Document RJq7qbwM2xm8XNOEpejvxeM1n
FILE NAME: GATX (GX)
DATE: 1998 DOC#: GX003
DOCUMENT DESCRIPTION: Legal - Plaintiffs Second Supplemental Answers to Defendant GATX's Interrogatories
IN THE COURT OF COMMON PLEAS
TRUMBULL COUNTY, OHIO
LOIS J. MISSIK,
)
)
Plaintiff,
)
)
v.
)
)
OWENS-CORNING FIBERGLAS CORP., )
et al.
)
)
Defendants.
)
_________________________________________ )
Case No. 97-CV-303 Judge Kontos
PLAINTIFF'S SECOND SUPPLEMENTAL ANSWERS TO DEFENDANT GATX'S INTERROGATORIES
COMES NOW plaintiff, Lois J. Missik, pursuant to the Rules of this Court, and
provides the following supplemental responses to interrogatories served upon her by
defendant General American Transportation Corporation ("GATX"). These responses
have been made with the assistance of counsel. Therefore, the word usage and sentence
structure may be that of my lawyers and do not purport to be the exact language I would
use.
23. State the name and address of each person whom you expect to call as an expert witness in the trial of this action, together with the subject matter on which each expert is expected to testify, the substance of the facts and opinions to which such expert is expected to testify, and a summary of the grounds for each opinion.
ANSWER: My lawyers have not decided whom they may use as expert witnesses at trial.
SUPPLEMENTAL ANSWER: : It is anticipated that the following expert witnesses
will testify on my behalf at trial:
Gerdt W. H. Schepers, M.D., Sc.D. 6527 Sunny Hill Court McLean, VA 22101 Doctor Schepers is a physician and Director of the Institute of Industrial and Forensic Medicine. Doctor Schepers is expected to testify that, to a reasonable degree of medical certainty, Mike Missik died from a malignant asbestos-caused pleural mesothelioma. Additionally, Dr. Schepers is expected to testify that Mike Missik had asbestosis. Doctor Schepers' opinions concerning Mr. Missik are set out more fully in his reports of October 23, 1997, and April 30, 1998, that are being produced this date in response to GATX's requests for production of documents. In addition to the foregoing opinions arrived at for the purpose of this litigation, Dr. Schepers is expected to testify as to widely known facts concerning the health hazards associated with exposure to asbestos and to dust containing asbestos particles. Further more, Dr. Schepers is expected to testify concerning the availability of information about such hazards. Barry I. Castleman, Sc.D. 2412 Pickwick Road Baltimore, MD 21207. Doctor Castleman is an Environmental Consultant and the author of Asbestos: Medical and Legal Aspects (4* ed. 1996). Doctor Castleman is expected to testify that there were numerous articles published about asbestos, asbestosis, lung cancer, and mesothelioma in persons exposed to asbestos and asbestos products before 1961. Doctor Castleman is also expected to testify that, from a public health standpoint, by the late 1930's, it was known from the published and widely available medical and scientific
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literature that persons exposed to dust released from asbestos-containing products were at risk for developing lung disease.
Lois Missik
COUNTY OF STATE OF
I HEREBY CERTIFY THAT on this________day of June 1998, before me, a Notary Public, in and for_________________________, Lois Missik personally appeared before me and made oath in due form of law that the matters and facts set forth above are true to the best of her knowledge and belief.
My commission expires:________________
NOTARY PUBLIC
Respectfully,
AND
DEAN E. SWARTZ, ESQ. (0043469) SWARTZ & REED 1825 Jefferson Place, N.W. Washington, D.C. 20036 Phone: (202) 429-0429 Fax: (202)429-0109
RONALD A. MARKS, ESQ.(0000977) 258 Seneca N.E. Warren, Ohio 44481 Phone: (330) 373-1028 Fax: (330)373-1029 Co-Counselfor Plaintiff
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