On January 30, 2009 a
Motion-Secondary
was filed
involving a dispute between
Conte, Anthony,
and
3M Company,
All Asbestos Defendants See Scanned Documents,
Asbestos Defendants B*P As Reflected On Reflected,
Bnsf Railway Company,
Bucyrus International Inc,
Burlington Northern Santa Fe Corporation,
Cbs Corporation, A Delaware Corporation,
Chrysler Llc,
Does 1-800, Inclusive,
Does 1-8500,
Garlock Sealing Technologies Llc,
General Electric Company,
Hennessy Industries Inc.,
Honeywell International, Inc.,
Honeywell International Inc., F K A Alliedsignal,,
J.T. Thorpe, Inc.,
J.T. Thorpe & Son, Inc.,
Macarthur Company,
Owens-Illinois, Inc.,
Parker Hannifin Corporation,
Plant Insulation Company,
Quintec Industries, Inc.,
The Budd Company,
Union Pacific Railroad Company,
Viacom And Not The Claims Against Cbs Corporation,
Viacom, Inc.,
Western Asbestos Company,
Western Macarthur Company,
for civil
in the District Court of San Francisco County.
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Gordon & Rees LLP
101 West Broadway, Suite 2000
San Diego, CA 92101
Sw wR
STEVEN SOBEL (SBN: 177210)
ssobel@eordonrees.com
LORRIE A. WALKER (SBN: 272637)
lwalker@gordonrees.com
GORDON & REES LLP
101 W. Broadway, Suite 2000
San Diego, CA 92101
Telephone: (619) 696-6700
Facsimile: (619) 696-7124
Attorneys for Defendant
HENNESSY INDUSTRIES, INC.
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
DEC 05 2013
Clerk of the Court
BY: MICHAEL RAYRAY
Deputy Clerk
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ANTHONY CONTE,
Plaintiff,
vs.
ASBESTOS DEFENDANTS (BP) As
Reflected on Exhibits B, B-1, C, F, G: and
DOES 1-8500; and SEE ATTACHED LIST.
NN Ne Ne ie a ee ee ea Ne el a Ne ee
dif
hid
dit
fil
ole
CASE NO. CGC-09-275046
Complaint filed: 01/30/09
DECLARATION OF LORRIE A.
WALKER IN SUPPORT OF
DEFENDANT HENNESSY
INDUSTRIES, INC.’S MOTION FOR
SUMMARY JUDGMENT, OR IN THE
ALTERNATIVE, SUMMARY
ADJUDICATION
Filed & Served Together
. Notice of Motion and Motion
Memorandum of Points & Authorities
. Separate Statement of Undisputed Facts
. Request for Judicial Notice
Declaration of Craig Mountz
. Declaration of Russell Darnell
. Declaration of Lorrie A. Walker
. Appendix of Exhibits
. Appendix of Exhibits to Darnell
Declaration
SWRADABWN
Date: February 20, 2014
Time: 9:30 a.m.
Judge: Teri Jackson
Dept.: 503
DECLARATION OF LORRIE A. WALKER EN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES,
INC.°S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATIONGordon & Rees LLP
101 West Broadway, Suite 2000
San Diego, CA 92101
Dn Bw Ww
DECLARATION OF LORRIE A. WALKER
I, Lorrie A. Walker, hereby declare as follows:
i. I am an attomey duly licensed to practice before the courts of the State of
California. I am an attorney practicing with Gordon & Rees LLP, attorneys of record for
Defendant Hennessy Industries, Inc. (“Hennessy”).
2. The facts stated herein are true of my own personal knowledge except those
matters stated on information and belief, and, as to those matters, I believe them to be true. If
called as a witness, I could and would competently testify to the same.
3. Attached to the accompanying Index of Exhibit as Exhibit “H” is a true and
correct copy of Plaintiff Anthony Conte’s First Amended Complaint in the instant matter, Conte
y, Hennessy Industries, Ine., Case No. CGC-09-275046.
4, Attached to the accompanying Index of Exhibits as Exhibit “I” is a true and
correct copy of Plaintiff Anthony Conte’s Responses to Hennessy’s Special Interrogatories, Set
One.
5. Attached to the accompanying Index of Exhibits as Exhibit “J” is a true and
correct copy of Plaintiff Anthony Conte’s Supplemental Responses to Standard Asbestos Case
Interrogatories, Set One.
6. Attached to the accompanying Index of Exhibits as Exhibit “K” is a true and
correct copy of Plaintiff Anthony Conte’s Responses to Standard Asbestos Case Interrogatories,
Set Two.
7. Attached to the accompanying Index of Exhibits as Exhibit “L” is a true and
correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume 1, in
pertinent part,
8. Attached to the accompanying Index of Exhibits as Exhibit “M” is a true and
correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume I, in
pertinent part.
