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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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 COGLEY MANION JONES HAKE KUROWSKI LLP FILED 444 South Flower Street, Suite 1550 Super ni 7 superior Court of California, Los Angeles, CA 90071 County of San Francisco Tel: (213) 622-7300 AUG 06 2010 Fax: (213) 622-7313 Clerk of the Court BY: CHRISTLE ARRIOLA Attorneys for Defendant Deputy Clerk TEMPORARY PLANT CLEANERS, INC, IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA iN AND FOR THE COUNTY OF SAN FRANCISCO CHARLES HUSBAND, Case No.: CGC-09-275098 Plaintiff, NOTICE OF MOTION AND MOTION TO COMPEL VERIFIED RESPONSES TO v. TEMPORARY PLANT CLEANERS, INC.’S SPECIALLY PREPARED ASBESTOS DEFENDANTS (B*P), INTERROGATORIES ‘TO PLAINTIFF, SET Defendants. [Filed Concurrently with Memorandum of Points and Authorities; Declaration of Fernando Saldivar, [Proposed] Order] Dept: 220 Date: September 2, 2010 Time: 9:00 a.m. Judge: Harold E. Kahn TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that on September 2, 2010, at 9:00 am., or as soon thereafter at this matter can be heard. in Department’220 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 (hereinafter “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 PLAINTIFF TO PROVIDE ESSOR os compel Plaintiff to provide responses to Interragatories Nos. 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47. 48, 49, 50, 51 and 2. - oe This Motion is brought pursuant to, Code of Civil Procedure $§ 2017.010; 2030.290. This Motion is further based upon the attached Memorandum of Points and Authorities, . the Declaration of Fernando 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: August, 2010 COOLEY MANION JONES HAKE KUROWSKI LLP “Fernando C. Saldivar Attorneys for Defendant TEMPORARY PLANT CLEANERS, INC. 2 “DEFENDANT TEMPORARY PLANT CLE. ANSWERS TO SPECIALLY PREPARED INTERROGATORIESPROOF OF SERVICE BY ELECTRONIC TRANSMITTAL 4, Elona C. Conchas, am a citizen of the United States and employed i in Los Angeles, Califomia I am over the age of eighteen years and not a party to the within- entitled action. My_ business address i is 444 So. Flower Street, Suite 1550, ‘Los Angeles, CA 90071. / On August 6, 2010, | electronically served. via LexisNexis F ile and Serve the following document on all parties 88 set forth in the accompanying transaction report: NOTICE OF MOTION AND MOTION TO COMPE {L VERIFIED RESPONSES TO TEMPORARY PLANT CLEANERS, INC.’S SPECIALLY PRERARE D 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. Executed on August 6, 2010, at Los Angeles, California. (Maral! (bekio— Elona C. Conchas ANSWERS TOS ECIAT) i y PREPARED IN] TERROGATORIES