SUPERIOR COURT
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`J.D. OF FAIRFIELD
`
`AT BRIDGEPORT
`
`NOVEMBER 18, 2016
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`ASB -FBT-CV-14-6043933-S
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`MICHAEL TULLIE, PERSONAL
`REPRESENTATIVE OF THE ESTATE
`OF JAMES TULLIE AND MILDRED
`TULLIE, SURVIVING SPOUSE
`
`v.
`
`A.O. SMITH CORP., ET AL
`
`BW/IP, INC.’S DISCLOSURE OF
`EXPERT WITNESSES
`
`BW/IP, Inc. (“BW/IP” or “Defendant”) discloses the following expert witnesses who
`may be called to testify at trial:
`
`1.
`
`Vittorio Argento, Ph.D., PE, 5018 Southwest 8th Court, Cape Coral, Florida
`33914.
`Dr. Argento is an expert in the field of environmental engineering. He is familiar with
`tests performed on asbestos-containing products, the amount of asbestos fibers released by the
`use of these products, the ambient air level exposures around the United States, the EPA
`definitions of friability, and state of the art. Dr. Argento may testify as to matters relating to the
`standards, customs, practices, and general principles in the field of industrial hygiene; the
`manner and method of conducting and reporting the results of industrial hygiene surveys;
`historical development, design, use application, and interpretation of dust counting surveys and
`air sampling tests; interpretation of dust counting surveys and air sampling tests performed in
`industrial settings, historical development, purpose, meaning application, and maintenance of
`threshold limit values and permissible exposure limits for asbestos exposure and their application
`in industrial settings; size, construction, engineering controls, layout, and nature of the plaintiff’s
`working environment; composition and asbestos content, if any, of the products which the
`plaintiff claims exposure, including the ability, if any, of such products to emit respirable
`asbestos fibers; state of the scientific and medical art throughout history regarding knowledge of
`asbestos related diseases; estimated duration and intensity of exposure necessary to cause
`asbestos related diseases; retrospective assessment of the plaintiff’s exposure to asbestos,
`including a calculation of the plaintiff’s lifetime cumulative asbestos exposure on a time-
`weighed average basis from various sources and from products and/or equipment; fiber release,
`fiber drift, the speed with which asbestos fiber settles out of the air and fails to remain airborne,
`and the speed with which asbestos leaves the breathing zone of individuals; purpose, history and
`operation of the American Conference of Governmental Hygienists; responsibilities of
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`employers, unions, and individual workers regarding industrial hygiene and safety; use and
`effectiveness of respirators; development of product warnings; and/or documentary evidence
`relevant to the defense of the individual plaintiff’s claims, including without limitation drawings
`and other materials concerning the specific product or product model with respect to which the
`plaintiff alleges exposure.
`2.
`J. LeRoy Balzer, Ph.D., 408 Horse Trail Court, Alamo, California 94507.
`Dr. Balzer is an industrial hygienist with a doctorate in Environmental Health Sciences
`with a focus on industrial hygiene. He will testify regarding industrial hygiene issues, including
`the aerodynamic properties of fibrous material such as asbestos. He will also testify as to the
`historical development of industrial hygiene knowledge of asbestos. Dr. Balzer may testify
`about the size, construction, layout and working environment of facilities such as where the
`plaintiff worked. As an industrial hygienist, Dr. Balzer may testify about the nature of the
`environment in such locations. He may testify about his knowledge of the composition and
`asbestos content of products allegedly used by the plaintiff and concerning the ability of these
`products to emit asbestos fibers under certain conditions.)
`3.
`Jeff Birkner, MS, CIH, Chemistry & Industrial Hygiene, 10201 West 43rd
`Avenue, Suite 201, Wheatridge, Colorado 80033.
`
`He is expected to testify in the areas of retrospective exposure assessment, health risk
`assessment, product apportionment with respect to asbestos exposures, substantial exposure
`factors, the relative and absolute potentials of various asbestos products to produce dust,
`industrial hygiene and environmental standards and their bases, control technology and process
`specific aspects of exposure, analytical chemistry, chemistry, asbestos related measurement
`techniques, general industrial hygiene issues, including the effects of ventilation and distance on
`exposure, and related subjects. He may also testify on the state of the art in the field of industrial
`hygiene and toxicology concerning occupational and non occupational asbestos exposures in
`earlier years. Mr. Birkner will calculate the percentage ranges of asbestos exposure from a
`particular defendant’s products.
