Document g2eJNdEQpxrYMbXLqZKQ5GEZL

'"I' I 1 SEDGWICK, DETERT, MORAN & ARNOLD ROGER W. SLEIGHT MICHAEL G. ORNSTIL 2 STEVEN X. SCHWENK 3 3 One Embarcadero Center, 16th Floor San Francisco, California 94111-3765 4 Telephone: (415) 781-7900 5 Attorneys for Defendant GENERAL ELECTRIC COMPANY 6 .Otter ^7 0 PM .T&AfD EflAYTON & ASSOCIATES APR i111991 RECEIVED W&DEF Mi. J*- 7 8 IN THE SUPERIOR COURT OF THE STATE OF CALIF'f)P$CaA 9 IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 11 GALAN STEGEMAN, 12 Plaintiff, 13 v. 14 ABEX CORPORATION, et al., 15 Defendants. 16 ) NO. 924565 ) ) DEFENDANT GENERAL ELECTRIC ) COMPANY'S RESPONSE TO ) PLAINTIFF'S INTERROGATORIES ) ]) ) PLAINTIFF'S ) EXHIBIT ) GE-4 1. 17 PROPOUNDING PARTY Plaintiff GALAN STEGEMAN 16 RESPONDING PARTY Defendant GENERAL ELECTRIC COMPANY 19 SET NUMBER ONE 20 GENERAL ELECTRIC COMPANY ("GE") responds to plaintiffs 21 first set of interrogatories as follows: 22 GENERAL OBJECTIONS 23 The General Objections set forth below are applicable 24 to the interrogatories in their entirety as well as to each 25 individual interrogatory. By this reference, GE incorporates 26 each General Objection into its objections to the individual *T 0 >1*6 r0*ft TC* 1 interrogatories. 1. GE objects to the interrogatories on the ground 2 3 that they seeks information that is irrelevant and not reasonably 4 calculated to lead to the discovery of admissible evidence. The 5 information sought pursuant to the interrogatories principally 6 relates either to GE's asbestos-containing electrical cable or to 7 asbestos-containing products in general. 8 Although plaintiff, in both his complaint an/i 9 interrogatory answers, identifies numerous asbestos-containing 10 products to which he claims he was exposed, he has failed to 11 specifically identify a single GE-manufactured 12 asbestos-containing product. In fact, in his interrogatory- 13 answers, plaintiff has not claimed exposure to 14 asbestos-containing electrical cable. He has only claimed 15 exposure to asbestos-containing electrical wire. Thus, any 16 information relating to asbestos-containing electrical cable, 17 circuit breakers, control boxes, switchboard and motors is 18 irrelevant. - 19 2. GE objects to the interrogatories on the grounds 20 that they are overbroad and unduly burdensome and oppressive. As 21 noted above, plaintiff has failed to identify a single 22 asbestos-containing product manufactured by GE to which he was 23 exposed and to require GE to undertake an extensive and 24 exhaustive search for information under such circumstances is an 25 abuse of the discovery process. 26 3. GE is a large, decentralized corporation whose \T, 0 HMQ 'ION* NTC 2. 4*1520 product and service business undergo constant change and growth. 1 Due to its size and the fact that it has facilities in numerous 2 3 states and foreign countries, there is no central repository for 4 information of the type sought by way of the instant 5 interrogatories. Due to the nature of the interrogatories, the only way to attempt to answer them is to review documents and 6 7 collate the information contained in said documents. As 8 previously explained to plaintiff's counsel, GE no longer has or 9 never had many of the documents required to answer these 10 interrogatories. Moreover, in light of the breadth of 11 plaintiff's inquiries and the fact that information is sought 12 dating back to 1950, it is essentially impossible for defendant 13 to conduct a complete search for the information sought. 14 Additionally, even a limited search will be extremely 15 time-consuming and costly. 16 4. GE no longer manufactures wire and cable and its 17 wire and cable operations ceased years ago. This fact, coupled 18 with the fact that old documents that may have been discarded, 19 lost or misplaced are needed to respond to these interrogatories, 20 makes it virtually impossible to locate and provide the 21 information requested. 22 5. GE objects to these interrogatories on the ground 23 that they assume the truth of matters not established and seek 24 information or materials which have been gathered or prepared in 25 anticipation of litigation or which are otherwise subject to the 26 attorney-client privilege or the attorney work product privilege. IT 0 >NO rtCNs : ure* 3. 