`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
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`STEPHEN HUDAK and JANET
`HUDAK, his wife,
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` Plaintiffs,
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` CIVIL DIVISION
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`v.
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`A.O. SMITH CORPORATION, et al.,
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`Defendants.
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` Case No.: GD 22-014317
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`PRETRIAL STATEMENT
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`FILED ON BEHALF OF DEFENDANT
`FMC CORPORATION, ON BEHALF OF ITS
`FORMER PEERLESS PUMP BUSINESS,
`improperly sued as FMC Corporation
`And Sterling Fluid Systems (USA) LLC
`
`Counsel of record for this party:
`W. Matthew Reber, Esquire
`PA I.D. #67035
`Christopher S. Arnold, Esquire
`PA I.D. #319354
`Matthew J. Doz, Esquire
`PA I.D. # 86135
`Katherine A. Lowery, Esquire
`PA I.D. #312186
`
`KELLEY JASONS McGOWAN
`SPINELLI HANNA & REBER, LLP
`
`1818 Market Street
`Suite 3205
`Philadelphia, PA 19103
`(215) 854-0658
`
`Gulf Tower Building, Suite 2701
`707 Grant Street
`Pittsburgh, PA 15219
`(412) 434-6577
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`

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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`STEPHEN HUDAK and JANET HUDAK,
`his wife,
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`
` CIVIL DIVISION
`
`Plaintiffs,
`
`
`
`v.
`
`
`A.O. SMITH CORPORATION, et al.,
`
`
`
`
` Case No.: GD 22-014317
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`Defendants.
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`PRETRIAL STATEMENT
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`AND NOW, come Defendants FMC CORPORATION, ON BEHALF OF ITS
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`FORMER PEERLESS PUMP BUSINESS improperly sued as FMC Corporation and
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`STERLING FLUID SYSTEMS, (USA), LLC (“Peerless”) by and through counsel, and
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`submits the following Pretrial Statement:
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`I. BRIEF STATEMENT OF THE CASE
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`Plaintiffs brings this action alleging Plaintiff-husband Stephen Hudak, developed lung
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`cancer as a result of occupational exposure to asbestos containing products manufactured,
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`supplied, or utilized by various Defendants, including Peerless, during the scope of his
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`employment at Calloy Corporation Foundry in Wilkinsburg, Pennsylvania from 1969 to 1971
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`and again from 1974 to 1975; Jeanette Glass in Jeanette, Pennsylvania in 1975; and United States
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`Steel Edgar Thomson Works in Braddock, Pennsylvania from 1974 to 2015; and through
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`personal automotive and home remodeling work throughout his lifetime. Plaintiffs further allege
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`Plaintiff-Husband was exposed to asbestos dust on the clothing and person of his father, William
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`Hudak, who worked for United States Steel Homestead Works in the early 1950s.
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`Peerless did not manufacture asbestos-containing pumps. Peerless manufactured pumps
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`that were made of metal alloys. Some Peerless pumps may have incorporated asbestos-
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`2
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`

