Exhibit,Appendix: CHARLES BOUDREAUX et al VS. ADVOCATE MINES, LTD et al

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PERKINS COIE LLP

Four Embarcadero, Suite 2400
San Francisco, California 9411
Telephone: (415) 344-7000
Facsimile: (415) 344-7288

‘Attomeys for Defendant

CHARLES BOUDREAUX and DEBORAH,
BOUDREAUX,

Plaintiff,
v.

ADVOCATE MINES LTD., et al.,

Defendants.

DAVID T, BIDERMAN: (State Bar No. 101577)
PATRICK M. MALONE, (State Bar No, 167433)

£60312-0001.03157.5GAL13630687.1

ELECTRONICALLY
FILED

‘Superior Court of California,
County of San Francisco
OCT 16 2007

GORDON PARK-LI, Clerh
BY: CHRISTLE ARRIOLA

Deputy Clerk]

(Georgia-Pacific LIC, ffk/a Georgia-Pacific Corporation

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

Case No. CGC-07-274029

EXHIBITS A THROUGH DT ‘Oo
DECLARATION OF PATRICK M.
MALONE IN SUPPORT OF DEFENDANT
GEORGIA-PACIFIC LLC’S MOTION FOR

SUMMARY JUDGMENT
Hearing Date: October 29, 2007

Time: 9:30am.

Department: 301

Judge: Hon. Patrick J. Mahoney
Complaint Filed: Janvary 12, 2007

Trial Set: November 13, 2007

RATION OF PATRICK M. MALONE.

-XHIBITS A THROUGH D TO DECLA!
CASE NO. CGC-07-274129.EXHIBIT ACT CORPORATION
Atak

se campany

or Erinn Lavan -(G-P)
Nawgant Consus

Service of Process

Transmittal
owesr2007
Log Number 511849370

RECEIVED

{Me eno: rv Bas Sue 101 JAN 29 2007

‘ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED &Y THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

Tm oF acriam:

ocumeNTis) SERVED:
‘countingeney:

NATURE OF ACTION:
‘ON witow process Was SEAvED:
[DATE AND MOUA OF SERVICE:
APPEARANCE 98 ANSWER QUE.

ATTORNEY(S) /SENDER(SY:

ACTION tre:

Charles Boudreaux and Deb
i ‘Pact Cor
‘Sypsum Company.

Secaraahatt Compa gctmant erotrinary Fact hoot, CiviiCaso Cover
Sheet, Answers), Ordor Mandating &

San Francice County Supacar Court, CA, CA
Case #07.274029 “ on

‘Asbestos Ligation - Personal inlury- Loss of Consortium

th Boudroaur, Pfs. vs, Advocate Mines, Ltd. et al
Kparstin, ey Guay and as Successor ner
i

30 calendar days afer sanvioe
Geran Spning
Baron &

‘ata. Suite 450
HES, CA, 0212,

ferme S'S GA. nis GA domastc company has fed a Conversion to « DE domestic.
Gf gs show a he lst agent before ta conversion. Fonesded per atnazaton

200 Panes wih vans via Fas x2 Oa, TaBnB4s0N6Se

Aeiaton. Sn Lavi FeeaSenieagpiavganiconsig com
Enya Natal, Gaara Pace Cop Acbeute
asbestasiawg@Clnoteegapack

GT Corpocation System

& ae Sys

{Got deactive Sve,
‘0961

Atlanta, GA,
404-965-3840

Paget of 1/MJ01/12/2007 FRI 13:92 FAX 415 957 0585 SPECIALIZED LEGAL SERV.

Bawons °

{CITACION JUDICIAL)

nonce 10 ofrhonr CO

{AVISO AL DENNDADO): novocars veves. cr: sttis CHALNEIRS CORTERALION ROOTES
LLAaILATY TRUST, BORGWARNER Woah Pex NC, hh) wd neem rasceatePene Capccan:
(ancl Paton

YOU ARE BEING SUED BY PLAINTIFF:
(0 ESTA DEMANDANDO EL DEMANDANTE):
{CHARLES BOUDREAIIX of DEBORALE BOUDREAU

"atachmen fon aches

Boosvooe

e SUM-109
FOR COURT USE ONLY
(S0L0 PARA USO BELA CORTE

PY

“You hava 30 CALENDAR DAYS after is surmona and lel papers
lait. Aster or phone call wl nt tote you. Your wien response

Court form that your ean wn
couutinfa ‘county Ian, ofthe csnthotse

hare are ether legal cequlramants You may want eal zn aterm
Sends. fou cannot aford an attamay, you ay be elgDe for fen let sare
‘groups at tke Caliomla Legal Services Web ale (ew bwhlpcaiTo

by contacting your local court or sounty bar aeesciaon,

Trane 30 DIAS DE CALENDARIO dnapube Se qu
ques enUgve Une copia af demandarte Uns cara «ana lumads elefinlen

“ 2. govreelep), Your ret you. you cannot pay the fy fe, 22k the court cht fora foa waver form,
you do nt la your rexponse on dna, yau may lave the eas by defaul, ard your wager, monty. sod property ry be fake without futher warning fom tre
ay you do met know

te ectroguas esta ctctén y papatea fagales para presenia na ruspuests por excita an outa corte y hacer
ta paatagon. Su reapuetta por tha Senn que netroots
Tg ses ae ence as incr Be pu ge hyn Re tad poe a or eget Pt A es

Shanes xn mae

The name and adress of ie court :
(Elaombrey direcci6n data corte ex}:

‘SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO

400 HoAllister Street

‘San Francisco, Californta 94102

‘CASE NUMBER:
(Nomero det Caso):

csc ~07-27 4020

The name, address ang tslephone mumber of plalntitfs etorney, or plsinif' without an attomay, iz:
(Bl nonttre, fa drecein y el ndmaro de teléfono del abogade dot demandante, o del denandante que no tine abogado, )"

Carolin KC Shining, Eq. (SBN 207440)
Erie Brown, £q. (SENZ29622)
BARON

'& SUD, P.C,
9485 Wishire Blvd, Suite 480, Beverty Hills, CA 90242
Tolephone: {810} 860.0478
Faceimnie: (310) 860-0480
Gordon Parkeli Deborah Steppe

DATE. “JAN 1 g S308 lei, by Depuy
(Pech) 2007 Gocretarioy (ajuatoy
(For proof of service of tis summons, use Froof of Service of Summons (form POS-010))
(Pare prucda de entrega do osta cltén use ol formulads Proof of Servico'of Summans, (POS-040).
(SEALY NOTICE TO THE PERSON SERVED: You are served

4. 0 as an individual defendant

2. G asthe person sued under the fictions name of (speedy):

Lf on pena gFepeciyp: :

under CoP 416.10 (corporation) 1D cop 416;60,minor)
CCP 416.20 (defunct corporation) LI CCP.416.70 feonservateo)
CCCP 416.40 (association or parinership) CCP 476.80 (authorized person)
other (epeciia:
4, © by personal delvey on (da
. GEORGIA-PACITIC CORPORATION

Farm pastas tg 133 PEACHTRER STREET, NE seams

siti pe aoe B89 SUMMONS

ATLANTA, Ga, 30303SHORT TITLE: CHARLES BOUDREAUX and DEBORAH. CASE NUMBER:
BOUDREAUX

INSTRUCTIONS FOR USE

"> This form may be used as an attachment to any summons if space doss not parmit the listing of all parties an the
summons.

‘= If this attachment is used, insert the following statement in the plaintiff or defendant box on the surumons: “Additional
Pariies Attachment form is attached.”

