Answer: JAMES JORDAN VS. ASBESTOS DEFENDANTS (BHC)

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Mar-21-2003 11:24 am

Case Number: CGC-01-402113
Filing Date: Mar-17-2003 11:23
Juke Box: 001 Image: 00645092
ANSWER

JAMES JORDAN VS. ASBESTOS DEFENDANTS (BHC)

001000645092

Instructions:
Please place this sheet on top of the document to be scanned.Becherer
Kannett &
Schweitzer

2200

Powell St
‘Suite 805
Emeryville, CA
94608
510-658-3600

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_ ORIGINAL

SHEILA DOYLE KELLEY (SBN 121423)
BECHERER, KANNETT & SCHWEITZER
2200 Powell Street, Suite 805

Emeryville, California 94608

Telephone: (510) 658-3600

Facsimile: (510) 658-1151

Attorneys for Defendant
AMERICAN HONDA MOTOR Co., INC.

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

JAMES JORDAN, CASE NO. 402113
(Unlimited Civil Division)
Plaintiff,
vs. DEFENDANT AMERICAN HONDA MOTOR
CO., INC.’S ANSWER TO PLAINTIFF’S
ASBESTOS DEFENDANTS (BHC) UNVERIFIED COMPLAINT FOR PERSONAL
As Reflected on Exhibits B, B-1, C, F, INJURY - ASBESTOS

and H; and DOES 1-800.

GENERAL DENIAL

Defendant American Honda Motor Co., Inc. (“Defendant”), answering solely on its
own behalf and for no other person or entity, responds to Plaintiffs Complaint for Damages
on file herein as follows:

Pursuant to the provisions of section 431.30(d) of the Code of Civil Procedure of the
State of California, Defendant denies each, every and all of the allegations of said Complaint
and the whole thereof, including each and every purported cause of action contained therein.

Further, Defendant denies that Plaintiff sustained any injury, damage or loss, by
reason of any act, omission or negligence on the part of Defendant. And, Defendant

specifically denies any liability or fault whatsoever with respect to the matters complained of
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DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF’S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOS.Becherer
Kannett &
Schweitzer

2200
Powell St.
Suite 805
Emeryville, CA
94608
510-658-3600

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in Plaintiff's Complaint.
AFFIRMATIVE DEFENSES
Failure to State a Cause of Action

Plaintiff's Complaint fails to state sufficient facts to constitute a cause of action upon

which relief may be granted against this answering Defendant.
Statute of Limitations

On information and belief, Defendant alleges that Plaintiff's Complaint and each
purported cause of action therein is barred by the applicable statute of limitations provision of
the Code of Civil Procedure of the State of California, and/or of other statutes of the State of
California and/or the statutes of the states in which Plaintiff resided at the time the causes of
action alleged in the Complaint arose, including without limitation, Code of Civil Procedure
sections 337, 338, 339, 340, 340.2, 343, 353.1,361 and/or 474, and California Commercial
Code section 2725.

Further, on information and belief, Defendant alleges that Plaintiff's Complaint and
each purported cause of action therein is barred by the applicable statute of limitations of the
State or states where Plaintiff was residing at the time of alleged exposure and/or injury
and/or at the time the causes of action alleged in Plaintiff's Complaint arose.

Assumption of the Risk

On information and belief, Defendant alleges that Plaintiff voluntarily, knowingly, and
unreasonably entered into and engaged in the operations and conduct alleged in Plaintiff's
Complaint and voluntarily and knowingly assumed the alleged risks incident to said
Operations, acts and conduct at the time and places alleged in Plaintiff's Complaint.

Failure to Follow Warnings

On information and belief, Defendant alleges that Plaintiff was advised, informed,
and warned of any potential hazards and/or dangers, if any there were, associated with the
normal and foreseeable use, handling, and storage of the products, substances, and

equipment described in Plaintiff's Complaint, and Plaintiff failed to follow such warnings.

-2-

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF'S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSBecherer
Kannett &
Schweitzer

2200
Powell St.
Suite 805
Emerwille, CA
94608
510-658-3600

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Comparative Negligence

On information and belief, Defendant alleges that Plaintiff was entirely at fault in and
about the matters set forth in Plaintiff's Complaint and entirely and solely failed to exercise
ordinary care, which negligence and carelessness on Plaintiff's part proximately caused the
injuries, loss and damages complained of, if any there were. In the event of any judgment or
verdict in favor of Plaintiff, said judgment or verdict must be reduced to the extent that said
negligence and carelessness of Plaintiff caused or contributed to the injuries and damages
allegedly sustained by Plaintiff, if any there were.