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`containing component parts, such as gaskets and packing, manufactured by Peerless’ suppliers.
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`However, some pumps did not contain packing at all, and many did not utilize asbestos-
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`containing gaskets or packing. In fact, the vast majority of the gaskets utilized with Peerless
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`pumps were vellumoid, comprised of a non-asbestos vegetable fiber. Upon information and
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`belief, some of the gaskets and packing provided by Peerless’ suppliers may have contained, in
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`part, encapsulated asbestos for a limited period of time. A small number of Peerless pumps for
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`specialized applications may have been assembled with gasket materials composed in part of
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`asbestos fibers encapsulated in a resin-like medium. To the best of Peerless’ knowledge, any
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`asbestos-containing gaskets and packing that may have been utilized with some of its pumps
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`were non-friable, and any such packing components were saturated with oil or impregnated with
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`graphite.
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`At trial, Peerless will introduce evidence supporting its position that Peerless pumps did
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`not require any asbestos-related warnings. Peerless will also establish that Peerless pumps were
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`neither hazardous nor released significant respirable asbestos fibers during normal operation as
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`the gaskets provided by suppliers which may have contained asbestos, were encapsulated in a
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`resin-like medium and non-friable, and any such packing components provided by suppliers
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`were saturated with oil or impregnated with graphite. Further, Peerless will show that it neither
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`had a duty, nor breached any such duty, to Plaintiff-husband to warn of any alleged dangers
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`involving work with and/or around Peerless pumps. Peerless will also show that the alleged work
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`around Peerless pumps was not the proximate cause, let alone any cause, of the Plaintiff-
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`husband’s alleged injuries.
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`In the alternative, to the extent that Plaintiff-husband’s alleged work around Peerless
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`pumps purportedly exposed him to asbestos, such exposure was minimal and did not have any
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`3
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`causal or contributing effect on Plaintiff-husband’s alleged injuries. Peerless denies all
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`allegations with respect to its alleged liability to Plaintiff-husband. It is denied that any product
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`attributable to Peerless was defective or unreasonably dangerous as a result of allegations of
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`failure to warn or on any other basis. It is further denied that the ordinary and foreseeable use of
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`Peerless pumps was inherently dangerous or involved or amounted to an ultra-hazardous activity.
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`
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`Defendant Peerless reserves the right to supplement this pretrial memorandum up to and
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`including the time of trial.
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`II.
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`DAMAGES
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`Plaintiffs claim that Plaintiff-husband developed lung cancer as a result of his purported
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`work with and/or around pumps. Defendant contends that work with and/or around its pumps, if
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`any, was not a proximate cause of his alleged illness and any alleged subsequent damages.
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`III. WITNESS DISCLOSURES
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`This list of witnesses is, at the time of its filing, Defendant’s best effort to identify and
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`disclose those witnesses it may call at trial. Therefore, the need for additional witnesses may
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`arise in order to rebut the facts to which Plaintiffs’ witnesses may testify. Peerless reserves the
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`right to supplement or amend its list of witnesses due to the fact that discovery is ongoing.
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`Moreover, Defendant previously filed its Fact Witness List in this matter. By reference, Peerless
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`hereby incorporates all witnesses previously disclosed as if the same were set forth herein in the
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`within pretrial memorandum.
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`Defendant reserves the right to call any or all of the following persons as witnesses at the
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`trial of this case, including:
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`1.
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`Custodian of records for Plaintiff-husband and any and all named defendants and
