Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023
EXHIBIT 68
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
:
JOHN G. RENTKO, as Executor for the : Index No. 190267/2020
Estate of MARILYN ANN RENTKO, and :
JOHN G. RENTKO, Individually :
: EXPERT WITNESS LIST OF
Plaintiff, : DEFENDANT CHARLES B.
- against - : CHRYSTAL, INC.
:
AVON PRODUCTS, INC., et al., :
:
Defendants. :
DEFENDANT, Charles B. Chrystal, Inc. (improperly sued as “Charles B. Chrystal
Company, Inc.”) (“Defendant”), by and through its counsel, McElory, Deutsch, Mulvaney &
Carpenter, LLP, hereby discloses the following expert witnesses who may be called to testify at
trial in person or by deposition. Defendant reserves the right to call all witnesses filed by lead
counsel for defendants in this litigation. Defendant also reserves the right to call all witnesses
identified by the individual defendants in their respective Fact and Expert Witness Disclosures.
Defendant also reserves the right to call as a witness any witness necessary to rebut witnesses
produced by Plaintiff at trial.
The below-listed experts may offer testimony regarding one or more of the following
topics:
1. The symptoms associated with mesothelioma, the disease process and diagnosis
of diseases and cancers of the respiratory system;
2. The anatomy and function of the respiratory system including the systems of the
body which expel inhaled dust particles, and the diagnosis and treatment of diseases that affect
these systems;
3. The effect of exposure to substances other than asbestos and the development of
diseases of the lungs, respiratory system and other systems of the body;
4. The method of diagnosing various diseases including, but not limited to, the
method of diagnosing asbestos-related diseases and non-asbestos-related diseases and the criteria
for distinguishing asbestos-related diseases from non-asbestos-related diseases;
5. The effect of mesothelioma, asbestos exposure and other asbestos-related diseases
on life expectancy;
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
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6. The history and evolution of knowledge regarding asbestos-related diseases
among members of the medical and scientific communities;
7. The history and evolution of knowledge regarding asbestos-related diseases
among manufacturers, trade organizations, and members of the general public;
8. The characteristics of various asbestos fiber types, the difference in their
composition, durability and size and their propensity or lack of propensity for causing
mesothelioma, lung cancer, asbestosis, cancer, respiratory diseases or other diseases;
9. The medical and/or scientific aspects of the use of cosmetic talc;
10. The testing of cosmetic talc; and
11. The history and evolution of regulations promulgated by OSHA, the EPA and
other governmental and non-governmental entities regarding the use of asbestos.
1.) Gary Marsh, Ph.D.
Professor, University of Pittsburgh School of Public Health
A410 Crabtree Hall
Graduate School of Public Health
30 DeSoto Street
Pittsburgh, PA 15261
Dr. Marsh is a Professor of Epidemiology, Biostatistics and Clinical and Translational
Science at the University of Pittsburgh School of Public Health. He is the Founder and Director
of the University's Center for Occupational Biostatistics and Epidemiology. He has extensive
experience designing and conducting research in the areas of occupational epidemiology,
environmental epidemiology, health services evaluation, and survey sampling. He has authored
more than 160 peer reviewed articles published in the scientific literature.
Dr. Marsh may testify about the science of epidemiology and the differences between
case reports and the various types of epidemiological studies, the interpretation and reliability of
relevant epidemiological studies, including the Bradford Hill criteria, and the published literature
related to mesothelioma and cancer. He may testify to his work in the field of epidemiology,
including the state of the art in the field over time, particularly as it relates to asbestos, talc,
mesothelioma, and lung cancer. He may testify concerning the absence of scientific evidence
supporting Plaintiff's claims that Plaintiff's disease was caused by the application of cosmetic
talcum powder. He may also testify concerning the scientific evidence regarding differing
exposure levels of asbestos, the exposure levels of asbestos that may cause disease, the
nonhazardous nature of cosmetic talc, and consumer use of talcum powder. He may also testify
regarding the risk of cancer associated with workers exposed to asbestos or talc. Dr. Marsh may
further testify about the existence of exposure-response relationships between exposure to
asbestos and asbestos-related diseases and talc and talc-related diseases. He may testify
regarding the state of epidemiological evidence with respect to the causation of malignant
mesothelioma and other types of cancer or lung disease.