Conduct of Others

The losses and damages alleged in Plaintiff's Complaint, if any there were, were
proximately caused by the negligent acts, omissions, and/or fault of persons or entities other
than this answering Defendant, and no damages of Plaintiff were caused by any acts or
omissions or fault of this answering Defendant.

Willful Misconduct

On information and belief, Defendant alleges that Plaintiff was guilty of willful
misconduct which proximately caused or contributed to the occurrences complained of in
Plaintiff's Complaint and the damages alleged to have been suffered therein, and Plaintiff is
therefore precluded from comparing such conduct with the alleged negligence or fault of this
Defendant, if any there was.

Proposition 51

Defendant alleges that California Civil Code §§ 1431.1 through 1431.5, known as the
Fair Responsibility Act of 1986, is applicable to the present action and to certain claims
therein, and based upon principles of comparative fault, the liability, if any, of Defendant for
non-economic damages shall be several and not joint.

Ratification and Consent

On information and belief, Defendant alleges that at all times mentioned in Plaintiff's

Complaint, Plaintiff acknowledged, ratified, consented to, and acquiesced in the alleged acts

or omissions, if any , of this Defendant, thereby barring Plaintiff from any relief as prayed for

3.
See

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF’S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOS1} herein.
Modification/Alteration of Product
On information and belief, Defendant alleges that after they left the custody and

control of Defendant, the products which allegedly injured Plaintiff were altered, changed, or

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5 || otherwise modified by parties, individuals, or entities other than Defendant, and said

6 || modifications, changes, alternations were a proximate cause of the damages alleged by

7 || Plaintiff, if any there were.

8 Misuse and Abuse

9 Prior to and at the time of the alleged injuries to Plaintiff, the products which allegedly
10 |] caused or contributed to said injuries were misused and abused, and were not being used in
11 | a manner in which they were intended to be used. Such misuse and abuse caused and/or
12 || contributed to the loss, injury or damages, if any, incurred by Plaintiff.

13 Spoliation of Evidence

14 On information and belief, Defendant alleges Plaintiff and/or Plaintiff's agents

15 || negligently or intentionally failed to preserve and permitted the spoliation of material

16 || evidence including but not limited to the products which Plaintiff alleges give rise to Plaintiff's
17 || Complaint. Such conduct bars Plaintiff's action and/or gives rise to liability on the part of

18 }) Plaintiff for damages payable to this Defendant.

19 No/De Minimis Exposure

20 Plaintiff was not exposed to or injured by any product distributed by this Defendant,
21 || and even if Plaintiff was, which Defendant denies, such exposure was so minimal to be

22 || insufficient to cause the injury, damage or loss complained of by Plaintiff's and such

23 || exposure, if any, could not have been a substantial factor in causing the injury, damage or

24 || loss complained of by Plaintiff, barring any liability on the part of Defendant to Plaintiff.

Becherer .
Kannett & 25 Failure to Mitigate
Schweitzer
mo 26 Plaintiff failed to exercise reasonable care and diligence to mitigate his injuries,
Powell St
sue 8 ca 27 || losses, and damages, if any, and, therefore, is barred from recovering any damages which
merywille,

$10:856-3600 28 || could have been avoided by reasonable mitigation efforts.

4.

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DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF'S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSBecherer
Kannett &
Schweitzer

2200
Powell St.
Suite 805
Emeryville, CA
94608
510-658-3600

25

Inadequate Notice

Plaintiff failed to give reasonable, timely, sufficient and adequate notice to this

Defendant of the alleged liability, damage or injury, if any.
Laches

Plaintiff has unreasonably delayed in the bringing of this action and serving it on
Defendant, without good cause therefor. Further, Plaintiff failed to serve on Defendant any
order allowing his late amendment to name Defendant as Doe 2. Said delay has directly
resulted in prejudice to this Defendant, and, therefore, this action is both barred by the
Doctrine of Laches, and subject to dismissal.

Unclean Hands

Plaintiff is precluded from maintaining this action, or any cause stated therein as
against Defendant because Plaintiff's actions preclude equitable relief under the doctrine of
Unclean Hands.

Workers’ Compensation Exclusive Remedy/Set-Off

The Court lacks subject matter jurisdiction over the matters alleged in Plaintiff's
Complaint because said Complaint is barred by the exclusive remedy provisions of the
California Labor Code, section 3601, et seq. Further, at the time of the injuries alleged in
Plaintiff's Complaint, Plaintiff was employed and was entitled to receive workers’
compensation benefits from his employers; that all of Plaintiff's employers were negligent in
and about the matters referred to in Plaintiff's Complaint; that such negligence on the part of
said employers proximately and concurrently contributed to the happening of the accident
and to the loss or damage complained of by Plaintiff, if any there were; and that by reason
thereof, this answering Defendant is entitled to set-off any such benefits received or to be
received by Plaintiff against any judgment witch may be rendered in favor of Plaintiff.

