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

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                                ay HA Ww

Eugene C. Blackard Jr. (Bar No. 142090)
Jocelyn M. Soriano (Bar No. 201169)

Jasun c. Moline (Bar No. 204456) ELECTRONICALLY
jmolinelli@archernorris.com
ARCHER NORRIS . FILED

Superior Court of California,

A Professional Law Corporation ‘
2033 North Main Street, Suite 800 . County of San Francisco
PO Box 8035 JUL 21 2011
Walnut Creek, California 94596-3728 Clerk of the Court
Telephone: 925.930.6600 BY: WILLIAM TRUPEK
Faesimile: 925.930.6620 Deputy Clerk
Attorneys for Defendant

ALBAY CONSTRUCTION COMPANY
SUPERIOR COURT OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

CHARLES HUSBAND, ASBESTOS
Case No. CGC-09-275098
Plaintiff,
INDEX OF EXHIBITS IN SUPPORT OF
v. : DEFENDANT’S MOTION FOR

SUMMARY JUDGMENT
ASBESTOS DEFENDANTS (BP), et al, .
Date: Octeber 13, 2011
Defendant. Time: 9:30 am.

Dept.: 220
Judge: Hen. Harold Kahn

Action Filed: March 2, 2009
Trial Date: November 14, 2011

_ INDEX OF EXHIBITS
1. Attached hereto as Exhibit “A” is a true and correct copy of Plaintiff's Answers to
Interrogatories, Set One.

2. Attached collectively hereto as Exhibit “B” are true and correct copies of the

- relevant portions of the transcript from the Deposition of Plaintiff.

3. Attached hereto, collectively as Exhibit “C” is a true and correct copy of Albay’s
Special Interrogatories, Request for Production of Documents, Request for Admissions and Form
Interrogatories.

4. Attached hereto, collectively as Exhibit “D” are true and correct copies of the

Plaintiff's responses to Albays’s Special Interrogatories, Request for Production of Documents,
ALB184/1193105-1

INDEX OF EXHIBITS IN SUPPORT GE MOTION FOR SUMMARY JUDGMENTRequest for Admissions and Form Interrogatories.

Dated: July 15, 2011 ARCHER NORRIS

Jasun C. Molimelli
Attorneys for Defendant
ALBAY CONSTRUCTION COMPANY

ALB184/1193105-1 2

INDEX OF EXHIBITS IN SUPPORT OF MOTION FOR SUMMARY JUDGMENTEXHIBIT ACe a Aw kw we

BRAVTON@PURCELI. LLP
ATTORNEYS AT LAW?

222 RUSH LANDING ROAD
POBOX6I69
NOVATO, CALIFORNIA 94942-6169
(615) S98-1558

Hp eee ae . :

ALAN R. BRAYTON, BSQ,, §.B. #73685.

EPFAT R. HUSSAIN, "ESQ., S.B. #255847 : .
BRAYTON4*PURCELL LLP “2 ot
Attameys at Law . .
222 Rush Eanding Read

P.O. Box 6169

Novato, California 94948-6169 1
(415) 898-1555 .

Attorneys for Plaintiff
{
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO '
‘T CHARLES HUSBAND, ASBESTOS '
No. 275098
Plaintiff, :
ANSWERS TO INTERROGATORIES
vs. re
ASBESTOS DEFENDANTS (BP)

PROPOUNDING PARTY: STANDARD ASBESTOS CASE INTERROGATORIES
RESPONDING PARTY: Plaintiff CHARLES HUSBAND ’
SET NO: * ONE

ANSWERS
CHARLES DENNING HUSBAND.
February 10, 1948,
60 years.
_ Oakland, California.
Asrowhead Road, Clearlake, California 94522.
Height: 6 2", weight: 200 pounds.
564-72-1477.
Not applicable. . - . i

aes fg

ye mo

KAlnjured 05815 VAleswost pd 1 tewo WA HW PP YN

25

1 26

i, 364-72-1477.

i Unknown at present.

k California, P0317428.

L Charlie or Charles Husband.

m. 12% grade.

in. -None.

ovt, Notapplicabie,

3. Katy Husband.

t 1981.

a Plaintiff's marriage to Katy ended with her death in 2006. '

2. a _ Bradi Hushand Myers.

db. September 18, 1978.

a Natural.

a. 752 Shell Avenue, #15, Martinez, California 94553.

e Housewife. . 1
f. Living.

No.

None. |

Plaintiff is currently able to recall the following addresses:

1948 ta 1967: Releiz Valley Read, Lafayette, California,

1967 to 1969: United States Army;

1970 ta 1972: Oakland, California; . :

1972 to 1976: Martinez, California;

1977 to. 1986: Oakley, California;

1986 to present; Clearlake, Califomia. ‘
6. Plaintiff: attended grade school in Lafayette, California and Stanley, California.

1 27} Plaintiff attended Acalines High School in Lafayette, California; and high school in Pleasant Hill

28

Califomia.

KAlnjured\LOS81SAbsacof wp 2 .Son Aw Pw

7 March 26, 2009.

8. ‘This interrogatory calls for information that is not relevant to the subject matter o:
this action, and so remote that it is net calculated to Jead to the discovery of admissible evidence,
and therefore privileged under plaintiff's right of privacy. Evid, Code §§ 350, 352. See also
People v, Castro (1985) 38 C.34; People v, Beagle (1972) 6 C.3d 441.

9, _ Plaintiff was a member of'the United States Army from 1967 to 1969, Please see
Sesponse ta Interrogatory No. 26, below. - :

10, Excluding plaintiff's expert consultants, Plaintiff recalls the following psa

a Dr. Freeman Mark.

b 15322 Lakeshore Drive, Clearlake, California.

c. General health maintenance, including exams arid treatment for severe.
colds. Plaintiff was prescribed inhalers and steroids. .

d. --2001 to the present.

e Primary health care.

£ Plaintiff's investigation and discovery are continuing.

Il. Excluding those used by plaintiff's expert consultants, plaintiff currently recalls

the following hospitals: ,
a Redbud Hospital.
b. Clearlake, California,
G Plaintiff received stitches for a cut on his hand.
d. 3008. -
e Stitches, cut on hand.
£ Plaintiff's investigation and discovery are continuing.

Veterans Administration Hospital.

San Francisco, California.

Plaintiff had a colonoscopy.

