Klinger

BACKGROUND

The Underlying Lawsuit On April 6, 2012, Shirley Alderete filed a lawsuit against Barney Klinger and approximately 40 other defendants stating claims for asbestos-related injuries (the underlying lawsuit).2 Alderete alleged that her husband worked on various construction projects at which he was exposed to asbestos. One of these projects was at the Schlitz Brewery in Los Angeles, where Alderete‟s husband worked for Klinger as a pipefitter for approximately one month in 1971. Alderete claimed that she became exposed to asbestos through contact with her husband, particularly when she would shake out and launder his dusty, asbestos-laden work clothes after he returned home from work. Alderete‟s husband died of mesothelioma in 2004. In her complaint filed in 2012, Alderete stated that she suffered “from a condition related to exposure to asbestos and asbestos- containing products,” and she sought damages for injuries suffered because of this condition. The complaint in the underlying lawsuit was served on Klinger on April 24, 2012. On May 9, 2012, Klinger‟s attorney, Hillel Chodos, noticed Alderete‟s deposition and requested documents from her. Alderete, through her…