2
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Dr. Marsh may testify regarding the likelihood that the alleged exposures at issue in this
case caused or contributed to Plaintiff's alleged mesothelioma. He will testify that Plaintiff's
alleged exposure to products manufactured and/or sold by Defendant did not cause or
substantially contribute to Plaintiff's alleged mesothelioma. He may testify about how exposure
other than exposure allegedly from the use of Defendant’s products may have caused Plaintiff's
alleged injury. He may testify about government evaluations of talc and evaluations of talc
performed by scientific, regulatory and other bodies. He may testify about the existence of
spontaneous and non-malignant mesothelioma, as well as other risk factors that may contribute
to the development of mesothelioma. He may testify regarding the opinions or testimony of any
of Plaintiff's or other defendants' fact or expert witnesses related to causation. Dr. Marsh may
also testify regarding his review of scientific literature, documents, testimony, or other materials
produced in this matter or entered into evidence. He may additionally provide testimony in
response to the opinions and testimony by Plaintiff's experts.
2.) Christy Barlow, Ph.D.
249 Vanderbilt Ave
Norwood, Massachusetts 02062
Dr. Barlow obtained a Bachelor’s of Science in Biology and a minor in chemistry from
Eckerd College in the year 2000. In 2006, she obtained a Ph.D. in cellular molecular biology
from the Environmental Pathology and Toxicology program at the University of Vermont. She
completed her postdoctoral fellowship at the University of Wisconsin in Madison.
3.) Alan Segrave, P.G.
Bureau Veritas
3380 Chastain Meadows Parkway, Suite 300
Kennesaw, GA 31044
Mr. Segrave is a Division Manager, Laboratory Director at Bureau Veritas North
America, Inc. He has 28 years of experience in environmental laboratory management,
consulting, and business development. His responsibilities in operations management include
technical proposal and report development, oversight of microscopy analyses, quality control
implementation and application, staffing and professional development, budget preparation, and
P&L accountability. He oversees laboratory protocols and quality assurance programs based on
guidelines of the National Voluntary Laboratory Accreditation Program, International Standards
Organization, American Industrial Hygiene Association, and American Society for Testing and
Materials. He directs a staff of 10 professionals performing microscopical analysis by scanning
electron microscopy, polarized light microscopy, phase contrast microscopy, transmission
electron microscopy, and energy-dispersive spectroscopy. Mr. Segrave is also a Professional
Geologist, State of Georgia, and is an internationally recognized expert in asbestos mineral
identification. As an expert in asbestos mineral identification in air, dust, water, and bulk
matrices, he has been retained for matters involving product liability, personal injury, and
product identification cases involving asbestos. He is an active member of the American Society
for Testing and Materials (ASTM), currently serving as Vice Chairman of D22.07, Sampling and
Analytical Committee for Asbestos.
3
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Mr. Segrave may address and rebut opinions offered by Plaintiff’s experts and other
experts in Mr. Segrave's same field(s). He may testify about mineralogical and geological issues
related to various forms of asbestos and talc. He may testify regarding the asbestos content of
talc and of mines. He may testify about hypotheticals. He may testify about testing of talc and
consumer talcum powder products for the presence of asbestos, by others, including Plaintiff’s
experts. He may testify about the literature and historical knowledge regarding talc and asbestos
4.) Stanley J. Geyer, M.D.
