Motion-Secondary: RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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                                Becherer
Kannett &
Schweitzer

1955
Powell SL

Emeryville, CA
94608 .

510-658-3600

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Mark S. Kannett (SBN 104572)

Shahrad Milanfar (SBN 201126) ELECTRONICALLY
Jennifer K. Thai (SBN 258612) FILED
BECHERER KANNETT & SCHWEITZER Superior Court of Calon,
1255 Powell Street

Emeryville, CA 94608 . MAR 25 2011
Telephone: (510) 658-3600 ocak of the Court ¥
Facsimile: (510) 658-1151 Deputy Clerk

Attorneys for Defendant
Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO - COURT OF UNLIMITED JURISDICTION
RUFUS ALEXANDER, CASE NO. CGC-08-274719

Plaintiff, DECLARATION OF JENNIFER K. THAI IN
SUPPORT OF BRIDGESTONE FIRESTONE
vs. NORTH AMERICAN TIRE, LLC’S JOINDER|
TO DEFENDANTS ARVINMERITOR, INC.
ASBESTOS DEFENDANTS, et al., AND MAREMONT CORPORATION'S
MOTION TO DISMISS FOR DELAY IN
Defendants. PROSECUTION

Date: June 7, 2011

Time: 1:30 p.m.

Dept.: 220

Judge: Hon. Harold E. Kahn
Complaint

Filed: April 6, 2010

Trial Date: Not yet set

I, Jennifer K. Thai, declare as follows:
1. Iam attorney duly licensed to practice law in all state courts of the State of California.
lam an associate with the firm of Becherer Kannett & Schweitzer, LLP, attorneys of record
for defendant Bridgestone Firestone North American Tire, LLC (hereinafter “Bridgestone”).
If called to testify, I could and would competently testify to the following which are

personally known to me.

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC’S JOINDER TO.
DEFENDANTS ARVINMERITOR, INC. AND MAREMONT CORPORATION’S MOTION TO DISMISS FOR DELAY IN PROSECUTIONBecherer
Kannett &
Schweitzer

510-658-3600

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2. Attached hereto as Exhibit A is a true and correct copy of Bridgestone’s Motion to
Compel Discovery Responses, and For Monetary Sanctions and Terminating Sanctions,
served on Plaintiff on September 21, 2010.
3. Attached hereto as Exhibit B is a true and correct copy of Bridgestone’s
Supplemental Briefing Support of its Motion to Compel Discovery Responses, and For
Monetary Sanctions and Terminating Sanctions, served on October 21, 2010.
4, Mr. Alexander failed to oppose Bridgestone’s motion to compel. Attached hereto as
Exhibit C is a true and correct copy of Bridgestone’s Notice of Plaintiff's Failure to Oppose
Its Motion to Compel Discovery Responses, and For Monetary Sanctions and Terminating
Sanctions, served on November 10, 2010.
5. Plaintiff Rufus Alexander has failed to obey this Court's order requiring him to
appear for his deposition.
6. Plaintiff Rufus Alexander failed to obey this Court's order requiring him to respond
to Bridgestone’s written discovery.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct to the best of my knowledge. Executed on March 25, 2011 in

Emeryville, California.

mifef K/Thai —

2

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC’S JOINDER TO
DEFENDANTS ARVINMERITOR, INC. AND MAREMONT CORPORATION'S MOTION TO DISMISS FOR DELAY IN PROSECUTIONEXHIBIT A

DECLARATION OF JENNIFER K. THAI IN SUPPORT OF
BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE,
LLC’s JOINDER TO DEFENDANTS ARVINMERITOR,
INC. AND MAREMONT CORPORATION’S MOTION TO
DISMISS FOR DELAY IN PROSECUTIONow Wn Oa PF WN

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Mark S. Kannett (SBN 104572)
Shahrad Milanfar (SBN 201126)
Jennifer K. Thai (SBN 258612)
BECHERER KANNETT & SCHWEITZER
1255 Powell Street

Emeryville, CA 94608

Telephone: (510) 658-3600

Facsimile: (510) 658-1151

Attorneys for Defendant
Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO

CASE NO. CGC-08-274719

NOTICE OF MOTION AND MOTION BY
BRIDGESTONE FIRESTONE NORTH
AMERICAN TIRE, LLC, TO COMPEL
DISCOVERY RESPONSES, AND FOR
MONETARY SANCTIONS AND
TERMINATING SANCTIONS

RUFUS ALEXANDER,
Plaintiff,
vs.
ASBESTOS DEFENDANTS (BP), et al.,
Date: Nov. 18, 2010
Time: 1:30 p.m.
Dept: 220
Judge Hon. Harold E. Kahn

Complaint Filed: July 1, 2008
Trial Date: Not assigned.

Defendants.

a re a el a el a

TO PLAINTIFF RUFUS ALEXANDER:

PLEASE TAKE NOTICE that on November 18, 2010, at 1:30 p.m., or as soon thereafter!
as this matter may be heard in Department 220 of the above-entitled Court located at 400
McAllister St, San Francisco, CA, the Honorable Harold Kahn, presiding, defendant
BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC (“Bridgestone”), will move this
Court for an order compelling plaintiff to provide verified responses to Special
| Interrogatories, Requests for Production of Documents, and Requests for Admission
without objections, and for payment of monetary sanctions in the amount the court sees fit.

This motion will be made on the basis that plaintiff has not served timely, verified

NOTICE OF MOTION AND MOTION BY BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE, LLC, TO COMPEL DISCOVERY |oO wen anast Oo Be

NY NN NY NN YN BP BB Bee ee eB Se oe
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responses to properly propounded discovery in this action, failed to produce verified
responses, and on the basis that there is no substantial justification for plaintiff's failure to
respond. In addition, Bridgestone wil] request terminating sanctions.

This motion ‘will be based upon this notice, supporting declaration of attorney
Jennifer K. Thai, supporting memorandum of points and authorities, all pleadings presented

for the Court’s consideration in al] matters at such time as the matter may be heard, and|

upon such other evidence as may be presented. ~
Dated: September 21, 2010 ” BECHERER KANNETT & SCHWEITZER

 Purcell LLP

"ATTORNEY OR PARTY WITHOUT ATTORNEY (feme, state far mumbar, and address): FOR COURT USE ONLY

Nancy T, Williams Esq. (State Bar # 201095)

222 Rush Landing Road

Novato, CA 94948-6169 San Francisco County” ‘Superior Court
reurmvoneno: (415) 898-1555 ax wo. ontone:(415) 898-1247

ame OCF 90 rN -

ATTORNEY FOR mNamor Plaintiff(s) .

