On March 02, 2009 a Party Discovery was filed involving a dispute between Husband, Charles, and Albay Construction Company, All Asbestos Defendants See Scanned Documents, American Conference Of Governmental Industrial, Asbestos Defendants, Asbestos Manufacturing Company, Auto Friction Corporation, Auto Specialties Manufacturing Company, Bell Asbestos Mines Ltd., Bigge Crane And Rigging Co., Borgwarner Morse Tec, Inc., Brassbestos Brake Lining Company, Bridgestone Firestone North American Tire, Llc, Bucyrus International Inc, Carone Brothers, Inc., Cbs Corporation,, Certainteed Corporation, Chicago Bridge & Iron Company,, Cleaver-Brooks, Inc., Conocophillips Company, Csk Auto, Inc., Daimlerchrysler Corporation, Daimlerchrysler Corporation (And Not The Claims, Dillingham Construction, N.A., Inc., Does 1-8500, Emsco Asbestos Company, Fibre & Metal Products Company, Forcee Manufacturing Corporation, Garlock Sealing Technologies Llc, Gatke Corporation, Georgia-Pacific Corporation, Georgia-Pacific Llc,, Hamilton Materials, Inc, Hanson Permanente Cement, Inc. Fka Kaiser Cement, H. Krasne Manufacturing Company, Honeywell International Inc.,, Ingersoll-Rand Company, J.T. Thorpe & Son, Inc., Kaiser Gypsum Company, Inc., Lasco Brake Products, Lear Siegler Diversified Holdings Corp., L.J. Miley Company, Maremont Corporation, Marine Engineering And Supply Company, Metropolitan Life Insurance Company, Molded Industrial Friction Corporation, Morton International, Inc., National Transport Supply, Inc., Owens-Illinois, Inc., Pacific Gas And Electric Company, Parker Hannifin Corporation, Plant Insulation Company, Pneumo Abex Llc, Quintec Industries, Inc., Riteset Manufacturing Company, Rossendale-Ruboil Company, Santa Fe Braun, Inc. As Successor-In-Interest To, Shell Oil Company, Silver Line Products, Inc., Southern Friction Materials Company, Standard Motor Products, Inc., Standco, Inc., Stuart-Western, Inc., Temporary Plant Cleaners, Inc., The Budd Company, Thomas Dee Engineering Company, Underwriters Laboratories, Inc., Union Carbide Corporation, Universal Friction Materials Company, U.S. Spring & Bumper Company, Wheeling Brake Block Manufacturing Company, York International Corporation, for civil in the District Court of San Francisco County.
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CS we RW A h RB BW NW oN wow Mom R py & FS Rk & RE BRE SG William M. Hake, Esq, (State Bar No. 110956) Melissa R. Badgett, Esq. State Bar No, 246238) Fernando C. Saldivar, Esq. (State Bar No. 241035) ELECTRONICALLY COOLEY MANION JONES HAKE KUROWSKI LLP FILED 444 South Flower Street, Suite 1550 Superior Court of California, Los Angeles, CA 90071 County of San Francisco Tel: (213) 622-7300 JUL 23 2010 Fax: (213) 622-7313 Clerk of the Court Attorneys for Defendant BY: CHRISTLE ARRIOLA TEMPORARY PLANT CLEANERS, INC. Deputy Clerk INTHE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO CHARLES HUSBAND, Case No.7 CGC-09-275098 Plaintiff, NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO ¥. TEMPORARY PLANT CLEANERS, INC’S SPECIALLY PREPARED ASBESTOS DEFENDANTS (B*P), INTERROGATORIES TO PLAINTIFE, SET NE Defendants. [Filed Concurrently with Memorandum of Points and Authorities; Declaration of Fernando Saldivar; [Proposed] Order] Dept: 206 Date: August 19, 2010 Time: 9:30 am. Judge: Hon. James McBride TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that on August 19, 2010 at 9:30 a.m., or as soon thereafter at this matter can, be heard in Department 206 of this Court located at 400 McAllister Street, San Francisco, California 94102, Defendant TEMPORARY. PLANT CLEANERS, INC. (hereinafter “TPC") will move this court for an Order compelling Plaintiff CHARLES HUSBAND (bereinafier “Plaintiff”) to provide verified responses to its Specially. Prepared Interrogatories to Plaintiff, Set-One. ‘TPC further requests that Plaintiff serve the supplemental responses, without objections, within seven (7) days of the Court's order. Specifically, TCP requests the Court to “DEFENDANT TEMPORARY PLANT CLEANERS, INC.’S MOTION TO COMPLEL PLAINTIFF TO PROVIDE ANSWERS TO SPECIALLY PREPARED INTERROGATORIESSoe WA th Bs ot compel Plaintiff to provide responses to: Interrogatories Nos. 36, 37, 38, 39, 40, 41,42, 43, 44, 45,46, 47, 48, 49, 50, 51 and 52. - / : This Motion is brought pursuant to Code of Civil Procedure $f 2017.010; 2030296. This Motion is further based upon the, attached Memeorandum af Points and Authorities, the Declaration of Femando c, Saldivar in Support thereof, the papers and pleadings on. file herein and on such other and further evidence and argument as may be presented. at the hearing. of this. Motion. DATED: July 23, 2010 COOLEY MANION JONES HAKE KUROWSKT LLP Attoneye for Defendant TEMPORARY PLANT CLEANERS, INC. “DEFENDANT TEMPORARY PLANT CLEANERS, INC.’S MOTION TO COMPLEL PLAINTIFF TO.PROVIDE | ANSWERS TO SPECIALLY PREPARED INTERROGATORIES.ia OQ oe Sas PROOF OF SERVICE BY ELECTRONIC TRANSMITTAL ~ : I, Elona C. Conchas, am a citizen. of the United States and employed in Los Angeles, California. Lam over the-age of eighteen years and not a party to the.within-entitled action. My business address is 444 So. Flower Street, Suite 1550, Los Angeles, CA 90071, / On Aly 23, 2010, Lelectronically served via Lexis/Nexis File and Serve the following document on.all parties as set forth in the accompanying transaction report: NOTICE OF MOTION AND MOTION TO.COMPEL VERIFIED RESPONSES. 10 TEMPORARY PLANT-CLEANERS, INC’S SPECIALLY PREPARED INTERROGATORIES TO PLAINTIFF, SET ONE, I declare under penalty of perjury under the laws of the State.of California that the above is true and correct. / : ” Byecuied on July 23, 2010, at. Los Angeles, California. Elona C.Conchas “DEFENDANT TEMPORARY PLANT CLEANERS, INC ANSWERS TO SPECIALLY. PREPARED INTERROGATORIES