Document G69oXeEYDdarzBOmX5QVNRr8x

FILE NAME Kubota KUB DATE 2010 DOC KUB040 DOCUMENT DESCRIPTION Legal - Plaintiffs Requests for Production to Defendant Kubota JEFFREY A. KAISER ESQ SBN 160594 T. SCOTT HAMES ESQ SBN 197574 2 LEVIN SIMES KAISER & GORNICK LLP 44 Montgomery Street 36th Floor 3 San Francisco California 94104 4 Telephone Facsimile 415 646-7160 415 981-1270 5 Attorneys for Plaintiffs RHODA EVANS AND BOBBY EVANS 6 7 8 SUPERIOR COURT OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 Unlimited Jurisdiction 11 1212 RHODA EVANS AND BOBBY EVANS ) Case No. BC418867 ) 13 Plaintiffs ) PLAINTIFFS REQUESTS FOR ) PRODUCTION TO DEFENDANT KUBOTA 14 ) CORPORATION VS. ) 15 15 A.W. CHESTERTON COMPANY et al ) 1617 Defendants ) ) 18 ) 19 ) 19 ) 2020 PROPOUNDING PARTIES RHODA EVANS AND BOBBY EVANS 2121 RESPONDING PARTY KUBOTA CORPORATION 2222 SET NO TWO 2323 2424 2525 2626 2727 2828 1 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 5681421 1 DEFINITONS 2 3 YOU YOUR or DEFENDANT shall refer to Kubota America Corporation 4 Kubota Iron and Machinery Works Kubota Corporation its officers directors 5 partners EMPLOYEES agents joint venturers parent entities predecessors 6 subsidiaries divisions and contract units 7 VOSS shall refer to A.H. Voss Company Voss International Corp. and Voss 8 9 International its officers directors partners EMPLOYEES agents joint venturers 10 10 parent entities predecessors subsidiaries divisions and contract units 11 11 The phrase CONTAINING MATERIALS ASBESTOS- 12 12 CONTAINING MATERIAL means any product which YOU know or believe to 13 13 contain any amount of the mineral asbestos including but not limited to any and all raw 14 14 15 15 asbestos vermiculite amosite tremolite chrysotile crocidolite asbestine and talc 16 16 Also this phrase shall include any product which YOU know or believe to contain any 17 17 amount of the mineral asbestos including valves gaskets insulation insulating 18 18 materials packing materials transite pipes asbestos pipe pipe insulation or 19 19 other products containing any amount of asbestos 222220 2222 2222 CONTAINING MATERIALS shall refer to any and all non- 22222222 containing pipe 2222 2222 CONCERNING herein means demonstrating reflecting evidencing referring to 24 depicting concerning referencing touching upon discussing evidencing describing 25 25 identifying supporting or resulting from the matter specified including in each 26 26 27 27 2828 2 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 instance documents now or previously attached or appended to or used in the preparation 1 of any document called for by each request 3 DOCUMENTS shall mean writing as defined in California Evidence Code 250 4 which includes without limitation all handwriting typewriting printing photostating 5 photographing and every other means of recording upon any tangible thing any form of 6 7 communication or representation including catalogs letters words pictures sounds or 8 symbols or combinations thereof This term shall also include mail transmissions and 9 writings stored on all computer medium including hard disk drives floppy disk 10 10 drives Roms and DVDs and will be referred to below as documents 11 12 EMPLOYEE shall refer to any individual currently or formerly in an employment 12 1313 relationship with DEFENDANT and any individual acting as a corporate officer and 1414 serving as a consultant or independent contractor OO 1515 HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE shall refer to the risks 1616 of the development of asbestos related lung disease including but not limited to 1717 mesothelioma lung cancer asbestosis and pleural plaques 18 18 IDENTIFICATION MARKINGS shall refer to any branding logo symbol sign 1919 22222222 emblem badge insignia indication feature characteristic crest motif and mark 22222222 10 IDENTIFY with regard to a person or business means to state his or her or its name 22222222 her or her place of employment or the