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO GQRDON PAR Rh Clerk
sraecr saoress: 400 McAllister Street a Deputy Cher
MAILING ADDRESS: °

cory ano zip cove: San Francisco 94102
BRANCH NAME:

‘CASE NAME: CASE NUMBER:
RUFUS ALEXANDER v. ASBESTOS DEFENDANTS (BOP) 274719
Heanine pare: October 30, 2009
ORDER GRANTING ATTORNEY'S * oct: 301 swe:9:30 a.m.
MOTION TO BE RELIEVED AS COUNSEL—CIVIL perore Hon: Peter Busch
pare acrioneuzo.July 1, 2008
wy pate: N/A.

1. The motion of (name of attorney): Nancy T. Williams Esq.
to be relieved as counsst of record for (name of cheat): Rufus Alexander, ct al. .
a party to this action or proceeding, came on regulary for hearing at the date, time, and place indicated above.

2. The foliowing persons were present al the hearing:

Cairontey Cour Sem BraRPO CUTE ue

FINDINGS
3, Atlomey has
a. C_} personally served the client wilh papers in support of this motion. .
b, £4] served tient by mail and submitted a dectaration establishing that the service requirements of California Rules of Court,
tule 3.1362, have been satisfied.

4. Attomey has shown sufficient reasons why the motion to be relleved as counsel should be granted and why the allomey has brought
a motion under Code of Civil Procedure section 284(2) instead of filing a consent under section 284(1).

ORDER
5. Alto! relieved as counsel of record for client

a effective upon the filing of the proof of service of thts signed order upon the client.
6. (J effective on (specify date): -
6. Thectients [3] curent [_] lastknown — address and telephone number:
Mr. Rufus Alexander, 170 Cashmere Street, Apt. D, San Francisco, California 94124

Mf the client's current address is known, service an the client must hereafter be made at that address unless otherwise ordered In llem
43. If the current address is not known, service must be made according to Code of Civil Procedure section 1011 (b) and rule 3.252 of
the California Rules of Court.

5, 2009 at 1:30 p.m., San Francisco Superior Court, Dept. 206
b_ The hearing will concern (subject matter)-Status and Setting Conference

7. a., Jhe eA scheduled hearing in this action or proceeding is set for (date, lime, and place):

NOTICE To CLIENT
You or your new attomey, if any, must prepare for and attend this hearing. Page ot 2
Form end Mandar se ORDER GRANTING ATTORNEY'S Sade a Chl roms. 6204
CSS fer trey 207] MOTION TO BE RELIEVED AS COUNSEL—CIVIL ae uaa

LexisNexiyid Automated Colifornta Judicial Coasncil FormsMC~053

~ CASE NAME: CASE NUMBER:
” RUFUS ALEXANDER v. ASBESTOS DEFENDANTS (B<>P) 2747 19

8. The following additional hearings and other proceedings (including discovery matters) are set In this action (describe the date,
lime, place, and subject matier of each):

in this action or proceeding:
a. is not yet set,
b. [_] is set for (specify date, time, and piace):

40. Client is hereby notified of the following effects this order may have upon parties.

NOTICE TO CLIENT

Your present attorney will no longer be representing you. You may not in most cases represent yourself If you are
one of the parties on the following list:

. + Aguardian - Apersonal representative » Aguardian ad litem”
+ Aconservator + A probate fiduciary + Anunincorporated associalion
+ Atnstee = Acorporation

Ifyou are one of these parties, YOU SHOULD IMMEDIATELY SEEK LEGAL ADVICE REGARDING LEGAL
REPRESENTATION. Failure to retain an attorney may lead to an order striking the pleadings or to the entry of a
default judgment.

11. Client is notified that, if the client will be representing himself or herself, the client shail be solely responsible for the case.

NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
‘You will nat have an attorney representing you. You may wish to seek legal assistance. If you do not have ancw
atiorney to represent you in this action or proceeding, and you are legally permitted to do so, you will be
representing yourself. It will be your responsibility to comply with all court rules and applicable laws. If you fail to
do so, oF fail to appear at hearings, action may be faken against you. You may lose your case.

42. Client is nolified that it is the client’s duly to keep the court informed at all times of the client's current.address.

NOTICE TO CLIENT WHO WILL BE UNREPRESENTED
The court needs to know how to contact you. If you do not keep the court and other parties informed of your current
address and telephone number, they will not.he able to send you notices of actions that may affect you, including
actions that may adversely affect your interests of result in your losing the case.

13, The court further orders (specify):

Date: lofsef aq Lin O02

Heo ey any 7 OM ORDER GRANTING ATTORNEY'S - Pear Fol
MOTION TO BE RELIEVED AS COUNSEL—CIVIL

LexisNexis® Autamuted California Judicial Council FornsExhibit Bwe mY AH & wD Ne

Boe ee
A Ww FF WN FF S

26
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Mark S. Kannett (SBN 104572)
Shahrad Milanfar (SBN 201126)
Jennifer X. Thai (SBN 258612)
BECHERER KANNETT & SCHWEITZER
1255 Powell Street
ille, CA 94608

Tel one et 658-3800
Facsimile: (510) 658-1151

Atiomeys for Defendant
Bridgestone Firestone North American Tire,

successor to Bridgestone Firestone, Inc. vie il

SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN. FRANCISCO

CASE NO. GGC-08-274719

arte

RUFUS ALEXANDER,
SPEGIJAL INTERROGATORIES TO
Plaintiff PLAINTIFF RUFUS ALEXANDER BY
: DEFENDANT BRIDGESTONE
vs. +) FIRESTONE NORTH AMERICAN TIRE,
yw

ASBESTOS-DEFENDANTS (BP), et al, }

Defendanis. .

