MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO DISMISS (TRANSACTION ID # 53336400) FILED BY DEFENDANT GENERAL DYNAMICS CORP.

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On July 7, 2008 an asbestos case was filed by Koshes, Veda, represented by Donadio, David R, and Pro Per, against All Asbests Defts, Allis-Chalmers Corporation Product Liability Trust, Asbestos Defendants et al. represented by Fadeff, Jeffery John, Foley, Stephen J., Jackson, Gabriel Anne et al. in the jurisdiction of San Francisco County. Judge Teri L. Jackson presiding.

                        
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                          GABRIEL A. JACKSON, State Bar No. 98119
KER! A. DONOHUE, State Bar No. 226411

JEFFREY P. WILSON, State Bar No. 258027

JACKSON JENKINS RENSTROM LLP ELECTRONICALLY

55 Francisco Street, 6th Floor FILED

San Francisco, CA 94133 Superior Court of California,

Tel: 415.982.6300 County of San Francisco

Fax: 415.982.6700 JUL 26 2013
Clerk of the Court

Attorneys for Defendant, BY: ALISON AGBAY

GENERAL DYNAMICS CORPORATION Deputy Clerk

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

VEDA KOSHES, as Wrongful Death Heir, Case No. CGC-08-274728
and as Successor-in-interest to FRANK
JOSEPH KOSHES, Deceased, MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF DEFENDANT
Plaintiff, GENERAL DYNAMICS CORPORATION’S
MOTION TO DISMISS PLAINTIFF’S COMPLAINT
ve
Date: August 27, 2013
ASBESTOS DEFENDANTS (BP), et al. Time: 9:30 a.m.
Defendants. Dept: 503

Complaint Filed: July 7, 2008
Trial Date: None

1 INTRODUCTION AND RELEVANT FACTS

it has been over five years…