Escolar Documentos
Profissional Documentos
Cultura Documentos
Information 1
1 Expert Profile 3
2 Court Documents 4
Expert Litigation 4
Non-Expert Litigation 16
6 Expert Publications 26
7 Internet Research 30
8 Expert Patents 33
Appendix One 36
Appendix Two 38
Appendix Three 41
Appendix Four 44
Appendix Five 47
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Information
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Information 1
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Information 2
1 Expert Profile
JOHN H. DOE, PE, PH.D.
PHOTO
John Doe, PE, Ph.D., is senior consulting engineer and founding partner of Doe Enterprises, LLC.
As an organic chemist with more than 20 years of experience in professional engineering, he
provides expertise in matters such as property damage, personal injury, failure analysis, and
patent infringement. He earned his M.Sc. and Ph.D. from Major State University. Doe has provided
expert testimony on behalf of both plaintiffs and defendants in federal courts.
Wisconsin
online.drl.wi.gov/LicenseLookup/CredSummaryDetails.aspx?chid=46495
PUBLIC RECORDS
1 Expert Profile 3
2 Court Documents
This section includes information regarding the experts court activity obtained from multiple Westlaw databases, including
Westlaw dockets. These databases are updated frequently, providing access to current reports, affidavits, depositions and trial
transcripts.
EXPERT LITIGATION
GOESEL, ET AL. V. BOLEY INTL (HK) LTD., ET AL. SUBWAY INTL BV V. GILL
WHITE V. FLORIDA MARINE TRANSPORTATION, INC. HANKERSON V. CRETE CARRIER CORP., ET AL.
FORTUNE MFG. CO., LTD. V. ZURN INDUSTRIES, LLC SOLT, ET AL. V. UNITED PLASTICS FABRICATION, INC.,
ET AL.
1. Trial Motions/Memoranda
Memorandum of Law of Defendants Hearthmark, LLC and Wal-Mart Stores, Inc. in Support
of Motion to Exclude the Opinions and Testimony of Dr. John Joe
Kimberly LANDIS and Alva Nelson, as parents and guardians of A.N., a minor, Plaintiffs, v.
JARDEN CORPORATION, Hearthmark, LLC d/b/a Jarden Home Brands, Wal-Mart Stores,
Inc., C.K.S. Packaging, Inc., Packaging Service Company, Inc., and Stull Technologies, Inc.,
Defendants/Third Party Plaintiffs, v. Kimberly Landis and Alva Nelson, in their individual
capacities, Third Party Defendants. United States District Court, N.D. West Virginia., Elkins
Division November 22, 2013 No. 2:11-CV-00-101-JPB. 2013 WL 7137592
2 Court Documents 4
2. Case Decisions/Trial Orders
Landis v. Hearthmark, LLC
United States District Court, N.D. West Virginia, Elkins. January 15, 2014 Slip Copy 2014 WL
198555 2:11-CV-101
1. Expert Testimony/Reports/Affidavits
Deposition of: John Doe, Ph.D.
Partial Expert Testimony Yucatan FOODS, L.P., a Delaware Limited Partnership, Plaintiff, v.
BERRY PLASTICS CORPORATION, a Delaware Corporation; and Does 1 through 50,
inclusive, Defendants. Superior Court of California. January 08, 2013 No. BC458182. 2013
WL 5352378
2. Jury Verdicts/Settlements
Yucatan Foods LP vs. Berry Plastics Corporation
Superior Court, Los Angeles County, California. March 15, 2013 DOCKET NUMBER:
BC458182 41 Trials Digest 16th 12
1. Appellate Briefs
Brief of Appellant Williams, Bax & Saltzman, P.C. Redacted Pursuant to Order of
September 10, 2013
Andrew GOESEL, et al., v. BOLEY INTERNATIONAL (HK) LTD., et al. United States Court of
Appeals, Seventh Circuit. September 13, 2013 No. 13-2434. 2013 WL 5324298
2. Dockets
GOESEL ET AL V. BOLEY INTERNATIONAL ET AL
July 29, 2009 IL U.S. DIST. CT., NORTH 1:09-CV-04595 TORTS/NEGLIGENCE, PRODUCT
LIABILITY, PERSONAL INJURY Judge(s): HONORABLE MILTON I. SHADUR BOTH
2 Court Documents 5
WHITE V. FLORIDA MARINE TRANSPORTATION, INC.
(E.D. LA. 2012)
1. Expert Testimony/Reports/Affidavits
Report of John Doe Ph.D.
Expert Report and Affidavit Maritime Tammie WHITE, v. FLORIDA MARINE
TRANSPORTERS. United States District Court, E.D. Louisiana. April 01, 2012 No.
211CV01161. 2012 WL 1425261
FULL TEXT
2. Trial Motions/Memoranda
Opposition to Plaintiffs Daubert Motion to Preclude Testimony of Defendants Medical
Expert, Dr. Gerard Orthopedist
Tammie WHITE, v. FLORIDA MARINE TRANSPORTATION, INC. United States District
Court, E.D. Louisiana. April 17, 2012 No. 2:11-cv-01161. 2012 WL 1412218
3. Dockets
WHITE V. FLORIDA MARINE TRANSPORTERS, INC
May 17, 2011 LA U.S. DIST. CT., EAST 2:11-CV-01161 TORTS/NEGLIGENCE, MARINE
Judge(s): JUDGE ELDON E. FALLON NONE
2 Court Documents 6
FORTUNE MFG. CO., LTD. V. ZURN INDUSTRIES, LLC
(C.D. CAL. 2011)
1. Dockets
FORTUNE MFG. CO., LTD. V. ZURN INDUSTRIES, LLC
January 18, 2011 CA U.S. DIST. CT., CENT. 2:11-CV-00530 CONTRACTS, OTHER
CONTRACT
Entry 101 dated 11/03/2011 includes a PDF Of Plaintiff And Counterdefendant Fortune Mfg.
Co., Ltds Notice Of Lodging Of Deposition Transcript Of John Doe, P.E. In Support Of Its
Opposition To Zurns Motion For Summary Judgment. (Kpa) Modified On 11/7/2011 (Kpa).
(Entered: 11/07/2011)
1. Trial Motions/Memoranda
Defendant Rood Landscape, Inc. And Juan Zunigas Expert Witness List
Eric JOHNSON, Plaintiff, v. ROOD LANDSCAPE, INC., a Florida Corporation, and Juan
Zuniga., Defendant. Circuit Court of Florida., 19th Judicial Circuit January 27, 2011 No.
101295. 2011 WL 2975828
1. Trial Motions/Memoranda
Defendant Philip Morris USA Inc.s Objections to Plaintiffs revised Designation of
Testimony of Robert C. Roe
John GRILL, on behalf of himself and as fiduciary: of the estate of Ann Grill, Plaintiff, v.
PHILIP MORRIS USA INC., Defendant. United States District Court, S.D. New York. April
22, 2011 No. 7:05-cv-09174-CS. 2011 WL 1938647
2 Court Documents 7
Philip Morris USA Inc.s Consolidated Reply Memorandum of Law in Support of Its Motions
in Limine Nos. 8, 9, 10, and 11 (Concerning Testimony Regarding the meaning of
Documents or the intent of Their Drafters, the minimum Effective Dose of Nicotine
Theory, and Expert Testimony of Drs. Doe And Roe)
John GRILL, on behalf of himself and as fiduciary of the estate of Ann Grill, Plaintiff, v.
PHILIP MORRIS USA INC., Defendant. United States District Court, S.D. New York.
November 22, 2010 No. 05 Civ. 9174 (CS) (LMS). 2010 WL 6679994
Memorandum of Law in Support of Philip Morris USA Inc.s Motion in Limine No. 22 to
Exclude Evidence or Argument Relating to the Aggregate Harm Allegedly Caused by
Smoking
John GRILL, on behalf of himself and as fiduciary of the estate of Ann Grill, Plaintiff, v.
