Hansen v. Owens-Corning Fiberglas Corp. (1996) 51 Cal.App.4th 753 was an asbestos case with 200 named defendants. (Id. at p. 756.) One defendant moved, pursuant to the forum non conveniens doctrine, to stay the litigation because Montana, where the plaintiff had lived and where most of the asbestos exposure allegedly occurred, was a suitable alternative forum. (Id. at pp. 756-757.) The moving defendant was amenable to service of process in Montana and the "vast majority of the defendants had contacts in both California and Montana." (Id. at p. 757.) However, at least three other defendants did not consent to jurisdiction in Montana and it was not known whether they had sufficient contacts with Montana to subject them to personal jurisdiction. (Id. at p. 758.) The trial court granted the motion to stay the California litigation subject to the following condition. After the plaintiff filed suit in Montana, he could return to the California trial court and request the stay be lifted if he could conclusively show that Montana was not a suitable alternative jurisdiction. (Id. at pp. 756-757.) The appellate court affirmed the trial court's order. It rejected the plaintiff's argument that the moving party was required to prove that all defendants were amenable to service in Montana. It explained that it was "aware of no authority that a moving defendant must show all defendants are subject to jurisdiction in a particular alternative forum." (Id. at pp. 758-759.) It concluded, after analyzing the cases relied upon by the plaintiff for that proposition, that none "stated or implied all defendants must be subject to jurisdiction in an alternative forum before an order staying an action can be affirmed." (Id. at p. 759.) Given the lack of specific precedent on the issue, the Hansen court reasoned: "In asbestos cases such as this, where there are 200 named defendants, it is unreasonable to expect the moving defendant to prove all defendants are subject to jurisdiction in a particular alternative forum. Given the early stage for bringing a forum non conveniens motion, it would likely be unclear in many cases whether all defendants were even subject to jurisdiction in California." (Id. at p. 759.) Because the trial court had stayed the action pending a determination that all defendants were subject to jurisdiction in Montana, the appellate court upheld its ruling.