San Francisco — Exhibit E - Standard Interrogatories (Wrongful Death)

Source: https://sf.courts.ca.gov/system/files/sfciv-026-exhibit-e-standard-interrogatories-wrongful-death.pdf

1 Attorney Name(s) or Party without Attorney Firm Name 2 Firm Address 3 City, State, Zip Code Phone Number(s) 4 Fax Number Email Address 5 6 Attorney for (Name) or Self-Represented

7 SUPERIOR COURT OF CALIFORNIA

8 COUNTY OF SAN FRANCISCO

9 PLAINTIFF'S NAME, Case Number: 10 Plaintiff, 11 ASBESTOS – EXHIBIT E vs. 12 STANDARD INTERROGATORIES (WRONFUL DEATH) DEFENDANT'S NAME,13 14 Defendant

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 1

SFCIV-026 Rev. Jun-29-2012

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17 EXHIBIT E 18

19

20

21

22

23

24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 2

SFCIV-026 Rev. Jun-29-2012

1 DEFENDANTS' STANDARD INTERROGATORIES TO PLAINTIFF (WRONGFUL DEATH) [SET ONE] 2

3 PROPOUNDING PARTY: Defendants

4 RESPONDING PARTY:

5 SET NO.: One 6 INTRODUCTION 7 Each plaintiff in the above-captioned asbestos litigation is required to respond to 8

9 the following standard interrogatories separately and fully in writing, under oath,

10 pursuant to Code of Civil Procedure section 2030.010 et seq. within 30 days of the first

11 service on any defendant. These interrogatories should be answered by the plaintiff 12 most knowledgeable about the information sought regarding the decedent. In 13 responding to these standard interrogatories, YOU are required to furnish all information 14 15 that is available to YOU or YOUR attorney(s). If YOU cannot answer a standard

16 interrogatory completely, answer it to the fullest extent possible and specify the

17 reason(s) for YOUR inability to respond fully. 18

19 DEFINITIONS 20 21 1. "AREA" means the name of the specific structure, building, building

22 number, floor of the building, ship compartment, process line, unit, piece of equipment,

23 or other specific place within the WORKSITE. 24 2. "ASBESTOS-CONTAINING MATERIAL" means a material or product 25 which consists of, or contains the mineral asbestos. 26

27 3. "CONTROL" means the act(s) of directing the manner and/or methods of

28 conducting the work at a WORKSITE.

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 3

SFCIV-026 Rev. Jun-29-2012

1 4. "DECEDENT" means the deceased individual whose claimed asbestos

2 exposure forms the basis of the allegations underlying this lawsuit. 3 5. "DESCRIBE" as it relates to material means provide a complete 4 description of the material including but not limited to: the material name, manufacturer, 5 6 supplier, distributor, color, texture, consistency, shape, size and any markings; a

7 description of the material's container including size, color and all writing on that

8 container; and a description of how the material was used. 9 6. "DOCUMENTS" means any writing as defined in Evidence Code section 10 250 and includes the original or a copy of handwriting, typewriting, printing, 11 12 photostating, photographing, computer printout, and every other means of recording

13 upon any tangible thing or form of communication or representation including letters,

14 words, pictures, sounds or symbols or combinations of them. 15 7. "IDENTIFY" as it relates to a DOCUMENT means provide the title of the 16 DOCUMENT, the date the DOCUMENT was generated, the name of the author of the 17 18 DOCUMENT, a description of the DOCUMENT (e.g., letter, memorandum, report, book,

19 photograph, etc.) and any other information which would be required to specify the

20 DOCUMENT in a request for production of DOCUMENTS issued pursuant to Code of 21 Civil Procedure section 2031. 22 8. "IDENTIFY" as it relates to an employer means to state the employer's 23 24 name, address and telephone number.

25 9. "IDENTIFY" as it relates to a person means to provide the name, address

26 and telephone number for each person. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 4

SFCIV-026 Rev. Jun-29-2012

1 10. "IDENTIFY" as it relates to a ship means to state the name of the ship, the

2 owner of the ship, the operator of the ship, the type of ship, and the hull number of the 3 ship. 4 11. "LOCATION" means the city, state, country, street address, intersection or 5 6 shipyard. For work aboard ship, please IDENTIFY the ship and where it was located

7 during the time DECEDENT worked on board.

