On September 25, 2023 a
Summons
was filed
involving a dispute between
Stinnett, Fred,
and
Asbestos Corporation Limited,
Collins Electrical Company, Inc.,
Crown Cork & Seal Company, Inc.,
C V Supply, Inc.,
Dillingham Construction N.A., Inc.,
Does 1 Through 800, Inclusive, As Required By,
Itt Llc,
Mcdonald Supply Co., Inc.,
Metropolitan Life Insurance Company,
York International Corporation,
for ASBESTOS
in the District Court of San Francisco County.
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1 DAVID R. DONADIO, ESQ., S.B. #154436
NANCY T. WILLIAMS, ESQ., S.B. #201095
2 NWilliams@braytonlaw.com
BRAYTON PURCELL LLP ELECTRONICALLY
3 Attorneys at Law
222 Rush Landing Road
FILED
Superior Court of California,
4 P.O. Box 6169 County of San Francisco
Novato, California 94948-6169 10/23/2023
5 (415) 898-1555 Clerk of the Court
Tentative Ruling Contest Email: motions@braytonlaw.com BY: SANDRA SCHIRO
6 Deputy Clerk
Attorneys for Plaintiff
7
8 SUPERIOR COURT OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
10
11 FRED STINNETT, as Successor-in- ) ASBESTOS
Interest to and as Wrongful Death Heir of ) No. CGC-23-277160
12 JAMES STINNETT, Deceased, )
) DECLARATION OF NANCY T.
NOVATO, CALIFORNIA 94948-6169
BRAYTON PURCELL LLP
13 Plaintiff, ) WILLIAMS IN SUPPORT OF EX PARTE
222 RUSH LANDING ROAD
) APPLICATION FOR ORDER DIRECTING
ATTORNEYS AT LAW
14 vs. ) SERVICE OF SUMMONS ON
(415) 898-1555
P O BOX 6169
) DEFENDANT C V SUPPLY, INC., Entity
15 C V SUPPLY, INC., et al., ) No. C0711783, BY DELIVERY OF
) PROCESS TO SECRETARY OF STATE
16 Defendants. )
[C.C.P. § 416.20(b); Corp. Code § 2011(b);
17 Former Corp. Code § 3305]
18 Dept.: 503, Hon. Samuel K. Feng
Trial Date: N/A
19 Action Filed: September 25, 2023
20 I, Nancy T. Williams, declare and state as follows:
21 1. I am an attorney duly authorized and licensed to practice law in the State of California
22 and am an associate in the law firm of Brayton Purcell LLP, attorneys of record for plaintiff
23 herein.
24 2. I have reviewed the file in this action and believe the facts contained herein to
25 accurately reflect the procedural history of this case.
26 3. Plaintiff herein has filed this complaint for wrongful death arising out of decedent’s
27 exposure to asbestos and/or asbestos-containing products. C V SUPPLY, INC., is a named
28 defendant in this action.
K:\Injured\102906\PLD\DECL NTW XPT SRV CASOS CAMEL.wpd 1 NTW
DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER DIRECTING SERVICE OF
SUMMONS ON DEFENDANT C V SUPPLY, INC., BY DELIVERY OF PROCESS TO SECRETARY OF STATE
1 4. Defendant's Articles of Incorporation are attached as Exhibit A to the Declaration of
2 Montie Derby, and incorporated herein by this reference. As stated in the Declaration of Montie
3 Derby, the corporation has Dissolved status with the Department of Corporations, with the date
4 of dissolution listed as December 23, 1986.
5 5. As set out in more detail in the Declaration of Montie Derby, exercising due diligence,
6 this office has investigated and has found that all Agents for Service of Process and Officers of
7 defendant, are deceased or otherwise unlocatable, and we have not been successful in locating
8 any other person who has charge of the corporate assets on which service of process can be
9 effected.
10 I declare under penalty of perjury under the laws of the State of California that the
11 foregoing is true and correct.
