IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CIVIL DIVISION - ASBESTOS
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`
` GD No. 22-014317
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`PLAINTIFF’S PRETRIAL STATEMENT
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`Filed on Behalf of Plaintiffs
`
`Counsel of Record for this Party:
`
`
`STEPHEN HUDAK and JANET
`HUDAK, his wife,
`
`
` Plaintiffs,
`
`v.
`
`A.O. SMITH CORPORATION, et al.,
`
`
`
` Defendants.
`
`Leif J. Ocheltree, Esquire
`PA ID No. 163508
`
`Goldberg, Persky & White, P.C.
`11 Stanwix Street, Suite 1800
`Pittsburgh, PA 15222, and
`281 Three Springs Drive, Suite 285
`Weirton, WV 26062
`Telephone: (412) 471-3980
`Facsimile: (412) 471-8308
`Telephone: (304) 723-0213
`
`Firm # 744
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`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`CIVIL DIVISION - ASBESTOS
`
`STEPHEN HUDAK and JANET
`HUDAK, his wife,
`
`
` Plaintiffs,
`
`v.
`
`A.O. SMITH CORPORATION, et al.,
`
`
`
` Defendants.
`
` GD No. 22-014317
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` PLAINTIFF’S PRETRIAL STATEMENT
`
`AND NOW COME the above-captioned Plaintiffs, by and through their counsel, Leif J.
`
`Ocheltree, Esquire, and Goldberg, Persky & White, PC, and file the following Pretrial Statement:
`
`
`PLAINTIFF’S PROPOSED VOIR DIRE STATEMENT
`
`Plaintiff, Stephen Hudak, was born on February 13, 1951 and currently lives with his wife, Janet,
`in Irwin, PA. He was diagnosed with lung cancer on December 3, 2020. Mr. Hudak was
`exposed to asbestos-containing products and equipment that he used personally and that were
`used in his vicinity while working various positions at: Calloy Corporation, a foundry located in
`Wilkinsburg, PA, from 1969 until 1971 and upon his discharge from the Army in 1974; at
`Jeannette Glass from late-1975 for about two months and; United States Steel, Edgar Thomson
`Works in Braddock, PA in mid to late-1974 until 2015.
`
`Most of the defendants manufactured asbestos products or equipment that was designed to utilize
`asbestos component parts. Defendants knew the components would be replaced periodically with
`asbestos parts. The defendants had reason to know their products were defective because they
`contained asbestos, but they issued no warning.
`
`Plaintiff’s experts will testify that asbestos fibers are microscopic, and float for many hours on
`air currents. Nearly all asbestos-containing materials release airborne fibers, and asbestos fibers
`persist for long periods in a workplace, unless aggressive abatement is performed to remove
`them.
`
`Medical experts will testify that asbestos is a carcinogen and that asbestos exposure elevated the
`plaintiff’s risk of developing lung cancer. We will ask you to award monetary damages.
`
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`2
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`PLAINTIFF’S PROPOSED VOIR DIRE QUESTIONS
`
`1. Would you have difficulty awarding damages for pain, suffering, and loss of enjoyment
`of life to someone who was injured by a corporation’s defective product?
`
`
`2. Do you have a negative opinion of warning labels on products?
`
`3. Do you feel that it is wrong to bring a lawsuit?
`
`4. Do you believe that jury awards are too large?
`
`5. Have you, or your spouse or significant other, ever made a claim for personal injuries or
`damages as a result of a workplace accident or illness related to your job?
`
`
`
`
`Plaintiff reserves the right to supplement this section of their Pretrial Statement should they
`acquire any new information that would require the need for additional questions.
`
`*BRIEF NARRATIVE OF THE CASE
`
`Plaintiff Stephen Hudak filed a Complaint in Civil Action on November 18, 2022. Plaintiff
`suffers from Lung Cancer, an asbestos-related disease. He was diagnosed on December 3, 2020.
`Plaintiff claims that as a direct and proximate result of inhaling the asbestos fibers and dusts
`contained in the products manufactured, supplied, specified for use, installed, removed and/or
`otherwise manipulated by the defendants and/or their predecessors-in-interest plaintiff contracted
`Lung Cancer and its associated complications which resulted in his disability.