8 12. "OCCASION" refers to a day, any part of a day, or a series of day(s), 9 week(s), month(s) or year(s) during which DECEDENT worked continuously at a 10 WORKSITE. 11 12 13. "RAW ASBESTOS" means asbestos fiber mined or milled, either

13 packaged or in bulk, not compounded with other substances and essentially pure with

14 the exception of naturally occurring trace amounts of other substances. 15 14. "RESPONSIBLE PARTY" means any person, business organization, or 16 enterprise, including but not limited to the defendants in this action. 17 18 15. "SAFETY PRECAUTION" means respirators, masks, fans, air blowers,

19 tarps, wetdown procedures, isolation and any other equipment and/or methods used to

20 limit or prevent exposure to dust. 21 16. "WORKSITE" means any LOCATION where DECEDENT worked at any 22 time. 23 24 17. "YOU" and "YOUR" refer to the person who is named above as the

25 responding party. If more than one responding party is named, "YOU" and "YOUR" refer

26 to each responding party separately, not jointly. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 5

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORIES

2 INTERROGATORY No. 1: 3 Please state YOUR: 4 a. Full name including first, middle and last names; 5 6 b. Relationship to the DECEDENT;

7 c. Date of birth;

8 d. Age; 9 e. Place of birth; 10 f. Address; 11 12 g. Height and weight;

13 h. Social Security Number;

14 i. Kaiser Number; 15 j. Government Serial Number; 16 k. Military Serial Number; 17 18 l. Driver's License Number and State;

19 m. All of the names by which YOU have been known;

20 n. Highest grade level completed; 21 o. Spouse's name; 22 p. Date of YOUR most recent marriage; 23 24 q. Name of any former spouse;

25 r. Date(s) of any former marriage(s); and

26 s. Place, date and circumstances under which any marriage(s) was (were) 27 dissolved or terminated. 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 6

SFCIV-026 Rev. Jun-29-2012

1

2 INTERROGATORY No. 1B: 3 Please state for the DECEDENT: 4 a. Full name including first, middle and last names; 5 6 b. Date of birth;

7 c. Place of birth;

8 d. Last residence address; 9 e. Height and weight; 10 f. Social Security Number; 11 12 g. Kaiser Number;

13 h. Government Serial Number;

14 i. Military Serial Number; 15 j. Driver's License Number and State; 16 k. All of the names by which the DECEDENT was known; 17 18 l. Highest grade level completed;

19 m. Spouse's name;

20 n. Spouse's date of birth; 21 o. Date of marriage; 22 p. Spouse's current address; 23 24 q. Spouse's occupation/employer;

25 r. Name of any former spouse(s);

26 s. Date of any former marriage(s); and 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 7

SFCIV-026 Rev. Jun-29-2012

1 t. Place, date and circumstances under which any marriage(s) was (were)

2 dissolved or terminated. 3

4 INTERROGATORY No. 2: 5 6 For each child (either natural or adopted) of the DECEDENT, of any marriage,

7 state:

8 a. Name; 9 b. Date of birth; 10 c. Whether natural or adopted; 11 12 d. Address;

13 e. Occupation; and

14 f. Whether the child is living or deceased. 15

16 INTERROGATORY No. 3: 17 18 Are either of the DECEDENT's natural parents alive? If your answer is "yes",

19 please state for each parent:

20 a. Name of parent; 21 b. Current age; 22 c. Any history of cancer or respiratory disease; and 23 24 d. Occupation.

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 8

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 4:

2 For each of DECEDENT'S blood relatives (for example: parent, grandparent, 3 sibling, child, aunt, uncle) whom YOU believe died of either a malignancy (cancer) or 4 pulmonary (lung) disease other than pneumonia, please state, separately for each 5 6 person:

7 a. Full name;

8 b. Blood relation to DECEDENT (for example: parent, grandparent, sibling, 9 aunt, uncle); 10 c. Age at death; 11 12 d. Date of death;

13 e. Cause of death, as specifically described as possible;

14 f. City, county and state where the person died; and 15 g. Either (1) attach all DOCUMENTS evidencing the information sought in 16 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 17 18 disks containing such data, or (3) describe such DOCUMENTS with sufficient

19 particularity that they may be made the subject of a request for production of

20 documents. 21

22 INTERROGATORY No. 5: 23 24 State as completely as possible the address of each of the DECEDENT's

25 residences during his/her lifetime and the inclusive dates of each period of such

26 residence. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 9

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 6:

2 Please state the DECEDENT's educational background and identify all 3 institutions attended, including any apprenticeship courses or formal on-the-job training, 4 and identify all institutions attended, the date graduated from each institution, the major 5 6 course of study and any special scholastic honors or degrees received.

7

8 INTERROGATORY No. 7: 9 State the earliest date that service of the summons and complaint was effected 10 on any defendant in this case. 11

12

13 INTERROGATORY No. 8:

14 Were either YOU or the DECEDENT ever convicted of a felony? If "yes", please 15 state fully and in detail the date, place and nature of each such felony conviction and 16 who was convicted. 17

18

19 INTERROGATORY No. 9:

20 Had the DECEDENT ever been a member of the Armed Forces? If "yes", please 21 state: each branch of service in which the DECEDENT served; the inclusive dates of 22 service; the date of discharge from active duty; the DECEDENT's service number; each 23 24 place (e.g., fort, base, station, etc.) at which the DECEDENT served; and, duties at

25 each place. If the DECEDENT was not a member of the Armed Forces due to health