12 Executed October 23, 2023, at Novato, California.
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Nancy T. Williams
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K:\Injured\102906\PLD\DECL NTW XPT SRV CASOS CAMEL.wpd 2 NTW
DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER DIRECTING SERVICE OF
SUMMONS ON DEFENDANT C V SUPPLY, INC., BY DELIVERY OF PROCESS TO SECRETARY OF STATE
Document Filed Date
October 23, 2023
Case Filing Date
September 25, 2023
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1 DAVID R. DONADIO, ESQ., S.B. #154436 NANCY T. WILLIAMS, ESQ., S.B. #201095 2 NWilliams@braytonlaw.com BRAYTON PURCELL LLP ELECTRONICALLY 3 Attorneys at Law 222 Rush Landing Road FILED Superior Court of California, 4 P.O. Box 6169 County of San Francisco Novato, California 94948-6169 10/23/2023 5 (415) 898-1555 Clerk of the Court Tentative Ruling Contest Email: motions@braytonlaw.com BY: SANDRA SCHIRO 6 Deputy Clerk Attorneys for Plaintiff 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 FRED STINNETT, as Successor-in- ) ASBESTOS Interest to and as Wrongful Death Heir of ) No. CGC-23-277160 12 JAMES STINNETT, Deceased, ) ) DECLARATION OF NANCY T. NOVATO, CALIFORNIA 94948-6169 BRAYTON PURCELL LLP 13 Plaintiff, ) WILLIAMS IN SUPPORT OF EX PARTE 222 RUSH LANDING ROAD ) APPLICATION FOR ORDER DIRECTING ATTORNEYS AT LAW 14 vs. ) SERVICE OF SUMMONS ON (415) 898-1555 P O BOX 6169 ) DEFENDANT C V SUPPLY, INC., Entity 15 C V SUPPLY, INC., et al., ) No. C0711783, BY DELIVERY OF ) PROCESS TO SECRETARY OF STATE 16 Defendants. ) [C.C.P. § 416.20(b); Corp. Code § 2011(b); 17 Former Corp. Code § 3305] 18 Dept.: 503, Hon. Samuel K. Feng Trial Date: N/A 19 Action Filed: September 25, 2023 20 I, Nancy T. Williams, declare and state as follows: 21 1. I am an attorney duly authorized and licensed to practice law in the State of California 22 and am an associate in the law firm of Brayton Purcell LLP, attorneys of record for plaintiff 23 herein. 24 2. I have reviewed the file in this action and believe the facts contained herein to 25 accurately reflect the procedural history of this case. 26 3. Plaintiff herein has filed this complaint for wrongful death arising out of decedent’s 27 exposure to asbestos and/or asbestos-containing products. C V SUPPLY, INC., is a named 28 defendant in this action. K:\Injured\102906\PLD\DECL NTW XPT SRV CASOS CAMEL.wpd 1 NTW DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER DIRECTING SERVICE OF SUMMONS ON DEFENDANT C V SUPPLY, INC., BY DELIVERY OF PROCESS TO SECRETARY OF STATE 1 4. Defendant's Articles of Incorporation are attached as Exhibit A to the Declaration of 2 Montie Derby, and incorporated herein by this reference. As stated in the Declaration of Montie 3 Derby, the corporation has Dissolved status with the Department of Corporations, with the date 4 of dissolution listed as December 23, 1986. 5 5. As set out in more detail in the Declaration of Montie Derby, exercising due diligence, 6 this office has investigated and has found that all Agents for Service of Process and Officers of 7 defendant, are deceased or otherwise unlocatable, and we have not been successful in locating 8 any other person who has charge of the corporate assets on which service of process can be 9 effected. 10 I declare under penalty of perjury under the laws of the State of California that the 11 foregoing is true and correct. 12 Executed October 23, 2023, at Novato, California. 13 14 Nancy T. Williams 15 16 17 18 19 20 21 22 23 24 25 26 27 28 K:\Injured\102906\PLD\DECL NTW XPT SRV CASOS CAMEL.wpd 2 NTW DECLARATION OF NANCY T. WILLIAMS IN SUPPORT OF EX PARTE APPLICATION FOR ORDER DIRECTING SERVICE OF SUMMONS ON DEFENDANT C V SUPPLY, INC., BY DELIVERY OF PROCESS TO SECRETARY OF STATE