`
`4.
`
`Charles L. Blake, CIH, Vice President, Director Technical Services, Bureau
`Veritas North America, Inc, 3380 Chastain Meadows Parkway, Suite 300,
`Kennesaw, Georgia 30144.
`
`Mr. Blake is a certified industrial hygienist. He may testify concerning the following
`subjects: the appearance, application, properties and uses of various asbestos-containing
`products; the presence or absence of warnings on such products; the presence or absence of risks
`posed by such products in connection with different types of activities; industrial hygiene and
`industrial hygiene practice and principles; the available literature and studies relating to
`installation and removal of asbestos-containing products; and the state of thinking and
`knowledge within the industrial hygiene community regarding the risks, if any, posed by
`asbestos-containing products. Mr. Blake may testify regarding alleged occupational exposures
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`of plaintiff, and whether such exposures created significant risk of asbestos-related disease. Mr.
`Blake may testify as to the state of the art and rely upon his experience with and knowledge of
`asbestos-containing building products and his familiarity with articles, literature, publications,
`government regulations, EPA and state guidance documents and industrial hygiene literature and
`practices concerning and/or applicable to asbestos-containing products. Mr. Blake may also give
`opinions on the literature, studies, data and opinions relied upon by plaintiff’s experts.
`
`5. William J. Blot, Ph.D., 1455 Research Blvd., Suite 550, Rockville, Maryland
`20850.
`
`Dr. Blot is a biostatistician and epidemiologist. Dr. Blot may testify regarding the
`application of epidemiology and biostatistics to asbestos related disease in various populations,
`as shown by literature and his research. He may testify concerning relevant epidemiologic
`studies showing the incidence and progression of asbestos related diseases, the existence of a
`dose response relationship between exposure to asbestos and asbestos related disease, fiber
`gradients, and the relative risk of personal injury or death as a result of exposure to different
`types of asbestos at different exposure levels. Dr. Blot may also testify on the relationship
`between asbestos exposure and malignant and nonmalignant conditions. He may also testify
`regarding the linear dose extrapolation model and quantitative risk assessment of different
`individuals with different levels and types of asbestos exposures and determine, insofar as
`science is able, the risks of those individuals to contract conditions which may be asbestos-
`related, as well as their risks of contracting various forms of cancer. Dr. Blot may also respond
`to matters raised within his field of expertise by plaintiff in the presentation of his case in chief.
`Accordingly, Dr. Blot’s testimony is dependent upon prior testimony of plaintiff’s experts and
`cannot be predicted with further specificity. Dr. Blot’s testimony will be based on his training,
`experience, research, education, writings, review of medical and scientific literature concerning
`asbestos disease and other relevant matters, and review of depositions, expert reports, documents
`and medical records relevant to plaintiff.
`
`6.
`
`Frederick W. Boelter, CIH, Boelter Environmental Consultants, 1300
`Higgins Road, Suite 301, Park Ridge, Illinois 60068-5772.
`
`Mr. Boelter is a certified industrial hygienist with an extensive background in the
`prevention of adverse health effects and injuries in the workplace. He has extensive experience
`evaluating the workplace for potential hazards with regard to work practices and workplace
`design; measuring and evaluating various substances to assess exposure, exposure potential and
`health and safety risks; and controlling the occupational setting with engineering, work practice,
`administrative, and personal protective equipment methods. Mr. Boelter may opine on issues
`related to workplace hazard anticipation, recognition, evaluation and control. He may also
`testify on issues related to exposure standards and the relationship between exposure and disease
`risk. Mr. Boelter may testify as to the state of the art with respect to asbestos in the field of
`industrial hygiene, and, in particular, the evolution of knowledge regarding the effects of
`asbestos exposure and its control during the period relevant to this case. He may also testify as
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`to the development and utility of methodologies for identifying and measuring asbestos in air,
`dust and products. He may also testify about the evolution of and the process for setting
`Threshold Limit Values (“TLVs”), Occupational Safety and Health Administration standards-
`Permissible Exposure Limits (OSHA-PELs), and other standards used for assessing and
`controlling asbestos exposure. Mr. Boelter may discuss the relationship between scientific
`knowledge and the development of public policy and the standards relating to asbestos exposure,
`and all aspects of government regulation of asbestos exposure. He may also testify as to
`industrial hygiene relating to asbestos, including, but not limited to, asbestos-containing products
`used in manufacturing facilities, buildings, construction sites, and the assessment of risk of
`exposure under various circumstances. Mr. Boelter may also conduct an exposure or
`retrospective assessment of plaintiff’s exposure to asbestos in various work settings and to
`specific products. Mr. Boelter may also testify about the development of knowledge regarding
`the dose-response relationship between exposure to asbestos and disease, and other related
`matters. He may also comment about testing done by or on behalf of plaintiff, including critique
`and analysis of the sampling methods and analysis, protocols and scientific bases for the tests,
`and accuracy of the testing in reproducing field conditions.
