On August 10, 2018 a
Party Discovery
was filed
involving a dispute between
Sinar Seen
Individually And As Administrator Of The Estate Of Munir Seen, Deceased,
and
84 Lumber Company,
Aerco International, Inc.,
Algoma Hardwoods, Inc.,
Benjamin Moore & Company,
Bmce Inc., In Itself And As Successor To United Centrifugal Pump Co.,
Cbs Corporation, A Delaware Corporation, F K A Viacom Inc., Successor By Merger To Cbs Corporation, A Pennsylvania Corporation, F K A Westinghouse Electric Corporation,
Certain-Teed Corporation,
Conwed Corporation,
Crane Co.,
Dap, Inc. N K A La Mirada Products, Inc.,
Foster Wheeler Energy Corporation,
General Electric Company,
Industrial Holdings Corporation F K A The Carborundum Company,
Ingersoll-Rand Company,
Ipa Systems, Inc.,
John Crane Inc.,
John Doe 1 Through John Doe 75,
Kaiser Gypsum Company, Inc.,
Kelly Moore Paint Company Inc.,
Mario & Dibono Fireproofing Corp.,
Mario & Dibono Plastering Co. Inc.,
Mckesson Corporation,
Metropolitan Life Insurance Company,
Pfizer, Inc.,
Sherwin-Williams Automotive Finishes Corporation,
Simpson Timber Company,
Tishman Construction Company,
Turner Construction Company,
Union Carbide Corporation,
U.S. Plywood A K A International Paper Company,
Weyerhaeuser Company,
for Torts - Asbestos
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018
NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
IN RE: NEW YORK COUNTY |
ASBESTOS LITIGATION
MUNIR SEEN,
Plaintiff,
Index No.: 190225/2018
-against-
84 LUMBER COMPANY, et al., | NOTICE OF EXAMINATION
BEFORE TRIAL
Defendants.
!
i
IPA SYSTEMS, INC.,
Third-Party Plaintiff,
-against-
KAISER GYPSUM COMPANY, INC.,
Third-Party Defendant.
TO: Simmons Hanly Conroy LLC
112 Madison Avenue, 7th Floor
New York, New York 10016
PLEASE TAKE NOTICE, pursuant to applicable portions of Article 31 of the Civil
Practice Laws and Rules of New York, McGivney, Kluger & Cook, P.C., attorneys for defendant
IPA Systems, Inc. (hereinafter "IPA Systems"), hereby notice their intent to take the oral
Plaintiffs'
examination of the following fact witnesses identified in Fact Witness List:
1. Sirsa Seen (Plaintiff's Daughter)
2. Sinar Seen (Plaintiff's Son)
PLEASE TAKE FURTHER NOTICE, we further intend to depose Plaintiff's wife,
Rwida Basha, who was not included on Plaintiff's Fact Witness List, but is equally essentially to
Discovery in this matter.
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FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018
NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019
The depositions will be cêñducted at a rsetcally agreeable location, date and time to be
before a Public or other officer authorized to
ad 4 i÷r and will
determined, Notary oaths,
continue day-to-day until co-pletc. The witnesscs will
testify
with respect to all facts relevant to
the subject matter of this action.
Dated: April 25, 2019
New York, New York
Yours etc.,
McGIVNEY, KLUGER, & COOK P.C.
Attorneys for Defendant
IPA SYSTEMS, INC.
NICHOLAS P IANNUZZI, E .
23d
80 Broad Street, Floor
New York, New York 10004
(212) 509-3456
cc: All Counsel of Record
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FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018
NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK .
IN RE: NEW YORK COUNTY |
ASBESTOS LITIGATION
MUNIR SEEN,
Plaintiff,
Index No.: 190225/2018
-against-
84 LUMBER COMPANY, et al., | REQUEST FOR PRODUCTION
OF DOCUMENTS
Defendants.
,
IPA SYSTEMS, INC.,
Plaintiff
Third-Party
-against-
KAISER GYPSUM COMPANY, INC.,
Third-Party Defendant.
PLEASE TAKE NOTICE that defendant IPA Systems, Inc., hcreby demands that upon
the deposinon of fact witness Rwida Basha, the witñêss, coñcuuently with oral exa_-±-+ion,
produce a certified copy of her marriage license with the plaintiff, Munir Seen.
Dated: April 25, 2019
New York, New York
Yours etc.,
McGIVNEY, KLUGER, & COOK P.C.
Attorneys for Defendant
IPA SYSTEMS, INC.