26 reasons, please state the health reason(s) why. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 10

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 10:

2 For every doctor who has ever treated or examined the DECEDENT during the 3 last 10 years for any condition, and beyond 10 years for cancer and/or conditions 4 related to the lungs, respiratory system, and/or ribs and any additional complaints or 5 6 conditions stated in response to Interrogatory No. 16, please state for each treatment or

7 examination:

8 a. Doctor's name; 9 b. Doctor's address; 10 c. Treatment or examination received; 11 12 d. Date(s) of treatment or examination;

13 e. Reason for treatment or examination; and

14 f. Either (1) attach all DOCUMENTS evidencing the information sought in 15 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 16 disks containing such data, or (3) describe such DOCUMENTS with sufficient 17 18 particularity that they may be made the subject of a request for production of

19 documents.

20

21 INTERROGATORY No. 11: 22 For every hospital in which the DECEDENT had ever been treated, tested or 23 24 examined whether as an "inpatient" or as an "outpatient" during the last 10 years for any

25 condition, and beyond 10 years for cancer and/or conditions related to the lungs,

26 respiratory system, and/or ribs and any additional complaints or conditions stated in 27 response to Interrogatory No. 16, please state for each hospital visit: 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 11

SFCIV-026 Rev. Jun-29-2012

1 a. Name of hospital;

2 b. Address of hospital; 3 c. Test, treatment, examination or hospitalization received; 4 d. Date of test, treatment, examination or hospitalization received; 5 6 e. Reason for hospital visit; and

7 f. Either (1) attach all DOCUMENTS evidencing the information sought in

8 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 9 disks containing such data, or (3) describe such DOCUMENTS with sufficient 10 particularity that they may be made the subject of a request for production of 11 12 documents.

13

14 INTERROGATORY No. 12: 15 Did DECEDENT ever have an x-ray, CT scan or high-resolution CT scan taken of 16 his/her trunk? If "yes", please state for each: 17 18 a. Name and address where taken;

19 b. Date(s) and number taken of each;

20 c. Part(s) of body x-rayed or scanned; 21 d. Results, conclusions and/or diagnosis from each, except those prepared 22 by consultants; and 23 24 e. Either (1) attach all DOCUMENTS evidencing the information sought in

25 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach

26 disks containing such data, or (3) describe such DOCUMENTS with sufficient 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 12

SFCIV-026 Rev. Jun-29-2012

1 particularity that they may be made the subject of a request for production of

2 documents. 3

4 INTERROGATORY No. 13: 5 6 Had the DECEDENT ever undergone a pulmonary function test? If "yes", please

7 state the following:

8 a. Name and address where test was performed; 9 b. Date of test; 10 c. Name of doctor administering and/or interpreting test; 11 12 d. Reason for test;

13 e. Results, conclusions and/or diagnosis from each test, except those

14 prepared by consultants; 15 f. Was the DECEDENT informed of the results of the test? 16 g. Who informed the DECEDENT of the results of the test? 17 18 h. Either (1) attach all DOCUMENTS evidencing the information sought in

19 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach

20 disks containing such data, or (3) describe such DOCUMENTS with sufficient 21 particularity that they may be made the subject of a request for production of 22 documents. 23

24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 13

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 14:

2 Describe the name and quantity of each type of drug, tranquilizer, sedative, or 3 other medication taken or used by the DECEDENT during the last 10 years of the 4 DECEDENT's life, specifying the frequency and purpose of use. 5

6

7 INTERROGATORY No. 15:

8 Do YOU or YOUR attorney have any medical reports except those prepared by 9 consultants from any persons, hospitals, doctors, or medical practitioners or institutions 10 that ever treated or examined the DECEDENT at any time? If "yes", either (1) attach all 11 12 DOCUMENTS evidencing the information sought in this interrogatory and its subparts to

13 your answers to these interrogatories, or (2) attach disks containing such data, or (3)

14 describe such DOCUMENTS with sufficient particularity that they may be made the 15 subject of a request for production of documents. If YOU will not voluntarily attach 16 copies of reports to the answers to these interrogatories, then please state fully and in 17 18 detail for each:

19 a. The identity of the report(s) by date, subject matter, name, address, job

20 title or capacity of the persons to whom it is addressed or directed and the job title or 21 capacity of the person or persons who prepared the same; and 22 b. The name, address and present whereabouts of the person who has 23 24 present custody or control thereof and the purpose of said preparation.