`
`7.
`
`Philip Cagle, M.D., Center for Pulmonary Pathology, Baylor College of
`Medicine, One Baylor Plaza, Houston, TX 77030.
`
`Dr. Cagle is a licensed physician and a pathologist. Dr. Cagle may testify regarding the
`pathological aspects of the case, plaintiff’s medical condition, issues of alternative causation and
`life shortening problems not related to alleged asbestos exposure.
`
`8.
`
`Bruce W. Case, M.D., M.Sc., D. Occup. Hygiene, Department of Pathology,
`McGill University, 3775 University St., Montreal, Canada H3A2B4.
`
`Dr. Case is a pathologist and epidemiologist at McGill University in Montreal, Canada.
`Dr. Case received his degree in medicine from McGill University in 1972. Following his
`residency in pathology at McGill, he trained with Graham Gibbs in Occupational Hygiene from
`September 1979 until May 1980. During the years, 1980 through 1983, he worked as a post-
`doctoral fellow and instructor at the Mount Sinai School of Medicine, New York. After this
`work, he returned to McGill University and worked in the Dust Disease Research Unit. The
`focus of this group was the epidemiological study of diseases related to mineral fiber exposure
`using lung-retained fiber in exposure assessment. In 1986 he received the national Health
`Scholarship of NHRDP (Canada) for his work in this field. In 1988 Dr. Case moved to the
`University of Pittsburgh, where he succeeded Defendant anticipates that Dr. Case will testify
`regarding diagnosis and clinical aspects of pulmonary disease, including asbestosis,
`mesothelioma, and lung cancer in general and as they relate to plaintiff specifically. Dr. Case
`may testify as to the diagnosis in this case, and the causative role, if any, of various asbestos
`fiber types generally as well as specific product types and brands. His testimony may also
`include opinions about the role of cigarette smoke, diet, lifestyle and other factors in the
`causation of any cancer. Dr. Case may also testify as to plaintiff’s life expectancy as of the date
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`of plaintiff’s diagnosis of cancer and may also be asked to perform and/or testify regarding lung
`tissue digestion fiber burden studies if suitable lung tissue is or becomes available. Dr. Case may
`also provide general expert testimony about the ubiquitous, prevalent nature of asbestos fibers in
`urban cities as well as in mountainous Western states, the levels of asbestos fibers in the lung
`tissue of individuals with and without occupational asbestos exposure, and the causal
`significance, if any, of such lung fiber burdens.
`
`9.
`
`Eric J. Chatfield, Ph.D., Chatfield Technical Consulting Ltd., 2071 Dickson
`Road, Mississauga, Ontario, Canada, L58148.
`
`Dr. Chatfield is a microscopist who may analyze bulk samples collected in this matter and
`who may present testimony regarding constituents thereof.
`
`10.
`
`Andrew Churg, M.D., The University of British Columbia, 2211 Westbrook
`Hall, Vancouver, B.C., Canada V6T IW5.
`
`Dr. Churg is a licensed physician and a pathologist. Dr. Churg may testify on pathological
`evidence and on the causation of plaintiff’s alleged disease.
`
`11.
`
`James Collins, M.D., Radiologist, U.C.L.A. Medical Center Radiology, 10833
`Le Conte Avenue, West Los Angeles, CA 90024.
`
`Dr. Collins may testify regarding radiographic evidence pertaining to plaintiff’s medical
`condition.