`
`Mr. Hudak worked as a grinder for Calloy Corporation, a foundry located in Wilkinsburg, PA,
`from 1969 until 1971 and upon his discharge from the Army in 1974. The foundry was one big
`building. He worked as a grinder and was positioned in one area of the foundry. He was
`exposed to asbestos-containing products and equipment during his employment at Calloy. Mr.
`Hudak next worked at Jeannette Glass from late-1975 for about two months. His job was on the
`“hot side” and involved removing the glass from the molds. There were four mold machines at
`Jeanette Glass and that he worked on all four machines. His job at the glass plant required him
`to use a pair of tongs to remove the glass from the molds. Finally, Mr. Hudak began to work at
`United States Steel, Edgar Thomson Works in Braddock, PA in mid to late-1974 until 2015. He
`worked with and around asbestos-containing products. The first five years or so he spent half of
`his time in the BOP (aka the BOF) and the other half in Mold Conditioning. They were separate
`building and both buildings are enclosed. The BOP is where the steel was actually produced and
`was one big, open area. He began as a laborer in the BOP and that his job duties were to clean
`up around the BOP. During the first five years of his employment, he would be moved from
`laborer to perform the jobs of: stopper maker, ladle liner, third and fourth helper, gate man, mold
`conditioner and lance burner. He performed all of these jobs about equally and that all, but for
`mold conditioner, were performed in the BOP. The job of mold conditioner was performed in
`Mold Conditioning which was about a quarter mile from the BOP. His job as a stopper maker
`required that he, after every pour, replace the twenty-foot-long metal rods referred to as “stopper
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`3
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`rods” which went inside the ladle and were used to stop and start the flow of steel from the ladle.
`Thiss job also required that he put the ceramic coatings, called “sleeves”, on the stopper rods.
`His job as a ladle liner his job was to reline/rebrick the ladles. This required that he remove the
`old brick and mortar with a gradall machine and then reinstall the same. He thought he did this
`job steady for fifteen years. He testified that as a third and fourth helper, he was on the pouring
`platform pouring steel. As a gate man, it was his job to service and rebuild the gates located at
`the bottom of the ladle. The gates were the newer method of stopping the flow of steel from the
`ladle and replaced the old method, which were the stopper rods. As a mold conditioner, it was
`his job to prepare the molds for steel pouring which was the method of steel production prior to
`the caster. The job of mold conditioner involved the use of hot tops. He would work as a mold
`conditioner off and on, sometimes for a day and sometimes for a couple of months. As a lance
`burner, it was his job to remove steel that had been spilled and hardened and that this was done
`through the use of an oxygen lance. After five years or so of performing the jobs of laborer,
`stopper maker, ladle liner, third and fourth helper, gate man, mold conditioner and lance burner
`he worked steady as a lance burner for about three years or so. He then worked as a stopper
`maker steady for two years or so. He then worked as a ladle liner for the next fifteen years or so.
`He worked steady as a third helper for three years or so. He then worked steady as a gate man
`for the next three years or so. For the remaining ten years or so, he worked as an LMF which
`stood for ladle metallurgical furnace operator which he explained was the “fine tuning” of the
`steel being produced to meet the customers specifications. He would occasionally be bumped
`from the position of ladle metallurgical furnace operator to the job of degasser operator. This job
`involved adjusting the amount of carbon in the steel which impacted its pliability. These time
`frames are to the best of his memory and could be off. Mr. Hudak testified that he was exposed
`to asbestos-containing products and equipment during his employment at the Edgar Thomson
`Works.
`
`Plaintiff will introduce evidence of his exposure to asbestos-containing products manufactured,
`sold and distributed by the defendants, and to asbestos-containing component parts that were
`utilized as original equipment, and as replacement parts, on equipment including: pumps, valves,
`crane motors, crane brakes, motors that ran various pieces of equipment, panel boxes and panel
`boards, and air compressors (stationary and mobile), ladles, rope packing, gaskets (pre-formed
`and sheet), pipe covering, heat-protective clothing (hood, coats, pants, and gloves), brick, metal-
`clad brick, cement, spray, panel boards, blankets and grinding wheels manufactured by the
`defendants and sold to Mr. Hudak’s various employers and their suppliers.
