On March 02, 2009 a Answer 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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28 Walsworth, Frankia, Bevins & MeCall, LLP AnrowSES 57 L40 MICHAEL T. MCCALL, State Bar No. 109580 WALSWORTH, FRANKLIN, BEVINS & McCALL, LLP 601 Montgomery Street, Ninth Floor ELECTRONICALLY San Francisco, California 94111-2612 Telephone: (415) 781-7072 F ILED mile: i superior Court of California, Facsimile: (415) 391-6258 County of San Francisco Attorneys for Defendant JAN 19 2010 QUINTEC INDUSTRIES, INC. GORDON PARK-LI, Clerk BY: CHRISTLE ARRIOLA Deputy Clerk SUPERIOR COURT OF CALIFORNIA. COUNTY OF SAN FRANCISCO CHARLES HUSBAND, Case No, CGC-09-275098 Plaintiff, ANSWER OF DEFENDANT QUINTEC INDUSTRIES, INC. TO PLAINTIFF'S vs. COMPLAINT FOR PERSONAL INJURY - ASBESTOS ASBESTOS DEFENDANTS (B*P), etc.; et al., Defendant. Defendant QUINTEC INDUSTRIES, INC. (hereafter "Defendant"), in answering the Plaintiff's unverified complaint for itself alone, and severing itself from all others, admits, denies and alleges as follows: 1. Pursuant to California Code of Civil Procedure Section 431.30, Defendant denies, both generally and specifically, each, every and all allegations of each and every purported cause of action or count of Plaintiffs complaint, denying specifically that Plaintiff has been, is, or will be injured or damaged in the manner or sum alleged, or in any other manner or sums at all, and further denying that Defendant was negligent in any manner, that the alleged product or products were defective in any way, or that the alleged defect or defects were the proximate cause of the Plaintiff's claimed damages or injuries, DEFENDANT HEREIN ALLEGES AND SETS FORTH SEPARATELY AND DISTINCTLY THE FOLLOWING AFFIRMATIVE DEFENSES TO EACH AND EVERY