Sophisticated Employer’s Negligence - Superceding Cause

The loss, injury or damage, if any, incurred by Plaintiff was the result of superseding,

intervening causes arising from negligent or willful acts or omissions by parties Defendant

neither controlled nor had the right to control, and were not proximately caused by any acts,
5-
SSS

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF'S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSBecherer
Kannett &
Schweitzer

2200
Powell St
Suite 805
Emeryville, CA
94608
510-658-3600

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omissions or other conduct of Defendant. In particular, Plaintiff's employer or employers by
reason of advice, information, warnings, and use, handling, and storage information given to
them, and by reason of their own long-standing and continuous experience with the
products, substances, and equipment referred to in Plaintiff's Complaint, are and were
sophisticated users, handlers, and storers of any and all such products, substances, and
equipment and thereby acquired a separate and affirmative duty to provide the products to
employees in a non-negligent and non-reckless manner, and said employers acquired an
affirmative duty to warn, advise, and inform Plaintiff of any potential harmful effects from the
mishandling, improper storage, and/or misuse of the subject product, if any. Said employer's
failure to provide and/or warn was a superseding and intervening cause of Plaintiff's injuries,
losses, and damages, if any there were.
Unconstitutionality of Defect Standards

The State of California’s judicially created definitions of “manufacturing” and “design
defects” and the standards for determining whether there has been an actionable failure to
warn are unconstitutional in that, among other things, they are void for vagueness and place
an undue burden upon interstate commerce, as well as constitute an impermissible effort to
regulate in an area that has previously been preempted by the federal government.

No Market Share/Enterprise Liability

To the extent that plaintiffs’ Complaint attempts to assert this Defendant’s “market
share” liability or “enterprise” liability, Plaintiff's Complaint fails to state facts sufficient to
constitute a cause of action against Defendant as such theory of liability is not applicable to
friction products in that such products are not fungible. Further, Plaintiff has failed to join as
defendants in this action the producers of a substantial market share of the product or
products which allegedly injured Plaintiff.

State of The Art

The state of the medical, scientific, and industrial knowledge and practices was at all

material times such that this Defendant neither breached any alleged duty owed to Plaintiff,

nor knew, or could have known, that the product(s) it allegedly distributed presented a
-6-
SSS

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF'S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSBecherer
Kannett &
Schweitzer

2200
Powell St.
Suite 805
Emeryville, CA
94608
510-658-3600

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foreseeable risk of harm to Plaintiff in the normal and expected use of such product(s).
Defendant's products, if any, were manufactured, produced, supplied, sold and distributed in
conformity with and pursuant to statutes, government regulations and industry standards
based upon the state of knowledge existing at the time of said, manufacture, production,
sale, or distribution.
Contributory Negligence/Conduct of Others
The sole proximate and/or partial proximate cause of the injuries, losses, or damages
claimed by Plaintiff was due to the fault, negligence, and/or strict liability of other defendants
and/or other unnamed persons, firms, or entities. In the event that Defendant is held liable to
Plaintiff, which liability is expressly denied, and any other co-defendants are likewise held
liable, Defendant is entitled to contribution of the total liability from said co-defendants in
accordance with the principles of equitable indemnity and comparative contribution. Further,
Defendant is entitled to a reduction in any verdict or judgment in accordance with California
Civil Code, section 1431.2.
Unconstitutionality of Punitive Damages

The imposition of any punitive damages in this matter would deprive Defendant of its
property without due process of law under the California Constitution and the United States
Constitution. Further, the imposition of punitive damages in this matter would violate
Defendant's right to protection from “excessive fines” as provided in the Eighth Amendment
of the United States Constitution and Article |, section 17 of the California State Constitution.

Violation of Commerce Clause

The Commerce Clause of the United States Constitution (U.S. Const. Art. I, section
8, clause 3) precludes the application of a state statute to commerce that takes place wholly
outside of a state’s borders, whether or not the commerce has effects within the state; and
protects against inconsistent verdicts and legislation arising from the projection of one state
regulatory scheme into the jurisdiction of another state.

Failure to State Sufficient Facts to Support Punitive Damages
Neither the Complaint nor any purported cause of action alleged therein states facts

7
ee

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF’S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSsufficient to entitle Plaintiff to an award of punitive damages against Defendant.