`
`Plaintiff will show that the defendants designed their pumps, valves, steam traps, strainers, panel
`boxes, ladles, grinding wheels, cranes, hoists, furnaces, hot tops, boilers, hot water heaters,
`HVAC equipment, cooling towers, pipes, burners, and compressors to use asbestos-containing
`component parts such as asbestos insulation, fibers, gaskets, packing, refractory materials, resins,
`and friction products; that the defendants knew that these asbestos-containing components would
`be manipulated, removed and replaced in a manner very likely to create airborne dust; that the
`defendants knew that the replacement parts were wear items that would be renewed periodically
`by the equipment owners and that the replacement parts utilized during the life of the equipment
`would necessarily be asbestos-containing, and of the same design and composition as the original
`component parts, regardless of the manufacturer of the replacement parts; that the defendants had
`
`
`
`4
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`an opportunity to warn end users of their equipment of the hazards of asbestos, but either
`deliberately or negligently failed to provide any such warning.
`
`Plaintiff will show that the defendants had actual knowledge of the hazards of asbestos during
`the time period when they were actively manufacturing, selling, supplying, specifying or
`distributing asbestos products, or that at the very least they had access to information concerning
`the dangers of asbestos and were charged with a duty to ensure the safety of products they were
`putting on the market. Plaintiff will show that the defendants did nothing to warn Stephen Hudak
`of the hazards of asbestos, and that they failed to place warnings on the products, develop and
`provide asbestos-free substitute materials in a timely and prudent manner, and that they failed to
`recall their products despite having a network of sellers and distributors through which they
`could convey safety information to end users of their products. Plaintiff will rely upon certain
`documentary evidence to substantiate these claims as well.
`
`Plaintiff will rely upon his testimony to establish the manner in which specific products were
`used and the manner in which visible dust was released from the products. Plaintiff will rely
`upon the deposition testimony of corporate representatives of the defendants who testified in this
`case and admitted that the defendants utilized, specified and required asbestos-containing
`component parts, and that the defendants’ products by design required asbestos replacement
`components, and that the defendants’ own repair manuals specified the use of asbestos material
`and described unsafe, dust-creating methods for removing and replacing the component parts.
`Plaintiff will rely upon certain documentary evidence to substantiate these claims as well.
`
`Plaintiff will rely upon the testimony of medical experts to establish that his Lung Cancer was
`caused by asbestos exposure. They will establish that asbestos is a carcinogen, capable of
`causing Mesothelioma by itself. Plaintiff will also rely upon medical records and other
`documentary evidence to substantiate these claims.
`
`Plaintiff will rely upon the testimony of non-medical experts to establish that he was exposed to
`respirable asbestos fibers as a result of working in close proximity to the defendants’ products.
`They will testify that asbestos fibers are microscopic, and that fiber bundles break down into
`smaller and smaller fibers with mechanical force, and that fibers float for many hours on air
`currents and are easily reintrained and again become airborne. They will testify that nearly all
`asbestos-containing materials are capable of releasing asbestos fibers, regardless of the matrix
`they may be contained in, and that asbestos fibers generally persist in an environment such as a
`closed building, and that absent aggressive asbestos abatement measures such as negative air
`pressure enclosures, glove bag removal, washing with amended water, reducing airborne
`concentrations with HEPA filters and other means, and final testing to ensure concentrations
`below background levels, that asbestos fibers will remain a health threat from an industrial
`hygiene perspective. They will testify as to the evolution of industry standards propounded by
`various state governments as well as OSHA and the duties incumbent upon asbestos
`manufacturers with subsequent rule changes. They will discuss the evolution of the knowledge of
`asbestos hazards, and the timeline that shows when information about asbestos hazards should
`have been known to responsible manufacturers and sellers of industrial products. They may
`testify as to various efforts by certain companies to suppress the dissemination of information
`about asbestos hazards to end users, and to use industry funding of ostensibly unbiased research
`
`
`
`5
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`

`to influence the medical and epidemiological literature so as to generate a body of research
`seeming to exculpate certain asbestos products, when in fact other research substantiated that the
`products were indeed hazardous. Plaintiff will rely upon certain documentary evidence to
`substantiate these claims as well.