2008. : :

aes

KAigjurecMOS81SVAf-sacsfl wp 3oe UO eR ON

Se ee
Qh = oS

e Colonoscopy.
£ Plaintiff's investigation and discovery are continuing.
12. Excluding any taken by plaintiff's expert consultants, plaintiff does not recall arly
other chest x-rays, Plaintiff's investigation and discovery are continuing.
13. Excluding any taken by plaintiff's expert consultants, plaintiff dees not recall any
other pulmonary function tests. Plaintiffs investigation and discovery are continuing. 3

14. Please see response to Interrogatory No.'s 16 and if, above. Plaintiff defers tohis

medical records as the best sousce of information for medications prescribed,
15. Notat this time. Plaintiff's medical records are equally available to defendants
through Betry & Berry, designated defense counsel. :
16, Plaintiff has the following complaints from ashestes exposure: shortness of ¢

breath,

a Approximately 1998, .

b ‘No cessation. . :

o Plaintiff is currently unaware of any physical change.

d. Plaintiff contends that his lungs have primarily been affected. However,
as the lung function affects tlie rest of the body, plaintiff also contends t
all parts of his body have been affected.

e-f, Not applicable.

g Plaintiff does not at this time contend that he hes lost time from warkas a
result of his asbestos related conditions. Plaintiffs investigation and "
discovery are continuing. :

h Not applicable.

i, Plaintiffs investigation and discovery are continuing.

17 Yes. ~

ab, Plaintiff was diagnosed with asbestosis on or about July 2007.

cl. Information protected by either the atiormey work-product doctrine or the
attorney-client privilege. Plaintiff's investigation and discovery are :

KAtnfuredOSBISALsacsfl apd 4continuing. . ‘

1
i 2 18. No. -
3 19, Plaintiff has suffered respiratory complaints and symptoms during the last 10”
4]! years, including but not limited to: shoriness of breath. t
sh 20, No.
 6i. 21. ‘Not applicable. . .
: 7 22. No. - .
: 8 23. Yes. . :
{ 9 a, __ Plaintiff recalis smoking from 1975 to 2008. :
: - 40 “h, — Plaintiffrrecalls smoking cigarettes. :
il c. Plaintiff recalls he usually smoked approximately 10 cigarettes per day.
, 12 d. _Plaintiffrecalls he usually smoked pack of cigarettes per day.
| 13 Plaintiff recalls smoking Keal, Pall Mall and Maribora brand cigarettes.
: 4 No. :
! 15 24. No. . . : ‘
| 46 25, Plaintiff seoals first consuming alcoholic beverages at age 17. Plaintiff presently
17]] drinks 6 beers, or 2 shots of whiskey. ‘
: 1g 26, Plaintiff is currently able to identify the following employment information: +
8 Location of Exposuze, :
+ 20] Employer Exposure Job Title Dates
: 21] Donald R. Husbands General Glassblowing Co. GlassBlower 1964-1965
General Glassblowing Co, —_- Richmond, C. :
* 221 Richmond, . .y
, » fob Davis Pat pew es glass, blew it and it ond shaped it. ni currently unaware reife
. Location of Exposure
25 || Employer Exposure » Job Title Dates
26 | Best Bay Newspaper Inc. Contra Costa ‘Times Laborer 1964-1965. *
eek, CA : (2-3 weeks) .

JobD Duties: Pisin operated machinery in the room and stacked the newspapers as they
rinting press. Plaintiff prepared { prepared for delivery. Plaintiff recalls the
allowing cowotker: steve Pelz, c/o Brayton Purcell, LLP. Piaintiff is currently unaware ifhe

KNqjured 0581 RAC sacsit.wpd, §was exposed to asbestos during this employment. /

L
, 5 Exposure
2} sploe reesionot ote Bas
3 ‘ Cook =. —«1966 ,
: Lacord Drive ins. Inc. Chaps Drivel | :
i 4 s Drive In Lafayette, CA
Vallejo, CA :
‘ . 3, s
5 Job Duties: Plaintiff prepared haniburgers. Plaintiff is currently unaware if he was exposed to,
: 61) asbestos during this employment. :
. Location of Exposure
‘ 7 Employer Eeposure Job Title Dates +
8
: i Laborer 1966 '
5 Gaiversal Press of San Jose A Unknown Gee
10 “San Jose, CA . '
‘ Job Duties: Plaintiff operated machinery in the pressroom andl stake she newspapers TY
i came off the printing press. Plaintiff’ ‘prepared the papers for delivery. Plaintiff is currently '
b ‘unaware if he was exposed to asbestos during this employment. .
‘ Location of Exposure,
13] Employer Exposure lob Tit Dates
' 14l US Anny US Amny - Mechanic 1967-1970
Fort ‘Lewis
15 Tacoma, WA '
i6 ‘US-Amy 1968-1969 ;
Vietnam

. '
Job Duties: Plaintiff completed his basic taining in at Port Lewis, Plaintiff was trained in
mechanical maintenance. Plaintiff: maintained mihtary sucks manufactured by FORD, jEEF and

Plaintiff used BENDIX replacement brakes provided his employer. Plaintiff’ Teplaced
valve covers. Plaintiff wa sent to Vietnam & work in the caintiion forces. inti

Plaintiff recalls Ughtening the clutch on an AMERICAN CRAN! CORPORATION crane with a
drag line, Plaintiff recalls the following coworker: “ Mr, Coker,” current address unknown.”
Plaintiff currently contends le was exposed to asbestos during this employment. «

Location of te Exposure

Manpower Inc of Washington Unknown Janitor " 1967 a
De, Milwankee, WI .

Job Duties: Plaintiff currently does not recall the specifies of this employment. Plaintiffis
currently unaware if he was exposed to asbestos during this employment. Lot

KAlnjured\l0541S\aLpnest wed 6ee Na eR NS

\

Employer
"Santa Ee-Pametoy Inc. Unknown Location

Location of eT Expos

Dutics: Plaintiff currently does not recall the specifics of this employment. Plaintiff is
Jeb Oe aware if! he was exposed to asbestos during this employment.

a ect

Location of Title Exposurt vf

‘USN: Naval Wea} Station Rigger 1970 ;
Us Wear ons Station. Concord, CA . (3-6 months)

Concord: CA +

fob Duties: Flsintity loaded bombs on various Victory Ships. securing them § for tas tation,
laintiff recalls ing-asbestos-containing pipe insulation on steam wi
bombs. Plaintiff cut and Fe ees contakniag paacnite board to secure the loads. PI anti ’

currently contends he was exposed to asbestos ‘during this employment. 4

Location of Exposure .
Employer Exposure Job Title DB: ‘

Marin Storage & Tracking © Unknown Unknown 4970
Tnc., Petaluma, CA . .

Tob Duties: Plaintiff currently does not recall the specifies of ‘this employment. Plaintiffis ,
currently unaware if he was exposed to asbestos during this employtnent. ,

Location of Exposure
Employer Exposure. Job Title Dates
Bradford Building Services Unknown . Unknown i97i ‘
Inc., Los Angeles, CA . :

Job Duties: Plaintiff curently does not recall the specifics of this employment. Plaintiffis ,
currently unaware if he was exposed to asbestos during this employment ,

Location of Exposure
Employer Exposure Job Title Dates .
Triple A Machine Shop Inc. Triple A Machine Mechanic 971 ‘
Richmond, CA Be onal CA Shop ° x

‘

Job Duties: Plaintiff performed maintenance on co! vehicles. Plaintiff recalls the following,
coworker: Steve Pela. clo Brayton Purcell, LLP. Pines currently laintie rege aecamased tS
asbestos during this employment. .