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`third-party defendants to authenticate the records or documents which may be used in this case;
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`2.
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`Any expert or physician listed by Plaintiffs, any defendant, or dismissed
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`defendant, who is expected to testify about asbestos-related disease, including any such expert
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`who has reviewed x-rays or issued a report on Plaintiff-husband’s medical condition in this case;
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`3.
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`All health care practitioners of any description,
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`including physicians,
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`chiropractors, physical therapists, psychiatrists, nurses, EMTs, paramedics, or any other health
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`care practitioners who have treated Plaintiff-husband or who were or ever have been consulted
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`concerning Plaintiff-husband.
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`4.
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`Any expert witness designated by Plaintiffs, defendants, or any dismissed
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`defendant, including the statement of subject matter, opinion, and grounds of that witness;
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`5.
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`All persons identified in the parties’ Answers to Interrogatories, Supplemental
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`Answers to Interrogatories, Response to Request for Production, or other discovery requests by
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`any party or non-party and/or the witness list filed by any party to this action.
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`6.
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`Plaintiffs and any family members or damages witnesses, including, but not
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`limited to the following:
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`Janet Cecilia Hudak
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`Holly Delduca
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`Chelsea Hudak
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`Devin Hudak
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`7.
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`Current or former representatives and/or employees of Peerless Pumps, including
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`but not limited to Lawrence Link, either in person or by deposition, may be offered. Peerless
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`reserves the right to call additional expert witnesses and/or company witnesses, whose testimony
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`cannot be reasonably anticipated at this time due to limited discovery being conducted to date,
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`for purposes of either direct or rebuttal testimony upon reasonable notice to counsel.
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`5
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`8.
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`Any Peerless corporate representatives, to the extent any parts of their depositions
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`are read into evidence.
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`9.
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`Representatives and/or records custodians from Plaintiff-husband’s employers,
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`including, without limitation, representatives from those employers disclosed by Plaintiffs, or
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`identified in depositions, including but not limited to the following employers:
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`Calloy Corporation Foundry
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`Jeanette Glass
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`United States Steel
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`10.
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`Peerless reserves the right to use any deposition taken in this action.
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`11.
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`Plaintiff-husband’s supervisors, foremen, and co-workers, either in person or by
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`deposition.
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`12.
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`Any and all representatives of any of Plaintiff-husband’s employers or companies
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`on whose premises Plaintiff-husband worked;
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`13. Any witnesses listed or called by Plaintiffs, or any other party, including
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`dismissed parties;
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`14. Any person identified in any party or former party’s discovery responses or
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`deposition;
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`15. Any and all parties or dismissed parties to this litigation;
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`16.
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`Representatives and/or records custodians of all co-defendants;
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`17.
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`Representatives and/or records custodians for each and every physician, hospital,
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`and health care provider for Plaintiff-husband, including, but not limited to, the following:
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`Latrobe Hospital (now Excela Health)
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`Excela Health Westmoreland Hospital
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`6
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`