44S2o \I 1 RESPONSE TO INTERROGATORY NO. 1: . GE objects to this interrogatory on the grounds that it 2 is vague and ambiguous with respect to the phrase "heat and flame 3 4 resistant cable." GE further objects to this interrogatory on 5 the grounds that it is overbroad, unduly burdensome and 6 oppressive and seeks information that is irrelevant and not 7 reasonably calculated to lead to the discovery of admissible B evidence insofar as absolutely no geographic limitations are 9 placed on the scope of the inquiry and absolutely no evidence 10 exists that plaintiff's decedent worked with GE's 11 asbestos-containing cable. In fact, in plaintiff's interrogatory 12 answers, he lists numerous asbestos-containing products to which 13 he may have been exposed. Asbestos-containing cable is not on 14 plaintiff's list. 15 Notwithstanding said objections, and without waiving 16 said objections, GE is unable to determine how much 17 asbestos-containing cable it sold, if any, to be provided to the 18 shipyards in San Francisco at which plaintiff worked, or how much 19 asbestos-containing cable it sold to the U.S. Government during 20 the relevant time period. 21 RESPONSE TO INTERROGATORY NO. 2: 22 See Response to Interrogatory No. 1, above. 23 RESPONSE TO INTERROGATORY NO. 3: 24 See Response to Interrogatory No. 1, above. 25 RESPONSE TO INTERROGATORY NO. 4: 26 See Response to Interrogatory No. 1, above. IT. 0 >N :ntc* 4. 44520 1 RESPONSE TO INTERROGATORY NO. 5: 2 See Response to Interrogatory No. 1, above. 3 RESPONSE TO INTERROGATORY NO. 6 : 4 See Response to Interrogatory No. 1, above. 5 RESPONSE TO INTERROGATORY NO. 7 : 6 GE objects to this interrogatory on the grounds that it 7 is vague and ambiguous with respect to the phrase 8 "asbestos-containing cable other than heat and flame resistant 9 cable." All asbestos-containing cable is resistant to heat and 10 flame to a degree and thus, this interrogatory is 11 unintelligible. GE further objects to this interrogatory on the 12 grounds that it is overbroad, unduly burdensome and oppressive 13 and seeks information that is irrelevant and not reasonably 14 calculated to lead to the discovery of admissible evidence as 15 absolutely no geographic limitations are placed on the scope of 16 the inquiry and absolutely no evidence exists that plaintiff 17 worked with GE asbestos-containing cable. In fact, in 18 plaintiff's interrogatory answers, he lists numerous 19 asbestos-containing products to which he was allegedly exposed. 20 Asbestos-containing cable is not on plaintiff's list. 21 Notwithstanding said objections, and without waiving 22 said objections, GE is unable to determine the amount of 23 asbestos-containing cable, if any, it sold to be provided to the 24 shipyards in which plaintiff's decedent worked or sold to the 25 U.S. Government during the relevant time period. 26 Ill IT. D >|C no** NTC 5. 44S2o 1 RESPONSE TO INTERROGATORY NO. 8: See Response to Interrogatory No. 7, above. 2 RESPONSE TO INTERROGATORY NO. 9: 3 4 See Response to Interrogatory No. 7, above. 5 RESPONSE TO INTERROGATORY NO. 10: 6 GE objects to this interrogatory as vague and ambiguous 7 with respect to the term "promoted." GE further objects to this 8 interrogatory on the grounds that it seeks information, that is 9 irrelevant and not reasonably calculated to lead to the discovery 10 of admissible evidence. 11 Notwithstanding said objections, and without waiving 12 said objections, GE has not been able to locate any records that 13 reflect the existence, if any, of a California sales office that 14 sold heat and flame resistant cable during the relevant time 15 period. 16 RESPONSE TO INTERROGATORY NO. 11: ` 17 See Response to Interrogatory No. 10, above. 18 RESPONSE TO INTERROGATORY NO, 12: .. 19 See Response to Interrogatory No. 10, above. 20 RESPONSE TO INTERROGATORY NO. 13; 21 See Response to Interrogatory No. 10, above. GE 22 further objects to this interrogatory to the extent it seeks 23 privileged and confidential information. 24 RESPONSE TO INTERROGATORY NO. 14: 25 See Response to Interrogatory Nos. 10 and 13, above. 26 /// IT. 6. 