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`CAROLYN HENDERSON, an individual,
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`Plaintiff,
`v.
`A-BEST PRODUCTS COMPANY, INC., et
`al.,
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`Defendants.
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`CIVIL DIVISION
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`No. GD02-002686
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`Code: 012
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`FACT WITNESS DISCLOSURE LIST
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`Filed on behalf of Defendant
`Hunter Sales Corporation
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`Counsel of Record for this Party:
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`ANDREW F. ADOMITIS, ESQUIRE
`Pa. I.D. 49689
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`GROGAN GRAFFAM, P.C.
` Firm I.D. No. 072
`Four Gateway Center
`Twelfth Floor
`Pittsburgh, PA 15222
`(412) 553-6300
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`18805-00003
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`JURY TRIAL DEMANDED
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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
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`CAROLYN HENDERSON, an individual,
`
`Plaintiff,
`v.
`A-BEST PRODUCTS COMPANY, INC., et
`al.,
`
`
`Defendants.
`
`CIVIL DIVISION
`
`GD02-002686
`
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`FACT WITNESS DISCLOSURE LIST
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`AND NOW, comes the defendant, Hunter Sales Corporation by and through its
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`attorney, Andrew F. Adomitis, Esquire of Grogan Graffam, P.C. and files the following
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`the following Fact Witness Disclosure List:
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`I. TRIAL WITNESSES
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`Hunter Sales Corporation (hereinafter referred to as "Hunter Sales") reserves the
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`right to call as witnesses, regarding liability and/or damages, any or all of the parties to
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`this action and their employees, as well as witnesses identified in the Pretrial Statements,
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`Exhibit and Witness Disclosure Lists, pleadings and/or discovery responses filed on
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`behalf of any party to this lawsuit, as well as those revealed in depositions or any other
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`matter of record in this suit. This right is reserved up to and including the date of the
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`Pretrial Conciliation and the time of trial. Hunter Sales also reserves the right to call
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`witnesses not listed herein whose testimony may be necessary to rebut evidence offered
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`by the Plaintiff and/or any other party at the time of trial. Further, Hunter Sales reserves
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`the right to conduct further investigation and call such witnesses as may be revealed by
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`that investigation, including expert witnesses necessary to interpret or rebut matters
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`revealed in any testimony, responses to discovery requests, including depositions, either
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`filed or to be filed in this matter, up to and including the Pretrial Conference and time of
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`A.
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`Liability Witnesses
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`R. Russell Hunter, President
`Hunter Sales Corporation
`3338 Industrial Boulevard
`Bethel Park, PA 15102
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`Employees and representatives of Hunter Sales Corporation
`Hunter Sales Corporation
`3338 Industrial Boulevard
`Bethel Park, PA 15102
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`trial.
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`1.
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`2.
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`B.
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`Damage Witnesses
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`1. Record Custodians of any and all hospitals, physicians, surgeons and/or
`medical professionals that examined and/or otherwise rendered care or treatment to
`Plaintiff.
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`III. RESERVATION OF RIGHTS
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`Hunter Sales reserves the right to amend and/or supplement this Fact Witness
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`Disclosure List at any time up to and including the Pretrial Conciliation and time of trial.
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`GROGAN GRAFFAM, P.C.
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`____________________________________
`ANDREW F. ADOMITIS, ESQUIRE
`Attorneys for Hunter Sales Corporation
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`CERTIFICATE OF SERVICE
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`I, Andrew F. Adomitis, do hereby certify that a true and correct copy of the within Fact
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`Witness Disclosure List was served upon Plaintiff’s counsel as identified below, and a copy of
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`the cover letter thereof has been forwarded to all other known defense counsel by depositing
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`same into the United States mail, first-class, postage prepaid on this 8th day of February, 2008:
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`
`Holly L. Deihl, Esquire
`Carrie L. Furlan, Esquire
`Goldberg, Persky & White, P.C.
`1030 Fifth Avenue, 3rd Floor
`Pittsburgh, PA 15219
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`_______________________________
`ANDREW F. ADOMITIS, ESQUIRE
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