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`Dialysis Clinic, Inc.
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`Excela Health Westmoreland Hospital Outpatient Clinic
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`Mohammad M. Zaitoon, MD
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`Adnan Nassur, MD
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`Kim Avolio, MD
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`Jeffrey Grasmeder, CRNP
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`Excela Square Latrobe Primary Case
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`John K. Waas, DO
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`UPMC Hillman Arnold Palmer Pavilion
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`Gautam Agrawal, MD
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`Norman P. Gebrowsky, MD
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`Robert Yakulis, MD
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`Yoaxian Ding, MD
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`18.
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`Representatives and/or records custodians of the Internal Revenue Service
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`regarding records with information about Plaintiff-husband;
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`19.
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`Representatives and/or records custodians of the Social Security Administration
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`regarding records with information about Plaintiff-husband;
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`20.
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`Representatives and/or records custodians of any accident, health, life and/or
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`disability carrier for Plaintiff-husband regarding records with information about Plaintiff-
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`husband;
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`21.
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`Representatives and/or records custodians of the Worker’s Compensation Fund
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`regarding any records with information about Plaintiff-husband;
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`22.
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`Any family members, friends, or relatives of Plaintiff-husband;
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`7
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`23.
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`Any and all physicians, nurses, and other medical personnel referenced in any of
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`Plaintiff-husband’s medical records;
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`24.
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`Any person needed for the authentication of any documents, medical records, or
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`other evidence;
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`25.
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`Peerless discloses the following expert witnesses:
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`DONNA M. RINGO, C.I.H.
`DMR & ASSOCIATES, INC.
`604 Pennyroyal Way
`Louisville, KY 4022
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`Ms. Donna M. Ringo is a Certified Industrial Hygienist. She may provide testimony regarding
`her experience and her testing of pumps or similar products and will provide opinions that these
`products have been, and still are, used safely in a workplace environment, that they are not
`unreasonably dangerous, that they do not pose an occupational hazard, and that no warning label
`is required to be placed on them.
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`She may give testimony on the fiber release from gasket and packing products in the occupational
`setting. She may testify regarding exposure assessments performed on pumps or similar
`products, including assessments and testing she has performed on asbestos-containing gasket and
`packing materials. She may rely on the testing done by, among others, Mr. Mangold, Mr. Boelter,
`Mr. Balzer, Mr. Spencer, and Mr. Liukonen.
`
`She has been or will be provided with product exposure information and other case specific data
`in this case, including, but not limited to, case depositions, including co-worker depositions, if
`any, Complaints, Amended Complaints (if any), Answers or Responses to Interrogatories,
`including any Supplemental Answers or Responses, Mr. Longo's Studies 1, 2, 3, 4, and 5, the
`article published by Mr. Longo and others in Applied Occupational and Environmental Hygiene,
`Vol. 17(1):55-56, 2002, Fred W. Boelter, Gary N. Crawford, and Daniel M. Podraza "Airborne
`Fiber Exposure Assessment of Dry Asbestos containing Gaskets and Packing Found in Intact
`Industrial and Maritime Fittings" AIHA-Journal, 63:732-740, 2002, certain Peerless
`documents/records and other discovery produced or pleadings filed in this lawsuit. She will
`review plaintiff/decedent’s exposures to this defendant's products as well as plaintiff/decedent’s
`exposure
`to other manufacturers' asbestos-containing products. She may quantify
`plaintiff/decedent's alleged exposure to asbestos-containing components, such as gaskets and
`packing, as well as exposures to asbestos-containing products manufactured by other companies,
`and provide opinions regarding the significance of each exposure.
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`She has also reviewed and will rely upon air sampling data and other literature regarding
`exposure to asbestos-containing products. She may discuss historical uses of asbestos-containing
`components, such as gaskets and packing, and how they are used and/or manufactured. She may
`quantify exposures to all asbestos-containing products to which plaintiff/decedent may have been
`exposed and discuss the distinction between friable and non-friable products. Ms. Ringo's opinion
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`8
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`is that because gasket and/or packing products are encapsulated, any potential fiber release from
`the products is equal to, or less than, background exposure levels. Ms. Ringo's opinion is that this
`defendant’s products do not create an occupational hazard. Ms. Ringo's opinion is that working
`with or nearby a Peerless pump presented no harmful airborne asbestos exposure from the
`associated asbestos-containing gaskets or packing. The contribution of the asbestos fibers from
`gasket and packing was so insignificant that the cumulative fiber dose would not have been
`discernible from ambient exposure that the general population incurs on a daily basis. Ms. Ringo