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 14

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 16:

2 Identify each and every complaint, symptom, adverse reaction or other injury 3 which YOU allege is directly or indirectly related to DECEDENT's alleged exposure to 4 RAW ASBESTOS or ASBESTOS-CONTAINING MATERIAL(S), and for each 5 6 complaint, symptom, adverse reaction, or other injury, please state:

7 a. The date on which the DECEDENT first became aware of the signs of the

8 complaint, symptom, adverse reaction or injury; 9 b. The date each such complaint, symptom, adverse reaction or injury 10 ceased to affect the DECEDENT; 11 12 c. Any physical change in the DECEDENT's appearance occasioned by such

13 complaint, symptom, adverse reaction or injury;

14 d. Each part of the DECEDENT's body which YOU contend was affected; 15 e. The date upon which the complaint, symptom, adverse reaction or injury 16 was reported to a doctor or physician; 17 18 f. State the name, address and telephone number of each such physician to

19 whom said complaint, symptom, adverse reaction or injury was reported;

20 g. State whether the DECEDENT lost any time from work as a result of the 21 DECEDENT's asbestos-related injury or medical condition; 22 h. If such injury resulted in lost time from work, please state the date on 23 24 which the DECEDENT first lost work and the amount of time lost from work; and

25 i. Either (1) attach all DOCUMENTS evidencing the information sought in

26 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 27 disks containing such data, or (3) describe such DOCUMENTS with sufficient 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 15

SFCIV-026 Rev. Jun-29-2012

1 particularity that they may be made the subject of a request for production of

2 documents. 3

4 INTERROGATORY No. 17: 5 6 Please state when it was first determined that the DECEDENT was suffering

7 from an asbestos-related disease. Please include in YOUR answer:

8 a. The nature of the asbestos-related disease(s); 9 b. The date and time of such determination; 10 c. When and by what means that determination was first communicated to 11 12 each plaintiff herein;

13 d. The name, address and telephone number of the physician and/or other

14 person(s) who so informed you; 15 e. The method and information upon which such determination was based; 16 f. The name, address and telephone number of any hospital, medical 17 18 institution, laboratory, physician, nurse, laboratory technician, etc., involved in any part

19 of such determination;

20 g. The name, address and telephone number of every person, including the 21 DECEDENT's relatives, employer, or anyone acting in the DECEDENT's behalf, to 22 whom such determination was made known. Please include the date, time and place of 23 24 such revelation, and the name, address and telephone number of anyone witnessing

25 said revelation;

26 h. The name, address and telephone number of the DECEDENT's 27 employer(s) at the time of such determination; 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 16

SFCIV-026 Rev. Jun-29-2012

1 i. The specific course(s) of treatment or therapy, including any medicine

2 prescribed as a result of such determination, and the name, address and telephone 3 number of each prescribing physician; 4 j. State whether the DECEDENT followed the medication or therapy regime 5 6 prescribed by each of the said physicians for the treatment of said complaint, symptom,

7 adverse reaction or injury;

8 k. Please state the names and addresses of any other physicians or 9 practitioners subsequently affirming or making the same determination; and 10 l. Either (1) attach all DOCUMENTS evidencing the information sought in 11 12 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach

13 disks containing such data, or (3) describe such DOCUMENTS with sufficient

14 particularity that they may be made the subject of a request for production of 15 documents. 16

17 18 INTERROGATORY No. 18:

19 Did any of the said treating physicians inform either YOU, any plaintiff or the

20 DECEDENT at any time that the complaints, symptoms, adverse reactions or injuries 21 may have been caused by factor(s) or reason(s) other than exposure to RAW 22 ASBESTOS or ASBESTOSCONTAINING MATERIAL(s)? If "yes", please state: 23 24 a. The other factor(s) or reason(s) involved;

25 b. The names, addresses and telephone numbers of the physicians believing

26 or suspecting such other factor(s) or reason(s) to be involved; 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 17

SFCIV-026 Rev. Jun-29-2012

1 c. The date(s) that said physicians told either YOU, any plaintiff or the

2 DECEDENT that they believed or suspected that other factor(s) or reason(s) might be 3 involved and to whom that information was provided on each such date; 4 d. The reason that said factor(s) or reason(s) were excluded as possible 5 6 sources or causes of the symptoms; and

7 e. Either (1) attach all DOCUMENTS evidencing the information sought in

8 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 9 disks containing such data, or (3) describe such DOCUMENTS with sufficient 10 particularity that they may be made the subject of a request for production of 11 12 documents.

13

14 INTERROGATORY No. 19: 15 Was a death certificate prepared after the death of the DECEDENT? If "yes", 16 please state: 17 18 a. Whether it was filed;

19 b. The office in which it was filed;

20 c. The address and occupation of the person listed on the certificate as the 21 informant; 22 d. The relationship to or connection with DECEDENT of the person listed as 23 24 the informant;

25 e. The name, address and specialty of each doctor furnishing information

26 appearing on the death certificate; 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 18

SFCIV-026 Rev. Jun-29-2012

1 f. The immediate cause of death shown on the death certificate and, if

2 known, any contributing causes listed; and 3 g. The exact time, date and place of death shown on the death certificate. 4

5 6 INTERROGATORY No. 20:

7 Was an autopsy performed on the body of the DECEDENT? If "yes", for each

8 autopsy state: 9 a. The name, address and official capacity of each person authorizing or 10 ordering the autopsy; 11 12 b. The relationship to or connection with DECEDENT of each person