PHILIP MORRIS USA INC., Defendant. United States District Court, S.D. New York.
September 10, 2010 No. 05 Civ. 9174 (CS) (LMS). 2010 WL 4949290
Memorandum of Law in Support of Philip Morris USA Inc.s Motion in Limine No. 10 to
Exclude Testimony of Dr. John Doe
John GRILL, on behalf of himself and as fiduciary of the estate of Ann Grill, Plaintiff, v.
PHILIP MORRIS USA INC., Defendant. United States District Court, S.D. New York.
September 10, 2010 No. 05 Civ. 9174 (CS) (LMS). 2010 WL 4949291
3. Dockets
GRILL ET AL v. PHILIP MORRIS USA, INC
October 29, 2005 NY U.S. DIST. CT., SOUTH 7:05-cv-09174 TORTS/NEGLIGENCE,
PRODUCT LIABILITY, PERSONAL INJURY
2 Court Documents 8
Entry 155 Dated 09/10/2010 Refers To Declaration Of Lucy E. Mason In Support Re: 152
Motion In Limine No. 10 To Exclude Testimony Of Dr. John Doe.. Document Filed By Philip
Morris Usa, Inc. (Attachments: # Exhibit P, # Exhibit Q, # Exhibit R, # Exhibit S, # Exhibit T, #
Exhibit U, # Exhibit V, # Exhibit W, # Exhibit X, # 10 Exhibit Y, # 11 Exhibit Z, # 12 Exhibit Aa, #
13 Exhibit Bb, # 14 Exhibit Cc, # 15 Exhibit Dd, # 16 Exhibit Ee)(Mason, Lucy) (Entered: 09/10/
2010)
Entry 154 Dated 09/10/2010 Refers To Declaration Of Lucy E. Mason In Support Re: 152
Motion In Limine No. 10 To Exclude Testimony Of Dr. John Doe.. Document Filed By Philip
Morris Usa, Inc. (Attachments: # Exhibit A, # Exhibit B, # Exhibit C, # Exhibit D, # Exhibit E, #
Exhibit F, # Exhibit G, # Exhibit H, # Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13
Exhibit M, # 14 Exhibit N, # 15 Exhibit O)(Mason, Lucy) (Entered: 09/10/2010)
Entry 153 Dated 09/10/2010 Refers To Memorandum Of Law In Support Re: 152 Motion In
Limine No. 10 To Exclude Testimony Of Dr. John Doe. Document Filed By Philip Morris Usa, Inc.
(Mason, Lucy) (Entered: 09/10/2010)
Entry 152 Dated 09/10/2010 Refers To Motion In Limine No. 10 To Exclude Testimony Of Dr.
John Doe. Document Filed By Philip Morris Usa, Inc. Return Date Set For 12/20/2010 At 09:30
Am.(Mason, Lucy) (Entered: 09/10/2010)
1. Court-Filed CVs
John H. Doe, Ph.D.
Expert Resume United States District Court, D. Utah. September 24, 2007 2007 WL
6920823
2. Trial Motions/Memoranda
Defendants Memorandum of Law in Support of Its Motion for Summary Judgment and
Motion to Exclude Plaintiffs Experts
Mark S. BOUCHER, an individual, Linda B. Boucher, an individual, and as husband and
wife, Plaintiffs, v. ZIMMER, INC., a Delaware corporation, Defendant. United States District
Court, D. Utah., Northern Division February 16, 2010 No. 2:06cv000380 DAK. 2010 WL
1480265
2 Court Documents 9
SUBWAY INTL BV V. GILL
(D. CONN. 2009)
1. Arbitration Awards
Subway Intl BV, v. GILL.
Court Filed Awards Case Type: Contract D.Conn. Award December 07, 2009 No.
09CV01675. 2009 WL 5427346
1. Expert Testimony/Reports/Affidavits
Deposition of: John Doe, Ph.D.
Expert Deposition Vehicle Negligence Russell HANKERSON, Plaintiff, v. CRETE CARRIER
CORPORATION and Stephen Mann, individually and as an agent of Crete Carrier Corp.,
Defendants. United States District Court, S.D. Georgia, Augusta Division. December 03,
2009 No. CV109-73. 2009 WL 6866566
1. Expert Testimony/Reports/Affidavits
(Report or Affidavit of Joe J. Engineer, P.E.)
Expert Report and Affidavit Construction & Industrial Accidents WILSON SOLT, III. ET.UX.,
v. UNITED PLASTICS FABRICATION, INC. & L.W. Tank Repair. Inc. United States District
Court, M.D. Pennsylvania. February 17, 2009 No. 07CV01867. 2009 WL 1073706
Technical Report Expert Opinion on Cause of Failure during Hoisting of Elliptical Tank of
John Doe, Ph.D.
Expert Report and Affidavit Construction & Industrial Accidents Wilson SOLT III, v. UNITED
PLASTIC FABRICATION, INC. United States District Court, M.D. Pennsylvania. October 17,
2008 No. 07CV01867. 2008 WL 8215311
FULL TEXT
Technical Report Expert Opinion Regarding the Cause of Failure of Raymond A. Doctor,
Ph.D.
Expert Report and Affidavit Construction & Industrial Accidents Wilson SOLT III, v. UPF et
al. United States District Court, M.D. Pennsylvania. October 16, 2008 No. 07CV01867.
2008 WL 8215312
2 Court Documents 10
2. Trial Motions/Memoranda
Plaintiffs Brief in Support of Motion in Limine to Preclude Defendants From Raising The
Defense of Plaintiffs Alleged Assumption of The Risk
Wilson SOLT, III and Sandra Solt, Individually and Husband and Wife, Plaintiffs, v. UNITED
PLASTIC FABRICATION, INC. and L.W. Tank Repair, Inc., Defendants. United States
District Court, M.D. Pennsylvania. February 27, 2009 No. 307CV01867. 2009 WL 1109725
3. Jury Verdicts/Settlements
Wilson Solt v. United Plastic Fabrication Inc. and L.W. Tank Repair Inc.
PRODUCTS LIABILITY - DESIGN DEFECT - WORKPLACE United States District Court,
M.D. Pennsylvania. May 21, 2009 No. 3:CV 07-1867-JMM 2009 WL 3011557
1. Arbitration Awards
CITY OF SOUTHAVEN, Mississippi, v. DATAMATIC, LTD.
Court Filed Awards Case Type: Premises Liability N.D.Miss. Ruling On Motion to Exclude
and Award of Arbitrator May 19, 2008 Nos. 07CV00058, 153436. 2008 WL 8126465
1. Expert Testimony/Reports/Affidavits
Deposition of John Doe
Expert Deposition Vehicle Negligence Josephine CANTWAY, as court-appointed guardian
of Laura McGrath, an incompetent person, and as guardian on behalf of Riley J. McGrath
and Reece E. McGrath, Plaintiff, v. FEDERAL EXPRESS CORPORATION, a foreign
corporation, Automotive Rentals, Inc., a foreign corporation, and Shannon Lotito,
Defendants. Circuit Court of Florida, 15th Judicial Circuit, General Jurisdiction Division.
August 30, 2008 No. CL 99-6082 AB. 2008 WL 5967275
FULL TEXT
Continued Deposition of Dr. John Doe taken on behalf of the Defendant pursuant to a
notice of taking deposition
Expert Deposition Vehicle Negligence Josephine CANTWAY, as court-appointed guardian
of Laura McGrath, an incompetent person, and as guardian on behalf of Riley J. McGrath
and Reece E. McGrath, Plaintiff, v. FEDERAL EXPRESS CORPORATION, a foreign
corporation, Automotive Rentals, Inc., a foreign corporation, and Shannon Lotito,
Defendants. Circuit Court of Florida, 15th Judicial Circuit, General Jurisdiction Division.