`may testify and opine that foreseeable use of this defendant’s products does not cause any
`occupational hazard. She may further opine that there was no duty to warn associated with
`gaskets and packing. She may also provide testimony regarding Peerless pump, including, but not
`limited to, packing and/or fluid sealing products, how they are used in the workplace and,
`specifically, plaintiff/decedent's workplace. She may provide testimony about the type of asbestos
`fiber and other fiber used in this defendant’s products as applicable. She may also testify about
`the types of asbestos fibers found in other companies' products.
`
`She may discuss ambient air exposure to asbestos, the sources of ambient air asbestos exposure,
`quantification studies and the presence of asbestos in drinking water and provide her opinion that
`these exposures, if any, are not harmful or hazardous. Ms. Ringo's opinion is that exposure to this
`defendant’s products is comparable to ambient air exposure. She may discuss general re-
`entrainment theory.
`
`She may further provide testimony about the role of the industrial hygienist in assessing risk,
`generally, and with respect to asbestos-containing products. She may provide current and
`historical information regarding air and dust sampling methods for asbestos in occupational
`settings, including, but not limited to, the NIOSH 7400 and 7402 methods, the OSHA reference
`method, as well as EPA, AHERA and ASTM, methods. She may provide expert testimony on the
`proper use and application of all such methodologies. She will also provide testimony regarding
`the proper and improper methods for occupational sampling of asbestos. She may also provide
`testimony that the use of settled dust methods or Tyndall or refractive light methods do not
`provide a proper scientific basis for sampling and have no value in assessing occupational risk to
`asbestos exposure.
`
`She may provide testimony that the standard and accepted occupational exposure methodologies
`for asbestos require the use of validated scientific air sampling and analytical methods. She may
`testify that the standards for occupational exposure determination to asbestos are the NIOSH and
`OSHA established methods. In this methodology, air samples are collected in conformance with
`the OSHA methodology, which has specific criteria for air sampling, filter preparation and fiber
`counting rules. Scientifically reliable samples are prepared by "direct" preparation techniques as
`opposed to "indirect" preparation techniques and are counted by phase contrast microscopy
`(PCM).
`
`She may evaluate, review and provide comments on the tests performed on gaskets and packing
`by Messrs. Longo and Hatfield, including without limitation, Studies 1, 2, 3, 4, and 5, and the
`article published by Mr. Longo and others in Applied Occupational and Environmental Hygiene,
`Vol. 17(0:55-56, 2002. Ms. Ringo's opinion is that these individuals have used incorrect
`methodology. She may testify that the "indirect" sample preparation technique is not validated or
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`9
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`reliable for occupational exposure determination or health hazard assessments. Ms. Ringo's
`opinion is that use of Tyndall or stage lighting is not an acceptable industrial hygiene practice for
`the evaluation of occupational exposure nor is it a reliable or relevant method of quantification of
`asbestos fibers. Ms. Ringo's opinion is that none of these methods would be relied upon by any
`health or safety professional in performing an exposure assessment. Ms. Ringo's opinion is that
`most of what is seen is non-respirable. The Longo and Hatfield tests provide no basis for
`determination of whether the visible dust is respirable or not. Tests by these individuals do not
`properly simulate work practice or duration of tasks. The measurement of fibers on clothing worn
`in the simulation is not a validated or reliable method for determining exposure of airborne
`asbestos and is not reliable in providing any information on the health effects of asbestos under
`these circumstances. She may provide testimony that neither use of settled dust methods nor
`Tyndall or refractive light methods provide a proper scientific basis for sampling and have no
`value in assessing occupational risk to exposure to asbestos.
`
`She may further provide testimony regarding governmental regulations affecting maximum
`allowable concentrations or asbestos exposures in an occupational setting. She may also provide
`testimony regarding the ACGIH threshold limit values. She may provide opinions that any
`exposure to this defendant’s products are below the current, and all historical, permissible
`exposure limits, excursion and short-term limits and are subject to the warning label exemption of
`OSHA.
`
`She may testify that the current regulation for the industry is found at 29 CFR 1910.1001 and the
`regulation for construction trades is found at 29 CFR 1926.1101. The current OSHA permissible
`exposure level, published in 1994, is 0.1 fibers per cubic centimeter (f/cc), as an eight-hour time
`weighted average. The OSHA permissible level from 1986 to 1994 was 0.2 f/cc, as an eight-hour
`time weighted average. The OSHA permissible level from 1976 to 1986 was 2 f/cc, as an eight-
`hour time weighted average. The OSHA permissible level from 1971 to 1976 was 5 f/cc, as an
`eight-hour time weighted average.
`
`She may also provide testimony regarding historical literature and other applicable government
`regulations of asbestos and their importance to this defendant’s products, including, but not
`limited to the EPA and NESHAPS. She will provide an opinion that in occupational settings,
`thermal insulation can generate exposure levels above background, and gaskets and packing
`products do not. The basis for her testimony will be her experience, her education, research,
`testing, review of the appropriate scientific literature and review of case materials supplied to her.
`
`Ms. Ringo may give testimony on the typical methods for installation and removal of gaskets
`and/or packing from this defendant’s products.
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`She may provide testimony and opinions reviewing and criticizing the opinions and testimony,
`including the bases therefore, of plaintiff's experts in this matter.
`
`She may also provide certain testimony regarding the state of the art of knowledge and literature
`regarding alleged asbestos fiber exposure risks from pumps or similar products, gaskets, and
`packing. She may opine that gasket and packing exposures have not been, and are not understood
`to present significant or serious asbestos exposure risks.
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`10
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`