Location of
Matson Terminals Inc. ‘Various Matson Navigati - ‘
Matson Tem vaious! lavigation Carpenter 1971-1973

Maison Perminals

Qakland, CA
‘Kare OSB1S AL snestt spd 7Job Duties: Plaintiff set up scaffolding aang ovine for maintenance of pi Nal salle “t

pipe insulation alve ster
| {ls debris from the. itters work fell onto os-contgini Se atly on
daring maintenance. seen contends he was exposed to asbestos during /

employment.

ion of Exposure
| Employer iiiaewe Job Ti Bates.
6|
| Fluor Products Company Inc. PG & E > Carpenter 1972
7|| Santa Rosa, Pittsburg, CA

| Job Duties: Plaintiff set scaffold a.cpoting tos tower that needed replacement of ‘
asbestos-contaiting insulat insulati st aut recais the iding collected ‘asbestos-containing ,
oP alseanded insulation scab ne the scaffolding. Plaintiff

9|| insulation. Plai
0 currently contends he was exposed to asbestos during this emp!
I
Location of Exposure *
11] Employer Exposure Job Title Dates :
12|] Arne Fatk Construction oe Unknown ‘Unknown 1972 .

General, Redwood City, CA

Job Duties: Plaintiff currently does not recall the s sfics of this employment. Plaintiff i is’
currently unaware if he was exposed to asbestos during this employment.

15 Location of Exposure
16 | Employer © Exposure . Job Title Dates

} Ronald Jean Bohm Various residential Carpenter 1972 t
17} Pro-Duction Co Quality locations throughout Contra

Construction, ©: and, CA Casta County, CA. so

Job} Duties: Plaintiff cut, fit and assembled wood materials for Framing, Plaintiff built seaffol scaffolding
19] used Sea other trades. Plaintiff moved and dismantled sunffolding y various other
I includ ers, electricians and insulators. ging use ‘disturbed us other ade: asbestos!

201 ‘materials used coe ‘tir trades Which fell to the ground, creating dust. Plaintiff currently contends
I| he was exposed to asbestos during this employment.

Location of "Exposure
22\ Employer Exposure Job Title Dates - +
231 Oscar E. Erickson Inc. Bex Re 1972
Osc von . pexonR efinery Carpenter

| Job Duties: Plaintiff cut, fit.and assembled materials for framing. Plaintiff’ built moved and
dismantled scaffolding used by sarious ter including insulators, pipefitters, boilerskaker

which fell to the ground, creating dust when bs tumed se ileton boards. ae ‘set uP
stageing for, {radesmen ios work on laren ‘bagged i
gisposed of of i it ing atrash esse buildi Scattoldiy
BENE PLANT woken removing a ond wie
} Moons containing paskets and saves on refint ent and machinery. Plaiti
| scaffolding used by insulators from PLANT INS! non removing and replacing ‘

WK Alnjured O58 \Al-cxcstT pd &: 1] insulation. Plaintiff recalls se flowing geworkers: George ingles, slo Bras fe, Cea i,
24} California; Mr. Strout,

: Location of Exposure
4{ Employer Exposure dob Title Dates :
5 Foley PMI Tac. Shell Ci . Carpenter 1972, .
Chantilly Martinez, CA :

stagging for pipefitters,
7/|| Plaintiff used boards for ctat then g and sine ieee ee removed the scaftoldi when repalts were

8 || containing insulation that the the boards, Plaintiff currently contends he was
9 exposed to asbestos during this ts
. Location of Exposure
10] Employer Exposure . Job Title Dates
11 || RL Chaides Construction Co, Various Residential Drywall 1972
Inc. Locations throughout Carpenter
12}| Fremont, CA Contra Costa geet CA .

13
14

PANY VY Joint and and taping com: laintit? recalis the following cow coworker: Steve Pelz c/o}
a Tatty contends he was exposed to asbestos during this
aan 1
Location of Exposure
Employer Exposure ile Dates 2,
| KB Home North Bay Inc. Various Locations Drywall. 1972

‘Los Angeles, CA feroughout Nor By Carpenter

Job Duties: Plaintiff set B , scaffolding for new construction, Plaintiff assisted drywallers .

ER GYPS' Null A Fire’ 5/8 inch he ed X drywall boards.

on Purcell,
ard Gentry, de ceased; Les Moot
currently nly onkaown. Plaintiff currently ee mends that

LLP; Roland Bjork, Concerd,
exposed to asbestos during this employment.

‘

Job Duties: Plaintiff set up scaffolding and insulators and boilermakers,

complete, Plainti? recalls that he removed the scaffolding, he

Job Duties: Plaintiff mixed and applied ashestos-containing joint and taping compounds, :
Plaintiff sanded asbestos-containing joint ome is hetween application of each . Plaintiff;
Bit and sanded KAISER ove es COM ANY, INC and UNITED STATES GYPSUM

moving and ins and install KAI

em ismantled scaffolding used by yerious other trades including.

lasterers, el Se aes and insataiors Plaintiff disturbed discarded asbestos materials used by
Phe trades which fell to the ground, creating ust, Panne recalls debris from the apy ication
‘and sanding of asbestos-containing all board and joint and topping compounds often féll
onto the scaficiding and was disturbed when he took if apart. Plaintiff currently contends he was

to asbestos during this
Location of * Exposure *
Employer Exposure Tob Title Dates :
California Delta Homes Inc. Various Locations Drywall 1972
Byron, CA. throughout Carpenter

Contra Costa County, CA .
Job Duties: Plaintiff set up scaffolding and framing for new construction. Plaintiff assisted -

KAlnjured OSBISAL secs wed 928 2 FY

OM Nae
BS S$ 6 oe UA hw PB oN & So

. Fire-rated X
ters moving and installing KAISER GYPSUM ‘Null-A-Fire’ 5/8 inch erate oa

ne Plaintiff moved sta enantled scaffolding used by drywailers.

sanding of asbestos-containing drywall board and joint and toppi
from ne lication and sending Folding and waa disturbed when he took it apart Pl ica
currently contends he was exposed to asbestos during this employment.