List additional parties (Check only one box. Use a separate page for each type of party):
© piaintrt 3 etendant 41 Cross-Complainant 1 Gross-Defendant

BORGWARNER, INC,, individually and as successor-in-interest to Borg-Warner Corporation; BUFFALO
PUMPS, INC.; CBS CORPORATION, fk/a Viacom, Inc, (suocessor-by-merger to CBS Corporation,
sucoessor-by-merger to Westinghouse Electric Corporation); CRANE CO.; CSK AUTO, INC. (individually and
fbla “Checker Auto Parts", *Shuck's Auto Supply,” and "Kragen Auto Parts"); CSR, LTD., (k/a Colonial
Sugar Refining Company); IDATMLERCHRYSLER CORPORATION (ida Chrysler Corporation);
FLOWSERVE CORPORATION, individually and as successor-in-interest to Dusco International, Inc, fk/a The
‘Duriron Company, Inc.; FORD MOTOR COMPANY; FOSTER WHEELER ENERGY CORPORATION;
GARLOCK SEALING TECHNOLOGIES, LL:C. (individually and as successor-in-interest to Garlock, Inc.)
GHNERAL ELECTRIC COMPANY; GENERAL MOTORS CORPORATION, GEORGIA-PACIFIC
CORPORATION, individually and as successor-in-interest to Bestwall Gypsum Company; HANSON
PERMANENTE CEMENT, INC., (fk/a Kaiser Cement Corporation, individually and as successor-in-intereat to
Kaiser Gypsum Company, Inc.); HONEYWELL INTERNATIONAL, INC. (individually and as
successor-in-interest to Allied-Signal, Inc. and The Bendix Corporation); IMO INDUSTRIES, INC. (individually
and as successor-in-interest to Del aval Turbine, Inc.); INGEKSOLL-RAND COMPANY; KAISER GYPSUM
COMPANY, INC.; PLANT INSULATION COMPANY, FORMERLY ASBESTOS COMPANY OF CA;
RINKER MATERIALS CORPORATION, fk/a CSR Amatica, Inc.; SEPCO CORPORATION; 1HE PEP
BOYS MANNY MOE & JACK OF CALIFORNIA; THORPE INSULATION COMPANY; UNION CARBIDE i
CORPORATION, and DOES 1-300

ucaemcnceann ‘ADDITIONAL PARTIES ATTACHMENT

spt or ese ‘Attachment to Summons01/12/2007 ERI 13:92 FAK 415 357 O585 SPECIALIZED LEGAL SERY.

Boosso06

/

° “* COPY

John Langdoo, Fsq. (SBN 235509) ENDORSED

BARON & BUDD, P.C. D
3102 Oak Lawn Avenue, Suite 1100 sonranfool iol bbarar coos
Dallas, Texas 75219 :

Telephone: 214/521-3605 ati 1 2 a0d7
Facsimile: 214/520-1181 ABORDON FAK KL, Clerk

BRON STE
Carolin K. Shining, Esq. (SBN 201140) oe BS SIS

Eric Brown, Bsq. (SBN229622) ~
BARON & BUDD, P.C.

9465 Wilshire Blvd., Suite 460

Beverly Hills, CA 90212

‘Telephone: 310/860-0476

Facsimile: 310/860-0480

‘Attorneys for Plein,
“SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION

COUNTY OF SAN FRANCISCO
PRELIMINARY REACT SHEET
CHARLES BOUDREAUX aad, Nol C.GC-07~274029
DEBORAH BOUDREAUX,
” Phaintifts, PRELIMINARY FACT SHEET/
NEW FILING/ASRESTOS
vs . LITIGATION
ADVOCATE MINES, LTD et al,
(See General Order No. 129. In Re
G No. 12

Le AcT Stcront,

PRELIMINARY FACT SHEET

iNOTICE

‘TO NEW DEFENDAN1S SERVED IN COMPLEX ASBESTOS LITIGATION
IN THE SUPERIOR COURT IN AND FOR THE STATE OF CALIFORNIA,
CITY AND COUNTY OF SAN FRANCISCO

You have been served with process in an action which has been designated by the Coust as
complex litigation pursuant to Standard 19 of the Standards of Judicial Administration. This
litigation bears the caption "In Re: Complex Asbestos Litigation”, [San Francisco Superior Court
No, 828684]

This litigation is govemed by various general orders, some of which affect the judicial
management and/or discovery obligations, including the responsibility to answer interrogatories
deemed propounded in the case. You may contact the Court or Designated Defense Counsel,
Berry & Berry, Station D, Post Office Box 70250 (1300 Clay Street, Ninth Floor), Oaldand, CA
946120250, Telephone: (510) 8358330; FAX: (510) 8355117, for further information and/or
copies of these orders, at your expense.

1. State the complete name and address of each person whose claimed exposure to asbestos
is the basis of this lawsuit (exposed person"): Charles Boudreaux, 13323 Gina De
Lockeford, CA_95237

2. " Does plaintiff anticipate filing a motion for » preferential lial date within the next four
months?
x Yes No

{If yes, the action will be govemed by General Order No. 140; if no, the action will be
govemed by General Order No, 129.]

3. Date of birth of each exposed person im itern one and, if applicable, date of death:

Date of Birth: 1/17/1952

Social Security Number of each exposed person:

437-86-7738

4. Specify the nature or type of asbestos-related disease alleged by each exposed person,

Jos RNOUAABOUDRERKC RACY SEE

sige
‘PRECAMINARY PACT SHEETAsbestosis: X__ Mesothelioma

2 Pleural Thickening/Plaques Other Cancer, Specify:
3
4 Lang Cancer Other than Other
Mesothelioma Specify:
5
6] & For purposes of identifying the nature of exposure allegations involved in this action,
please check one or more:
7
8 Shipyard Construction X_ Friction Automotive
9 Premises Acrospace X_ Military
10 Other: Specify all that apply: _ Secondary
vl
2 Tfapplicable, indicate which exposure allegations apply to which exposed person.
3 =
14]. 6. Identify eack location alleged to be a sourve of an asbestos exposure, and fo the extent
1s known, provide the beginning and ending year(s) of each such exposure. Also specify
‘each exposed person's employer and job title or job description during each period of
16 exposure, (For example: “San Francisca Naval Shipyard Pipefitier 19391948").
1 amples of locations of exposure might he a specific shipyard, a specific railroad
‘maintenance yard, or pethaps more generalized descriptions such as “merchant marine”
18) ‘or “coristruction". {fan exposed person claims exposure during only a portion of'a year,
19 ‘the answer should indicate that year as the beginning and ending year (e.g, 19471947).
20 °
Location of Job Title at Year(s) of Exposure
2k Time of
2 Exposure Empioyer Exposure Beginning Ending
2B ‘see work history
attached”
24
2s
26
7
28
29
30
grape 7s abeeeraneeon

(Attach Additional Pages, ,If Necessary)

7. For each exposed person who:

@ worked in the United States or for a U.S. agency outside the territorial United
States, attach to the copy of this fact sheet provided to Designated Defense Counsel
a fully executed Social Security Eamings authorization (Exhibit N4 to General Order
No. 129), .

b. may have had « Social Security disability award or isno longer employed and whose
Jast employment was not with a United States government agency, attach to the copy
of this fact sheet provided to Designated Defense Counsel a filly executed Social
Security Disability authorization (Exhibit NS to General Order No. 129);

¢. served at any time in the United States military, attach to the copy of this fact sheet
provided to Designated Defense Counsel two fully executed originals of the
stipulation (Exhibit N3 to General Order No. 129);

4. was emplayed by the United States government in 2 civilian capacity, attach to the
copy of this fact sheet provided to Designated Defense Counsel two filly exeouted
originals of the stipulation (Exhibit N3 to General Order No. 129).