September 11, 2000 No. CL 99-6082 AB. 2000 WL 35743418
2 Court Documents 11
Deposition of: Another Expert, Ph.D.
Expert Deposition Vehicle Negligence Josephine M. CANTWAY, etc., Plaintiff, v. FEDERAL
EXPRESS CORPORATION, etc., et al., Defendants. Circuit Court of Florida, 15th Judicial
Circuit, General Jurisdiction Division. August 31, 2000 No. CL 99-6082 AB. 2000 WL
35743899
1. Appellate Briefs
Petition for Writ of Mandamus
Ex Parte: APAC SOUTHEAST, INC. Re: Sara Ann McGilvary, as Administrator of The Estate
of James McGilvary, deceased, Plaintiff, v. PAC Southeast, Inc., Defendant. Supreme Court
of Alabama. April 24, 2007 No. 1061048. 2007 WL 6707142
1. Expert Testimony/Reports/Affidavits
Video Deposition of: John Doe
Partial Expert Testimony Class Action FARRAR & FARRAR DAIRY, INC, and Farrar & Farrar
Farms, a North Carolina General Partnership, on behalf of itself and all others similarly
situated, Plaintiffs, v. MILLER-ST. NAZIANZ, INC, Defendant. United States District Court,
E.D. North Carolina, Western Division. December 17, 2007 No. 5:06-CV-160-D1. 2007 WL
7003999
FULL TEXT
2. Court-Filed CVs
John H. Doe, Ph.D.
Expert Resume United States District Court, E.D. North Carolina. March 26, 2007 2007 WL
6948699
2 Court Documents 12
STAUB V. HOEGANAES CORP.
(N.J. SUPER. CT. 2006)
1. Jury Verdicts/Settlements
Glen & Marilyn Staub on behalf of themselves and others similarly situated v. Hoeganaes
Corp.
DAMAGES - PROPERTY Superior Court of New Jersey, Law Division, Burlington County
June 22, 2006 No. BUR-L-2080-03 2006 WL 2882888
1. Trial Motions/Memoranda
Defendant Howmedica Osteonics Corporations Renewed Motion for Summary Judgment
or, in the Alternative, Summary Adjudication
Marylou PRIMIANO and Charles Primiano, Plaintiffs, v. STRYKER CORPORATION,
Howmedica Osteonics Corp. and Robert J. Tait, M.D., Defendants. United States District
Court, D. Nevada. October 11, 2005 Case No. CV-03-0373-JCM (PAL). 2005 WL 3780378
1. Trial Motions/Memoranda
Harrison Countys Motion for Summary Judgment
Judson Clark LOWERY, Jordan Hiatt Lowery, and Charlie Jade Lowery, Minors, as Wrongful
Death Beneficiaries of Robin Rebecca Clark Irby, Deceased, By and Through John Mark Irby,
Administrator of the Estate of Robin Rebecca Clark Irby, and John Mark Irby Individually
Plaintiff, v. Harrison COUNTY, Mississippi and Waste Management of Mississippi, Inc.
Defendants. Circuit Court of Mississippi, First Judicial District. March 03, 2003 Cause No.
A2401-2001-00081. 2003 WL 25257737
1. Trial Motions/Memoranda
Defendant R.J. Reynolds Tobacco Companys Motion for Judgment as a Matter of Law
Elaine CONLEY, Dorothy White, and Weldon White, Plaintiffs, v. R.J. REYNOLDS
TOBACCO COMPANY, et al., Defendants. United States District Court, N.D. California.,
Oakland Division December 18, 2002 No. C-00-01740 SBA. 2002 WL 33769933
2 Court Documents 13
Defendants Motion in Limine to Limit Dr. Feingolds Testimony to Pulmonology and
Internal Medicine
Elaine CONLEY, Dorothy White, and Weldon White, Plaintiffs, v. R.J. REYNOLDS
TOBACCO COMPANY, et al., Defendants. United States District Court, N.D. California.,
Oakland Division November 08, 2002 Case No. C-00-01740 SBA. 2002 WL 33760384
Defendants Motion in Limine to Prohibit Plaintiffs Expert Witnesses from Testifying to the
Meaning of Defendants Documents or to Defendants Intent in Preparing Documents
Elaine CONLEY, Dorothy White, and Weldon White, Plaintiffs, v. R.J. REYNOLDS
TOBACCO COMPANY, et al., Defendants. United States District Court, N.D. California.,
Oakland Division November 08, 2002 No. C-00-01740 SBA. 2002 WL 33760388
3. Dockets
CONLEY, ET AL v. R J REYNOLDS TOBACCO, ET AL
May 16, 2000 CA U.S. DIST. CT., NORTH 4:00-cv-01740 TORTS/NEGLIGENCE, PRODUCT
LIABILITY, PERSONAL INJURY
The following docket entries refer to documents that are not available on Westlaw, but
Westlaw CourtExpress can retrieve these documents upon request. Call 240-751-9013
for pricing and to initiate the process.
Entry 412 Dated 12/19/2002 Refers To Trial Minutes: Plaintiffs Witness: Dr. Doe; Defendants
Witness: Professor Loan Hoth ( C/R Raynee Mercado) ( Hearing Date: 12/19/02) [4:00-Cv-
01740] (Jlm, Court Staff) (Entered: 12/26/2002)
Entry 394 Dated 12/11/2002 Refers To Trial Minutes: Plaintiffs Motion For Reconsideration
Re: Brief Of Dr. John Doe Is Denied With Prejudice ( C/R Raynee Mercado) ( Hearing Date: 12/
11/02) [4:00-Cv-01740] (Jlm, Court Staff) Modified On 12/13/2002 (Entered: 12/13/2002)
Entry 388 Dated 12/05/2002 Refers To Brief In Respect To Qualifications Of Dr. John Doe Re:
Testimony As Expert Witness By Plaintiffs [4:00-Cv-01740] (Jlm, Court Staff) (Entered: 12/10/
2002)
Entry 383 Dated 12/02/2002 Refers To Order By Judge Saundra B. Armstrong Granting
Motion In Limine To Preclude Dr. Doe From Testifying As An Expert Witness [280-1], Entry is
redacted for brevity. All mentions of expert are included.
2 Court Documents 14
Entry 331 Dated 11/18/2002 Refers To Opposition By Plaintiff To Motion In Limine To Preclude
Dr. Doe From Testifying As An Expert Witness [280-1] [4:00-Cv-01740] (Kc, Court Staff)
(Entered: 11/21/2002)
Entry 300 Dated 11/12/2002 Refers To Proof Of Service By Defendants Of, Motion In Limine To
Preclude Dr. Doe From Testifying As An Expert Witness [280-1]. Entry is redacted for brevity.
All mentions of expert are included.
Entry 291 Dated 11/12/2002 Refers To Response By Plaintiffs Re Motion In Limine To Preclude
Dr. Doe. Entry is redacted for brevity. All mentions of expert are included.
Entry 288 Dated 11/08/2002 Refers To Proof Of Service By Defendants Of, Declaration [281-1],
Motion In Limine To Preclude Dr. Doe From Testifying As An Expert Witness [280-1], Entry is
redacted for brevity. All mentions of expert are included.
Entry 281 Dated 11/08/2002 Refers To Declaration By Patrick J. Gregory On Behalf Of
Defendants In Support Of Motion In Limine To Preclude Dr. Doe From Testifying As An Expert
Witness [280-1] [4:00-Cv-01740] (Kc, Court Staff) (Entered: 11/12/2002)
Entry 280 Dated 11/08/2002 Refers To Motion Before Judge Saundra B. Armstrong By
Defendants In Limine To Preclude Dr. Doe From Testifying As An Expert Witness [4:00-Cv-
01740] (Kc, Court Staff) (Entered: 11/12/2002)
1. Expert Testimony/Reports/Affidavits
Deposition of A. Nother Expert Jr., Ph.D.
