On December 16, 2019 a
Party Notice
was filed
involving a dispute between
Rogers, Hilda,
Rogers, Joe Carl,
and
Acousti Engineering Company Of Florida,
Certainteed Corporation,
Honeywell International, Inc.,
J-M Manufacturing Company, Inc.,
Kaiser Gypsum Company, Inc.,
Mckesson Corporation,
Pfizer, Inc.,
Premix-Marbletite Manufacturing Co,
Supro Corporation,
Union Carbide Corporation,
Vanderbilt Minerals, Llc,
W.W. Gay Mechanical Construction Co.,
for Products Liability/Asbestos
in the District Court of Broward County.
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Filing # 117447300 E-Filed 12/01/2020 02:02:16 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
JOE CARL ROGERS and HILDA ROGERS, his
wife,
Plaintiffs,
v.
Case No.: CACE-19-025692
ACOUSTIC ENGINEERING COMPANY OF
FLORIDA, et al.,
Defendants.
DEFENDANT, VANDERBILT MINERALS, LLC’S NOTICE OF FILING ITS
VERIFICATION PAGE TO ITS ANSWERS TO PLAINTIFF’S FIRST
INTERROGATORIES AND RESPONSES TO PLAINTIFF’S REQUESTS FOR
PRODUCTION OF DOCUMENTS TO VANDERBILT MINERALS, LLC
Defendant, Vanderbilt Minerals, LLC, through its undersigned counsel, hereby gives
notice of filing its Verification Page of its Answers to Plaintiff's First Interrogatories and its
Responses to Plaintiff's Requests for Production of Documents directed to Vanderbilt Minerals,
LLC and dated October 30, 2020.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed and
served via the ePortal on this 1‘t day of December, 2020, to all counsel of record.
FOLEY & MANSFIELD, P.L.L.P.
4770 Biscayne Boulevard, Suite 1000
Miami, Florida 33137
Telephone: (305) 438-9899
Facsimile: (305) 438-9819
/s/ Eduardo J. Medina
EDUARDO J. MEDINA
Florida Bar Number 56344
emedina@foleymansfield.com
Counsel for Vanderbilt Minerals, LLC
4670056 v1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/01/2020 02:02:16 PM.****IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JOE CARL ROGERS and HILDA ROGERS, his
wife,
Plaintiffs,
v.
Case No.: CACE-19-025692
ACOUSTIC ENGINEERING COMPANY OF
FLORIDA, et al.,
Defendants.
STATE OF / i} :
COUNTY OF Yolk :
BEFORE ME, a Notary Public, personally appeared Matthew Stewart, who being duly
VERIFICATION
sworn according to law deposes and says that he is authorized on behalf of Vanderbilt Minerals,
LLC to make this affidavit on its behalf, and that the facts contained in the foregoing Answers to
Plaintiffs’ First Interrogatories and Responses to Plaintiffs’ Requests for Production of Documents
to Vanderbilt Minerals, LLC are true and correct to the best of his knowledge and belief.
MATTHEW STEWART
SWORN TO AND SUBSCRIBED
before me this 4074 day Commanueath of PenndyWvania Notary Seal
of Afou , 2020 PrerNescum ne
My commission expires July 25,2024
Commission number 1208368
Member, Pennsylvania Association of Notaries,
Document Filed Date
December 01, 2020
Case Filing Date
December 16, 2019
Category
Products Liability/Asbestos
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Filing # 117447300 E-Filed 12/01/2020 02:02:16 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JOE CARL ROGERS and HILDA ROGERS, his wife, Plaintiffs, v. Case No.: CACE-19-025692 ACOUSTIC ENGINEERING COMPANY OF FLORIDA, et al., Defendants. DEFENDANT, VANDERBILT MINERALS, LLC’S NOTICE OF FILING ITS VERIFICATION PAGE TO ITS ANSWERS TO PLAINTIFF’S FIRST INTERROGATORIES AND RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS TO VANDERBILT MINERALS, LLC Defendant, Vanderbilt Minerals, LLC, through its undersigned counsel, hereby gives notice of filing its Verification Page of its Answers to Plaintiff's First Interrogatories and its Responses to Plaintiff's Requests for Production of Documents directed to Vanderbilt Minerals, LLC and dated October 30, 2020. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was filed and served via the ePortal on this 1‘t day of December, 2020, to all counsel of record. FOLEY & MANSFIELD, P.L.L.P. 4770 Biscayne Boulevard, Suite 1000 Miami, Florida 33137 Telephone: (305) 438-9899 Facsimile: (305) 438-9819 /s/ Eduardo J. Medina EDUARDO J. MEDINA Florida Bar Number 56344 emedina@foleymansfield.com Counsel for Vanderbilt Minerals, LLC 4670056 v1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/01/2020 02:02:16 PM.****IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. JOE CARL ROGERS and HILDA ROGERS, his wife, Plaintiffs, v. Case No.: CACE-19-025692 ACOUSTIC ENGINEERING COMPANY OF FLORIDA, et al., Defendants. STATE OF / i} : COUNTY OF Yolk : BEFORE ME, a Notary Public, personally appeared Matthew Stewart, who being duly VERIFICATION sworn according to law deposes and says that he is authorized on behalf of Vanderbilt Minerals, LLC to make this affidavit on its behalf, and that the facts contained in the foregoing Answers to Plaintiffs’ First Interrogatories and Responses to Plaintiffs’ Requests for Production of Documents to Vanderbilt Minerals, LLC are true and correct to the best of his knowledge and belief. MATTHEW STEWART SWORN TO AND SUBSCRIBED before me this 4074 day Commanueath of PenndyWvania Notary Seal of Afou , 2020 PrerNescum ne My commission expires July 25,2024 Commission number 1208368 Member, Pennsylvania Association of Notaries,