_

2 Other Affirmative Defenses
3 Defendant reserves the right to allege other affirmative defenses as they may
4 || become known during the course of discovery, and hereby specifically reserves the right to
5 || amend its answer to allege said affirmative defenses at such time as they become known.
6 WHEREFORE, Defendant prays:
7 1. That the Plaintiff take nothing by reason of his Complaint entirety;
8 2. For judgment in favor of Defendant and against Plaintiff on each and every
9 |] cause of action of Plaintiff's Complaint:
10 3. That Defendant be awarded its costs of suit, including its attorneys’ fees;
11 4. That Defendant be granted appropriate credits and set-offs arising out of any
2 payment of workers’ compensation benefits and settlements as alleged
3 above; and,
14 5. For such other and further relief as the Court may deem proper.
15
6 || DATED: March 14 , 2003 BECHERER KANNETT & SCHWEITZER
17 .
18 py, Oth Aly.
Sheila Doyle Kelley
9 Attorneys for Defendant

AMERICAN HONDA MOTOR Co., INC.

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Becherer
Kannett& 25
Schweitzer
——— _ 26
2200
Sure 808 27
Emeryville, CA,
siosss-e0 28

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ee

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’S ANSWER TO PLAINTIFF'S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY - ASBESTOSBecherer
Kannett &
Schweitzer

2200

Powell St.
‘Suite 805
Emeryville, CA
94608
510-658-3600

oOo ON OO FF WO DY =

PROOF OF SERVICE

|, the undersigned, 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 2200 Powell Street, Suite 805, Emeryville, California 94608.
On the date set forth below, | caused to be served the foregoing document(s):

DEFENDANT AMERICAN HONDA MOTOR CO., INC.’s ANSWER TO PLAINTIFF’S
UNVERIFIED COMPLAINT FOR PERSONAL INJURY-ASBESTOS; OBJECTION TO
DISCOVERY HEARING BEFORE COMMISSIONER; OBJECTION TO TRIAL BEFORE
COMMISSIONER ACTING AS JUDGE PRO TEMPORE

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:

David R. Donadio, Esq. SEE ALSO SERVICE LIST
Oren Noah, Esq. ATTACHED

Brayton + Purcell

222 Rush Landing Road

P. O. Box 6169

Novato, CA 94948-6169
T: 415-898-1555

F: 415-898-1247

Attys for Plaintiff

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.

f (By Mail) | deposited such envelope with postage thereon fully prepaid to be placed in

oa (By Personal Delivery) | caused such envelope to be delivered by hand to the office of
the addressee(s).

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

| declare under penalty of perjyry that the foregoing is true and correct and that this
declaration is executed on March Pp 20, at Emeryville, California.

Service List

James Jordan v. Asbestos Defs (BHC) et al. - SFSC #CGC-01-402113Becherer
Kannett &
Schweitzer

2200
Powell St
‘Suite 805
Emeryille, CA
94608
510-658-3600

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NO ON F WH A DOG AN DO BPW ND SB

28

SERVICE LIST

James Jordan v. Asbestos Defs (BHC) et al. - SFSC #CGC-01-402113

Brayton + Purcell Filice Brown Eassa McLeod
David R. Donadio Bruce E. McLeod

222 Rush Landing Road 1999 Harrison St., 18" Fl.
P. O. Box 6169 Oakland, CA 94612-3541

Novato, CA 94948-6169 T: 510-444-3131

T: 415-898-1555 Defs/The Dow Chemical Co;
F: 415-898-1247 Keenan Properties, Inc;
Attys for Plaintiff Tosco Refining Co.

Thelen Reid & Priest LLP
Karen A. Henry

Jennifer Kuenster

101 Second St., #1800

San Francisco, CA 94105

T: 415-371-1200
Defs/DaimlerChrysler Corp;
Ford Motor Co.

Becherer Kannett Schweitzer Adams Nye Siununu Walker

Mark S. Kannett 633 Battery St., 5" Fl.

Stephen M. Frayne San Francisco, CA 94111
2200 Powell St., #805 T: 415-982-8955

Emeryville, CA 94608

T: 510-658-3600 Defs/Oscar Erickson, Inc;

F: 510-658-1151 Taylor Plumbing Supply, Inc.

Defs/Bridgestone/Firestone
North American Tire, LLC;
Dillingham Construction NA,
Inc.

Morgenstein & Jubelirer LLP
One Market Plaza

Spear Street Tower, #3200
San Francisco, CA 94105

T: 415-901-8700

Defs/4520 Corp; General
Refractories Co; Dixon Boiler
Works, Inc.