business's address his or her job title present 2323 business or present or last known home address and present business telephone number 222224 mean 22222222 11. IDENTIFY with regards to a DOCUMENT shall to state a the author b the 22222222 addressee c the date of origin d the nature of the writing or document e.g. letter 2222222 telephone memorandum tape recording photograph etc. and present location and 2828 3 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 name the present location and present address of the custodian thereof 2 12 WORKSITES shall include but not be limited all sites located in Los Angeles 3 County CA wherein VOSS supplied ASBESTOS CEMENT PIPE between 1965 and 4 1967 inclusive 5 13 RESPIRATORY PROTECTION shall refer to any respiratory protective device 6 7 including but not limited to full or partial face coverings masks respirators filters 8 cartridges canisters hoses straps air supply systems and linings designed to remove 9 dust fibers ASBESTOS fumes and contaminants from the air 1010 14. SAFETY MEETING shall refer to any gathering wherein matters concerning 1 11 occupational safety safety procedures safe work practices and the HAZARDS 12 ASSOCIATED WITH ASBESTOS EXPOSURE are discussed or information 13 1314 CONCERNING these matters is disseminated 15 15. SAFETY PERSONNEL shall refer to individuals trained to identify safety hazards 16 and required to enforce safety regulations and inform EMPLOYEES of safety hazards 17 and safe work practices 18 1819 16. SUPPLY or SUPPLIED or SUPPLIER shall refer to any entity engaged in 2222222 selling distributing making available providing leasing or otherwise transferring for 212222 value 22222222 17 The term SYSTEM OF DISTRIBUTIUON shall refer to distribution receiving from 22222222 supplier warehousing shipping delivery and the manner in which all of the before is 2424 2525 accomplished 2626 18. The term COMMUNICATION shall refer to any message communiqu^' 2727 announcement statement letter phone call memo memorandum note declaration 2828 4 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 notice proclamation report account assertion publication advertisement whether the 2 communication be made written or verbal via mail or telephone and made first 3 person and througha third party 4 19. The term CLAIM shall refer to any lawsuit claim notice request for 5 compensation and COMMUNICATION wherein any entity individual and 6 7 individuals alleged exposure to asbestos as a result of YOUR negligent or intentional 8 conduct 9 20. The term CONSUMER shall refer to the ordinary user of the product as referred to 1010 in Jury Instruction 1203 of the Judicial Council of California Advisory Committee on 11 Civil Jury Instructions CACI 12 13 21 The term WARNING shall refer to its ordinary meaning as referred to in Jury 14 Instruction 1205 of the Judicial Council of California Advisory Committee on Civil Jury Instructions CACI 15 REQUESTS FOR PRODUCTION 17 1518 REQUEST FOR PRODUCTION NO 1 19 DOCUMENT RELATING to the announcement by YOU on approximately June 29 2020 2005 regarding the occurrence of many occupational victims of asbestos as well as the victims 2121 Kanzaki of asbestos dust from environmental exposure around the 2222 plant REQUEST FOR PRODUCTION NO 2 2323 DOCUMENT CONCERNING YOUR Retired Employees Association Directory 2424 REQUEST FOR PRODUCTION NO 3 2222282228 DOCUMENT CONCERNING the Retired Employees Association Directory for the 2222282228 asbestos cement pipe division of Kubota 2222282228 2222282228 5 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 REQUEST FOR PRODUCTION NO 4 2 DOCUMENT RELATING to any and all asbestos deaths of former Kubota 3 employees 4 REQUEST FOR PRODUCTION NO 5 5 DOCUMENT IDENTIFYING all current and former Kubota employees who worked 6 at the Kanzaki Plant located in Amagasaki City Japan who YOU have knowledge have 7 developed mesothelioma including but not limited to all those former employees YOU have | 8 