`
`12.
`
`John Craighead, M.D., Pathologist, Chairman, Department of Pathology.
`University of Vermont College of Medicine, A249 Given Medical
`Building, Burlington, VT 05405.
`
`Dr. Craighead may testify regarding the pathological aspects of the case, plaintiff’s
`medical condition, issues of alternative causation and life shortening problems not related to
`alleged asbestos exposure.
`
`13.
`
`James D. Crapo, M.D. Professor of Medicine and Pathology; Chief of
`Division of Critical Case and Pulmonary Medicine; Board Certified Internal
`Medicine and Pulmonary Medicine. National Jewish Medical and Research
`Center, 4650 South Forest Street, Englewood, CO 80110.
`
`Dr. Crapo is a licensed physician and pulmonary specialist who will testify regarding the
`epidemiology of asbestos exposure and the disease caused by such exposure, and concerning
`issues of his specialty as applicable to the medical issues presented by this case.
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`14.
`
`James Delaney, 1398 W. Liberty Greens Dr., Washington, Utah 84780.
`
`Mr. Delaney served in the U.S. Navy as a machinist mate from 1964 until 1979. He
`served on a number of nuclear surface ships, as well as a nuclear submarine. In 1979, Mr.
`Delaney was commissioned as an ensign, and served as an assistant to Admiral Rickover from
`1979 until 1991. During this time, he audited, inspected, and reported on maintenance and repair
`performance of machinist mates on both nuclear surface crafts and nuclear submarines. In 1991,
`Mr. Delaney became an inspector at Pearl Harbor Naval Shipyard, focusing on nuclear ships,
`especially nuclear submarines. In 1996, he was assigned to head a nuclear program for the U.S.
`Navy, and retired in 1997 with the rank of Commander. Mr. Delaney will testify regarding the
`substantial similarity of the maintenance and repair techniques that he learned and practiced on
`nuclear surface ships to those he observed on nuclear submarines; to the similarity of nuclear
`propulsion systems that he had experience with on nuclear surface compared with nuclear
`submarines; the range of duties he practiced himself as a machinist mate and those he observed
`throughout his career; and regarding the maintenance and repair techniques machinist mates
`performed on pumps and valves that he practiced and observed.
`
`15. Horace DeLisser, M.D., (Internal and Pulmonary Medicine), Pulmonary,
`Allergy & Critical Care Division, Department of Medicine, University of
`Pennsylvania, 806 BRB II/III, 421 Curie Boulevard, Philadelphia, PA 19104.
`
`Dr. DeLisser is a medical doctor. He may testify regarding the following areas: (1) the
`anatomy and function of the respiratory and circulatory systems, including the protective systems
`of the body with regards to the inhalation and retention of dust, and the diagnosis and treatment
`of disease affecting such systems; (2) the nature of asbestos and asbestos-related diseases, and
`the epidemiological evidence in regard to asbestos-related disease and disease potential; (3) the
`symptomatology, disease process and diagnosis of asbestosis and cancer associated with the
`respiratory system, peritoneum and peritoneal cavity; (4) the nature and extent of medical and
`scientific knowledge regarding any association of obstructive pulmonary disease with asbestos
`fiber exposure; (5) the effect of exposure to substances other than asbestos on the development
`and manifestation of obstructive and restrictive conditions and diseases of the respiratory system
`and other causes of obstructive and restrictive disease or defects of the respiratory system; (6)
`methods of diagnosis of various diseases, especially the means of establishing the differential
`diagnosis of alleged asbestos-related diseases with other non-asbestos-related diseases; (7)
`incidence of lung cancer among individuals with asbestosis or asbestos exposure as compared to
`non-asbestotic asbestos workers, non-asbestos exposed workers and to the general population;
`(8) cigarette smoking and its effects on the lungs and other organs; (9) the relationship of
`cigarette smoking to cancer of the lung and cancers of other body parts with reference to
`epidemiology studies and physiologic effect; (10) the difference between impairment and
`disability; (11) the effect of asbestosis or other asbestos-related disease, or asbestos exposure
`without asbestosis or other asbestos-related disease, on disability and life expectancy; (12) the
`lack of relationship between the presence of pleural plaques and a later development of any form
`of cancer; (13) the history of evolution and knowledge of asbestos related diseases; (14) the
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`import of any exhibit introduced as evidence, or any items prepared for use or used for
`demonstrative purposed by any witness; (15) cancer incidence in the general population and
`among asbestos workers and its potential causes; (16) the incidence of mesothelioma among
`various kinds of workers exposed to asbestos, and the relative importance of various fiber types
`and the cause of mesothelioma; (17) the radiological manifestations of asbestos disease, the ILO
`classification method for chest radiographs, other medical diseases or conditions which can
`produce radiological manifestations similar to those sometimes experienced after asbestos
`exposure, and the various techniques employed in producing x-rays and the effect that techniques
`may have on the subsequent interpretations of chest radiographs; and (18) to the extent not
`covered above, asbestos medicine in general. He may also testify about examination of plaintiff
`or review of plaintiff’s work history, medical records, tests, x-rays, CT scans, gallium scans,
`pathology, and other evidence and diagnostic tools in this case. He may also testify as general
`medical witnesses and may give testimony regarding the lack of any role of a defendant’s
`product in the case of plaintiff’s disease. Additionally, he may testify regarding any matters
`raised in depositions previously taken by or supplied to plaintiff. He may also testify about any
`matter raised by experts called by the plaintiff or any co-defendants.
