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`STATE OF CONNECTICUT
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`SUPERIOR COURT JUDICIAL DISTRICT OF
` FAIRFIELD AT
` BRIDGEPORT
` C.A. No.: CV-24-6139710S
`__________________________________________
`DAVID MORIARTY, )
` )
` Plaintiff, )
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` v. )
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`ARVIN INDUSTRIES, INC., individually )
`and as successor in interest to Maremont )
`Corporation, ET AL., )
` )
` Defendants. )
`__________________________________________)
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`DEFENDANT INTERNATIONAL
`MOTORS, LLC EXPERT WITNESS DESIGNATIONS
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`The Defendant, International Motors, LLC, f/k/a Navistar, Inc. (“International”), by and
`through its counsel, hereby designates the expert witnesses it may call to testify at the trial of the
`above-captioned case. International notes that product identification is not closed and reserves
`the right to supplement this disclosure following the closure of product ID. International
`specifically reserves the right to call any witness listed by any party, either live or by deposition,
`or previous trial testimony, or who may have been called to testify in this case for the purpose of
`impeachment, rebuttal or any other purpose the law allows.
`International has not yet completed its determination of witnesses and reserves the right
`to supplement and amend this list up to and including the time of trial or such other deadlines as
`may be set by the Court. In addition, International reserves the right to call as fact or expert
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`witnesses any physicians, nurses, and other medical/paramedical and technical personnel who
`treated, examined and/or rendered care to Plaintiff’s decedent.
`The opinions of the following experts will be based on one or more of the following:
`his/her training, experience, education, publications, review of the medical, governmental and
`scientific literature regarding asbestos-related disease, various air sampling studies, work facility
`documents, product formulae or constituent analysis, site specific documents, medical records,
`reports from other experts to the extent deemed reliable and of a type customarily relied upon by
`experts in his/her field, fiber burden or digestion studies, chest films and/or pathology materials.
`International will provide the curriculum vitae for any disclosed expert upon request. The
`following descriptions were drafted by counsel for International upon information and belief.
`EXPERTS
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`1. Dominick D. Alexander, Ph.D., M.S.P.H.
`MetaMethod, Inc.
`16769 Bernardo Center Drive, Suite K1-144
`San Diego, CA 92128
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` It is expected that by the time of a deposition, Dr. Alexander will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Alexander’s hourly fee for providing
`deposition testimony is $450.00, with a one-hour minimum. I am informed and believe that this
`witness has agreed with counsel for International to testify at trial of matters of this nature.
`Dr. Alexander is Principal Epidemiologist at Metamethod. Dr. Alexander attended the
`University of South Florida College of Public Health where he received his M.S.P.H. in 2001
`in epidemiology and biostatistics. He subsequently attended the University of Alabama-
`Birmingham School of Public Health where he received his Ph.D. in 2004 in epidemiology. He
`is a member of numerous professional societies in the field of epidemiology and public health,
`including the American College of Epidemiology, the Society for Epidemiologic Research, and
`the American Society of Nutrition. He also serves as a reviewer of scientific papers for a number
`of journals, including the American Journal of Epidemiology. His qualifications are set out in
`greater detail in his curriculum vitae.
`Dr. Alexander may discuss the science of epidemiology, the methodology, design and
`conduct of epidemiological studies, issues of validity and reliability, and the differences
`between case reports and systematic epidemiological studies. He may explain the uses of meta-
`analysis, cohort studies, case-control studies, and the interpretation of measures of association
`in epidemiology. He may discuss how causal inferences are made in epidemiology, the synthesis
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`of results from a body of scientific literature, and the recommendations made by Sir Austin
`Bradford-Hill.
`Dr. Alexander may discuss the present and historical scientific and epidemiological
`literature relating to the risk of asbestos related disease, including mesothelioma, in various
`occupations and from various activities, including vehicle and equipment repair work. He may
`discuss what the literature demonstrates regarding circumstances that increase the risk of
`asbestos related disease and those that do not, including with respect to exposure levels, fiber
`type, and other factors. He may discuss the studies that have measured the asbestos exposure of
`vehicle mechanics and whether brake mechanics or other vehicle repair workers are at an
`increased risk for asbestos related disease, including mesothelioma. He may discuss the state of
`medical knowledge with respect to the causation of various types of cancer and medical
`conditions of the injured party. Dr. Alexander is also expected to opine that there is no reliable
`scientific evidence that performing vehicle repairs, including brake or other component
`replacement, places individuals at increased risk of asbestos-related disease. Further, he may
`address the potential risk of disease from other forms of asbestos exposures and other potential
`causes of disease, including genetic conditions.
