IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
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`DEMETRIES J. BRIDGE, an individual,
` Plaintiff,
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` v.
`
`OWENS-CORNING FIBERGLASS
`CORPORATION, et al.,
`
`Defendants.
`
`CIVIL DIVISION
`
`GD 01-5751
`
`FACT WITNESS LIST
`
`Filed on behalf of Defendant:
`Eichleay Corporation
`
`Counsel of Record:
`
`DANIEL E. KRAUTH, ESQUIRE
`Pa. I.D. #59674
`
`ZIMMER KUNZ PLLC
`Firm No. 920
`3300 US STEEL TOWER , 600 Grant St.
`Pittsburgh, PA 15219
`412-281-8000
`
`668586
`1700.0003
`
`
`
`
`
`DEMETRIES J. BRIDGE, an individual,
` Plaintiff,
`
` v.
`
`OWENS-CORNING FIBERGLASS
`CORPORATION, et al.,
`
`Defendants.
`
`CIVIL DIVISION
`
`GD 01-5751
`
`FACT WITNESS LIST
`
`Filed on behalf of Defendant:
`Eichleay Corporation
`
`Counsel of Record:
`
`DANIEL E. KRAUTH, ESQUIRE
`Pa. I.D. #59674
`
`ZIMMER KUNZ PLLC
`Firm No. 920
`3300 US STEEL TOWER , 600 Grant St.
`Pittsburgh, PA 15219
`412-281-8000
`
`668586
`1700.0003
`
`
`
`EICHLEAY CORPORATION'S FACT WITNESSES LIST
`
`
`
`
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`Eichleay Corporation, by and through its counsel, Zimmer Kunz PLLC and Daniel E.
`
`Krauth, Esquire, and files the within FACT WITNESS LIST.
`
`LAY WITNESS LIST
`
`Eichleay Corporation may call any and all of the following witnesses:
`
`Mr. Greg Cesnik
`(Former Eichleay Employee)
`Eichleay Corporation
`6585 Penn Avenue
`Pittsburgh, PA 15206
`
`John Borman
`(Former Eichleay Employee)
`Eichleay Corporation
`6585 Penn Avenue
`Pittsburgh, PA 15206
`
`Mr. William G. Zeilfelder
`4107 Circle Drive
`Allison Park, PA 15101
`
`Mike Milan
`971 Agnew Road
`Pittsburgh, PA
`
`Records Custodian of Eichleay Corporation and/or Eichleay Receivership
`6585 Penn Avenue
`Pittsburgh, PA 15206
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`Any and all parties to this action, including their past or present employees who
`have knowledge of the within actions.
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`Any and all witnesses listed as liability witnesses in Pretrial Statements
`filed by other defendants.
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`Any and all other Eichleay Corporation’s former employees and representatives.
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`Any and all witnesses listed and/or identified as witnesses in Plaintiff's
`Interrogatories, Answers and depositions.
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`668586
`1700.0003
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`Any and all parties to the within action including, but not limited to, corporate
`representatives and plaintiffs.
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`Any and all co-workers who have provided affidavits and/or depositions as to
`other defendants in this litigation, or any and all co-workers listed by the Plaintiffs
`as witnesses against any Defendant.
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`Any and all representatives of contractors for whom and/or around whom
`plaintiffs worked at any facilities during their working careers.
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`DAMAGE WITNESSES
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` Eichleay Corporation may call any and all of the following witnesses on the damage aspect
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`of this lawsuit:
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`Any and all witnesses listed by Eichleay Corporation as liability witnesses.
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`Any and all medical or damages witnesses identified by other defendants to this
`litigation.
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`Any and all medical or damage witnesses identified in discovery by the plaintiffs.
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`Any and all witnesses listed as damage or liability witnesses in Pretrial Statements
`filed by other defendants to this action.
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`Any and all witnesses identified in discovery by plaintiffs and defendants.
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`EXPERT WITNESSES
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`1.
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`Earl Gregory, Ph. D, CIH, CSP
`5718 Yamassee Drive
` Hamilton, OH 45011
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`2.
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`3.
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`John A. Pendergrass, CIH, CSP, PE
`6700 Milkhouse Court
`Mobile, AL 36695-2709
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`Gregory J. Fino, M.D.
`St. Clair Hospital
`1000 Bower Hill Road, Suite 211
`Pittsburgh, PA 15219
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`668586
`1700.0003
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`4.
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`7.
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`Michael J. Warhol, M.D.
`135 Allgates Drive
`Haverford, PA 19041
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`All general and Plaintiff specific medical expert witnesses identified by
`Plaintiff.
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`All general and Plaintiff specific medical expert witnesses identified by
`all Defendants.
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`This Defendant reserves the right to call and/or use the testimony of any and all
`expert witnesses listed by any party to these lawsuits.
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`EXHIBITS
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`The Defendant may introduce at the time of trial the following exhibits:
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`Eichleay Corporation job cards and/or job documents.
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`Eichleay Corporation construction contracts and specifications.
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`Prior testimony and/or affidavits of John Nunez.
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`Prior testimony and/or affidavits of Greg Cesnik.
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`Prior testimony and/or affidavits of William Zeilfelder.
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`Prior testimony and/or affidavits of Mike Milan.
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`Any and all documents attached as exhibits to depositions of the
`Plaintiffs.
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`Any and all work records of the Plaintiffs, including but not limited to union
`records.
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`Any and all medical records referred to, produced and/or otherwise identified in
`discovery by Plaintiffs.
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`Any exhibits listed by any other Defendants in their Pre-Trial
`Statements.
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`Any and all documents referred to, produced or otherwise identified in discovery by
`Plaintiffs.
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`Any and all co-workers who have provided affidavits as to other defendants in this
`litigation.
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`668586
`1700.0003
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`1.
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`RESERVATIONS
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`Eichleay Corporation reserves the right to amend Eichleay Corporation’s Fact
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`Witness List up until and including the time of trial.
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`Respectfully submitted,
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`ZIMMER KUNZ PLLC
`
`By: /s/Daniel E. Krauth, Esquire
`
`Counsel for Defendant,
`
`Eichleay Corporation
`
`668586
`1700.0003
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing document was served upon
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`plaintiffs’ counsel, and all defense counsel, by first-class U.S. mail, postage prepaid on the 6th day
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`of September, 2007.
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`ZIMMER KUNZ PLLC
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`By: _/s/Daniel E. Krauth, Esquire
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`668586
`1700.0003
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