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, LLC
RESPONDING PARTY: Plaintiff Rufus Alexander _.
SET NO.: One (1) :

, Defendant BFS requests that the responding paity, plaintiff Rufus Alexander
(Plaintiff), answer the following individual set of interrogatories, under oath, within thirty
(30) days, pursuant to California Code of Civil Procedure §§ 2030.010 through 2030.410.
As used herein, the term “DEFENDANT or BFS” refers, but is not limited; to Bridgestone
Firestone North American Tire, LLC, Bridgestone / Firestone, Inc., Firestone Tire and
Rubber Company, World Bestos Corporation.

Each answer provided by the responding party must be “as complete and straightforward as
the information reasonably available to the responding parly permits.” Code Civ. Pros. §

-l

BES’ SPECIAL INFERROGATORIES TO PLAINTIFF, SET-ONEoe NT mh MH BR BIN

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2030.220(a). If an interrogatory cannot be answered completely, the responding party must
answer to the extent possible. Code Civ. Proc. § 2030.220(b).. If the responding party does
not have personal knowledge sufficient to respond fully to an interrogatory, that party shail
so state and shail make a reasonable and good faith effort to obtain the information by
inquiry to other natural persons or organizations, except where the information is equally
available to the propounding party. Code Civ. Proc. § 2030. 220(c). Whenever an
interrogatory may be answered by referring fo a document, the document may be. attached
as an exhibit to the response and referred to in the response. If the decument has more
than one page, ‘refer to the page.and section where the answer to the interrogatory c can be
found.
INTERROGATORY NO. 1

If YOU contend that BFS is responsible for any product(s) which caused YOU to be

exposed fo asbestos, specifically describe each product by product name, part number and -

manufacturer. : .
TA number of terms contained in these interrogatories are typed in capital letters.

When in capital letters, YOU and YOUR means plaintiff, RUFUS ALEXANDER, as well as

anyone acting or purporting to act on their behalf, including, but not limited to, YOUR

agents, YOUR employees, YOUR insurance companies, their agents, thetr employees,

YOUR attorneys, YOUR accountants, YOUR investigators, and anyone else acting on

YOUR behalf]

INTERROGATORY NO. 2

| If You contend that BFS is responsible for any product(s) which caused YOU to be

exposed to asbestos, please describe in detail the manner in which YOU used each

product.

-2-

BES’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET ONE +°o

i

Come UA We wD =

INTERROGATORY NO. 3

if YOU contend that YOU were exposed to any asbestos-containing produci(s) for
which BFS is responsible, please IDENTIFY any and all DOCUMENTS, which support
YOUR contention. - , ,

IA jumber of terms contained in these intarrogatories are typed in capital letters.
When in capital letters, IDENTIFY, when used with respect to a DOCUMENT, means fo set
forth a description sufficient to distinguish the individual DOCUMENT from all other
DOCUMENTS. DOCUMENT means a “writing” as defined in Califomia Evidence Code
section 250, and includes the original or a copy of handwriting, typewriting, printing,
photostatfing, photographing, and every ofher means of recording upon any tangible thing
and form of conimunicating or representation, including letters, words, pictures, sounds, or
symbols, or combinations of them.] -

INTERROGATORY NO. 4 ,

IF-YOU contend that YOU were exposed to any asbestos-tontaining product(s) for
which BFS is responsible, please IDENTIFY each PERSON YOU believe may have
knowledge of facts supporting YOUR contention. ,

[A number of terms contained in these interrogatories are typed in capital letters,
When in capital jetters, PERSON includes a natural person, firm, association, organization,
partnership, business, trust, corporation, and/or public entity: IDENTIFY means, with .
respect to a PERSON, to set forth such PERSON’s full name, last known address, including
city, state, zip code, and last known telephone number]

INTERROGATORY NO. 5 a

if YOU contend that YOU purchased, for private use, any asbestos-containing

product(s) for which BFS is responsible, please describe each purchase by identifying the

| product(s) purchased; the seller, the seller's sfreet address and Jocation, and the date of”

each such purchase.

Be

BES’ SPECIAL INTERROGATORIES TO PLAINTIEE, SET ONEwo oe NA UM FF WYN

mee oe ee em Pe ee
De NIN DH FP YN RS

INTERROGATORY NO. 6

If YOU contend that YOU ever purchased, for private use, any asbasine-confaining
product(s) for which BFS is responsible, please IDENTIFY all DOCUMENTS which support
YOUR contention. , :
INTERROGATORY NO. 7

if YOU contend that YOU ever purchased, for private use, any asbestos-containing
product(s} for which BFS is responsible, please IDENTIFY each PERSON whom You
believe may have knowledge of facts which support YOUR contention.
INTERROGATORY NO. 8

f€ YOU contend that anyone else purchased, for YOUR use, any asbestos-coniaining
product(s) for which BFS is responsible, please describe each purchase by identifying the
product(s) purchased, the seller, the seller's street address and location, and the date of
each such purchase. :
INTERROGATORY NO. 3

If YOU contend that anyone else ever purchased, for YOUR use, any asbestos-
containing product(s) fer which BFS is responsible, please IDENTIFY all DOCUMENTS
which support YOUR contention. :
INTERROGATORY NO. 10

If YOU contend that anyone else ever purchased, for YOUR use, any asbesios-

containing product(s) for which BFS is responsible, please IDENTIFY each PERSON whom
YOU believe may have knowledge of facts which support YOUR contention.

DATED: November 20, 2009 BECHERER KANNETT & SCHWEIZER

LIZZ.

Cire for 7 Benda
ridgestone Fi Firestone North American Tire, LLC

4.

BFS SPECIAL INTERROGATORIES TO PLAINIIFE, SET ONESpt eet
a RR GOBES

Becherer
Karwett &
‘Schwelbar

Co Oo ND mH Bow mM

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION 1

. |, Barbara Golstein, declare that | am, and was at the time of service of the
documents herein referred to, over the age of 18 years, and not a party to the action; and |
am employed in the County of Alameda, State of Califomia. My business address is 1255
Powell Street, Emeryville, Califomia 94608.