44520 1 RESPONSE TO INTERROGATORY NO- 15: 2 See Response to Interrogatory Nos. 10 and 13, above. 3 RESPONSE TO INTERROGATORY NO. 16: 4 GE objects to this interrogatory on the grounds that it 5 seeks information that is irrelevant and not reasonably 6 calculated to lead to the discovery of admissible evidence. See 7 Response to Interrogatory Nos. 1 and 10, above. 8 Notwithstanding said objections, and without, waiving 9 said objections, GE has not been able to locate documents which 10 reflect the existence of California distributors of GE 11 asbestos-containing heat and flame resistant cable, if any, 12 during the period January 1, 1950 to December 31, 1959. 13 RESPONSE TO INTERROGATORY NO. 17: 14 See Response to Interrogatory No. 16, above. 15 Notwithstanding said objections, and without waiving 16 said objections, Gibson Supply Co. may have been a distributor of 17 GE asbestos-containing heat and flame resistant cable during the 18 period January 1, 1960 to December 31, 1969. .. 19 RESPONSE TO INTERROGATORY NO. 18: 20 See Response to Interrogatory No. 16, above. 21 Notwithstanding said objections, and without waiving 22 said objections, Graybar Oakland, Graybar San Jose, Graybar San 23 Francisco and Phillips and Ober may have been distributors of GE 24 asbestos-containing wire and cable during the period January 1, 25 1970 to December 31, 1979. 26 /// IT. O ni0 HT%* 7. 44520 RESPONSE TO INTERROGATORY NO. 19: 1 GE objects to this interrogatory on the grounds that it 2 3 seeks information that is confidential and privileged. 4 Notwithstanding said objections and without waiving said 5 objections, GE has been unable to locate any records indicating 6 who held the position of Vice President, Marketing, of the Wire 7 and Cable Division as of December 31, 1969. 8 RESPONSE TO INTERROGATORY NO. 20: . 9 See Response to Interrogatory No. 19, above. 10 Notwithstanding said objections, and without waiving said 11 objections, GE has been unable to locate any records indicating 12 who held the position of Vice President, Marketing, of the Wire 13 and Cable Division as of December 31, 1979. 14 RESPONSE TO INTERROGATORY NO. 21; 15 GE objects to this interrogatory on the grounds that it 16 is vague, ambiguous, overbroad, unduly burdensome and oppressive, 17 and seeks information that is irrelevant and not reasonably 18 calculated to lead to the discovery of admissible evidence. 19 Notwithstanding said objections, and without waiving said 20 objections, GE has not been able to locate any sales records 21 relating to the shipyards in which plaintiff worked during the 22 relevant time period. 23 RESPONSE TO INTERROGATORY NO. 22: 24 See Response to Interrogatory No. 21, above. GE has no 25 information as to whether any such records ever existed or if 26 they did exist at some point in time, whether they were IT. 8. 44520 subsequently lost, misplaced or discarded. 1 RESPONSE TO INTERROGATORY NO. 23i 2 See Response to Interrogatory No. 21, above. 3 4 RESPONSE TO INTERROGATORY NO. 24: See Response to Interrogatory No. 22, above. 5 .6 RESPONSE TO INTERROGATORY NO. 25: 7 GE objects to this interrogatory on the grounds that it 8 is vague and ambiguous, overbroad and seeks information that is 9 irrelevant and not reasonably calculated to lead to the discovery 10 of admissible evidence. Notwithstanding said objections, and 11 without waiving said objections, GE has not been able to locate 12 any photographs and/or catalog representations depicting the type 13 of asbestos-containing cable suitable for shipboard use, if any, 14 that was used at the shipyards at which plaintiff worked during 15 the relevant time period. GE's investigation is continuing. It 16 should be noted that plaintiff has not identified any GE cable 17 that plaintiff worked with and excluded cable from the list of 18 asbestos-containing products to which he was allegedly exposed. 19 RESPONSE TO INTERROGATORY NO. 26: 20 See Response to Interrogatory No. 25, above. 21 RESPONSE TO INTERROGATORY NO. 27t 22 See Response to Interrogatory No. 25, above. 23 RESPONSE TO INTERROGATORY NO. 28: 24 See Response to Interrogatory No. 25, above. 25 RESPONSE TO INTERROGATORY NO. 29: 26 See Response to Interrogatory No. 25, above. T. 9. 