DOCKET NO. KNL-CV-14-6022140-S
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`CARL UPTON,
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`Plaintiff,
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`VS.
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`A.W. CHESTERTON COMPANY, ET AL
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`Defendants
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`SUPERIOR COURT
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`J.D. OF NEW LONDON
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`AT NEW LONDON
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`AUGUST 1, 2016
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`PLAINTIFF'S WITNESS DISCLOSURE
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`Pursuant to Connecticut Practice Book Section 13-4, Plaintiff hereby discloses expert
`witnesses and offers a statement of the opinions the witnesses will express and the basis and
`reasons for them, the exhibits, data and other information that has been or will be used to
`summarize or support their opinions, a statement of the substance of the facts and opinions to
`which the experts are expected to testify and summaries of the grounds for their opinions.
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`As discovery is still ongoing, plaintiff reserves the right to supplement this disclosure
`with additional witnesses as they are discovered or their testimony becomes relevant, and to
`substitute any witness in the event any witnesses named herein is unavailable to appear at trial.
`Plaintiff is continuing trial preparation of this matter and reserves the right to file a list of
`additional expert witnesses, medical or otherwise. Plaintiff hereby incorporates any prior
`disclosures of product identification and co-worker witnesses, the subject matter of their
`testimony has been provided. Plaintiff reserves the right to call other lay, product identification,
`and co-worker witnesses.
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`Plaintiff reserves the right to call other expert witnesses and diagnostic / treating
`physicians and medical practitioners for purposes of rebuttal and for other issues not anticipated.
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`Plaintiff reserves the right to call these witnesses either live or by deposition and reserves
`the right to call at trial any additional witnesses, fact and expert, for rebuttal and impeachment
`purposes.
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`Plaintiff reserves the right to supplement this disclosure at any time before trial with prior
`testimony of any of the experts or with written reports as the same become available in
`accordance with the pretrial order.
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`Custodian of medical and business records will be called, if necessary, to
`I.
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`authenticate the medical records of the plaintiff and business records.
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` (Live or by deposition)
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`Expert Witnesses
`II.
`The plaintiff hereby incorporates any prior disclosures of expert and diagnostic witnesses
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`and supplements as follows:
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`1. Dr. Susan Daum, M.D.
` 6 East 96th Street Apt. 5A
` New York, New York 10128
` (212) 876-9273
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`Dr. Daum is an occupational and environmental physician who may be called upon to
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`testify in this case. Dr. Daum was on the faculty of the Mt. Sinai School of Medicine and has
`conducted extensive research on the health effects of asbestos exposure. She has worked closely
`with Dr. Irving J. Selikoff, a world-renowned expert on asbestos-associated diseases.
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`Dr. Daum may be asked to examine the medical records, reports and results of the
`plaintiff, and based on her experience, knowledge and review of the medical literature,
`experience and training, state her opinion that the plaintiff suffered from lung cancer, loss of
`lung function and / or other asbestos-related diseases; the cause oflung cancer, loss of lung
`function and / or other asbestos-related diseases; and that lung cancer, loss of lung function and
`/or other asbestos-related diseases caused the plaintiff's symptoms. Dr. Daum may testify
`regarding the increased risk persons exposed to asbestos, such as the plaintiff, have in developing
`diseases including but not limited to lung cancer, loss of lung function and other asbestos-related
`diseases; the factors in the risk and the development of lung cancer, loss of lung function and
`other asbestos-related diseases; and the relationship asbestos-related diseases may have in
`causing and increasing the risk and severity of heart disease, congestive heart failure and other
`diseases and illnesses.
`Dr. Daum will rely on the medical records, results and reports of the plaintiff. Dr. Daum
`will also base her opinions on her extensive review of the medical literature concerning asbestos-
`related injuries and asbestos exposure and the results of her own research and the research of her
`colleagues. Dr. Daum will review the state of the art, the defendants’ knowledge of asbestos-
`related exposures and when the defendants knew or should have known about the hazards of
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`asbestos and their products. She will discuss the special hazards asbestos presents to tobacco-
`consuming and tobacco-exposed workers.
