Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

..1 ` :1; I Case 3:03-cv-00990-AWT Document 23-3 I Filed 06/15/2004 _ Page 1 of 2
i_ r l. \
UNITED STATES DISTRICT COURT
. DISTRICT OF CONNECTICUT
ALEXANDER GRAHAM and : CIVIL ACTION NO.
y Joss cuavns ;
: 303 CV990(AWT)
Plaintiffs :
vs. . i
=
FIRELINE, INC. : JANUARY 29, 2004
Defendant
DISCLOSURE OF EXPERT
Pursuant-to Rule 26(a)(2) of the F .R.C.P., the Plaintiffs, ALEXANDER GRAHAM and
JOSE CUEVAS, hereby disclose the following as anexpert witness with respect to` the above-
_ entitled matter, and upon whom it intends to rely for testimony at the time of trial by supplying
the following information:
Name of Expert: Raymond J. Erikson, M.Sc. of Robson Lapina, 21 Wilbraham Street,
Suite 2A, Building #1, Palmer, MA 01069.
Subject Matter: Mr. Erikson is expected to testify as to the nature and cause of the June
3, 2000 incident at casting station #21, of the Ansonia Copper & Brass plant in Ansonia,
Connecticut. He will testify as to the cause ofthe failure ofthe ceramic pouring cup, which
resulted in a billet leak which thereafter caused an explosion of steam and molten metal which - g
ultimately injured the Plaintiffs.
Substance ofthe Facts and Qpinions: Mr. Erikson is expected to testify as to his opinion
based upon his review of relevant materials, that the ceramic pouring cup was made of low-
density clay-based refractory ceramic; that thermal stresses can become sufficiently hight so as to
fracture the cup; that loss ofthe bottom ofthe cup during the pouring process can lead to a ` l
disruption ofthe metal lieezing process, and changes in the billet temperature distribution; that P
such changes in billet temperature distribution can lead to tearing or leaking of molten metal from
the billet; and that the material hom which the pouring cup was made is not suitable, in its
present form, for applications such as a pouring cup.
Grounds for Qpinion: Mr. Erikson is expected to testify as to his opinion based upon his
review of statements given by the Plaintiffs, excerpts from an OSHA report related to the subject
incident, photographs and sketches of the casting furnace set—up and layout, classifications P
furnished by the American Society for Testing and Materials, an exemplarlpouring cup which
failed (in much the same way as the subject cup)` on May 7, 2003, and online data.
"" I

A __ · l Case 3:03-cv—00990-AWT Document 23-3 Filed 06/j 5/2004 Page 2 of 2
_ THE PLAINTIFF
/ /‘/ .
By _; / “'
Homagx. rgulto
Fed. Bar No. ct 12058
Mongillo, Insler & Virgulto, P.C.
26 Elm Street
. New Haven, CT 06510 _
(203) 787-5805
(203) 777-9020 [Fax]
CERTIFICATION: I hereby certify that a copy of the foregoing was mailed, postage prepaid,
` to Charles F . Gfeller, Esq., Edwards & A11gel1,.LLP, 90 State House Square, Hartford, CT 06103
on January 29, 2004.
7 n Thomas A. Virgulto

l