Motion,Ex Parte: CHARLES HUSBAND VS. ASBESTOS DEFENDANTS (B*P) AS REFLECTED ON EXHIBITS

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Dean Pollack, State Bar No. 176440
Raymond A. Greene, Hl, State Bar No. 131510

BO AM BROWN ELECTRONICALLY
rofessional Law Corporation

P.O. Box 1 19 i sopekr IL EDP
Oakland, California 94604-0119 County of San Francisco
1901 Harrison Street, 14th Floor FEB 21 2012
Oakland, California 94612 . Clerk of the Court
Telephone: (510) 444-6800 BY: VANESSA WU
Facsimile: (510) 835-6666 Deputy Clerk

Attorneys for Defendant
YORK INTERNATIONAL CORPORATION

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
CHARLES HUSBAND, No, CGC-09-275098

Plaintiff, DECLARATION OF RAYMOND A.
GREENE, ILL, IN SUPPORT OF

v. DEFENDANT YORK
INTERNATIONAL CORPORATION'S
ASBESTOS DEFENDANTS (B#P), MOTION IN LIMINE TO PROHIBIT
EVIDENCE AND ARGUMENT
Defendants. REGARDING ITS ALLEGED
LIABILITY FOR “AFFIXED” OR,
“REPLACEMENT” PARTS

Date:

Time:

Dept.: 608

Judge: Hon. Curtis E. A. Karnow

Complaint Filed: March 2, 2009
Pretrial Date: March 9, 2012

I, Raymond A. Greene, IIL, declare as follows:

1. Tam an attorney licensed to practice law in the State of California and a partner of
the Law Firm of Burnham Brown, attorneys of record for Defendant York International
Corporation (“York”) in this action. The facts set forth below are of my personal knowledge.

and if called to testify, I could and would testify competently as to those facts.
1

DECL OF RAYMOND A. GREENE, IIL, ISO DEF. YORK INTERNATIONAL CORPORATION'S MOTION CGC-09-275098
IN LIMINE TO PROHIBIT EVIDENCE AND ARGUMENT REGARDING ITS ALLEGED LIABILITY FOR
“AFFIXED” OR “REPLACEMENT” PARTSCo Fe DD Hh FH NH Mm

yb MR RP RP YP BR RP ON Pp Be Be me Be Be eB Be Be ke
2 lak GF OHS FF SBA R A EKDHREE SES

2. Attached hereto as Exhibit A is a true and correct copy of the deposition
transcript of Plaintiff Charles Husband (“Plaintiff”).

3. Attached hereto as Exhibit B is a true and correct copy of the deposition transcript
of Plaintiff's expert, Charles Ay.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, and that this Declaration was executed on February 21, 2012,

at Oakland, California.

OND A. GREENE, IIT

1115038

2

DECL OF RAYMOND A. GREENE, IIL, ISO DEF. YORK INTERNATIONAL CORPORATION’S MOTION CGC-09-275098
TN LIMINE TO PROHIBIT BVIDENCE AND ARGUMENT REGARDING ITS ALLEGED LIABILITY FOR
“AFFIXED” OR “REPLACEMENT” PARTS:Re: Charles Husband v. Asbestos Defendants (BP)
Court: San Francisco Superior Court
Action No: CGC-09-275098

PROOF OF SERVICE OF ELECTRONIC SERVICE

I declare that I am over the age of 18, not a party to the above-entitled action, and
am an employee of Burnham Brown whose business address is 1901 Harrison Street,
14" Floor, Oakland, Alameda County, California 94612 (mailing address: Post Office
Box 119, Oakland, California 94604).

On the date executed below, I electronically served the document(s) via
LexisNexis File & Serve described as:

DECLARATION OF RAYMOND A. GREENE, II, IN SUPPORT OF
DEFENDANT YORK INTERNATIONAL CORPORATION’S MOTION IN
LIMINE TO PROHIBIT EVIDENCE AND ARGUMENT REGARDING ITS
ALLEGED LIABILITY FOR “AFFIXED” OR “REPLACEMENT” PARTS

on recipients designated on the Transaction Receipt located on the LexisNexis File &
Serve website. I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct and was executed on February 21, 2012,
at Oakland, California.