`
`16.
`
`Laura Fuchs Dolan, Managing Director, 600 Anton Blvd., Suite 1350, Costa
`Mesa, CA 92626.
`
`Ms. Dolan is an economist who will testify regarding economic damage and losses and
`related matters as alleged by plaintiff.
`
`17.
`
`Edward Drasin, M.D., Radiology Department, Merritt Hospital, Hawthorne
`and Webster Streets, Oakland, California.
`
`Dr. Drasin is a radiologist. Dr. Drasin may testify regarding his opinions in this case upon
`request by opposing counsel, regarding x-rays or CT scans pertaining to plaintiff and plaintiff’s
`medical condition.
`
`18.
`
`Christopher J. Dunn, M.D., Pulmonologist, Internist, 77 Birch Street, Suite
`A, Redwood City, CA 94062.
`
`Dr. Dunn may testify regarding his knowledge of lungs and thoracic organ functions,
`plaintiff’s medical condition, issues of alternative causation and life shortening problems not
`related to alleged asbestos exposure.
`
`19. William Dyson, Ph.D., Workplace Hygiene, 6518 Bryan Boulevard - Suite
`203, Greensboro, NC 27419.
`
`Dr. Dyson will offer testimony on the state-of-the-art as it relates to the field of industrial
`hygiene, industrial hygiene principles, practices and procedures as they relate to exposure to
`asbestos-containing products and plaintiff’s particular exposures; on his review of plaintiff’s
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`medical records and reports, including chest x-rays and pulmonary function test data and
`information relating to plaintiff’s work history. Specific reference will be made to historical,
`scientific and medical literature, government regulations, other historical information pertaining
`to asbestos, and dust counts of asbestos-containing products. This witness is expected to base his
`testimony on his respected background, training, experience and review of relevant literature.
`Dr. Dyson is also expected to provide testimony as to plaintiff’s exposure and the role that
`asbestos-containing products played in the development of his alleged disease.
`
`20. W. Brooks Emory, M.D., Ochsner Clinic, 1514 Jefferson Highway, New
`Orleans, Louisiana 70121.
`
`Dr. Emory will be offered by this Defendant as an expert in pulmonology. Dr. Emory will
`testify concerning his examination and diagnosis of plaintiff’s physical condition and the
`relationship, if any, to the plaintiff’s exposure to asbestos. The scope of Dr. Emory’s testimony
`is expected to include matters concerning the clinical aspects of non-malignant changes alleged
`to be associated with exposure to asbestos-containing products, including, comment concerning
`various epidemiologic studies that have been reported concerning nonmalignant conditions
`allegedly associated with exposure to asbestos containing products in some populations. Dr.