Tf there is a wrongs death claim, attach to the copy of this fact sheet provided to
Designated Defense Counsel a copy of the death certificate, if available. fan autopsy
report was done, also attach 2 copy of it to the copy of this fact sheet provided to
Designated Defense Counsel,

By:
9465 Wilshire Blyd,, Suite 460
Beverly Hills, CA 90212
Telephone: 310/860-0476
2
sessed irae

‘PRELIMINARY FACT SHEET‘NAME: CHARLES BOUDREAUX

WAS JOB INDOORS? :

CADMIUM

NICKNAME: "CHARLIE'
GROUP NAME:
WORK HISTORY SHEET

HOUSEHOLD. EXPOSURE SUPERVISOR:

Greate! Osea NAMES OF COWORKERS & JOB TITLES:
EMPLOYER BOUDREAUX, DECEASED
JOB SITE. JOHNS:MANVILLE PLANT.
CITY, STATE: MARRERO, LOUISIANA —__
DATE OF —-.---—_.
EXPOSURE: 1952-1954

SURE: : ‘ON THIS JOB SITE WERE YOU EXPOSED TO
LENGTH OF EXPO! — ANY OF THE FOLLOWING:
HOUSEHOLD EXPOSURE WINESS CUTIES AT 5
THIS JOBSITE: LINE WORKER ‘CHEMICALS YES__. —

FUMES Yes

WAS JOB NEW CONSTRUCTION GASES YES
REPAIRWORK____ of BOTH CHROMIUM YES

OUTDOORS? 5 Or BOTH
REASON FOR LEAVING:

WAGE RATE/HOUR:
AVERAGE HOURS WORKEDAWEEK:

YES_.
ANY OTHER PRODUCT YES__

ust:

DID YOU WEAR A RESPIRATOR, MASK OR
OTHER PROTECTIVE DEVICE ON THIS JOB TO.
AVOID INHALATION OF ANY DUST GR FUMES:

INCLUDING ASBESTOS OUST?
YES: NO:
COMMENTS:
ASBESTOS MATERIALS USED ON THESE JOBS: _ WORKED
WITH AROUND
UNKNOWN.

ET -Page 1

WORK HISTORY SHEET «|
(Aocuments ed Serrigatmuecitncst Setingal Teper nena OLA SPABOUDREALNCE WH (ope {CCSHOINL 2007)NAME: CHARLES BOUDREAUX
NICKNAME: “CHARLIE”
GROUP NAME:
WORK HISTORY SHEET
EMPLOYER UNKNOWN EMPLOYER. SUPERVISOR
JOB SITE: RESIDENTIAL SITE (S| NAMES OF COWORKERS & JOB ‘TITLES:
CITY, STATE: LOUISIANA
DATE OF JOB: MID 1960'S
APPROXIMATELY 3
LENGTH OF JOB: MONTHS:
MY DUTIES AT THIS JOBSITE: eR ON THIS JOB SITE WERE YOU EXPOSED TO
a

WAS JOB NEW CONSTRUCTION ____; ANY OF THE FOLLOWING.
REPAIR WORK__X__; of BOTH

CHEMICALS YES__NO x
WAS JOB INDOORS? FUMES: YES NO _X
OUTDOORS? __X__: or BOTH GASES YES___NO _X
REASON FOR LEAVING: CHROMIUB YeS___ NO, “x
SHanasp Joas NS CADMIUM YES__" NO TX”

—~ ANYOTHEReRODUCT YES NO “x

WAGE RATE/HOUR: —_
AVERAGE HOURS WORKEDWEEK: UST:

INCLUDING ASBESTOS OUST?
YES: No: x
COMMENTS:
ASBESTOS MATERIALS USED ON THESE JOBS. He QRKED
WITH AROUND
UNKNOWN

ORC HsTORY SHEET - Page 2
‘CrDscomante al Selina

erase ocl Setings\Tempory ntnet FResIOLKI2UBOUDREALYCE WH wpe (wpeXC?S NO 007]NAME: _CHARLES BOUDREAUX
NICKNAME: “SCHARLIE™
GROUP NAME:
wi STORY SHEET
HOUSEHOLD EXFOSURE SUPERVISOR,
CAROUGE FATHER: NAMES OF COWORKERS & JOB TITLES:
EMPLOYER: BOUDREAUX, DECEASE:
JOB SITE: AVONDALE SHIPYARD
CITY, STATE: WESTWEGO, LOUISIANA ———
DATE OF
EXPOSURE: 1954-1969
GN THIS 108 SITE WERE YOU EXPOSED 10
LENGTH OF EXPOSURE: ANY OF THE FOLLOWING:
HOUSEHOLD EXPOSURE WITNESS DUTIES AT
THIS JOBSITE: SHEET METAL WORKER "CHEMICALS ES.
WAS JOB NEW CONSTRUCTION GASES Yes
REPAIR WORK ;0r BOTH CHROMIUM Yes
CADMIUM YES

WAS JOB INDOORS?
OUTDOORS? ; or BOTH

REASON FOR LEAVING:

WAGE RATE/HOUR:
AVERAGE HOURS WORKED/WEEK:

ANY OTHER PRODUCT YES__

ust:

DID YOU WEAR A RESPIRATOR, MASK OR
OTHER PROTECTIVE DEVICE ON THIS JOB TO
AVOID INHALATION OF ANY DUST OR FUMES

INCLUDING ASBESTOS DUST?
YES: NO:
COMMENTS:
ASBESTOS MATERIALS USED ON THESE JOBS: WORKED
WITH AROUND
UNKNOWN

WORK HISTORY SHEET

-Page 3
aDecumons end Stingsnwateostoce Setng\Tengaray bienot FlevOLK{20BOUORFAUX CWHpd (wpexe25y04102007)NAME: CHARLES BOUDREAUX
NICKNAME: SCHARL IE
GROUP NAME,
WORK H'STORY SHEET

CHEVRON SERVICE SUPERVISOR;
EMPLOYER TA NAMES OF COWORKERS & JOB TITLES:

CHEVRON SERVICE
JOB SITE: STATION

CITY, STATE: TERR NLA

DATE OF JOB: ATE 1960'S,

APPROXIMATELY 3
LENGTH OF JOB: MONTHS
MY DUTIES AT THIS JOBSITE: SERVICEMAN
WAS JOB NEW CONSTRUCTION ____:
REPAIR WORK, Sof SOTH

WAS JOB INOGORS? :
OUTDOORS? _ 5 BOTH

REASON FOR LEAVING:
CHANGED JOBS

WAGE RATE/HOUR™
AVERAGE HOURS WORKEDWEEK:

ON THIS JOB SITE WERE YOU EXPOSED TO

ANY OF THE FOLLOWING:
CHEMICALS YES__ NO _X
FUMES YES NOX
GASES YES NO TX_
CHROMIUM YES_ NO "X.
CADMIUM. YES___NO _X
ANY OTHER PRODUCT YES___NO 7X

AVOID INHALATION GF ANY DUST OR FUMES

INCLUDING ASBESTOS DUST?
YES: NO: x
COMMENTS:
ASBESTOS MATERIALS USED ON THESE JOBS: WORKED
WITH
UNKNOWN:

WORK HISTORY SHEET Page ¢

‘CiDoccmerts pd SeUngs\miateciL ocd Setings\Terporey Inna Fes! LKU2BQUDREALK CW Hurd (wpeHEZS)OIN 2007)NAME: CHARLES BOUDREAUX
NICKNAME: “CHARLIE™
GROUP NAME
WORK HISTORY SHEET.

EMPLOYER: AVONDALE SHIPYARD SUPERVISOR:
JOB SITE: OND) IPYARD NAMES OF COWORKERS & JOB TITLES:
CITY, STATE: WESTWEGO, LOUISIANA ——
DATE OF Joa: 1968-1970 ———.

