IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`
`
`
`
`GERALD J. OSWALD, Individually and
`as Executor of the ESTATE OF MARY
`LOU OSWALD, a/k/a MARY LOUISE
`OSWALD,
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`
`Plaintiff,
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`
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` vs.
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`A.O. SMITH CORPORATION, et al.,
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`
`CIVIL DIVISION - ASBESTOS
`
`
`No. GD 23-000132
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`JURY TRIAL DEMANDED
`
`
`CO-WORKER AND FACT
`WITNESS DISCLOSURE
`
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`Filed on behalf of defendant:
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`CHAMPLAIN CABLE
`CORPORATION
`
`Counsel of Record for this Party:
`
`David E. Lamm, Esquire
`PA ID. #49532
`
`Paul K. Vey, Esquire
`PA ID. #30824
`
`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`Firm I.D. #834
`One Oxford Centre, 38th Floor
`301 Grant Street
`Pittsburgh, PA 15219
`Ph: 412-263-2000
`Fax: 412-263-2001
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`GERALD J. OSWALD, Individually and
`as Executor of the ESTATE OF MARY
`LOU OSWALD, a/k/a MARY LOUISE
`OSWALD,
`
`
`Plaintiff,
`
`
`
` vs.
`
`A.O. SMITH CORPORATION, et al.,
`
`
`CIVIL DIVISION - ASBESTOS
`
`
`No. GD 23-000132
`
`
`JURY TRIAL DEMANDED
`
`
`CO-WORKER AND FACT
`WITNESS DISCLOSURE
`
`
`Filed on behalf of defendant:
`
`CHAMPLAIN CABLE
`CORPORATION
`
`Counsel of Record for this Party:
`
`David E. Lamm, Esquire
`PA ID. #49532
`
`Paul K. Vey, Esquire
`PA ID. #30824
`
`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`Firm I.D. #834
`One Oxford Centre, 38th Floor
`301 Grant Street
`Pittsburgh, PA 15219
`Ph: 412-263-2000
`Fax: 412-263-2001
`
`
`
`
`
`
`
`
`
`
`
`
`
`GERALD J. OSWALD, Individually and
`as Executor of the ESTATE OF MARY
`LOU OSWALD, a/k/a MARY LOUISE
`OSWALD,
`
`
`Plaintiff,
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`
`
`CIVIL DIVISION - ASBESTOS
`
`
`No. GD 23-000132
`
`
`
`
`
`JURY TRIAL DEMANDED
`
`
` vs.
`
`A.O. SMITH CORPORATION, et al.,
`
`
`
`
`
`
`
`Defendants.
`
`
`CO-WORKER AND FACT WITNESS DISCLOSURE OF
`CHAMPLAIN CABLE CORPORATION
`
`
`
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`AND NOW comes the Defendant, Champlain Cable Corporation, by and through its
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`counsel, Pietragallo Gordon Alfano Bosick & Raspanti, LLP, David E. Lamm, Esquire, and Paul
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`K. Vey, Esquire and files the within Co-Worker and Fact Witness Disclosure as follows:
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`I.
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`CO-WORKER AND FACT WITNESS DISCLOSURE
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`All parties to this action.
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`Any and all relatives of plaintiff’s, including but not limited to, those relatives
`named in the Plaintiff’s Answers to Interrogatories.
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`Corporate Representative/Representatives of any and all facilities in which
`decedent and her late father were employed, including:
`
`a) West Penn Hospital;
`b) UPMC Passavant Hospital;
`c) UPMC Shadyside Hospital;
`d) J&L Steel, Aliquippa (decedent’s late father);
`e) Sharon Steel (decedent’s late father);
`f) Babcock & Wilcox’ Koppel and Wallace Run facilities (decedent’s late
`father);
`g) Mesta Machine (decedent’s late father);
`h) Rockwell International/Meritor Automotive (decedent’s late father);
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`1.
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`II.
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`4.
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`7.
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`8.
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`Any and all corporate representatives, fact witnesses, and/or co-workers identified
`in the plaintiff’s responses to any and all Motions for Summary Judgment filed in
`this matter.
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`Any party deposed in reference to this matter, including but not limited to
`corporate representatives, fact witnesses and/or co-workers.
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`All corporate representatives, fact witnesses, and 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.
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`Any or all persons referenced in the decedent’s medical records.
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`Any or all persons referenced in the decedent and her late father’s employment
`records.
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`9.
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`Records custodian/representative of the Internal Revenue Service.
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`10.
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`Records custodian/representative of all employers of the decedent and her late
`father.
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`11.
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`Records custodian/representative of the Social Security Administration.
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`12.
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`13.
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`14.
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`15.
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`16.
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`Records custodian/representative of any and all health care providers of the
`decedent.
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`Any or all persons referenced in any Co-worker and/or Fact Disclosure filed by
`any and all parties named in this action.
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`Any and all persons referenced in any Pre-Trial Statement filed by any and all
`parties named in this action.
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`Representative/records custodian of any and all co-defendants.
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`Any person or entity named in any and all discovery taken in this case.
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`RESERVATION OF RIGHTS
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`As discovery in this matter is ongoing, Defendant reserves the right to supplement this
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`Fact Witness Disclosure up to the time of trial.
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`Respectfully submitted,
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`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`
`
`
`By: /s/ David E. Lamm
`
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`David E. Lamm, Esquire
`
`PA ID #49532
`
`
`
`Paul K. Vey, Esquire
`
`PA. I.D. #30824
`
`
`
`One Oxford Centre, 38th Floor
`
`Pittsburgh, PA 15219
`
`(412) 263-2000
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`Attorneys for Defendant, CHAMPLAIN
`CABLE CORPORATION
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`3
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`CERTIFICATE OF SERVICE
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` The undersigned hereby certifies that a true and correct copy of the foregoing
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`CO-WORKER AND FACT WITNESS DISCLOSURE OF CHAMPLAIN CABLE
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`CORPORATION, was served upon plaintiff’s counsel, via electronic mail, and all other
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`counsel of record were notified of the filing of same, via electronic mail this 1st day of March,
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`2024.
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`Mark D. Troyan, Esquire
`ROBERT PEIRCE & ASSOCIATES
`Gulf Tower
`707 Grant Street, Suite 125
`Pittsburgh, PA 15219
`(Counsel for Plaintiff)
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`PIETRAGALLO GORDON ALFANO
`BOSICK & RASPANTI, LLP
`
`BY: /s/ David E. Lamm
`
`
`David E. Lamm, Esquire
`
`PA ID #49532
`
`Paul K. Vey, Esquire
`
`PA ID #30824
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`Attorneys for Defendant, CHAMPLAIN
`CABLE CORPORATION
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