

SPECIAL INTERROGATORY NO. 24:

For each location where YOU allege YOU were exposed to asbestos-containing products
sold by YORK, please identify by name and ADDRESS, each supplier from whom each of the
asbestos-containing products sold by YORK was obtained.

SPECIAL INTERROGATORY NO. 25:

Do YOU contend that YOU were exposed to asbesios-containing products installed by
YORK?
SPECIAL INTERROGATORY NO. 26:

To what asbestos-containing products installed by YORK do YOU allege YOU were
exposed?
SPECIAL INTERROGATORY NO. 27:

If YOU contend that YOU were exposed to asbestos-containing products installed by
YORK, please state for cach product each fact that supports YOUR contention.
SPECIAL INTERROGATORY NO. 28:

For each fact that supports YOUR contention that YOU were exposed to asbestos-
containing products installed by YORK, for each product please identify by name, ADDRESS
and telephone number, each PERSON who corroborates that fact.

SPECIAL INTERROGATORY NO. 29:

For each fact which supports YOUR contention that YOU were exposed to asbestos-
containing products installed by YORK, for each product please identify by date, subject matter,
author and‘addressee, each DOCUMENT which supports that fact.

SPECIAL INTERROGATORY NO. 30:

If YOU contend that YOU were exposed to asbestos-containing products installed by
YORK, for each product please identify by name and ADDRESS each location where YOU
allege YOU were exposed.
if
il
Mt

6
DEF. YORK INTERNA TIONAL CORPORATION'S SPECIAL INTERROGATORIES TO ‘No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONENo

Oo we WH ee wD

10
i
2
B
14
15
16
17
18
19
20
a1
2
23
24
25
26
2
28

SPECIAL INTERROGATORY NO. 31:

Please state the manner in which YOU were allegedly exposed to each asbestos-
containing product installed by YORK at each of the locations at which YOU claim such.

exposure occurred.
SPECIAL INTERROGATORY NO. 32:

For each location where YOU allege YOU were exposed to asbestos-containing products
installed by YORK, please specify for each product whether the exposure was to products being
installed.

SPECIAL INTERROGATORY NO. 33:

For each location where YOU allege that YOU were exposed to asbestos-containing
products installed by YORK during installation, please describe, by type, the specific asbestos-
containing product sold by YORK to which YOU contend YOU were exposed,

SPECIAL INTERROGATORY NO. 34:

For each location where YOU allege YOU were exposed to asbestos-containing products
installed by YORK, please specify for each product whether the exposure was to products being

removed.

SPECIAL INTERROGATORY NO. 35: :

For each location where YOU allege that YOU were exposed to asbestos-containing
products installed by YORK during removal, please describe, by type, the specific asbestos-
containing product installed by YORK to which YOU contend YOU were exposed.

SPECIAL INTERROGATORY NO. 36: :

For each location where YOU allege YOU were exposed to asbestos-containing products
installed by YORK, please identify by name and ADDRESS, each supplier from whom each of
the asbestos-containing products installed by YORK was obtained.

SPECIAL INTERROGATORY NO. 37:

Please state the total amount of economic damages that YOU have sustained as a result
of YOUR alleged exposure to asbestos products.
ii

7
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TG No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONEoe Ua AH eR YW NY OF

pop wR PN NR NY DP HE eB Be PB ep Ss
RPRYRRPRPBBER BSS BARR EG EE S

SPECIAL INTERROGATORY NO. 38:

Please state the amount of economic damages that YOU have sustained as a result of any
alleged acts or omissions of YORK.
SPECIAL INTERROGATORY NO. 39:

Do YOU contend that YORK engaged in conduct or is responsible for omissions which

would make YORK liable for punitive damages?
SPECIAL INTERROGATORY NO. 40:

If YOUR response to Interrogatory No. 39 is affirmative, please state each and every fact
which supports YOUR contention.
SPECIAL INTERROGATORY NO. 41:

For each fact stated in YOUR response to Interrogatory No. 40, please identify the name,
ADDRESS and telephone number of each PERSON who has knowledge of that fact.
SPECIAL INTERROGATORY NO, 42:

For each fact set forth in response to YOUR response to Interrogatory No. 40, please
identify-as to date, subject matter, author and addressee of each and every DOCUMENT which

supports that fact.
SPECIAL INTERROGATORY NO. 43:

What do YOU contend is the amount of punitive damages to which YOU are entitled as

a result of any alleged acts or omissions of YORK?
SPECIAL INTERROGATORY NO. 44:

Please state the bases, including calculations, for the amount of punitive damages set out
in YOUR response to the Interrogatory No. 43.
SPECIAL INTERROGATORY NO. 45:

Please identify each and every DOCUMENT which YOU believe supports the amounts

of damages referred to in Interrogatories Nos. 37, 38 and 43.

