Free Complaint - District Court of California - California

Case 3:07-cv-04352-EMC

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Filed 08/23/2007

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EXHIBIT A

Decedent: Michael T. Carolan, deceased Decedent's injuries: Decedent was diagnosed with lung cancer on or about February 2006 and asbestosis on or about October 2006. Decedent died on September 2, 2006. Defendants: Plaintiffs contend that the asbestos-containing products to which Decedent was or may have been exposed to were manufactured, supplied, distributed, installed and/or contracted for by defendants and each of them. Decedent's exposure to asbestos occurred at the following times and places, and involved exposure to dust created by the contractors and the products of the entities listed below. The exposure includes, but is not limited, to the following presently known contractors and the manufacturers and distributors of asbestos-containing products: Location of Exposure The Boeing Co. Seattle, WA Exposure Dates 1968-1969

Employer The Boeing Co. Seattle, WA

Job Title Riveter

Job Duties: Decedent fabricated wings for BOEING 747s (powered by PRATT & WHITNEY JT9D engines). Decedent used a pneumatic hammer and rivet shaver. Decedent occasionally worked in close proximity to engine mechanics on "shakedowns." Decedent was unable to recall the names of any supervisors or co-workers. Plaintiff currently contends that decedent was exposed to asbestos during this employment. Location of Exposure Fort Ord, Monterey, CA U.S. Army, Germany Exposure Dates 1970 (8 weeks) 1970-1972

Employer U.S. Army

Job Title Trainee Clerk (Personnel Management Specialist)

U.S. Army, Fort Benjamin Harrison, Indianapolis, IN Job Duties: Decedent performed clerical work and assisted with job placement. Decedent occasionally walked through the basement at the barracks in Germany, where the boiler was
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EXHIBIT "A"

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located. Decedent was unable to recall the names of any supervisors or co-workers. Plaintiff is currently unaware if decedent was exposed to asbestos during this employment. Location of Exposure Comsystems, Long Beach, CA Exposure Dates 1973

Employer Comsystems Long Beach, CA

Job Title Draftsman

Job Duties: Decedent drafted plans for electrical parts and then assembled them. Decedent was unable to recall the names of any supervisors or co-workers. Plaintiff is currently unaware if decedent was exposed to asbestos during this employment. Location of Exposure Exposure Dates 1974-9/1997

Employer

Job Title

Long Beach Naval Shipyard, Long Beach Naval Welder Long Beach, CA Shipyard, Long Beach, CA USS BOXER (LHD-4) USS FLETCHER (DD992) USS HORNET (DLG-30) USS MERRILL (DD-976) USS OLDENDORF (DD972) USS ORISKANY (CVA34) USS PELELIU (LHA-5) USS PIGEON (ASR-21)

Job Duties: Decedent performed welding on ships in floating drydock. Decedent welded pipes, which included removing existing insulation from them. Decedent recalled that the welders helped the insulators install and construct boilers, including tearing out and installing refractory brick because the welders needed to weld tubes and bulkheads inside the boilers. Decedent used 6010 HOBART BROTHERS COMPANY and 6010 LINCOLN ELECTRIC COMPANY welding rods. Decedent worked in close proximity to GENERAL ELECTRIC COMPANY
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EXHIBIT "A"

Case 3:07-cv-04352-EMC

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turbines. Decedent worked in close proximity to other trades performing maintenance and repair on fans, pumps, heaters, and steamlines. Decedent worked in close proximity to various trades, including but not limited to: electricians, insulators, boilermakers, pipefitters, carpenters, and laborers. Decedent was unable to recall the names of any supervisors or co-workers. Throughout his employment with Long Beach Naval Shipyard, decedent worked in the engine rooms, boiler rooms and machine spaces aboard all of the ships. Decedent worked in close proximity to others performing maintenance and overhaul on INGERSOLL-RAND COMPANY compressors; ELLIOTT COMPANY pumps, compressors and turbines; LESLIE CONTROLS, INC. pumps; WARREN PUMPS, LLC pumps; and GARLOCK SEALING TECHNOLOGIES, LLC gaskets. Decedent used asbestos-containing blankets while welding scars on steam drums during his employment with Long Beach Naval Shipyard. Plaintiff currently contends that decedent was exposed to asbestos during this employment. Location of Exposure Exposure Dates 1974-9/1997 (1 year)

Employer

Job Title

Long Beach Naval Shipyard, USS ANTIETAM (CG-54); Welder Long Beach, CA Pearl Harbor Naval Shipyard, Honolulu, HI

Job Duties: Decedent supervised other welders in the repair of this ship. Decedent removed existing insulation from the pipes. Decedent used HOBART BROTHERS COMPANY and LINCOLN ELECTRIC COMPANY welding rods. Decedent worked in close proximity to other trades performing maintenance and repair on fans, pumps, heaters, and steamlines. Decedent worked in close proximity to various trades, including but not limited to: electricians, insulators, boilermakers, pipefitters, carpenters, and laborers. Decedent was unable to recall the names of any supervisors or co-workers. Plaintiff currently contends that decedent was exposed to asbestos during this employment. Location of Exposure Prax-Air Signal Hill, CA Exposure Dates 1998-1999

Employer Prax-Air, Signal Hill, CA

Job Title Agent

Job Duties: Decedent worked as a rental agent. Plaintiff is currently unaware if decedent was exposed to asbestos during this employment.