Geyer Pathology Services LLC
3 Willow Farms Lane
Pittsburgh, PA 15238
Dr. Geyer is a specialist in pathology. Based on his knowledge, experience, training, and
his review of the relevant medical and scientific literature and plaintiff’s medical records and
case materials, he is expected to testify about the pathology of asbestos in general and with
particular reference to the plaintiff to include any or all of the following areas:
Dr. Geyer may testify as to the general medical aspects of the diagnosis and treatment of
asbestos-related disease and the pathological effects of asbestos in the lung. He may also testify
as to the relationship of asbestos exposure and the incidence of conditions alleged by Plaintiff,
including pleural plaques, asbestosis, lung cancer and mesothelioma. Dr. Geyer may testify
about the classifications of asbestos fibers. Dr. Geyer may testify regarding the differing
potential of these various forms of asbestos to cause conditions alleged by Plaintiffs, including
pleural plaques, asbestosis, lung cancer and mesothelioma. Dr. Geyer may testify generally
regarding the role that the size, structure and chemical composition of different types of asbestos
fibers plays in their ability, or lack thereof, to cause conditions alleged by Plaintiff. Dr. Geyer
may testify generally regarding the role of dose in determining whether certain types of asbestos
fibers can cause or contribute to conditions alleged by Plaintiff. Dr. Geyer may testify generally
regarding the latency periods associated with asbestos-related conditions alleged by Plaintiff.
Dr. Geyer may also testify regarding the diagnosis of any purportedly asbestos related
disease or condition alleged by Plaintiff and respond to testimony by any of Plaintiff’s experts
regarding the same. Dr. Geyer may also testify regarding other probable or possible causes of
any disease or condition alleged by Plaintiff, including, but not limited to, smoking where
relevant.
5.) A. Michael Ierardi, MES, MS
Cardno ChemRisk
231 Front St Suite 212,
Brooklyn, NY 11201’
Mr. A. Michael Ierardi is a Supervising Health Scientist and Regional Unit Manager with
Cardno ChemRisk in the Brooklyn office. His principal areas of expertise, interest, and training
include industrial hygiene and safety, exposure science, environmental health, and human health
risk assessment. At Cardno ChemRisk, Mr. Ierardi provides on-site industrial hygiene support
and sampling; conducts exposure assessments and dose reconstructions for a variety of
4
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023
chemicals, including asbestos, talc, and diacetyl, in a diverse array of occupational and non-
occupational settings; and routinely assists clients with risk management and risk communication
strategies. Mr. Ierardi has also previously been invited to teach lectures related to industrial
hygiene, including on asbestos exposures and health effects, and has served as an Adjunct
Lecturer at the CUNY Graduate School of Public Health & Health Policy.Mr. Ierardi graduated
from the University of Pennsylvania with a Bachelor of Arts degree in Environmental Studies
and Hispanic Studies in 2013, as well as with a Master of Environmental Studies degree, with a
concentration in Environmental Health, in 2014. He also graduated with a Master of Science
degree in Industrial Hygiene from the CUNY Graduate School of Public Health & Health Policy
in 2020.
6.) Bryan Bandli
RJ Lee Group
350 Hochberg Road
Monroeville , PA 15146
Bryan Bandli, Ph.D., Geology, is a Principal Investigator and a member of the Technical
Consulting Group at RJ Lee Group, Inc. He is a mineralogist and microscopist with over a
decade of practical experience performing microanalytical investigations of a wide variety of
materials. He has worked extensively on the characterization of asbestos and the application of
electron backscatter diffraction (EBSD) to the identification of asbestos minerals and zeolites.
His previous work also included characterization of amphibole minerals contained in vermiculite
from Libby Montana, and airborne particulates produced from taconite mining operations in
Minnesota. He has also utilized various automated scanning electron microscopy systems to
characterize both bulk and particulate materials for mining, geology, and stack emission testing
projects. Dr. Bandli has authored or co-authored more than 40 publications/presentations
including in peer-reviewed journals.
Charles B. Crystal may amend and/or supplement its expert witness list as discovery
continues, up to and including at the time of trial, and as justice so requires.
DATED: November 22, 2022 By: /s/ Josie Sheppard Wilson
Rochester, New York Josie Sheppard Wilson, Esq.
Attorneys for Charles B. Chrystal, Inc.
(improperly sued as “Charles B. Chrystal
Company, Inc.”)
MCELROY, DEUTSCH, MULVANEY &
CARPENTER, LLP
820 BAUSCH & LOMB PLACE
ROCHESTER, NY 14604
TELEPHONE: (585) 623-4290
5
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023
TO: Weitz & Luxenberg, P.C.