`Dr. Alexander may be asked to respond to the testimony and documents of certain
`witnesses offered at the time of trial or in depositions, including, but not limited to, testimony
`of witnesses offered by Plaintiffs.
`Dr. Alexander's testimony will be based on his training, expertise, education, review of
`the medical and scientific literature, as well as case specific materials, if any.
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`2. Richard Luther Attanoos, B.Sc., MB BS, F.R.C.
`Path. Department of Histopathology
`University Hospital Llandough Penarth
`South Glamorgan CF64 2XX United Kingdom
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`It is expected that by the time of a deposition, Dr. Attanoos will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Attanoos hourly fee for providing
`deposition testimony is $750.00, with a one-hour minimum. I am informed and believe that
`this witness has agreed with counsel for International to testify at trial of matters of this nature.
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`Dr. Attanoos is a pathologist with a special interest in thoracic pathology. He received
`his MB BS (medical degree) from Charing Cross and Westminster Medical School at London
`University in 1987 and was awarded Fellowship in the Royal College of Pathologists in
`Histopathology in 1993. Dr. Attanoos is an invited member of the International Mesothelioma
`Panel, the US-Canadian Mesothelioma Panel, and the Asbestosis Committee of the College of
`American Pathologists/Pulmonary Pathology Society. He is the past chair of the Pulmonary
`Pathology Working Group, European Society of Pathology, and the current chair of the
`Pulmonary Pathology Society Research Award Committee. In 2008, Dr. Attanoos was enlisted
`as a medical advisor to the All- Party Parliamentary Committee of the British government on
`the Health Effects of Asbestos. He has published approximately 100 papers in the peer-reviewed
`medical and scientific literature, many of which are in the fields of occupational lung disease,
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`asbestos and mesothelioma. In 2015, he was a contributing author to Chapter 2 of the Fourth
`Edition of the World Health Organization Classification of Tumours of the Lung, Pleura,
`Mediastinum and Heart. His qualifications are set out in greater detail in his curriculum vitae,
`a copy of which is available upon request. Dr. Attanoos has been actively involved in the
`research of malignant mesothelioma and mineral particles since 1991. In 2008, Dr. Attanoos
`was enlisted as a medical advisor to the All-Party Parliamentary Committee of the British
`government on the Health Effects of Asbestos. Dr. Attanoos has been invited by the W.H.O. to
`serve as Task force member on the Health effects of Bentonite and Clay minerals. He has
`published over 125 papers in the peer-reviewed medical and scientific literature, many of which
`are in the fields of occupational lung disease, asbestosis and mesothelioma.
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`Dr. Attanoos may testify as to the general medical aspects of the diagnosis of lung
`cancer, asbestosis, and mesothelioma and the pathological effects of asbestos on the lung. He
`may also testify as to the relationship of asbestos exposure, if any, and the incidence of the
`conditions alleged by the plaintiff, including pleural plaques, lung cancer, asbestosis and
`mesothelioma.
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`Dr. Attanoos may testify that “asbestos” is a generic term for a group of naturally
`occurring fibrous minerals. Dr. Attanoos may testify that there are two major groups of asbestos
`– serpentine and amphiboles – which have different physical forms and clearance rates after
`deposition in human lungs. Dr. Attanoos may testify that the serpentine group contains one form
`of asbestos – chrysotile – and that the amphibole group contains several forms of asbestos –
`including crocidolite, amosite, tremolite, actintolite, and anthophyllite. Dr. Attanoos may testify
`regarding the differing potential of these various forms of asbestos to cause conditions alleged
`by the plaintiff, including pleural plaques and mesothelioma. Dr. Attanoos may testify generally
`regarding the role that the size, structure and chemical composition of different types of asbestos
`fibers plays in their ability, or lack thereof, to cause conditions alleged by the plaintiff.
