IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`LISA LANDRY, Independent Executor of the
`Estate of JULIANNA FRAHLMAN, Deceased,
`Plaintiffs,
`v.
`ARMSTRONG INTERNATIONAL,
`INC., et al.,
`Defendants.
`
`ARMSTRONG INTERNATIONAL, INC.’S
`CO-WORKER AND FACT WITNESS LIST
`
`CIVIL DIVISION
`G.D. No. 22-002284
`Issue No.
`Code:
`Filed on behalf of Defendant,
`Armstrong International, Inc.
`Counsel of record for this party:
`Richard C. Polley, Esquire
`PA I.D. #34283
`Shannan Noé Cerrone, Esquire
`PA I.D. #200601
`DICKIE, MCCAMEY & CHILCOTE, P.C.
`Firm #067
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`
`JURY TRIAL DEMANDED
`
`
`
`LISA LANDRY, Independent Executor of the
`Estate of JULIANNA FRAHLMAN, Deceased,
`Plaintiffs,
`v.
`ARMSTRONG INTERNATIONAL,
`INC., et al.,
`Defendants.
`
`ARMSTRONG INTERNATIONAL, INC.’S
`CO-WORKER AND FACT WITNESS LIST
`
`CIVIL DIVISION
`G.D. No. 22-002284
`Issue No.
`Code:
`Filed on behalf of Defendant,
`Armstrong International, Inc.
`Counsel of record for this party:
`Richard C. Polley, Esquire
`PA I.D. #34283
`Shannan Noé Cerrone, Esquire
`PA I.D. #200601
`DICKIE, MCCAMEY & CHILCOTE, P.C.
`Firm #067
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`
`JURY TRIAL DEMANDED
`
`
`
`ARMSTRONG INTERNATIONAL, INC.’S CO-WORKER AND FACT WITNESS LIST
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`LISA LANDRY, Independent Executor of
`CIVIL DIVISION
`the Estate of JULIANNA FRAHLMAN,
`G.D. No. 22-002284
`Deceased,
`Plaintiffs,
`v.
`ARMSTRONG INTERNATIONAL,
`INC., et al.,
`Defendants.
`AND NOW, comes the Defendant, Armstrong International, Inc., by and through its
`attorneys, Dickie, McCamey & Chilcote, P.C. and sets forth the following Co-Worker and Fact
`Witness List:
`1.
`Armstrong International, Inc. may 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, Armstrong International, Inc. does
`not intend to incorporate by reference any proposed testimony which identifies any
`product manufactured, sold, or supplied by Armstrong International, Inc.
`Armstrong International, 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.
`Armstrong International, 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.
`Armstrong International, 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.
`Armstrong International, Inc. reserves the right to call any impeachment or rebuttal
`witnesses made necessary by any witnesses’ testimony at trial.
`
`RESERVATIONS
`
`2.
`3.
`4.
`5.
`
`
`
`A.
`
`LAY WITNESSES
`
`Armstrong International, Inc. reserves the right to call as a witness, any
`6.
`photographer, subpoena server, or investigator of the Plaintiff or any Defendant.
`Armstrong International, Inc. reserves the right to call as a witness any and all
`7.
`employees or ex-employees at Plaintiff’s particular work sites;
`Armstrong International, Inc. reserves the right to call as a witness, all parties and
`8.
`any present or former agent, servant, employee, representative or officer of any
`party.
`Each of the above inclusions and provisions pertains to each of the following
`9.
`categories of witnesses and should be read so as to be included in each category.
`1.
`This Defendant may call any or all of the following persons as liability
`witnesses at the time of trial:
`A.
`Plaintiff-Executor, Lisa Landry.
`B.
`All co-workers of Plaintiff, including:
`i)
`All witnesses listed by Plaintiff in their Fact Witness List, to the
`extent that said witnesses do not have an interest adverse to
`Armstrong International, Inc. A description of likely testimony
`and any reference to previous testimony and/or affidavit can
`be found in Plaintiff's Fact Witness List.
`Any and all employees or former employees or representatives of Armstrong
`2.
`International, Inc.
`Records Custodian of any or all of the following companies:
`3.
`A.
`Any company at which the Plaintiff worked and claims exposure to
`asbestos-containing products, including but not limited to: Pittsburgh Des Moines Steel Co.
`(1963-1965); Union Carbide in Humble, TX (1990-1992); Administaff in Kingwood, TX
`(1992-1994); and Humble Independent School District in Humble, TX (1994-2009).
`4.
`Records Custodian and/or representation of the various labor unions of
`which the Plaintiff was a member.
`3
`
`
`
`5.
`Records Custodian
`Bureau of Workers’ Compensation
`6.
`Records Custodian
`Internal Revenue Service
`7.
`Records Custodian
`Social Security Administration
`Bureau of Disability Insurance
`Baltimore, MD 21235
`8.
`Records Custodian
`Social Security Administration
`Office of Central Records Operations
`Baltimore, MD 21235
`9.
`Custodian of records/corporate representative
`Pennsylvania Department of Revenue
`Office of Chief Counsel
`Dept. 281061
`Harrisburg, PA 17128
`10.
`For the purposes of obtaining testimony concerning corporate identity, the
`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, Armstrong International, Inc. may call representatives of all
`parties in these actions.
`11.
`Custodian of records/representative of each and every treating physician
`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.
`12.
`Any and all treating, examining and/or diagnosing physicians and/or other
`health care providers of Plaintiff.
`4
`
`
`
`B.
`
`DAMAGE WITNESSES
`
`Custodian of records of the Manville Personal Injury Settlement Trust c/o
`13.
`Claimants Resolution Management Corporation.
`14.
`Custodian of records/representatives of any other asbestos-related bankrupt
`entity against whom a claim has been made by Plaintiff.
`1.
`This Defendant may call any or all of the following persons as damage
`witnesses at the time of trial:
`A.
`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.
`B.
`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.
`Any and all of the aforementioned Liability Witnesses.
`C.
`Respectfully submitted,
`DICKIE, McCAMEY & CHILCOTE, P.C.
`By: /s/ Shannan Noe Cerrone
`Richard C. Polley, Esq. (PA # 34283)
`Shannan Noé Cerrone, Esq. (PA #200601)
`Two PPG Place, Suite 400
`Pittsburgh, PA 15222-5402
`(412) 281-7272
`Attorneys for Defendant,
`Armstrong International, Inc.
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing Fact Witness List was
`served via electronic mail to Plaintiff’s counsel of record this 27th day of October, 2022, and
`notice of the filing of same was served via electronic mail to all other counsel of record.
`DICKIE, McCAMEY & CHILCOTE, P.C.
`By: /s/ Shannan Noe Cerrone
`Richard C. Polley, Esq. (PA # 34283)
`Shannan Noé Cerrone, Esq. (PA #200601)
`Attorneys for Defendant,
`Armstrong International, Inc.
`
`
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