. . _ > Location of Exposure =‘
Employer Exposure : Job Title Dates t
George B. Congdon Itt Unknown . Unknown 1972-1973,
Construction Co. Inc. : :

Los Altos, CA © 1
Job Duties: Plaintiff currently does not recall the specifics of this employment. Plaintiffis  -
currently unaware if he was exposed to asbesto: asbestos during this employmient.
Locationof . Exposure
Employer Exposure . Job Title Dates
gel ne. CA Matigus residential the Drywall 1973
lose, oo Arya Carpenter
a San Jose Area,
Job Duties; Plaintiff set up re for new construction. Plaintiff moved and
dismantled scaffolding ‘sel by aged ers. recalls debris from the application and 4
sanding of asbestos-c and joint and topping Is often fell onto
the scaffolding and was disturbed when he board €8 ite ‘apart, Plaintiff ¢: contends he was *
exposed to asbestos during this employment. . : .
*  Lecationof © : Exposure
Employer Exposure dob Title Dates
United States Army Reserves Angell Island Immigration Reservist 1973 ‘
on an Brancisco, CA ‘
Job Duties: Plaintiff removed piling left from the demolition of ald buildings on the ihnd
Plaintiff currently contends he was exposed to asbestos during this employment.
Location of Exposure +
Employer _ _ Exposure: Job Title Dates
Kenneth Rose Unknown ‘Unknown 1973

Napa, CA

Job Duties: Plaintiff current]; does not recall the specifics of this employment. Plaintiff ig
currently unaware if he was eposed to asbestos during this eraployment. ,

Location of Exposure .
Employer Exposure Job Title Dates“
Christensen Contracting Co. Various Residential: Drywall 1973-1974 *
Santa Rosa, CA ‘ing locations thro utthe- Carpenter
. San Francisco, Bay

Job Duties: Plaintiff worked on new construction. Plaintiff set up scaffolding and framing for

KAtnjured losses ab sansta.wod > iWlaintiff moved and dismantled by drywallors. Plaintiff
cared ares anata if drywall boards to crs, Pla see recalls ¢ ope from the ds
ication and sandin, asbestes-containing ing con compound
en fell onto the folding and was disturbed Tren: board one it hart Paina
contends he was exposed to asbestos og during this employment.

Location of Exposure -
Employer Exposure Job Title Dates .
Howell & Lec Inc. Unknown Unknown 1973 ‘

Napa, CA :

Job Duties: Plaintiff currently does not recall the specifies of this employment. Plaintiff i is -
currently unaware if he was exposed to asbestos during this emp!

Location of . Exposure
‘Emplover . Exposure: "eb Title - Dates
Rahlves Organization Unknown *- Unknown 0B,
Benicia, . : ’

Job Duties: Plaintiff currently does not recall the specifics of this eniployment. Plaintiff is
surrently ‘unaware ifhe was exposed to asbestos during this employment. :

: _ Location of : , Exposure
Employer Exposure deb Tide Dates :
DL Nelson Corp Unknown - Carpenter 1973 ‘
Oakland, CA :
Job Duties: Plaintiff set up scaffolding used by miliwri . Plaintiff récalls that hat mitlorighs
made repairs to pumps. Plantiff assisted millwrights ‘ing asbestos-containing gaskets on

these pumps, changing the seals and leveling the pumps. Planet ‘currently contends he was
exposed te asbestos during this employment .

Location of Exposure.

Employer Exposure dob Title Dates |
Biltwell Development Co. A Vatious Residential ” Carpenter 1973

locations throu; .

San rancisea, CA San Francisco uf the .

Job Duties: Plaintiff worked on new construction. Piaintiff cut, fit and assembled wood materials
for farming, Plaintiff built soaffoldi used by other trades, Plaintiff moved and dismantled
scaffold ing used by various ein ee Oe abe Gedee w Jumbers and insulators. Plaintiff
disturbed discarded asbestos, materials used by trades, which fell to the mad, creating
Gust. Plaintiff worked. adjacent to drywailers Huxing, appl sanding G GEORGIA F

jm compounds, Plaintiff currently contends ds he was 10 asbestos.

employment.

ue
Wt

KAlsjured f0S8(StAL-tsesf1.wpd liLocation of - Exposure

"Employer Exposure Job Title Dates
Floyd Raynor Const. Inc. Various Residential and Carpenter 1973-1974
San Jose, CA Commercial locations
thro! the San :
Francisco Bay Area, CA

Job Duties: Plaintiff cut, fit and assembled wood materials for framing. Plaintift built
scaffolding used by other trades, Plaintiff moved and dismantled scaffolding used by various
other trades Stan is deywallers, plasterers, electricians and insulators. Plaintiff disturbed

discarded asbestos materials yy other trades, which fell to the ground, creating dust,
Plaintiff currently contends he was exposed to asbestos during this employment. :
Location of Exposure

Employer _ Exposyre Job Tide Dates ‘
Dillingham Corporation Shell O11 Carpenter 1974; 1978
Walnut Creek, Martinez, CA ’
Job Duties: Plaintiff recalls on shutdowns. Plaintiff removed asbestos-containing pipe

i block insulation to set up ing snugly against equipment requiring. a

zi insulation on steamtines, replacing, eutting and insta!
Plaintiff worked adjacent to insulators cutting and installing new insulation on pi
equipment after the necessary repairs were made to the Pines. Plaintiff removed and dismantled

ding containing discarded asbestos-containing debris after other trades finished their Wor
Plaintiff cesrently contends he was exposed to asbestos during this employment. ‘ e
Location of . Exposure
Eraployer Exposure dnb Title Dates
Malpass Construction Co. Various Commercial Carpenter 1974 ‘
. . ‘buildings throughout the
Pleasant Hill, CA = Francisco Bay Area, ’

Job Duties: Plaintiff set up scaffolding for roofers. Plaintiff is currently unaware ifhe was
exposed to asbestos during this employment. a

Location of Ex °

Bmoloyse Exposure JobTide = Dalen,

Ser Industries Inc. . Unknown Locations Carpenter 1974 ‘
apa, CA Petaluma and Healdsburg, .

Job Duties: Plaintiff recalls working in a rock quarry, hauling asphalt. Plaintiff is currently -
-unaware if he was exposed to asbestos during this employment, pal . y

Location of : Exposure
Employer Exposure Job Title Dates :
Hess Concrete Construction Various homes throughout Carpenter 1974
Co, Inc. Contra Costa County and
American Canyon, CA. Solano County, CA

KAlajwred\ S81 Latest. wpd "32t

ed concrete for curbs and gutter. Plaintiff is currently

a
iff set up forms and
Job Dates Plains exposed to mebestog daring this employment. ©

Locati Exposure ‘
: 3{| Employer Lone job Title Dates 1
‘ Bechtel Inc. Phillips Petrolewn Carpenter - 1975-3976 .