44520 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 .AW OFFICES SEDCWrCK. DETEST MORAN & ARNOLD A iNCLUO'Np `O'CSSrOHAi. ONC CMAAftCAOCftO Crca 1TH 00 SA* rftANCJSCC (4 > 51 *$ RESPONSE TO INTERROGATORY NO. 30: See Response to Interrogatory No. 25, above. RESPONSE TO INTERROGATORY NO. 31: GE objects to this interrogatory on the grounds that it is overbroad, unduly burdensome and oppressive, and seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff has not identified any GE cable that he was exposed to and failed to include cable on his list of asbestos-containing products to which he was allegedly exposed. Unless and until an identification is made, GE is unable to respond to this interrogatory. RESPONSE TO INTERROGATORY NO. 32: See Response to Interrogatory No. 31, above. RESPONSE TO INTERROGATORY NO. 33: See Response to Interrogatory No. 31, above. RESPONSE TO INTERROGATORY NO. 34i GE objects to this interrogatory on the grounds that it is vague, ambiguous and unintelligible. GE further objects to this interrogatory on the grounds that it is overbroad and seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. GE further objects to this interrogatory insofar as it assumes facts not in evidence. Unless and until plaintiff identifies what type of GE cable, if any, he was exposed to, GE cannot respond to this interrogatory. GE notes, however, that many of its cable 10. 44$2o products were built to government specifications which are part 1 of the public record and equally available to plaintiff. 2 3 RESPONSE TO INTERROGATORY NO. 35; 4 GE objects to this interrogatory on the grounds that it 5 is overbroad, unduly burdensome and oppressive, and seeks 6 information that is irrelevant and not reasonably calculated to 7 lead to the discovery of admissible evidence. GE further objects to this interrogatory insofar as it assumes facts not .in 8 9 evidence. Notwithstanding said objections, and without waiving 10 said objections, GE has not been able to locate any records 11 reflecting from whom it purchased asbestos from for use in GE's 12 asbestos-containing heat and flame resistant cable during the 13 relevant time period. GE's investigation is continuing. 14 RESPONSE TO INTERROGATORY NO. 36: 15 GE objects to this interrogatory on the grounds that it 16 is vague and ambiguous with respect to the phrase 17 "asbestos-containing material" and is unintelligible. See 18 Response to Interrogatory No. 35, above. ~ 19 RESPONSE TO INTERROGATORY NO. 37; *. 20 GE objects to this interrogatory on the grounds that it 21 is vague, ambiguous, overbroad, unduly burdensome and oppressive, 22 harassing, seeks information that is irrelevant and not 23 reasonably calculated to lead to the discovery of admissible 24 evidence, and seeks information that is equally available to 25 plaintiff. . 26 /// IT. 0 >i*6 'OHl *T* 11. 4452o RESPONSE TO INTERROGATORY NO. 38: 1 2 GE objects to this interrogatory on the grounds that it 3 is overbroad, unduly burdensome and oppressive, and seeks 4 information that is irrelevant and not reasonably calculated to 5 lead to the discovery of admissible evidence. Unless and until 6 plaintiff specifies which GE asbestos-containing cable, if any, 7 he was exposed to, GE is unable to respond to this interrogatory. 8 RESPONSE TO INTERROGATORY NO. 39: . 9 See Response to Interrogatory No. 38, above. 10 RESPONSE TO INTERROGATORY NO. 40: 11 GE objects to this interrogatory on the grounds that it 12 seeks information that is irrelevant and not reasonably 13 calculated to lead to the discovery of admissible evidence. GE 14 further objects to this interrogatory on the grounds that it 15 assumes facts not in evidence. Plaintiff has not claimed that he 16 was exposed to asbestos contained in a GE circuit breaker and in 17 fact, has excluded circuit breakers from the list of 18 asbestos-containing products to which he was allegedly exposed. 19 RESPONSE TO INTERROGATORY NO. 41: *- 20 See Response to Interrogatory No. 40, above, which is 21 equally applicable to inquiries regarding switchboards. 22 RESPONSE TO INTERROGATORY NO. 42: 23 See Response to Interrogatory No. 40, above, which is 24 equally applicable to inquiries regarding control boxes. 