Attn: Ambre Brandis, Esq.
Attorneys for Plaintiff
700 Broadway
New York, NY 10003
All Defense Counsel of Record (available upon request)
6
Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 EXHIBIT 68 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK : JOHN G. RENTKO, as Executor for the : Index No. 190267/2020 Estate of MARILYN ANN RENTKO, and : JOHN G. RENTKO, Individually : : EXPERT WITNESS LIST OF Plaintiff, : DEFENDANT CHARLES B. - against - : CHRYSTAL, INC. : AVON PRODUCTS, INC., et al., : : Defendants. : DEFENDANT, Charles B. Chrystal, Inc. (improperly sued as “Charles B. Chrystal Company, Inc.”) (“Defendant”), by and through its counsel, McElory, Deutsch, Mulvaney & Carpenter, LLP, hereby discloses the following expert witnesses who may be called to testify at trial in person or by deposition. Defendant reserves the right to call all witnesses filed by lead counsel for defendants in this litigation. Defendant also reserves the right to call all witnesses identified by the individual defendants in their respective Fact and Expert Witness Disclosures. Defendant also reserves the right to call as a witness any witness necessary to rebut witnesses produced by Plaintiff at trial. The below-listed experts may offer testimony regarding one or more of the following topics: 1. The symptoms associated with mesothelioma, the disease process and diagnosis of diseases and cancers of the respiratory system; 2. The anatomy and function of the respiratory system including the systems of the body which expel inhaled dust particles, and the diagnosis and treatment of diseases that affect these systems; 3. The effect of exposure to substances other than asbestos and the development of diseases of the lungs, respiratory system and other systems of the body; 4. The method of diagnosing various diseases including, but not limited to, the method of diagnosing asbestos-related diseases and non-asbestos-related diseases and the criteria for distinguishing asbestos-related diseases from non-asbestos-related diseases; 5. The effect of mesothelioma, asbestos exposure and other asbestos-related diseases on life expectancy; FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 6. The history and evolution of knowledge regarding asbestos-related diseases among members of the medical and scientific communities; 7. The history and evolution of knowledge regarding asbestos-related diseases among manufacturers, trade organizations, and members of the general public; 8. The characteristics of various asbestos fiber types, the difference in their composition, durability and size and their propensity or lack of propensity for causing mesothelioma, lung cancer, asbestosis, cancer, respiratory diseases or other diseases; 9. The medical and/or scientific aspects of the use of cosmetic talc; 10. The testing of cosmetic talc; and 11. The history and evolution of regulations promulgated by OSHA, the EPA and other governmental and non-governmental entities regarding the use of asbestos. 1.) Gary Marsh, Ph.D. Professor, University of Pittsburgh School of Public Health A410 Crabtree Hall Graduate School of Public Health 30 DeSoto Street Pittsburgh, PA 15261 Dr. Marsh is a Professor of Epidemiology, Biostatistics and Clinical and Translational Science at the University of Pittsburgh School of Public Health. He is the Founder and Director of the University's Center for Occupational Biostatistics and Epidemiology. He has extensive experience designing and conducting research in the areas of occupational epidemiology, environmental epidemiology, health services evaluation, and survey sampling. He has authored more than 160 peer reviewed articles published in the scientific literature. Dr. Marsh may testify about the science of epidemiology and the differences between case reports and the various types of epidemiological studies, the interpretation and reliability of relevant epidemiological studies, including the Bradford Hill criteria, and the published literature related to mesothelioma and cancer. He may testify to his work in the field of epidemiology, including the state of the art in the field over time, particularly as it relates to asbestos, talc, mesothelioma, and lung cancer. He may testify concerning the absence of scientific evidence supporting Plaintiff's claims that Plaintiff's disease was caused by the application of cosmetic talcum powder. He may also testify concerning the scientific evidence regarding differing exposure levels of asbestos, the exposure levels of asbestos that may cause disease, the nonhazardous nature of cosmetic talc, and consumer use of talcum powder. He may also testify regarding the risk of cancer associated with workers exposed to asbestos or talc. Dr. Marsh may further testify about the existence of exposure-response relationships between exposure to asbestos and asbestos-related diseases and talc and talc-related diseases. He may testify regarding the state of epidemiological evidence with respect to the causation of malignant mesothelioma and other types of cancer or lung disease. 