APPROXIMATELY 2 —
LENGTH OF JO8: YEARS
‘MY DUTIES AT THIS JOBSITE: TACK WELDER oN FISTS OCS OTE ON ETS

1S JOB EXPO:
WAS JOB NEW CONSTRUCTION ____; ANY OF THE FOLLOWING.
REPAIR WORK. 3 ot BOTH
CHEMICALS YES,
WAS JOB INDOORS? ; FUMES YES
OUTDOORS? 5 or BOTH GASES YES
REASON FOR LEAVING: CHROMIUM YES.
SOINED MILITARY. _ CADMIUM ves,
ANY OTHER PRODUCT

WAGE RATEHOUR: © . OTHER c —

AVERAGE HOURS WORKEDAWEEK: 40

ASBESTOS MATERIALS USED ON THESE JOBS,

ust:

DID YOU WEAR A RESPIRATOR, MASK OR
OTHER PROTECTIVE DEVICE ON THIS JOB TO
AVOID INHALATION OF ANY DUST CR FUMES

INCLUDING ASBESTOS DUST?
YES) NO; LX
COMMENTS:

WHS AEOUND
x

GLOVES & PROTECTIVE CLOTHING: UNKNOWN GLOVES
WELDING PRODUCTS: UNKNOWN WELDING RODS: x
won sr Page §

Wonk wisTORY sHEer
‘SADocuments and Seiogsimuaton ed Settoge Yenparary hint FieelOLKI2SGQUDREALALC WH.upd apelfOZSYOUNC:2007)NAME: CHARLES BOUDREAUX
NICKNAME: CHARLIE
GROUP NAME:
WORK HISTORY SHEET
EMPLOYER: PERSONAL USE SUPERVISOR:
Jos sive PERSONAL VEHICLES NAMES OF COWORKERS & JOB 7ITLES:
LOCKEFORD,
CALIFORNIA; TRACY,
CMY, STATE, CALIFORNIA ——
DATE OF JOB: 1969-2606 ——
sooaurey =
i SS
‘GAVTHIS JOB SITE WERE VOU EXPOSED TO
LENGTH OF JOB: 220. GASKET JOBS Any OF THE FOLLOWING:
: MECHAN! ©
My DUTIES AT THIS JOBSITE We ay YES
WAS JOB NEW CONSTRUCTION FUMES YES
REPAIR WORK, ; or BOTH GASES YES
WAS JOB INDOORS? ; CHROMIC veS___ NO __
OUTDOORS? ; rBOTH ‘CADMIUM YES__. —
— —— _ ANYOTHER PRODUCT YES NO __
REASON FOR LEAVING::-
ust: _
WAGE RATE/HOUR:

AVERAGE HOURS WORKEDIWEEK:

DID YOU WGAR A RESPIRATOR, MASK OR
“OTHER PROTECTIVE DEVICE ON THIS JOB TO
AVOID INHALATION OF ANY-DUST OR FUMES
INCLUDING ASBESTOS DUST?

YES: NO:

COMMENTS:

BESI ESE JOB: WORKED
wit! AROUND
GASKETS & SHEET PACKING: UNKNOWN x
‘BRAKE LININGS: UNKNOWN x
AUTOMOTIVE PRODUCTS: UNKNOWN BRAKE LATHE x
PERSONAL VEHICLE(S}: 1900'S OLDSMOBILE x

we °Y SHEET - Page 6

(CiDucneris and Sutingéenwatsoat aes Stings Tempotmy intel Finck KI24BOUDREAUXCWHwpd twpci{CZS NONE 2007,NAME: CHARLES BOUDREAUX

NICKNAME: “CHARLIE”
GROUP NAME:
WORK HISTORY SHEET
EMPLOYER: S.AIR FORCE SUPERVISOR:
JOB SITE SEE ATIACHED UST NAMES OF COWORKERS & JOB “ITLES:

CITY, STATE SEE ATTACHED LIST

DATE OF JOB; 1974-1979

LENGTH OF JOB;

MY DUTIES AT THIS JOBSITE: COMPUTER
SPecialisy

SPECIALIST

WAS JOB NEW CONSTRUCTION

REPAIR WORK,

WAS JOB INDOORS?
QUTDOCORS? ____s or BOTH.

REASON FOR LEAVING:
HONORABLE DISCHARGE

‘or BOTH

APPROXIMATELY 8
YEARS

‘ON THIS JOB SITE WERE YOU EXPOSED TO.
ANY OF THE FOLLOWING:

CHEMICALS YES___NO _X_
FUMES: YES NO TX”
GASES YES_ NO “xX”
CHROMIUM: yes ~NO XT
CADMIUM. NO XT
ANY OTHER PRODUCT eS, NO XT

WAGE RATEHQUR: MILITARY SCALE ust:

AVERAGE IIOURS WORKEDIWEEK:

BESTOS MA’ USEI SE

WORK HISTORY SHEET. Page ?

DID YOU WEAR A RESPIRATOR, MASK OR
‘OTHER PROTECTIVE DEVICE ON THIS JOB TO
AVOID INHALATION OF ANY DUST OR FUMES
INCLUDING ASBESTOS DUST?

YES: NO: x

COMMENTS:

WORKED
WITH AROUND
UNKNOWN

‘CaOacaments ed Slingvrvetson oc! Selingst Tamper inant FeclOAKICAWBOUDREAULC Hp OwpeKCZSYOHNE2007)NAME: EGWARD J. KAMINSKI
NICKNAME: "EDDIE"
GROUP NAME:  _KAMINSK EDWARD.

WORK HISTORY SHEET

JOBSITES, INCLUDI TO:

LACKLAND AIR FORCE BASE
‘SAN ANTONIO, TX

1971-1972

APPROXIMATELY 6 MONTHS

U.S. AIR FORCE TRAINING FACILITY
DENVER, CO. :
1972-1973

APPROXIMATELY 1 YEAR

EDWARDS AiR FORCE BASE
MOJAVE DESERT, CA,
1973-1975

APPROXIMATELY 1 4 YEARS

N.KP. AIR FORCE BASE
THAILAND

1975-1976
APPROXIMATELY 8 MONTHS:

TRAVIS AIR FORCE BASE
FAIRFIELD, CA

1976-1979
APPROXIMATELY 3 YEARS

WORK HISTORY SHEET Page
{CaDocamens ond Seingsaleentocd SetingetTenpay interet FIaSOLK BOUDREAUX WHipd (ecKCZS 0107007)NAME:
NICKNAME:
GROUP NAME:

EMPLOYER’

JOB SITE:
CITY, STATE:
DATE OF JOB:

LENGTH OF JOB:

CHARLES BOUDREAUX

CHARLIE"

WORK HISTORY.

STITH CHEVROLET SUPERVISOR:

STITH CHEVROLET BODY
SHOP

NAMES OF COWORKERS & JOB TITLES:

VACAVILLE, CALIFORNIA,
4979-1980

APPROXIMATELY 1
YEAR

MY DUTIES AT THIS JOBSITE; AUTO BODY

REPAIRMAN.

WAS JOB NEW CONSTRUCTION _____

REPAIR WORK__X__; or BOTH

WAS JOBINDOORS? = _X

‘OUTDOORS?

oF BOTH

REASON FOR LEAVING:
CHANGED JOBS

WAGE RATE/HOUR:

AVERAGE HOURS WORKEDIWEEK: 40+

ON THIS JOB SITE WERE YOU EXPOSED TO

ANY OF THE FOLLOWING:
CHEMICALS YES NO LX.
FUMES YES" NO XT
GASES YES NO TX"
‘CHROMIUM YES NO. Tx”
CADMIUM YES NO x”
ANY OTHER PRODUCT YES___ NO ~X_

LIST:

DID YOU WEAR A RESPIRATOR, MASK OR

INGLUDING ASBESTOS busT?