Expert Deposition Products Liability Donald A. LABELLE, as Personal Representative of the
Estate of Christine Lezzo Labelle, Deceased, Plaintiff, v. PHILIP MORRIS, INCORPORATED,
et al., Defendants. United States District Court, D. South Carolina, Charleston Division. July
25, 2000 No. 2:98-3235-23. 2000 WL 35720269
2 Court Documents 15
3. Dockets
LABELLE V. BROWN & WILLIAMSON, ET AL
November 04, 1998 SC U.S. DIST. CT. 2:98-CV-03235 TORTS/NEGLIGENCE, PRODUCT
LIABILITY, PERSONAL INJURY
Entry 247 Dated 06/29/2001 Refers To Motion By Defendant Phillip Morris Inc In Limine
To Exclude Or Limit Testimony Of John Doe Phd (Cmck) (Entered: 07/02/2001) This
document is not available on Westlaw, but Westlaw CourtExpress can retrieve these
documents upon request. Call 240-751-9013 for pricing and to initiate the process.
NON-EXPERT LITIGATION
Cases in which Does patents Cases in which Doe or Does Cases in which Doe is cited
are the subject of litigation firm is a party
EX PARTE JOHN DOE, ET AL. PROFESSIONAL V. DOE IN RE: PLIBRICO CO.
EX PARTE DEAN L. SICKING AND DOE V. UNITED STATES
JOHN DOE
PROFESSIONAL V. DOE
(FLA. CIR. CT. 2010)
1. Dockets
PROFESSIONAL v. JOHN DOE
December 28, 2010 FL BREVARD 18TH JUDICIAL CIR. 05-2010-SC-065566-XXXX-XX
SMALL CLAIMS
1. Administrative Decisions
EX PARTE DEAN L. SICKING, JOHN DOUGLASS REID, RONALD KEITH FALLER, JOHN
DOE, BARRY THOMAS ROSSON AND JOHN ROBERT ROHDE
Bd.Pat.App. & Interf. January 01, 2009 2002 WL 31112843
EX PARTE DEAN L. SICKING, JOHN D. REID, RONALD K. FALLER, JOHN DOE, BARRY T.
ROSSON AND JOHN R. ROHDE
Bd.Pat.App. & Interf. January 01, 2009 2001 WL 1057283
2 Court Documents 16
EX PARTE DEAN L. SICKING AND JOHN DOE
(BD. PAT. APP. & INTERF. 2009)
1. Administrative Decisions
EX PARTE DEAN L. SICKING AND JOHN DOE
Bd.Pat.App. & Interf. January 01, 2009 1998 WL 1736094
1. Trial Motions/Memoranda
Defendants Answer to Complaint and Affirmative Defenses
John Doe and Susan Doe, a married couple, Plaintiffs, v. UNITED STATES OF AMERICA,
through the United States Department of Agriculture, Defendant, United States District
Court, N.D. Florida, Tallahassee Division. November 13, 2007 No. 4:07cv391-RH/WCS.
2007 WL 4671290
1. Expert Testimony/Reports/Affidavits
Expert Report of Expert A. Name
Expert Report and Affidavit Intellectual Property KOTHMAN ENTERPRISES, INC.,
successor by merger to Kothman & Kothman, Inc., v. TRINITY INDUSTRIES, INC.,
Defendant. United States District Court, S.D. Texas, Houston Division. January 16, 2004
No. H-01-2668. 2004 WL 3779924
2. Trial Motions/Memoranda
Plaintiff Kothmann Enterprises, Inc.s Response in Opposition to Defendant Trinity
Industries, Inc.s Expedited Motion to Compel Plaintiff to Supplement Discovery and for
Leave to Take Additional Discovery Regarding Plaintiffs New Patent Application
KOTHMANN ENTERPRISES, INC., successor by merger to Kothmann & Kothmann, Inc.,
Plaintiff, v. TRINITY INDUSTRIES, INC., Defendant. United States District Court, S.D. Texas,
Houston Division. February 05, 2005 No. H-01-2668. 2005 WL 6156135
2 Court Documents 17
Plaintiffs First Amended Complaint
KOTHMANN ENTERPRISES, INC., successor by merger to Kothmann & Kothmann, Inc.,
Plaintiff, v. TRINITY INDUSTRIES, INC., Defendant. United States District Court, S.D. Texas,
Houston Division. January 14, 2003 Civil Action No. H-01-2668. 2003 WL 24337745
1. Trial Motions/Memoranda
Second Amended Disclosure Statement Regarding Second Amended Joint Plan of
Reorganization Dated August 1, 2005
In re: PLIBRICO COMPANY Plibrico Sales & Service, Inc., Debtors. United States
Bankruptcy Court, N.D. Illinois., Eastern Division August 04, 2005 Nos. 02 B 09952, 02 B
09957. 2005 WL 6488661
2 Court Documents 18
3 Expert Challenge Report
This section summarizes instances in which the experts testimony, credibility, qualifications or methods were formally
challenged or otherwise called into question.
WHITE V. FLORIDA MARINE 2012 Admitted (Order at docket entry 106; motion at
TRANSPORTATION, INC. 2012 WL 1412218 and entry 68)
GRILL V. PHILIP MORRIS USA INC. 2010 Admitted in part/Excluded in part (Order at
docket entry 228; motion at 2010 WL 4949291
and entry 152)
BOUCHER, ET AL. V. ZIMMER, INC. 2010 Undetermined (Motion at 2010 WL 1480265)
Appearance Summary
Appearances 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Dockets by year initiated 0 0 1 0 1 0 0 0 0 0 2
Judicial opinions 0 0 0 0 1 1 1 1 0 0 4
Jury Verdicts 0 0 1 0 0 0 1 0 0 0 2
Roles
Role 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Defendant 0 0 0 0 0 0 1 0 0 0 2
Plaintiff 0 0 2 0 2 1 1 1 0 0 7
Document Type 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Appellate Brief 0 0 0 0 3 0 0 0 0 0 3
Expert Testimony 4 5 1 0 4 1 7 2 0 0 24
Trial Filing 0 0 0 1 0 0 0 0 0 0 1
Name 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Altemose, Mark K. 0 0 1 0 0 0 0 0 0 0 1
Brugger, Gregg W. 0 0 0 0 0 0 1 0 0 0 1
Cowart, John P. 0 0 1 0 0 1 0 0 0 0 2
Harrison, Matthew P. 0 0 0 0 0 0 1 0 0 0 1
Mansell, Jeffrey V. 0 0 0 0 1 0 0 0 0 0 1
McCluskey, Kevin G. 0 0 0 0 0 0 1 0 0 0 1
Mohler, Travis T. 0 0 0 0 1 0 0 0 0 0 1
Romano, John F. 0 0 0 0 1 0 0 0 0 0 1
Romano, Todd Aaron 0 0 0 0 1 0 0 0 0 0 1
Shaw, Ethan L. 0 0 1 0 0 1 1 0 0 0 3
Parties
Name 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
* ALVA NELSON AS PARENTS 0 0 0 0 1 0 0 0 0 0 1
AND GUARDIANS OF A N A
* KIMBERLY LANDIS AS 0 0 0 0 1 0 0 0 0 0 1
PARENTS AND GUARDIANS
OF A N A
* LEVERT LYONS 0 0 1 0 0 1 1 0 0 0 3
* None 0 0 1 0 0 0 0 0 0 0 1
Federal Court 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Fourth Circuit (Appellate & 0 0 0 0 2 0 0 1 0 0 3
District)
State Courts
State Court 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
California 0 0 0 0 0 0 1 0 0 0 1
Judges
Name 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Acosta, Hon. John V. 0 0 1 0 0 1 1 0 0 0 3
Type 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
Contracts 0 0 0 0 0 0 1 0 0 0 1
Intellectual Property: 0 0 0 0 0 1 0 0 0 0 1
Generally
Products Liability 0 0 1 0 0 0 1 0 0 0 2
Torts/Negligence 0 0 0 0 1 0 0 0 0 0 1
Awards
Award Amount 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 Total
$0 0 0 0 0 0 0 0 0 0 0 0
$1 - 49,999 0 0 0 0 0 0 0 0 0 0 0
$50,000 - 99,999 0 0 0 0 0 0 0 0 0 0 0
$100,000 - 199,999 0 0 0 0 0 0 0 0 0 0 0
$200,000 - 499,999 0 0 0 0 0 0 0 0 0 0 0
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$1,000,000,000- 0 0 0 0 0 0 0 0 0 0 0
$999,999,999,999
New Jersey: Celebrated Polymers Expert Morton Denn to Speak at Inaugural Marino Xanthos
Memorial Lecture
US Official News (Pakistan) March 10, 2015
-: Opportunities for Additives in the European and North American Engineering Plastics Industry
2015
M2 PressWIRE February 19, 2015
Plenary Speakers at SPE ANTEC Will Focus on Nanotechnology, Space Flight, and Additive ...