Ua ‘

f

““Cinda Andrew-Marshall ©

1040060

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
---00---
CHARLES HUSBAND,

Plaintiff,
vs. No. 275098

ASBESTOS DEFENDANTS (BP),

Defendants.

NEWLY SERVED DEPOSITION OF CHARLES HUSBAND
VOLUME I
(Pages 1 through 180, inclusive)

Taken before Kimberly L. Avery
CSR No. 5074
April 18, 2011oan fab OB NY =

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INDEX

PAGE
EXAMINATION BY MS. HUTH 668
EXAMINATION BY MS. GLEZAKOS 60 119
EXAMINATION BY MR. BURKE 71
EXAMINATION BY MS. STERN 428

EXHIBITS
(No Exhibits Marked)

Aiken Welch Court Reporters Charles Husband 8/18/201124
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NEWLY SERVED DEPOSITION OF CHARLES HUSBAND

BE IT REMEMBERED, that pursuant to Notice, and on
the 18th day of April 2011, commencing at the hour of
9:28 a.m., in the offices of Aiken Welch, One Kaiser
Plaza, Suite 505, Oakland, California, before me,

Kimberly L. Avery, a Certified Shorthand Reporter,
personally appeared CHARLES HUSBAND, produced as a
witness in said action, and being by me first duly

sworn, was thereupon examined as a witness in said

cause.

~-000---

APPEARANCES:
For the Plaintiff:

UMU TAFISI

Brayton Purcell

222 Rush Landing Road
Novato, California 94948

For the Defendant, Albay Construction:

JOCELYN SORIANO

(via phone)

Archer Norris

2033 N. Main Street, Suite 800
Walnut Creek, California 94596

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For the Defendant, J.T. Thorpe & Son, Inc.:

ERIN POPPLER

(via phone)

Bassi, Edlin, Huie & Blum

351 California Street, Suite 200
San Francisco, California 94104

For the Defendant, Union Carbide Corporation:

TINA GLEZAKOS

Brydon, Hugo & Parker

135 Main Street, 20th Floor
San Francisco, California 94105

For the Defendant, York International:

NICHOLAS BURKE

Burnham Brown

1901 Harrison Street, 11th Floor
Oakland, California 94612

For the Defendant, Bigge Crane & Rigging:

RYAN JACOBSON
(via phone)
~ Knox Ricksen
1300 Clay Street, Suite 500
Oakland, California 94612

For the Defendant, CertainTeed:

SAM STERN :
McKenna, Long & Aldridge
101 California Street, 41st Floor
San Francisco, California 94111

For the Defendant, Chicago Bridge & Iron:

CHRIS DIAS

(via phone)

Sack Rosendin LLP

One Kaiser Plaza, Suite 340
Oakland, California 94612

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For the Defendants, Thomas Dee Engineering Company;
Hamilton Materials, Inc.; Cleaver-Brooks, Inc.:

HILLARY H: HUTH

Walsworth, Franklin, Bevins & McCall
601 Montgomery Street, Ninth Fioor
San Francisco, California 94111

For the Defendant, Temporary Plant Cleaners, Inc.:

BRITTANY MALY

Cooley Manion Jones Hake & Kurowski
201 Spear Street, 18th Floor

San Francisco, California 94105

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t would have to say in the late 'SOs, all the
way up in the '60s, you know. Some grade school,
junior high, and high school days.

a. Do you recall the last year that you worked for
or you worked at Whalen Engineering?

A. Well, | went to Vietnam in '68, so | went in
the Army in '67, so it would have to be in '66.

a Now, you mentioned that you were in school at
the time. Was this work that you performed on the
weekends or --

A. | performed it on the weekends. | went to the
shop, and my dad brought the work to the house for me
to do sometimes at night, you know, a couple hours here
and there, because he was in rebuilding of the
refrigeration industry, you know, take new and make
new -- take old and make new, | mean.

Q Sure.

What specifically, what kind of work did you

perform?