`Specifically, amphibole asbestos is far more potent than chrysotile asbestos as a result of its
`long, straight structure and its biopersistence in the human body. Dr. Attanoos may testify
`regarding the evidence that exposure to amphibole asbestos explains the incidence of certain
`asbestos- related disease among individuals exposed to chrysotile asbestos.
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`Dr. Attanoos may testify generally regarding the role of dose in determining whether
`certain types of asbestos fibers can cause or contribute to conditions alleged by the plaintiff.
`There is no evidence that exposure to low doses of chrysotile asbestos increases the risk of
`asbestos-related disease, including mesothelioma. Dr. Attanoos may testify generally regarding
`the latency periods associated with asbestos-related conditions alleged by the plaintiff.
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`Dr. Attanoos may also refer to, among others, the study by Bernstein, et al. on the
`evaluation of the deposition, translocation and pathological response of the lung and pleura to
`brake dust with and without added chrysotile in comparison to crocidolite asbestos following
`short-term inhalation, including the articles published by Bernstein et al. in Toxicology and
`Applied Pharmacology in 2014 and 2015. Dr. Attanoos may discuss the results of the study,
`specifically the deposition, translocation, and pathological response in the lung and pleura of
`rats to short term exposures to high concentrations of brake dust, crocidolite, brake dust
`enhanced with additional chrysotile, and normal air. He may discuss the differences in
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`biopersistence and pathological response in the lung and pleura between brake dust derived
`from brake pads manufactured with chrysotile compared to crocidolite asbestos and normal air
`controls.
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`Dr. Attanoos may testify that the epidemiological evidence, as well as fiber burden
`studies, involving auto mechanics, and other friction product workers, has consistently
`demonstrated that there is no increased risk of asbestosis, lung cancer, or mesothelioma in such
`workers from asbestos exposure.
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`Dr. Attanoos may testify about the causes of mesothelioma, including erionite and
`therapeutic radiation. He may testify that a significant percentage of mesotheliomas are
`idiopathic, or spontaneous, and have no association with asbestos exposure.
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`Dr. Attanoos may testify peritoneal mesotheliomas, when asbestos-related, have been
`associated with heavy, prolonged exposure to amphibole asbestos. There is no convincing
`evidence that exposure to chrysotile asbestos causes peritoneal mesothelioma.
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`Dr. Attanoos may review Plaintiff’s medical records and history as well as available
`pathology. He may testify regarding the diagnosis and cause of any purportedly asbestos-
`related disease or condition alleged by Plaintiff and respond to testimony by any of plaintiff’s
`experts regarding the same. Dr. Attanoos may also testify regarding other probable or possible
`causes of any disease or condition alleged by Plaintiff, including but not limited to, smoking
`where relevant. Dr. Attanoos may be asked to respond to the testimony and documents of certain
`witnesses offered at the time of trial or in deposition, including, but not limited to, testimony of
`witnesses offered by the plaintiffs. He may also be asked to review pertinent medical records
`and medical materials and offer his opinions on the medical condition of the plaintiff.
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`Dr. Attanoos may also testify regarding the role of genetic mutations in the causation of
`mesothelioma and lung cancer, and address genetic causes and environmental causes unrelated
`to asbestos, including radiation, cigarette smoke and other carcinogens.
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`3. Mary Beth Beasley, M.D.
`Mt. Sinai Medical Center
`Department of Pathology
`One Gustave L. Levy Place, Box 1194
`New York, NY 10029
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`It is expected that by the time of a deposition, Dr. Beasley will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Beasley’s fee for providing deposition
`testimony is $600.00 per hour, with a one-hour minimum. I am informed and believe that this
`witness has agreed with counsel for International to testify at trial of matters of this nature.
`Dr. Beasley is a pathologist. She may testify, live or by deposition, concerning her
`review of the medical records, pathology and/or work history of Plaintiff and Plaintiff’s medical
`condition, and the cause of Plaintiff’s medical condition. Her testimony may also include
`discussion of asbestos and its effect on human health generally and Plaintiff specifically, and
`the effect that other substances have on human health generally and Plaintiff’s condition
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`specifically. Dr. Beasley may also testify regarding the medical conditions of Plaintiff based on
`review of medical records, x-rays, Plaintiff’s experts’ reports and supplemental reports and her
`training, experience, and other special expertise. Further, Dr. Beasley may testify concerning
`the increased risk, if any, of cancer faced by asbestos exposed workers and the prognosis of
`such individuals.