`Ms. Ringo’s testimony will be based upon her education, training and experience and upon her
`review of the applicable scientific and medical literature, the parties’ responses to written
`discovery, and the deposition testimony of plaintiff/decedent, defendant(s), and witnesses; and
`the medical records of plaintiff/decedent. She may also review the testimony and work product
`of plaintiff’s expert witnesses and the deposition testimony and documents relative to
`manufacturers of asbestos-containing products.
`
`
`MICHAEL A. GRAHAM, M.D.
`Office of the Medical Examiner
`City of St. Louis
`1300 Clark Street
`St. Louis, Missouri 63104
`
` or
`St. Louis University Medical Center
`Department of Forensic Pathology
`3556 Caroline St.
`St. Louis, MO 63104
`
`Dr. Michael A. Graham is a board certified pathologist who may give testimony concerning
`asbestos-related diseases and the effects of exposure to various asbestos-containing products
`upon persons in occupational settings. He may further testify regarding the epidemiology of
`asbestos diseases, the criteria for diagnosis of asbestos-related disease, as well as the existence of
`a dose response relationship between exposure to asbestos and asbestos-related diseases. He
`may also testify regarding asbestos-containing products generally, including their asbestos fiber
`content, manufacture, use and their respective ability to cause or contribute to disease. He may
`also testify regarding the determination of the relative risks of suffering personal injury or death
`as a result of exposure to various asbestos-containing products in various settings. He will
`explain the dose response relationship between exposure to asbestos and asbestos-related disease
`for each type of disease alleged. Dr. Graham may provide an opinion that the foreseeable use,
`installation or removal of this defendant’s products during a human life span cannot produce an
`appreciable risk of any asbestos related disease and cannot cause or contribute to any asbestos
`related disease.
`
`He may also testify regarding the existence or non-existence of any alleged asbestos-related
`disease in the plaintiff/decedent, including but not limited to pleural changes, asbestosis, lung
`cancer, mesothelioma, laryngeal cancer, esophageal cancer, and gastrointestinal cancer, where
`applicable. He will also testify on general medicine issues regarding asbestos-related diseases
`including, but not limited to, lung physiology, lung function, lung defense mechanisms and the
`mechanisms by which asbestos fibers do or do not cause a particular disease. He may also testify
`that background levels of asbestos fibers in human tissue do not represent disease and
`background or ambient air exposure do not cause disease. He may further testify that any
`asbestos-related disease allegedly suffered by plaintiff/decedent was not proximately caused by
`exposure to this defendant’s asbestos-containing products. He may also testify regarding
`government regulations applicable to defendant’s products and whether these products are
`unreasonably dangerous.
`
`
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`11
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`
`He may also testify on increased risk of cancer issues and whether a particular plaintiff has a
`reasonable fear of cancer due to exposure to asbestos. He may also testify on the health
`consequences of smoking and the relationship between smoking and alleged asbestos-related
`diseases, generally and with respect to this plaintiff/decedent. He will testify regarding the
`contribution of smoking and asbestos to this plaintiff/decedent’s disease. It is also his opinion
`that the non-occupationally exposed general public is not at risk for the development of an
`asbestos-related condition or disease, even though there is asbestos in the ambient air. Thus,
`because of the large dose needed to cause an asbestos related disease, a single asbestos fiber
`cannot cause or contribute to disease.
`
`He may also testify regarding the biological effects of asbestos and the evidence of the
`relationship between the inhalation of various forms of asbestos fibers and asbestos-related
`disease and the factors that go onto evaluating whether there is any medical risk from asbestos-
`containing products. Dr. Graham may also provide testimony concerning animal research