A. Teardown.

Qa What's teardown?

A. If you rebuild a compressor, you have to tear
itdown.

Q. And were you doing this when you were in grade
school?

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A. Yes.
Qa. Could you describe what's involved in a
teardown?
MS. TAFISI: Calls for speculation.
THE WITNESS: You have kind of --
MS. TAFISI: Let me finish my objection and you

can go ahead,
Calls for a narrative. Vague and ambiguous.

THE WITNESS: ! can probably go down and take a

picture, but the shop is not there.

{t was like an assembly line. You bring in the

compressors, they tear down the unit that's bad in the

component, the compressor or whatever comes down the

line, you wash them, you clean them, take them apart,

and it goes down to the end and you wash them again

scrape gaskets off of them, clean them out for -- to

renew them.
BY MR. BURKE:

Qa. So you washed compressors?

A. Yes, in solvent, and scraped gaskets, and

cleaned goo off of them with screwdrivers, wire

brushes, whatever, you know, get stuff off of there.

a. When did you start -- strike that.
Did you start -- did you take apart compressors

for the entire time that you worked for Whalen?

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Q. You said "per day." Would this be on the
weekend?

A. Yes. Yes. On the weekends per day, but at the
home, no, maybe two -- two at the most, if | did.

Q. On a weekly basis, how many compressors did you

take apart?
A. 15 to 20._| wouldn't go any higher than 25,

26. We had an upper shop area at the house in
Lafayette where it was set up the same as his shop but
a lot smaller, you know, with air and water,

everything, solvent to clean gaskets and all that

stuff.

Q. At your house?

A. Yes.

Q. Do you know the brand name or manufacturer of
any of the compressors you took apart when you were
working for your dad?

A. I'd have to think about that, because |
testified before about these compressors. We got the
ones submersed in oil. We got... There's a York.
There was Frigidaire, G -- Electric, what's that
Electric -- General Electric -- | don't know, General
Electric.

I'll have to get back to you on those. They'll

come to me.

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THE WITNESS: Lwould say York was about 25,

30 percent of our -- of our work, so, man, I'd say

about one-third.
| can't give you numbers, but | can say about
30 percent.
BY MR. BURKE:
Qa. Okay. That's fine.

So 30 percent of compressors you worked on when
you were working for your dad were York compressors?
A. [ can remember the York because | had to order
parts for some of them, and, you know, Frigidaire and
all that stuff, They'll come to me, but | just ~
these were -- Yorks were bigger compressors than most

that 1 remember.

Qa. Let's stick with York for now.
A. Yeah.
Q. Can you tell me what the York compressors that

you worked on looked like?
MS. TAFIS!: Calls for a narrative.
BY MR. BURKE:
Q. For example, size and shape.
A. Sizes are different, but the configuration
like, looks like a small Harley motor, cylinders come
out on each side, you know, with valves on top, but

they are not conventional valves, but...

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that's the only way we could get them off.

Qa So the first step in the process after taking

apart the compressor would be to immerse it in the

solvent?
A. Yes, and clean it, clean everything.
Qa. And you would clean it while it was still

immersed in the solvent?

A. Yeah, yeah, under the solvent.

Q. When the gaskets were baked on, how long would
it take typically to scrape off the gasket?

A. Ahard one, 15. 20 minutes. or longer.

Sometimes you had to set them aside and come back to

them.

a And during the entire cleaning process, was the

compressor -- were the compressor parts covered in this

solvent?
A. Well --
MS. TAFISI: Misleading. Misleading.
THE WITNESS: Lightly, yes.
BY MR. BURKE:

Q. What kind of solvent was this?

A. Same kind of solvent we have today, a clean
solvent. | don't know the chemical compound of it,
but...

Q Do you know the brand name?

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A. Well, it's almost impossible to wear gloves
when you are breaking down machinery. | guess you-can
do it, but we never did.

Q. Would you wear a respirator or any type of
breathing equipment?

A. No.

Q Other than your brothers, are there any other
co-workers that you worked with when you were at Whalen
Engineering?

