NAGLE PUMPS, INC.’S CO-WORKER AND
`FACT WITNESS LIST
`
` IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`GARY TYRONE STEVENS,
`CIVIL DIVISION - ASBESTOS
`
`
`Plaintiff,
`G.D. No. 20-003392
`
`v.
`NAGLE PUMPS, INC., et al. Defendants.
`Filed on behalf of Defendant
`Nagle Pumps, Inc.
`Counsel of record for this party:
`Richard C. Polley, Esquire
`PA I.D. # 34283
`Adam J. Warhola, Esquire
`PA I.D. # 201065
`Timothy J. Chiappetta, Esquire
`PA I.D. #206477
`DICKIE, MCCAMEY & CHILCOTE, P.C.
`Firm #067
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`
`JURY TRIAL DEMANDED
`
`
`FACT WITNESS LIST
`
` IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`GARY TYRONE STEVENS,
`CIVIL DIVISION - ASBESTOS
`
`
`Plaintiff,
`G.D. No. 20-003392
`
`v.
`NAGLE PUMPS, INC., et al. Defendants.
`Filed on behalf of Defendant
`Nagle Pumps, Inc.
`Counsel of record for this party:
`Richard C. Polley, Esquire
`PA I.D. # 34283
`Adam J. Warhola, Esquire
`PA I.D. # 201065
`Timothy J. Chiappetta, Esquire
`PA I.D. #206477
`DICKIE, MCCAMEY & CHILCOTE, P.C.
`Firm #067
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`
`JURY TRIAL DEMANDED
`
`
`
`))))))))))
`
`RESERVATION OF RIGHTS
`
`NAGLE PUMPS, INC.’S CO-WORKER AND FACT WITNESS LIST
`
`IN THE COURT OF COMMON PLEAS OF
`ALLEGHENY COUNTY, PENNSYLVANIA
`GARY TYRONE STEVENS,
`
`
`CIVIL DIVISION
`Plaintiffs,
`GD No. 20-003392
`v.
`NAGLE PUMPS, INC., et al.,
`Defendants.
`
`AND NOW, comes the Defendant, Nagle Pumps, Inc., by and through its attorneys,
`Dickie, McCamey & Chilcote, P.C. and sets forth the following Co-Worker and Fact Witness
`List:
`1.
`Nagle Pumps, Inc. reserves the right to call any and all witnesses listed in any
`Witness List or Disclosure of Witnesses filed on behalf of any party or in any Supplemental
`Witness List or Supplemental Disclosure of Witnesses, including any medical, liability,
`opinion, condition, damage, expert or records witnesses. By this incorporation and
`subsequent incorporations, Nagle Pumps, Inc. does not intend to incorporate by reference
`any proposed testimony which identifies any product manufactured, sold, or supplied by
`Nagle Pumps, Inc.
`2.
`Nagle Pumps, Inc. reserves the right to call any witness to offer factual or opinion
`testimony for purposes of impeachment or rebuttal, whether or not such a witness has
`been identified on the Witness List of any party.
`3.
`Nagle Pumps, Inc. reserves the right to call any and all of the witnesses named in any
`of the pleadings of record, depositions, Answers to Interrogatories, or Responses to
`Request for Admissions.
`4.
`Nagle Pumps, Inc. reserves the right to call any or all of Plaintiff’s treating,
`consulting, and examining physicians which are now known or which later become known.
`5.
`Nagle Pumps, Inc. reserves the right to call any impeachment or rebuttal witnesses
`made necessary by any witness’s testimony at trial.
`
`
`
`Nagle Pumps, Inc. reserves the right to call as a witness any photographer, subpoena
`6.
`server, or investigator of the Plaintiff or any Defendant.
`7.
`Nagle Pumps, Inc. reserves the right to call as a witness all parties and any present
`or former agent, servant, employee, representative, or officer of any party.
`8.
`Nagle Pumps, Inc. reserves the right to call as a witness any co-worker identified by
`Plaintiff in his Fact Witness List, Supplemental Fact Witness Lists, Pretrial Statement, or
`identified in opposition to any Defendant’s Motion for Summary Judgment.
`9.
`Each of the above inclusions and provisions pertains to each of the following
`categories of witnesses and should be read so as to be included in each category.
`A.