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`Dr. Daum may also testify as to the general medical issues concerning the development,
`cause and diagnosis of lung cancer, loss of lung function and other asbestos-related diseases; the
`environmental evidence in developing lung cancer, loss of lung function and other asbestos-
`related diseases; and the state of the art regarding occupational and environmental factors of
`asbestos use.
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`Dr. Daum may offer diagnostic testimony and testimony based on her review of the
`statements of the plaintiff, co-workers and product identification witnesses, medical records,
`results and reports and will base her opinion upon occupational history, subjective medical
`findings, and a review of medical literature.
`Further, she may respond to or comment upon records, evidence and testimony regarding
`the defendants and to the opinions offered by any other experts and /or fact witnesses relating to
`any subject matter that pertain to her specialties or areas of expertise and experience.
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`The report rendered by this expert witness as well as expert qualifications, writings, list
`of testimony, and invoice has been or will be provided under separate cover.
`2. Dr. Jerrold L. Abraham
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`(Live or by deposition)
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`University Pathologists Laboratories
`Department of Pathology
`750 East Adams Street
`Syracuse, NY 13210
`(315) 464-4750
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`Dr. Jerrold Abraham is a practicing pathologist at the University Pathologists
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`Laboratories, LLP. Dr. Abraham may be asked to review the pathology material, pathology
`reports, other medical reports, results and records and the literature, and he may be called to
`testify concerning his findings based on a review of the pathology material, pathology reports
`and other medical reports and records. It is expected that he will base his diagnoses on the
`growth and histological appearance of the tumors, other pathology materials and reports, medical
`records, results and reports and the literature.
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`Dr. Abraham may testify as to the relationship between asbestos exposure and the
`development of lung cancer, loss of lung function and other asbestos-related diseases. He will
`state that most mesotheliomas are caused by exposure to asbestos, and he will state that all forms
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`of asbestos are capable of producing mesothelioma, lung cancer, other cancers, asbestosis, other
`lung diseases, pleural plaques, thickening, scarring and effusions, loss of lung function and other
`asbestos-related diseases.
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`Dr. Abraham may testify regarding the asbestos levels capable of producing lung cancer,
`loss of lung function and other asbestos-related diseases. He may also testify as to the general
`medical issues concerning the development, cause and diagnosis of lung cancer, loss of lung
`function and other asbestos-related diseases.
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`Dr. Abraham may testify regarding the increased risk persons exposed to asbestos, such
`as the plaintiff, have in developing diseases including but not limited to lung cancer, loss of lung
`function and other asbestos-related diseases; the factors in the risk and the development of lung
`cancer, loss of lung function and other asbestos-related diseases; and the relationship asbestos-
`related diseases may have in causing and increasing the risk and severity of heart disease,
`congestive heart failure and other diseases and illnesses. He may also testify as to the general
`medical issues concerning the development, cause and diagnosis of lung cancer, loss of lung
`function and other asbestos-related diseases.
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`Dr. Abraham may offer diagnostic testimony and testimony based on his review of the
`statements of the plaintiff, co-workers and product identification witnesses, medical records,
`results and reports and will base his opinion upon occupational history, subjective medical
`findings, and a review of medical literature.
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`Dr. Abraham will review the state of the art and the defendants’ knowledge of asbestos
`related exposures and when the defendants knew or should have known about the hazards of
`asbestos and their products. He will discuss the special hazards asbestos presents to tobacco-
`consuming and tobacco-exposed workers. Further, he may respond to or comment upon records,
`evidence and testimony regarding the defendants and to the opinions offered by any other experts
`and /or fact witnesses relating to any subject matter that pertain to his specialties or areas of
`expertise and experience.
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`The report rendered by this expert witness as well as expert qualifications, writings, list
`of testimony, and invoice has been or will be provided under separate cover.
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` 3.
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`Arthur C. DeGraff, Jr., M.D.