`
`Plaintiff testified by deposition and will testify at trial describing the effect of Lung Cancer on
`his health including the suffering he has endured through treatments including chemotherapy and
`surgery. He will describe the mental and physical pain, suffering and mental anguish he and his
`family have suffered. He will discuss the medical procedures that were done, as well as
`incidental costs that he was forced to pay as a result of his disease. He will establish that he
`suffered damages for pain, suffering, mental anguish, lost income, medical expenses, household
`expenses, medical care expenses and loss of enjoyment of life and health.
`
`*NON-EXPERT WITNESSES
`Plaintiff may rely upon the following individuals at trial, either live, by deposition or by previous
`trial testimony: all witnesses identified in Plaintiff’s Discovery Responses, Defendant’s
`Discovery Responses, Plaintiff’s Fact Witness List, Defendants’ Fact Witness List, Plaintiff’s
`Responses to Motions for Summary Judgment (including all supplements), Defendants’ Motions
`for Summary Judgment, previously disclosed non-expert witnesses and all corporate
`representatives and/or employees (past or present) of Defendants. Plaintiff may additionally call
`as a witness any Treating Physicians and/or Records Custodian at any facility at which Plaintiff
`was diagnosed with or treated for Lung Cancer.
`
`
`Plaintiff reserves the right to rely upon the deposition testimony and/or sworn testimony of any
`witnesses in lieu of live testimony at the time of trial. Plaintiff further reserves the right to call
`only certain live witnesses identified below and has no obligation to call all listed witnesses.
`
`Damages Witnesses
`Stephen Hudak
`Janet C. Hudak
`Holly Delduca
`Chelsea Hudak
`Devin Hudak
`
`Medical Records Librarians and Billing Clerks
`Excela Health
`Latrobe Hospital
`Westmoreland Hospital
`UPMC Univ. of Pittsburgh Physicians
`UPCI Cancer Services
`Westmoreland Emergency Medical Specialists
`
`Liability Witnesses
`Stephen Hudak
`
`
`
`
`6
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`

`

`Any and all historical witnesses from Plaintiff’s Fact Witness List and Responses to Motions for
`Summary Judgment.
`
`Any and all prior corporate representatives or persons most knowledgeable of the defendants.
`
`Daniel Braun, MD
`Industrial Health Foundation
`
`Jane Brislin, Secretary
`Industrial Health Foundation
`
`Jane Kennedy, Secretary
`Industrial Health Foundation
`
`Representatives of the National Safety Counsel
`
`*EXPERT WITNESSES AND REPORTS
`The following expert witnesses are expected to provide reports and may be called upon to
`provide testimony regarding the treatment of the individual decedent’s disease. Plaintiff reserves
`the right to call any expert witnesses whose reports have been or will be submitted in this case.
`Plaintiff reserves the right to call any witness listed on any other expert witness list filed in this
`action. Plaintiff’s Medical and Non-Medical Expert Disclosure is hereby incorporated by
`reference. The Plaintiff reserves the right to amend, modify or supplement this Expert
`Designation if additional information is discovered or due to inadvertent errors or omissions.
`
`David Zhang, M.D. – Narrative report dated July 24, 2023. Dr. Zhang is a pathologist. He will
`testify as to all of the opinions set forth in this report. Dr. Zhang will testify as to general
`medicine, with an emphasis on pulmonary pathology, lung cancer and mesothelioma. He will
`discuss the diagnosis and treatment of asbestos-related diseases and the ability of various types of
`asbestos fibers to cause disease. Dr. Zhang will opine that all asbestos fiber types are capable of
`producing asbestosis, lung cancer and mesothelioma. He will testify that the plaintiff’s
`mesothelioma diagnosis is due to asbestos exposure.
`
`Dr. Arnold Brody – General medicine, mechanics of asbestos disease including the
`development of fibrosis and cancer, animal research with asbestos, molecular biology, asbestos
`fiber types and the propensity of various fibers to cause disease.
`
`Donal Kirwan, SPHR – Narrative report dated June 9, 2023. Mr. Kirwan is the managing
`director of Forensic Human Services. He will testify regarding the economic loss attributable to
`Plaintiff’s diseases.