`Emory is expected to provide testimony concerning interstitial lung changes, the range of
`elements that can cause interstitial lung changes, the lungs’ response to foreign substances and/or
`insult of any sort, the clinical elements and testing necessary and/or generally accepted within
`the medical community and the diagnoses of various nonmalignant conditions alleged to be
`associated with asbestos exposure, differential diagnoses, notions of impairment associated with
`various conditions, progression (both its definition and likelihood of progression of certain
`conditions as reported epidemiologically in certain populations), and the effects of confounding
`conditions. Dr. Emory further is expected to offer testimony concerning the effects of inhaled
`tobacco smoke and other factors on the occurrence of disease in populations who also are alleged
`to be exposed to asbestos-containing products and, additionally, concerning how the effects of
`inhaled tobacco smoke and other factors can confound the apparent results of certain
`epidemiologic studies. Dr. Emory further is expected to testify concerning the circumstances
`under which exposure to asbestos fibers may be associated with the incidence of some forms of
`cancer, including mesothelioma, in some persons and will testify concerning the results of his
`own experiences, the medical and scientific literature, and existing epidemiologic studies
`concerning associations that are alleged to exist epidemiologically between exposure to asbestos
`in some populations and the mortality and/or incidence of some forms of cancer. It is expected
`that Dr. Emory’s testimony generally will respond, within the scope of his expertise, to the
`subject matter of internal and pulmonary medicine testimony that may be offered by plaintiff’s
`experts, and in that sense his testimony is dependent upon the prior testimony of such experts
`and cannot specifically be predicted. Dr. Emory will base his opinions on his own research,
`knowledge and experience, his background and education, his writings, his review of the medical
`and scientific literature, including epidemiologic and other research on asbestos and conditions
`associated with asbestos, and other relevant publications and materials.
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`21.
`
`David Feigin, M.D., University of California, San Diego, Department of
`Radiology (9114), La Jolla, CA 92093.
`
`Dr. Feigin is a licensed physician and a radiologist. Dr. Feigin may testify regarding the
`radiographic aspects of this case, including interpretation of chest x-rays and CT scans,
`plaintiff’s medical condition, issues of alternative causation, and life shortening problems not
`related to alleged asbestos exposure.
`
`22.
`
`Ilan Allan Feingold, M.D., South Miami Hospital, Division of Pulmonary
`Medicine, South Miami Hospital, 6200 S.W. 73rd Street, Miami, Florida
`33143.
`
`Dr. Feingold is a pulmonologist who may testify to the standards for diagnosing asbestos-
`related disease, including but not limited to discussion of chest x-ray, pulmonary function,
`pathological and clinical techniques. He may also discuss the literature relative to diagnosis of
`asbestos-related diseases and the techniques and literature on the diagnosis of other diseases
`suffered by the plaintiff. Dr. Feingold may also review plaintiff’s pertinent medical records for
`and pieces of medical evidence, including but not limited to medical records from health care
`providers, chest x-rays, pulmonary test, and other types of evidence, and offer his opinions on
`the medical conditions on the plaintiff based on such review. Dr. Feingold may also testify as to
`ILO/NIOSH B reading of plaintiff’s x-rays, with opinions related to this undertaking. Dr.
`Feingold may also offer his opinion on other stimulating or coexisting conditions, including but
`not limited to cardiac, orthopedic, congenital, or neurological, disorders or diseases of other
`organ systems. His testimony may include a medical presentation of lung diseases including but
`not limited to those caused by tobacco abuse, other inhale agents, heredity, or environment. In
`addition, Dr. Feingold may discuss epidemiology of asbestos-related disease and other diseases
`which the plaintiff may suffer from, including but not limited to analysis of plaintiff’s exposure
`to asbestos and other potential agents; discussion of latency of exposure to asbestos and other
`potential agents; discussion of the latency of asbestos and other diseases; discussion of the
`contribution of this Defendant’s product, if any, to plaintiff’s illness; discussion of various
`models of risk versus time, duration, and extent of exposure; and other related topics. He may
`also discuss the prognosis; risk of cancer of various forms; risk of progression, including but not
`limited to discussion of risk of cancer from asbestos versus tobacco; risk of cancer from heredity
`and environment; risk of death or impairment from other causes; prognosis of the plaintiff. An
`analysis of plaintiff’s work environment; work history; occupational history, including but not
`limited to discussion of significance, intensity, and disease causing potential arising from
`exposure to this Defendant’s products, if any, versus other types of exposure.
`
`22.
`
`Stanley B. Fiel, M.D., Medical College of Pennsylvania, 3300 Henry Avenue,
`Philadelphia, PA 19129.