`160 Hunter Drive
`West Hartford, CT 06107
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`Dr. Arthur DeGraff is a Pulmonary Specialist practicing in private consultation practice
`and as President of the Physicians Research Center, Inc., Hartford, CT. Dr. DeGraff may be
`called upon to testify as to the plaintiff’s medical conditions of lung cancer and the relationship
`to asbestos based on his experience, knowledge and knowledge and review of the medical and
`other literature, expertise and training. He will base his testimony on his knowledge and review
`of the literature, experience, training, knowledge and his interpretation of medical reports, results
`and records, hospital studies, x-rays, pathology results, pulmonary function studies and explain
`their significance in light of the plaintiff’s occupational history of exposure. Dr. DeGraff may
`also testify as to asbestos-exposed workers and the special risks asbestos poses for asbestos
`exposed workers who consume tobacco products.
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`Dr. DeGraff may testify as to the relationship between asbestos exposure and the
`development of mesothelioma, lung cancer, other cancers, asbestosis, other lung diseases, pleural
`plaques, thickening, scarring and effusions, loss of lung function and other asbestos-related
`diseases, the increased risk persons exposed to asbestos, such as the plaintiff, have in developing
`diseases including but not limited to mesothelioma, lung cancer, other cancers, asbestosis, other
`lung diseases, pleural plaques, thickening, scarring and effusions, loss of lung function and other
`asbestos-related diseases, the factors in the risk and the development of mesothelioma, lung
`cancer, other cancers, asbestosis, other lung diseases, pleural plaques, thickening, scarring and
`effusions, loss of lung function and other asbestos-related diseases, and the relationship asbestos-
`related diseases may have in causing and increasing the risk and severity of heart disease,
`congestive heart failure and other diseases and illnesses. He may testify as to the general
`medical issues concerning the development, cause and diagnosis of mesothelioma, lung cancer,
`other cancers, asbestosis, other lung diseases, pleural plaques, thickening, scarring and effusions,
`loss of lung function and other asbestos-related diseases.
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`Dr. DeGraff will review the state of the art, the defendants’ knowledge of asbestos related
`exposures and when the defendants knew or should have known about the hazards of asbestos
`and their products. He will discuss the special hazards asbestos presents to tobacco- consuming
`workers.
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`Dr. DeGraff may offer diagnostic testimony and testimony based on his review of the
`statements of the plaintiff, co-workers and product identification witnesses, medical records,
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`(Live or by deposition)
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`results and reports and will base his opinion upon occupational history, subjective medical
`findings, and a review of medical literature.
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`Any reports rendered by Dr. DeGraff have been or will be provided.
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`4.
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`Laura Welch, MD
`The Center to Protect Workers Rights Inc.
`7118 Cedar Ave
`Takoma Park, MD 20912-4252
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`Dr. Laura S. Welch is a physician with board certification in both Occupational and
`Environmental Medicine and Internal Medicine. She received her medical degree from the State
`University of New York at Stony Brook, and has held faculty positions at the Schools of
`Medicine at Albert Einstein, Yale, and George Washington Universities. She has extensive
`experience in diagnosis and treatment of asbestos-related diseases. She has been in occupational
`medicine practice for more than 25 years, and a substantial part of her practice has consisted of
`the examination of workers exposed to asbestos. Dr. Welch recently retired as medical director at
`The Center to Protect Workers Rights, a research institute in Washington, D.C.
`Dr. Welch will testify about the properties and composition of asbestos, the properties
`that cause disease and the pathogenesis, how asbestos is measured in the air, diseases caused by
`asbestos, mechanisms of asbestos fiber carcinogenesis, general and specific causation of asbestos
`disease, and the mechanisms of exposure to asbestos.