`LAY WITNESSES
`This Defendant may call any or all of the following persons as liability
`witnesses at the time of trial:
`1.
`Plaintiff and Plaintiff’s family members:
`a)
`Gary T. Stevens;
`
`
`b)
`Christine Stevens;
`
`c)
`Deborah Stevens;
`
`d)
`Joe Stevens; and
`
`e)
`Tyler Stevens.
`2.
`All co-workers of Plaintiff, including:
`
`a)
`All witnesses referenced in Plaintiff’s Fact Witness List, to the extent
`that said witnesses do not have an interest adverse to Nagle Pumps, Inc. A
`description of likely testimony and any reference to previous testimony and/or
`affidavit can be found in Plaintiff’s Fact Witness List.
`3.
`Any and all employees or former employees or representatives of Nagle
`
`Pumps, Inc.
`4.
`Records Custodian of any or all of the following companies:
`a)
`Any company at which the Plaintiff worked and claims exposure to
`asbestos-containing products, including but not limited to: United States Steel
`Workers, and Industrial Cleaning.
`Records Custodian and/or representation of the various labor unions of
`5.
`2
`
`
`
`which Plaintiff was a member.
`
`Records Custodian
`6.
`Bureau of Workers’ Compensation
`
`Records Custodian
`7.
`Internal Revenue Service
`
`Records Custodian
`8.
`Social Security Administration
`
`Bureau of Disability Insurance
`
`Baltimore, MD 21235
`
`Records Custodian
`9.
`Social Security Administration
`
`Office of Central Records Operations
`
`Baltimore, MD 21235
`
`Custodian of records/corporate representative
`10.
`Pennsylvania Department of Revenue
`
`Office of Chief Counsel
`
`Dept. 281061
`
`Harrisburg, PA 17128
`
`For the purposes of obtaining testimony concerning corporate identity, the
`11.
`manufacture or sale of asbestos-containing products/insulation products, the
`composition of those products, the dates of manufacture and/or sale to those
`products and the placing of warnings on those products, Nagle Pumps, Inc.
`may call representatives of all parties in these actions.
`Custodian of records/representative of each and every treating physician
`12.
`and/or other health care provider who examined, reported on, and/or
`treated the Plaintiff, as identified in any medical records, pretrial statement,
`discovery, and in any depositions to be taken in this lawsuit and/or related
`lawsuits, if any, brought by Plaintiff.
`
`
`Any and all treating, examining and/or diagnosing physicians and/or other
`13.
`health care providers of Plaintiff.
`Custodian of records of the Manville Personal Injury Settlement Trust c/o
`14.
`Claimants Resolution Management Corporation.
`Custodian of records/representatives of any other asbestos-related bankrupt
`15.
`entity against whom a claim has been made by Plaintiff.
`
`DAMAGE WITNESSES
`3
`
`B.
`
`
`
`This Defendant may call any or all of the following persons as damage witnesses at
`the time of trial:
`1.
`Any or all witnesses, including expert medical or technical witnesses, listed
`
`in the Witness List or Disclosure of Witnesses of any party to this action.
`2.
`All physicians, lab technicians, and other health care personnel identified in
`
`all hospital and/or medical records as well as appearing in the Witness List
`
`or Disclosure of Witnesses of the Plaintiff and/or any other party to this
`
`action.
`3.
`Any and all of the aforementioned Liability Witnesses.
`Nagle Pumps, Inc. specifically reserves the right to supplement this list as
`investigation and discovery continue.
`Respectfully submitted,
`Dickie, McCamey & Chilcote, P.C.
`By /s/ Timothy J. Chiappetta
`Richard C. Polley, Esquire
`Adam J. Warhola, Esquire
`Timothy J. Chiappetta, Esquire
`Attorneys for Defendant,
`Nagle Pumps, Inc.
`
`
`
`
`
`
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`4
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing was electronically
`
`served upon Plaintiff’s counsel of record notice of the filing of same was served on all other
`counsel of record by electronic mail, this 1st day of December, 2021.
`DICKIE, McCAMEY & CHILCOTE, P.C.
`By /s/ Timothy J. Chiappetta
`
`Timothy J. Chiappetta, Esq.
`
`Attorneys for Defendant,
` Nagle Pumps, Inc.
`
`
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