On November kb. 2009, | electronically served the document(s) via LexisNexis File
& Serve described as: - :

+ SPECIAL INTERROGATORIES TO P|_AINTIFF RUFUS ALEXANDER
BY DEFENDANT BRIDGESTONE FIRESTONE
.NORTH AMERICAN TIRE, LLC

on the recipients designated on the.Transmission Receipt located on the LexisNexis File &
Serve website. :

" | declare under penalty of perjury pursuant to the laws of the State of California th
the foregoing is true and correct and that this declarafion was © on November

2009, at Emeryville, California. .
(fi

ra Golstein

5- :

BFS’ SPECIAL INTERROGATORIES TO PLAINTIFF, SET ONEwoe KN DH nH PB WY

PROOF OF SERVICE

|, Barbara Golstein, declare that ! am employed in the County of Alameda, State of
California; | am.over the age of eighteen (18) years and not a party fo the within entitled
action; my business address is 1255 Powell Street, Emeryville, California 94608. :

On November wb 2009, | caused to be served the foregoing:

. SPECIAL INTERROGATORIES TO PLAINTIFF RUFUS
ALEXANDER BY DEFENDANT BRIDGESTONE FIRESTONE
NORTH AMERICAN TIRE, LLC

In said action by placing a true copy thereof enclosed in a sealed envelope and served in
the manner and/or manners described below fo each of the parties herein and addressed as -
follows:

Plaintiff, In Pro Per Rufus Alexander
170 Cashmere Street, No. D
San Francisco, CA 94124

XX (By Mail) | deposited such envelope with pestage thereon fully prepaid to be placed in
the United States Mail at Emeryville, Califomia. | am familiar with the mail collection
practices of Becherer Kannett & Schweitzer Attomeys and pursuant to those practices the
envelope would be deposited with the United States Postal Service the same day.

CD @y Personal Delivery) l caused such envelope to be delivered by hand to the office of
the addressee(s).

(1 @y Ovemight Courier) [ caused such envelope to be delivered via overnight courier
service to the addressee(s) designated.

(1 (Via Facsimile) | caused said document(s) fo be transmitted to the facsimile number(s)
of the addressee(s) designated.

| declare under penalty of pesjury that the foregoing is true and eorrect and that this
declaration is executed on November 2/7, 2009, at Emeryville, Galifomi

+

BFS’ SPECIAL INTERROGATORIES TO PLAINTIFF, SEL ONE: Page 1 of 2

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Transaction ID: . 28151504 -

Submitted by: Berbara Golstein, Becherer Kannett & Schweltzer-Emeryville
_ Authorized byt Jennifer Thal, Becherer Kannett & Schweltzer-Emeryville
Authorize and file on: Noy 20 2009 10:12AM PST
Court: CA Superior Court County of San Francisco
Division/ Courtroom: N/A
Case Class: Civil
Case Type: : . Personal Injury-Asbestus ‘
(Case Number: 274719
(Case Name: Alexander vs Asbestos Defendants (Brayton)
‘Transaction Option: Serve Only - Public
Billing Reference: BFS/Rufus Alexander
Read Status for o-service:  ~ Not Purchased
Documents List
_ 3 Pecament{s}
Attached Document, 6 Pages Document ID: 25792499 PDF Format [ Orioipal Format
Document Type: Access: Statutory Fee: Linked:
Discovery - use for electronic service only Public $0.00
Document title: . .
Requests for Admission to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC -
‘Attached Document, 7 Pages Document ID: 25792542 PDF Format | Original Foonat
Document Type: . * Aocess: Statutory Fee: Linked:
Discovery ~ use for electronic service only Pabjic $0.00
Document titfe: - -
Requests for Production of Documents to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire,”
uc
Attached Document, 6 Pages Document ID: 25792959 PDE Format { Original Format
Document Typer Recess: Statutory Fee: Linked:
Discovery - use for electronic service only Pubic $0.00
Document ttle:
‘Special Interrogatories te Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC
Expand Alt . - r
E21 Sending Parties (1). :
_ Party ae Attorney Firm Attorney Type
Bridgestone Firestone North American Tire, Defendant Milanfar, Becherer Kannett & Schweltzer- Attorney in
LLC (pending) . Shahred =“ Emeryville x Charge
B) Becipients (isy oo
El Service List (15) °
Delivery Party Attorney
Option Party Tr Attorney Firm Type Method
Service Alexander, Rufis Plaintiff Pollack, Bean ~~ ‘Burnham Brown-Oakland = Attomey = p. .

Dk LD En ten Ft Re TT I atinnamanaDamell

Service Alexander, Rufus

Alexander, Rufus
Service Dame

_ Servies ArvinMeritar Inc

. B M W of North America
Service ue

. B M W of North America
Service tic :

Service Carlisle Co Inc

Service Chryster LLC .

Service Cummins Engine Co Inc Defendant E

Service - Dana CoLLC

. Garlock Sealing
“Service . Technologies LLC
servi Hennessy Industri
Lear Siegler Diversified
Service pet Corp
Service Mack Trucks Inc
NACCO Materlals
Service jtandling Corp

Service Plant Insulation Corp

Service Preurno Abex Lc

Toyota Motor Sales

Service USA Inc

[_Additional Recipients (0)
FA _case Parties.

Plain = Rundin, Walter C
Piaintif Gonzales, Susana

Defendant Oberg, Lisa
Defendant Ames, Richard

Cunningham,
Defendant 5 mes Patrick

Defendant Davidson, Africa E

Defendant Kuenster, Jennifer
Golden, Catherine

Counsel, Asbestos"
Defendant BHP

Defendant Glaspy, David
Defendant Goetz, Andy 3°

Defendant’ Keesal, Samuel A

Defendant Ostertag, James 3

Defendant. Reilley, Mary E
Defendant Travis, Monte S

Defendant ae Asbestos

Servos

Burnham Brown-Oakdand Attomey Service
BE

Bumham Brown-Oakiand Attorney Service
McKenna Long & Aldridge 9 Atiomey in E-
LLP-San Francisco Charge Service ©
Carroll Burdick &
McDonough LLP-San ey ne vice

_ Francisco
Peponeush LLP-San Attorney in E-
Francisco Charge - Service
Bassi Edin Hule & Blum © Atfomeyin E-  *
LLP-San Francisco Charge Service
Nixon Peabody LLP-San Attomey m= = E-
Francisco Charge Service
Jackson & Wallace-San Attomey in E-
Francisco . Charge Service
Brydan Hugo & Parker-San Attomey in  E-
Francisco Charge Service
Giaspy &Glaspy / Gee ym Sorvice
Prindle Decker & Amaro Attomey In E-
LLP-Long Beach Charge * Service
Keesal Young & Logan-Long Attomey In E+
Beach Charge Service
Nixon Peabody LLP-San Attomey In E-
Francisco Charge Service
Keieg Keller Sloan Rellley & Attorney in E-
Roman LLP Charge Service
Travis & Pon gene E rvice
Brydon Hugo & Parker-San Attorney in &
Francisco: Charge Service
Brydon Hugo & Parker-San Attorney In E-

Counsel, Asbestos
Defendant Fra °

Francisco - Charge Service

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ateninnanExhibit C_-

26

SC eT DH mR Ww ON

Mark S. Kannett (GBN 104572)
Shahrad-Milanfar (SBN 201126)

Jennifer K. Thai (SBN 258612) - .
BECHERER KANNETT & SCHWEITZER
1255 Powell Street.