SPECIAL INTERROGATORY NO. 46:

Please state separately the total amount of settlement payments YOU have received to

date in the instant Action No. 275098.

&
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONEeC or a ma a Ww YM

MPD eB em
= S$ 6 eA aA wm PB BW HY FS

22

SPECIAL INTERROGATORY NO. 47:
Please identify the Defendants separately which have settled with YOU in the instant

Action No. 275098.
SPECIAL INTERROGATORY NO. 48:

For each Defendant identified in response to Interrogatory No. 47, please state the

amount each Defendant has paid or agreed to pay.
SPECIAL INTERROGATORY NO. 49:

For each Defendant identified in response to Interrogatory No. 47, please state how such
Defendant's settlement funds were allocated to YOU.
SPECIAL INTERROGATORY NO, 50:

For each Defendant identified in response to Interrogatory No. 47, please state how much
of such Defendant’s settlement funds were allocated to YOU as economic damages.
SPECIAL INTERROGATORY NO, 51: ,

For each Defendant identified in response to Interrogatory No. 47, please state how much
of such Defendant’s settlement funds were allocated to YOU as non-economic damages.
SPECIAL INTERROGATORY NO. 52:

If YOU have ever given a deposition in an asbestos-related matter, including but not
limited to, workers’ compensation matters, for each such deposition, please state the date of the
deposition, the names of the court reporters, the court and action number of the involved matter,
and whether YOU were deposed as a witness or party.

SPECIAL INTERROGATORY NO. 53: :

If YOU ever gave trial testimony in an asbestos-related matter, including but not limited
to, workers’ compensation matters, for such testimony, please state the date of the testimony, the
names of the court reporters, the court and action number of the involved matter, and whether

YOU gave testimony as a witness or party.
SPECIAL INTERROGATORY NO. 54:

IDENTIFY (as used in these interrogatories, the term “IDENTIFY” when used with

reference to a document, means to provide a complete description of that document, together with

9
DEF, YORI INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098
PLAINTIFF CHARLES HUSBAND, SET ONESe ew a HR Hh RH HR

10

the name, address and telephone number of the custodian of the document) the “TRANSCRIPT”
(as used in these interrogatories, the term TRANSCRIPT refers to any transcription of a deposition,
trial, hearing or other proceeding) of each PERSON with knowledge of the facts which support
YOUR contention that YOU were exposed to asbestos-containing products on job or other sites due
to the actions or omissions of YORK fram 1948 to the present.

SPECIAL INTERROGATORY NO, 55:

IDENTIFY the DECLARATION (as used in these interrogatories, the term
DECLARATION refers to any affidavit and/or written or printed declaration or statement of
facts, confirmed by the oath or affirmation of the party making it) of each PERSON with
knowledge of the facts which support YOUR contention that YOU were exposed to asbestos-

containing products at job or other sites due to the actions or omissions of YORK from 1948 to

. the present.
DATED: Nov. 2 0/0 BURNHAM BROWN
By Bae BPraronck
BINA GHANAAT
Attomeys for Defendant
YORK INTERNATIONAL CORPORATION
x
10
DEF. YORK INTERNATIONAL CORPORATION'S SPECIAL INTERROGATORIES TO No. 275098

PLAINTIFF CHARLES HUSBAND, SET ONEwe mda nn & WwW N eH

10
11
12
13
4
15
16
17
18
19
20
21
22
23
24
25
26
27
28

DECLARATION FOR ADDITIONAL DISCOVERY
[Civ. Proc. Cade § 2030.050]

}, Bina Ghanaat, declare:

1. I am presently the attorney for Defendant YORK INTERNATIONAL
CORPORATION, sued herein as YORK INTERNATIONAL CORPORATION, a party to this
action or proceeding.

2. lam propounding to Plaintiff CHARLES HUSBAND the attached set of specially
prepared interrogatories.

3. This set of specially prepared interrogatories will cause the total number of
interrogatories propounded to the party to whom they are directed to exceed the number of
interrogatories permitied by section 2030.030 of the Code of Civil Procedure.

4. This set of specially prepared interrogatories contains a total of 55 interrogatories.

5, Lam familiar with the issues and the previous discovery conducted by all of the
parties in this case.

6. I have personally examined each of the interrogatories in this set of specially
prepared interrogatories.

7. This number of specially prepared interrogatories is warranted under paragraphs (1),
(2) and (3), of section 2030.040 of the Code of Civil Procedure because of the complexity and
the quantity of the existing and potential issues in this particular case. Plaintiff has brought this
action against numerous defendants, with allegations of exposures to asbestos through various
pro