On June 09, 2021 a
Exhibit,Appendix
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.
Preview
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3129443
Book Page CIVIL
Return To: No. Pages: 67
JASON ANTHONY BOTTICELLI
Instrument: EXHIBIT(S)
Control #: 202207080612
Index #: E2021005118
Date: 07/08/2022
Karnisky, Robert A. Time: 12:17:00 PM
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
202207080612 Index #
INDEX : E2021005118
NO. E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
Exhibit C
202207080612 INDEX NO. E2021005118
Index#:E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
SEVENTH JUDICIAL DISTRICT
PLAINTIFFS'
VERIFIED
DEFENDANTS'
In re: Seventh Judicial District Asbestos Litigation ANSWERS TO
STANDARD SET OF
INTERROGATORIES
This Document Applies to:
SUPREME COURT OF THE STATE OF NEW YORK Index No.: E2021005118
COUNTY OF MONROE
ROBERT A. KARNISKY and
PAULA A. KARNISKY, his spouse,
Plaintiffs,
vs.
AIR & LIQUID SYSTEMS CORPORATION
as successor by merger to
BUFFALO PUMPS, INC., et al.
Defendants.
i
A. PERSONAL BACKGROUND OF PLAINTIFF AS REPRESENTATIVE OF
DECEDENT'S ESTATE
INTERROGATORY NO. 1
If you represent decedents estate, state the following for yourself:
(a) Full name and allother names by which you have been known;
(b) Relationship to the decedent;
(c) Date and place of birth;
(d) Address; recommended
(e) Social security number;
(f) Present marital status and, ifapplicable, name of present spouse and date of marriage;
and
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
spouses'
(g) Dates of all prior marriages, names, and dates of termination of marriages.
ANSWER:
Not applicable.
B. PERSONAL BACKGROUND OF INJURED PLAINTIFF/DECEDENT
INTERROGATORY NO. 2
State the following for injured plaintiff/decedent:
(a) Full name and allother names by which injured plaintiff/decedent has been known;
(b) Date and place of biith;
(c) Whether injured plaintiff/decedent was an adopted child and, ifadopted, state date of
adoption;
(d) Present age; or date and place of death;
(e) Present marital status and, ifapplicable, name of present spouse and date of marriage,
or marital status at the time of death, and ifapplicable, the name of spouse at the time of death and
date of marriage;
spouses'
(f) Dates of all prior marriages, names, and dates of termination of marriages;
(g) Present home address, or home address at time of death; and
(b) Social security number.
ANSWER:
(a) Robert A, Karnisky;
(b) Date of Birth: October 8, 1945; Place of Birth: Rochester, NY;
(c) Not adopted;
(d) Plaintiff is 76 years old;
. -2-
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEXIndex NO.
#: E2021005118
E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(e) Married to Paula A. Karnisky; The two were wed on June 10, 1967 and remain
married;
(f) Not applicable;
(g) Plaintiff resides at 624 Atlantic Avenue, Macedon, New York 14502;
(h)
INTERROGATORY NO. 3
State the following with regard to injured plaintiffs/decedent's father, mother and each sibling:
(a) Name, relationship and date of birth;
(b) Current address (if deceased, state lastknown address);
(c) Current condition of each one's health, including any specific medical problems;
(d) If either of injured plaintiffs/decedent's parents is deceased, please state for each
deceased parent:
(i) Specific medical problems;
(ii) Date and place of death; and
(iii) Cause of death.
(e) If injured plaintiffs/decedenes grandparent, aunt, uncle, great aunt, great uncle or first
cousin has had any respiratory illness (other than common colds), cardiac problem, or any cancer,
state as to each:
(i) Name, relationship and date of birth;
(ii) Cunent address (if deceased, state lastknown address); and
(iii) The specific respiratory illness, cardiac problem, or cancer the
individual had or has.
ANSWER:
Plaintiff's father died in 1987 at the age of 72 from a heart attack and diabetes.
