On June 09, 2021 a Party Discovery was filed involving a dispute between Paula A. Karnisky His Spouse, Paula A. Karnisky His Spouse, Robert A. Karnisky, and Air & Liquid Systems Corporation As Successor By Merger To Buffalo Pumps, Inc., Air & Liquid Systems Corporation As Successor By Merger To Buffalo Pumps, Inc., Alray Construction Corp. F K A Hebert Construction Corp., Alray Construction Corp. F K A Hebert Construction Corp., Armstrong International, Inc., Armstrong Pumps Inc., Aurora Pump Company, Cleaver-Brooks, Inc. F K A Aqua-Chem, Inc., Cleaver-Brooks, Inc. F K A Aqua-Chem, Inc., Clyde Union Inc. F K A Union Pump Company, Clyde Union Inc. F K A Union Pump Company, Crane Co., Elmer W. Davis Inc., Flowserve Corporation F K A The Duriron Company, Inc. Sued As Successor By Merger To Durco International, Flowserve Corporation F K A The Duriron Company, Inc. Sued As Successor By Merger To Durco International, Flowserve Us, Inc. Solely As Successor To Rockwell Manufacturing Company Edward Valves, Inc. And Edward Vogt Valve Company, Flowserve Us, Inc. Solely As Successor To Rockwell Manufacturing Company Edward Valves, Inc. And Edward Vogt Valve Company, Fmc Corporation Individually And As Successor To Northern Pump Company And Coffin, Fmc Corporation Individually And As Successor To Northern Pump Company And Coffin, Foster Wheeler Llc, Frontier Insulation Contractors, Inc. F K A Frontier Insulation And Asbestos, Inc., Frontier Insulation Contractors, Inc. F K A Frontier Insulation And Asbestos, Inc., Gardner Denver, Inc., General Electric Company, Goulds Pumps, Incorporated F K A Goulds Pumps Merger Corporation, Goulds Pumps, Incorporated F K A Goulds Pumps Merger Corporation, Grinnell Llc, Honeywell International Inc. F K A Alliedsignal, Inc. And As Successor In Interest To The Bendix Corporation, Honeywell International Inc. F K A Alliedsignal, Inc. And As Successor In Interest To The Bendix Corporation, Imo Industries Inc. Individually And As Successor In Interest To Imo Delaval, Imo Industries Inc. Individually And As Successor In Interest To Imo Delaval, Industrial Insulation Sales, Inc., Insulation Distributors, Inc., Itt Corporation F K A Itt Industries, Inc. Individually And As Successor To Itt Fluid Products Corp. Itt Hoffman Itt Bell & Gossett Company And Itt Marlow, Itt Corporation F K A Itt Industries, Inc. Individually And As Successor To Itt Fluid Products Corp. Itt Hoffman Itt Bell & Gossett Company And Itt Marlow, Mader Capital, Inc., Mader Plastering Corp., Met-Pro Technologies Llc A Ceco Environmental Company Successor By Merger To Met-Pro Corporation On Behalf Of Its Dean Pump Division, Met-Pro Technologies Llc A Ceco Environmental Company Successor By Merger To Met-Pro Corporation On Behalf Of Its Dean Pump Division, Neles-Jamesbury, Inc, Pfaudler, Inc., R.E. Hebert And Company, Inc., Riley Power Inc. F K A Babcock Borsig Power, Inc. F K A Db Riley, Inc. F K A Riley Stoker Corporation, Riley Power Inc. F K A Babcock Borsig Power, Inc. F K A Db Riley, Inc. F K A Riley Stoker Corporation, Rochester Acoustical Corp., Rochester Industrial Insulation, Inc., Spirax Sarco, Inc. Individually And As Successor To Sarco Company, Inc., Spirax Sarco, Inc. Individually And As Successor To Sarco Company, Inc., Spx Cooling Technologies, Inc. F K A Marley Cooling Technologies, Inc. F K A The Marley Cooling Tower Company, Spx Cooling Technologies, Inc. F K A Marley Cooling Technologies, Inc. F K A The Marley Cooling Tower Company, The Mader Corporation, The Marley-Wylain Company F K A Weil-Mclain, The Marley-Wylain Company F K A Weil-Mclain, The William Powell Company, Union Carbide Corporation, Velan Valve Corp., Viacomcbs, Inc., Warren Pumps Llc, Watts Water Technologies, Inc F K A Watts Industries, Inc, Individually And As Successor To Mueller Steam Specialty Company, Weir Valves & Controls Usa, Inc. D B A Atwood & Morrill Co., Inc., Weir Valves & Controls Usa, Inc. D B A Atwood & Morrill Co., Inc., William Summerhays' Sons Corporation, Zurn Industries, Llc Individually And As Successor In Interest To Erie City Iron Workers Corporation, Zurn Industries, Llc Individually And As Successor In Interest To Erie City Iron Workers Corporation, for Torts - Asbestos in the District Court of Monroe County.