`In addition, if called to testify, either live or by deposition, Dr. Beasley is expected to
`provide testimony regarding the areas stated below:
`(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;
`(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 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) diagnosis of the physical condition and relationship, if any, between Plaintiff’s
`exposure to asbestos as well as asbestos exposure through gasket work or brake
`or clutch servicing;
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`(18) may testify in the area of the medical and scientific aspects of exposure to dust
`as produced by gasket, brake or clutch products and the development of
`asbestos-related disease generally;
`(19) the difference in fiber composition, fiber durability, the human body’s ability to
`clear certain fibers and the fibers relation to types cancer, if any;
`(20) the role of genetic mutations, including BAP-1, in the causation of
`mesothelioma; and
`(21) to the extent not covered above, asbestos medicine in general.
`4. Phillip Jay Beron, M.D.
`Radiation Oncologist
`3104 E Camelback Road
`Phoenix, AZ 85016
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`Dr. Beron may be called to testify and if so, will testify regarding the connection
`between plaintiff’s or decedent’s medical condition and radiation treatment for lymphoma. Dr.
`Beron has agreed, if called, to testify at the trial of this matter and will be sufficiently familiar
`with the pending action to submit to a meaningful oral deposition concerning any opinion and
`its basis. Dr. Beron’s hourly consultation and deposition fee is $850.00 and is tracked to the
`nearest quarter of an hour. Deposition fees must be paid in advance a full five business days
`prior to the time reserved for the deposition. Cancellation of a deposition with one or two
`business days’ notice will result in a cancellation fee equal to 50% of the advance payment
`made for the deposition, and if the deposition is cancelled or rescheduled the same day it is
`scheduled, the cancellation fee is 100% of the advance payment made for the deposition.
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`His court appearance fee is $5,000.00 per half day or $10,000.00 per day...
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`5. Charles Blake, C.I.H.
`Apex Companies, LLC
`965 Piedmont Rd., Ste 100
`Marietta, GA 30066.
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`It is expected that by the time of a deposition, Mr. Blake will be sufficiently familiar
`with this case to provide meaningful testimony. Mr. Blake’s fee for providing deposition
`testimony is $350.00 per hour, with a one-hour minimum. I am informed and believe that this
`witness has agreed with counsel for International to testify at trial of matters of this nature.
`Mr. Blake is a certified industrial hygienist. He is expected to testify regarding general
`industrial hygiene principles and the role of the industrial hygienist in proper occupational
`airborne sampling for asbestos and other substances. He will also discuss the asbestos exposures
`of persons that do brake maintenance work and other vehicle repair work as those exposures
`are reported in both the peer reviewed and NIOSH literature. He will opine that the exposures
`of such persons are low dose exposures, generally at or beneath the OSHA levels. He will opine
`that such exposures do not create the risk of contracting asbestos-related diseases. He will
`discuss the significance of fiber type, size, decomposition, and conversion. Mr. Blake is also
`knowledgeable about vehicle maintenance procedures and he will be called upon to testify
`regarding the specifics of some of those procedures. Mr. Blake’s testimony will also include
`discussion of protocols established by both OSHA and the scientific community for
`occupational airborne sampling. He will also discuss the differences between direct and indirect
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`filter preparation vis a vis occupational airborne sampling. He will opine that indirect filter
`preparation is inappropriate for occupational airborne sampling. He will further opine on the
`limited use of Tyndall lighting and its lack of precision with regard to occupational airborne
`sampling. His testimony may also include demonstrative videotapes of sonication and Tyndall
`lighting, and of occupational airborne sampling for asbestos and other substances. His testimony
`may also include a discussion of any studies he has done regarding occupational airborne
`asbestos and brake work. Mr. Blake will provide testimony regarding the field of industrial
`health, industrial hygiene and epidemiology generally and particularly, as it relates to exposure
`to asbestos, health risk assessment, product issues with respect to alleged asbestos exposures,
`substantial exposure factors, the relative and absolute potentials of various asbestos products to
`produce dust, industrial hygiene and environmental standards and their basis, workplace
`practices, control technology, and process specific aspects of exposure, and general industrial
`hygiene issues, including ventilation and distance/exposure potential. Mr. Blake will testify in
`the areas of asbestos and related epidemiology, field sampling, and laboratory measurement.