13 authorizing or ordering the autopsy;

14 c. Why the autopsy was ordered; 15 d. Whether the autopsy involved the DECEDENT's entire body and, if not, to 16 which organ(s) it was confined. 17 18 e. The name, address, occupation and professional specialty of each person

19 performing the autopsy;

20 f. The name, address, occupation and professional specialty of any person 21 or organization which in addition to that identified in subpart 19(E) also had custody of 22 DECEDENT's body or any portion thereof in furtherance of obtaining the autopsy or any 23 24 portion of an autopsy;

25 g. The time and date the autopsy and/or any limited autopsy was performed;

26 h. The cause of death shown by the autopsy; 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 19

SFCIV-026 Rev. Jun-29-2012

1 i. The name, address and occupation of each person having custody of the

2 report of the results of the autopsy; 3 j. Whether YOU have or can obtain a copy of the autopsy report or if YOU 4 will do so without a Motion to Produce and attach a copy of each autopsy report to 5 6 YOUR answers to these interrogatories; and

7 k. Either (1) attach all DOCUMENTS evidencing the information sought in

8 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 9 disks containing such data, or (3) describe such DOCUMENTS with sufficient 10 particularity that they may be made the subject of a request for production of 11 12 documents.

13

14 INTERROGATORY No. 21: 15 Do YOU know of any pathology slides that were made of any tissue samples of 16 the DECEDENT during the last 10 years of DECEDENT'S life? If YOUR answer is 17 18 "yes", for each set of slides made please state:

19 a. The name of the hospital;

20 b. The name of the doctor; 21 c. The current location; 22 d. The date said slides were made; 23 24 e. The accession number(s); and

25 f. Either (1) attach all DOCUMENTS evidencing the information sought in

26 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 27 disks containing such data, or (3) describe such DOCUMENTS with sufficient 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 20

SFCIV-026 Rev. Jun-29-2012

1 particularity that they may be made the subject of a request for production of

2 documents. 3

4 INTERROGATORY No. 22: 5 6 Had the DECEDENT ever suffered any personal injuries other than those

7 involved in this lawsuit? If "yes", state for each such injury:

8 a. The date, place, names of persons involved, and circumstances 9 surrounding such injury; 10 b. The nature and extent of the injuries including any ill effects or disabilities 11 12 remaining at the time of the last treatment or examination;

13 c. The nature and extent of the injuries including all ill effects or disabilities

14 remaining at the time of death of DECEDENT; 15 d. The names, addresses and date(s) of last treatment or examination by all 16 persons who treated or examined DECEDENT in connection with such injury; 17 18 e. The nature and source of any disability benefits, pensions or other

19 payments for such injuries; and

20 f. Either (1) attach all DOCUMENTS evidencing the information sought in 21 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 22 disks containing such data, or (3) describe such DOCUMENTS with sufficient 23 24 particularity that they may be made the subject of a request for production of

25 documents.

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 21

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 23:

2 Did the DECEDENT ever smoke tobacco products of any type? If "yes", please 3 state: 4 a. The dates and time periods during which the DECEDENT smoked; 5 6 b. The type of tobacco products the DECEDENT smoked and whether the

7 DECEDENT inhaled the smoke or not;

8 c. The daily frequency with which the DECEDENT smoked; 9 d. If the DECEDENT ever smoked cigarettes, state the average number of 10 packs per day so consumed; 11 12 e. The commercial brand name(s) of any tobacco products that the

13 DECEDENT used; and

14 f. Whether any physician ever advised DECEDENT to stop or curtail 15 smoking tobacco products? If "yes", please state: 16 1. The name of each such physician; and 17 18 2. The date(s) on which DECEDENT was so advised.

19

20 INTERROGATORY No. 24: 21 Was any person with whom the DECEDENT shared a household for more than 22 one year a regular user of cigarettes during the time DECEDENT shared a household 23 24 with that individual(s)? If "yes", please state fully and in detail for each such person:

25 a. The name and relationship to the DECEDENT of the smoker;

26 b. The dates during which the DECEDENT shared a household with that 27 person; 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 22

SFCIV-026 Rev. Jun-29-2012

1 c. The brand name(s) of cigarettes the person used during the time

2 DECEDENT shared a household; and d. The frequency with which that person smoked 3 cigarettes in the DECEDENT's presence during the time the DECEDENT shared a 4 household. 5

6

7 INTERROGATORY No. 25:

8 Describe the extent to which the DECEDENT drank alcoholic beverages during 9 the DECEDENT's lifetime, specifying the particular kind of alcoholic beverages and the 10 quantity consumed per week over the period of time such beverage(s) were consumed. 11

12

13 INTERROGATORY No. 26:

14 For every type of employment that DECEDENT had ever had, whether self- 15 employed or employed by others, please complete the following: (If more space is 16 needed, please attach additional sheets containing the requested information.) Either 17 18 (1) attach all DOCUMENTS evidencing the information sought in this interrogatory and

