In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3630

DECLARATION of Wedeking in Support re: (157 in 1:04-cv-04973-SAS) MOTION for Summary Judgment for Lack of Evidence Pertaining to Causation.. Document filed by Coastal Chem, Inc.. (Attachments: #1 Exhibit #1, #2 Exhibit #2, #3 Exhibit #3, #4 Exhibit #4, #5 Exhibit #5, #6 Exhibit #6, #7 Exhibit #7, #8 Exhibit #8, #9 Exhibit #9)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:04-cv-04973-SAS(Allen, Brent)

Exhibit 8

37205186

Apr 22 2011
6:17PM

6.

Beneto Inc.

Exxon Mobil Corporation's electronic data for the relevant time period shows that
Beneto Inc., which had a business and delivery address of 4076 Seaport Blvd., West Sacramento,
CA, purchased gasoline from Exxon Corporation from the Fresno terminal from 1993 through
1998. The dates, amounts, and description of the gasoline purchased by Beneto in Fresno during
this time period are set forth in the spreadsheet attached to this Declaration as Exhibit I.
7.

El Monte Gas Inc.

Exxon Mobil Corporation's electronic data for the relevant time period shows that
El Monte Gas Inc., which had a business and delivery address of 10389 Avenue 416, Dinuba,
CA, purchased gasoline from Exxon Corporation from the Fresno terminal from 1993 through
1998. The dates, amounts, and description of the gasoline purchased by El Monte in Fresno
during this time period are set forth in the spreadsheet attached to this Declaration as Exhibit 2.
8.

E.R. Vine & Sons Inc.

Exxon Corporation had a distributor relationship with E.R. Vine & Sons, Inc.
Exxon Mobil Corporation's electronic data for the relevant time period shows that E.R. Vine &
Sons, Inc., which had a business and delivery address of 2825 Railroad Avenue, Ceres, CA,
purchased gasoline from Exxon Corporation from the Fresno terminal in 1987 and from 1994
through 2000. The dates, amounts, and description of the gasoline purchased by E.R. Vine &
Sons in Fresno during this time period are set forth in the spreadsheet attached to this Declaration
as Exhibit 3.
9.

Inter-City Petroleum Marketers, Inc.

Exxon Corporation had a distributor relationship with Inter-City Petroleum
Marketers, Inc. (dba Red TriangleOil Co.). Exxon Mobil Corporation's electronic data for the
relevant time period shows that Inter-City Petroleum Marketers, which had a business and
delivery address of 2809 S. Chestnut, Fresno, CA, purchased gasoline from Exxon Corporation
from the Fresno terminal from 1992 through 2000. The dates, amounts, and description of the

W02-WFST I ANK 1\4033·18104.2

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gasoline purchased by Inter-City Petroleum Marketers in Fresno during this time period arc set
forth in the spreadsheet attached to this Declaration as Exhibit 4.
I 0.

Jack Griggs Oil

Exxon Mobil Corporation's electronic data for the relevant time period shows that
Jack Griggs Inc., which had a business and delivery address of 1149 S. Kaweah, Exeter, CA,
purchased gasoline from Exxon Corporation from the Fresno terminal from 1989 through 1990
and from 1992 through 2000. The dates, amounts, and description of the gasoline purchased by
Jack Griggs in Fresno during this time period are set forth in the spreadsheet attached to this
Declaration as Exhibit 5.
11.

John Harness Oil

Exxon Mobil Corporation's electronic data for the relevant time period shows that
John Harness & Son Inc., which had a business and delivery address of 1150 El Monte Way,
Dinuba, CA, purchased gasoline from Exxon Corporation from the Fresno terminal from 1986
through 1988. 'lbe dates, amounts, and description of the gasoline purchased by John Harness in
Fresno during this time period are set forth in the spreadsheet attached to this Declaration as
Exhibit 6.
12.

King Currie, Inc.

Exxon Corporation had a gasoline supply relationship with King Currie, Inc.
Exxon Mobil Corporation's electronic data for the relevant time period shows that King Currie,
which had a business and delivery address of 3217 E. Lorena, purchased gasoline from Exxon
Corporation from prior to 1989 until 1994. The dates, amounts, and description of the gasoline
purchased by King Currie in Fresno during this time period arc set forth in the spreadsheet
attached to this Declaration as Exhibit 7.
13.

