On January 02, 2019 a
Exhibit,Appendix
was filed
involving a dispute between
Mark Welt,
Mary Welt,
and
Ann Mattioli,
Richard Mattioli D B A Clinton Auto Repair,
Richard Mattioli
D B A Clinton Auto Repair,
Wing Enterprises, Incorporated D B A Little Giant Solutions,
Wing Enterprises, Incorporated
D B A Little Giant Solutions,
for Torts - Other (Fall)
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 11/18/2021
01/20/2022 10:25
04:28 AM
PM INDEX NO. 800040/2019
NYSCEF DOC. NO. 49
57 RECEIVED NYSCEF: 11/18/2021
01/20/2022
EXHIBIT A
FILED: ERIE COUNTY CLERK 11/18/2021
01/20/2022 10:25
04:28 AM
PM INDEX NO. 800040/2019
NYSCEF DOC. NO. 49
57 RECEIVED NYSCEF: 11/18/2021
01/20/2022
THOMAS E. BAYER P.E.
ACCOMPLISHMENTS
Project Management
• Managed Engineering Department for a 2500 item product line
• Provided ANSI code rewrites for numerous sections
• Managed Thirty Professionals with annual budgets of three million dollars
• Managed the redesign and introduction of 75 climbing products after acquisition of a
competitor and completed project in six months
• Conducted ladder and scaffolding safety programs for manufacturers, schools, & colleges
• Provided P.E. Application Review for Scaffold, Shoring, & Forming Installations
• Researched applications for electronic assisted manufacturing (EAM)
• Managed a specify/build project for a 40 model fall protection product line
• Served as Project Manager for the start up of a new 50 employee assembly facility
Product Design
• Designed products that used aluminum and plastic extrusions; die, sand and investment
castings; plastic injection and blow molding ; fiberglass pultrusion; piercing, blanking, drilling,
bending , and forming fabrication processes; solid, semitubular, and blind riveting; welding;
plating; and heat treating
• Redesigned scaffold plank side rails providing additional capacity and 15% weight reduction
• Developed a folding scaffold base section
• Provided Product Design/Development advice for inventors of various products
• Designed a mechanically joined scaffold with improved static and cyclic strength over
existing welded units, while reducing production time 75%
• Conducted Stress/Deflection analyses for architectural applications
• Awarded 2 patents for climbing equipment (scaffold board hook and handrail coupler)
Forensic Engineering
• Performed live courtroom accident reenactments and product integrity demonstrations
• Built full scale mock-ups and videotaped accident reenactment evidence
• Prepared animations to demonstrate accident theories
• Provided expert advice and testified in over 25 trials and 90 depositions
WORK HISTORY
Bayer Engineering, Greenville, PA 2001-Present
Engineering Consulting Service
Werner Co, Greenville, PA 1982-2001
Director Product Engineering 2000-2001
Chief Product Engineer 1993-2000
Product/ Senior Product Engineer 1982-1993
General Bectric Co, 1sn-1ss2
Development Engineer- Transportation Systems 1979-1982
Manufacturing Management Program 1977-1979
EDUCATION / CERTIFICATIONS CONTINUING EDUCATION
B.S.M .E. University of Pittsburgh, 1977 OSHA 500 Construction Safety
Registered Professional Engineer, PA, OH, D.C. Manufacturing Studies Courses
OSHA Certified Construction Trainer ANSYS Finite Element Analysis
Metal Fatigue Life Prediction
Design of Experiments
Aluminum Metallurgy
Document Filed Date
January 20, 2022
Case Filing Date
January 02, 2019
Category
Torts - Other (Fall)
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Preview
FILED: ERIE COUNTY CLERK 11/18/2021 01/20/2022 10:25 04:28 AM PM INDEX NO. 800040/2019 NYSCEF DOC. NO. 49 57 RECEIVED NYSCEF: 11/18/2021 01/20/2022 EXHIBIT A FILED: ERIE COUNTY CLERK 11/18/2021 01/20/2022 10:25 04:28 AM PM INDEX NO. 800040/2019 NYSCEF DOC. NO. 49 57 RECEIVED NYSCEF: 11/18/2021 01/20/2022 THOMAS E. BAYER P.E. ACCOMPLISHMENTS Project Management • Managed Engineering Department for a 2500 item product line • Provided ANSI code rewrites for numerous sections • Managed Thirty Professionals with annual budgets of three million dollars • Managed the redesign and introduction of 75 climbing products after acquisition of a competitor and completed project in six months • Conducted ladder and scaffolding safety programs for manufacturers, schools, & colleges • Provided P.E. Application Review for Scaffold, Shoring, & Forming Installations • Researched applications for electronic assisted manufacturing (EAM) • Managed a specify/build project for a 40 model fall protection product line • Served as Project Manager for the start up of a new 50 employee assembly facility Product Design • Designed products that used aluminum and plastic extrusions; die, sand and investment castings; plastic injection and blow molding ; fiberglass pultrusion; piercing, blanking, drilling, bending , and forming fabrication processes; solid, semitubular, and blind riveting; welding; plating; and heat treating • Redesigned scaffold plank side rails providing additional capacity and 15% weight reduction • Developed a folding scaffold base section • Provided Product Design/Development advice for inventors of various products • Designed a mechanically joined scaffold with improved static and cyclic strength over existing welded units, while reducing production time 75% • Conducted Stress/Deflection analyses for architectural applications • Awarded 2 patents for climbing equipment (scaffold board hook and handrail coupler) Forensic Engineering • Performed live courtroom accident reenactments and product integrity demonstrations • Built full scale mock-ups and videotaped accident reenactment evidence • Prepared animations to demonstrate accident theories • Provided expert advice and testified in over 25 trials and 90 depositions WORK HISTORY Bayer Engineering, Greenville, PA 2001-Present Engineering Consulting Service Werner Co, Greenville, PA 1982-2001 Director Product Engineering 2000-2001 Chief Product Engineer 1993-2000 Product/ Senior Product Engineer 1982-1993 General Bectric Co, 1sn-1ss2 Development Engineer- Transportation Systems 1979-1982 Manufacturing Management Program 1977-1979 EDUCATION / CERTIFICATIONS CONTINUING EDUCATION B.S.M .E. University of Pittsburgh, 1977 OSHA 500 Construction Safety Registered Professional Engineer, PA, OH, D.C. Manufacturing Studies Courses OSHA Certified Construction Trainer ANSYS Finite Element Analysis Metal Fatigue Life Prediction Design of Experiments Aluminum Metallurgy