Association, Organization and Government News (Blog) February 09, 2015
Researchers Submit Patent Application, "System and Methods for Identifying Possible
Associations and Monitoring Impacts of Actual Associations...
Politics & Government Week Jul 17, 2014
Coming out ahead at ANTEC[R] 2014: winning ideas flowed freely at the Las Vegas event.
Plastics Engineering Jun 01, 2014
Researchers Submit Patent Application, Self-Cooling Compositions, Systems and Methods, for
ApprovalHeat Wave Technologies, LLC
Food Weekly News May 2, 2013
Australia: Alan Expert, John Doe, Scott Scientist, James Researcher, Richard Engineer, Christian A.
Inventor Receive Patent for...
Gov Australia Live April 11, 2012
US Patent Issued to BEC Companies on April 26 for Automated Material Handling System with
Load Transfer Vehicles (Florida Inventors)
US Federal News April 28, 2011
Tuesday, May 3.
Plastics Engineering March 1, 2011
Patent No. 7,753,637 Issued on July 13 for Port Storage, Distribution System (Florida Inventors)
US Federal News July 14, 2010
IBC Subsidiary Renewable Chemicals Corporation is Highlighted in Chemical and Plastics Industry
Publication
Business Wire August 11, 2008
528.Ladders
American Law of Products Liability 3d Product Citator Am. L. Prod. Liab. 3d, Prod. Citator
528Other Products
1:127.Leading Technologies
Lawyers Desk Reference 10th Edition 1 Lawyers Desk Reference 9th 1:127 Expert Witnesses Harry
M. Philo, Harry M. Philo, Jr.
6 Expert Publications 26
1:128.Alphabetical listing of experts
Lawyers Desk Reference 10th Edition 1 Lawyers Desk Reference 9th 1:128 Expert Witnesses Harry
M. Philo, Harry M. Philo, Jr.
6 Expert Publications 27
NCHRP Report 350 Evaluation of the Nebraska Thrie-Beam Transition
MwRSF Research Report No. TRP 03-70-98, May 1998
John H. Doe
ntl.bts.gov/lib/20000/20700/20776/PB98148729.pdf
ARTICLES/PAPERS (ABSTRACTS)
Effects of O-3 and NO2 on the Natural Weathering of Plasticized Poly(vinyl chloride)
J. Vinyl Addit. Technol., vol. 17: 105-111, 2011
John H. Doe, et al.
tinyurl.com/ng7key5
Forces Associated With Pneumatic Power Screwdriver Operation: Statics And Dynamics
Ergonomics, vol. 46(12): 1161-1177, Oct. 10, 2003
John H. Doe, et al.
ncbi.nlm.nih.gov/pubmed/12933078
NCHRP Report 350 Compliance Testing of the Beam-Eating Steel Terminal System
Journal of the Transportation Research Board, vol. 1647: 130-138, 1998
John H. Doe
tinyurl.com/crghs7d
A Dynamic Mechanical Model For Hand Force In Right Angle Nutrunner Operation
Human Factors, vol. 39(3): 497-506, Sept. 1997
Samantha K. Doe, Robert G. Doe, and John H. Doe
ncbi.nlm.nih.gov/pubmed/9394642
Full-Scale 4,500 Lb Vehicle Crash Test on the Permanent Precast Concrete Median Barrier
MwRSF Research Report No. TRP-03-24-90, Mar. 1991
John H. Doe, et al.
trid.trb.org/view.aspx?id=412346
6 Expert Publications 28
CONFERENCES/PRESENTATIONS
Simulated Helical Gear Pump Analysis Using a New CFD Approach
ASME Fluids Engineering Division Summer Conference, vol. 1(A-C): 445-455, Aug. 2, 2009
Asa S. Doe, James J. Doe, and John H. Doe
proceedings.asmedigitalcollection.asme.org/proceeding.aspx?articleid=1636636
Design, simulation, and validation of a bond graph model and controller to switch between pump
and motor operation using four on/off valves with a hydraulic axial piston pump/motor
American Control Conference, vol. 5: 360509, 2000
John H. Doe and David Doe
ieeexplore.ieee.org/stamp/stamp.jsp?arnumber=879242
DISSERTATION (ABSTRACT)
Development and Simulation of Energy-Absorbing Guardrail Terminal
Dissertations Publishing, DAI-B 58/03: 1425, Sept. 1997
John H. Doe
tinyurl.com/cst78kg
6 Expert Publications 29
7 Internet Research
This section contains citations to information gathered from online sources re the expert. It may include online profiles; videos;
blogs posts or comments; posts in online forum; conference or workshop agendas and personal information.
VIDEO/AUDIO
Why a Diagnostic Workshop with SpecialChem Commercial Acceleration?VideoJul. 4, 2014
tinyurl.com/qge7ssv
INTERNET PROFILES
University of Wisconsin-Madison profiles of John H. Doe
tinyurl.com/o8gupa5
discoveryportal.org/faculty.aspx?id=1949
7 Internet Research 30
CONFERENCES/PRESENTATIONS
Polymer Composites with Hollow Glass Microspheres
Feb. 26, 2014: tinyurl.com/plpvclf
Apr. 2, 2012: tinyurl.com/oycamvz
Processing Behavior, Morphology and Benefits of Using Low-Density Hollow Glass Microspheres
in Polymer Wood CompositesMay 17, 2011
issuu.com/fpsusa/docs/biofiber_2011_program_vfinal/6
BLOGS/FORUMS
Nine Ways to Break Your Systems Code Using VolatileAug. 15, 2010
blog.softwaresafety.net/2010/08/nine-ways-to-break-your-systems-code.html
New Space Engines May Trade Fuel for PhotonsFeb. 22, 2010
popularmechanics.com/space/deep-space/a6407/4346578/
Oxidative Degradation of High Density Polyethylene Pipes from Exposure to Drinking Water
DisinfectantsPowerPoint Presentation2010
tinyurl.com/jwqqef8
Efficient Centrifuge Enriches Nuclear Power Future: How it WorksDec. 17, 2009
popularmechanics.com/science/energy/a2757/4257042/
7 Internet Research 31
How to Use a Cyclotron Particle Accelerator to Fight CancerOct. 29, 2009
popularmechanics.com/science/health/a4990/4335465/
Cardan Gear Mechanism Versus Slider-Crank Mechanism in Pumps and EnginesFeb. 2008
tinyurl.com/ldvnehv
Illinois Secretary of State Information regarding Doe Enterprises, LLC (searchable site)
ilsos.gov/corporatellc/
7 Internet Research 32
8 Expert Patents
This section includes any publications by the subject in carefully selected Westlaw databases and news wires. The information
contained in this section is pulled from newspapers, magazines, journals, newsletters, government press releases, transcripts of
television and radio shows and congressional testimony. The section also contains results from an online search of theses,
books, abstracts and articles.