‘San Francisco, CA Company .
Avon, CA

Plaintiff built scaffolding used
Job Duties: Plaintiff cut, fit and assembled materials for sing cod aint seat foldin

- ther trades. Plaintiff moved and dismantled 2 block s Ma
‘ ifn ing gel to the gu cing See cap si ee ee eon
to the a jainti n
pipes. Plena beep bri cain faintiff worked adjacent to ¢
insulators fom PLANT INSULATIO: insulating pipes with ashesies-containing pipe insulation,
* Plaintiff currently contends he was exposed to os during this employment. :
10 - Location of Beane
it © 7
Albay Construction Co. Shell Oil . Carpenter 1975-1977
+ 125 Mi Martinez, CA

ies a ear olog png a end pipewny. Plaintiff set tf ged ppt ‘
‘Ss insu! 3 of ‘ass i
Bom P Sr Pn BO ARY PLANT CLEANERS, Futeeee

repairi cen va ad tea On Dij virig asbestos. containing INC ton Plaintiff
15 ree pang ake 1 op Pipes secs asbese ig ips nealation,P insulator
removed oc half- ound be on pipes, See ‘recalls laborers hired
16} directly by the refi and clgoning di sito asbestos debris. Plaintiff currently
" contends ee arias this
: Location of . Exposure *
18] Employer Exposure Job Title Dates t
19}| Hayman Homes inc. Vi residential a i
‘Los Altos, CA - Yavions esi Tocations eee 1915 :
20 throughout the San’ .
mn Francisco Bay Area, CA
Job Duties: Plaintiff operated a back hoe, removin a pul: wut asbestos-cement
22 | for tie-in work. Plains recalls uncovering the beloe cement pipe ng os rd and pulling it out. ee ie
n currently contends he was exposed to asbestos during thi s employment.
Location of
24 . Peposnce
251) Simpson Flolding Inc. - Unknown © Unknown 1976
Pleasanton, C: . : .

Job Duties: Plaintiff currently does not recall the specifics f this employment. Plainti .
currently unaware if he was exposed to asbestos during this his employment. iets .

ut

KAlnjured MOSBLSWASsncaf wed BB .own nw & wy

Exposure

Fool Location of job Title Dates '
nstructi PG&E Equipment 1977
ABB Consteuejon «Pittsburg, CA Operator
Chattanooga, TN .
Job Duties: Plaintiff operated aback hoe. Plaintiff is currently unaware ifhe was exposed to .
asbestos during this employment. :
Location of Exposure
Employer Exposure Iob Tile Dates :
Kirkham Chaon & Kirkham Various residential and Equipment 1997 ,
Ine., Concord, CA commercial locations Operator
throughout the San
Francisco Bay Area, CA
‘Job Duties: Pleindift operated a back hoe. Plaintiff is currently unaware if he was exposed to,
asbestos during this employment. 1
Location of Exposure,
Employer Exposure lob Title Dates
Dee Mac Construction Co. 9 Unknown Byuipment 1977
Tnc., Farmington, NM Operator
Job Duties; Plaintiff operated a backhoe. Plaintiff is currently unaware if he was exposed 9
asbestos during this employment.
. Location of . Expose |
Employer Exposure _ dopTitle Dates
Alva G. Banks Unknown wipment «1977
Reliable Cleaners Baer
Salinas, CA '
Job Duties: Plaintiff operated a backhoe. Plaintiff is currently unaware ifhe exposed fo*
asbestos during this capi loyment. ly was fe"
Location of : Exposure
Employer Exposure Job Title Dates
SJ Amoroso Construction . Various residential and Equipment 1977
commercial locations Operator
Ronmpany Shores, CA throughout Contra Costa
County, CA
Job Duties: Plaintiff operated a back hee. Plaintiff is currently unaware if he was exposed 16
asbestos during this employment.
Location of Exposure
Employer Exposure dob Title Dates
Gallagher Properties Inc, ‘Unknown Unino 1978
caesar wn

KAtgnoed 0581S A paceth wt 14ww NAH eR BOW

mee
= so

not recafl the specifies of this employment, Plaintiff is

jes: Plaintiff currently does ecifics |
10 ee ware ifhe was exposed fo asbestos during this employment.
Location of Exposure ;
‘Employer Exposure Job Title Dates :
Cahill Construction Co. Unknowa location Carpenter 1978 ‘
San Francisco, CA San Francisco, CA

ies: Plainti scaffolding and framing for new construction. Plaintiff moved and

dGeuoniled seablding a ales. Piainti Hs gebeis from the application an and
§ i ny e '

Sag ot es hen he took ip ‘currently contends he was exposed to asbestos .

during this employment.

Location of Exposute
Employer ure Job Title Dates
Self Emplo: Various residential Equipment 1979; 1980»
Hiub's Backhoe Service locations ti yui Contra Operator

Casta County, CA .

Job Duties: Plaintiff drove a backhoe and a dump truck for various clients. Plaintiff dug ditefes
for clients and looked for pipelines, Plaintiff is currently unaware if he was exposed to asbestos
during this employment,

>

Location of Exposure.
Employer Exposure, lob Tifle Dates ‘
Moseman Construction Co. Various commercial and Equipment 1982-1983
ACorp., Englewood, CO residential locations Operator +

throughout the San

Francisco Bay Area, CA .

Job Duties: Plaintiff operated equipment trailers and fuel trucks. Plaintiff performed tune-ips
and mechanical repairs on trucks and equipment. Plaintiff recalls removing and replacing the
‘rakes and chan ing the valve cover gaskets. Plaintiff operated equi for

cons! ion. ‘was adjacent to underground crews installing piping for water lines, sewer
Fines and ston drains. Plaintiff ocalle using back: hoes fo dig up esbestos-comsent pipe wien
performing underground tie-ins and piping work. Plaintiff currently contonds he was exposed to
asbestos during this employment. .

Location of Exposure.
Emplover Exposure JobTile Dales
Eugene G, Alves Unknown Sho; pipment g ,
Construction Co. Inc. sknown Shop eee i 1983
Pittsburg, CA.

Job Duties: Plaintiff operated FORD and MACK TRUCKS INC, fuel trucks and loaders, ,
scrapers and dozers manufactured by INTERNATIONAL HARVESTER. Plaintiff assisted the
-company mechanic ig an air hose to blow out brake dust before the mechanic removed an

brakes and clutches. Plaintiff was adjacent to the mechanic as he removed the brake
shoes. Plaintiff currently contends he was exposed to asbestos during this empl

KAlnjured N0S81S\AL-sacsfi wpe 15 > .Exposure '

Location of .
Employer Exposure Tob Title Dates .
Ferma Corporation Unknown -* Operator- 1983
Mountain View, CA F Mechanic /
ies: Plaintiff operated CATERPILLAR excavators, dozers end loaders. Plaintiff
ee eet er aiptient By adjusting the brakes and re-shoeing the brakes. Plaintiff blew out the '
asbestos debris when ins; the brakes, Plaintiff’ acoworker: “Eugene,” current
address unknown. Plaintiff currently contends he was exposed to asbestos during this
employment. . . .
Location of . Exposure
‘Employer Exposure Job Title Bates .
Jamieson Cony Jamieson Ci Shop Mechanic 1984-1985,
iimcary = mace

Job Duties: Plaintiff serviced fuel tracks, scrapers, dozers and loaders manufactured by _
INTERNATIONAL HARVESTER and CA’ TERPILLAR. Plaintiff crawled around surveying:
equipment for damaged Plaintiff greased the equipment and inspected the brake systems
using compressed air to blow out the dust. Plaintiff. s the following coworker: “Rusty” *
address, Plaintiff ordered all replacement parts directly from the original manufacturer. Plaintiff
currently contends he was exposed to asbestos during this employment.

