Document pmJVJ8oXNBkO1mJ8BK0X2Dz46
Case: 2:13-md-02433-EAS-EPD Doc #: 3441 Filed: 05/15/15 Page: 1 of 3 PAGEID #: 59320
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
IN RE: E.I. DU PONT DE NEMOURS AND COMPANY C-8 PERSONAL INJURY LITIGATION
CASE NO: 2:13-MD-2433
JUDGE EDMUND A. SARGUS, JR.
MAGISTRATE JUDGE ELIZABETH P. DEAVERS
This document relates to:
Carla Marie Bartlett v. E.I. du Pont de Nemours and Company, Case No. 2:13-cv-170.
John M. Wolf v. E.I. du Pont de Nemours and Company, Case No. 2:14-cv-095.
TRIAL PLAINTIFFS' NOTICE OF FILING UPDATED EXPERT REPORTS
Now that a number of confidentiality challenges between the parties have been resolved that had previously required various expert reports to be filed either originally under seal or in redacted form in multiple filings throughout the record, Plaintiffs Carla Bartlett and Jon Wolf ("Trial Plaintiffs") hereby re-submit in one consolidated filing all of their proffered expert reports, including several in fully-un-redacated form that were previously redacted:
- Exhibit A: Report of Steven Amter, dated November 21, 2014; - Exhibit B: Report of Robert R. Bahnson, MD., FACS, dated December 8, 2014; - Exhibit C: Report of Stephen E. Petty, P.E., C.I.H., C.S.P., dated December 6, 2014; - Exhibit D: Reports of Robert W. Johnson, dated December 3, 2014 and March 9, 2015; - Exhibit E: Report of Vitaly Margulis, M.D., F.A.C.S., dated December 8, 2014; - Exhibit F: Report of Robert J. Herceg, M.D., dated December 8, 2014;
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- Exhibit G: Report of Robert A. Gross, M.D., dated December 8, 2014;
- Exhibit H: Report of Michael B. Siegel, M.D., M.P.H., dated November 21, 2014;
- Exhibit I: Report of James S. Smith, Ph.D., CPC, dated November 20, 2014;
- Exhibit J: Report of Barry S. Levy, dated November 20, 2014; and
- Exhibit K: Report of David L. Macintosh, dated December 8, 2014.
Each report is accompanied by a sworn declaration executed by the expert, attesting that
the report is a true and accurate copy and that all opinions in the report are stated to a reasonable
degree of scientific and/or medical certainty based on reliable methods. Each expert further
attests that, if called as a witness, he would testify competently to the matters stated in his report.
Respectfully submitted,
s/ Michael A. London______ Michael A. London Douglas & London, P.C. 59 Maiden Lane, 6thFloor New York, NY 10038 Telephone: 212-566-7500 Fax: 212-566-7501 Email: mlondon@douglasandlondon.com
Jon C. Conlin Cory Watson, P.C. 2131 Magnolia Ave., Suite 200 Birmingham, AL 35205 Telephone: 205-328-2200 Fax: 205-324-7896 Email: jconlin@cwcd.com
Robert A. Bilott Taft Stettinius & Hollister LLP Cincinnati, Ohio 45202-3957 Telephone: 513-381-2838 Fax: 513-381-0205 Email: Bilott@taftlaw.com
Plaintiffs 'Steering Committee Co-Lead Counsel
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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was electronically filed with this Court's CM/ECF on this 15th day of May 2015 and was thus served electronically upon all counsel of record.
s/ Michael A. London Michael A. London