19 its subparts to your answers to these interrogatories, or (2) attach disks containing such

20 data, or (3) describe such DOCUMENTS with sufficient particularity that they may be 21 made the subject of a request for production of documents. 22 Employer’s Name and Job Title Date Started-Date Ended 23 Address (Month, Day, Year) 24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 23

SFCIV-026 Rev. Jun-29-2012

1 Job Sites:

2

3

4

5 6 Your Estimate of Total Time (Days, Weeks, etc.) Decedent Worked at That Site:

7

8

9

10 Do you claim Decedent was exposed to asbestos at this employment? 11 12 ☐ Yes ☐ No

13 Employer’s Name and Job Title Date Started-Date Ended 14 Address (Month, Day, Year)

15

16

17

18 Description of Job Duties: 19

20

21

22

23 Job Sites: 24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 24

SFCIV-026 Rev. Jun-29-2012

1 Your Estimate of Total Time (Days, Weeks, etc.) Decedent Worked at That Site:

2

3

4

5 6 Do you claim Decedent was exposed to asbestos at this employment?

7 ☐ Yes ☐ No

8 Employer’s Name and Job Title Date Started-Date Ended 9 Address (Month, Day, Year)

10

11

12

13 Description of job Duties: 14

15

16

17

18 Job Sites: 19

20

21

22

23 Your Estimate of Total Time (Days, Weeks, etc.) Decedent Worked at That Site: 24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 25

SFCIV-026 Rev. Jun-29-2012

1 Do you claim Decedent was exposed to asbestos at this employment?

2 ☐ Yes ☐ No 3 Employer’s Name and Job Title Date Started-Date Ended 4 Address (Month, Day, Year) 5

6

7

8 9 Description of job Duties:

10

11

12

13 Job Sites: 14

15

16

17

18 Your Estimate of Total Time (Days, Weeks, etc.) Decedent Worked at That Site: 19

20

21

22

23 Do you claim Decedent was exposed to asbestos at this employment? 24 ☐ Yes ☐ No 25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 26

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 27:

2 Was the DECEDENT ever a member of any labor union, including but not limited 3 to the Heat, Frost, Insulation and Asbestos Workers Union? If "yes", please state for 4 each such union membership: 5 6 a. The name of each such international union and its number, along with the

7 local number of each such union; and

8 b. The date and time periods during which the DECEDENT maintained 9 membership in such union. 10

11 12 INTERROGATORY No. 28:

13 When and how did the DECEDENT first learn that exposure to asbestos was a

14 potential health hazard? 15

16 INTERROGATORY No. 29: 17 18 When did the DECEDENT first observe anyone use any type of SAFETY

19 PRECAUTION while working around RAW ASBESTOS or ASBESTOS-CONTAINING

20 MATERIAL(s)? 21

22 INTERROGATORY No. 30: 23 24 When, where and at whose direction did the DECEDENT first use any type of

25 SAFETY PRECAUTION while working around RAW ASBESTOS or ASBESTOS-

26 CONTAINING MATERIAL(s)? 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 27

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 31:

2 Please state whether any of the DECEDENT's employers either required or 3 made available physical examinations for their employees. If such physical 4 examinations were either required or made available to the DECEDENT, please state 5 6 for each such employer:

7 a. The employer;

8 b. The nature and extent of examinations; 9 c. The frequency of examinations; 10 d. Whether they were required or optional; 11 12 e. Whether x-ray examination was included;

13 f. The frequency, including specific dates and times with which the

14 DECEDENT submitted to such examinations; 15 g. Whether the DECEDENT received the results of any such examinations; 16 the dates that they were given to the DECEDENT and the nature of the results; 17 18 h. The name, address and telephone number of the examining physician,

19 nurse or technician;

20 i. The DECEDENT's detailed reasons for failing to submit to such 21 examination when required or made available, if the DECEDENT did so fail to submit; 22 and 23 24 j. Either (1) attach all DOCUMENTS evidencing the information sought in

25 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach

26 disks containing such data, or (3) describe such DOCUMENTS with sufficient 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 28

SFCIV-026 Rev. Jun-29-2012

1 particularity that they may be made the subject of a request for production of

2 documents. 3

4 INTERROGATORY No. 32: 5 6 Was the DECEDENT ever exposed to RAW ASBESTOS or

7 ASBESTOSCONTAINING MATERIAL(S) outside of the DECEDENT'S work

8 environment? If "yes", please state for each such OCCASION: 9 a. The circumstances surrounding the exposure; 10 b. The date(s) and LOCATION; 11 12 c. The duration and manner of the exposure; and

13 d. DESCRIBE the RAW ASBESTOS or ASBESTOS-CONTAINING

14 MATERIAL(S). 15

16 INTERROGATORY No. 33: 17 18 Was the DECEDENT ever discharged from or did the DECEDENT ever

19 voluntarily leave a position due to health problems? If "yes", please state in detail the

20 time, name of employer, place and circumstances and either (1) attach all 21 DOCUMENTS evidencing the information sought in this interrogatory and its subparts to 22 your answers to these interrogatories, or (2) attach disks containing such data, or (3) 23 24 describe such DOCUMENTS with sufficient particularity that they may be made the

25 subject of a request for production of documents..