Lacation of : Exposure
Employer Exposure Job Title Dates ‘
Jamieson Company _ Unknown Unknown 1986-1988 °

Pleasanton, CA : t

Job Duties: Plaintiff currently does not recall the specifics of this employment. Plaintiff is
currently unaware if he was exposed to asbestos during this employment.

Location of Expo:
‘Diablo View Equestrian Unknown 3 I ,
i Faves Unknown 989

Job Duties: Plaintiff currently does not recall the specifics of this employment. Plaintiffis ~
currently unaware if he was exposed to asbestos during this employment. anaes .

Location of Ex .
Employer Exposure Tob Titl Dag
Peck & Hiller Co, “Various residential and. i 1
Hayward, CA commercial locations Ea emior 989

throughout the

Francisco, Bay Area, CA.

Job Duties: Plaintiff operated fork lifts and loaders, Plaintiff is currently i
exposed to asbestos aurieg this employment. ore. < tnaware ifhe was .

iif 7

KAnjured OS 1S\AL-sscsElupt 16Employer

OC Jones & Sons Shasta
Constructors Inc. A Joint

Venture
OC Jones & Sons
Berkeley, CA

Job Duties: Plaintiff operate
unaware if he was exposed to

Employer
Mscobo. op.

Job Duties: Plaintiff operated back hoes and cor
Fe Outi usrently unaware if he Was exposed to

‘Employer

Location of Exposure
Employer Exposure Sob Title Dates : :
MCM Trailer Services inc. Unknown ipment 1991 .
Granite Bay, CA Savers 4
Job Duties: Plaintiff operated a back hoe. Plaintiff is currently unaware if he was exposed to
asbestos during this employment. ty oP .
Location of Exposure *
Employer Exposure igh Title Bates
Advantage Transport Inc. ‘Unknown Equipment 1991
pe ce Operator ‘
-Job Duties: Plaintiff installed wiring on trailers. Plaintiff is currently unaware if he was exposed
to asbestos during this employment. oe
Location of -  * Sxposure
Employer Exposure Iob Title Dates
Granite Construction Yasious locations Eauipment 1991-1992 -
oughout erator
Watonville, CA Francisco Bay Area, CA

KAjures OSB EAL secsftwpd

Location of
Exposure

Various residential and
ial locations

commercial

d dozers, loaders and seray
asbestos during this employment.

Location of
Exposure

Various hoi tractsin Equipment
farious using in

pa y trucks a and dog tugs nina ‘

Fremont,

a

Exposure ‘

JobTitle - Dates
Equipment «1989; 1994
Operator

4

s end a fuel truck. Plaintiff is currently

JobTitle - ‘Dates
1989-1991

Exposure,
iobTile . Dates
uipment 1989; 2002
Operator ‘

‘|

Job Duties: Plaintiff operated a fuel service truck, Plaintiff is currently unaware ifhe was —
exposed to asbestos during this employment. :

Location of Exposure :
Job Tithe Dates

Employer . Exposure ic ‘

DW Construction Inc. Unknown Equipment - 1991 .

Alamo, CA . Operator
Job Duties: Plaintiff: currently does not recall the specifics of this employment. Plaintiff is

currently unaware if he was ‘exposed to asbestos during this employment.

Location of Exposure,
Employer Exposure - Job Tith Dates
MBM & Daughters Inc. Waldo Tunnel Equipment 1991
Redwood City, CA. Highway 101 Operator 4

Sausalito, CA 4
Job Duties: Plaintiff ran a forklift on a Prgied used to install new crash barrier walls. Plaintiff’ is
currently unaware if he was exposed to asbestos during this employment. .

Location of Exposure
Employer Exposure Job Title Dates ,
Wayward Baker Inc. Unknown, Unknown 1992, .
Odenton, MD .

Job Duties: Plaintiff currently daes not recall the specifies ofthis employment. Plsintiffis
currently unaware ifhe was exposed to asbestos during this employment. 1

Location of Exposure
“Employer Exposure Job Title Dates :
Bay Cities Crane & Rigging Standard Oil ipment 1992
ine, Long Beach, CA 3 Richmond, CA Seetor
Job Duties: Plaintiff ed a truck crane, Plaintiff i be i
sO ee Raina this operat amr ¢ is currently unaware if he was exposed lo
Location of Exposure
Employer Exposure Aob Title Dates
William P. Young inc. Unknown Unknowa 1892

Foster City, CA

Job Duties: Plaintiff currently does not recall the specifics of this employment Plaintiffis °
currently unaware ifhe Ten coeet ta asbestos during this employment s

: Location of Exposure
Employer : Exposure dob Title Dates
Darren James Kirby Gradex Unknown Crane 1992 .
Company, Concord, CA Operator

Job Duties: Plaintiff operated a crane. Plaintiff is currently unaware if he was exposed to aspesto:

KAlnforedn0581S\AL-stcstsepd 18during this employment.
i Exposure *
Location of Ti . .
. Bo
Rasmussen Inc. 101 B | Equipment 1992-199:
Gaenta, cA Senta Hoss, cA ‘Operator :
Job Duties: Plaintiff operated a fuel track. Plaintiff is currently unaware if he was exposed to ¢
asbestos during this employment. :
Location of OSU
Ezoployer Exposure - Job Title eS
Equipment «194 ‘
Ames Construction Inc. Unknown Coal Mine ipment .
Brunsviile, MN Nevada - Operator .
-Job Duties: Plaintiff operated a fuel truck. Plaintiff is-currently unaware if he was exposed to!
asbestos during this employment. ‘
Location of Exposure’!
Employer Exposure . Job Tite Dates ‘
Kiewit Pacific CO; Unknown freeway near Equipment ——‘*1994-2003
Omaha, NE Burlingame, CA Operator

:
Job Duties: Plaintiff ran an excavator, dozers and_ back hoes for new construction. Plaintiff is

‘currently unaware if he was exposed to asbestos during this employment.

: Location of : . Exposure ‘
Employer Exposure ob Title Dates
SPX Cooling Technologies Various residential . i 1994; 1995 '
The.- locations throu, Operator ‘
Charlotte, NC Rohnert Park,

Job Duties: Plaintiff ran an excavator, dozers and back hoes for new construction, Plaintiff js

currently unaware if he was exposed fo asbestos during this employment.