compensated for mesothelioma 9 REQUEST FOR PRODUCTION NO 6 10 All DOCUMENTS CONCERNING asbestos currently in the possession or control of 1011 YOUR current or former employee Mr. Itoh or Ito collected during his tenure with YOUR 12 Department of Corporate Social Responsibility 13 REQUEST FOR PRODUCTION NO 7 14 DOCUMENT IDENTIFYING the surviving families of deceased workers at the 15 Kanzaki Plant located in Amagasaki City Japan who YOU have knowledge have developed 16 mesothelioma including but not limited to all those former employees YOU have compensated 17 for mesothelioma 1818 REQUEST FOR PRODUCTION NO 8 19 DOCUMENT IDENTIFYING all persons who YOU have compensated for 1920 developing mesothelioma who lived in Amagasaki City Japan during the years the Kanzaki 2121 Plant produced containing products 2222 REQUEST FOR PRODUCTION NO 9 2222 DOCUMENT IDENTIFYING all persons who YOU have been requested to 2424 compensate for developing mesothelioma who lived in Amagasaki City Japan during the years 2525 the Kanzaki Plant produced containing products 2626 /// 2727 /// 2828 6 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 REQUEST FOR PRODUCTION NO 10 2 DOCUMENT RELATING to all former employee deaths since 1978 including 3 approximately 75 workers from YOUR Kanzaki Japan factory and approximately 4 4 subcontractors who had been employed at the same facility | 5 REQUEST FOR PRODUCTION NO 11 6 DOCUMENT RELATING to the health of approximately 552 other workers from 7 YOUR Kanzaki Japan factory who were directly involved in the manufacture of asbestos pipes 8 for a minimum of one year at any time from 1962 through 1975 | 9 REQUEST FOR PRODUCTION NO 12 1010 All DOCUMENTS from 1962 through 1975 reflecting the approximate 240,000 tons of 11 asbestos used at the Kanzaki plant in the production of asbestos water pipes and building 12 materials the majority of fiber consumed was crocidolite 13 REQUEST FOR PRODUCTION NO 13 14 ALL DOCUMENT RELATING to THEY TYPE OF FIBER USED AT THE Kanzaki 1515 plant in the production of asbestos water piped at any time from 1962 through 1975 16 REQUEST FOR PRODUCTION NO 14 17 All DOCUMENTS and INFORMATION uncovered during KUBOTA'S investigation of 17 a mesothelioma epidemic in the neighborhood around its own former ASBESTOS- 1919 CONTAINING pipe manufacturing plant 2020 REQUEST FOR PRODUCTION NO 15 21 All DOCUMENTS internal corporate DOCUMENTS and interviews conducted 222 created or discovered as a result of Kubota Shock 2323 REQUEST FOR PRODUCTION NO 16 2424 2525 2626 2727 All DOCUMENTS you produced to any third party after the June 29 2005 announcement concerning your use of asbestos at the Kansaki Asbestos Cement Pipe plant from 1962 through 1975 2828 7 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 5681421 REQUEST FOR PRODUCTION NO 17 2 All DOCUMENTS CONCERNING the 1960 Japanese Pneumoconiosis Act 3 REQUEST FOR PRODUCTION NO 18 4 All DOCUMENTS CONCERNING the 1975 Japanese Ordinance on Prevention of 5 Hazards Caused by Specific Chemical Substances 6 REQUEST FOR PRODUCTION NO 19 7 All DOCUMENTS containing information regarding how many workers compensation 8 claims YOU have received relating to an asbestos disease 9 REQUEST FOR PRODUCTION NO 20 10 All DOCUMENTS containing information regarding when YOU first received a 11 workers compensation claim relating to an asbestos disease 12 REQUEST FOR PRODUCTION NO 21 13 All DOCUMENTS containing information regarding any workers compensation claims 14 relating to an asbestos disease YOU have received 15 REQUEST FOR PRODUCTION NO 22 16 All DOCUMENTS containing information regarding YOUR knowledge of HAZARDS 17 ASSOCIATED WITH ASBESTOS EXPOSURE and CONTAINING 18 MATERIAL 19 REQUEST FOR PRODUCTION NO 23 20 All DOCUMENTS containing information regarding when YOU first learned about the . 21 HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE 22 REQUEST FOR PRODUCTION NO 24 23 All DOCUMENTS containing information regarding YOUR membership in any 24 organization that discussed the HAZARDS ASSOCIATED WITH EXPOSURE TO 25 ASBESTOS 26 It 27 28 8 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 REQUEST FOR PRODUCTION NO 25 2 All DOCUMENTS containing information CONCERNING any precautions YOU took 3 to protect YOUR employees from HAZARDS ASSOCIATED WITH EXPOSURE TO 4 ASBESTOS 5 REQUEST FOR PRODUCTION NO 26 6 All DOCUMENTS concerning the use of protective respiratory equipment by employees 7 at all of your asbestos cement pipe manufacturing facilities from 1962 through 1975 8 REQUEST FOR PRODUCTION NO 27 9 All DOCUMENTS containing information CONCERNING any research reviewed by 10 YOU CONCERNING what knowledge CONSUMERS of CONTAINING 11 MATERIALS YOU MANUFACTURED possessed CONCERNING the HAZARDS 1012 ASSOCIATED WITH ASBESTOS EXPOSURE 13 REQUEST FOR PRODUCTION NO 28 14 All DOCUMENTS containing information CONCERNING any research reviewed by 15 YOU CONCERNING what knowledge VOSS possessed CONCERNING the HAZARDS 1616 ASSOCIATED WITH ASBESTOS EXPOSURE from CONTAINING 17 MATERIALS YOU MANUFACTURED at any time 18 REQUEST FOR PRODUCTION NO 29 1819 All DOCUMENTS CONCERNING YOUR contention if YOU so contend that Bobby 20 Evans received WARNINGS CONCERNING HAZARDS ASSOCIATED WITH ASBESTOS 2021 EXPOSURE CONCERNING CONTAINING PRODUCTS YOU manufactured | 22 REQUEST FOR PRODUCTION NO 30 2323 All DOCUMENTS CONCERNING any IDENTIFICATION MARKINGS on 222200 CONTAINING MATERIALS that you SUPPLIED to VOSS at any time 222200 /// 2 0222200 222200 222200 9 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 5681421 REQUEST FOR PRODUCTION NO 31 2 All DOCUMENTS containing information concerning any WARNINGS about the 3 HAZARDS RELATED TO ASBESTOS EXPOSURE YOU provided with the ASBESTOS- 4 CONTAINING MATERIAL YOU SOLD at any time from 1962 through 1975 5 REQUEST FOR PRODUCTION NO 32 6 All DOCUMENTS concerning any asbestos WARNINGS that YOU placed on 7 any packaging or product itself associated with CONTAINING MATERIAL at any 8 time 9 REQUEST FOR PRODUCTION NO 33 10 All DOCUMENTS concerning any WARNINGS that YOU provided with YOUR sales 1011 of CONTAINING MATERIAL at any time from 1962 through 1975 12 REQUEST FOR PRODUCTION NO 34 1213 All DOCUMENTS related to any WARNINGS provided that YOU provided with YOUR 14 sales of CONTAINING MATERIAL to VOSS at any time from 1962 through 1515 1975 1616 REQUEST FOR PRODUCTION NO 35 1717 All DOCUMENTS related to any WARNINGS that YOU provided with YOUR sales of 1818 CONTAINING MATERIAL provided to the Los Angeles Department of Water 1919 and Power at any time from 1962 1975 2020 REQUEST FOR PRODUCTION NO 36 2121 All DOCUMENTS containing information CONCERNING any research performed by 2222 YOU of the CONSUMERS response to any WARNINGS that may have CONCERNED 2323 CONTAINING PRODUCTS YOU manufactured at any time from 1962 through 2424 1975 2525 /// 2626 /// 2727 2828 10 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 1 REQUEST FOR PRODUCTION NO 37 2 All DOCUMENTS reviewed by YOU CONCERNING CONSUMERS responses to any 3 WARNINGS that may have CONCERNED CONTAINING PRODUCTS YOU 4 manufactured at any time from 1962 through 1975 5 REQUEST FOR PRODUCTION NO 38 6 All DOCUMENTS containing information CONCERNING any research performed by 7 YOU of VOSS's actions in response to any WARNINGS that may have CONCERNED 8 CONTAINING PRODUCTS YOU manufactured at any time from 1962 through 9 1975 1010 REQUEST FOR PRODUCTION NO 39 11 11 All DOCUMENTS containing information CONCERNING VOSS's actions in response 1212 to any WARNINGS that may have CONCERNED CONTAINING PRODUCTS 1313 13 YOU manufactured that YOU are aware of at any time from 1962 through 1975 1414 REQUEST FOR PRODUCTION NO 40 1515 All DOCUMENTS CONCERNING YOUR statement made in response to Plaintiff's 16 form interrogatories that Manville asbestos fiber bags sold to Japan did not have 17 WARNINGS until 1977 17 18 REQUEST FOR PRODUCTION NO 41 19 All DOCUMENTS containing information CONCERNING any product safety testing 2020 performed by YOU at any time CONCERNING the CONTAINING MATERIALS 2222222 YOU SUPPLIED to VOSS 22222222 REQUEST FOR PRODUCTION NO 42 22222222 All DOCUMENTS containing information CONCERNING any product safety testing 2424 performed by an entity or person other than YOU reviewed by YOU CONCERNING the 2525 CONTAINING MATERIALS YOU SUPPLIED to VOSS at any time 2626 /// 228228 /// 228228 11 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 1 REQUEST FOR PRODUCTION NO 43 2 All DOCUMENTS in your possession containing information CONCERNING any 3 testing CONCERNING asbestos fiber release from ASBESTOS CEMENT PIPE 4 REQUEST FOR PRODUCTION NO 44 5 All DOCUMENTS containing information CONCERNING any research performed by 6 YOU of how CONTAINING PRODUCTS you manufactured where being used by 7 CONSUMERS at any time from 1962 through 1975 8 REQUEST FOR PRODUCTION NO 45 9 All DOCUMENTS you reviewed containing information CONCERNING how 10 CONTAINING PRODUCTS you manufactured where being used by 11 CONSUMERS at any time from 1962 through 1975 12 REQUEST FOR PRODUCTION NO 46 13 All DOCUMENTS containing information CONCERNING the asbestos fiber release that 14 occurred when CONTAINING MATERIALS YOU manufactured and supplied to 15 VOSS were cut with a power saw at any time from 1962 through 1975 16 REQUEST FOR PRODUCTION NO 47 1 17 All DOCUMENTS CONCERNING the SUPPLIER of ASBESTOS to YOU used in 18 the MANUFACTURING of CONTAINING MATERIALS YOU SUPPLIED to 19 VOSS at any time from 1962 through 1975 2020 REQUEST FOR PRODUCTION NO 48 21 21 All DOCUMENTS IDENTIFYING WORKSITES where VOSS supplied ASBESTOS- 2222 CONTAINING MATERIALS you MANUFACTURED at any time from 1962 through 1975 2323 REQUEST FOR PRODUCTION NO 49 2424 All DOCUMENTS CONCERNING the physical appearance of KUBOTA asbestos 2525 cement pressure pipe that you SUPPLIED to VOSS at any time from 1962 through 1975 2626 /// 2727 2828 12 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 1 REQUEST FOR PRODUCTION NO 50 - 2 All DOCUMENTS CONCERNING the type of asbestos fiber contained in ASBESTOS- 3 CONTAINING MATERIALS that you SUPPLIED to VOSS at any time from 1962 through | 4 1975 5 REQUEST FOR PRODUCTION NO 51 6 All DOCUMENTS CONCERNING the chemical composition of ASBESTOS- 7 CONTAINING MATERIALS that you SUPPLIED to VOSS at any time from 1962 through 8 1975 9 REQUEST FOR PRODUCTION NO 52 10 10 All DOCUMENTS CONCERNING the percentage of asbestos contained in 11 11 CONTAINING MATERIALS that you SUPPLIED to VOSS at any time from 1962 12 12 through 1975 1313 REQUEST FOR PRODUCTION NO 53 14 14 All DOCUMENTS containing information regarding YOUR SALE of ASBESTOS- 15 15 CONTAINING MATERIAL to VOSS at any time 16 16 REQUEST FOR PRODUCTION NO 54 17 17 Any DOCUMENTS concerning any distribution agreements YOU entered into with 18 18 VOSS regarding the SALE of CONTAINING MATERIAL at any time from 1962 1919 1975 20 20 REQUEST FOR PRODUCTION NO 55 21 21 All DOCUMENTS containing information CONCERNING any and all agreements you 2222 had with VOSS regarding the SUPPLY of CONTAINING MATERIALS in Los 2323 Angeles County CA anytime from 1962 through 1975 2424 REQUEST FOR PRODUCTION NO 56 2525 All DOCUMENTS containing information concerning VOSS SALE of ASBESTOS- 2626 CONTAINING MATERIAL to Los Angeles Department of Water and Power of Los Angeles 2727 CA at any time from 1962 through 1975 28 28 13 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 1 REQUEST FOR PRODUCTION NO 57 2 All DOCUMENTS reflecting any correspondence between YOU and VOSS at any time 3 from 1962 to1975 4 REQUEST FOR PRODUCTION NO 58 5 All DOCUMENTS CONCERNING any statements made by former Voss employee 6 Robert Arbizo 7 REQUEST FOR PRODUCTION NO 59 8 All DOCUMENTS CONCERNING any testimony under oath made by former Voss 9 employee Robert Arbizo 10 10 REQUEST FOR PRODUCTION NO 60 11 11 All DOCUMENTS CONCERNING any statements made by former Voss employee 12 12 Bonifacio Lesso 