YES NOX
COMMENTS: |
}
TOS ON TH! WORKED
WHO
UND
BRAKE LININGS, UNKNOWN x
AUTOMOTIVE PRODUCTS: ‘UNKNOWN BONDS x |

Wopuistory sheer Panes
iCeesemans d Gotngsimentsent.oe Seting\Temscray ema FesiOLK12080UDREAUKC WHwed (wpeXCZSO102007),NAME, CHARLES BOUDREAUX
NICKNAME: “CHARLIE"
GROUP NAME:
WORK HISTORY SHEET

COMMERCIAL SUPERVISOR: —————
EMPLOYER: TRANSPORT NAMES OF COWORKERS & JOB TITLES:

SOMMERCIAL
JOB SITE: IRT SHOP
CITY, STATE: TRACY, JFORNW
DATE OF JOB: 1994-2000

APPROXIMATELY 6

LENGTH OF JOB; (EARS.

ON THIS JOB SITE WERE YOU EXPOSED TO

MY DUTIES AT THIS JOBSITE: DIESEL TRUCK ANY OF THE FOLLOWING:
MECHANIC __ CHEMICALS YES.

WAS JOB NEW CONSTRUCTION ; FUMES: YES.

REPAIR WORK. ; or BOTH, GASES YES.

WAS JOB INDOORS? : GHROMUN Ye

OUTDOORS? ____; er BOTH ANYOTHER PRODUCT YES__

REASON FOR LEAVING:

CHANGED JOBS. LIST:

WAGE RATB/HOUR: DID YOU WEAR A RESPIRATOR, -MASK OR

AVERAGE HOURS WORKEDWEEK: 40+

SBEST TERIALS USED. (ESE JOBS:
GASKETS & SHEET PACKING: UNKNOWN
BRAKE LININGS: BENDIX
CLUTCH LININGS: UNteNoWn
Work HisToR, Pogo 10

INCLUDING ASBESTOS DUST?
YES: NO: &
COMMENTS:
WORKED
WITH ARQUND
x
x.
x

WORK HISTORY SHEET.
‘CaUseumons ond Seilnptotier nea Sesings\T reper tana FUesIOUKI2ABOUDREALKC. WEL (epeXCESHMAC 2007)NAME: -GHARLES BOUDREAUX
NICKNAME: SCHARLIE®
GROUP NAME:

WORK HISTORY SHEET

‘72UP BOTTLING COMPANY,
Z-UP BOTTLING.

SACRAMENTO,
CALIFORNIA,

2000-2006
APPROXIMATELY 6
YEARS

CITY, STATE:
DATE OF JOB:

LENGTH OF JO8:

MY DUTIES AT THIS JOBSITE: FLEET
MECHANIC

WAS JOB NEW CONSTRUCTION 5
REPAIR WORK jor BOTH

WAS JOB INDOORS? 2
OUTDOORS? jor BOTH

REASON FOR LEAVING:

WAGE RATEVHOUR:
AVERAGE HOURS WORKEDMWEEK: 40+

SUPERVISOR
NAMES OF COWORKERS & JOB TITLES:

|

OW THIS JOB SITE WERE YOU EXPOSED TO

ANY OF THE FOLLOWING:
CHEMICALS YES__.
FUMES: YES,
GASES YES___
CHROMIUB Yes
CADMIUM, YES.

ANY OTHER PRODUCT YES

ust:

DID YOU WEAR A RESPIRATOR, MASK OR
‘OTHER PROTECTIVE DEVICE ON THIS JOB TO
AVOID.INHALATION OF ANY DUST OR FUMES
INCLUDING ASBESTOS DUST?

YES: NO: _X
COMMENTS:
ESTOS MATERIA THES! WORKED
WITH AROUND
GASKETS & SHEET PACKING: Uniavown x
BRAKE LININGS: x
FORD x
[GENERAL MOTORSIDELCO x
CLUTCH LININaS: FORD x
WELDING PRODUCTS: UNKNOWN WELDING RODS x

WORK HISTORY SHEET «Pago tt
(Pidesments ase Seba

loa oe Stings\Teparaty htemat Past OLKA2AOUOREALL WH ap (pe kOZS}OUIE-2007)NAME:
NICKNAME:
GROUP NAME:

CHARLES BOUDREAUX

"CHARLIE"

RK HISTORY SI

OTHER EMPLOYERS AND JOBSITES

Plaintiff is not aware at this time of exposure to asbestos at the foliewing jobs:

EMPLOYER:
JOB STE:
CITY, STATE:

DATE OF JOB.

SHUGART

SHUGART FACILITY

SANTA CLARA, CALIFORNY

1980-1981

MY DUTIES AT THIS JOBSITE: COMPUTER PARTS HANDLER

EMPLOYER:
JOB SITE:
CITY, STATE:

DATE OF JOB:

CONTROL BATA.

CONTROL DATA FACILITY

SUNNYVALE, CALIFORNIA

1981-4990

MY DUTIES AT THIS JOBSITE: RESEARCH AND DEVELOPMENT

EMPLOYER:
JOB SITE:
CITY, STATE:

DATE OF JOB:

SAN JOAQUIN COUNTY,

‘SAN JOAQUIN COUNTY FACILITY.

STOCKTON, CALIFORNIA

1980-1995

MY DUTIES AT THIS JOBSITE: COMPUTER OPERATOR REPAIRMAN

yore story sueer.
‘Adee.

Page 12

and Betingdimatson ona Setings Taper ay Intuinot FasL I24EOLUREALDLCWHged (wpe XCZENOIN 2007}91/12/2007 FRE 19:32 FAX 415 387 0385 SPECIALIZED LEGAL SERV.

a

whe we

we wo

a

John Lengdoc, Esq. (SBN 235509)
BARON & BUDD,
5102 Oak Lav Avenue, Suite 1100
Dallas, Texas 75219 .
‘Telephone: 214/521-3605

Facsimile: 214/520-1181

Carolin K. Shining, Esq. (SBN 201 0

Eric Brown, 5 (oaNosos22)
BARON & ID, P.

9465 Wilshire Bivd., Suite 460

Beverly Hills, CA 96212

Telephone: 310/860-0476

Facsimile; 310/860-0480

Allorneys for Plaintifis,
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO-UNLIMITRD TURISDICTION

DEC 19 2007 -1eM

‘DEPARTMENT 206

CUARLES BOUDREAUS and DEBORAH
BOUDREAUX,

COMPLAINT FOR
Plaintifis, PERSONAL INJURIES
vs. [ASBESTOS GENERAL
ADVOCATE MINES, LTD.; ALLIS-CHALMERS:

(Guccessor-y mgr to CBS Corportion,
Seeessor to” eres house Fe Blectric
Corporations, CRANE CO; CK AUTO, INC.
fadividualy ond dba "Checker Auto Pers,
Sender aee Supply," and "Kragen Auto Barts");
GSR, LTD. (ok Clonal Sup Retaing

Leite
a an |
)

)

)

ION; GARLOCK SBALING
TECHNOLOGIES, 1.L.C. Gndividuslly and as
successor-i lorintrest to G
BLECTRIC COMPANY: GENERAL MOTORS
CORPORATION, GEOK GEA PACIFIC

003/008

cASERE -07-27 4025

PUARiFinrs ORiGHAL ASUESTOE COMPLAINT 7
‘eADorumens and Sacingsenideos StingstTorperty nbaet FlislOLKUAEOUDREAUK Opt (SCM) (any 11,2007)

PoetCORPORATION, individually and as
Successor-in-interest to Bestwall Gypsum Company;
HANSON PERMANENTE, CEMENT, INC,, tide
Kaiser Cement Corporation, individually and as
successor-in-interest to Kniser Gypsum Company,
Inc.); HONEYWELL INTERNATIONAL, INC.
Gadidually aad as successor intnterest 18

llied-Signal, Inc. and The Bendix Corporation);
IMO INDUSTRIES, INC. (individually and as
successor-in-interest to DeLaval ‘Turbine, Inc,);
INGERSOLL-RAND COMPANY; KAISER
‘GYPSUM COMPANY, INC; PLANT
INSULATION COMPANY, FORMERLY
ASBESTOS COMPANY OF CA;

Aumerica, Inc.; SEPCO CORPORATION; THE PEP
BOYS MANNY MOE & JACK OF CALIFORNIA;
‘THORPE INSULATION COMPANY: UNION
‘CARBIDE CORPORATION, and DOES 1-300,

Defendants.