Location of . Exposure
Employer Exposure Job Ti Dates
Bechtel Construction Co, Shell Oil ipment 1994 .
San Francisco, CA Martinez, CA autos .
Job Duties: Plaintiff worked on a clean fucl project ting hea ipment. Plaintiffis .
' currently unaware if he was exposed to aebentoe fatte dus employment Plaintifis

Location of - Exposure
Emplover Eaoosue IobTie Bates
Bechtel Capital Management Unkno ipment 195-1996
San Branco, CA wm nies * 1995-199 .
Job Duties: Plaintiff ran an excavator and a back hoe. Plaintiff is currently unaware if he wis
exposed to asbestos during this employment, . .
‘KAfure 1058 1S1AT-acsf.wpd . 18oe WD HA hw Ye

ee ee
BD RS

4

Location of Exposure
or Jab Title Dates

Employer , Expose

‘Delta Excavating Inc. Unknown ae 1996 :
Job Duties: Plaintiff operated an excavator. Plaintiff is eurrently unaware if he was exposed 6
asbestos during this employment. \

. _ Location of Exposure
Employer Exposure : Job Title Dates ,
AP Hill ne, ‘Unknown location — Equipment 1996-1998
San Ramon, CA East Bay San Francisco, Operator '
Job Duties: Plaintiff worked for this contractor operating excavator and back hoes. Plaintiffs
currently unaware if he was exposed to asbestos during this employment.

. Location of Exposure .
Employer Exposure igh Title Dates ,
J&Mine. Various residential Equipment S/2V1996
Livermore, CA Jooations thro mat Operator 7

Rohnert Park, CA. ;
Job Duties: Plaintiff ran an excavators and dug out underground trenches, Plaintiff is currently
“unaware if he was exposed to asbestos during this employment. ‘
: Location of Exposure’
Employer Exposure Job Title Bass
. oot
Fee Construction Inc, Various residential wipment 1996-2002;
San Ramon, CA locations throughout weer RAOTAISSE +
Oakland, CA : 3/30/1998 |
G/AO/998; ;
1/13/1999; ©

Job Duties: Plaintiff ran an excavator and dug out underground trenches £¢ struction.
Plaintiff is currently unaware if he was expose to asbestos during this employment. ™

Location of sure
Employer Exposure Iob Title Bas
Mountain Cascade Ine, ‘Various residential ‘
Livermore, CA Jooations throu, out the Carpenter 1996
: San Fran ciseo Bay Area,

Job Duties: Plaintiff ran an excavators, dozers and back hoss for new construction. Plaintiff is
“currently unaware if he was exposed to asbestos during this employment.

tt

RAlnjurecMOSE VAT anced 26—

Employer ogee Job Title bas :
Tuocsapecon udm Bast at)
employment. — . / :
Employer sone jpTile «= Da,
Mille ete. - Barponnagcation Bauipment R997

Job Duties: Plaintiff operated an excavator, Piaintiffis currently unaware if he was exposed to
asbestos during this employment. ,

Location of Exposure,
Employer Exposure Job Title Dates
Independent Construction Co, Unknown location Equipment 1997 ‘
Contant CA Oakland, CA Operator
Job Duties: Plaintiff operated an excavator, Plaintiff is currently unaware if he was exposedito

asbestos during this employment.

Location of- . . Exposore :
Employer . Exposure igh Title >
HF Ehier Pres Unknown location | Equipment 1997
Antioch, CA Qakland, CA Operator '
Job Duties: Plaintiff operated an excavator. Plaintiff is currently unaware if he was exposed fo
-asbestos during this employment.
. Location of Exposure ,
Employer Exposure Job Title Dites ‘
Buffalo Construction Inc. ‘Unines . uipment 1997-1998 +
San Anselmo, CA. we Bauipne

é

Job Duties: Plaintiff operated a loader and a dozer. Plaintiff is currently unaware if he was
exposed to asbestos during this employment. - . , .

- Location of Baposure
Employer. . - Exposure dob Tile .
R &L Brosamer Inc. A ‘Unknown Location Mechanic 1997; 1998
California Corp. Qakiand, CA
Walnut Creek, CA .

Job Duties: Plaintiff serviced excavators, dozers and loaders. Plaintiff is currently unaware if he
was exposed to asbestos during this employment.

‘KAlgjurea OSE S\aLsecsflwpd 2iwow AH Fe YN

ee eo
= UA EF ORE S

ig

Exposure
Dass:

1998;

1/13/1999;
12/7/1998

Exposure
Dates

3/03/1999

Location of .
Employer Exposure dob Title
Gordon N. Ball, Inc. ‘Unknown location Equipment
Ramo, aa 1 Ine Oakland, CA Operator
Job Duties: Plaintiff operated excavators. Plaintiff is currently unaware if he was exposed to ,
asbestos during this employment. :
* Location of
Employer Exposure Job Title
RGW Construction Inc. ‘Unknown location Mechanic
Oakland, CA

'

Job Duties: Plaintiff serviced loaders, dozers and excavators. Plaintiff is currently unaware ifhe

was exposed to asbestos during this employment.

Location of
‘Nessco Construction Inc. ‘Unknown site Mechanic
Santa Rosa, CA Rohnert Park, CA, :

Exposure

Job Title Dates «

1999

Job Duties: Plaintiff serviced loaders, dozers and excavators. Plaintiff is currently unaware if he

was exposed to asbestos during this employment.

Location of
Empioyer Exposure
Grade-Way Construction Unknown Unknown
Livermore, CA

Exposure
Job Title Dates

2000

| Job Duties: Plaintiff currently does not recall the specifics of this employment, Plaintiff is ‘
currently unaware if he was exposed to asbestos during this employment. :

=

2000-2001; '
12/13/2000 +

Dates

1712/2000 +

. Location of
Employer Exposure - ob Title
Kiewit Power Constructors © Unknown construction Equipment
Co., Omaka,NE company, Oakland, CA. Operator
Job Duties: Plaintiff operated a lift. Plaintiff is currently unaware if he was exposed to asbestos
-during this employment.
Location of
Employer Exposure JobTitle
Port of Oakland Constructors Unknown Unknown
A Joint Venture
‘Omaha, NE

Job Duties: Plaintiéf currently does not recall the specifics of this employment, Plaintiff is

currently unaware if he was exposed 10 asbestos during this employment.

KAlnjuseOSBINALseestt. pd 22-Job Duties: Plaintiff operated a loader, Plaintiff is currently unaware if he was exposed to

, Location of . Exposure
Employer Exposure + Job Title Dates
Dumbarton Quarry Unknown cor construction site ment 5/13/2002
Rumbarion Q Oakland, CA See

asbestos during this employment.

