On December 10, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Patsy Young,
and
Aventis Inc.,
Avon Products, Inc.,
Block Drug Company, Inc.,
Block Drug Corporation,
Brenntag North America, Inc.,
Brenntag Specialties, Inc. F K A Mineral Pigment Solutions, Inc.,
Charles B. Chrystal Company, Inc.,
Chattem, Inc.,
Colgate-Palmolive Company,
Cyprus Amax Minerals Company,
Cyprus Mines Corporation,
Glaxosmithkline Llc (Sued Individually And As Successor-In-Interest To Block Drug Corporation, Successor-In-Interest To The Gold Bond Sterilizing Powder Company A K A The Gold Bond Company And As A Successor-In-Interest To Novartis Corporation And
Novartis Consumer Health Inc.),
Gsk Consumer Health, Inc. F K A Novartis Consumer Health Inc. F K A Ciba Self-Medication, Inc.,
Insight Pharmaceuticals Corporation, A Subsidiary Of Prestige Brands Holdings, Inc.,
Insight Pharmaceuticals Llc,
Macy'S Inc. F K A Federated Department Stores, Inc.,
Novartis Pharmaceuticals Corporation,
Prestige Brands Holdings, Inc.,
Prestige Consumer Healthcare Inc. F K A Prestige Brands, Inc.,
Sanofi-Aventis U.S. Llc,
Sanofi Us Services, Inc.,
Whittaker Clark & Daniels, Inc.,
for Torts - Asbestos
in the District Court of Erie County.
Preview
FILED: ERIE COUNTY CLERK 03/17/2021
01/13/2022
03/23/2022 02:22
09:46
09:33 PM
AM INDEX NO. 815818/2020
NYSCEF DOC. NO. 21
49
53 RECEIVED NYSCEF: 03/17/2021
01/13/2022
03/23/2022
Patsy Young v. Aventis Inc., et al.
Eighth Judicial District Asbestos Litigation – Erie County, Index # 815818/2020
Pretrial Conferences Scheduled for: June 7, 2021
August 2, 2021
November 15, 2021
January 3, 2022
Jury Selection Scheduled for: February 1, 2022
DISCOVERY AND TRIAL SUBMISSION SCHEDULE
3/23/2021 To extent not already provided, plaintiff to serve responses to defendants’
standard interrogatories and document requests and defendants’ standard
Article 16 interrogatories and document requests; provide copies of all medical
records and reports, personnel, union, earnings, social security, worker’s
compensation and tax documents in his/her/their possession; and provide
written authorizations on defendants.
3/23/2021 Defendants to serve non-repetitive, supplemental interrogatories upon plaintiff.
Plaintiff to serve responses to defendants’ non-repetitive, supplemental
interrogatories within 60 days following service.
3/30/2021 Plaintiff to serve non-repetitive, supplemental interrogatories or notice(s) to
produce. Defendants to serve responses to plaintiff’s non-repetitive,
supplemental discovery within 60 days following service.
3/30/2021 Plaintiff to provide names and addresses of all product identification witnesses
known to date, together with a list of the expected jobsites/shared residences
with the decedent; and defendants about which each witness is expected to offer
testimony. Plaintiff may amend and/or supplement this list at any time prior to
the date on which plaintiff is to respond to defendants’ product identification
letters. Plaintiff to serve Proof of Claim information to the extent any Proofs of
Claim have been filed (or to be provided within 30 days of submission to Trust,
whichever is sooner).
3/30/2021 Date of commencement of depositions
4/20/2021 Plaintiff to provide all original medical materials to defendants. Plaintiff
undertakes the duty to locate and obtain possession of all original medical
materials and to provide them to the defendants.
4/27/2021 Plaintiff to serve medical expert designations and information.
5/25/2021 Plaintiff’s deposition to be completed.
6/7/2021 Pretrial conference.
FILED: ERIE COUNTY CLERK 03/17/2021
01/13/2022
03/23/2022 02:22
09:46
09:33 PM
AM INDEX NO. 815818/2020
NYSCEF DOC. NO. 21
49
53 RECEIVED NYSCEF: 03/17/2021
01/13/2022
03/23/2022
6/23/2021 Last day for defendants to file third party actions.
6/23/2021 Last day for defendants to forward product and/or premises identification
letters.
7/13/2021 Last day for plaintiff to respond to product and/or premises identification
letters.
8/2/2021 Pretrial conference.
8/3/2021 All depositions to be completed with the exception of depositions of
defendants, spouse/surviving spouse, children/distributees, and/or estate
representative, which may be conducted until jury selection, except as to those
witnesses who will offer product identification testimony at trial.
8/10/2021 Plaintiff to serve and file notes of issue and statements of readiness and to serve
on each defendant a settlement demand.
8/10/2021 Plaintiff to serve non-medical expert designations and information.
9/14/2021 Defendants to serve summary judgment motions.