`
`Gerald E. Markowitz, Ph.D. – Dr. Markowitz is a distinguished professor of history at the John
`Jay College of Criminal Justice with approximately 35 years of research and publishing on
`deadly dust, including the interface of science, medicine, engineering, trade and industry
`practices and in particular how large organizations like companies and governmental bodies have
`reacted to risk information regarding dangers of deadly dusts. Dr. Markowitz will testify on the
`
`
`
`7
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`state of art knowledge regarding publicly disseminated information regarding the hazards of
`asbestos found in the scientific, medical, technical, and business literature dating back to the
`early 1900s.
`
`Arthur L. Frank, M.D., Ph.D. – Dr. Frank is currently a Professor of Public Health at the
`Center for Environmental and Occupational Health at Drexel University. He will testify as to the
`general medical issues surrounding asbestos-related diseases. He will explain how asbestos
`affects the multiple organs in the body and may discuss the diseases asbestosis, lung cancer and
`mesothelioma. Dr. Frank may testify concerning the latency of asbestos-related diseases and the
`progressive nature of the diseases. He will relate his experiences concerning the epidemiological
`studies which have been performed by the Mt. Sinai School of Medicine. He will discuss the
`increased risk of the development of lung cancer, mesothelioma and other cancers caused by
`working around and being exposed to asbestos. Dr. Frank's testimony will be based on his
`education, training, experience, review of the medical and scientific literature and review of case
`specific materials.
`
`Dr. Laxminarayana C. Rao, F.C.C.P., F.A.C.P. – Dr. Rao is a pulmonologist and b-reader
`who has an expertise in diagnosing diseases caused by asbestos. He will discuss general
`medicine, pulmonology medicine and the diagnosis and treatment of asbestos-related diseases,
`and the ability of various types of asbestos fibers to cause disease. Dr. Rao has reviewed x-rays
`and medical records in this case, and he will discuss the diagnosis and the cause of disease
`suffered by the Plaintiff.
`
`Barry Castleman, Sc.D. – Dr. Castleman may testify regarding public health, state of the art,
`corporate knowledge, industry association knowledge and other public and private sources of
`knowledge and information about the health hazards of asbestos. Dr. Castleman's testimony will
`involve the summarization, explanation and analysis of the scientific literature, medical,
`industrial hygiene, corporate and other documents and material which discuss the hazards of
`asbestos and in some instances the knowledge of the defendants regarding this literature. He may
`testify as to what the defendants and/or others knew or should have known concerning the
`dangers of asbestos at various points in time. He may testify as to knowledge of defendants
`concerning the hazards of asbestos and their efforts to prevent the disclosure of this information.
`
`Dr. Richard Lemen – Dr. Lemen retired as the Deputy Director of the National Institute for
`Occupational Safety and Health (“NIOSH”). He served as Assistant Director of the NIOSH in
`Washington, D.C. as well as for the Centers for Disease Control in the Washington, D.C. office.
`Dr. Lemen has conducted several retrospective cohort studies on workers who have been
`exposed to substances such as asbestos. In addition, he has been responsible for directing field
`teams conducting occupational surveys of the asbestos industries of the United States. He has
`surveyed asbestos plants and administered pulmonary function tests to asbestos workers. Dr.
`Lemen will testify on state of the art issues, industrial hygiene, dust dispersion, fiber types and
`diseases caused by exposure to asbestos. He will testify about the hazardous nature of asbestos
`containing products and their ability to cause disease. Dr. Lemen may also testify about threshold
`limit values and industrial hygiene practices and procedures. Dr. Lemen will discuss the
`precautions needed to protect workers from the hazards of asbestos. This testimony will be
`relevant to all defendants.
`
`
`
`8
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`

`
`*DAMAGES
`As a direct and proximate result of the actions of the defendants, Plaintiff has been damaged and
`claims damages of the defendants in excess of Fifty Thousand Dollars ($50,000). Plaintiff’s
`damages include, but are not limited to, economic damages (hospital, physician and prescription
`expenses incidental to his mesothelioma diagnosis and treatment, lost income, and loss of future
`earning capacity) and noneconomic damages (pain and suffering, loss of life’s pleasures, and
`punitive damages). Copies of all medical bills will be made available to Defense counsel upon
`request.