25 RESPONSE TO INTERROGATORY NO. 43: 26 See Response to Interrogatory No. 40, above, which is IT. D r>o : st(* 12. 44520 1 equally applicable to inquiries regarding motors. 2 RESPONSE TO INTERROGATORY NO. 44: 3 GE objects to this interrogatory on the grounds that it 4 seeks information that is irrelevant and not reasonably 5 calculated to lead to the discovery of admissible evidence. 6 Notwithstanding said objections, and without waiving said 7 objections, GE believes it ceased the manufacture of 8 asbestos-containing heat and flame resistant Navy cable in 1962. 9 GE's investigation is continuing. 10 RESPONSE TO INTERROGATORY NO. 45; 11 GE objects to this interrogatory on the grounds that it 12 is vague and ambiguous with respect to the phrase "heat and flame 13 resistant cable" and seeks information that is irrelevant and not 14 reasonably calculated to lead to the discovery of admissible 15 evidence. 16 RESPONSE TO INTERROGATORY NO. 46: 17 GE objects to this interrogatory on the grounds that it 18 is overbroad as to time and assumes facts not in- evidence. 19 Notwithstanding said objections, and without waiving said 20 objections, GE has no reports or studies concluding that its 21 asbestos-containing cable posed any health dangers. 22 RESPONSE TO INTERROGATORY NO. 47: 23 See Response to Interrogatory No. 46, above. 24 RESPONSE TO INTERROGATORY NO. 48: 25 GE objects to this interrogatory on the grounds that it 26 is vague, ambiguous, overbroad and seeks information that is (T. D TON* ;NTt* 13. 44520 irrelevant and not reasonably calculated to lead to the discovery 1 2 of admissible evidence. GE further objects to this interrogatory 3 on the ground that it assumes facts not in evidence and is 4 misleading in that it assumes that health hazards from exposure 5 to GE wire and cable products were known or should have been 6 known prior to 1979. 7 Notwithstanding said objections, and without waiving 8 said objections, GE has not been able to locate any documents 9 relating to health hazards caused by exposure to asbestos in GE 10 wire and cable products. Further, GE has not been able to locate 11 any documents reflecting when GE, as a corporate entity, first 12 learned that health hazards may result from the inhalation of 13 asbestos fibers. 14 RESPONSE TO INTERROGATORY NO. 49: 15 GE objects to this interrogatory on the ground that it 16 is misleading as it assumes facts not in evidence and is 17 misleading in that it assumes that health hazards from exposure 18 to GE wire and cable products were known or should have been 19 known prior to 1979. \ 20 GE refers plaintiff to its response to the "most 21 knowledgeable employee" deposition notices served by the Brayton 22 office in the Denison v. Abex case and subsequent correspondence 23 from GE's counsel to the Brayton office indicating the lack of 24 any such witness. 25 Ill 26 III IT. 0 >IN9 TtONft .Nft A 14. 44520 1 RESPONSE TO INTERROGATORY NO. 50: GE objects to this interrogatory on the grounds that it 2 3 seeks information that is irrelevant and not reasonably 4 calculated to the discovery of admissible evidence. GE further 5 objects to this interrogatory insofar as it assumes facts not in 6 evidence. Notwithstanding said objections, and without waiving 7 said objections, GE has not been able to locate any studies 8 concerning the dangers posed to electricians using any. type of GE 9 cable. 10 RESPONSE TO INTERROGATORY NO. 51: 11 See Response to Interrogatory Nos. 46 and 50, above. 12 RESPONSE TO INTERROGATORY NO. 52: 13 See Response to Interrogatory Nos. 46 and 50, above. 14 RESPONSE TO INTERROGATORY NO. 53: 15 See Response to Interrogatory Nos. 46 and 50, above. 16 RESPONSE TO INTERROGATORY NO. 54; 17 See Response to Interrogatory Nos. 46 and 50, above. 18 RESPONSE TO INTERROGATORY NO. 55; - 19 GE objects to this interrogatory on the grounds that it 20 is vague and ambiguous with respect to the term "varnished." 21 Notwithstanding said objections, and without waiving said 22 objections, GE's Type AA wire was saturated and finished with a 23 flame resistant compound. 