COME NOW, Plaintiffs CHARLES BOUDREAUX end DEBORAH BOUDREAUX
and for causes of action against Defendants, and each of them, complain and allege es

follows:

GENERAL ALLEGATIONS,

1. The true names and/or capacities, whether individual, corporate, associate,
governmental, or otherwise, of Defendants, DOES 1 through 300, inclusive, are unknown
to Plaintiffs at this time; who, therefore, sue ssid Defendants by such fictitious names; and
when the true names and capacities of said Defendants have been ascertained, Plaintiffs will
amend this complaint accordingly. Plaintiffs are informed and believe, and thereon altege
that each Defendant designated herein as a DOE is responsible, negligently or in some
other actionable manner, for the events and happenings hercinafter referred to, and caused
injuries and damages proximately thereby to Plaintifls, as hereinafter alleged, ether through
said Defendant's own conduct or through the conduct of its agents, servants or employees,
or due to the ownership, lease or sale ofthe instrumentality causing the injury, or in some

other manner.

ee

FLAINTIFFS" ORIGINAL AZBEETOS COMPLINT

‘CADsauments and Setingecanniacal SstingTemporsy IlamctFiesOLIC2AIBOUOREAUK.C.nped (S34) any 11,2007 )2, Plaintiffs are informed and believe, and thereon allege that at all times
mentioned herein, Defendants and each of them, were the agents, servants, employees
and/or joint venturers of their co-Defendants and were, as such, acting within the scope,
course, and authority of said ageacy, employment and/or joint venture, in that each and
every Defendant, as aforesaid, when acting as a principal, wes negligent in the selection and
hiring or cach and every other Defendant as the agent, servant, employee and/or joint
ventures,

3. Plaintiff CHARLES BOUDREAUX was (and is now) a California resident
during a substantial period of his asbestos exposure upon which Plaintiffs’ claims are based

4. Plaintiffs are informed and beliove, and thereon allege, that at all times
mentioned herein, Defendants ADVOCATE, MINES, LTD.; ALLIS-CHALMERS
CORPORATION PRODUCT LIABILITY TRUST, BORGWARNER MORSE TEC,
INC,, individually and as successor-in-interest to Borg-Warner Corporation;
BORGWARNER, INC,, individually and us successor-in-interest to Borg-Warner
‘Conporation; BUFFALO PUMPS, INC.; CBS CORPORATION, fik/a Viacom, Inc.
{(successor-by-merger to CBS Corporation, successor-by-merger to Westinghouse Electric
Corporation); CRANE CO.; CSK AUTO, INC. (individually and d/bia "Checker Auto
Paris", "Shuck’s Auto Supply,” and “Kragen Auto Parts"); CSR, LTD., (@k/e Colosial
Sugar Refining Company); DAIMLERCHRYSLER CORPORATION (Wi/a Chrysler
Corporation); FLOWSERVE CORPORATION, individually and as successor-in-interest
to Darco Intemational, Inc, fk/a The Duriran Company, Ine.; FORD MOTOR
COMPANY; FOSTER WHEELER ENERGY CORPORATION; GARLOCK SEALING
TECHNOLOGIES, LLC. (individually and as successor-in-interest 10 Garlock, Inc.);
GENERAL ELECTRIC COMPANY; GENERAL MOTORS CORPORATION;
GEORGIA-PACIFIC CORPORATION, individually and as successor-in-interest to
Bestwall Gypsum Company; HANSON PERMANENTE CEMENT, INC., (fk/a Keiser
‘Cement Corporation, individually and as successor-in-interest to Kaiser Gypsum Company,
Inc.}; HONEYWELL INTERNATIONAL, INC. (individually and as successor-in-interest

BLAINTIFES' GROWL ABSESTOS CONPLATT
‘ADecumants and SetiegecardoinLocal Setings Torpaary Inert Hac!OLKPAWBOUOREAUX C.wpd (SEL) (anuary 14,007)wa on

to Allied-Signal, Inc. and The Bendix Corporation); IMO INDUSTRIES, INC.
(individually and as successor-in-interest to DeLaval Turbine, Inc.); INGERSOLL-RAND-
COMPANY; KAISER GYPSUM COMPANY, INC, PLANT INSULATION
COMPANY, FORMERLY ASBESTOS COMPANY OF CA; RINKER MATERIALS:
CORPORATION, ffk/a CSR America, Inc,; SEPCO CORPORATION; THE PEP BOYS.
MANNY MOE & JACK OF CALIFORNIA; THORPE INSULATION COMPANY;
UNTON CARBIDE CORPORATION and DOES 1 through 300, inclusive, are
corporations organized and existing under and by virtue of the laws of the State of
California, or the laws of some other state of the United States of America, or some
foreign jurisdiction, and that said Defendants were authorized to do and are doing business
in the State of California, and that said Defendants have regularly conducted business in the
‘State of California

5. At all times mentioned above, Defendants, and each of them, were engaged in
‘the business of manufacturing; fabricating, designing, assembling, distributing, leasing,
buying, selling, inspecting, servicing, instalting, repairing, marketing, wercanting, and
advertising a certain substance, the generic name of which is asbestos, and other products
containing said substance,

6. Plaintiff CHARLES BOUDREAUX was exposed to Defendants’ asbestos
and asbestos containing products contributing to and causing the development of
mesothelioma. A listing of Defendants’ asbestos and asbestos-containing products alleged
at this time to have caused Plaintiff's injuries are provided on the Work: History Sheet.
attached as Exhibit "A." As a result of exposure to Defendants’ asbestos and asbestos
containing products, asbestos Sbers entered his body, Plaintiff suffers from mesothelioma
and each of Defendants asbestos and asbestos containing products that eatered his body
‘was a substantial factor in bringing about, prolonging, or aggravating Plaintiff's
mesothelioma, The asbestos and asbestos containing products Plaintiff was exposed to
were manufactured or supplied by a named defendant

DPLRINTERS ORIGINAL ASBESTOS COMPUT
(SiDocumoits and Saltingsentsnlocal SethgsiTemporry bnevat FRes\OLK7AWECUDREAUK Cp (ORS) (lnaary 11, 2007)HIRST CAUSE OF ACTION
Negligence)
‘(Against all Defendants)

7. Plaintiffs hereby incorporate by reference, 2s though fillly set forth hereia,
each and every allegation contained in the General Allegations above.

8. At all times herein mentioned, each of the named Defendaats and DOES 1
throiigh 300 was the successor, successor in business, successor in product line or a
portion thereof, assign, predecessor, predecessor in business, predecessor in product line or
4 portion thereof, parent, subsidiary, wholly or partially owed by, or the whole or partial
‘owner of or member in an entity researching, studying, manufacturing, fabricating,
designing, modifying, labeling, assembling, distributing, leasing, buyiag, offering for sale,
supplying, selling, inspecting, servicing, installing, contracting for installation, repairing,
rmarketing, warranting, re-braading, manufacturing for otkers, packaging and advertising as
certain product, namely asbestos, and other products containing asbestos. Said entities
shall hercinafter collectively be called “Alternate Entities." Each of the herein named
‘Defendants is liable for the tortious conduct of each successor, successor in business,
surecessorn product fine ora portion thereof, assign, predecessor in product line or a
portion thereof, parent, subsidiary, whole or partial owner, or wholly or partially owned
‘entity, or entity that it was a member of, or funded, that researched, studied, manufactured,
fabricated, designed, modified, labeled, assembled, distributed, leased, bought, offered for
sale, supplied, sold, inspected, serviced, installed, contracted for installation, repaired,
marketed, warranted, re-branded, manufactured for others and advertised a certain
product, namely asbestos, and other products containing asbestos: ‘The following
Defendants, and each of them, are liable for the acts of eack and every "Alternate Entity,"
and each of them, in that there bas been a virtual destruction of Plaintiff's remedy against
each such "Alternate Entity," Defendants, and each of them, have acquired the assets,
product line, or 8 portion thereof, of each such "Alternate Entity,” sich "Alternate Eatity,”
Defendants, and each of them, caused the destruction of Plaintiff's remedy against each

BUARTIEFS ORIGINAL ASBESTOS COMPLANT
‘OxDocumens ond SetingsicancsLcal SeegsSTemporay Inlamat FlbslOLX2A\BOUGREAUK.G 6 (SGM) (January 11,2007 )such "Altemate Entity," each such Defendant has the ability to assurue the risk-spreading,

tole of each such "Altemate Entity," and that each such Defendant enjoys the goodwill
originally attached to each such “Alternate Entity."