10/5/2021 Plaintiff to serve responses to summary judgment motions.
10/26/2021 Defendants to serve replies to plaintiff’s responses to summary judgment
motions.
11/15/2021 Pretrial conference and argument of summary judgment motions.
11/23/2021 Plaintiff to serve trial witness and exhibit lists and all motions in limine.
12/21/2021 Defendants to serve expert designations and information, trial witness and
exhibit lists, and all motions in limine.
12/28/2021 Plaintiffs and defendants to serve opposition to all motions in limine.
1/3/2022 Plaintiff and defendants to serve counter submissions and to serve all replies to
motions in limine.
1/3/2022 Final settlement conference and argument of motions in limine
2/1/2022 Jury selection.
Exhibit A
Document Filed Date
March 23, 2022
Case Filing Date
December 10, 2020
Category
Torts - Asbestos
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Preview
FILED: ERIE COUNTY CLERK 03/17/2021 01/13/2022 03/23/2022 02:22 09:46 09:33 PM AM INDEX NO. 815818/2020 NYSCEF DOC. NO. 21 49 53 RECEIVED NYSCEF: 03/17/2021 01/13/2022 03/23/2022 Patsy Young v. Aventis Inc., et al. Eighth Judicial District Asbestos Litigation – Erie County, Index # 815818/2020 Pretrial Conferences Scheduled for: June 7, 2021 August 2, 2021 November 15, 2021 January 3, 2022 Jury Selection Scheduled for: February 1, 2022 DISCOVERY AND TRIAL SUBMISSION SCHEDULE 3/23/2021 To extent not already provided, plaintiff to serve responses to defendants’ standard interrogatories and document requests and defendants’ standard Article 16 interrogatories and document requests; provide copies of all medical records and reports, personnel, union, earnings, social security, worker’s compensation and tax documents in his/her/their possession; and provide written authorizations on defendants. 3/23/2021 Defendants to serve non-repetitive, supplemental interrogatories upon plaintiff. Plaintiff to serve responses to defendants’ non-repetitive, supplemental interrogatories within 60 days following service. 3/30/2021 Plaintiff to serve non-repetitive, supplemental interrogatories or notice(s) to produce. Defendants to serve responses to plaintiff’s non-repetitive, supplemental discovery within 60 days following service. 3/30/2021 Plaintiff to provide names and addresses of all product identification witnesses known to date, together with a list of the expected jobsites/shared residences with the decedent; and defendants about which each witness is expected to offer testimony. Plaintiff may amend and/or supplement this list at any time prior to the date on which plaintiff is to respond to defendants’ product identification letters. Plaintiff to serve Proof of Claim information to the extent any Proofs of Claim have been filed (or to be provided within 30 days of submission to Trust, whichever is sooner). 3/30/2021 Date of commencement of depositions 4/20/2021 Plaintiff to provide all original medical materials to defendants. Plaintiff undertakes the duty to locate and obtain possession of all original medical materials and to provide them to the defendants. 4/27/2021 Plaintiff to serve medical expert designations and information. 5/25/2021 Plaintiff’s deposition to be completed. 6/7/2021 Pretrial conference. FILED: ERIE COUNTY CLERK 03/17/2021 01/13/2022 03/23/2022 02:22 09:46 09:33 PM AM INDEX NO. 815818/2020 NYSCEF DOC. NO. 21 49 53 RECEIVED NYSCEF: 03/17/2021 01/13/2022 03/23/2022 6/23/2021 Last day for defendants to file third party actions. 6/23/2021 Last day for defendants to forward product and/or premises identification letters. 7/13/2021 Last day for plaintiff to respond to product and/or premises identification letters. 8/2/2021 Pretrial conference. 8/3/2021 All depositions to be completed with the exception of depositions of defendants, spouse/surviving spouse, children/distributees, and/or estate representative, which may be conducted until jury selection, except as to those witnesses who will offer product identification testimony at trial. 8/10/2021 Plaintiff to serve and file notes of issue and statements of readiness and to serve on each defendant a settlement demand. 8/10/2021 Plaintiff to serve non-medical expert designations and information. 9/14/2021 Defendants to serve summary judgment motions. 10/5/2021 Plaintiff to serve responses to summary judgment motions. 10/26/2021 Defendants to serve replies to plaintiff’s responses to summary judgment motions. 11/15/2021 Pretrial conference and argument of summary judgment motions. 11/23/2021 Plaintiff to serve trial witness and exhibit lists and all motions in limine. 12/21/2021 Defendants to serve expert designations and information, trial witness and exhibit lists, and all motions in limine. 12/28/2021 Plaintiffs and defendants to serve opposition to all motions in limine. 1/3/2022 Plaintiff and defendants to serve counter submissions and to serve all replies to motions in limine. 1/3/2022 Final settlement conference and argument of motions in limine 2/1/2022 Jury selection. Exhibit A