IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CHARLES A. SCHANO, JR. and
`MARILYN ANN SCHANO,
`
`Plaintiffs,
`
`CIVIL DIVISION-ASBESTOS
`
`No: GD 19-001278
`
`v.
`
`PRETRIAL STATEMENT
`
`A.O. SMITH CORPORATION, et al.,
`
`Defendants.
`
`Filed on Behalf of Defendant:
`
`Grinnell LLC f/k/a Grinnell Corporation
`
`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
`
`
`
`CHARLES A. SCHANO, JR. and
`MARILYN ANN SCHANO,
`
`Plaintiffs,
`
`CIVIL DIVISION-ASBESTOS
`
`No: GD 19-001278
`
`v.
`
`PRETRIAL STATEMENT
`
`A.O. SMITH CORPORATION, et al.,
`
`Defendants.
`
`Filed on Behalf of Defendant:
`
`Grinnell LLC f/k/a Grinnell Corporation
`
`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 19-001278
`
`CHARLES A. SCHANO, JR. and
`MARILYN ANN SCHANO,
`
`Plaintiffs,
`
`v.
`
`A.O. SMITH CORPORATION, et al.,
`
`Defendants.
`
`DEFENDANT GRINNELL PUMPS LLC’S PRETRIAL STATEMENT
`
`AND NOW, comes the Defendant Grinnell LLC f/k/a Grinnell Corporation (“Grinnell”
`
`or “Defendant”), by and through its attorneys, MORGAN, LEWIS & BOCKIUS LLP, files the
`
`within Pretrial Statement:
`
`I.
`
`NARRATIVE
`
`Plaintiffs, CHARLES A. SCHANO, JR. and MARILYN ANN SCHANO (hereinafter
`
`referred to as “Plaintiffs”), 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 Charles A. Schano, Jr.
`
`II.
`
`LAY WITNESS LIST
`
`1.
`
`This Defendant may call any and all of the following witnesses:
`
`a.
`
`b.
`
`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 Plaintiffs and other Defendants;
`
`
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Any and all witnesses listed and/or identified as witnesses in Plaintiffs’
`responses to discovery requests and depositions;
`
`Any and all parties to the within action, including but not limited to
`corporate representatives and the Plaintiffs;
`
`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 Plaintiffs 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 any party to these lawsuits.
`
`V.
`
`EXHIBITS
`
`1.
`
`This Defendant may introduce at the time of trial the following exhibits:
`
`a.
`
`Any and all work records of the Plaintiffs, including but not limited to
`union records.
`
`
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`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 Plaintiffs;
`
`Any and all medical records referred to, produced and/or otherwise
`identified in discovery by the Plaintiffs;
`
`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 Plaintiffs;
`
`Any and all affidavits prepared by co-workers;
`
`Any documents in the possession of Defendant responsive to the
`Plaintiffs’ discovery requests.
`
`
`
`VI. RESERVATION OF RIGHTS
`
`Grinnell LLC f/k/a Grinnell Corporation, reserves the right to amend and/or supplement
`
`this Pretrial Statement at any time.
`
`DATED: February 13, 2020 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 f/k/a
`Grinnell Corporation
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Steven A. Luxton, hereby certify that a copy of the above and foregoing PRETRIAL
`
`STATEMENT was served via U.S. First Class Mail, postage prepaid, 13th day of February, 2020,
`
`as follows:
`
`Mark D. Troyan, Esq.
`Robert Peirce & Associates, PC
`2500 Gulf Tower
`707 Grant Street
`Pittsburgh, PA 15219
`
`Attorneys for Plaintiffs
`
`All Known Defense Counsel of Record via email (w/o enclosure)
`
`/s/ Steven A. Luxton
`Steven A. Luxton
`
`
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