`
`JEAN M. CHAPMAN,
`
`CIVIL DIVISION - ASBESTOS
`
`Plaintiff,
`
`vs.
`
`No. GD-22-005304
`
`A.O. SMITH CORPORATION, et al.,
`
` Defendants.
`
`DEFENDANT CHICAGO PNEUMATIC
`TOOL COMPANY, LLC’S FACT
`WITNESS LIST
`
`JURY TRIAL DEMANDED
`
`Filed on behalf of:
`
`Defendant, CHICAGO PNEUMATIC TOOL
`COMPANY, LLC
`
`Counsel of Record for this party:
`JONI M. MANGINO, ESQUIRE
`Pa. I.D. #43586
`
`RYAN A. ZELI, ESQUIRE
`Pa. I.D. #203054
`
`ZIMMER KUNZ, PLLC
`310 Grant Street, Suite 3000
`Pittsburgh, PA 15219
`(412) 281-8000
`
`02352831.DOCX 7918-0177
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CIVIL DIVISION - ASBESTOS
`
`No. GD-22-005304
`
`JEAN M. CHAPMAN,
`
`Plaintiff,
`
`vs.
`
`A.O. SMITH CORPORATION, et al.,
`
` Defendants.
`
`JURY TRIAL DEMANDED
`
`)
`)
`)
`)
`)
`)
`)
`)
`
`)
`)
`
`CHICAGO PNEUMATIC TOOL COMPANY, LLC’S FACT WITNESS LIST
`
`AND NOW comes the Defendant, Chicago Tool Company, LLC (herein “Chicago Tool”).,
`
`by and through its counsel, JONI M. MANGINO, ESQUIRE, RYAN A. ZELI, ESQUIRE and
`
`ZIMMER KUNZ, PLLC, and submits the following Fact Witness List:
`
`I.
`
`Fact Witnesses
`
`1.
`
`2.
`
`Plaintiff and/or Plaintiff/ family members;
`
`Any and all corporate representatives, fact witnesses and/or co-workers identified in
`
`the Plaintiffs Response to any and all Motions for Summary Judgment filed in this action;
`
`3.
`
`Any party deposed in reference to this action including, but not limited to corporate
`
`representatives, fact witnesses and/or co-workers;
`
`4.
`
`All corporate representatives, fact witnesses and/or 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;
`
`02352831.DOCX 7918-0177
`
`
`
`Representative/records custodian of Defendant;
`
`Any witnesses necessary to provide a foundation for and/or authenticate any and all
`
`5.
`
`6.
`
`exhibits;
`
`7.
`
`Any or all persons referenced in the Plaintiff’s medical records including, but not
`
`limited to treating physicians;
`
`8.
`
`Any physicians, medical practitioners, or other health care providers who have
`
`examined or treated the Plaintiff, or examined x-rays, tissue slides or biopsy materials taken from
`
`Plaintiff;
`
`9.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`Any independent medical examiner, if applicable;
`
`Any or all persons referenced in the Plaintiff’s employment records;
`
`Records custodian/representative of the Internal Revenue Service;
`
`Records custodian/representative of all employers of the Plaintiff;
`
`Records custodian/representative of the Social Security Administration;
`
`Records custodian/representative of any and all health care providers of the Plaintiffs;
`
`Records custodian of military records (if applicable) of Plaintiffs;
`
`Any and all persons referenced in any discovery undertaken in this action’
`
`Any or all persons referenced in any Co-Worker and/or Fact Disclosure filed by any
`
`and all parties named in this action; and
`
`18.
`
`Any and all persons referenced in any Pre-Trial Statement filed by any and all parties
`
`named in this action.
`
`02352831.DOCX 7918-0177
`
`
`
`II.
`
`Reservation of Rights
`
`As discovery in this matter is ongoing, Defendant Chicago Pneumatic Tool Company, LLC.
`
`reserves the right to supplement this Fact Witness List up to the time of trial. In addition, Defendant
`
`specifically reserves the right to call any and all necessary fact witnesses necessary for rebuttal.
`
`Respectfully Submitted
`
`ZIMMER KUNZ, PLLC
`
`By:
`/s/ Ryan A. Zeli
`JONI M. MANGINO, ESQUIRE
`RYAN A. ZELI, ESQUIRE
`Attorneys for Defendant,
`Chicago Pneumatic Tool Company, LLC
`310 Grant Street, Suite 3000
`Pittsburgh, PA 15219
`(412) 281-8000
`
`02352831.DOCX 7918-0177
`
`
`
` CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the within DEFENDANT, CHICAGO
`
`PNEUMATIC TOOL COMPANY, LLC’S FACT WITNESS LIST has been served upon Plaintiffs’
`
`counsel and all counsel of record via email, this 31st day of August 2022.
`
`Leif J. Ocheltree, Esquire
`GOLDBERG, PERSKY & WHITE, P.C.
`11 Stanwix Street, Suite1800
`Pittsburgh, PA 15222
`
`ZIMMER KUNZ, PLLC
`
`By:
`
`/s/ Ryan A. Zeli
`JONI M. MANGINO, ESQUIRE
`RYAN A. ZELI, ESQUIRE
`Attorneys for Defendant,
`Chicago Pneumatic Tool Company, LLC
`310 Grant Street, Suite 3000
`Pittsburgh, PA 15219
`(412) 281-8000
`
`02352831.DOCX 7918-0177
`
`
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