‘te
fle
-2-
DECLARATION OF LORRIE A. WALKER IN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES,
INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATIONGordon & Rees LLP
101 West Broadway, Suite 2000
San Diego, CA 92101
186034:1 78776350 1
9. Attached to the accompanying Index of Exhibits as Exhibit “N” is a true and
correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume Ill, in
pertinent part.
10. Attached to the accompanying Index of Exhibits as Exhibit “O” is a true and
correct copy of Hennessy Industries, Inc.’s Answer to Plaintiff's First Amended Complaint.
1 declare under penalty of perjury under the laws of the State of California that all of the
above is true and correct.
Executed December 3, 2013, at San Diego, California.
Lomie A: Walker
3.
DECLARATION OF LORRIE A. WALKER IN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES,
INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION
Preview
Gordon & Rees LLP 101 West Broadway, Suite 2000 San Diego, CA 92101 Sw wR STEVEN SOBEL (SBN: 177210) ssobel@eordonrees.com LORRIE A. WALKER (SBN: 272637) lwalker@gordonrees.com GORDON & REES LLP 101 W. Broadway, Suite 2000 San Diego, CA 92101 Telephone: (619) 696-6700 Facsimile: (619) 696-7124 Attorneys for Defendant HENNESSY INDUSTRIES, INC. ELECTRONICALLY FILED Superior Court of California, County of San Francisco DEC 05 2013 Clerk of the Court BY: MICHAEL RAYRAY Deputy Clerk SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO ANTHONY CONTE, Plaintiff, vs. ASBESTOS DEFENDANTS (BP) As Reflected on Exhibits B, B-1, C, F, G: and DOES 1-8500; and SEE ATTACHED LIST. NN Ne Ne ie a ee ee ea Ne el a Ne ee dif hid dit fil ole CASE NO. CGC-09-275046 Complaint filed: 01/30/09 DECLARATION OF LORRIE A. WALKER IN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES, INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION Filed & Served Together . Notice of Motion and Motion Memorandum of Points & Authorities . Separate Statement of Undisputed Facts . Request for Judicial Notice Declaration of Craig Mountz . Declaration of Russell Darnell . Declaration of Lorrie A. Walker . Appendix of Exhibits . Appendix of Exhibits to Darnell Declaration SWRADABWN Date: February 20, 2014 Time: 9:30 a.m. Judge: Teri Jackson Dept.: 503 DECLARATION OF LORRIE A. WALKER EN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES, INC.°S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATIONGordon & Rees LLP 101 West Broadway, Suite 2000 San Diego, CA 92101 Dn Bw Ww DECLARATION OF LORRIE A. WALKER I, Lorrie A. Walker, hereby declare as follows: i. I am an attomey duly licensed to practice before the courts of the State of California. I am an attorney practicing with Gordon & Rees LLP, attorneys of record for Defendant Hennessy Industries, Inc. (“Hennessy”). 2. The facts stated herein are true of my own personal knowledge except those matters stated on information and belief, and, as to those matters, I believe them to be true. If called as a witness, I could and would competently testify to the same. 3. Attached to the accompanying Index of Exhibit as Exhibit “H” is a true and correct copy of Plaintiff Anthony Conte’s First Amended Complaint in the instant matter, Conte y, Hennessy Industries, Ine., Case No. CGC-09-275046. 4, Attached to the accompanying Index of Exhibits as Exhibit “I” is a true and correct copy of Plaintiff Anthony Conte’s Responses to Hennessy’s Special Interrogatories, Set One. 5. Attached to the accompanying Index of Exhibits as Exhibit “J” is a true and correct copy of Plaintiff Anthony Conte’s Supplemental Responses to Standard Asbestos Case Interrogatories, Set One. 6. Attached to the accompanying Index of Exhibits as Exhibit “K” is a true and correct copy of Plaintiff Anthony Conte’s Responses to Standard Asbestos Case Interrogatories, Set Two. 7. Attached to the accompanying Index of Exhibits as Exhibit “L” is a true and correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume 1, in pertinent part, 8. Attached to the accompanying Index of Exhibits as Exhibit “M” is a true and correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume I, in pertinent part. ‘te fle -2- DECLARATION OF LORRIE A. WALKER IN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES, INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATIONGordon & Rees LLP 101 West Broadway, Suite 2000 San Diego, CA 92101 186034:1 78776350 1 9. Attached to the accompanying Index of Exhibits as Exhibit “N” is a true and correct copy of the transcript from the deposition of Plaintiff Anthony Conte, Volume Ill, in pertinent part. 10. Attached to the accompanying Index of Exhibits as Exhibit “O” is a true and correct copy of Hennessy Industries, Inc.’s Answer to Plaintiff's First Amended Complaint. 1 declare under penalty of perjury under the laws of the State of California that all of the above is true and correct. Executed December 3, 2013, at San Diego, California. Lomie A: Walker 3. DECLARATION OF LORRIE A. WALKER IN SUPPORT OF DEFENDANT HENNESSY INDUSTRIES, INC.’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION