Document NEMLpwD5z6yzaojbZGGmx1x3R

FILE NAME Kubota KUB DATE 2007 DOC KUB018 DOCUMENT DESCRIPTION Legal - Notice of Taking Deposition of Kubota 1 JEFFREY A. KAISER ESQ SBN 160594 2 RAYMOND D. MUELLER ESQ SBN 215358 LEVIN SIMES KAISER & GORNICK LLP 3 44 Montgomery St. 36th Floor San Francisco CA 94104 4 Telephone 415 646-7160 Fax 5 415 981-1270 Attorneys for PLAINTIFF 6 CHRIS WEBBER 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES 10 ee 11 1212 13 1414 1515 @ 1616 1717 1818 19 19 CHRIS WEBBER Plaintiffs VS. A.H. VOSS INDIVIDUALLY AND AS SUCCESSOR TO VOSS INTERNATIONAL CORPORATION et al Defendants ) Case No BC 368967 Ne Se NOTICE OF TAKING DEPOSITION OF Seer DEFENDANT KUBOTA CORPORATION Nee INDIVIDUALLY AND AS SUCCESSOR IN ) INTEREST TO KUBOTA IRON AND ) MACHINERY WORKS AND KUBOTA ) AMERICA PERSON MOST ) KNOWLEDGEABLE AND CUSTODIAN OF ) RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION CCP 20172019 AND 2025 NOTICE 2 - PRODUCT SAFETY TESTING TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD 2020 PLEASE TAKE NOTICE that on December 4 2007 at 1:00 p.m. at the offices of Ludwig 2121 222 2 2323 2424 Klein Court Reporters & Video Inc. located at 10868 Kling Street Toluca Lake California 800540-0681 plaintiffs will take the deposition of KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS 2625 2727 { } 28 AND KUBOTA AMERICA KUBOTA who shall designate and produce its Custodian of Records Pursuant to C.C.P. 2025 and 2026 plaintiff in the captioned action requests KUBOTA to bring to the deposition for inspection and copying the documents and things described herein and to make these documents and things available two days prior to the commencement of the Webber.Deposition.PMK.Kubota.PMK2.AmendedWebber.DeposiWebtr.Depositoin.PMK.ubotao.PMK2.Amendn.WebePr.DepMositiKon.PM.K.KubKota.PuMK2.AbmendedoWebter.Depoasition..PMK.KubPota.PMKM2.AmendKed W2eber..DepAositmion.PeMK.Knubotad.PMKe2.Amdended - i - NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 -- PRODUCT SAFETY TESTING wo deposition for plaintiff's review This Notice to Produce specifically embraces documents within the 2 possession custody or control of KUBOTA its agents representatives or attorneys This Notice to 3 Produce also embraces originals identical copies all identical copies whether different from the 4 original because of notes made on such copies or otherwise and other documents described herein 6 The deposition will be recorded both by a certified shorthand reporter and by video and will continue 7 9 10 day to day until completed Ludwig PLEASE TAKE NOTICE that on December 4 2007 at 2:00 p.m. at the offices of Klein Court Reporters & Video Inc. located at 10868 Kling Street Toluca Lake California 800540-0681 plaintiffs will take the deposition of KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS . AND KUBOTA AMERICA KUBOTA through its person most knowledgeable about the matters 1013 set forth in this Notice Said deposition will be recorded both by a certified shorthand reporter and by 1414 and video will continue day to day until completed 15 16 NOTICE IS FURTHER GIVEN that said KUBOTA and deponent is required to produce at said time and place the documents papers books and other things set forth under the Documents 17 Requested section below for copying and examination pursuant to California Code of Civil Procedure 18 Section 2025 19 DEFINITIONS YOU 20 1 21 YOUR or DEFENDANT shall refer to Kubota America Corporation Kubota 22 Iron and Machinery Works Kubota Corporation its officers directors partners 23 24 EMPLOYEES agents joint venturers parent entities predecessors subsidiaries divisions and | contract units 25 2 VOSS shall refer to A.H. Voss Company Voss International Corp. and Voss 26 27| International its officers directors partners EMPLOYEES agents joint venturers parent | entities predecessors subsidiaries divisions and contract units 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Webber.Deposition.PMK.Kubota.PMK2 2084.Weber.Depositon.PMK.ubota.PMK2 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Weber.Deposition.PMK.Kubota.PMK2 Amended 2 NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING 1 2 3 5 6 7 9 10 10 1112 1313 14 3 ASBESTOS CONTAINING MATERIALS shall refer to any and all asbestos pipe ASBESTOS CONTAINING MATERIALS shall refer to any and all asbestos containing pipe CONCERNING herein means demonstrating reflecting evidencing referring to depicting concerning referencing touching upon discussing evidencing describing identifying supporting or resulting from the matter specified including in each instance documents now or previously attached or appended to or used in the preparation of any document called for by each request DOCUMENTS shall mean writing as defined in California Evidence Code 250 which includes without limitation all handwriting typewriting printing photostating photographing and every other means of recording upon any tangible thing any form of communication or representation including catalogs letters words pictures sounds or symbols or combinations thereof This term shall also include mail transmissions and writings stored on all computer- related medium including hard disk drives floppy disk drives Roms and DVDs and will be referred to below as documents EMPLOYEE shall refer to any individual currently or formerly in an employment relationship with DEFENDANT and any individual acting as a corporate officer and serving as a consultant or independent contractor HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE shall refer to the risks of the development of asbestos related lung disease including but not limited to mesothelioma lung cancer asbestosis and pleural plaques 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Webr.Depositon.PMK.ubota.PMK2.Amend 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended -3- NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING 3 4 S 6 8 9 10 11 12 13 14 15 16 17 18 IDENTIFICATION MARKINGS shall refer to any branding logo symbol sign emblem badge insignia indication feature characteristic crest motif and mark IDENTIFY with regard to a person or business means to state his or her or its name her or her place of employment or the business's address his or her job title present business or present or last known home address and present business telephone number 11 IDENTIFY with regards to a DOCUMENT shall mean to state a the author b the addressee c the date of origin d the nature of the writing or document e.g. letter telephone memorandum tape recording photograph etc. and present location and name the present location and present address of the custodian thereof 12 WORKSITES shall include but not be limited all sites located in Los Angeles County CA wherein VOSS supplied ASBESTOS CEMENT PIPE between 1965 and 1967 inclusive 13 RESPIRATORY PROTECTION shall refer to any respiratory protective device including but not limited to full or partial face coverings masks respirators filters cartridges canisters hoses straps air supply systems and linings designed to remove dust fibers ASBESTOS fumes and contaminants from the air 19 20 21 22 23 24 25 26 -27 14. SAFETY MEETING shall refer to any gathering wherein matters concerning occupational safety safety procedures safe work practices and the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE are discussed or information CONCERNING these matters is | disseminated 15. SAFETY PERSONNEL shall refer to individuals trained to identify safety hazards and required to enforce safety regulations and inform EMPLOYEES of safety hazards and safe work practices : 28 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended -4- NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE PRODUCT SAFETY TESTING SUPPLY or SUPPLIED or SUPPLIER shall refer to any entity engaged in selling distributing making available providing leasing or otherwise transferring for value 17. The term SYSTEM OF DISTRIBUTION shall refer to distribution receiving from supplier warehousing shipping delivery and the manner in which all of the before is accomplished 18 The term COMMUNICATION shall refer to any message communiqu^'announcement statement letter phone call memo memorandum note declaration notice proclamation report account assertion publication advertisement whether the communication be made written or verbal via mail or telephone and made first person and through a third party 19 The term CONSUMER shall refer to the ordinary user of the product as referretdo in Jury Instruction 1203 of the Judicial Council of California Advisory Committee on Civil Jury Instructions CACI 20 The term WARNING shall refer to its ordinary meaning as referred to in Jury Instruction 1205 of the Judicial Council of California Advisory Committee on Civil Jury Instructions CACI DOCUMENTS TO BE PRODUCED 1. All DOCUMENTS containing information CONCERNING any product safety testing performed by YOU prior to 1967 CONCERNING the ASBESTOS CONTAINING MATERIALS YOU SUPPLIED to VOSS between the years 1965 and 1967 inclusive 2 All DOCUMENTS containing information CONCERNING any product safety testing performed at YOUR request reviewed by you prior to 1967 CONCERNING the ASBESTOS CONTAINING MATERIALS YOU SUPPLIED to VOSS between the years 1965 and 1967 inclusive 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Webr.Depositon.PMK.ubota.PMK2.Amend 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended S NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING All DOCUMENTS containing information CONCERNING any product safety testing 2 performed by any entity or person other than YOU reviewed by you prior to 1967 3 VOSS CONCERNING the ASBESTOS CONTAINING MATERIALS YOU SUPPLIED to 4 5 between the years 1965 and 1967 inclusive 6 All DOCUMENTS containing information CONCERNING any research performed by YOU being 7 of how ASBESTOS CONTAINING PRODUCTS you manufactured where used by 8 CONSUMERS prior to 1967 inclusive 9 10 All DOCUMENTS containing information CONCERNING any research performed by YOU of how ASBESTOS CONTAINING PRODUCTS you manufactured where being HANDLED by VOSS prior to 1967 inclusive All DOCUMENTS containing information CONCERNING any research performed by YOU of the CONSUMERS response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive All DOCUMENTS containing information CONCERNING any research performed by YOU of VOSS's actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive All DOCUMENTS you reviewed prior to 1967 inclusive containing information CONCERNING how ASBESTOS CONTAINING PRODUCTS you manufactured where being used by CONSUMERS All DOCUMENTS containing information CONCERNING any research reviewed by YOU prior to 1967 inclusive CONCERNING what knowledge CONSUMERS of ASBESTOS CONTAINING MATERIALS YOU MANUFACTURED possessed CONCERNING the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended -6- NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE PRODUCT SAFETY TESTING '2 3 4 5 6 7 8 9 10 11 1210 14 14 16 17 1818 1919 222222 222222 222 232 2 2424 2525 26 2726 ( 28 All DOCUMENTS containing information CONCERNING any research reviewed by YOU prior to 1967 inclusive CONCERNING what knowledge VOSS possessed CONCERNING the HAZARDS ASSOCIATED WITH ASBESTOS EXPOSURE from ASBESTOS CONTAINING MATERIALS YOU MANUFACTURED 11 All DOCUMENTS containing information CONCERNING any research reviewed by YOU of how ASBESTOS CONTAINING PRODUCTS YOU manufactured where being used by VOSS prior to 1967 inclusive 12 All DOCUMENTS reviewed by YOU prior to 1967 inclusive CONCERNING CONSUMERS actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive 13. All DOCUMENTS containing information CONCERNING VOSS's actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured that YOU are aware of prior to 1967 inclusive 14 All DOCUMENTS containing information CONCERNING the asbestos fiber release that occurred when ASBESTOS CONTAINING MATERIALS YOU manufactured and supplied to VOSS prior to 1967 inclusive were cut with a power saw 15 All DOCUMENTS in your possession containing information CONCERNING any testing CONCERNING asbestos fiber release from ASBESTOS CEMENT PIPE 16 All DOCUMENTS in your possession containing information CONCERNING any quality assurance testing CONCERNING ASBESTOS CONTAINING MATERIALS you SUPPLIED to VOSS prior to 1967 inclusive All DOCUMENTS containing information CONCERNING the identitoyfEMPLOYEES who were consulted in the identification of documents for Categories 1-16 of this notice 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Webber.Deposit2i084.Webr.Deopositon.PMK.nubota.PMK2.Am.end P208M4.WebeKr.Depo.sitionK.PMK.Kuubota.bPMK2.Aomendedt2084.Waeber.Dep.ositon.PMPK.ubota.MPMK2.AmenKde 2208.4.WebAer.Dempositeion.PnMK.Kubdota.PeMK2.Admended 7 NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 SAFETY TESTING PRODUCT om 2 3 4 5 6 7 9 1010 1111 1212 1313 14 14 pr PLAINTIFF'S NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS AND KUBOTA AMERICA'S PERSON MOST KNOWLEDGEABLE AND CUSTODIAN OF RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION NOTICE 2 18 All DOCUMENTS containing information CONCERNING YOUR DOCUMENT RETENTION POLICY as it CONCERNS all DOCUMENTS produced in response to Categories 1-16 of this notice PLAINTIFF'S NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS AND KUBOTA AMERICA'S PERSON MOST KNOWLEDGEABLE AND CUSTODIAN OF RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION NOTICE 2 17 18 19 20 2222 2222 23 2222 25 26 27 19. ALL DOCUMENTS you reviewed in preparation for this deposition PERSON MOST KNOWLEDGEABLE KNOWLEDGEABLE 1. All information CONCERNING any product safety testing performed by YOU prior to 1967 CONCERNING the ASBESTOS CONTAINING MATERIALS YOU SUPPLIED to VOSS between the years 1965 and 1967 inclusive 2. All information CONCERNING any product safety testing performed at YOUR request reviewed by you prior to 1967 CONCERNING the ASBESTOS CONTAINING MATERIALS YOU SUPPLIED to VOSS between the years 1965 and 1967 inclusive 3. All information CONCERNING any product safety testing performed by any entity or person other than YOU reviewed by you prior to 1967 CONCERNING the ASBESTOS 2084.Webber 2084.Webber Deposition.PMK.Kubota.PMK2 Deposition.PMK.Kubota.PMK2 Deposition.PMK.Kubota.PMK2 Deposition.PMK.Kubota.PMK2 Amended -&- NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE SAFETY TESTING PRODUCT CONTAINING MATERIALS YOU SUPPLIED to VOSS between the years 1965 and 1967 inclusive 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 4. All information CONCERNING any research performed by YOU of how ASBESTOS CONTAINING PRODUCTS you manufactured where being used by CONSUMERS prior to 1967 inclusive 5. All information CONCERNING any research performed by YOU of how ASBESTOS CONTAINING PRODUCTS you manufactured where being HANDLED by VOSS prior to 1967 inclusive All DOCUMENTS containing information CONCERNING any research performed by YOU of the CONSUMERS response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive All information CONCERNING any research performed by YOU of VOSS's actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive All DOCUMENTS you reviewed prior to 1967 inclusive containing information CONCERNING how ASBESTOS CONTAINING PRODUCTS you manufactured where being used by CONSUMERS 9. All information CONCERNING any research reviewed by YOU prior to 1967 inclusive 2222223 CONCERNING what knowledge CONSUMERS of ASBESTOS CONTAINING MATERIALS 2222223 2222223 YOU MANUFACTURED possessed CONCERNING the HAZARDS ASSOCIATED WITH | _ 2222223 ASBESTOS EXPOSURE 2222223 10. All information CONCERNING any research reviewed by YOU prior to 1967 inclusive 2222223 CONCERNING what knowledge VOSS possessed CONCERNING the HAZARDS 2084.Webber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Webber.Deposition.PMK.Kubota.PMK2.Amended 9 NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING ASSOCIATED WITH ASBESTOS EXPOSURE from ASBESTOS CONTAINING MATERIALS YOU MANUFACTURED 11. All information CONCERNING how ASBESTOS CONTAINING PRODUCTS YOU manufactured where being used by VOSS prior to 1967 inclusive 12. All information knew by YOU prior to 1967 inclusive CONCERNING CONSUMERS actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured prior to 1967 inclusive 13. All information CONCERNING VOSS's actions in response to any warnings that may have CONCERNED ASBESTOS CONTAINING PRODUCTS YOU manufactured that YOU are aware of prior to 1967 inclusive 14. All information CONCERNING the asbestos fiber release that occurred when ASBESTOS CONTAINING MATERIALS YOU manufactured and supplied to VOSS prior to 1967 inclusive were cut with a power saw 15. All information CONCERNING any testing CONCERNING asbestos fiber release from ASBESTOS CEMENT PIPE 16. All information CONCERNING any quality assurance testing CONCERNING ASBESTOS CONTAINING MATERIALS you SUPPLIED to VOSS prior to 1967 inclusive 17. All information CONCERNING the identity of EMPLOYEES who were consulted in the identification of documents CONCERNING Categories 1-19 of this notice PLAINTIFF'S NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS AND KUBOTA AMERICA'S PERSON MOST ) 28 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Webber.Deposition.PMK.Kubota.PMK2 2084.Weber.Deposition.PMK.Kubota.PMK2 2084.Webber.Deposition.PMK.Kubota.PMK2 Amended - 10 - NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE PRODUCT SAFETY TESTING 2 3 4 5 6 7 8 9 10 12 16 18 KNOWLEDGEABLE AND CUSTODIAN OF RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION NOTICE 2 18. All information CONCERNING YOUR DOCUMENT RETENTION POLICY as it CONCERNS all DOCUMENTS produced in response to Categories 1-19 of this notice PLAINTIFF'S NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS AND KUBOTA AMERICA'S PERSON MOST KNOWLEDGEABLE AND CUSTODIAN OF RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT DEPOSITION NOTICE -2 19. All information concerning any DOCUMENTS you reviewed in preparation for this deposition 20. All information concerning any DOCUMENTS requested in Categories 1-19 of the DOCUMENTS TO BE PRODUCED section of this deposition notice 21. All information CONCERNING the identity of EMPLOYEES who were consulted in the identification of documents for Categories PRODUCTION OF DOCUMENTS SET TWO 1-18 of PLAINTIFF'S REQUEST FOR 20 DATED October 17 2007 221 2 LEVIN SIMES KAISER & GORNICK LLP Raymond D. Mueller Attorney for Plaintiff 22 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Webber.Deposition.PMK.Kubota.PMK2.Amended 2084.Webr.Depositon.PMK.ubota.PMK2.Amend 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended - Wi - NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING PROOF OF SERVICE 3 I certify that am over the age of 18 years and not a party to the within action that my business | 4 address is 44 Montgomery St. 36th Floor San Francisco CA 94104 and that on the date last written 65 I served a true copy of the document entitled NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION INDIVIDUALLY AND AS SUCCESSOR IN INTEREST TO KUBOTA IRON AND MACHINERY WORKS AND KUBOTA AMERICA PERSON MOST KNOWLEDGEABLE 8 AND CUSTODIAN OF RECORDS AND REQUEST TO PRODUCE DOCUMENTS AT 9 DEPOSITION CCP 20172019 AND 2025 NOTICE 2 - PRODUCT SAFETY TESTING 10 Service was effectuated by forwarding the above document in the following manner 11 x By Regular and Mail in a sealed envelope addressed as noted below with postage fully prepaid placing it for collection and mailing following the ordinary business practices of Levin 12 Simes Kaiser & Gornick LLP . 13 SEE SERVICE LIST 14 15 16 17 18 19 20 21 [ ] By Hand Delivery in a sealed envelope addressed as noted above through services provided by and billed to Levin Simes Kaiser & Gornick LLP ( ) By Facsimile to the numbers as noted below by placing it for facsimile transmittal following the ordinary business practices of Levin Simes Kaiser & Gornick LLP 1 By Overnight Courier in a sealed envelope addressed as noted above through services provided by Federal Express UPS and billed to Levin Simes Kaiser & Gornick LLP () Electronic service via LexisNexis File & Serve on the recipients designated on the Transaction Receipt located on the LexisNexis File & Serve website I declare under penalty of perjury under the law of the State of California that the foregoing is true and correct Executed on Wednesday October 17 2007 at San Francisco California Thursday 22 23 Amity Armstrong 24 25 26 Chris Webber v AH Voss Company et al LASC BC368967 27 fiwfo ) 28 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.WebrDpositn.PMKubota.PMK2Amend 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended 2084.Weber.Depositon.PMK.ubota.PMK2.Amende 2084.Weber.Deposition.PMK.Kubota.PMK2.Amended - 12 - NOTICE OF TAKING DEPOSITION OF DEFENDANT KUBOTA CORPORATION NOTICE 2 PRODUCT SAFETY TESTING