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Case 5:13-cv-00365-FJS-DEP Document 47 Filed 05/13/13 Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF NEW YORK ____________________________________________x CAMILLUS CLEAN AIR COALITION, Robert and Colleen Bartlett, William and Michelle Barrington III, Kim Calverase, Daniel and Veruska Dantuono, David and Juliette Dedo, Timothy and Sally DeLany, Brian and Tracy Dellow, Ron Gryziec and Brenda Carpenter, Douglas and Charlene Hart, Thomas and Kimberly Kshyna, Michael and Alpha Kshyna, Matthew and Tracy Licameli, John and Kathleen Marinelli, William and Stephanie Mathewson, Peter and Jenafer Medina, Bryan Mignone and Elaine Everitt, Brian and Kimberly Murphy, Scott and Jill Musumeci,Jerry and Kristina Parzych, Jonathan and Margaret Patch, Timothy and Sharon Pieper, Frederick and Heather Puchta, Lynore and Mark de la Rosa, Robert and Lori Smith, Joey St. Louis, Robert and Megan Vertucci, and Michael and Lynda Wade, Plaintiffs, -againstHONEYWELL INTERNATIONAL, INC, Defendant. ___________________________________________x PLAINTIFFS’ AMENDED PRE-HEARING DISCLOSURE OF WITNESSES IN SUPPORT OF APPLICATION FOR A PRELIMINARY INJUNCTION Pursuant to the Court’s order of April 19, 2013, Plaintiffs, through their undersigned counsel, provide a list of witnesses that they intend to call to testify at the Hearing scheduled for May 15, 2013: 1. Timothy Minnich Mr. Minnich is expected to testify consistent with his Affidavit filed on April 12, 2013 in support of Plaintiffs’ Application for injunctive relief [Docket 19], and his supplemental affidavits filed on May 1 and May 2, 2013, respectively, in further support of Plaintiffs’ Application [Docket 32 and 34]. It is also anticipated that Mr. Minnick would testify consistent with the Report of Minnich & Scotto, Inc(“M&S”), the M&S

Case No. 5:13-CV-365 (FJS/DEP)

Case 5:13-cv-00365-FJS-DEP Document 47 Filed 05/13/13 Page 2 of 3

Report Addendum, and M&S’s Response, dated May 8, 2013, to DEC Review of M&S’s April 8, 2013 Report . See Exhibits 6, 7 and 36 of Plaintiffs’ Amended Exhibit List. He is further expected to testify with regard to Honeywell’s failure to comply with the terms of the Consent Decree and related documents, including the failure to dispose of the contaminated waste at Waste Bed 13 in Camillus in a “closed system” that would prevent chemical toxins from being released into the air and exposing plaintiffs and other residents to airborne contaminants. 2. Robert Scotto Mr. Scotto, the partner of Timothy Minnich in the environmental consulting firm of Minnich & Scotto, may supplement Mr. Minnich’s testimony regarding the need for stateof the art air monitoring methods, such as EPA-approved TO-16 and other issues set forth in the Minnich & Scotto reports. 3. Dennis M. Stainken, PhD Dr. Stainken is expected to testify as to the toxic nature of the chemical toxins emanating from the Wastebed 13 Facility due to the fact that much of the so-called “dewatering process” is exposed to the open atmosphere, rather than being closed, as was required by the Consent Decree and related documents. Dr. Stainken will further testify as to the basis of his opinion that the manner in which the contaminated waste is being disposed of in Camillus presents a serious health risk to the residents in the vicinity of Wastebed 13. Dr. Stainkin’s Report, dated May 7, 2013, is attached as Exhibit 25, and his CV is attached as Exhibit 26. 4. Lynda Wade


Case 5:13-cv-00365-FJS-DEP Document 47 Filed 05/13/13 Page 3 of 3

Ms. Wade is a plaintiff and a coordinator for the community group, CCAC, the lead plaintiff in this action. It is expected that Ms. Wade would testify consistent with her Affidavit submitted in support of Plaintiffs’ Application [Docket 18]. 5. Frederick Puchta Mr. Puchta is a plaintiff and resident of Camillus, who is expected to testify consistent with his Affidavit filed on April 12, 2013 [Docket 17]. 6. Elaine Everitt Ms. Everitt is a plaintiff and is expected to testify regarding the headaches and respiratory symptoms that she has experienced during the dumping of contaminated waste at Waste Bed 13 near her residence. It is further expected that Ms. Everitt will testify as to her recent medical visits, including a visit to Dr. Michael B. Lax on 04/27/13 at the Occupational Health Clinical Center, Central New York. Dated: New York, New York May 13, 2013 McCALLION & ASSOCIATES LLP

____________/s/__________________ By: Kenneth F. McCallion 100 Park Avenue – 16th floor New York, New York 10017 Attorneys for Plaintiffs


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