ISSUE DATE
04/26/2011
US PAT 7909558 OVERHEAD VEHICLE FILING DATE DOE, JOHN H. 2011 WL 665074
STORAGE SYSTEM 05/02/2007 BENEDICT CHARLES E.
US PAT APP YATES, CHRISTIAN A.
20080075566 PUBLICATION BLADEN, SCOTT K.
DATE LACKINGER, RICHARD E.
03/27/2008 DOBBS, JAMES R.
ISSUE DATE
03/22/2011
US PAT APP PORT STORAGE AND FILING DATE DOE, JOHN H. 2010 WL 6535448
20110027059 DISTRIBUTION SYSTEM FOR 07/09/2010 BENEDICT CHARLES E.
INTERNATIONAL SHIPPING YATES, CHRISTIAN A
CONTAINERS PUBLICATION BLADEN, SCOTT K.
DATE 02/03/2011 LACKINGER, RICHARD E.
DOBBS, JAMES RE
US PAT 6416041 GUARDRAIL SYSTEM FILING DATE SICKING, DEAN LEO 1997 WL 34494471 2010 WL 3408299
12/26/1996 REID, JOHN DOUGLAS
FALLER, RONALD KEITH
ISSUE DATE DOE, JOHN H.
07/09/2002 ROSSON, BARRY THOMAS
ROHDE, JOHN ROBERT
8 Expert Patents 33
EUROPEAN PATENTS INVENTED BY/ASSIGNED TO JOHN H. DOE
EP PAT APP 2081858 WAREHOUSE STORAGE FILING DATE DOE, JOHN, BENEDICT, CHARLES
A1 SYSTEM 05/03/2007 BENEDICT, E.; PFEIFER, BRIAN G.;
CHARLES E. YATES, CHRISTIAN A,;
PUBLICATION DATE YATES, CHRISTIAN BLADEN, SCOTT K.;
07/29/2009 BLADEN, SCOTT K. LACKINGER, RICHARD
LACKINGER, E.; AND DOBBS,
RICHARD E. JAMES R.
DOBBS, JAMES R.
EP PAT APP 2081818 OVERHEAD BOAT FILING DATE DOE, JOHN, BENEDICT, CHARLES
A2 STORAGE SYSTEM 05/03/2007 BENEDICT, E.; PFEIFER, BRIAN G.;
CHARLES E. YATES, CHRISTIAN A,;
PUBLICATION DATE YATES, CHRISTIAN BLADEN, SCOTT K.;
07/29/2009 BLADEN, SCOTT K. LACKINGER, RICHARD
LACKINGER, E.; AND DOBBS,
RICHARD E. JAMES R.
DOBBS, JAMES R.
EP PAT APP 2076641 OVERHEAD VEHICLE FILING DATE DOE, JOHN, BENEDICT, CHARLES
A2 STORAGE SYSTEM 05/03/2007 BENEDICT, E.; PFEIFER, BRIAN G.;
CHARLES E. YATES, CHRISTIAN A,;
PUBLICATION DATE YATES, CHRISTIAN BLADEN, SCOTT K.;
07/08/2009 BLADEN, SCOTT K. LACKINGER, RICHARD
LACKINGER, E.; AND DOBBS,
RICHARD E. JAMES R
DOBBS, JAMES R.
EP PAT APP GUARDRAIL SYSTEM FILING DATE DOE, JOHN KOTHMANN &
790765 A1 11/06/1995 SICKING, DEAN L. KOTHMANN, INC
PUBLICATION DATE
08/27/1997
8 Expert Patents 34
WIPO PATENTS INVENTED BY/ASSIGNED TO JOHN H. DOE
8 Expert Patents 35
Appendix One
(BACK TO CASE)
United States District Court, E.D. Louisiana.
Tammie WHITE,
v.
FLORIDA MARINE TRANSPORTERS.
Representing: Defendant
I am a senior toxicologist and director of toxicology at the Center for Toxicology and
Environmental Health, LLC (CTEH) specializing in risk assessment, exposure assessment, toxicity
evaluations, the evaluation of experimental design and methodologies, and assessing causal
relationships between chemical exposure and disease. My educational background includes a B.S.
in biochemistry with an emphasis in toxicology from Murray State University in 1993, and a Ph.D. in
toxicology from The University of Georgia in 2000. My current duties at CTEH include serving as
a consulting toxicologist; leading responses to, and providing toxicological support for hazardous
materials incidents; and providing toxicological support to care providers and workers with
potential chemical exposures. I have gained extensive knowledge and experience in the
mechanisms and toxicities of a wide range of compounds including chlorinated hydrocarbons,
volatile organic hydrocarbon solvents (VOCs) including trichloroethylene, polycyclic aromatic
hydrocarbons (PAHs), pesticides/herbicides, irritant gases, and heavy metals.
Appendix One 36
It is my understanding that plaintiff, Mr. Tammie White, alleges exposure to harmful
concentrations of H H2S 2S while onboard the vessel BILL SEYMOUR, a Florida Marine
Transportation boat that had two barges in tow that were being loaded with vacuum gas oil (VGO)
in the early morning hours of January 24, 2011. He had initial complaints of dizziness, nausea,
vomiting, ringing in ears, nasal congestion, hearing loss, loss of balance, loss of consciousness,
and headache, which resolved in the days to weeks after the alleged exposure. The only long-term
health effects that he claims are hearing loss in his right ear, and loss of balance.
A list of the case-related documents I have relied upon is provided in Appendix B. In addition, I
have relied on scientific literature that is cited at the end of this report.
On January 23, 2011 at approximately 17:00, the BILL SEYMOUR, a Florida Marine Transporters
(FMT) towboat with two barges in tow (barges M401 and 403), was tied to dock number two at the
ExxonMobil Chalmette refinery located in Chalmette, Louisiana. The barges were facing upstream
(west), and the BILL SEYMOUR was moored to the downstream (east) end of the barges. Both
barges were to be loaded with vacuum gas oil (VGO) from the refinery. The VGO loading
commenced at 20:50 on January 23, and was completed on January 24 at 03:45, a period of six
hours and five minutes. The crew of the BILL SEYMOUR consisted of the Captain, Charles German;
the Pilot, Mr. White; Deckhand, Ryan Mills; and two tankermen, John Starcher and Rodger Enzor.
Mr. White and Captain German alternated 6-hour shifts, with the Captain being on duty from
06:00-12:00 and 18:00-24:00 and Mr. White being on duty from 00:00-06:00 and 12:00-18:00.
The loading operation is staffed by one tankermen on the dock who is assigned to bottle watch.
This individuals role is to monitor the fresh air canisters and distribute if needed and to serve in a
safety capacity in case significant H2S exposures occur. Bottle watch responsibilities were shared
by Mr. Enzor and Mr. Starcher. Mr. Starcher was on bottle watch on January 23 from 18:00-24:00,
and was relieved by Mr. Enzor from 00:00-06:00 on January 24. The loading is also staffed by two
tankermen present on the barges that oversee the loading operations. Their duties during the
loading operations include walking around the barge monitoring tanks for leaks, spills, water
going into the wing tanks, checking for H2S and safety checks. There were two tankermen present
during the loading operation, Mr. Roy Huval from FMT and Mr. Odley Banks from Accutrans. They
were both present for the duration of the loading operations. Additionally, Mr. Toni Ghirardi, a
surveyor from Saybolt was present on the barges during the loading process to sample the
product in the barges during the loading process. Both onshore tankermen and onboard
tankermen and the Surveyor wear H2S badge monitors, and have been trained in H2S awareness.