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 29

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 34:

2 If the DECEDENT was not employed at the time of death, please state the 3 DECEDENT's last date worked and the reason that the DECEDENT was not employed 4 thereafter. 5

6

7 INTERROGATORY No. 35:

8 Was the DECEDENT receiving any form of disability pension at the time of 9 death? If "yes", please state: a. From whom; b. The amounts received each month; and 10 c. The anticipated duration of the disability pension. 11

12

13 INTERROGATORY No. 36:

14 If you state a claim for loss of DECEDENT'S income, state fully and in detail the 15 year and the DECEDENT's annual earnings for each of the last 10 years in which the 16 DECEDENT was employed. 17

18

19 INTERROGATORY No. 37:

20 Did the DECEDENT, during the last 10 years of DECEDENT's life, engage in any 21 other activity or participate in any way in any business designed to produce income not 22 mentioned in the preceding interrogatories? If "yes", for each such activity or business 23 24 state:

25 a. A description of the activity or business;

26 b. The amount of time DECEDENT devoted to the activity or business during 27 each of the last ten years of DECEDENT's life; and 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 30

SFCIV-026 Rev. Jun-29-2012

1 c. The amount of income received from the activity of business for each of the

2 last ten years of DECEDENT's life. 3

4 INTERROGATORY NO. 38: 5 6 At the time of death, had the DECEDENT incurred any hospital expenses as a

7 result of the injuries, complaints, etc. which YOU attribute to the DECEDENT's alleged

8 exposure to asbestos? If "yes", please state the total hospital expenses incurred and 9 itemize each charge if more than one hospital is involved. 10

11 12 INTERROGATORY No. 39:

13 At the time of death, had the DECEDENT incurred any medical expense (other

14 than hospitalization) or had any medical expenses been incurred on the DECEDENT's 15 behalf to date as a result of the injuries, complaints, etc. which YOU attribute to the 16 DECEDENT's alleged exposure to asbestos? If "yes", please state the total medical 17 18 expenses incurred, itemizing each such charge.

19

20 INTERROGATORY No. 40: 21 Has any insurance company, union or any other person, firm or corporation paid 22 for or reimbursed, or become obligated to pay for, any medical or hospital expenses 23 24 incurred by the DECEDENT as a result of the alleged exposure to asbestos? If "yes",

25 please state the name and address of the insurance company, union, person, firm or

26 corporation who or which has paid or is obligated for the payment of or reimbursement 27 for said expenses. 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 31

SFCIV-026 Rev. Jun-29-2012

1

2 INTERROGATORY No. 41: 3 Had the DECEDENT ever given a deposition or other testimony under oath? If 4 so, please state for each such deposition or testimony: 5 6 a. The date(s) it was given;

7 b. The name of the court or other body before which it was given; the identity

8 of the proceeding including name, docket or other number, and venue or location; 9 c. The name, address and telephone number of the court reporter or other 10 transcriber. If the proceeding was not transcribed, please so state; 11 12 d. Whether YOU or YOUR attorney have a copy of the transcript; and e.

13 Either (1) attach all DOCUMENTS evidencing the information sought in this

14 interrogatory and its subparts to your answers to these interrogatories, or (2) attach 15 disks containing such data, or (3) describe such DOCUMENTS with sufficient 16 particularity that they may be made the subject of a request for production of 17 18 documents.

19

20 INTERROGATORY No. 42: 21 Had the DECEDENT ever at any time made a claim for or received for an 22 asbestos-related condition any health or accident insurance benefits, Workers' 23 24 Compensation payments, disability benefits, pension, accident compensation payment

25 or veterans disability compensation? If "yes", please state:

26 a. The illness, injury or injuries for which the DECEDENT made the claim; 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 32

SFCIV-026 Rev. Jun-29-2012

1 b. The date when such injury or injuries were sustained, the place of

2 occurrence and the nature of the accident or incident causing such injury; 3 c. The names and addresses of the DECEDENT's employer(s) at the time of 4 each injury or illness; 5 6 d. The names and addresses of the examining doctors for each injury or

7 illness;

8 e. The name of the board, tribunal or superior officer which or to whom the 9 claim or claims were made or filed; 10 f. The date the claim was made or filed; 11 12 g. The claim, file or other number by which the DECEDENT's claim was

13 identified;

14 h. The present status of such claims (pending settlement, dismissal, etc.); 15 i. The amounts of the benefits or awards or payments; 16 j. The dates covering the times during which the DECEDENT received the 17 18 benefits or awards or payments;