DEFENDANT ALTE) EI
ADVOCATE MINES, LTD
ALLIS-CHALMERS CORPORATION
PRODUCT LIABILITY TRUST
BORGWARNER MORSE TEC, INC. | BORG-WARNER CORPORATION _

BORGWARNER, INC. BORG-WARNER CORPORATION

BUFFALO PUMPS, INC.

‘CRS CORPORATION WESTINGHOUSE ELECTRIC
CORPORATION

CRANE CO.

SK AUTO, INC CHECKER AUTO PARTS, SHUCK'S
AUTO SUPPLY, and KRAGEN AUTO
PARTS

CSR, LT COLONIAL SUGAR REFINING
COMPANY

DATMLERCHRY! CBRYSLER CORPORATION

CORPORATION

FLOWSERVE CORPORATION DURCO INTERNATIONAL, INC,
THE DURIRON COMPANY, INC.

FORD MOTOR COMPANY

FOSTER WHEELER ENERGY

CORPORATION.

GARLOCK SEALING GARLOCK, INC.

TECHNOLOGIES, LLC.

GENERAL ELECTRIC COMPANY

GENERAL MOTORS

CORPORATION

GEORGIA-PACIFIC CORPORATION _| BESTWALL GYPSUM COMPANY

HANSON PERMANENTE CEMENT, | KAISER GYPSUM COMPANY, INC.

HONEYWELL INTERNATIONAL, | THE BENDIX CORPORATION

IMO INDUSTRIES, INC.

DELAVAL TURBINE, INC.

‘BLAINTIERS ORIGHAL ASBESTOS COPLANT

(CADeouments and SetirgscardsLocal Stings Temporary Inmet Fles\OLK2A\SOUOREAUX Cp (SGM) (ney 11,2007 }

Poeaan een

DERENDANT ALTERNA’
INGERSOLL-RAND COMPANY
KAISER GYPSUM COMPANY, INC.
PLANT INSULATION COMPANY __| ASBESTOS COMPANY OF CA
ALS CSR AMERICA, INC.

‘RINKER MATERL
CORPORATION
SEPCO CORPORATION

‘THE PEP BOYS MANNY MOE &
JACK OF CALIFORNIA

THORPE INSULATION COMPANY
UNION CARBIDE CORPORATION

9. Defendants had duty to use reasonable care in manufacturing their products
and to war the customer, user, or bystander that their products were dangerous and
‘unsafe. At all times meitioned herein, Defendants, and each of them, negligently and
carclessly researched, tested, mianufactured, écsigned, developed, distributed, labeled,
advertised, marketed, warranted, inspected, repaired, fabricated, modified, serviced, and
sold @ certain substance, the generic name of which is asbestos, and other products
containing ssid substance, in that said substance wes capable of causing and did, in fact,
proximately cause persoudl injuries to users and consumers thereof while being used in
meaner reasonably foreseeable, thereby rendering said substance unsafe and dangerous for
use by the consumer, users, or bystanders thereof, and others to whom Defendants owe a
duty, including Plaintiff CHARLES BOUDREAUX.

10, Plaintiff CHARLES BOUDREAUX is a worker who, for a substantial length
of time, has used, handled, and been otherwise exposed to the asbestos and asbestos
products referred to in Paragraph 6 above, in a manner that was reasonably foresecable,
while he was working.

11, Plaintiff CHARLES BOUDREAUX would show that for a period of many
years, he/she was exposed to asbestos-containing products and/or machinery produced,
sold, or supplied by Defendants requiring or valling for the use of asbestos and/or asbestos-

TANTIFES ORIGINAL ASBESTOS COMPLART
‘CADscumants and Sefingsiaréi cal SeingsTempory ntanet FlasOLK2A\SOUDREAUK Cope (SGM) (Hnusy 11, 2007)containing products in the household setting as w result of Plaintiff CHARLES
BOUDREAUX's father, CHARLES JOSEPH BOUDREAUX working in various
industrial plants, manufacturing plants, commercial buildings, residential units, and/or other
facitities in the state of California, Further, Plaintiff CHARLES BOUDREAUX inhaled
great quantities of asbestos fibers from said products and/or machinery and suffered
injuries proximacely caused by his/her exposure to asbestos-containing products designed,
manufactured, and/or sold by Defendants.

12, Plaintiff CHARLES BOUDREAUX alleges that he/she was exposed to
asbestos fibers and dust emianatiag from the work clothing, body, and hair of Plaintiff’
‘CHARLES BOUDREAUX's father, CHARLES JOSEPH BOUDREAUX which
originated from the asbestos-containing products and/or machinery requiring or calling for
the use of asbestos and/or asbestos-containing products manufactured, sold, and/or
distributed by Defendants, Plaintiff CHARLES BOUDREAUX was exposed to asbestos
and dust fibers brought home by Plaintiff CHARLES BOUDREAUN's father, CHARLES
JOSEPH BOUDREAUX in the normal course of performing household activities, such as
shaking out and laundering work clothing, In that each exposure to such products caused
oor contributed to Plaintiff CHARLES BOUDREAUX's injuries, Plaintiff alleges thal (he
doctrine of joint and several liability should be extended to apply to each Defendant herein,

13, Ase direct and proximate result of the above-referenced conduct of the
Defendants, and each of them, as aforesaid, said exposure to said asbestos caused severe
and permanent injury to Plaintifs hings and body, including, but not limited to the disease
mesothelioma.

14. On or about September 7, 2606, Plaintiff CHARLES BOUDREAUX was
advised that he has the asbestos-related disease, mesothelioma. Prior to that date, Plaintiff
did not know, nor did he have reason to know, that he had contracted this disease related
to his exposure to asbestos. Prior to said date, Plaintiff was not aware that exposure to

asbestos presented any risk of injury and/or disease to him, and had not been advised or

-BAINTIFES' ORIGINAL ASHESTOS COMPLAINT
‘Cobscumes and Seeger eel SetegsCTempray lla ls} OLXIAIBOUDREAUX Compa (SG) (anuary 14,207)informed by anyone that he could contract, nor indeed did contract, any disease, sickness
or injury as a result of working in the vicinity of esbestos.

15, Plaintiffs informed and believes, and thereupon alleges, thit mesothelioma is
2 vicious, painfil and invariably fatal malignancy of the lining of the lung, stomach, of heart
and that said disease results from exposure-to asbestos and asbestos products over o period
oftime, There is no known cure for any form of malignant mesothelioma

16, Asa direot and proximate result of the aforesaid conduct of the Defendants,
and each of them, Plaintiff has suffered, and continues to suffer, severe and permanent
injuries to his person, body and health, including, but not limited to, the disease
mesotheliome, all to his general damage in a sum within the jurisdictional dats of this
court

17, Asadirect and proximate result of the aforesaid conduct of the Defendants,
and each of them, Plaintitf was compelled to and did employ the services of hospitals,
sinrgeons, physicians, murses, and the like, to care for and treat him, and did iacur medical,
hospital and professional incidental expenses, and Plaintiffs informed and believes and.
‘thereupon alleges that by reason of said Plaintiff's injuries, he will necessarily incur
additional like expenses for an indefinite period of time in the future, and when said
amounts are ascertained, he will allege said arnonnts.