A. There was one or two people that popped up, but
| don't remember them, you know, their names. | just
remember my immediate family, and a China man that
worked there, he was real fun. | don't remember his
name, but... | was the guy that always got teased down
there, always got kicked around. ,

Q. Do you have any information or knowledge that

you ever worked at any other job site where York

equipment was present?
MS. TAFISI: Asked and answered.

THE WITNESS: Well, no, I'd have to say on air

compressors the only thing that | -- | don't know about

York, but | know Ingersoll-Rand did more -- had most of

the industrial air compressors.

BY MR. BURKE:

Q. Let's stick with York. ['m just asking you --

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A. No, No. No.
Q. Do you have any information or knowledge that

you ever worked at a job site where York employees were

present’?
A, No. No.

Q. Do you know the names of any persons who can
provide any information as to any of the work you did
with or around any York equipment?

A. Weill, the only thing | can say now is just my
family. As far as the other people, you know, hard to
get ahold of or impossible to get ahold, just family.

| think the easiest ane would be my younger

brother Stewart which lives in Richmond.

Qa. Do you know of any documents that could provide
information as to any of the work you did with or
around any York equipment?

A. If there were, they are long past gone.

Q. Earlier | asked you if you knew the suppliers
of any of their replacement gaskets that you or that
Whalen purchased for York compressors, and --

A. ‘Like all the aftermarket stuff was done through
a job where it had nothing to do with York or anybody
else. The only time we couldn't get, the business
couldn't get parts from the manufacturer, it would go

in the aftermarket.

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109
screwdriver to replace them because they were rebuilt.

MS. TAFISI: Belated objection to the question,
asked and answered. Asked and answered, harassing,
oppressive.

I'll try to speak up, Kim.

THE WITNESS: Like if you come up with another
name of a compressor and | recognize it, then we're
going to go through the same thing, so | just...

Sorry.

BY MR. BURKE:
Q. Are you finished?
A. Yes, I'm finished.

Q. Do you know how many Frick compressors you

worked on when you were working at Whalen Engineering?

A. No, it's -- you have to have a number. Okay.

10, 15 percent,
Q. Okay. Yeah. Percentage is fine.

Earlier you testified that 25 to 30 percent of
the air compressors were York.
A. York is a big brand name, like Frigidaire, you
know.

Q. What do the Frick compressors look like?

A. Well --
Q. For example, size and shape, can you describe
that to me?

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take them apart?
A. Yes, and cleaned.
Q nd the pr as the s: re you! e

it submerged ina solvent?

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A. Yes, after it was all broke down,

Q. And how long would it take to break down a
Frick compressor?

A. Most of them were 45 minutes to an hour,
depending upon the gaskets. If they really got hot and
burned out, the gasket gets so hot, they are hard --
they are like stone, you know, and you got to chip them
off. The solvent doesn't really do anything to them,
it just takes -the dirt off of them. [t doesn't even
penetrate them, you know, and that's why these ones
take longer, because you are there with a chisel. You
can't get a chisel, so you get a wire brush and try to

get a groove in it so you can try and pop it off.

Q. How often would the gasket material be baked
onto the compressors?
A. 50 percent, because most of those things were

burned out from the heat.
Q. So 50 percent of the time that you were
cleaning compressors, the gasket material was baked on?
A. Oh, yeah, yeah.

Q. Were the appearance of the gaskets on the Frick

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estimate of, you know, the hours, 15 to 20 hours a week

“on both.

Qa. Okay. So it was 50 percent of the work -~
50 percent of the work you performed, was that home and
50 percent was in the shop?

A. Yes, that's more like...

Q. And at both locations you were performing the
same type of work?

A Same thing.

Q. You were taking apart the compressors, putting
them in solvent and cleaning them?

A. Same thing, just different places.

Q. Okay. At any -- strike that.

Do you have any information or knowledge that

you ever worked on any Frick equipment at any other

time?
A, No._ No, sir.
Q. Do you know of any documents, any writings or

photographs that would provide information as to any
work you did with or around Frick compressors?

A. No. | would never single any manufacturer out
with documents or pictures because at that age, you
know, that would be kind of, why would |?