`
`
`
`Provider
`
`Date
`
`Medical
`Expenses -
`Paid by
`Insurance
`
`Medical
`Expenses -
`Paid by
`Plaintiff
`
`Excela Health - Radiology
` CT Thorax w/o contrast
` PET Scan
` CT Thorax w/o contrast
` Chest x-ray
` MRI Brain w-w/o contrast
` Chest x-ray
` CT Abdomen/Pelvis w/contrast
` CT Thorax with contrast
` MRI Brain w-w/o contrast
` CT Thorax with contrast
` CT Abdomen/Pelvis w/contrast
` PET Scan
` Chest x-ray
` Chest x-ray
` MRI Brain w-w/o contrast
` CT Abdomen/Pelvis w/o contrast
` CT Thorax w/o contrast
` U/S Retroperitoneal
` CT Head w/o contrast
` CTA Neck w & w/o contrast
` CTA Neck w & w/o contrast
` MRI Brain w-w/o contrast
` Chest x-ray
` CT Abdomen/Pelvis w/o contrast
` CT Thorax w/o contrast
` U/S Retroperitoneal
`
`
`
`
`$46.50
`$95.66
`$46.51
`$7.37
`$92.16
`$9.21
`$70.34
`$44.89
`$88.41
`$44.89
`$70.34
`$114.78
`$10.61
`$10.61
`$110.51
`$84.14
`$52.01
`$28.36
`$41.06
`$84.17
`$84.17
`$70.87
`$8.88
`$84.14
`$52.01
`$27.80
`
`
`11/6/2020
`11/23/2020
`12/2/2020
`12/3/2020
`12/10/2020
`12/15/2020
`3/11/2021
`3/11/2021
`5/10/2021
`6/1/2021
`6/1/2021
`6/29/2021
`8/14/2021
`9/21/2021
`9/23/2021
`10/29/2021
`10/29/2021
`12/9/2021
`12/12/2021
`12/12/2021
`12/12/2021
`12/12/2021
`12/12/2021
`12/30/2021
`12/30/2021
`2/15/2022
`
`9
`
`
`$11.63
`$23.92
`$11.63
`$0.00
`$23.04
`$0.00
`$17.58
`$11.22
`$22.10
`$11.22
`$17.58
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`
`

`

` Chest x-ray
` Chest x-ray
` Biopsy Renal Perc
` U/S Guid Needle B/X
` CT Abdomen/Pelvis w/o contrast
` PICC S/I U/S
` Fluoro Guidance Venous
` Insertion Tunneled CAT
` U/S Retroperitoneal
` U/S Retroperitoneal
` CT Thorax w/o contrast
` CT Abdomen/Pelvis w/o contrast
` CT Thorax w/o contrast
` Bone Scan Whole Body
` Chest x-ray
` Chest x-ray
` Chest x-ray
` CT Head w/o contrast
` MRI Brain w/o contrast
` Chest x-ray
` PET Scan
` Chest x-ray
` CT Head w/o contrast
` Hip Unilateral w/pelvis
` Hip Unilateral w/pelvis
` Chest x-ray
` Chest x-ray
` Chest x-ray
` Chest x-rays
` Chest x-ray
` CT Thorax w/o contrast
` Cookie swallow
` Chest x-ray
` PET Scan
` CT
`Excela Health Medical Group
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Office Visit AET3/IH
`
`
`
`$7.05
`$7.05
`$99.90
`$24.47
`$83.13
`$10.88
`$14.62
`$204.20
`$22.24
`$27.52
`$51.06
`$81.47
`$50.55
`$31.00
`$8.07
`$8.58
`$0.00
`$31.22
`$54.63
`$8.58
`$109.44
`$8.45
`$39.03
`$10.40
`$10.40
`$8.45
`$8.45
`$8.45
`$10.08
`$8.45
`$49.75
`$24.70
`$10.08
`$109.44
`$83.90
`
`$133.20
`$91.39
`$60.74
`$60.74
`$72.96
`
`2/28/2022
`3/1/2022
`3/1/2022
`3/1/2022
`3/12/2022
`3/14/2022
`3/14/2022