19 k. The identity of the agencies or insurance companies from whom the

20 DECEDENT received the awards, benefits or payments; and 21 l. Either (1) attach all DOCUMENTS evidencing the information sought in 22 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach 23 24 disks containing such data, or (3) describe such DOCUMENTS with sufficient

25 particularity that they may be made the subject of a request for production of

26 documents. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 33

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 43:

2 Had the DECEDENT ever had an application for life, health, accident, medical or 3 hospital insurance rejected for health reasons? If "yes", please state: 4 a. The date of the application(s); 5 6 b. The date of rejection(s);

7 c. The type of insurance for which the DECEDENT applied;

8 d. The identity of the insurance company with which each application was 9 filed; 10 e. The reason for the rejection(s); and 11 12 f. Either (1) attach all DOCUMENTS evidencing the information sought in

13 this interrogatory and its subparts to your answers to these interrogatories, or (2) attach

14 disks containing such data, or (3) describe such DOCUMENTS with sufficient 15 particularity that they may be made the subject of a request for production of 16 documents. 17

18

19 INTERROGATORY No. 44:

20 Had the DECEDENT ever been a party to an action for damages for any 21 personal injury the DECEDENT suffered? If "yes", please state: 22 a. The identity of all parties to the action(s) and their attorneys; 23 24 b. The court and place where each such action was filed and the date(s) of

25 filing;

26 c. The nature and extent of the injuries claimed and whether any permanent 27 disability remained at the time DECEDENT died; and 28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 34

SFCIV-026 Rev. Jun-29-2012

1 d. The present status of each action and, if concluded, the final result thereof

2 including the amount of any settlement or judgment. 3

4 INTERROGATORY No. 45: 5 6 Had the DECEDENT ever made any claim for personal injury, other than this

7 lawsuit, for injuries which YOU claim are related to the DECEDENT's alleged exposure

8 to asbestos? If "yes", please state: 9 a. The nature of such injury or injuries; 10 b. The date when such injury or injuries were sustained in each instance, the 11 12 place of occurrence and the nature of the incident or accident causing this injury;

13 c. The names and addresses of all persons and companies to whom said

14 claims were made; 15 d. The caption and case number; 16 e. The court filing including state and county; 17 18 f. The name and address of YOUR counsel of record;

19 g. The present status of such claims (pending settlement, dismissal, etc.);

20 and h. Either (1) attach all DOCUMENTS evidencing the information sought in this 21 interrogatory and its subparts to your answers to these interrogatories, or (2) attach 22 disks containing such data, or (3) describe such DOCUMENTS with sufficient 23 24 particularity that they may be made the subject of a request for production of

25 documents.

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 35

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 46:

2 Had the DECEDENT received any payments or reimbursement or have any 3 payments been made on the DECEDENT's behalf from any source as a result of the 4 DECEDENT's alleged exposure to asbestos, including without limitation settlements 5 6 with defendants in this action, potential defendants, a bankrupt company, or any

7 RESPONSIBLE PARTIES? If "yes", for each payment please state:

8 a. The name of the each person or company making said payment(s); and 9 b. Total amount of payments from all sources. 10

11 12 INTERROGATORY No. 47:

13 Do YOU have in YOUR possession or under YOUR control a Social Security

14 office listing of all the DECEDENT's past employers and dates of employment? If "yes", 15 please either attach a copy or give the employer's name, address, date and quarterly 16 Social Security Credit for each employer listed. 17

18

19 INTERROGATORY No. 48:

20 Are YOU Medicare-eligible? If so, please state: 21 a. Whether you are currently enrolled in Medicare; 22 b. If you are not currently enrolled in Medicare, whether you have previously 23 24 been enrolled;

25 c. The dates on which you are or were enrolled in Medicare;

26 d. YOUR Medicare number. 27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 36

SFCIV-026 Rev. Jun-29-2012

1 INTERROGATORY No. 49:

2 Has any person other than YOU received or sought treatment from Medicare for 3 any reason related to your claims in this case? If so, please state, for each such person: 4 a. The name, address, and telephone number; 5 6 b. The person's relation to you (e.g. spouse, natural child);

7 c. The person's Medicare number;

8 d. The inclusive dates of such treatment. 9

10 INTERROGATORY No. 50: 11 12 Have YOU filed a claim against a bankruptcy trust? If "yes," state for each claim:

13 a. The name and address of that trust;

14 b. The date YOUR claim was filed; 15 c. Either (1) attach all DOCUMENTS evidencing the information sought in 16 this interrogatory to your answers to interrogatories, or (2) attach disks containing such 17 18 data, or (3) describe such DOCUMENTS with sufficient particularity that they may be

19 made the subject of a request for production of documents.

20

21

22

23

24

25

26

27

28

Jun-29-2012 IN RE COMPLEX ASBESTOS LITIGATION CMO - 37

SFCIV-026 Rev. Jun-29-2012