Emeryville, CA 94608 .
Telephone: (510) 658-3600 1
Facsimile: (510) 658-1151.

Attorneys for Defendant
Bridgestone Firestone North American Tire, LLC,
successor fo Bridgestone Firestone, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO

: oe . CASE NO. CGC-08-274719
RUFUS ALEXANDER, } :
: oe } REQUESTS FOR PRODUCTION OF
Plaintsft, DOCUMENTS TO PLAINTIFF RUFUS

_ ALEXANDER BY DEFENDANT
BRIDGESTONE FIRESTONE NORTH

ASBESTOS DEFENDANTS (B¢P), etal, ) AMERICAN TIRE, LLC
Defendants.

vs.

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, Le
RESPONDING PARTY: _ Plaintiff Rufus Alexander

SET NO.: _ One (1)

Pursuant to the provisions of Code of Civil Procedure § 2031.010, et  seq., Plaintiff Rufus
Alexander is hereby requested to identify and produce for inspection and copying at the law
offices of Becherer Kannett & Schweitzer, 1255 Powell Street, Emeryville, Califomia, 94608,
the following fangible things or writings (as that term is defined by Evidence Code § 250) :
within Plaintiff's possession, custody and/or control. True and correct copies of the
documents. described herein with an appropriate verification to the authenticity will be

J.

BES’ REQUESTS FOR PRODUCTION TO PLAINTIFF, ET ONECw eu nw he

ee
aA unk BN HS

accepted in feu of the original documents. With respect to photographs, color laser-copies
will be accepted In lieu of the original photographs. :

Pursuant to the provisions of Code of Civil Procedure § 2031. O60, if you object to the
production of any document or category of document, you must identify with particularity any
document being withheld from production, and set forth clearly the extent of, and the
specific grounds for, the objection. ,

If written response is not served in corhpliance with the time limit set forth in Code of
Civil Procedure Section 2031290, all objéctions will be deemed waived.

DEFINITIONS ,

1. As used in this request, the term "DOCUMENT(S)”" means any tangible object
which displays, records, or contains a "writing" within the meaning of California Evidence
Code §250, and includes, without being limited thereto, sales receipts, invoices, purchase
orders, warning labels, deposition transcripts, brochures, policies, procedure manuals, order
forms, pay stubs, work logs, and daily ime books or diaries. Evidenos Code §250 provides:
“ Writing’ means handwriting, typewrifing, printing, photostating, photographing, and every
other means of recording upon any tangible thing any form of communication or
representation, including letters, words, pictures, sounds or symbols, or combinations
thereof.” :

. "YOU" and “YOUR® refers ta each Responding Party, all agents, all attorneys, and
anyone acting on behalf of each Responding Party.

3.. When the context so requires, reference to the masculine gender includes the - ~
feminine and neuter, the feminine gender includes-the masculine and neuter, the singular
includes the plural, and the plural includes the singular. _

“4. As used herein, the term “DEFENDANT refers, but is not limfied, to Bridgestone
Firestone North American Tite, LLC, Bridgestone / Firestone, Inc., Firestone Tire and
Rubber Company, World Bestos Corporation.

2

BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONE.wae NA WN DB

10

5. As used herein, the term “ASBESTOS-CONTAINING PRODUCTS’ means any
product that contains, or that ‘you allege contains, any amount of the mineral asbestos, .
including but not limited to, call raw asbestos, vermiculite, amostte, trimolita, and chrysotile
and crocidilite,

6. “PERSON” as used herein refers to any individual, partnership, firm, association,
corporation or other govémiment, business or legal entity. /

7. As-used herein, the ferm “MEDICAL TREATMENT FACILITY” means hospitals,
dispensaries, laboratories, optometry clinics, psychologi¢al clinics, clinics of afl other kinds,
mental institutions, radiology laboratories, pathology laboratories, rest homes, sanitariums,
convalescent homes, and_all other institutions, organizations and facilities wherein are
practiced the healing arts. ,

8. As used herein, the term “MEDICAL PRACTITIONER’ refers fo all physicians,
osteopaths, dentists, chiropractors, nurses, psychiatrists, psychologists, optometrists,
physical therapists, and all other persons practicing, of purporting to practice, the healing
arts.

: . DOCUMENTS TO BE PRODUCED

4. All DOCUMENTS described or identified by YOU in YOUR response to
DEFENDANT'S Special Interrogatories, Set No. 1, if any.

2, All DOCUMENTS not previously identified and produced evidencing, relating to, or
concerning, any relationship of any kind between DEFENDANT and the persons claimed to
have incurred an asbestos-related injury in this action.

3. All DOCUMENTS supporting the amount of YOUR damages, inéluding, but not
limited to, employment records, invoices, bills, work logs or daily work diaries, household
expenses, and medical records from any MEDICAL TREATMENT FACILITY, medical
records from any MEDICAL PRACTITI [ONER and any medical bills.

4. All DOCUMENTS conceming or reflecting any and all.settlement reached with
other defendants in this lawsuit or any other lawsuits involving in which it was alleged thaia
person or persons were exposed to asbestos or asbestos-containing products,

3-

“BES’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONE1
2
3
_4
5
“6
7
&
9
10
11
12
13
14
15
16
17
1B
19
20
21
22,
23
24
25
26
bec 27
Schweitzer 2.
Powel St
Enea, CA
510-658-3500

5. All personal and/or work diaries kept by YOU at any time.

6, All DOCUMENTS representing, recording, referring or relating to: YOUR
allegations that YOU were exposed fo asbestos-containing products supplied by this
propounding DEFENDANT.