`Dr. Welch will testify based on her experience, knowledge and review of the literature,
`and her expertise and training, about the relationship between asbestos exposure and the
`development of mesothelioma, lung cancer, other cancers, asbestosis, other lung diseases, pleural
`plaques, thickening and effusions, and other asbestos-related diseases; including but not limited
`to lung cancer, other cancers, asbestosis, other lung diseases, pleural plaques, thickening,
`scarring and effusions, loss of lung function and other asbestos-related diseases; the factors in the
`risk and the development of lung cancer, other cancers, asbestosis, other lung diseases, pleural
`plaques, thickening, scarring and effusions, loss of lung function and other asbestos-related
`diseases; the environmental evidence in developing lung cancer, other cancers, asbestosis, other
`lung diseases, pleural plaques, thickening, scarring and effusions, loss of lung function and other
`asbestos-related diseases; attribution and the relationship asbestos-related diseases may have in
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`causing and increasing the risk and severity of heart disease, congestive heart failure and other
`diseases and illnesses. Dr. Welch will also testify as to the general medical issues concerning the
`development, cause and diagnosis of lung cancer, other cancers, asbestosis, other lung diseases,
`pleural plaques, thickening, scarring and effusions, loss of lung function and other asbestos-
`related diseases.
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`Dr. Welch will testify about the state of the knowledge regarding the hazards of asbestos
`and the hazards produced by asbestos, the need to limit and reduce exposure to asbestos and the
`defendants’ knowledge of asbestos related exposures and when the defendants knew or should
`have known about the hazards of asbestos and their products. She will review the special risks
`and hazards of asbestos products on tobacco consuming workers.
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`Dr. Welch may offer diagnostic testimony and testimony based on her review of Mr.
`Upton’s statements, co-worker and product identification witness statements, medical records
`and reports, and will base her opinion upon occupational history, subjective medical findings,
`and a review of medical literature.
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`Dr. Welch’s report in this case is attached, as well as her expert qualifications, writings
`and a list of testimony.
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`Capt. R. Bruce Woodruff, AinstlB.
`5.
` 6210 Shelter Cove Pointe
` Midlothian, VA 23112
` (804) 639-1224
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`(Live or by deposition)
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`Captain Woodruff is a retired U.S. Navy Engineering Duty Officer and holds the degrees
`of Ocean Engineer (Naval Architecture/Marine Engineering) and Master of Science in
`Mechanical Engineering from MIT. From the U.S. Naval Academy at Annapolis, he graduated
`with distinction with a degree of B.S. in Engineering (Naval Science). He attended the Industrial
`College of the Armed Forces (National Defense University) and also the U.S. Navy Submarine
`Nuclear Ship Superintendent Course at Puget Sound Naval Shipyard (S5W Reactor Physics and
`Radiological Controls).
`Captain Woodruff held three commands prior to retiring from the U.S. Navy. He was the
`Commanding Officer of SUPSHIP Pascagoula (MS) and Major Program Manager in
`Washington, D.C. for both the CG 47 Class Aegis Guided Missile Cruiser and the FFG 7 Class
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`Guided Missile Frigate ships. His prior duties included Production Officer at the Norfolk Naval
`Shipyard, Repair Officer on a nuclear-certified Destroyer Tender, and Chief Engineer and Main
`Propulsion Assistant on two Navy destroyers.
`Prior to his current position, he was the Vice President and Division General Manager for
`the Turbine Manufacturing Division of Asea Brown Boveri (ABB) Power Generation in
`Richmond VA.
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`Based on his experience, knowledge, expertise and training, Captain Woodruff will offer
`testimony regarding U.S. Navy and commercial ship design, construction and maintenance. In
`particular, he will address the specifications for and use of asbestos containing insulation,
`including asbestos aboard ship and present in shipyards for various marine engineering
`applications. This may include boilers, steam generators, main and auxiliary steam systems, and
`the equipment connected to the steam systems, i.e., pumps, valves, etc. He will address the use
`of asbestos for insulation, lagging, gaskets, and packing aboard ships and in shipyards.
`Captain Woodruff will testify as to the authenticity and meaning of records,
`specifications, qualified products lists and other documents pertaining to Navy and commercial
`ship construction and repair and overhaul.
`Captain Woodruff will offer testimony regarding research, development, design,
`engineering, procurement and shipyard production practices for Navy and commercial ships in
`regard to asbestos containing materials on board ship and in shipyard shops.
`Captain Woodruff will also testify about the plaintiff’s opportunities for exposure to
`asbestos-containing materials on board Navy vessels and submarines under construction and
`repair.
