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Direct Dial: 973-618-4166 Email: adbromberg@mdwcg.com ... - nycal
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Special Master Laraine Pacheco<br />
November 2, 2011<br />
Page 7<br />
Manigno, Martin (M): No medical objection<br />
Discovery: Lifelong Long Island resident with alleged Long Island exposures.<br />
Perez, Jose (LC): MEDICAL OBJECTION. The medical submission consists solely of<br />
pathology report from a biopsy of left neck lymph node. The pathology report is in<strong>com</strong>plete as it<br />
indicates that "a supplementary report for immunotains to follow." No Stage is given. The<br />
supplementary report is not provided. Accordingly, the malignancy is, as yet, not designated as a<br />
lung primary and the submitted pathology report, itself, does not establish that the plaintiff is in<br />
an in-extremis state, i.e. that the plaintiff has a terminal condition caused by an advanced-stage,<br />
asbestos-related lung cancer and has a prognosis of one year or less.<br />
Spina, Robert (M): No medical objection.<br />
Discovery: Florida resident since 1962, alleges Florida exposure from 1964 to present and USN<br />
1952-1956.<br />
Wilson, Carmen (M): No medical objection.<br />
Discovery: Plaintiffs responses to requests for document production are insufficient. Plaintiff<br />
has failed to respond as to the existence of documents or efforts to locate documents. In<strong>com</strong>plete<br />
authorizations provided to Record Trak.