`3/14/2022
`3/16/2022
`4/14/2022
`6/28/2022
`12/27/2022
`12/27/2022
`1/19/2023
`2/9/2023
`2/25/2023
`2/25/2023
`2/25/2023
`2/26/2023
`2/28/2023
`3/30/2023
`5/22/2023
`5/22/2023
`5/22/2023
`5/23/2023
`5/25/2023
`5/27/2023
`6/21/2023
`6/22/2023
`6/27/2023
`6/27/2023
`6/27/2023
`7/6/2023
`7/13/2023
`7/27/2023
`
`2/25/2023
`2/26/2023
`2/27/2023
`2/2/2023
`3/16/2023
`
`10
`
`$0.00
`$0.00
`$24.97
`$6.12
`$65.00
`$2.72
`$3.66
`$51.05
`$5.56
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`
`$33.98
`$23.32
`15..50
`$15.50
`$0.00
`
`

`

` TTE w/Doppler AET3/IH
` Hosp/Obs Car AET3/IH
` IN/PERI/SUBT AET3/IH
` Hosp/Obs Car AET3/IH
` IN/PERI/SUBT AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Inpt/Obs Dis AET3/IH
` X-ray
` X-ray
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Hosp/Obs Car AET3/IH
` Inpt/Obs Dis AET3/IH
` Office Visit
`Excela Health - Latrobe Hospital
` PET scan etc
` CT, Bloodwork, etc
` Bloodwork etc
` PET scan etc
`
` Hospital Stay
` PET scan etc
` PET scan etc
`Excela Health - Westmoreland Hospital
` CT Chest
` PFS Brochospasm Eval., etc
` Outpatient Surgery
` MR Brain
` Outpatient Surgery
`
`
`
`$65.49
`$141.53
`$1,174.04
`$124.88
`$140.88
`$114.25
`$114.25
`$114.25
`$114.25
`$114.25
`$114.25
`$114.25
`$75.93
`$77.29
`$33.76
`$0.00
`$141.53
`$124.88
`$97.11
`$75.93
`$75.93
`$75.93
`$114.25
`$114.25
`$109.67
`$103.34
`
`$1,070.30
`$83.13
`$10.77
`$1,298.96
`
`$21,643.39
`$1,317.86
`$1,317.83
`
`$83.13
`$187.72
`$5,043.75
`$283.21
`$2,055.40
`
`5/22/2023
`5/22/2023
`5/23/2023
`5/23/2023
`5/23/2023
`5/23/2023
`5/24/2023
`5/25/2023
`5/26/2023
`5/27/2023
`5/28/2023
`5/29/2023
`5/30/2023
`5/31/2023
`6/7/2023
`6/7/2023
`6/21/2023
`6/22/2023
`6/22/2023
`6/23/2023
`6/23/2023
`6/24/2023
`6/25/2023
`6/26/2023
`6/27/2023
`7/3/2023
`
`11/23/2020
`12/2/2020
`4/1/2021
`6/29/2021
`2/22/2023 to
`2/28/2023
`3/30/2023
`7/13/2023
`
`11/6/2020
`11/17/2020
`12/3/2020
`12/10/2020
`12/15/2020
`
`11
`
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`
`$287.58
`$20.78
`$1.91
`$108.70
`
`$0.00
`$0.00
`$0.00
`
`$20.37
`$46.01
`$0.00
`$69.41
`$513.85
`
`

`

` CT scans
` Bloodwork
` MR Brain
` CT scans
` Bloodwork, x-ray etc
` Outpatient Surgery
` Bloodwork, x-ray etc
` MR Brain
` Bloodwork
` CT scans
` Bloodwork
` Bloodwork
` Bloodwork
`
` ER, CT scan, etc
` Ext EKG
` CT Scan
` Bloodwork
` Bloodwork
` Bloodwork
`
` Hospitalization
` Bloodwork
` Bloodwork
`
` Hospitalization
` US Renal
` Bloodwork
` CT Scan
` Outpatient Surgery
` Bloodwork
` Outpatient Surgery
` Bloodwork
` Fistulagram Arm &/or Subclav. Etc
` CT Scan, bloodwork, etc.