`Based on Captain Woodruff’s research, education, training, and experience, Captain
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`Woodruff will identify and testify about the use of the defendants’ products on board submarines
`and submarines under construction on which the plaintiff worked. Capt. Woodruff will also
`offer testimony based on his review of the statements of the plaintiff, co-workers and product
`identification witnesses.
`Further, he may respond to or comment upon records, evidence and testimony regarding
`the defendants and to the opinions offered by any other experts and /or fact witnesses relating to
`any subject matter that pertain to his specialties or areas of expertise and experience.
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`Captain Woodruff will also offer testimony that the defendants had a duty to place
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`warnings regarding asbestos hazards on their products, had the opportunity to place warnings on
`their products, and failed and neglected to do so.
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`The report rendered by Captain Woodruff as well as expert qualifications, writings, list of
`testimony, and invoice have been or will be provided under separate cover.
`6.
`Dr. Barry Castleman, Sc.D.
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`(Live or by deposition)
`Environmental Consultant
`P.O. Box 188
`Garrett Park, MD 20896
`Dr. Barry Castleman is an environmental consultant. He holds a bachelor's degree in
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`chemical engineering, a master’s degree in environmental engineering, and a doctorate in public
`health policy from the Johns Hopkins School of Hygiene and Public Health. He is the author of
`Asbestos: Medical and Legal Aspects, (5th Ed., 2005).
`Based on Dr. Castleman’s experience, knowledge, expertise and training, he will testify
`regarding general state of the art issues, including the body of knowledge that exists about the
`danger of asbestos, industry and defendants’ knowledge of asbestos hazards, when the
`defendants knew or should have known the risks posed by asbestos and their products and the
`need of the defendants to warn of the hazards posed by asbestos and their products and to reduce
`or eliminate asbestos exposure, and the uses of asbestos in products.
`Dr. Castleman may testify regarding the specific knowledge and activities of defendant
`manufacturers based on his review of corporate documents and relevant material. Dr.
`Castleman will review the special risks asbestos poses for workers who consume or are exposed
`to tobacco products.
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`Based on his experience, knowledge, expertise and training, Dr. Castleman may testify
`regarding the plaintiff's exposure, the evaluation of asbestos materials, materials-testing
`techniques, air sampling techniques, dust sampling techniques, fiber counting techniques,
`governmental regulations concerning asbestos, exposure measures and limits, as well as facts and
`circumstances relating thereto. Dr. Castleman may also testify regarding his opinion of the
`composition risks incident to the exposure to and characteristics of asbestos products at points of
`manufacture, application and use. Additionally, Dr. Castleman may testify regarding EPA and
`state governmental policies, regulations and guidelines pertaining to asbestos and the utility of
`air and dust sampling in determining exposures and risks. Dr. Castleman may further testify as
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`to facts and circumstances regarding the nature of the damages that are subject to this action,
`industrial hygiene, risk analysis and assessment, safety considerations, public safety and policy.
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`Dr. Castleman will identify and disclose use of the defendants’ products at sites where
`the plaintiff worked. Dr. Castleman may also offer testimony based on his review of the
`statements of the plaintiff, co-workers and product identification witnesses. Further, he may
`respond to or comment upon records, evidence and testimony regarding the defendants and to the
`opinions offered by any other experts and /or fact witnesses relating to any subject matter that
`pertain to his specialties or areas of expertise and experience.
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`The report rendered by this expert witness as well as expert qualifications, writings, list
`of testimony, and invoice has been or will be provided under separate cover, as it is too large to
`transmit electronically.
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`7.
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`William Ewing, C.I.H.
`Compass Environmental, Inc.
`1751 McCollum Parkway
`Kennesaw, GA 30144-5908
`(770) 449-7127
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`Mr. Ewing is a board-certified industrial hygienist. Industrial Hygiene is the field of
`identification, evaluation and control of occupational and environmental health hazards. Mr.