NICHOLAS P IANNUZZI, E .
23d
80 Broad Street, Floor
New York, New York 10004
(212) 509-3456
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FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018
NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019
Index No.: 190225/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------------------------------------------------------------------------------X
MUNIR SEEN,
Plaintiff,
-against-
84 LUMBER COMPANY, et al.,
Defendants.
------------------------------------------------------------------------------X
IPA SYSTEMS, INC.,
Third-Party Plaintiff,
-against-
KAISER GYPSUM COMPANY, INC.,
Third-Party Defendant.
------------------------------------------------------------------------------X
NOTICE OF EXAMINATION BEFORE TRIAL and
REQUEST FOR PRODUCTION OF DOCUMENTS
Attorneys for Defendant: IPA SYSTEMS, INC.
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Preview
FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK COUNTY | ASBESTOS LITIGATION MUNIR SEEN, Plaintiff, Index No.: 190225/2018 -against- 84 LUMBER COMPANY, et al., | NOTICE OF EXAMINATION BEFORE TRIAL Defendants. ! i IPA SYSTEMS, INC., Third-Party Plaintiff, -against- KAISER GYPSUM COMPANY, INC., Third-Party Defendant. TO: Simmons Hanly Conroy LLC 112 Madison Avenue, 7th Floor New York, New York 10016 PLEASE TAKE NOTICE, pursuant to applicable portions of Article 31 of the Civil Practice Laws and Rules of New York, McGivney, Kluger & Cook, P.C., attorneys for defendant IPA Systems, Inc. (hereinafter "IPA Systems"), hereby notice their intent to take the oral Plaintiffs' examination of the following fact witnesses identified in Fact Witness List: 1. Sirsa Seen (Plaintiff's Daughter) 2. Sinar Seen (Plaintiff's Son) PLEASE TAKE FURTHER NOTICE, we further intend to depose Plaintiff's wife, Rwida Basha, who was not included on Plaintiff's Fact Witness List, but is equally essentially to Discovery in this matter. {N0858942-1} 1 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019 The depositions will be cêñducted at a rsetcally agreeable location, date and time to be before a Public or other officer authorized to ad 4 i÷r and will determined, Notary oaths, continue day-to-day until co-pletc. The witnesscs will testify with respect to all facts relevant to the subject matter of this action. Dated: April 25, 2019 New York, New York Yours etc., McGIVNEY, KLUGER, & COOK P.C. Attorneys for Defendant IPA SYSTEMS, INC. NICHOLAS P IANNUZZI, E . 23d 80 Broad Street, Floor New York, New York 10004 (212) 509-3456 cc: All Counsel of Record {N0858942-1} 2 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK . IN RE: NEW YORK COUNTY | ASBESTOS LITIGATION MUNIR SEEN, Plaintiff, Index No.: 190225/2018 -against- 84 LUMBER COMPANY, et al., | REQUEST FOR PRODUCTION OF DOCUMENTS Defendants. , IPA SYSTEMS, INC., Plaintiff Third-Party -against- KAISER GYPSUM COMPANY, INC., Third-Party Defendant. PLEASE TAKE NOTICE that defendant IPA Systems, Inc., hcreby demands that upon the deposinon of fact witness Rwida Basha, the witñêss, coñcuuently with oral exa_-±-+ion, produce a certified copy of her marriage license with the plaintiff, Munir Seen. Dated: April 25, 2019 New York, New York Yours etc., McGIVNEY, KLUGER, & COOK P.C. Attorneys for Defendant IPA SYSTEMS, INC. NICHOLAS P IANNUZZI, E . 23d 80 Broad Street, Floor New York, New York 10004 (212) 509-3456 {N0858942-1} 3 of 4 FILED: NEW YORK COUNTY CLERK 04/26/2019 09:44 AM INDEX NO. 190225/2018 NYSCEF DOC. NO. 149 RECEIVED NYSCEF: 04/26/2019 Index No.: 190225/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------------X MUNIR SEEN, Plaintiff, -against- 84 LUMBER COMPANY, et al., Defendants. ------------------------------------------------------------------------------X IPA SYSTEMS, INC., Third-Party Plaintiff, -against- KAISER GYPSUM COMPANY, INC., Third-Party Defendant. ------------------------------------------------------------------------------X NOTICE OF EXAMINATION BEFORE TRIAL and REQUEST FOR PRODUCTION OF DOCUMENTS Attorneys for Defendant: IPA SYSTEMS, INC. {N0858942-1} 4 of 4