` NM Bone Whole Body, etc.
` PSA, Diagnostic etc
` Bloodwork, x-ray etc
` Bloodwork
` Bloodwork
`
`
`
`$331.01
`$27.62
`$280.04
`$331.01
`$76.92
`$4,811.98
`$76.92
`$350.05
`$22.40
`$213.32
`$79.92
`$28.74
`$48.65
`
`$6,891.36
`$52.93
`$213.32
`$9.77
`$14.74
`$14.23
`
`$6,475.59
`$11.95
`$11.95
`
`$0.00
`$99.08
`$13.17
`$99.08
`$2,605.24
`$11.85
`$2,578.93
`$13.03
`$1,266.84
`$119.95
`$275.14
`$12.36
`$61.50
`$0.00
`$32.34
`
`3/11/2021
`4/13/2021
`5/10/2021
`6/1/2021
`8/14/2021
`8/23/2021
`9/21/221
`9/23/2021
`10/28/2021
`10/29/2021
`11/1/2021
`11/12/2021
`11/26/2021
`12/12/2021
`to
`12/13/2021
`12/16/2021
`12/30/2021
`1/27/2022
`2/7/2022
`2/11/2022
`2/15/2022 to
`3/5/2022
`3/7/2022
`3/9/2022
`3/13/2022 to
`3/17/2022
`4/14/2022
`6/17/2022
`6/28/2022
`6/29/2022
`9/23/2022
`10/26/2022
`12/5/2022
`12/13/2022
`12/27/2022
`1/19/2023
`1/23/2023
`2/9/2023
`3/2/2023
`4/12/2023
`
`12
`
`$82.75
`$6.12
`$70.01
`$82.75
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`
`$0.00
`$0.00
`$0.00
`$1.69
`$2.11
`$0.00
`
`$0.00
`$2.98
`$2.98
`
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$1.20
`$0.00
`$0.00
`$0.00
`$0.00
`$70.19
`$3.68
`$16.59
`$0.00
`$0.00
`
`

`

` Hospitalization
` Veni Op Tower, Erc
` Veni Op Tower, Erc
` Veni Op Tower, Erc
`
` Hospitalization
` X-ray
` CT
` Bloodwork, x-ray etc
`UPMC Univ. of Pittsburgh Physicians
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Sanjeev Bahri
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Sanjeev Bahri
` Dr. Sanjeev Bahri
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Dr. Igor Poltinnikov
` Angela Merlino, PA-C
` Dr. John Waas
` Dr. John Waas
` Dr. John Waas
` Dr. John Waas
` Dr. John Waas
` Dr. John Waas
`
`
`
`5/23/2023 to
`5/30/2023
`6/13/2023
`6/20/2023
`6/21/2023
`6/21/2023 to
`6/26/2023
`7/6/2023
`7/27/2023
`9/10/2023
`
`10/1/2021
`10/4/2021
`10/4/2021
`10/7/2021
`10/8/2021
`10/8/2021
`10/11/2021
`10/12/2021
`10/12/2021
`10/12/2021
`10/13/2021
`10/15/2021
`10/18/2021
`10/19/2021
`10/19/2021
`10/20/2021
`10/20/2021
`10/20/2021
`10/21/2021
`10/22/2021
`10/25/2021
`10/26/2021
`10/26/2021
`11/4/2021
`11/4/2021
`11/4/2021
`11/4/2021
`1/3/2022
`2/14/2022
`2/14/2022
`
`13
`
`$18,433.22
`$0.00
`$0.00
`$34.24
`
`$8,847.65
`$76.88
`$326.01
`TBD
`
`$139.73
`$134.86
`$521.42
`$182.45
`$308.52
`$269.72
`$300.69
`$12.23
`$273.52
`$205.62
`$273.52
`$273.52
`$273.52
`$85.31
`$273.52
`$12.23
`$273.52
`$205.62
`$273.52
`$273.52
`$273.52
`$85.31
`$273.52
`$139.73
`$8.55
`$0.00
`$4.42
`$160.18
`$0.00
`$6.84
`
`$0.00
`$0.00
`$0.00
`$0.00
`
`$0.00
`$0.00
`$0.00
`TBD
`
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`$0.00
`