IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
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`JOY E. HOPKINS, Executrix of the Estate
`of JOSEPH C. WILEY, JR., deceased,
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`Plaintiff,
`V.
`A.R. WILFLEY & SONS, INC., et al.,
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`Defendants
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`CIVIL DIVISION - ASBESTOS
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`No. GD 16-005457
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`JURY TRIAL DEMANDED
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`CO-WORKER AND FACT
`WITNESS DISCLOSURE OF
`CHAMPLAIN CABLE
`CORPORATION
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`Filed on behalf of defendant:
`CHAMPLAIN CABLE
`CORPORATION
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`Counsel of record for this Party:
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`Paul K. Vey, Esquire
`PA ID. #30824
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`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
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`Firm 1.D. #834
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`One Oxford Centre, 38th Floor
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`301 Grant Street
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`Pittsburgh, PA 15219
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`Ph: 412-263-2000
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`Fax: 412-263-2001
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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`JOY E. HOPKINS, Executrix of the Estate CIVIL DIVISION - ASBESTOS
`of JOSEPH C. WILEY, JR., deceased,
`Plaintiff, No. GD 16-005457
`V.
`A.R. WILFLEY & SONS, INC,, et al.,
`
`Defendants JURY TRIAL DEMANDED
`
`CO-WORKER AND FACT WITNESS DISCLOSURE OF
`CHAMPLAIN CABLE CORPORATION
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`AND NOW comes the Defendant, Champlain Cable Corporation, by and through its
`counsel, Pietragallo Gordon Alfano Bosick & Raspanti, LLP, Paul K. Vey, Esquire and files the
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`within Co-Worker and Fact Witness Disclosure as follows:
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`I. CO-WORKER AND FACT WITNESS DISCLOSURE
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`I. All parties to this action.
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`2. Any and all relatives of plaintiff decedent, including but not limited to, those
`relatives named in the plaintiff’s Answers to Interrogatories.
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`3. Corporate Representative/Representatives of any and all facilities in which
`plaintiff decedent was employed or made deliveries to: U.S. Steel, Duquesne.
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`4. Any and all corporate representatives, fact witnesses, and/or co-workers identified
`in the plaintiff’s responses to any and all Motions for Summary Judgment filed in
`this matter.
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`10.
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`11.
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`12.
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`13.
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`14.
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`15.
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`16.
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`No. GD 16-005457
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`Any party deposed in reference to this matter, including but not limited to
`corporate representatives, fact witnesses and/or co-workers.
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`All corporate representatives, fact witnesses and co-workers referenced and/or
`identified during the course of discovery undertaken in this action, including but
`not limited to those persons identified in Interrogatories, Request for Production
`of Documents, Depositions and/or Requests for Admission.
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`Any or all persons referenced in the plaintiff decedent’s medical records.
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`Any or all persons referenced in the plaintiff decedent’s employment records.
`Records custodian/representative of the Internal Revenue Service.
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`Records custodian/representative of all employers of the plaintiff decedent.
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`Records custodian/representative of the Social Security Administration.
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`Records custodian/representative of any and all health care providers of the
`plaintiff decedent.
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`Any or all persons referenced in any Co-worker and/or Fact Disclosure filed by
`any and all parties named in this action.
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`Any and all persons referenced in any Pre-Trial Statement filed by any and all
`parties named in this action.
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`Representative/records custodian of any and all co-defendants.
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`Any person or entity named in any and all discovery taken in this case.
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`II. RESERVATION OF RIGHTS
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`As discovery in this matter is ongoing, Defendant reserves the right to supplement this
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`Fact Witness Disclosure up to the time of trial.
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`No. GD 16-005457
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`Respectfully submitted,
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`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`
`By: /s/ Paul K. Vey
`Paul K. Vey, Esquire
`PA. 1D. #30824
`
`One Oxford Centre, 38th Floor
`Pittsburgh, PA 15219
`(412) 263-2000
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`Attorneys for Defendant, CHAMPLAIN
`CABLE CORPORATION, as successor-in-
`interest to Hercules, Inc.
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`No. GD 16-005457
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the foregoing
`CO-WORKER AND FACT WITNESS DISCLOSURE OF CHAMPLAIN CABLE
`CORPORATION, was served upon plaintiff’s counsel, addressed as follows, via First-Class
`United States Mail and all other counsel of record were notified of the filing of same, via
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`electronic mail this 24" day of October, 2017.
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`Michael J. Gallucci, Esquire
`Savinis, Kane & Gallucci, L.L.C.
`Gulf Tower, Suite 3626
`Pittsburgh, PA 15219
`(Counsel for Plaintiff)
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`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`
`BY: /s/ Paul K. Vey
`Paul K. Vey, Esquire
`PA ID #30824
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`3472400
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