18. The above-referenced conduct of said Defendant was and is willful, malicious,
‘outrageous and/or in conscious disregard and indifference to the safety of users of said
asbestos and asbestos products, including Plaintiff, Defendant is guilty of oppression,
fraud, or malice and engaged in conduct which was intended by the defendant to cause
ajury to the plaintiff or conduct which was cartied on by the defendant with a conscious
disregard of the rights or safety of others. Defendant subjected Plaintiff to cruel and unjust
hardship in conscious disregard of his rights and engaged in intentional misrepresentation,
deceit, or concealment of a material fact know to the defendant with the intention on the
part of the defendant of thereby depriving Plaintiff of property or legal rights or otherwise

BLAIITIFFS' ORIGINAL ASBESTOS COMPLAINT
‘CADovaments and Setngirerdi.ocl SetingsemporkyInamet FisslOLK2A\SOUOREAUK.Canp (SGM) (Janus 11, 2007)causing injury. Plaintiff therefore, for the sake of example and by way of punishing
Defendant, seeks punitive damages, according ta proof.

19, Plaintiffs further allege all of the foregoing portions of this cause of action
specifically against those Defendants who supplied asbestos fibers (as pled against those
Defendants who manufactured asbestos products), who are listed on Exhibit "B” attached,
and any other asbestos fiber supplier or distributor to manufacturers of the asbestos-
containing products to which Pleintiff was exposed, as well as any DOE Defendants who
may be determined at a later date.

SECOND CAUSE OF ACTION
(Strict Liahitity)
(Against all Defendants)

20. Plaintiffs liereby incorporate by reference, as though fully set forth herein,
‘each and every allegation contained in the First Cause of Action

21. At all timés mentioned herein, Defendants, and cach of them, researched,
manvfactured, tested, designed, labeled, distributed, advertised, marketed, warranted,
inspected, repaired, offered for sale, and sold a certain substance, the generic name of
which is asbestos, and other products containing said substance which Defendants knew
‘were to be used without inspection for defects and which substance contained design and
manufacturing defects, in that same was capable of cunsing and did, in fact, cause personal
injuries to the users, consumers, and bystanders while being used in a reasonably
foreseeable manner, thereby rendering same unsafe and dangerous for use by the
consumers, users, and bystanders.

22, Asa direct and proximate result of the above described conduct by
Defendants and esch of them, Pisintiff CHARLES BOUDREAUX suffered severe and
permanent injuries to his person, as alleged hereinabove.

23, At all times mentioned herein, the asbestos and products containing said
substance discussed ahove failed to perform as safely as an ordinary consumer would
expect when used in an intended or reasonably foreseeable manner, and the risk of danger

‘BURINTIFES' ORIGINAL ASBESTOS COMPLANT
‘0iDocamerts and Setngsieardin eal etingst Tero lnteret FiccIORKZAIBOUDREAUK.Cawpd (SGM) amany 11,2007 )THIRD CAUSE OF ACTION
(False Representation Under Restatement of Torts Section 402-B)
(Against All Defendants)

28. Plaintiffs hereby incorporate by reference, as though firly set forth herein,
each and every allegation contained in the First through Second Causes of Action.

29, At the aforementioned time when Defendants, their “Akemate Entities," and
each of them, researched, manufactured, fabricated, designed, modified, tested or failed to
test, inadequately warned or failed to warn, labeled, assembled, distributed, leased, bought,
offered for sate, supplied, sold, inspected, serviced, installed, contracted for installation,
ropeired, marketed, warranted, rebranded, manufactured for others, packaged and
advortised the said asbestos and asbesios-containing products, as herein above set forth,
the Defendants, théir "Alternate Entities," and each of them, expressly and impliedly
represented to members of the general public, including the purchasers and users of suid
product, and other “exposed persons," including the Plaintiff herein and his employers, that
asbestos and asbestos-containing products, were of merchantable quality, and safe for the
use for which they were intended.

30. The purchasers and users of said asbestos and asbestos-containing products,
and other "exposed persons," including the Ptaintiff and his employers, relied upon said
representations of Defendants, their “Altemate Enlilies,"and each of them, in the selection,
purchase and use of asbestos and asbestos-containing products,

31, Said representations by Defendants, their "Alternate Entities," and each of
them, were false and untrue, and Deferidants knew at the time they were uatrue, in that the
asbestos and asbestos-containing products were not safe for their intended use, nor were
they of merchantable quality as represented by Defendants, their “Alternate Entities,” and
cach of them, in that asbestos znd asbestos-containing products have very dangerous
properties and defects whereby said products cause asbestosis, other lung damages and
cancer, and have other defects that cause injury and damage to the users of said products

PLAINTIFFS ORIGINAL AZGESTOS COUBLANT Page 17
‘eXDovaments end Setngcarder aa SetngetTemporry nk Flss\OLKZNBOUOREAUK.C apt (SGM) (Janany 1, 2007)and other “exposed persons," thereby threatening the health and life of said persons
including Plaintiff hereia
32, Asa direct and proximate result of said false representations by Defendants,
their "Alternate Entities," and each of them, thé Plainti8iS sustained the iajuries and
damages herein above set forth
33. The above-referenced conduct of said Defeadant was and is willful, malicious,
outrageous and/or in conscious disregard and indifference to the safety of users of said
asbestos and asbestos products, including Plaintif, Defendant is guilty of oppression,
fraud, or malice and engaged in conduct which was intended by the defendant to cause
injury to the plaintiff or conduct which was carried on by the defendant with a conscious
isregard of the rights or safoty of others, Defendant subjected Plaintiff'to cruel and uajust
hardship in conscious disregard of his rights and engaged in intentiovial misrepresentation,
deceit, or concealment of a material fact known to the defendant with the intention on the
part of the defendant of thereby depriving Plaistff of property or legal rights or otherwise
causing injury. Plaintiff therefore, for the sake of exemple and by way of punishing
Defendant, socks punitive damages, according to proof
34, Plaintiffs further allege all of the foregoing portions of this cause of action
specifically against those Defendants who supplied asbestos fibers (as pled against those
Defendants who manufactured asbestos products), who ere listed on Exhibit "B" attached,
and any other asbestos fiber supplier or distributor to manufacturers of the asbestos-
containing products to which Plaintiff was exposed, as well as any DOE Defendants who
may be determined at a later date.
ORT At
(intentional Tort)
(Against All Defendants)
35. Plaintiffs, hereby incorporate by reference, as though fully set forth herein,
each and every allegation contained in the First through Third Causes of Action.

BLARTTIFFS ORIGINAL ASBESTOS COMPLAINT Pegs
‘CABecuments and SetingscardllL oes SitingsTomperayIlunatFlas\OLKZAIEOUOREAUX Cupid (SGM (Seruary 12,2007)oe san aen

36. At all times pertinent hereto, the Defendants, their "Alternate Entities," and
each of them, owed Plaintiff a duty, as provided for in Section 1708, 1709 and 1710 of the
Civil Code of the State of California, to abstain ftom injuring the person, property or rights
of the Plaintiff. When « duty to act was imposed, as set forth herein, the Defendants, their
“Alternate Entities,” and each of them, did do the acts and omissions in violation of that
duty, ‘thereby causing injury to the Plaintiff as is more fully set forth herein. Such acts and
omissions consisted of acs falling within Section 1709 (Deceit) and Section 1710 (Fraud)
and more specifically, included suggestions of fact which were not true and which
Defendants, their “Alternate Entitis,".and each of them,