`
`Dr. Stanley B. Fiel may testify, in general, concerning asbestos related diseases and the
`effects of exposure to asbestos upon persons in occupational settings, including tile
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`epidemiology of asbestos related diseases and the criteria for diagnosis of any asbestos-related
`disease. He may also testify regarding the existence or non-existence of any asbestos-related
`disease in plaintiff, including but not limited to pleural changes, asbestosis, lung cancer,
`mesothelioma, laryngeal cancer, esophageal cancer and stomach cancer. He may also testify on
`whether any asbestos related disease allegedly suffered by plaintiff was medically or proximately
`caused by exposure to asbestos-containing products. He may also testify on the existence of a
`dose response relationship between exposure to asbestos and asbestos-related disease. He may
`also testify on increased risk of cancer issues and whether a particular plaintiff has a reasonable
`fear of cancer due to exposure to asbestos. He may also testify on the health consequences of
`smoking. With respect to particular plaintiff, he may testify as to review and interpretation of x-
`ray films, review and interpretation of pulmonary function testing, the nature and extent of any
`impairment or disability, whether the condition is progressive and whether other disease or
`conditions are present in plaintiff. Dr. Fiel has studied the dose-response relationship between
`asbestos and disease, both clinically and academically. He is familiar with the studies of Carl
`Marigold, CIH and other Industrial Hygienists regarding the actual contribution of asbestos
`fibers during use of gasket and packing materials. Dr. Fiel’s testimony will be based on his
`training, experience, education and review of the medical literature concerning asbestos related
`diseases.
`
`23.
`
`Samuel Forman, M.D., Oak and Ivy Health Systems, Inc., 3-B Hollis Street,
`Cambridge, Massachusetts 02140.
`
`Dr. Forman is a medical doctor specializing in preventive medicine and is board certified
`in occupational medicine. He graduated from the University of Pennsylvania with a Bachelor of
`Arts degree in history and biology in 1973. He earned a Doctor of Medicine degree from the
`Cornell University Medical College in 1977. He also received a degree in public health in 1977
`as a result of a joint program with the Harvard School of Public Health. Thereafter, he became
`board certified in occupational medicine after attending a residency at the Harvard School of
`Public Health. Dr. Forman completed his internship in internal medicine at the National Naval
`Medical Center in Bethesda, Maryland. In 1977, Dr. Forman went on active duty as a
`commissioned officer in the United States Navy, and he performed his internship at the Bethesda
`Naval Medical Center in Bethesda, Maryland during 1977 and 1978. He resigned his
`commission as a Lieutenant Commander but continued to work for the Navy as a civilian
`employee at the Navy Environmental Health Center in Norfolk, Virginia until 1986. While
`serving on active duty, Dr. Forman was head of the occupational health clinic at the Seal Beach
`Naval Weapons Station, Seal Beach, California, and assisted in a medical surveillance program
`at Long Beach Naval Shipyard. In this capacity, he managed the asbestos medical surveillance
`program at Long Beach Naval Shipyard. In 1982, Dr. Forman was stationed at the Naval
`Environmental Health Center in Norfolk, Virginia, where he designed occupational medical
`programs with regard to Navy-specific occupational diseases, investigated potentially new
`hazards, assisted local commands in the execution of their occupational health programs and
`assisted in the Navy Occupational Safety and Health Inspection Program (NOSHIPS). In this
`capacity he also trained Navy doctors and nurses in occupational medicine.
`In 1983, Dr.
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`Forman worked with the Naval Medical Command to analyze and organize government
`documents. Through this work, Dr. Forman investigated the historical knowledge of the United
`States Government, and particularly of the Navy and the Maritime Commission, concerning
`industrial health aspects of various materials, including asbestos. Through this research, he
`became familiar with historic government and Navy documents including materials from the
`Bureau of Medicine and Surgery. Following his research, he published an article entitled U.S.
`Navy Shipyard Occupational Medicine Through World War II, published in the Journal of
`Occupational Medicine, Volume 30, No. 1, January 1988. Dr. Forman bases his opinions with
`regard to the state of the art upon all of the published medical and scientific literature that he has
`reviewed to date. His opinions with regard to government knowledge also are based upon his
`review of countle