2 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 Dr. Marsh may testify regarding the likelihood that the alleged exposures at issue in this case caused or contributed to Plaintiff's alleged mesothelioma. He will testify that Plaintiff's alleged exposure to products manufactured and/or sold by Defendant did not cause or substantially contribute to Plaintiff's alleged mesothelioma. He may testify about how exposure other than exposure allegedly from the use of Defendant’s products may have caused Plaintiff's alleged injury. He may testify about government evaluations of talc and evaluations of talc performed by scientific, regulatory and other bodies. He may testify about the existence of spontaneous and non-malignant mesothelioma, as well as other risk factors that may contribute to the development of mesothelioma. He may testify regarding the opinions or testimony of any of Plaintiff's or other defendants' fact or expert witnesses related to causation. Dr. Marsh may also testify regarding his review of scientific literature, documents, testimony, or other materials produced in this matter or entered into evidence. He may additionally provide testimony in response to the opinions and testimony by Plaintiff's experts. 2.) Christy Barlow, Ph.D. 249 Vanderbilt Ave Norwood, Massachusetts 02062 Dr. Barlow obtained a Bachelor’s of Science in Biology and a minor in chemistry from Eckerd College in the year 2000. In 2006, she obtained a Ph.D. in cellular molecular biology from the Environmental Pathology and Toxicology program at the University of Vermont. She completed her postdoctoral fellowship at the University of Wisconsin in Madison. 3.) Alan Segrave, P.G. Bureau Veritas 3380 Chastain Meadows Parkway, Suite 300 Kennesaw, GA 31044 Mr. Segrave is a Division Manager, Laboratory Director at Bureau Veritas North America, Inc. He has 28 years of experience in environmental laboratory management, consulting, and business development. His responsibilities in operations management include technical proposal and report development, oversight of microscopy analyses, quality control implementation and application, staffing and professional development, budget preparation, and P&L accountability. He oversees laboratory protocols and quality assurance programs based on guidelines of the National Voluntary Laboratory Accreditation Program, International Standards Organization, American Industrial Hygiene Association, and American Society for Testing and Materials. He directs a staff of 10 professionals performing microscopical analysis by scanning electron microscopy, polarized light microscopy, phase contrast microscopy, transmission electron microscopy, and energy-dispersive spectroscopy. Mr. Segrave is also a Professional Geologist, State of Georgia, and is an internationally recognized expert in asbestos mineral identification. As an expert in asbestos mineral identification in air, dust, water, and bulk matrices, he has been retained for matters involving product liability, personal injury, and product identification cases involving asbestos. He is an active member of the American Society for Testing and Materials (ASTM), currently serving as Vice Chairman of D22.07, Sampling and Analytical Committee for Asbestos. 3 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 Mr. Segrave may address and rebut opinions offered by Plaintiff’s experts and other experts in Mr. Segrave's same field(s). He may testify about mineralogical and geological issues related to various forms of asbestos and talc. He may testify regarding the asbestos content of talc and of mines. He may testify about hypotheticals. He may testify about testing of talc and consumer talcum powder products for the presence of asbestos, by others, including Plaintiff’s experts. He may testify about the literature and historical knowledge regarding talc and asbestos 4.) Stanley J. Geyer, M.D. Geyer Pathology Services LLC 3 Willow Farms Lane Pittsburgh, PA 15238 Dr. Geyer is a specialist in pathology. Based on his knowledge, experience, training, and his review of the relevant medical and scientific literature and plaintiff’s medical records and case materials, he is expected to testify about the pathology of asbestos in general and with particular reference to the plaintiff to include any or all of the following areas: Dr. Geyer may testify as