`Ewing is the technical director of Compass Environmental, Inc. He has practiced industrial
`hygiene for over 30 years with emphasis on asbestos exposure. He participated in the asbestos
`survey of the aircraft carrier, USS Lexington. He has conducted sampling for asbestos and has
`analyzed samples over the course of his career; thus, he is uniquely familiar with the standards,
`guidelines and regulations applicable to human exposure to asbestos. He is the former director
`of the Environmental Protection Agency-sponsored Asbestos Information Center at the Georgia
`Tech Research Institute. He has published extensively on the subject of asbestos exposure. His
`hourly rate is $245.
`Based on Mr. Ewing’s experience, knowledge, expertise and training, he may testify
`regarding the evaluation of asbestos materials, materials-testing techniques, air sampling
`techniques, dust sampling techniques, fiber counting techniques, governmental regulations
`concerning asbestos, exposure measures and limits, as well as facts and circumstances relating
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`thereto. Mr. Ewing may also testify regarding his opinion of the composition risks incident to
`the exposure to and characteristics of asbestos products at points of manufacture, application and
`use, and the risks of exposure as a by-stander and/or user of asbestos products. Additionally, Mr.
`Ewing may testify regarding EPA and state governmental policies, regulations and guidelines
`pertaining to asbestos and the utility of air and dust sampling in determining exposures and risks.
`Mr. Ewing may further testify as to facts and circumstances regarding the nature of the damages
`that are subject to this action, industrial hygiene, risk analysis and assessment, safety
`considerations, public safety and policy.
`Based on Mr. Ewing’s experience, knowledge, expertise and training, he may testify
`regarding the Occupational Health and Safety Administration’s (OSHA) inspection records at the
`locations where the plaintiff was exposed to asbestos. He may testify about the application of
`asbestos in shipbuilding. He may testify about the hazards of asbestos that were known to the
`industrial hygiene community and to the shipbuilding community including frequent vendors of
`component parts and machinery.
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`Mr. Ewing will review the state of the art and will discuss the defendants’ knowledge of
`asbestos exposure, when the defendants knew or should have known the risks posed by asbestos
`and the need of the defendants to warn of the hazards posed by asbestos and to reduce or
`eliminate asbestos exposure.
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`Any reports rendered by Mr. Ewing have been or will be provided. Mr. Ewing’s
`curriculum vitae is attached as well as a list of his publications and testimony.
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`8. Michael B. Teiger, M.D.
`
`New England Integrative Health Associates
`345 North Main Street, 1st Floor
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`West Hartford, CT 06117
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`(Live or by deposition)
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`Dr. Teiger is a pulmonary and occupational lung disease physician who may be called
`upon to testify in this case. Dr. Teiger is a physician in private practice and is an assistant
`professor of medicine at the University of Connecticut Health Center, pulmonary division.
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`Dr. Teiger is the plaintiff’s treating pulmonary physician and therefore will testify
`regarding the plaintiff's medical condition, disease, symptoms, care and treatment, testing,
`including but not limited to pulmonary function tests, radiological tests, pathological tests,
`biopsy results or review or analysis of any records, tissues or fluids of the plaintiff and may
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`testify based upon their evaluation, examination, care and treatment, review or analysis of any
`test results and knowledge of the plaintiff and any records, tissues or fluid.
`Dr. Teiger may also be asked to examine the plaintiff’s other medical records, reports and
`results, and based on his experience, knowledge and review of the medical literature, experience
`and training, state his opinion that the plaintiff suffered from lung cancer, other lung diseases,
`pleural plaques, thickening, scarring and effusions, loss of lung function and / or other asbestos-
`related diseases; the cause of the lung cancer, other lung diseases, pleural plaques, thickening,
`scarring and effusions, loss of lung function and / or other asbestos-related diseases; and that
`lung cancer, other lung diseases, pleural plaques, thickening, scarring and effusions, loss of lung
`function and /or other asbestos-related diseases caused the plaintiff’s illnesses. Dr. Teiger may
`testify regarding the increased risk persons exposed to asbestos, such as the plaintiff, have in
`developing diseases including but not limited to mesothelioma, lung cancer, other cancers,
`asbestosis, other lung diseases, pleural plaques, thickening, scarring and effusions, loss of lung
`function and other asbestos-related diseases; the factors in the risk and the development of
`mesothelioma, lung cancer, other cancers, asbestosis, other lung diseases, pleural plaques,
`thickening, scarring and effusions, loss of lung function and other asbestos-related diseases; and
`the relationship asbestos-related diseases may have in causing and increasing the risk and
`severity of heart disease, congestive heart failure and other diseases and illnesses. Dr. Teiger
`will rely on the medical records, results and reports of the plaintiff. Dr. Teiger will also base his
`opinions on his extensive review of the medical literature concerning asbestos-related injuries
`and asbestos exposure and the results of his own research and the research of his colleagues. Dr.