7. All! DOCUMENTS representing, recording, referring or relating to YOUR .
allegations that YOU ca came into physical contact with asbestos-containing products supplied
by this propounding DEFENDANT.

8. Ali DOCUMENTS representing, recording, referring or refating to YOUR
allegations that YOU were in the vicinity of others working with asbesios-containing
products supplied by this propounding DEFENDANT.

8. All DOCUMENTS representing, recording, referring or relating to YOUR .
allegations that YOU were exposed to asbestos-containing products supplied by this
propounding DEFENDANT. .

10. All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU came into Physical contact with asbestos-containing products supplied
by this propounding DEFENDANT.

11. All DOCUMENTS representing, recording, Teferting or relating io YOUR
allegations that YOU were in the vicinity of others working with asbestos-containing
products supplied by this propounding DEFENDANT.

"42. All DOCUMENTS representing, recording, ‘eferring or relating to YOUR
allegations that YOU were exposed to asbestes-confaining products sold by this
propounding DEFENDANT. = .

43, All DOCUMENTS representing, recording, referring or relating to YOUR
allegations that YOU came into physical contact with asbestos-containing products sold by
this propbunding DEFENDANT. .

14. All DOCUMENTS representing, recording, referting or relating to YOUR
allegations that YOU were in the vicinity of others working with asbestos-containing
products sold by this propounding DEFENDANT.

‘ A

BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEwo eA eh WN

Bee oe Se ee ee
oa A A kW RP SF S

15. Each and every box, package, container or carton in YOUR possession which
bears the trade name, fogo, or trademark of the asbestos-coniaining products
manufactured, supplied, or sold by this propounding DEFENDANT, to which YOU claim
YOU were exposed.

16. All statements, however recorded, of witnesses taken by YOU, YOUR attomeys
or investigators working for YOUR attomeys, or other agents, for which no privilege or claim
of work product is asserted.

a7. Any and all DOCUMENTS related to any claims YOU ever made for any
asbestos-related injuries, which claims were made. before or after this lawsuit.

18. Any and all DOCUMENTS relating to any payments requested or received from
the Johns-Manville Trust. ,

49. Any and all DOCUMENTS related to any claims YOU ever made te any
Bankruptey Trust based on any asbestos-related injuries, which claims were made before or
affer this lawsuit.

20. Any and all DOCUMENTS relafing to any payments requested or received from
any Bankruptcy Trust by YOU for any asbestos-related injury(ies).

24. Any and all DOCUMENTS that support or contradict YOUR responses to each

Request for Admissions.

DATED: November ‘2() , 2009 BECHERER KANNETT & SCHWEITZER
. . nniferK. Thai

‘Attorreys for Defendant
Bridgestone Firestone North American Tire, LLC

5.

BFS’ REQUESTS FOR PRODUCTION TO PLAINTIFF, SET ONEwwe QM An hk eR

ee ees
oe UA A RYN SO

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION

1, Barbara Golsiein, declare that | am, and was at the time of service of the
documents herein referred to, over the age of 18 years, and not a party to the action; and |
am employed in the County of Alameda, State of California. My business address is 1255
Powell Street, Emeryville, Califomia 94608.

On November 4 , D 2009, I electronically served the document(s) via LexisNexis File
& Serve deseribed ast

» REQUESTS FOR PRODUCTION OF DOCUMENTS JO PLAINTIFF
RUFUS ALEXANDER BY DEFENDANT BRIDGESTONE FIRESTONE
NORTH AMERICAN TIRE, LLC

a

on the recipients designated on the Transmission Receipt located on the LexisNexis File &
Serve website.

| declare under penalty of perjury pursuant to the laws of the State of California that,
the foregoing is tue and correct and that this declaration was executed on November Z{/,
2009, at Emeryville, California.

6

BFS’ REQUESTS FOR PRODUCTION TO PLAINTLIFR, SET ONEwe BS HH WN

= Fe ew ee Ye Se Se
ew A A BF BY NK S

PROOF OF SERVICE

- |, Barbara Golsfein, declare that { am employed in the County of Alameda, State of
California; [ am over the age of eighteen (18) years and not a party to the within entitled
action; my business address is 1255 Powell Street, Emeryville, California 94608.

On November Bb. 2009, | caused to be served the foregoing:

. REQUESTS FOR PRODUCTION OF DOCUMENTS TO
PLAINTIFF RUFUS ALEXANDER BY DEFENDANT BRIDGESTONE
FIRESTONE NORTH AMERICAN TIRE, LEC

In-said action by placing a true copy thereof enclosed in a sealed envelope and served in
the manner and/or manners described below to each of the parties herein and addressed as
follows:

Plaintiff, In Pro Per Rufus Alexander
170 Cashmere Street, No. D
-San Francisco, CA 94124

IX (By Mail} } deposited such envelope with postage thereon fully prepaid to be placed in
the United States Mail at Emeryville, Califomia. | am familiar with the mail collection
practices of Becherer Kannett & Schweitzer Attomeys and pursuant to those practices the
envelope would be deposited with the United States Postal Service, the sarne day.

(J @®y Personal Delivery) | caused such envelope to be delivered by hand t to the office of
the addressea(s). .

O (By Overnight Courjer) | caused such envelope to be delivered via overnight courier
service to the addressee(s) designated. . :

(1 Wia Facsimile) ‘| caused said document(s) to be transmitted to the facsimile number(s)
of the addressee(s) designated.

‘ | declare under penalty of perju
declaration is executed on November 4 LD

-T-

FS’ REQUESTS FOR PRODUCTION TO PLAINTLEF, SET ONEPage 1 of 2
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LexisNexis File & Serve Transaction Receipt

Transaction ID: . 28151504

Submitted by: Barbara Golstein, Bécherer Kannett & Schweitzer-Emeryville
Authorized by: 3ennifer Thal, Becherer Kannett & Schweftzer-Emery ville
Authorize and file on: - Nov 20 2009 10:124M PST
Court: . CA Superior Court County of San Francisoo -
Division /Courtreom: N/A -
Gur :
Personal Injury-Asbestos
274ng .