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Exposure EXHIBIT A

Case 3:07-cv-04352-EMC

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Employer Motion Pictures Aviation Services, Long Beach, CA

Exposure Motion Pictures Aviation Services Long Beach, CA

Job Title Fabricator

Dates 2000-2004

Job Duties: Decedent fabricated Hollywood sets. Plaintiff is currently unaware if decedent was exposed to asbestos during this employment. Location of Exposure Maclin Industries, Irvine, CA Exposure Dates 2005-2/2006

Employer Maclin Industries, Irvine, CA

Job Title Fabricator

Job Duties: Decedent fabricated and refurbished fire trailers. Plaintiff is currently unaware if decedent was exposed to asbestos during this employment.

Decedent: Larry Prettyman, deceased. Decedent's injuries: Decedent was diagnosed with asbestosis on or about 2004 and asbestosrelated pleural disease on or about 2007. Decedent died April 2, 2007. Defendants: Plaintiffs contend that the asbestos-containing products to which Decedent was or may have been exposed to were manufactured, supplied, distributed, installed and/or contracted for by defendants and each of them. Decedent's exposure to asbestos occurred at the following times and places, and involved exposure to dust created by the contractors and the products of the entities listed below. The exposure includes, but is not limited, to the following presently known contractors and the manufacturers and distributors of asbestos-containing products: Location of Exposure Naval Training Center, San Diego, CA Naval Training Center, Boilerman Class A & B School, Great Lakes, IL Exposure Dates 8/30/1974-11/7/1974

Employer U.S. Navy

Job Title Boiler Tender

11/23/1974-1/15/1975

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EXHIBIT A

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Naval Training Base, Philadelphia, PA BARRY (DD-933)

1/20/1975-2/10/1975

3/19/1975-7/3/1976; 8/20/1976-8/28/1978; 8/30/1978-7/30/1979 7/6/1976-8/20/1976

Automation Power School, New Port, RI Philadelphia Naval Shipyard, Philadelphia, PA

8/17/1979-8/29/1979

Job Duties: Decedent completed Class A and B Boilerman training at Great Lakes, Illinois as well as additional training in Rhode Island. Decedent recalled during his training, he worked on 600 pound BABCOCK & WILCOX and FOSTER WHEELER boilers. Decedent repaired LESLIE control valves. After decedent received his training, he worked 16 hours per day for approximately three years on the USS BARRY. Decedent was responsible for maintaining two 1200 modified D BABCOCK & WILCOX boilers on the USS BARRY while it was docked at the Philadelphia Naval Shipyard, Philadelphia, Pennsylvania. Decedent recalled that the shipyard supplied all parts and supplies. Decedent removed and replaced valves, gaskets, packing and insulation in order to work on the boiler and other equipment in the fire room. Decedent tore out insulation inside the fire boxes and the drums of the boilers. Decedent recalled removing and replacing GARLOCK gaskets from boosters; propellers; heat exchanges; forced strap blowers; fans; and main feed pumps. Decedent used a putty knife and a wire brush to clean the gaskets. Decedent removed and replaced FLEXITALLIC gaskets. Decedent removed and replaced refractory brick and mixed the mortar used inside the fireboxes. Decedent recalled removing and replacing VOGT (HENRY VOGT MACHINE CO.) and CROSBY (TYCO INTERNATIONAL (US) INC.) valves. Decedent removed and replaced CROSBY valves on a DELAVAL (IMO INDUSTRIES, INC.) main feed booster. Decedent recalled removing and replacing LESLIE valves on the main feed pump that was manufactured by WORTHINGTON (DII INDUSTRIES TRUST). Decedent recalled using CRANE CO. valves, and GARLOCK gaskets and packing. Decedent worked on a CHICAGO (FMC CORPORATION) pump that was used to pump and store salt water in case of fire. Decedent recalled INGERSOLL-RAND pumps. Decedent worked on BUFFALO fuel pumps and GENERAL ELECTRIC motors on the fuel pumps. Decedent worked on steam equipment, pumps and turbines manufactured by ALLIS CHALMERS. Decedent recalled the following shipmates: Dale Maury, address unknown; Bill Boisvert, Sanford, North Carolina; Kenney Dee, address unknown; Glenn Barrick, Avon, Indiana; Gary Briggs, Dover, Ohio; Robert Brewer, Shoreline, Washington; Joseph Brady, Taylorsville, Kentucky; Andrew Bradick, McLean, Virginia; Phillip Boogaerts, New Orleans, Louisiana; John Rossin, Winona, Minnesota; and John Bickford, Lake Placid, New York. Plaintiff currently contends that decedent was exposed to asbestos during this employment.

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EXHIBIT A