24 RESPONSE TO INTERROGATORY NO. 56: 25 GE objects to this interrogatory on the grounds that it 26 is vague and ambiguous, assumes facts not in evidence and seeks T. 15. 44520 1 information that is irrelevant and not reasonably calculated to 2 lead to the discovery of admissible evidence. 3 RESPONSE TO INTERROGATORY NO. 57: 4 See Response to Interrogatory No. 56, above. 5 RESPONSE TO INTERROGATORY NO. 58: 6 GE objects to this interrogatory on the grounds that it 7 is overbroad and seeks information that is irrelevant and not 8 reasonably calculated to lead to the discovery of admissible 9 evidence. GE further objects to this interrogatory on the 10 grounds that it seeks information equally available to 11 plaintiff. Notwithstanding said objections, and without waiving 12 said objections, GE believes that it may have had cable products 13 of one specification or another on the Qualified Products List 14 during plaintiff's years of employment. See Response to 15 Interrogatory No. 44, however. 16 RESPONSE TO INTERROGATORY NO. 59: 17 See Response to Interrogatory No. 58, above. 18 RESPONSE TO INTERROGATORY NO. 60; - 19 GE objects to this interrogatory on the grounds that it 20 is vague and ambiguous, overbroad and seeks information that is 21 irrelevant and not reasonably calculated to lead to the discovery 22 of admissible evidence. As phrased, GE is unable to respond to 23 this interrogatory. 24 RESPONSE TO INTERROGATORY NO. 61: 25 GE objects to this interrogatory on the grounds that it 26 is overbroad and seeks information that is irrelevant and not IT. 16. 44S20 1 reasonably calculated to lead to the discovery of admissible 2 evidence. Notwithstanding said objections, and without waiving 3 said objections, GE believes all of its asbestos-containing wire 4 and cable products contained chrysotile fiber in which all 5 impurities were removed. 6 RESPONSE TO INTERROGATORY NO. 62: 7 See Response to Interrogatory Nos. 55 and 61, above. e RESPONSE TO INTERROGATORY NO. 63; t 9 GE objects to this interrogatory as vague and 10 ambiguous, overbroad, unduly burdensome and oppressive, and seeks 11 information that is irrelevant and not reasonably calculated to 12 lead to the discovery of admissible evidence. Notwithstanding 13 said objections, and without waiving said objections, GE believes 14 all of its cable suitable for shipyard use was saturated. 15 RESPONSE TO INTERROGATORY NO. 64: 16 GE objects to this interrogatory on the grounds that it 17 seeks information which is privileged and confidential. 18 RESPONSE TO INTERROGATORY NO. 65; ~ 19 See Response to Interrogatory No. 64, ab&ve. 20 RESPONSE TO INTERROGATORY NO. 66t 21 22 ill 23 Hi 24 /// See Response to Interrogatory No. 64, above. 25 111 . 26 ill U. s> >IN4 :nti 17. 4d52o 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 IT, RESPONSE TO INTERROGATORY NO. 67: See Response to Interrogatory No. 64, above. Dated: April ^ , 1991. SEDGWICK, DETERT, MORAN & ARNOLD By Michael G. Ornstil Attorneys for Defendant GENERAL ELECTRIC COMPANY 18. 44S2o 1 CERTIFICATE OF SERVICE BY MAIL 2 TITLE; GALAN STEGEMAN v. ABEX CORP., et al. 3 NO.: 924565 COURT: SUPERIOR COUNTY: SAN FRANCISCO 4 I am over 18 years of age and am not a party to the within entitled action. I am employed at and my business address 5 is One Embarcadero Center, 16th Floor, San Francisco, California 94111-3765. On this date, I served the following document(s): 6 7 DEFENDANT GENERAL ELECTRIC COMPANY'S RESPONSE TO PLAINTIFF'S 8 INTERROGATORIES 9 by placing a true copy thereof enclosed in a sealed envelope with 10 postage fully prepaid in the United States mail at San Francisco, California, addressed as shown below. n I declare under penalty of perjury under the laws of 12 the State of California that the foregoing is true and correct. 13 Executed this 16th day of April, 1991, at San Francisco, California. 14 15 16 17 Alan R. Brayton, Esq. BRAYTON St ASSOCIATES 18 999 Grant Avenue P.O. Box 2109 19 Novato, CA 94948 Barbra K. Kearney 20 Charles S. Bishop, Esq. JEDEIKIN, GREEN, SPRAGUE & BISHOP 21 300 Montgomery Street, Suite 450 San Francisco, CA 94104 22 Ray Wong, Esq. 23 HANCOCK, ROTHERT & BUNSHOFT Four Embarcadero Center, 10th Floor 24 San Francisco, CA 94111-4168 25 26 :s rear. OLD MAtlONt CKNru 45520