Algxander vs Asbestos Defendants (Brayton)

Serve Only - Public

BFS/Rufus Alexander
. Wot Purchased
Documents List” -
3 Document(s)
Attached Document, 6 Pages Document ID: 25792499 . PDF Format | Original Format
Docament Type? . Access: Statutory Fee: Linked:
Discovery — use for electronic service only Public - $0.00
Document title:
Requests for Admission to Ptaintitf Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LUC
Attached Document, 7 Pages Pocument Ib: 25792542 PDE Format | Original Format
Document Type: Access? Statutory Fea: Linked:
_ Discovery ~ use for electronic service only Public _ $0.00
Document tite:

Requests for Production of Docurnents to Plaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire,
uc .

Attached Document, 6 Pages Document ID: 25792959 . PDF Format | Origine! Format |

Document Type: . - Access: — Statutory Fee: Lnked:
Discovery ~ use for electronic service only Public $0.00
Document title:
Special Interrogatories fo Pfaintiff Rufus Alexander By Defendant Bridgestone Firestone North American Tire, LLC
Expand All OF
FA sending Parties (1)
Party Porty Attorney . Firm Attorney Type,

Bridgestone Firestone North American Tire; petengant Milanfar, Becherer Kennett & Schweitzer- Attorney in

LLC (pending) Mant shahrad =~ Emeryville Charge
2 Recipients (1z) .

8 joe List (18' '

omer? Party ae Atxorney Fir Ayre? Method

Service Alexander, Rufus Plaintiff — Pollack, Dean Burnham Brown-Oakland Attomey og.

demamnnnDamelt . . . Service

Service, leaner, Rufus Plaintiff — Rundin, Waller Burnham Brown-Oatiand Attorney; Eo
Service Alexander, Rufus paint — Gonziles, Susana Bumbain Brown-Oaldand ‘tomey EL
save Aone oes —_emntng As ty
sevin BMW ofan Aner peda Aes, Acid eben iarsan ASEM
Sovce  fILM Newt Art ae Ginger, eeDommgison SST Ee
- CO

Service. Carlisle Co Inc Defendant Davidson, Africa & Bass! Extin Huie & Bunn aon Ee
Service Chrysier IC” ——Defendant Kuenster, Jennifer Nbvon Peabody tum-San  Atomey in
Service Cummins Engine Co Ine Defendant Selden, Catherine Jackson & Wallace Son eee ee cevice
‘Service = Dana CoLLC§=———__—efentiant: Counsel, Asbestos Brydon Huge & Parker San Gen 0 OE ae
‘Service Sao SeaMic Defendant Giaspy, David Glaspy & Glespy aaeey ne vice
seven YETI ue Gn Anse Amee omen
Service tear Stealer DvesiNet pefendant. Keesal, Samuel A Besen Stogemtong tome Eevee
Service Mack Trucks Inc Defendant Ostertag, James 1 Nexon Peabody up-San ee Service
Service ieee Defendant Reiley, MaryE hea Keser Stoan Reiley & Goes in Scyvice
Setvice Plant Insulation Corp Defendant Travis, Monte S Travis Pon ee vice
Service Pneumo ‘Abex uc Defendant spuneele Asbestos Beydon Huge § Parker-Son thevet in Eonvice
sence — TaPOtR Motor Sale erent COUNSEL, Asbestos Bryon Hago 8 Parker-San torey in E-

BHP . Francisco Charge Service
El _additional Recipients (0)
_case Parties .

(ez=Beoir

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aetna bat TannaExhibit Dwo ew KN DAH ® YB HH

Mark S. Kannett (SBN 104572)
Shahrad Mitanfar (SBN 201126)
Jennifer K. Thal (SBN 258612)

,BEGHERER KANNETT & SCHWEITZER

1255 Powell Street

ilke, CA 94608
Telephone: (rt a 658-3600
Facsimile: (510) 658-1151

Attorneys for Defendant
Bridgestone Firestone North American Tire, LLC,
successor to Bridgestone Firestone, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF SAN FRANCISCO

CASE NO. CGC-08-274719

RUFUS ALEXANDER, :
REQUESTS FOR ADMISSION TO
Plaintiff, PLAINTIFF RUFUS ALEXANDER BY
DEFENDANT BRIDGESTONE
vs. FIRESTONE NORTH AMERICAN TIRE,
Lu :
ASBESTOS DEFENDANTS (B¢P), et al, :
"Defendants. }
)

PROPOUNDING PARTY: Defendant Bridgestone Firestone North American Tire, LLC
RESPONDING PARTY: Plaintiff Rufus Alexander
SET NO.: One (1)

Pursuant to the provisions of Califomia Code of Civil Procedure sections 2033.010
through 2033.740, Defendant Bridgestone Firestone North American Tire, LLC requests that
Plaintiff Rufus Alexander ("Plaintiff)} respond fo each of the following requests for
admission, under oath, by admitting fo the truth of the specified matters of fact, opinions
relating to fact, or applications of law to fact. Bridgestone Firestone North American Tire,
LLC requests that a written response be served within thirty (30) days from the date of
service of these requests.

Ie

BES’ REQUESTS FOR ADMISSION TO PLAINTIFF, SET ONESe me
oe NA A FF YN KF

N

Oo eB AH Fe BN

Bridgestone Firestone North American Tire, LLC (BFS) submits its Requests for
Admission pursuant fo C.C.P. § 203.010, within the scope delineated by C.C.P. §
2017.010, ef seq., and subject fo the restriction set forth in C.C.P. § 2019.030, ef seq. If
Plaintiff fails to admit the truth of any of these requests for admission, BFS expressly
reserves its rights under C.C.P. § 2033.420 to bring a motion fo recover ifs expenses
incurred in proving at trial any matters not so admitted.

REQUEST FOR. ADMISSION NO. 1

Admit that YOU never personally handled any brake products manufactured,
supplied, sold or distributed by BFS.