Location of Exposure
Employer Exposure Job Title Dates
Cooper Crane & Rigging Inc. Unknown Construction site Equipment WA12002
‘Novato, CA Rohnert Park, CA Operator

Job Duties: Plaintiff operated an excavator, Plaintiff is currently ‘turaware if he -was expesed to,
asbestos during this employment. :

Location of : Exposure
Employer Exposure b Title Dates -
OC Jones &s Sons Inc. Unknown Construction site Bawipment a18200%
Berkeley, C. Fairfield, CA 8/13/20;
Job Duties: Plaintiff operated a mult engine scraper and a smal tractor. Plaintiff is currenth:
unaware if he was exposed to amuldple ee this employment. y
Location of Exposure -
Employer * Exposure JobTitle Dates
“Ecco Equi it Corp. Unknown Construction site 8/01/2002 -
See aca . Fairfield, CA Obie Sa eOF 5

Job Duties: Plaintiff operated a loader. Plaintiff is currently unaware if he was exposed to |
asbestos during this employment. t

Location of Exposure
Employer Exposure Iob Title Dates
Taylor Bs -Bailey Inc. ° Unknown wn Construction Site Equipment 9/25/2003
‘Napa, CA Rohnert Park, C. Operator

Job Duties: Plaintiff operated a multi le engine scraper. Plaintiff is currently unaware if he was
exposed to asbestos during ‘his employment. y {

Location of Exposure
Employer Exposure ob Title Dates
Terracon Pipelines Inc. - Unknown Construction Site Faripment 1/05/2004
Healdsburg, CA Rohnert Park, CA :

-Job Duties: Plaintiff operated a backhoe and a loader. Plaintiff is curently unaware ifhe was ;

exposed to asbestos during this employment.

RAlnjured MOSEISALsassftovpd ~ . 23eo NM Am kh wD De

Ree ee ee
BSSe 328 R2RBR LS

"Job Duties: Plaintiff operated a backhoe and a loader, Plaintiff is currently unaware if he was

Location of . Exposure
Dates

Emplover Exposure Tob Title t
Diablo Contractors Inc. Unknown Location Operator 4/06/2004
San Ramon, CA Burlingame, CA.

Job Duties: Plaintiff: ‘operated a backhoe and a loader. Plaintiff is currently unaware if he va

exposed to asbestos during this employment,
. i

Location of : Exy
Ghilotti Construction Unknown . pipment 9/07/2004;
‘Company ° eee 9/15/2004; ;
Santa Rosa, CA . 10/11/2004 i

exposed to asbestos during this employment.

werhauls, plaintiff scraped|

during the removal and installation process, When performing engine o
and chipped existing burned out gaskets off exhaust manifo! ante engine head gaskets. i

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 recalis 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 manifoid gaskets, laced
timing shave covers, and overhauled the engine. Seon ied the brakes Soa the'clarch
IS Venic! !

1949 FORD MERCURY, acquired in 1964, Plaintiff replaced the brakes, pulled out 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. Le :

1965 VOLKSWAGEN Beetle acquired in the late 1960s by his father. Plaintiff replaced the
brakes and the clutch. :

Plaintiff currently contends he was exposed to asbestos during this automobile repair work.
Plaintiff's investigation and discovery are continuing.

KAigjuredGS81 SAL seest] pd 24coe NA wh Bw Ne

aoa
Bye S

PR PNM RR -_ ns
BNRRRBBRESGar au

—
&

27. Yes.
a, Carpenters Local 1149, Martinez, California.
'b. - Unktown at present. .

a. Operating Engineers Local 3, Alameds, Califomia, ©
b. Unknown at present.

28. Approximately the 1980s.

29. Plaintiff's investigation and discovery are continuing.

30. _ Plaintiff does not recall observing the use of any safety precautions by anyone
around asbestos or asbestos-containing materials, Plaintiff's investigation and discovery are ©
continuing. , .

31. Plaintiff does not recall using any safety precautions when working around
_asbestog of asbestos-containing materials. Plaintiff's investigation and discovery are continuing.
32. Yes.
Granite Construction Company.
b Physical exam, and drug screaning.
a ‘Once, upon hire.
a. —- Required.
e No,
£ Once, approximately 1991.
8. Plaintiff was hired, but did not receive specific results.
bh.” Unkcown, .
i. Not applicable. -
i Plaintiff's investigation and discovery are continuing.
33. Plaintiff took regular retirement in 2004. :
34. No, -
‘35. No.
36. Yes, please refer to the Non-Occupational Exposure section of Interrogatory No.

KAlgjured OSB RAL toee wpe ‘ 2526, above.

37. Plaintiff's investigation aud discovery are continuing.

38, The total hospital expense is unknown at this time and plaintiff has provided
authorizations for release of this information. Plaintifi's investigation and discovery are
continuing,

39. ‘The total medical expense is unknown st this time and plaintiff has provided
authorizations for release of this information. Plaintiff's investigation and discovery are

Ow Oo WM Aw fF & hb

moe -
ARGS HES

continuing.
40. No.
41. No.
42. Plaintiff currently is not claiming any wage or earning loss,
43. No.
44. No.
45, Yes.
a November 29 to 30, 2007. .
b. Steve Pelz v Asbestos Defendants (BF), San Francisco Superior Court
Case No. 440228; taken at the Law Offices of McKenna, Long &
Aldridge, 101 California Street, 41* Floor, San Francisco, California.
+ e& James Matthews CSR 7916, Tooker & Ants Court Reporting, 330
‘ Sansome Street, Suite 700, San Francisco, California 94104.
ad Yes. :
e See parts a. through ¢., above. ,
46, No.
47, No.
48. No.

Mt

1.4

ut

“KAinjures\aO581 Sval-seceEl,wpdmoe
a@eors

14

Ome a A nh Fw! oe

49. Ne.

i

‘KAlnjured 10581 3:AL saat wpa

50. Yes, a copy will be provided to Berry and Berry via couriet.

BRAYTON@PURCELL LLPi

g
&
g
&

ae
bop oS

Bw NA OH BY Ne

Charles Husband
San Francisco Superior Court Case No.275098
1, Charles Husband, dectare:
1am the plaintiff in the above-cntitled action. The foregoing Answers to Interrogatories,

Sst One., propounded by Defendants Jointly, except as to those matters which are therein stated
on my. information and belief and, as to those matters, 1 believe them true.

I declaré under penalty of perjury under the laws of the State of Catifomin that the
foregoing is true and correct, °

pac 4-20 -0G
, Chad Wn.

: Please do not write below this line. If you bave any changes, please submit them ona

separate sheet of paper. Thank you.EXHIBIT Boo nN OD GO F&F WOW NHN =

bh NM NM NY NS NY =&= @ Ss Bw Ba Be Ba Ba Ba se
a B&B oOo ND |= CG © DB N OO oO F WO NY | CO

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
---000---
CHARLES HUSBAND,

Plaintiff, -
vs. No. 275098

ASBESTOS DEFENDANTS (BP),

Defendants.

NEWLY SERVED DEPOSITION OF CHARLES HUSBAND
VOLUME II

(Pages 181 through 320, inclusive)

Taken before Kimberly L. Avery
CSR No. 5074
April 19, 2011oo Oo ODN DO oO FF WOW NH =

=

255
the room --
MR. MILLER: No.
MS. STERN: -- and we could get a copy of it.
MR, MILLER: You can have a copy of it at any
time. I'm allowed to take out and show him whatever |
want to.
MS. STERN: Let's go off the record.
(Break taken.)

EXAMINATION BY MS. SORIANO:

Q. Mr. Husband, are you able to continue?

A. Oh, yes, | am.

Q. Okay. My name is Jocelyn Soriano, and I'm
going to