Captain German was on duty when the BILL SEYMOUR arrived at the dock and when the loading
was initiated at 20:50 on the night of January 23rd. He reports that he didnt smell any odors or
have any reports of H2S detections from the tankermen or bottle watch staff. Capt. German was
relieved by Mr. White around midnight on the 23rd. Mr. White and Capt. German had a shift
change meeting/job briefing at midnight; during this meeting, Mr. White did not talk about
smelling any odors or about feeling ill. When Captain German got off his shift, he went to his
bunkroom. He did not smell any odors and did not report any symptoms of illness that night.
(END OF EXCERPT)
Appendix One 37
Appendix Two
(BACK TO CASE)
Technical Report Expert Opinion on Cause of Failure during Hoisting of Elliptical Tank of John
Doe, Ph.D.
Representing: Plaintiff
Dr. John Doe is a Professor of Mechanical Engineering and Mechanics at Lehigh University. He
joined the faculty of Lehigh University in 1995 after working in industrial research and
development for 13 years. His research interests have focused on the development of
computational tools for the solution of complex manufacturing problems, including welding
simulation, semiconductor packaging, plastic processing, interface fracture, and thermal shock
behavior. Dr. Doe has developed a number of specialized finite element codes for analyzing
fracture behavior, welding simulation, and thermoforming of plastics. He received his Ph.D. and
M.S. degrees in Applied Mechanics from Lehigh University in 1981 and 1978 respectively, and his
B.S.M.E. from the University of Rochester in 1976. The first phase of Dr. Does career was spent at
GEs Corporate Research Center, where he made numerous contributions to modeling, analysis
and development of experimental methodologies involving large deformation characterization of
polymers, blow molding and thermoforming of thermoplastics, glass/metal seals for lighting
applications, and computational fracture mechanics. He has received 13 patents and a number of
prestigious industrial awards. As Professor of Mechanical Engineering at Lehigh University, Dr.
Doe has developed advanced computational methods for failure analysis, and the design of
semiconductor and optoelectronic packages. In 1997 he received an NSF CAREER Award for
research in designing with thermoplastics for structural applications, and in 2005 was elected a
Fellow of ASME (American Society of Mechanical Engineers). From 2002 - 2008 he served as
Chairman of the Department of Mechanical Engineering and Mechanics. In addition to teaching
courses on Strength of Materials, and Advanced Mechanics of Materials, Dr. Doe has given a
number of invited lectures at international symposia on polymer processing and simulation of
Appendix Two 38
welding processes. Dr. Does full CV as attached as an addendum to this document.
The following documents and information were reviewed by Dr. Doe when conducting this
analysis:
14. Investigation Report, Accident with Injuries, by Edward W. Kline, Environmental, Health and
Safety Director, Kovatch Mobile Equipment Corp.
17. Mechanical Testing Reports, Laboratory Testing Inc., Hatfield, PA, 7/15/2008 and 7/28/2008.
19. CD containing photographs taken by Dennis Deegan, Solt v. United Plastics 340/71734.
20. CD containing photographs taken by Dennis Deegan, Dr. Priddy, Matt Burkart, and MKA.
3. Background
Appendix Two 39
On the afternoon of Monday, July 9, 2007, a 3,500-gallon polypropylene elliptical tank fell,
injuring Mr. Wilson Solt. The accident occurred at Kovatch Mobile Equipment Corporation (KME),
in Nesquehoning, PA, shortly after the tank had been hoisted from a flatbed truck. The
polypropylene tank was manufactured by United Plastics Fabricating, Inc. (UPF) and had been
wrapped with a stainless steel covering at L. W. Tank, Inc. (LW), prior to delivery at KME. At the
request of Mr. Gordon Einhorn, of the law firm Thomas, Thomas & Hafer LLP, I conducted an
investigation to determine the cause of failure. In this capacity, I analyzed the loads acting on the
tank components and assisted in developing the appropriate experimental tests needed to
determine the loads required for the tank lifting pegs to fail.
The elliptical tank weighed 2940 lbs and was lifted from the flatbed truck using a double-legged
chain sling (the tanks weight was measured at KME shortly after the accident). Figure 1
schematically depicts the approximate orientation of the tank just before it fell. The tank was
oriented on the flatbed truck with the fill tower end of the tank closest to the rear of the truck. The
weight distribution for this particular tank is such, that the center of gravity is shifted away from
the tanks geometric center, towards the fill tower end of the tank, causing the tank to rotate as
shown in Fig. 1, when hoisted with the chain sling. Because of this rotation, the tank did not clear
the rear of the truck before the hoist had reached its maximum lift height. In an effort to get the
tank to clear the rear of the truck, Mr. Solt, with the help of another KME employee, Mr. Mertz,
lifted the tank a small distance and had the truck driver, Mr. Lebo, drive the truck out from
underneath the tank. Shortly after Mr. Lebo pulled the truck away, the tank fell, injuring Mr. Solt.
From all accounts, less than 1 minute elapsed before the tank fell after the truck had pulled away.
In the investigation conducted by KME shortly after the accident, it was observed that four lag
bolts, which are used to attach the lifting hardware to the tanks four lifting pegs, had pulled out
from the lifting pegs, causing the tank to fall. The lifting pegs are 4.75? long cylinders (2?
diameter) made from polypropylene plastic and are welded to the support structure on the interior
of the tank, i.e., they are embedded into the tank with their top surface slightly protruding from the
tank wall. The lifting pegs are an integral part of the elliptical tank structure and serve as the
attachment points for steel brackets that are bolted onto the lifting pegs using 1/2? diameter steel
lag bolts. In this instance the lag bolts used were 3? long (usually UPF supplies 3.5? lag bolts). The
two steel brackets have large diameter holes for connecting lifting chains to the tank. The usual
method for attaching a chain sling to the steel brackets is to use a hook and shackle arrangement.
UPF supplies a detachable 7/16? shackle that can be used with an appropriately sized hook. The
customer, in this case KME, provides that rest of the lift equipment, i.e., the hoist and sling chain
with hooks. Figure 2 contains a photograph showing the steel bracket and detachable shackle
supplied by UPF, with the actual hook and chain used by KME to lift the tank.
An engineering assessment of what caused the lag bolts to pull out from the polypropylene lifting
pegs, requires an analysis of the forces acting on the lifting attachments, as well as experimental
measurements of the loads (acting at the appropriate angle) needed to pull the bolts out of the
lifting pegs. If the computed loads acting on the tank are close to, or exceed, the measured bolt
pull-out loads, then the cause of the accident can be accurately pinpointed.
(END OF EXCERPT)
Appendix Two 40
Appendix Three
(BACK TO CASE)
2008 WL 5967275 (Fla.Cir.Ct.) (Expert Deposition)
Circuit Court of Florida,
15th Judicial Circuit, General Jurisdiction Division.
Palm Beach County
Representing: Plaintiff
Appearances:
Searcy, Denney, Scarola, Barnhart & Shipley, by David K. Kelley, Esq.
Attorney for the Plaintiff.
Murray, Marin & Herman, by Ana Maria Marin, Esq. & David Herman, Esq.
Attorneys for the Defendants.
INDEX
EXHIBITS
Appendix Three 41
41 ... 3
42 ... 3
43 ... 16
44 ... 22
45 ... 25
46 ... 39
47 ... 125
48 ... 125
49 ... 125
MR. KELLEY: Weve agreed and we have remarked Dr. Dabbahs consultation report of Laura
McGrath that is marked as Exhibit 40. It is now correctly marked as Plaintiffs Exhibit 41, and the
Exhibit 40 is the newspaper photograph of Shannon Lotito identified by Mr. Grimes at his
deposition. That is the correct 40.