[When in capital letters, YOU, YOUR, and YOURSELF means plaintiff, RUFUS
ALEXANDER, as well as anyone acting or purporting to act on their behalf, including, but
not limited tn, YOUR agents, YOUR employees, YOUR insurance companies, their agents,

their employees, YOUR attorneys, YOUR accountants, YOUR investigators, and anyone
else acting on YOUR behalf] [BFS includes, but is not limited to, Bridgestone Firestone ‘
North American Thre, LLC, Bridgestone / Firestone, Inc., Firestone Tire and Rubber
Company, World Bestos Corporation, ]
REQUEST FOR ADMISSION NO. 2 -

Admit that YOU were never present while someone else handled brake products
manufactured, supplied, sold or distributed by BFS.
REQUEST FOR ADMISSION NO, 3

* Admit that YOU never personally handled any clutch disc facings manufactured,

supplied, ‘sold or distributed by BFS. /
REQUEST FOR ADMISSION NO. 4 -

Admit that YOU were never present while someone else handled clufch disc facings
manufactured, supplied, sold or distributed by BFS. :

Admit that YOU never personally handled any automotive gaskets manufactured,
supplied, sold or distributed by BFS. ,

2b

‘BFS! REQUESTS FOR ADMISSION TO PLAINTIFE, SET ONEoe NY DR UH & WN

REQUEST FOR ADMISSION NO. 6

' Admit that. YOU were néver present while someone else handled automotive gaskets
manufactured, supplied, sold or distributed by BFS.

Admit that YOU are unable to produce any documents that support YOUR contention
that an asbestos-containing product manufactured, supplied, distributed, or sold by BFS.
released fibers which YOU subsequently | inhaied..
| REQUEST EOR. ADMISSION NO. 8 .

Admit that YOU are’ unable to identify any individuals who observed the release of
asbestos fibers YOU ifhaled from a product manufactured, supplied, distributed, or sold.by
BFS. , oO oO
REQUEST FOR ADMISSION NO, 9 |

Admit that neither YOU ever purchased replacement automoiive parts which were
manufactured, supplied, distributed, or sold by BFS. -

REQUEST FOR ADMISSION NO, 10 :

Admit that YOU possess no documents or other admissible evidence showing that
YOU ever purchased replacement automotive parts which were manufactured, supplied or
sold by BFS.

REQUEST FOR ADMISSION NO. 11

Admit that YOU possess.no documents or other admissible evidence showing that
YOU were ever in the vicinity of replacement automotive parts purchased manufactured,
supplied, distributed, or sold by BFS. / :

REQUEST FOR ADMISSION NO. 12 .

Admit that YOU possess no documents or other evidence showing that BFS ever _
concealed facts from YOU any information regarding the safety of asbestos-containing
products. : °
REQUEST FOR ADMISSION N NO. 13

Admit that YOU possessed no documents or ather evidence showing that BFS ever

3.

BES’ REQUESTS FOR ADMISSION TO PLAINTIFF, SET ONEow YT A HW & LY N

ee ew eB BR Be
A & Rw N & DO

17

concealed from YOU regarding the safety of asbestos-containing products.
REQUEST FOR ADMISSION NO. 14

‘Admit that YOU possess no documents or other evidence showing that You ever
consciously disregarded the safety of persons such as YOURSELF regarding the use of
asbestos-containing products.
REQUEST FOR ADMISSION NO. 15

Admit that YOU possess no documents or other admissible evidence showing that
BFS ever intentionally failed to reveal its knowledge of the Fiske associated with its products
to YOU.

DATED: November “ZO _, 2009 BECHERER KANNETT & SCHWEIZER

Nhe

nee
Ket for Defendant
Bridgestone Firestone North American Tire, LLC

+

ES’ REQUESTS FOR ADMISSION TO PLAINTIFF, SET ONEoe

1

oe
MW Pb Ww MN

16

wD wont DA HH BR WN

PROOF OF SERVICE BY ELECTRONIC TRANSMISSION ,

4 Barbara Golstein, declare that I am, and was at the time of service of the
documents herein referred to, over the age of 18 years, and not a party to the action; and !
am employed in the County of Alameda, State of California. My business address is 1285
Powell Street, Emeryville, California 94608,

On November pw, 2009, | electronically served the document(s) via LexisNexis File
& Serve described as: :

+ REQUESTS FOR ADMISSION TO PLAINTIFF RUFUS ALEXANDER BY
DEFENDANT BRIDGESTONE FIRESTONE NORTH AMERICAN TIRE,

on the recipients designated on the Transmission Receipt located on the LexisNexis File &
Serve website.

| declare under penalty of peyjury pursuant fo the laws of the State of California that
the foregoing is tue and correct and that this declaration was © on November /
2009, at Emeryville, California, f

bara Golstein -

5

EFS’ REQUESTS FOR ADMISSION TO PLAINTIFF, SET ONEe
oe

ll

Sm NAH eR WN oe

PROOF OF SERVICE ©

I, Barbara Golstein, declare that | am employed in the County of Alameda, State of
Califomia; | am over the age of eighteen (18) years and not_a party to the within entitled
action, my business address is 1255 Powell Street, Emeryville, Califomia 94608.

On November wD 2009, I caused fo be served the foregoing:

. REQUESTS FOR ADMISSION TO PLAINTIFF RUFUS
ALEXANDER BY DEFENDANT BRIDGESTONE FIRESTONE NORTH
AMERICAN TIRE, LLC ©

in said action by placing a tnie copy thereof enclosed in a sealed envelope and served in
the manner and/or manners described below to each of the parties herein and addressed as
follows:

Plaintiff, In Pro Per Rufus Alexander
170 Cashmere Street, No. D-
Sari Francisco, CA 94124

EX] (By Mail) | deposited such envelope with postage thereon fully prepaid to be placed in
the United States Mail at Emeryville, California. | am familiar with the mail collection
practices of Becherer Kannett & Schweitzer Attorneys and pursuant to those practices the
envelope would be deposited with the United States Postal Service the same day.

(1 {By Personal Delivery) I caused such envelope fo be delivered by hand to the office of
the addressee(s).

C1 (By Overnight Courier) 'I caused such envelope to be delivered via overnight courier
service to the addressee(s) designated.

C (Via Facsimile) | caused said document(s) to be fransmitted to the facsimile number(s)
of the addressee(s) designated. . ,

I'declare under penalty of re i the foregoing is true apd correct and that this

declaration is executed on November 009, at Emeryville,

fbara Golstein ~

* 6

BFS’ REQUESTS FOR ADMISSION TO PLAINTIFE, SET ONE|
|

Page 1 of 2

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usenet

. LexisNexis File & Serve Transaction Receipt

‘Transaction IDs *2B151504
Submitted by: Barbara Golstein, Becherer Kannett & Schweltzer-Emeryvilie
Authorized by: . Jennifer Thai, Becherer Kannett