Q. So the answer would be no?

A. Yes, sir.

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STATE OF CALIFORNIA )

)
COUNTY OF ALAMEDA _ )

I, KIMBERLY L. AVERY, do hereby certify:

That CHARLES HUSBAND, in the foregoing deposition
named, was present and by me sworn as a witness in the
above-entitled action at the time and place therein
specified;

That said deposition was taken before me at said
time and place, and was taken down in shorthand by me,
a Certified Shorthand Reporter of the State of
California, and was thereafter transcribed into
typewriting, and that the foregoing transcript
constitutes a full, true and correct report of said
deposition and of the proceedings that took place;

IN WITNESS WHEREOF, ! have hereunder subscribed my
hand this 5th of May 2011.

KIMBERLY L. AVERY, A No. 5074 i

State of California

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“CERTIFIED COPY
SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE counry OF SAN FRANCISCO

CHARLES HUSBAND,
Plaincife,

No. CGc-09-
275038

vs.

ASBESTOS DEFENDANTS,

Defendants.

DEPOSITION OF CHARLES AY, a witness herein,
noticed by McKENNA LONG & ALDRIDGE LLP, at
400 North Tustin Avenue, Suite 301, Santa Ana,
California, at 10:35 a.m., on Wednesday,

October 12, 2011, before Julie Heyward, CSR 7907.

Hutchings Numbér 343290

HUTCHINGS |
COURT REPORTERS

800-697-3210 www.hutchings.com

Forbest results, we recommend Adobe Actobat or Adobe Reader (free at: hitp:/get.adobe.cem/reader/).CHARLES HUSBAND vs. ASBESTOS DEFENDANTS
Ay, Charles on 10/12/2011

lo : " ORRTIFIED copy
2 , SUPERIOR COURT OF wae STATE OF CALIFORNIA
3 FOR THE COUNTY OF SAN FRANCISCO
4 :
5 CHARLES HUSBAND, )
6 " Plaintiff, i
7 va. } No. cac-09~
} 275098
8 ASBESTOS DEFENDANTS, )
9 Defendants. . i ,
Lo ,
21
a2
13 DEPOSITION OF CHARLES AY, a witness, herein,
“14 noti¢ed by McKENNA LONG & -ALDRIDGR LLP, at
is 400 North Tustin Avenue, Suite 301, santa Ana,
16 ° California, at 10:35 ae on Wednesday,
17 ‘october 12, 2011, before Julie Heyward, CSR 7907.
18
{19 Hutchings Number 343290
20
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22
23
24
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Hutchings Court Reporters - Global Legal Services Page 1

800-697-3210CHARLES HUSBAND vs. ASBESTOS DEFENDANTS
Ay, Charles on 10/12/2011

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the varioua componente. fv At took about 45 mimtas to
an hour, depending on the difficulty, to remove each
exlating asbestos-contalning gasket from the compreseor,
So he saya it tock him 45 mimtes to an hour to xemve a
gasket, And df that's the case, one wuld nok expect:
that to be wet because, if it's wat, dt should cone off
fairly easy because it's yonked.

PS eels auevne

“undaratanding aa to the vashing elenent?

Q, Tn breaking dem the sacking, cleaning and -
disassembling of the compressors, what's your

A. Tdan't know, He'doemn't state -- It doesn't
atate, *
@. So you don't have information about: that?

Ok to.

Q. Giz, what's your understanding ag to the
cleaning components of the procera the plainkifé wed
here with the Yark ail Prick compressors?

A, Tes not atated, ix, 1 have no Inovtetge of
what he weed to clean it with.

Q. And what's your understanding ax to the
submerging. process?

Ae Tdida'e aoe where it stated he submerged then,
T just seen that it was -- that he cledned them, wached
then, and then he would thea tear then dom.

Q. You're not aware of the apecitios of the

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‘the frequency that you've done it?