Bishop Barry Howe et al. Keesal Young Logan
2000 Powell St., #1425 4 Embarcadero Ctr #1500
Emeryville, CA 94608 San Francisco, CA 94111

T: 510-596-0888

Def/Stuart Radiator Core Mfg
Co., Inc; D.W. Nicholson
Corp.

T: 415-398-6000
Def/Lear Siegler Diversified
Holdings Corp.

Burnham Brown
1901 Harrison St., #1100

Theodore T. Cordery
Imai Tadlock Keeney et al.

Fortune Dreviow et al.
560 Mission St., #2100
San Francisco, CA 94105
Def/Trimon, Inc.

Grace Genson Cosgrove et al.
444 So. Flower St., #1100

Los Angeles, CA 90071-2912
T: 213-533-5400
Def/General Motors Corp.

Oakland, CA 94612 185 Berry St., #4300
T: 510-444-6800 San Francisco, CA 94107
Def/Borg Warner, Inc. T: 415-537-3930

Def/Elliott Co.
Lombardo & Gilles PLC Jackson & Wallace LLP
318 Cayuga St. 55 Francisco St, #600
Salinas, CA 93901 San Francisco, CA 94133
T: 831-754-2444 T: 415-982-6300
Defs/Pneumo Abex Corp; Defs/The Budd Co; Scott Co.
Dow Chemical Co. of California; Crane Co;

Republic Supply Co; Zurn
Industries, Inc; Fluor Corp;
Robertson-Ceco Corp.

Misciagna & Colombatto Bennett Samuelsen et al.
130 Sutter St., #700 1951 Webster St., #200
San Francisco, CA 94104 Oakland, CA 94612-2940

Wilson Elser Moskowitz et al.
650 California St., #1400
San Francisco, CA 94108

T: 415-433-0990

Def/A.H. Voss Co.

Stevens Drummond Gifford
1910 Olympic Blvd., #250
Walnut Creek, CA 94596

T: 415-391-6182 T: 510-444-7688 T: 925-944-5550
Def/Metalclad Insulation Corp. | Defs/Dresser Industries, Inc; | Def/Pneuma Abex Corp.
Gatke Corp.

Service List

James Jordan v. Asbestos Defs (BHC) et al. - SFSC #CGC-01-402113Becherer
Kannett &
Schweitzer

(2200

Powell St.
Suite 805
Emeryville, CA
94608
510-658-3600

=

CoO ON OW HO FF WOW DY

Erickson Arbuthnot et al.
530 Water St., #720
Oakland, CA 94607

T: 510-832-7770
Def/Goodrich Corp.

Prindle Decker Amaro LLP
P. O. Box 22711

Long Beach, CA 90801-5511
T: 562-436-3946

Gordon & Rees LLP
275 Battery St., #2000
San Francisco, CA 94111
T: 415-986-5900
Def/Rosendahl Corp.

Knox Ricksen LLP
2101 Webster St, #650
Oakland, CA 94612-3069
T: 510-285-2500

Berry & Berry
2930 Lakeshore Ave.
Oakland, CA 94610

T: 510-835-8330

Def/Lear Siegler Diversified
Holdings Corp.

Def/Henry Vogt Machine Co.

Def/Abblummus Global, Inc.

Walsworth Franklin et al.
550 Montgomery St, #800
San Francisco, CA 94111
T: 415-781-7072
Def/X-C/Thomas Dee
Engineering Co.

McKenna Long Aldridge LLP
One Market Plaza

Steuart Street Tower

San Francisco, CA 94105

T: 415-267-4000
Def/Quigley Co., Inc.

Burke Williams Sorensen
611 W. Sixth St., #2500
Los Angeles, CA 90017-3102
T: 213-236-0600
Defs/Genuine Parts Co;
Viacom, Inc.

Sack Miller Rosendin LLP
One Kaiser Plaza #340
Oakland, CA 94612

T: 510-286-2200
Def/Parson Energy &
Chemicals Group, Inc.

Service List

Hardin Cook Loper et al.
1999 Harrison St., #1800
Oakland, CA 94612

T: 510-444-3131
Def/OakFabco, Inc.

McNamara Dodge Ney et al.
P. O. Box 5288

Walnut Creek, CA 94596

T: 925-39-5330
Defs/Babcock Borsig Power
Inc; FMC Corp-Turbo Pump
Operation

Drinker Biddle Reath
225 Bush St., #1500
San Francisco, CA 94104
T: 415-397-1730

Def/Monsanto Co.

Ropers Majeski Kohn et al.
333 Market St., #3150

San Francisco, CA 94105
T: 415-543-4800
Def/Grinnel Corp.

James Jordan v. Asbestos Defs (BHC) et al. - SFSC #CGC-01-402113