`concerning asbestos-related disease, the biological effects of asbestos and various other dusts,
`cancer research, the practices and protocols regarding publication of scientific research and the
`history of research into such matters in the United States and elsewhere including state of the art.
`Dr. Graham may also be asked to respond to the testimony of certain witnesses offered at the
`time of trial including, but not limited to, testimony from plaintiff’s experts regarding the alleged
`hazards of exposure to packing and gasket materials and their alleged propensity to release
`fibers.
`
`Generally and with respect to this particular plaintiff/decedent, he may testify as to his review
`and interpretation of x-ray films, review and interpretation of pulmonary function testing, the
`nature and extent of any impairment or disability, whether a condition is progressive and whether
`other diseases or conditions are present in plaintiff/decedent.
`
`
`He may give an opinion that plaintiff/decedent’s use, installation, maintenance, removal or contact,
`if any, with this defendant’s products cannot and did not cause or contribute to this
`plaintiff/decedent’s asbestos-related disease. He will further testify that plaintiff/decedent’s
`asbestos-related disease was caused by amphibole asbestos products of companies other than this
`defendant.
`
`
`Dr. Graham's testimony will be based on one or more of the following: his training, experience,
`education, publications and review of the medical, governmental and scientific literature and
`various air sampling studies, work facility inspections and documents, where applicable, as well
`as review of medical records, fiber burden or digestion studies performed by him or another
`doctor, chest films, and all pathology materials. Dr. Graham may rely upon the exhibits, testing
`and testimony otherwise disclosed by this defendant in this case. Dr. Graham may review
`plaintiff/decedent’s(s’) and co-worker’s(s’) deposition testimony given in this case and rely upon
`them as a basis for his opinions. He may also provide testimony consistent with the disclosure of
`any other expert disclosed by this defendant or any other party to this case. As this defendant
`becomes aware of additional facts and the opinions of plaintiff’s experts, Dr. Graham will testify
`as to the opinions suggested by the additional facts or in response to the opinions of plaintiff’s
`experts.
`
`
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`The parties have stipulated to an extension to May 11, 2023 for defense expert reports.
`Additional expert reports may be produced up to that date.
`
`
`26.
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`Any fact and/or expert witness necessary for rebuttal;
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`27.
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`Any other witness necessary to publish demonstrative evidence to the jury;
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`28.
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`Any and all witnesses, expert or factual, listed or otherwise identified by Plaintiffs
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`and co-defendants to this action.
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`29.
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`Any person who may come to the attention of Peerless subsequent to the filing of
`
`this list and prior to trial, which person will be promptly disclosed to all other parties to this
`
`action.
`
`30.
`
`Peerless reserves the right to call any expert witness retained on behalf of all
`
`Defendants.
`
`31.
`
`For the purpose of proving cross-claims and obtaining testimony concerning
`
`corporate identity, the manufacture or sale of asbestos-containing products, the composition of
`
`those products, the dates of manufacture and/or sale of those products, and the placing of
`
`warnings on those products, Peerless may call representatives of all parties in this case and for
`
`any company that is not a party that allegedly manufactured, sold, or supplied an asbestos-
`
`containing product to which Plaintiff-husband was exposed, including, but not limited to, the
`
`following:
`
`A.O. Smith Corporation
`
`A.R. Wilfley & Sons Inc.
`
`A.W. Chesterton Company
`
`ABB Inc.
`
`Aecom Energy & Construction Inc.
`
`
`
`13
`
`