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FILED: MONROE COUNTY CLERK 01/10/2022 11:48 AM INDEX NO. E2021005118 NYSCEF DOC. NO. 71 RECEIVED NYSCEF: 01/10/2022 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 2954137 Book Page CIVIL Return To: No. Pages: 3 JASON ANTHONY BOTTICELLI Instrument: MISCELLANEOUS DOCUMENT Control #: 202201100443 Index #: E2021005118 Date: 01/10/2022 Karnisky, Robert A. Time: 11:49:27 AM Karnisky, Paula A. Air & Liquid Systems Corporation Alray Construction Corp. Armstrong International, Inc. Armstrong Pumps Inc. Aurora Pump Company Total Fees Paid: $0.00 Employee: State of New York MONROE COUNTY CLERK’S OFFICE WARNING – THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO MONROE COUNTY CLERK 1 of 3 202201100443 Index # INDEX : E2021005118 NO. E2021005118 FILED: MONROE COUNTY CLERK 01/10/2022 11:48 AM NYSCEF DOC. NO. 71 RECEIVED NYSCEF: 01/10/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF MONROE _____________________________________________ ROBERT A. KARNISKY and PAULA KARNISKY, his spouse, FIRST SET OF Plaintiffs, SUPPLEMENTAL INTERROGATORIES vs. AND REQUEST FOR PRODUCTION AIR & LIQUID SYSTEMS CORPORATION, as successor by merger to BUFFALO PUMPS, INC., et al. Index No. E2021005118 Defendants. _____________________________________________ PLEASE TAKE NOTICE that pursuant to Article 31 of the Civil Practice Law and Rules, defendant, WATTS WATER TECHNOLOGIES, INC., propounds the following interrogatories and document production requests to plaintiffs to be responded to within sixty (60) days of the date of service. These demands are continuing and require that you file supplemental answers if further or different information is obtained after serving your initial answers, before trial,including in such supplemental response the date upon the manner in which such further or different information came to your attention. INTERROGATORIES INTERROGATORY NO. 1: Has plaintiffs or anyone on their behalf ever filed or submitted a claim for compensation for an asbestos related disease to any Trust created to receive and process such claims, e.g., Manville Trust? If so, please state the following: a) The name and address of the Trust; b) The date the claim was submitted; c) The disease or condition for which compensation was sought; 1 31983901.v1 2 of 3 202201100443 IndexNO. INDEX #: E2021005118 E2021005118 FILED: MONROE COUNTY CLERK 01/10/2022 11:48 AM NYSCEF DOC. NO. 71 RECEIVED NYSCEF: 01/10/2022 d) The place and years of exposure to asbestos; e) The product to which exposure was claimed; f) Your occupation at the time of the claimed exposure; and g) The answer or payment received or promised, if any. REQUEST FOR PRODUCTION OF DOCUMENTS REQUEST NO. 1: Please produce the claim form(s) submitted/enclosed to any Trust described in response to Interrogatory No. 1, together with any attachments/exhibits thereto, as well as any correspondence or other documentation pertaining to any communication with the trust. DATED: Buffalo, New York January 10, 2022 GOLDBERG SEGALLA LLP By: ______________________________ Jason A Botticelli, Esq. Joseph J. Welter, Esq. Attorneys for Defendant WATTS WATER TECHNOLOGIES, INC 665 Main Street Buffalo, New York 14203 (716) 566-5400 TO: Sean Esford, Esq. Lipsitz, Ponterio & Comerford, LLC Attorneys for Plaintiffs 424 Main Street, Suite 1500 Buffalo, NY 14202 2 31983901.v1 3 of 3