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  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview
  • LAURANCE HAGEN VS. ASSOCIATED INSULATION OF CALIFORNIA ASBESTOS document preview 
						
                                
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                                Laura 1, Korson (SBN - 213679) ,
SELLAR HAZARD MANNING FICENEC & LUCIA ELECTRONICALLY

A Professional Law Corporation
1800 Sutter Street, Suite 460 FILED
Concord, CA 94520 Superior Court of California,
Telephone: 38 938-1430 County of San Francisco
Facsimile: (925) 256-7508 SEP 17 2010
Email: Ikorson@sellarlaw.com Clerk of the Court
BY: CHRISTLE ARRIOLA
Attorneys for: Deputy Clerk

Defendant Wesiern Insulation, Inc,

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO
LAURANCE HAGEN, Case No,: CGC-10-275582
Plaintiff, REQUEST FOR JUDICIAL NOTICE IN

SUPPORT OF DEFENDANT

v. WESTERN INSULATION, INC.’S
DEMURRER

ASSOCIATED INSULATION OF CALIFORNIA,

Defendants as Reflected on Exhibit | attached to [California Evidence Code §§ 452(h) and

the Summary Complaint herein; and DOES 1-8500, 453

Defendants. Hearing Date: October 6, 2010
Hearing Time: 9:30 a.m.
Department: 220 (Asbestos)
Judge: Hon, Harold E. Kahn
Trial Date: None Set

Complaint Filed: June 2, 2010

TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD HEREIN:

Defendant Western Insulation, Inc. hereby requests that the Court take judicial notice of Harold
M. Moore Insulation’s Certificate of Status, Domestic Corpotation showing an incorporation date of
November 15, 1976, attached hereto as Exhibit “A.” Defendant hereby further requests that the Court

take judicial notice of Certificate of Amendment of Articles of Incorporation changing the corporation

‘}j name to Western Insulation, Inc., attached hereto as Exhibit “B.”

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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT WESTERN INSULATION, INC.’S DEMURRER
80627 Case No. CGC-10-275582oer wt A HW PF WN

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BPRNRRRRSKSRBSSE RAF BE SHH SO

Defendant makes its requests for judicial notice pursuant to California Evidence Code §§
452(h) and 453.

DATED: September 3, 2010 SELLAR HAZARD MANNING FICENEC & LUCIA

a Kk

LAURA KORSON
Attorndy For Defendant Western Insulation, Inc.

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REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT WESTERN INSULATION, INC.’S DEMURRER

80627 Case No. CGC-10-275582EXHIBIT AStale
CSliomia

OFFICE OF THE SECRETARY OF STATE gy

CERTIFICATE OF STATUS
DOMESTIC CORPORATION

1, MARCH FONG EU, Seeretary of State of the State of California, hereby certify:

That on the isth day of = November .. 19.76 ,

HAROLD My MOORE INSULATION

became incorporated under the laws of the State of California by. filing its Articles of In-
corporation in this office; and on :

That no record exists in this of fice of a certificate of dissolution of said. corporation nor
of a court order declaring dissolution thereof, nor of a merger-or consolidation which ter-
minated its existence; and ‘ i :

That said corporation’s corporate powers, rights and privileges are not suspended on the
records of this of fice; and : ae ,

That according to the records of this office, the said corporation is authorized to exer-
cise all its corporate powers, rights and privileges in the State of California; and

That no information is available in this office on the financial condition, business ac-
tivity or practices of this corporation.

IN WITNESS WHEREOF, I execute this

certificate and affix the Great Seal

of the State of California this
20th dayof August, 1982

Wrench Foe, te

Secretary of State

SEC/STATE FORM CE-112 (REV. 7-81) ® 2.1988-862 7-81 10MCAM # OSPEXHIBIT Boe ENDORSED
CERTIFICATE OF AMENDMEN1 F 1 L E D

fF the Secretary of State
OF . ® the of Ghote of Calforsia

NOV~ & 1984

‘MARCH FONG EU, Secretary of State
By JANES. E. HARRIS

ARTICLES OF INCORPORATION

HAROLD M. MOORE and LINDA MARIE BULLINGTON certify that:

1. They are the President and Chief Financial Officer,
respectively, of HAROLD M. MOORE INSULATION, a California
Corporation,

2. The First Article of the articles of incorporation of this
corporation is amended to read as follows:

The name of the corporation is WESTERN INSULATION, INC.

3. The foregoing amendment of articles of incorporation has
been duly approved by the board of directors.

4. The foregoing amendment of articles of incorporation has
been duly approved by the required vote of sharéholders. in
accordance with Section 902 of the Corporations Code. The
total number of outstanding shares of the corporation is
7,500. The number of shares voting in favor of the amend-
ment equaled or exceeded the vote required. The percentage
vote required was more than 50%.

HAROLD M. MOORE, President

The undersigned declare under penalty of perjury that the
matters set forth in the foregoing certificate are true of
their own knowledge.

Executed at San Diego, California, on October 30, 1984.

Fler PO. ne

HAROLD M- MOORE :Oo Oo NID

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PROOF OF SERVICE

I, Alysia Fukuda, declare:

I am employed in the County of Contra Costa, California in the offices of a member of the Bar
of this Court, at whose direction this service was made. My business address is 1800 Sutter Street,
Suite 460, Concord, California. Iam over the age of eighteen years and not a party to this action. On
the date given, I served the following document(s):

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEFENDANT WESTERN
INSULATION, INC.’S DEMURRER

In the case entitled: Hagen v. Association Insulation of California, et al., San Francisco Superior
Court, Case No. CGC-10-275582, on all interested parties through their attorneys of record
electronically via Lexis Nexis File & Serve

(SEE ATTACHED SERVICE LIST)

BY FIRST CLASS MAIL (C.C.P. §§1013A, et seq.):

I caused said document(s) to be deposited in the United States Mail in a sealed envelope with
postage fully prepaid at Concord, California, following the ordinary practice at my place of
business of collection and processing of mail on the same day as shown on this declaration.

BY FACSIMILE (C.C.P. §§1012.5, et sea.)

I served such document(s) by fax to the fax number(s) provided by each of the parties in this
litigation at Concord, California. I received a confirmation sheet indicating said fax was
transmitted completely.

XX_. BY ELECTRONIC SERVICE (C.C.P. §187):
I caused said document to be served using LexisNexis File & Serve.

I declare under the penalty of perjury, under the laws of the State of California, that the above is true
and correct.

(Murad Aboud
DATED: September 17. 2010 (

Wlvsia Fokuda

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PROOF OF SERVICE
81175.doc Case No. CGC-10-275582