IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`JOY E. HOPKINS, Executrix of the Estate
`of JOSEPH C. WILEY, JR., deceased,
`
`Plaintiff,
`
`vs.
`
`A.R. WILFLEY & SONS, INC., et al.,
`
`CIVIL DIVISION-ASBESTOS
`
`No: GD 16-005457
`
`GRINNELL LLC’S PRETRIAL
`STATEMENT
`
`Defendants.
`
`Filed on Behalf of Defendant:
`
`GRINNELL LLC
`
`Counsel of Record for This Party:
`
`MORGAN, LEWIS & BOCKIUS LLP
`Firm I.D. No.: 603
`
`Steven A. Luxton (PA ID 318209)
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, DC 20004
`(202) 739-5452
`FAX (202) 739-3001
`steven.luxton@morganlewis.com
`
`
`
`JOY E. HOPKINS, Executrix of the Estate
`of JOSEPH C. WILEY, JR., deceased,
`
`Plaintiff,
`
`vs.
`
`A.R. WILFLEY & SONS, INC., et al.,
`
`CIVIL DIVISION-ASBESTOS
`
`No: GD 16-005457
`
`GRINNELL LLC’S PRETRIAL
`STATEMENT
`
`Defendants.
`
`Filed on Behalf of Defendant:
`
`GRINNELL LLC
`
`Counsel of Record for This Party:
`
`MORGAN, LEWIS & BOCKIUS LLP
`Firm I.D. No.: 603
`
`Steven A. Luxton (PA ID 318209)
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, DC 20004
`(202) 739-5452
`FAX (202) 739-3001
`steven.luxton@morganlewis.com
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CIVIL DIVISION-ASBESTOS
`
`No: GD 16-005457
`
`JOY E. HOPKINS, Executrix of the Estate of
`JOSEPH C. WILEY, JR., deceased,
`
`Plaintiff,
`
`vs.
`
`A.R. WILFLEY & SONS, INC., et al.,
`
`Defendants.
`
`DEFENDANT GRINNELL LLC’S PRETRIAL STATEMENT
`
`AND NOW, comes the Defendant Grinnell LLC (“Grinnell” or “Defendant”), by and
`
`through its attorneys, MORGAN, LEWIS & BOCKIUS LLP, files the within Pretrial Statement:
`
`I.
`
`NARRATIVE
`
`Plaintiff Joy E. Hopkins, Executrix of the Estate of Joseph C. Wiley, Jr., deceased,
`
`(hereinafter referred to as “Plaintiff”), initiated this action to recover damages for injuries alleged
`
`to have occurred as a result of the injured party’s exposure to various asbestos-containing products
`
`alleged to have been manufactured, distributed, and/or supplied by the Defendants. The evidence
`
`at trial, will confirm that the amount of exposure to products manufactured or supplied by Grinnell,
`
`was not a substantial factor to any injury suffered by Joseph C. Wiley, Jr.
`
`II.
`
`LAY WITNESS LIST
`
`1.
`
`This Defendant may call any and all of the following witnesses:
`
`a.
`
`b.
`
`c.
`
`Any and all parties to this action, including their past or present employees
`who have knowledge of the within actions;
`
`Any and all witnesses listed as liability witnesses in Pre-Trial Statements
`filed by the Plaintiff and other Defendants;
`
`Any and all witnesses listed and/or identified as witnesses in Plaintiff’s
`responses to discovery requests and depositions;
`
`
`
`d.
`
`e.
`
`f.
`
`g.
`
`Any and all parties to the within action, including but not limited to
`corporate representatives and the Plaintiff;
`
`Any and all co-workers who have provided affidavits as to other
`Defendants in this litigation;
`
`Any and all representatives of contractors and/or purchasers of products
`allegedly sold, supplied or distributed by Defendant; and
`
`Representatives of Defendant.
`
`III.
`
`DAMAGES
`
`1.
`
`This Defendant may call any and all of the following witnesses on the damage
`
`aspect of this lawsuit:
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`Any and all witnesses listed by this Defendant as liability witnesses.
`
`Any and all medical or damages witnesses identified by other Defendants
`to this litigation
`
`Any and all medical or damage witnesses identified in discovery by the
`Plaintiffs;
`
`Any and all witnesses listed as damage or liability witnesses in Pre-Trial
`Statements filed by other Defendants to this action;
`
`Any and all witnesses identified in discovery by the Plaintiff and
`Defendants.
`
`
`
`IV.
`
`EXPERT WITNESSES
`
`1.
`
`This Defendant reserves the right to call and/or use the testimony of any and all
`
`expert witnesses listed by and party to these lawsuits.
`
`V.
`
`EXHIBITS
`
`1.
`
`This Defendant may introduce at the time of trial the following exhibits:
`
`a.
`
`b.
`
`Any and all work records of the Plaintiff, including but not limited to
`union records.
`
`Contracts, purchase orders and/or invoices involving work performed or
`products purchased by any alleged purchaser of products sold, supplied
`and/or distributed by the Plaintiff;
`
`
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Any and all medical records referred to, produced and/or otherwise
`identified in discovery by the Plaintiff;
`
`Any exhibits listed by any other Defendants in their Pre-Trial Statements;
`
`Any and all documents referred to, produced or otherwise identified in
`discovery by the Plaintiff;
`
`Any and all affidavits prepared by co-workers;
`
`Any documents in the possession of Defendant responsive to the
`Plaintiff’s discovery requests.
`
`
`
`VI. RESERVATION OF RIGHTS
`
`Grinnell LLC reserves the right to amend and/or supplement this Pretrial Statement at any
`
`time.
`
`DATED: April 13, 2018
`
` Respectfully submitted,
`
`/s/ Steven A. Luxton
` Steven A. Luxton (PA ID 318209)
` MORGAN, LEWIS & BOCKIUS LLP
` 1111 Pennsylvania Avenue, NW
` Washington, DC 20004
` (202) 739-5452
` FAX (202) 739-3001
`steven.luxton@morganlewis.com
`
`Attorneys for Defendant Grinnell LLC
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Steven A. Luxton, hereby certify that a copy of the above and foregoing GRINNELL
`
`LLC’S PRETRIAL STATEMENT was served upon Plaintiff’s counsel, as addressed below,
`
`with notice of the filing of same upon all known counsel of record by electronic service this 13th
`
`day of April, 2018.
`
`Michael P. Robb, Esq.
`Savinis, Kane & Gallucci LLC
`Suite 3626, Gulf Tower
`707 Grant Street
`Pittsburgh, PA 15219
`
`Attorneys for Plaintiff
`
`/s/ Steven A. Luxton
`Steven A. Luxton
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