AL Well, I remember the first tine wall lave been
approximately 1961, Now, I didn’t do it a lot vhere 1
went out and brought then in from the chip and then did
he work, Rowevar, for about a five-y aix-, or
seven-roath period in the early '60s, after ‘61, though,
T wan assigned to the cooling section and that's share
we bad the dip tanks, And then I would -~ then whatever’
needed to be cleaned, 1 wuld put them in the bagkets
and dip them and clean them, So T ku what the proces
ie. 1 dida't do the entize atep,

from time to tine ven {wa Toate to the pipe
shop, T would be over in the refrigeration section, ad.
the refrigeration shop was in the eane building that my
shop waa in, the dnwwlatdon shop and alsa the pipe ehop,
‘wo were altogether. nd I would go dito tha
refrigeration shop and I would asalst from time to time
in the cleaning, wire brushing, scraping of varios
cooponente of coupressors. And we had York, Carciar --
1 want to say International, but I'm not positdve of
that, but there wae another big comresoor compaiy that
we did, comprised moat of what I recall working on,

Q. I'm sorry, what time frame was that, air?

A, ‘That vas in the *408,

Q.. And cauld you be a Little nore specific? Has

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mboerging process? .

& Na, T have 20 personal, soorledge of that. You
just said that the conpressors consist of vaghing, *
cleaning and disassembling. And I oan tell you at one *
time I worked in an ares where we cleaned compressors,
we washed thea dow, we removed gaskets. Gut the way we
did it wan we disasserbled the wulte, i.e., tore then
dom, put then in a basket, lowered the basket into
the -- either caustic materiale, depending on what the
compreacors wan made of, or cleaning solvents. And then
after they soaked for a while, take them out and wash
the parts off using a steam hove and get any aback
residue of material off.

‘tnd then after they dried, we would take them into
the shop, set then an the workbench, and then we would
clean up and sexape any materials that were atuck. Now,
that's the process that T used, What he used, I do not
know. Tt doesn't specify.

Q. So you don't have direct or indirect knowledge
of the inukmerging procasa the plaintiff usad in regarde
‘to the York and Frick coupressore?

A, That ig corect, air.

Q. Let's talk a Little bit -- Siz, you mentionsd
your experience in working with compressors.
Can you identify generally the time you did it and

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it 1960 to *68, "60 to ‘64, if you have an estimate?

A. Well, the cleaning of the mterdala where 1 was
back in the acid roams, that was in the "0, '65 time
period. ‘he working with the air-conditioning
refrigeration mechantca, that was "55 to "72 thm
period.

@. And if you had to categorize s percentage of
tine you spent with air-conditioning coummeasora during
that tive period, could you provide a percentage?

A. Mo, I coulda't; because these were jobs
depending on what my job was for that particular day,
Tt my he when 1 waa working in the ahop for an hour or
two and then go out in the field. It nay be when T wag
assigned to the shop all day. I don‘t recall a great
deal of miltiple-day work in the compressor area or
in -- not the compressor area, but the refrigeration
shop.

Q. and I'm sorry, six, did you work with
air-conditioning compreszora?

A. T did air-conditioning compeessors, regular air
compressor, you low, HP and LP compreaaora. I worked
with 2 lot of compressors.

Q. hod this was '63.to 72?

A Yea, air.

Q Okay.

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800-697-3210CHARLES HUSBAND vs. ASBESTOS DEFENDANTS
Ay, Charles on 10/12/2011

2 mony wich ve, Mistund'# ductarachen. to te wink Se
2 ence declarations attached ax a cinbined 2,
3d boeing ane, alte, jour Pim Su an che hook
4 fe one hows, ond apprectube St

swe, oesEa: oy.

6 “  neliove we sane a check.

