Direct Dial: 973-618-4166 Email: adbromberg@mdwcg.com ... - nycal
Direct Dial: 973-618-4166 Email: adbromberg@mdwcg.com ... - nycal
Direct Dial: 973-618-4166 Email: adbromberg@mdwcg.com ... - nycal
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Special Master Laraine Pacheco<br />
November 2, 2011<br />
Page 2<br />
BELLUCK and FOX<br />
Beers, Gerald (LC): MEDICAL OBJECTION. The medical submission consists solely of a<br />
pathology report from a fine needle aspiration biopsy of the left lung. No Staging is reported.<br />
This does not establish that the plaintiff is in an in-extremis state, i.e. that the plaintiff has a<br />
terminal condition caused by an advanced-stage, asbestos-related lung cancer and has a<br />
prognosis of one year or less.<br />
Discovery: Plaintiff is a Tennessee native and worked primarily in Michigan, Oregon and New<br />
Jersey. Sole NY claim is "afew months in BNY".<br />
Borst, Edward (LC): MEDICAL OBJECTION. The medical submission consists solely of a<br />
pathology report from right upper lobectomy and lymph node dissection. The Staging is<br />
reported as Tia, NO (i.e. no regional lymph node involvement), Mx. This does not establish that<br />
the plaintiff is in an in-extremis state, i.e. that the plaintiff has a terminal condition caused by an<br />
advanced-stage, asbestos-related lung cancer and has a prognosis of one year or less.<br />
Discovery: No interrogatories have been provided. No authorizations have been provided to<br />
RecordTrak.
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