Nella Oil Co.

Exxon Mobil Corporation's electronic data for the relevant time period shows that
Nella Oil Company, which had a business and delivery address of2349 Rickenbacker Way,
Auburn, CA, purchased gasoline from Exxon Corporation from the Fresno terminal from 1996

W02-WEST·! ANK I \40334& 104.2

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through 2000_ The dates, amounts, and description of the gasoline purchased by Nella Oil in
Fresno during this time period arc set forth in the spreadsheet attached to this Declaration as
Exhibit 8.
14.

New West Petroleum

Exxon Mobil Corporation's electronic data for the relevant time period shows that
New West Petroleum purchased gasoline from Exxon Corporation from the Fresno terminal from
1995 through 1997. The dates, amounts, and description of the gasoline purchased by New West

in Fresno during this time period are set forth in the spreadsheet attached to this Declaration as
Exhibit 9.
15.

Northridge Petroleum Marketing US

Exxon Mobil Corporation's electronic data for the relevant time period shows that
Northridge Petroleum Marketing US purchased gasoline from Exxon Corporation from the
Fresno terminal in 1997. The dates, amounts, and description of the gasoline purchased by
Northridge in Fresno during this time period are set forth in the spreadsheet attached to this
Declaration as Exhibit 10.
16.

Robert V. Jensen Inc.

Exxon Mobil Corporation's electronic data lor the relevant time period shows that
Robert V. Jensen Inc., which had a business and delivery address of 4029 S. Marble Ave, Fresno,
CA, purchased gasoline from Exxon Corporation from the Fresno terminal in 1999. The dates,
amounts, and description of the gasoline purchased by Robert V. Jensen in Fresno during this
time period are set forth in the spreadsheet attached to this Declaration as Exhibit II.
17.

The column headings contained in the attached spreadsheets have the

following meanings:
SHIP YEAR

Year of Delivery

ACCOUNT NUMBER

Identification number of customer account purchasing
gasoline

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·--~

NAME- DELVY- LINE- I

~~----

Name of Customer Account

--

NAME- DELVY- LINE- 2 Street address of delivery

--·

NAME- DELVY - LINE- 3 Alternate or Further Information re: address of delivery
----

- .

·-

NAME- DELVY- LINE- 4 Alternate or Further Information re: address of delivery
.

[-----·

.

SHIPPING DATE
DOCUMENT NUMBER

.

Date of delivery
Bill of Lading number
----

PRODUCT

Identifying code of Product Name being delivered

PROD - NAME-·-29

Name of product delivered

BILLING UNITS

Number of gallons of product invoiced to Customer per
delivery

..

'GRoss

UNITS

Number of gross gallons of product per delivery

STOCK UNITS

Number of gallons in stock (inventory) units per delive

PLANT NAME

Terminal name at which product is loaded

DEALER- LOC- FLR

Identifying number of station

DEALER LOCATION

Identifying number of station
.

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I have reviewed the declaration ofK.W. Gardner, which is submitted

concurrently with my declaration. In his declaration, Mr. Gardner identifies the product names
of Exxon gasoline that likely contained MTBE. Based on my review of the information
contained in Mr. Gardner's declaration and my knowledge of the type of information contained
in Exhibits I through II, the highlighted deliveries contain one of the product descriptions
identified in Mr. Gardner's declaration, indicating that these deliveries likely contained MTBE.
19.

Other than the relationships and deliveries identified above, a review of

historical and current databases has found no record of deliveries of gasoline by Exxon
Corporation/Exxon Mobil Corporation to any other Site.

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Apr 21

11 07:06p

20.

ExxanMobil

703-846-2506

No one employee of Exxon Mobil Corporation today can provide

complete responses to the request. These responses were compiled by counsel fur Exxon Mobil
Corporation. Based on matters that have been made known to me for the purposes of this
Declaration, l state that I am informed and believed that the matters stated herein are true and
correct.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed April)/, 2011, at Fairfax, Virginia.

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