? (Whereupon the decusents xeferced to ane marked by
the sweetie an tefenre wanintes 4 sed 2 foe

9 sdemetttcation.},

to (the proceedings conchuded aw VMS amd

1

12 ——«E dclose vedne ponaley of periucy wee the tava

44 of the State of Cattforia that the foxagoing 4s txue

45 and correct, ‘
16
47” executed at 4 Oaittornss,
Anon

2a
a ‘sennnenennie ae
RE RE
2a
2
a ‘
as
(1. STARE OF CALLPORNTA } an Page 35
2
’ 1, OnLte Hayward, O55 7907, do hereby deciarar
‘
5 ‘That, prior te maing examined, the witneaa named tn
& the oregoieg depasieton was by me daly swarn paconant
7 we Seuehon 1092tb) anh 2094 of Khe Code of Chul
6 Frogeduen: .
. ‘That sekd deporition waa taken dows by mw bu

0 abarehand sk the the and place tharain nuned and |
JA thenenftor eoduced to rext under ny dixeokion.

aa 1 kurther declare that T have no interdat in the
Ad event of the action.”

as 4% declare under penalty of perfury under che Lew»
A6 Of the tare of Calitornia that the Fareyoing is teas

A? aad corenet.

1 wEnegs oy band hte day of

PS AT Ea T9TF

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Pages 34.35CHARLES HUSBAND vs. ASBESTOS DEFENDANTS
Ay, Charles on 10/12/2011

Page 2) Page d
1 APPRARANCES OF COUNSEL: a tuoRe
2 4 amass: cMMLeS A
3 Dor Plaintltts 2 manny KOW ae wast
4 BRAYTON PURCELE LEP 4 MS. orenee .
5 BY RENS CASTILE (Present: telephonically) SMS. spate u
‘| & 222 Rush Landing Road . 6 MS. Wena »
7 Novato, Califomia 94948-6169 7 ete RANA
a : Bn, caste a
9 Por Defendant AWEAY CORSTRICTION COMPANY: MS. MextNaERy »
10 ARCHER NORRES w
_] 44 Bx doce soRtaNO (Present. Telephonically) n
12 2033 North Main Street, Suite 800 u
13 Walmut Creek, California 94596 " eRW TREES
u 14 pute Aaariognten ulatin ohe exanscsint J Pavan
5 as
16 For Defeadmbs SK AUTO, TNC; DILLINGWM csrencrion |**  PAPENE uemurtet yoomenrisa MARKED
Wo MA., DI: woe meee oF a
18 CAR, ORT & Son guctavation of gutting ay 8 “
19 BY BRIDGED VeEINSIRY (Prenent Telephonically) s 3m SUPT OF ene
20 Water Tower a. Tork, Thkemeetonet on to
ai 055 Soll Suet * Se ere een
22 metyville, Califomia 94608-2604 2 Ss'aeapert of wunaueare”s
" : a SRE Ghanersotien company’
ay tation tor 8 amen
4 * Shunney ndjusveneiony
B
1 APPRARANERS OF COUNSEL (Comteieoud) = faa) BX HTB EES (combina Paes
2 2 meade {dot fication within the tennscxtpe 4a fogged
2 IRR rhea as an beat btlae.
3. - Por Dafendamt UNION CARBIDE CORPORATE:
44 RRYDON HED & PARR 4 tmvexae pescaerkow momeecrraD wages
§ * BY RANDALL BMeNARD (Eresent. Telephonically) s 3 Bookeuation ot ae e “
6 135 Main street, 20th PLoor ‘ Rae Sehy Conetruction
7 San Prantdaca, Califomia 94105 7 Sepany'e Moticn OE ee
8 : Ragwaieseian
9 For Defendants YORK INTERURTIONNL CORPORATION: ’ fexeal
A) BUERNEK}BRONDE “
LL BY AY GREBNB (Present, Telephanfcally) a
12 190% Haxeson Street, 11th Floor “
13 Oakland, California 94612 s
uM “ .
15 For Defendant THAGORARY PLANT CLARNKIS, SNC. “
16 COOL MANILDHT JOS IRDA LP 6
17 BY LINDSAY (@resént, telephonically) uw
18 201 Spear Street, Suite 1600 ”
19 Sam Francisco, Califomia 94105" ”
20 *
21 Por Defendant, CaXTAMeTaD CORRIRATION: me
7a MORRIWA TONG & ALORIDGR LLP
23° BY SURILA O'GARA (Present Teleghonically} a
A WL Calfornia Street, Alot Floor ”
25, ‘San Francisco, California 94111 as

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