`

`Aecom Energy & Construction Inc.
`
`Air & Liquid Systems Corporation
`
`Airtek Inc.
`
`Ajax Magnethermic Corporation
`
`Allied Glove Corporation
`
`Ametek Inc.
`
`Applied Industrial Technologies Inc.
`
`Armstrong International Inc.
`
`Armstrong Pumps Inc.
`
`Aurora Pumps Company
`
`Baker Hughes Holdings LLC
`
`Beazer East Inc.
`
`Bloom Engineering Company Inc.
`
`BMI Refractory Services Inc.
`
`BW/IP Inc.
`
`Calloy Corporation
`
`Cameron International Corporation
`
`Carmeuse Lime Inc.
`
`Carver Pump Company
`
`Cashco Inc.
`
`Chicago Pneumatic Tool Company LLC
`
`Clark Reliance Corporation
`
`Clyde Union Inc.
`
`
`
`14
`
`

`

`Columbus McKinnon Corporation
`
`Corning Incorporated
`
`Dezurik Inc.
`
`Dick Corporation
`
`Donald McKay Smith Inc.
`
`E.E. Zimmerman Company
`
`Eaton Corporation
`
`Eichleay Corporation
`
`Electrolux Home Products Inc.
`
`Eriks North American Inc.
`
`Evoqua Water Technologies LLC
`
`Flowserve Corporation
`
`Flowserve US Inc.
`
`Flsmidth Dorr-Oliver Inc.
`
`Flsmidth Inc.
`
`Fluor Corporation
`
`Fluor Enterprises Inc.
`
`Foseco Inc.
`
`Foster Wheeler LLC
`
`Gardner Denver Inc.
`
`General Electric Company
`
`Genuine Parts Company
`
`GG of Florida Inc.
`
`
`
`15
`
`

`

`Goodyear Tire & Rubber Company
`
`Gorman-Rupp Company
`
`Gould Electronics Inc.
`
`Goulds Pumps LLC
`
`Greene Tweed & Company
`
`Grinnell LLC
`
`Honeywell Inc.
`
`Honeywell International Inc.
`
`Howden North America Inc.
`
`Hunter Sales Corporation
`
`I.U. North America Inc.
`
`IMO Industries Inc.
`
`Inductotherm Industries Inc.
`
`Industrial Holdings Corporation
`
`Industrial Rubber Products
`
`Intricon Corporation
`
`ITT Industries Inc.
`
`Joy Global Surface Mining Inc.
`
`Joy Global Underground Mining LLC
`
`KEC Closeco Inc.
`
`Leeds & Northrup Company
`
`Lindberg
`
`Lindberg MPH
`
`
`
`16
`
`

`

`Lintern Corporation
`
`M.S. Jacobs & Associates Inc.
`
`Magnetek Inc.
`
`McCarls Inc.
`
`McMaster Carr Supply
`
`McNeil Ohio Corporation
`
`Met-Pro Technologies LLC
`
`Metropolitan Life Insurance Company
`
`Milwaukee Valve Company LLC
`
`Mine Safety Appliances Company
`
`Morgan Engineering Systems Inc.
`
`MRC Global US Inc.
`
`Mueller Steam Specialty
`
`Nagle Pumps Inc.
`
`Neles-Jamesbury Inc.
`
`Nooter Construction Company
`
`Nooter Construction Company LLC
`
`North American Manufacturing Company
`
`Osram Sylvania Inc.
`
`P.F. Sherman Company
`
`Paramount Global
`
`Pollock Research & Design Inc.
`
`Power Piping Company
`
`
`
`17
`
`

`

`Rain Bird Corporation
`
`Red Devil Inc.
`
`Redco Corporation
`
`Resco Holdings L.L.C.
`
`Research-Cottrell Inc.
`
`Reunion Industries Inc.
`
`Riley Power Inc.
`
`Robbins & Myers Inc.
`
`Robinson Fans Inc.
`
`Rust Engineering & Construction Inc.
`
`Saint-Gobain Abrasives Inc.
`
`Santa Fe Braun Inc.
`
`Sauer Construction LLC
`
`Schneider Electric USA Inc.
`
`Sealing Specialists & Service Company
`
`Siemens Industry Inc.
`
`Simakas Company Inc.
`
`Spencer Turbine Company
`
`Spirax Sarco Inc.
`
`SPX Cooling Technologies Inc.
`
`SPX Cooling Technologies LLC
`
`Sunbeam Products Inc.
`
`Surface Combustion
`
`
`
`18
`
`

`

`Swindell-Dressler International Company
`
`Tenova Inc.
`
`Textron Inc.
`
`Thiem Corporation
`
`Tuthill Corporation
`
`United Conveyor Corporation
`
`United States Steel Corporation
`
`Valves and Controls US Inc.
`
`Velan Valve Corporation
`
`Viking Pump Inc.
`
`Warren Pumps LLC
`
`West End Contracting Corporation
`
`Wheelabrator Air Pollution Control Inc.
`
`Wheeling Rubber Products Inc.
`
`Whiting Corporation
`
`William Powell Company
`
`Williams First Management Company
`
`WT/HRC Corporation
`
`WTI