13 13 REQUEST FOR PRODUCTION NO 61 14 14 All DOCUMENTS CONCERNING any testimony under oath made by former Voss 15 15 employee Bonifacio Lesso 16 16 REQUEST FOR PRODUCTION NO 62 17 17 All DOCUMENTS CONCERNING any testimony under oath made by former Voss 18 18 employee Randall Waters 19 19 REQUEST FOR PRODUCTION NO 63 2020 All DOCUMENTS CONCERNING any statements made by former Voss employee 21 21 Randall Waters 22 22 REQUEST FOR PRODUCTION NO 64 2323 All DOCUMENTS CONCERNING any communication between YOU and Mr. A.H. 24 24 Voss concerning use of respirators by workers cutting asbestos cement pipe 2525 REQUEST FOR PRODUCTION NO 65 2626 All DOCUMENTS CONCERNING any communication between YOU and Mr. A.H. 2727 Voss concerning use of eye protection by workers cutting asbestos cement pipe 2828 14 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 1 REQUEST FOR PRODUCTION NO 66 2 All DOCUMENTS CONCERNING any communication between YOU and Mr. A.H. 3 Voss concerning use of gloves by workers cutting asbestos cement pipe 4 REQUEST FOR PRODUCTION NO 67 5 All DOCUMENTS CONCERNING the testimony of A.H. Voss to the International 6 Trade Commission 7 REQUEST FOR PRODUCTION NO 68 8 All DOCUMENTS containing information that supports YOUR contention if YOU so 9 contend that Bobby Evans was not exposed to asbestos from CONTAINING 1010 PRODUCTS that YOU MANUFACTURED 11 REQUEST FOR PRODUCTION NO 69 1212 All DOCUMENTS RELATING to asbestos currently in the possession or control of 1313 YOUR Department of Corporate Social Responsibility 1414 REQUEST FOR PRODUCTION NO 70 1515 All DOCUMENTS containing information regarding YOUR corporate history 1616 REQUEST FOR PRODUCTION NO 71 1717 All DOCUMENTS containing information regarding YOUR DOCUMENT 1818 RETENTION POLICY 1919 REQUEST FOR PRODUCTION NO 72 222222 All DOCUMENTS containing information regarding the IDENTITIES of any officers or 222222 directors of YOUR company over the last five years 222222 2323 2424 Dated February 2 2010 2525 LEVIN SIMES GORNICK LLP 2626 2727 Scott Hames \ r Attorneys for Plaintiffs 2828 15 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1 PROOF OF SERVICE 2 I certify that I am over the age of 18 years and not a party to the within action that my business address is 44 Montgomery St. 36th Floor San Francisco CA 94104 and that on the 3 date last written I served a true copy of the document entitled 4 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 5 Service was effectuated by forwarding the above document in the following manner 6 XX By Regular Mail in a sealed envelope addressed as noted below with postage fully 8 prepaid and placing it for collection and mailing following the ordinary business practices of Levin Simes Kaiser & Gornick LLP 9 THOMAS C. CORLESS ESQ 10 AIDE C. ONTIVEROS ESQ 11 WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP 555 S. FLOWER STREET SUITE 2900 22 LOS ANGELES CA 90071 22 ] 14 By Facsimile to the number as noted below by placing it for facsimile transmittal following the ordinary business practices of Levin Simes Kaiser & Gornick LLP 15 [ 16 ] 17 18 [ 22222 22222 By Hand Delivery in a sealed envelope addressed as noted below through services provided by WorldWide Messenger and billed to Levin Simes Kaiser & Gornick LLP By Overnight Courier in a sealed envelope addressed as noted below through services provided by Federal Express UPS and billed to Levin Simes Kaiser & Gornick LLP On the date executed below I electronically served the document via LexisNexis File & Serve on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website 22222 I certify under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this proof of service was executed on February , 2010 at 22222 San Francisco California 22222 Bahn 24 Liza | Barton Paralegal 25 26 Rhoda Evans et vs. A. W. Chesterton Company et al Los Angeles County Superior Court Case No. BC418867 27 28 16 PLAINTIFFS REQUESTS FOR PRODUCTION TO DEFENDANT KUBOTA CORPORATION 568142 1