`He will testify regarding the possibilities of any products in question to develop friable asbestos
`and whether as such it poses any risk of harm. He may also be asked to respond to the testimony
`and documents of witnesses offered at the time of trial or in deposition, but not limited to,
`testimony of witnesses offered by plaintiffs. He may also present historical state-of-the-art
`discussion relative to asbestos health effects, industrial health, epidemiology, regulation, and
`public policy.
`6. Frederick W. Boelter, CIH, PE
`Boelter & Yates, Inc.
`1300 Higgins Road, Suite 301
`Park Ridge, IL 60068
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`It is expected that by the time of a deposition, Mr. Boelter will be sufficiently familiar
`with this case to provide meaningful testimony. Mr. Boelter’s deposition fee will be provided
`upon request. I am informed and believe that this witness has agreed with counsel for
`International to testify at trial of matters of this nature.
`Mr. Boelter is a certified industrial hygienist and an expert in the field of industrial
`hygiene and occupational health. He will testify generally about the science of industrial
`hygiene, and how knowledge of work place hazards, including asbestos, has evolved over time.
`He will testify about the various studies that have been conducted on the content and size of
`asbestos fibers in brake dust, and the conclusions he draws from those studies. He will testify
`about the various studies that have been conducted on the exposure of persons working on
`brakes to asbestos fibers and the conclusions he draws from those studies. He will also discuss
`the studies that have been done on the cumulative lifetime exposure of a mechanic to asbestos
`fibers and how that exposure compares with other occupational exposures. He will discuss the
`relationship between threshold limit values and OSHA permissible exposure limits and the
`exposure of persons working with brake linings. He will comment on statements made by the
`EPA and other governmental entities on the exposure of persons working with brake linings to
`asbestos fibers. Mr. Boelter will also testify about Plaintiff’s occupational and para-
`occupational exposure to asbestos from all sources and will give his analysis and opinions on
`the occupational and para-occupational exposures of Plaintiff to asbestos fibers, including but
`not limited to, levels of exposure Plaintiff incurred and Plaintiff’s cumulative asbestos fiber
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`dose. He may also give opinions on the toxicity of various asbestos fiber types and their
`propensity to cause disease. Mr. Boelter may opine as to whether Plaintiff’s non-friction
`asbestos exposures put Plaintiff at risk of developing an asbestos-related disease.
`7. William S. Breall, M.D.
`2250 Hayes St., Ste. 204
`San Francisco, CA 94117
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`It is expected that by the time of a deposition, Dr. Breall will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Breall's deposition fee is $500.00 per hour.
`Dr. Breall has a 48-hour cancellation policy. I am informed and believe that this witness has
`agreed with counsel for International to testify at trial of matters of this nature.
`Dr. Breall is a cardiologist and internist. Dr. Breall may be called to testify and if so,
`will testify regarding his knowledge of cardiovascular organ functions, Plaintiff’s medical
`condition and prognosis, issues of alternative causation and life shortening problems not related
`to alleged asbestos exposure.
`8. C. Alan Brown, M.D.
`Cottage Health
`400 W. Pueblo Street
`Santa Barbara, California 93105
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`C. Alan Brown, M.D. is a board-certified cardiologist. He will be sufficiently familiar
`with the pending action and prepared to submit meaningful oral deposition testimony for
`purposes of trial. Dr. Brown may testify concerning plaintiff Michael Spielman’s medical
`condition, prognosis, and causation. Dr. Brown may also testify regarding plaintiff Michael
`Spielman’s health history.
`If called to testify in any matter, Dr. Brown will be sufficiently familiar with the facts
`of the case to submit a meaningful oral deposition concerning the specific testimony, including
`any opinion and its basis, that he is expected to give at trial. Dr. Brown charges $750.00 per
`hour for deposition testimony for a minimum of two hours. He charges a full day minimum for
`depositions and court or arbitration appearances outside Santa Barbara and Ventura counties.
`His consultation fee is $750.00 per hour. Court Appearances: $6,000 per day or $3,000 per half-
`day out-of-office plus travel expenses.
`9. James L. Caplan, M. D.