to the general medical aspects of the diagnosis and treatment of asbestos-related disease and the pathological effects of asbestos in the lung. He may also testify as to the relationship of asbestos exposure and the incidence of conditions alleged by Plaintiff, including pleural plaques, asbestosis, lung cancer and mesothelioma. Dr. Geyer may testify about the classifications of asbestos fibers. Dr. Geyer may testify regarding the differing potential of these various forms of asbestos to cause conditions alleged by Plaintiffs, including pleural plaques, asbestosis, lung cancer and mesothelioma. Dr. Geyer may testify generally regarding the role that the size, structure and chemical composition of different types of asbestos fibers plays in their ability, or lack thereof, to cause conditions alleged by Plaintiff. Dr. Geyer may testify generally regarding the role of dose in determining whether certain types of asbestos fibers can cause or contribute to conditions alleged by Plaintiff. Dr. Geyer may testify generally regarding the latency periods associated with asbestos-related conditions alleged by Plaintiff. Dr. Geyer may also testify regarding the diagnosis of any purportedly asbestos related disease or condition alleged by Plaintiff and respond to testimony by any of Plaintiff’s experts regarding the same. Dr. Geyer may also testify regarding other probable or possible causes of any disease or condition alleged by Plaintiff, including, but not limited to, smoking where relevant. 5.) A. Michael Ierardi, MES, MS Cardno ChemRisk 231 Front St Suite 212, Brooklyn, NY 11201’ Mr. A. Michael Ierardi is a Supervising Health Scientist and Regional Unit Manager with Cardno ChemRisk in the Brooklyn office. His principal areas of expertise, interest, and training include industrial hygiene and safety, exposure science, environmental health, and human health risk assessment. At Cardno ChemRisk, Mr. Ierardi provides on-site industrial hygiene support and sampling; conducts exposure assessments and dose reconstructions for a variety of 4 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 chemicals, including asbestos, talc, and diacetyl, in a diverse array of occupational and non- occupational settings; and routinely assists clients with risk management and risk communication strategies. Mr. Ierardi has also previously been invited to teach lectures related to industrial hygiene, including on asbestos exposures and health effects, and has served as an Adjunct Lecturer at the CUNY Graduate School of Public Health & Health Policy.Mr. Ierardi graduated from the University of Pennsylvania with a Bachelor of Arts degree in Environmental Studies and Hispanic Studies in 2013, as well as with a Master of Environmental Studies degree, with a concentration in Environmental Health, in 2014. He also graduated with a Master of Science degree in Industrial Hygiene from the CUNY Graduate School of Public Health & Health Policy in 2020. 6.) Bryan Bandli RJ Lee Group 350 Hochberg Road Monroeville , PA 15146 Bryan Bandli, Ph.D., Geology, is a Principal Investigator and a member of the Technical Consulting Group at RJ Lee Group, Inc. He is a mineralogist and microscopist with over a decade of practical experience performing microanalytical investigations of a wide variety of materials. He has worked extensively on the characterization of asbestos and the application of electron backscatter diffraction (EBSD) to the identification of asbestos minerals and zeolites. His previous work also included characterization of amphibole minerals contained in vermiculite from Libby Montana, and airborne particulates produced from taconite mining operations in Minnesota. He has also utilized various automated scanning electron microscopy systems to characterize both bulk and particulate materials for mining, geology, and stack emission testing projects. Dr. Bandli has authored or co-authored more than 40 publications/presentations including in peer-reviewed journals. Charles B. Crystal may amend and/or supplement its expert witness list as discovery continues, up to and including at the time of trial, and as justice so requires. DATED: November 22, 2022 By: /s/ Josie Sheppard Wilson Rochester, New York Josie Sheppard Wilson, Esq. Attorneys for Charles B. Chrystal, Inc. (improperly sued as “Charles B. Chrystal Company, Inc.”) MCELROY, DEUTSCH, MULVANEY & CARPENTER, LLP 820 BAUSCH & LOMB PLACE ROCHESTER, NY 14604 TELEPHONE: (585) 623-4290 5 FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 153 RECEIVED NYSCEF: 07/10/2023 TO: Weitz & Luxenberg, P.C. Attn: Ambre Brandis, Esq. Attorneys for Plaintiff 700 Broadway New York, NY 10003 All Defense Counsel of Record (available upon request) 6