On August 10, 2018 a Exhibit,Appendix 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.
For full print and download access, please subscribe at https://www.trellis.law/.
Please wait a moment while we load this page.
Preview
FILED: NEW YORK COUNTY CLERK 09/26/2019 03:48 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 298 RECEIVED NYSCEF: 09/26/2019 EXHIBIT A {N0025215-I} FILED: NEW YORK COUNTY CLERK 09/26/2019 03:48 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 298 RECEIVED NYSCEF: 09/26/2019 Daisy Acevedo From: Nicholas P. Iannuzzi Sent: Friday, February 22, 2019 2:33 PM To: 'Shelley Olsen'; Kerryann M. Cook; 'James Huss'; 'matthew.broderson@formanwatkins.com'; 'DPSCHAFFER@Malabylaw.com'; CaitlinE. Bell Subject: Munir - Index No.: 190225/18 - Request for Co-Defendant Depositions Seen, Dear Special Master, Pursuant to CMO §IX(L), Additional Discovery, and §XI(E), Dep0siticñs of Defendant, on behalf of IPA Systems, Inc.,I am requesting permission to seek case specific discovery from various co-defendants in the Munir Seen matter. Specifically, I am requesting permission to depose the persons most knowledgeable from McKesson, Weyerhaeuser, and Kaiser Gypsum, to testify in reference to the instant matter regarding the limited topics enumerated in the recent DeRoziers decision, namely products their company manufactured or sold; the asbestos content of these products; whether or not warnings were placed on the products, as well as the wording of the same; and the trade associations the entity was a rñêmber of and itsactivities with those associations. While we understand this issue of seeking co-defendant discovery iscurrently before the Court, absent a ruling, we believe this case specific, limited inquiry is the only mechanism to properly defend our clientat trial. As always, thank you in advance for your guidance and help. Sincerely, Nick lannuzzi Nicholas P. lannuzzi MCGIVNEY asso KLUGER & 80 Broad Street, 23rd Floor New York, New York 10004 www.mkclaw.us.com A C O M M IT M E N T T O EX C E L L E N C E Reception 212-509-3456 Direct 646-520-2115 Fax 212-509-4420 Florham Park, NJ | New York | Philadelphia | Syracuse | Hartford | St.Louis | Los Angeles | Fort Lauderdale| Buffalo | Wilmington, DE | New Brunswick, NJ | Sparta, NJ in f ............................................. The information contained in thisemail message is intendedonly forthe personal and confidentialuse ofthe named recipient(s) above.This message may be an attorney-clientccmmunication and such is privi!êged and If the confidential. reader ofthismessage is notthe intended recipientor an agent responsible fordeliveringit tothe intended you recipient, arehereby notifiedthatyou have receivedthisdocument in errorand that any review,dissemination, or copying distribution, of thismessage is strictly prohibited.If youhave receivedthiscommunkation in error, please notifyusimmediately by Email,and delete theoriginalmessage. ............................................. 1