MR. KELLEY: The consultation report, I believe, is the date of the collision, which I believe is the
15th, dictated on the 15th and transcribed on the 16th.
(The document referred to was marked for identification as Plaintiffs Exhibit 41, and a subsequent
document was marked as Defendants Exhibit 42.)
Thereupon:
JOHN DOE was called as a witness and having been first duly sworn, was examined and testified
as follows:
DIRECT EXAMINATION
BY MR. HERMAN:
A: John Doe
Q: Mr. Doe, Im going to show you whats been marked as Defendants Exhibit Number 42 and ask
you to turn your attention to Schedule A, which begins after page two of the subpoena,numbered
paragraphs 1 through 10.
Appendix Three 42
A: Yes.
A: (Witness complies).
A: Yes.
A: Yes.
A: Starting with my case file, I have a preliminary case information and progress sheet. I have a
request from our office dated June 21, 1999 to the Searcy, Denny law firm, a request for
information on this new case which just came in.
Q: Rather than identify everything with particularity, at this point I would just ask you to identify
generally parts of your file which are responsive to paragraph one of the subpoena.
MR. KELLEY: David we cant do that. That may take a lot of time. He really hasnt seen that
schedule, the way weve been short noticing these things.
What he has on this table is everything that he has in the case, and maybe the easiest way is just
mark everything. I mean we can take that kind of time --
Q: Okay, lets do it this way. Mr. Doe, will you please read paragraphs 1 through 10 to yourself of
Exhibit Number 42?
A: All right.
A: Yes.
MR. KELLEY: Yes, thees one down here, number 10, any and all records reflecting any prior cases
which -- I feel quite certain theres nothing on this table. Youre literally asking him to produce
everything, the way I read that, in his career.
A: The only other thing that would pertain to item 10 would be the list of deposition and trial
appearances, so in some ways that could correlate with a couple of items in your Schedule A.
A: Yes.
(END OF EXCERPT)
Appendix Three 43
Appendix Four
(BACK TO CASE)
2007 WL 7003999 (E.D.N.C.) (Partial Expert Testimony)
United States District Court, E.D. North Carolina,
Western Division.
FARRAR & FARRAR DAIRY, INC, and Farrar & Farrar Farms, a North Carolina General
Partnership, on behalf of itself and all others similarly situated, Plaintiffs,
v.
MILLER-ST. NAZIANZ, INC, Defendant.
Representing: Plaintiff
Notary Public
Q And why dont you describe for me the process of your failure analysis, the steps that you take --
took to analyze these bags?
A We, excuse me, analyzed first using optical microscopy. We measured the layer thickness, the
composition of the bags; we used infrared spectroscopy to identify the composition of each of the
layers.
Appendix Four 44
First of all, we saw that there was three layers. We separated the layers, analyzed the compo -- the
chemical composition of each layer, measured the thickness of each layer. We performed a
permeability or barrier measurements against oxygen, and noticed there was no barrier. Oxygen
went right through the bags, as if they werent even there. Then on further examination we noticed
actual pinholes in the bag, and thats why it had no barrier to oxygen.
We also noticed under the optical microscope severe abrasion of the inside surface of the bags.
And thats what led to the con -- the expert opinion that it was the abrasion of the shelled corn
that led to the failure.
Q Tell me about the composition of the bags that you examined in connection with that case.
A The outer layer was polyethylene; it was filled with titanium dioxide.
The middle layer was EVA, or ethylene vinyl acetate copolymer. The inside layer was polyethylene
filled with carbon black.
A Yes.
A Yes.
Q Had you ever examined a silage bag before you were retained in the Up North litigation?
A No.
Q And this is gonna be a broad question, but do your best to answer it.
A Uh-huh.
Q Is there any -- in your 30-year career at Dow and then subsequent consulting work, is there a
similar product to a silage bag that youve done any sort of substantive work relative to?
Q Okay. And -- and I -- if youd help me a little bit, is polyethylene film, is it correct that thats all
three layers? Theres polyethylene film in -- is that the entire product; is polyethylene film with
respect to the -- lets just talk about the Up North Ag-Bags?
Q Okay.
A With two of the layers being polyethylene and the middle layer being a copolymer.
Q Okay. What other products have you worked with that a component of which is polyethylene
film?
Appendix Four 45
A Shrink wrap. Thats it.
A Oh, no.
A 2004.
A Yes.
A Up North.
A Yes.
Q The EPM?
A Yes. Yes.
Q You mentioned -- you described your failure analysis for the Up North manufactured bags and
you mentioned infrared something, and I --
A Spectroscopy.
Q Spect?
A It generates a chemical fingerprint. Every material has a unique infrared spectrum which no
other molecule or plastic -- its like human DNA almost. So its used to identify materials. With
fingerprint matching it actually -- a computer sorts through the library of infrared spectra until it
gets a match and then tells you what the material is.
(END OF EXCERPT)
Appendix Four 46
Appendix Five
(BACK TO CASE)
2000 WL 35640000 (S.D.Cal.) (Expert Deposition)
United States District Court, S.D. California,
Charleston Division.
Representing: Plaintiff
Appearances of Counsel:
For Defendants Liggett & Myers, Inc., The Brooke Group Limited, and Liggett Group, Inc.: Sweeny,
Wingate, & Barrow, P.A.
By: Everett A. Kendall, II, Esq.
1515 Lady Street
Appendix Five 47
Columbia, South Carolina 29211
(803) 256-2233.
Also Present: J. Andrew Reynolds, Paralegal Barry Varanese, Videotape Operator.
Location: Hyatt Regency Irvine
17900 Jamboree Road
Irvine, California
Reporter:
Diane B. Hoffman, CSR
Certificate No. 5312
Deposition of John H. Doe, Ph.D., taken before Diane B. Hoffman, Certified Shorthand Reporter for
the State of California, Certificate Number 5312, commencing at 8:59 a.m., Thursday, July 20,
2000, at the Hyatt Regency Irvine, 17900 Jamboree Road, Irvine, California.
INDEX
Defendants:
INFORMATION REQUESTED:
(None)
8:59 A.M.
This is the videotaped deposition of John Doe, Ph.D., beginning at 9:00 oclock a.m. on July 20th,
2000 in the matter of Donald LaBelle versus Philip Morris, Incorporated, et al. Case No. 298-
Appendix Five 48
3235-23, taken at 17900 Jamboree Road, Irvine, California. This deposition is being taken on
behalf of the defendants.
MR. HENK: Pete Henk, Shook, Hardy & Bacon in Houston for Philip Morris.
MS. POWELL: Virginia Powell of Hunton & Williams for Philip Morris.
MR. WEBB: Kevin Webb, Hunton & Williams, for Philip Morris.
MR. OTERO: Brian Otero, also of Hunton & Williams and representing Philip Morris.
John H. DoeJohn Doe, Ph.D., called as a witness by and on behalf of the Defendants, and having
been first duly sworn by the Deposition Officer, was examined and testified as follows:
EXAMINATION
BY MR. OTERO:
Q Dr. Doe, I gather that having testified a number of times, you know the rules. Im going to ask
you questions, and youre supposed to give me answers. If you want to take a break at any time, let
me know, well take a break. Ill be calling a break myself to get some coffee probably in a few
minutes.
I want to ask you first off, have you seen the Notice of your deposition in this case?
A Yes, I have.
MR. OTERO: Okay, and well just mark that for the record as Exhibit 1 if we could.
(The documents referred to were marked by the Deposition Officer as Defendants Exhibits 1 and 2
for identification and are annexed hereto.)
Q BY MR. OTERO: And Ill ask you if whats been marked as Exhibit 1 is in fact the Notice that you
understand to be for your deposition today.
A Yes.
Q Okay, and then Exhibit 2 is plaintiffs identification of experts in this case. Have you seen this
document before?
(END OF EXCERPT)
Appendix Five 49
L-379822