`250 N. Robertson Blvd., Ste. 606
`Beverly Hills, CA 90211
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`It is expected that by the time of a deposition, Dr. Caplan will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Caplan's fee for deposition is $600 for a
`minimum of two hours; ($300.00 every hour after that). I am informed and believe that this
`witness has agreed with counsel for International to testify at trial of matters of this nature.
`James L. Caplan, M. D. is a Board Certified physician specializing in internal and
`pulmonary medicine. Dr. Caplan received his M.D. from the University of Pennsylvania. He is
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`the Clinical Chief, Pulmonary Division, at the Cedar-Sinai Medical Center. He is a Certified B
`reader. He may be called to testify and if so, will testify regarding his knowledge of lungs and
`thoracic organ functions, Plaintiff’s medical condition, cause and prognosis, issues of
`alternative causation and life shortening problems not related to alleged asbestos exposure. Dr.
`Caplan may also testify about his opinions based upon his review of medical records including
`radiographic and laboratory studies and possibly a medical examination of Plaintiff.
`10. Lucian R. Chirieac, M.D.
`Department of Pathology
`Brigham and Women’s Hospital
`75 Francis St.
`Boston, MA 02115
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`It is expected that by the time of a deposition, Dr. Chirieac will be sufficiently familiar
`with this case to provide meaningful testimony. Dr. Chirieac’s fee for providing deposition
`testimony is $750.00 per hour. Dr. Chirieac will charge a cancellation fee if the deposition is
`canceled or rescheduled within one week of the deposition date. I am informed and believe that
`this witness has agreed with counsel for International to testify at trial of matters of this nature.
`Dr. Chirieac is a pathologist. He may testify, live or by deposition, concerning his review
`of the medical records, pathology and/or work history of Plaintiff and Plaintiff’s medical
`condition, and the cause of Plaintiff’s medical condition. His testimony may also include
`discussion of asbestos and its effect on human health generally and Plaintiff specifically, and
`the effect that other substances have on human health generally and Plaintiff’s condition
`specifically. We may address scientific literature, including epidemiology studies, concerning
`various health conditions due to asbestos and other causes. Dr. Chirieac may also testify
`regarding the medical conditions of Plaintiff based on review of medical records, x-rays,
`Plaintiffs’ experts’ reports and supplemental reports and his training, experience, and other
`special expertise. Further, Dr. Chirieac may testify concerning the increased risk, if any, of
`cancer faced by asbestos exposed individuals and the prognosis of such individuals.
`In addition, if called to testify, either live or by deposition, Dr. Chirieac is expected to
`provide testimony regarding the areas stated below:
`(1) the relationship between therapeutic radiation and causation of mesothelioma;
`(2) 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;
`(3) the nature of asbestos and asbestos-related diseases;
`(4) the symptomatology, disease process and diagnosis of asbestosis and cancer
`associated with the respiratory system, peritoneum and peritoneal cavity;
`(5) the nature and extent of medical and scientific knowledge regarding any
`association of obstructive pulmonary disease with asbestos fiber exposure;
`(6) 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;
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`(7) 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;
`(8) 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;
`(9) cigarette smoking and its effects on the lungs and other organs;
`(10) the relationship of cigarette smoking to cancer of the lung and cancers of other
`body parts with reference to epidemiology studies and physiologic effect;
`(11) the difference between pulmonary impairment and disability;
`(12) the effect of asbestosis or other asbestos-related disease, or asbestos exposure
`without asbestosis or other asbestos-related disease, on disability and life
`expectancy;
`(13) the lack of relationship between the presence of pleural plaques and a later
`development of any form of cancer;
`(14) the history of evolution and knowledge of asbestos related diseases;
`(15) the import of any exhibit introduced as evidence, or any items prepared for use
`or used for demonstrative purposed by any witness;
`(16) cancer incidence in the general population and among asbestos workers and its
`potential causes;
`(17) the incidence of cancer among various kinds of individuals exposed to asbestos,
`and the relative importance of various fiber types, size, decomposition and
`conversion with respect to cancer and other conditions; and;
`(18) diagnosis of the physical condition and relationship, if any, between Plaintiff
`and/or Plaintiff’s exposure to asbestos as well as asbestos exposure through
`brake or clutch servicing;
`(19) may testify in the area of the medical and scientific aspects of exposure to dust
`as produced by brake or clutch products and the development of asbestos-related
`disease generally;
`(20) the difference in fiber composition, fiber durabil