`Teiger will review the state of the art, the defendants’ knowledge of asbestos related exposures
`and when the defendants knew or should have known about the hazards of asbestos and their
`products. He will discuss the special hazards asbestos presents to tobacco consuming workers.
`
`Dr. Teiger may also testify as to the general medical issues concerning the development,
`cause and diagnosis of lung cancer, other lung diseases, pleural plaques, thickening, scarring and
`effusions, loss of lung function and other asbestos-related diseases; the environmental evidence
`in developing mesothelioma, lung cancer, other cancers, asbestosis, other lung diseases, pleural
`plaques, thickening, scarring and effusions, loss of lung function and other asbestos-related
`diseases; and the state of the art regarding occupational and environmental factors of asbestos
`use.
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`Dr. Teiger may offer diagnostic testimony and testimony based on his treatment of the
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`plaintiff, his review of the statements of the plaintiff, co-workers and product identification
`witnesses, medical records, results and reports and will base his opinion upon occupational
`history, subjective medical findings, and a review of medical literature. Further, he may respond
`to or comment upon records, evidence and testimony regarding the defendants and to the
`opinions offered by any other experts and /or fact witnesses relating to any subject matter that
`pertain to his specialties or areas of expertise and experience.
`
`The report rendered by this expert witness as well as expert qualifications, writings, list
`of testimony, and invoice has been or will be provided under separate cover.
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`III. Health Care Providers Who Rendered Care Or Treatment To The Plaintiff
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` In addition to the experts disclosed above, the plaintiff hereby discloses the following
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`health care providers who rendered care or treatment to the plaintiff who may testify live, by
`deposition, or through their medical reports. They may testify regarding the opinions based upon
`their care or treatment. They may offer expert opinion testimony at trial as to any opinion as to
`which fair notice is given in the disclosed medical records or reports. They may testify regarding
`the plaintiff's medical condition, disease, symptoms, care and treatment, testing, including but
`not limited to pulmonary function tests, radiological tests, pathological tests, biopsy results or
`review or analysis of any records, tissues or fluids of the plaintiff and may testify based upon
`their evaluation, examination, care and treatment, review or analysis of any test results and
`knowledge of the plaintiff and any records, tissues or fluid.
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`The medical records of these health care providers who rendered care or treatment to the
`plaintiff have been provided to the defendants and will be supplemented if additional records are
`received. Furthermore, releases have been provided to each of the defendant’s attorneys
`authorizing each of them to obtain the plaintiff’s treatment records.
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`The plaintiff’s medical providers are as follows:
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`Michael B. Teiger, M.D.
`New England Integrative Health Associates
`345 North Main Street, 1st Floor
`West Hartford, CT 06117
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`John O. Thayer, M.D.
`Cardiothoracic Surgery
`1000 Asylum Avenue, Suite 3201A
`Hartford, CT 06105
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`Joseph Colasanto, M.D.
`St. Francis Hospital and Medical Center
`114 Woodland Street
`Hartford, CT 06105
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`Jacques Mendelsohn, M.D.
`Collins Medical Associates
`506 Cromwell Ave # 201
`Rocky Hill, CT 06067
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`IV. The plaintiff also reserves the right to call any of the following witnesses at trial:
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`A. Custodians of all applicable medical records.
`B. Representatives of the plaintiff's employers.
`C. Any of the plaintiff’s co-workers, supervisors, lead me