Plaintiff's mother died in 1979 at the age of 60 from heart disease.
-3-
zuzzurunuu12
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
INTERROGATORY NO. 4
State the following with regard to each of injured plaintiff's/decedents children:
(a) Name;
(b) Date of biith;
(c) Sex;
(d) Current address (if deceased, state the last known address);
(e) Whether natural child or adopted child and, ifadopted, state date of adoption;
(f) Current state of health, including a statement of specific medical problems;
(g) Ifany ofinjured plaintiffs/decedents children are deceased, statefor each deceased child:
(i) Specific medical problems;
(ii) Date and place of death; and
(iii) Cause of death.
ANSWER:
Plaintiff's son, Jon Karnisky is 51 years old, lives in Macedon, New York, and enjoys
good health. Plaintiff s twin sons, Kevin and Keith Karnisky are 48 years old, both live in
Webster, New York, and enjoy good health,
INTERROGATORY NO. 5
List allinjured plaintiff s/decedents residences, the dates injured plaintiff/decedent resided at
each, and with respect to each state:
(a) Whether such residence contained asbestos insulation;
(b) Whether any improvements were made to the residence (i.e., insulation, rewiring,
etc.);
(c) The type of fuel used for heating;
(d) The type of fuel us ed for cooking; and
-4-
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(e) Whether injured plaintiff/decedent ever changed residence for health reasons, and if
so, the residence left and the health reason for leaving.
ANSWER:
(a) Upon information and belief, plaintiff is unaware ifany residences listed below
contained asbestos insulation;
(b) Plaintiff did substantial work constructing his current home.
(c)-
(d)
ADDRESS DATES FUEL/ FUEL/
HEATING COOIGNG
179 Mosley Road 1945-1967 Gas Gas
Greece, New York
624 Atlantic Avenue 1967-Present Gas Gas
Macedon, New York
(e) Plaintiff has never changed residences for health reasons.
INTERROGATORY NO. 6
Identify each member of the injured plaintiffs/decedents household in the last five years, or
during the last five years prior to death, and also state as to each:
(a) His age, occupation, and relationship to the injured plaintiff/decedent; and
(b) The portion of the last 12 months, or the last 12 months of the decedents life, during
which he was a member of the household.
ANSWER:
Plaintiff lives with his wife, Paula.
INTERROGATORY NO. 7
List injured plaintiffs/decedents hobbies or the major leisure activities in which she engaged
during the last twenty years, or the last twenty years of his life. If the injured plaintiff/decedent did
not have hobbies or participate in leisure activities, describe how she spent his leisure time.
-5-
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
ANSWER:
Plaintiff enjoys gardening and spending time with his grandchildren.
INTERROGATORY NO. 8
Did injured plaintiff/decedent or his spouse ever filefor divorce against the other?
If your answer is yes, state the date of suit, itsdisposition, and the date of disposition.
ANSWER:
No.
INTERROGATORY NO. 9
Were injured plaintiff/decedent and his spouse ever separated for any period of more than 48
hours because of a marital disagreement?
If your answer is yes, indicate every such incident, stating the reason for the separation and
the length of time of each separation.
ANSWER:
No.
INTERROGATORY NO. 10
Was injured plaintiff/decedent ever a party to or a witness in any lawsuit, court or
administrative proceeding?
If your answer is yes,state:
(a) Whether injured plaintiff/decedent was a party or a witness and, if a party, whether
she was a plaintiff or a defendant;
(b) The titleof the lawsuit or proceeding, the court or agency in which itwas brought and
the docket number;
-6-
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(c) The nature of the charges or claims and, if injured plaintiff/decedent was a witness,
the substance of his testimony.
(d) The disposition of the case; and
(e) Identify all insurance carriers or administrative agencies that either made payment or
declined to make payment with respect to each such lawsuit or claim.
ANSWER:
Upon information and belief, no.
INTERROGATORY NO. 11
Has injured plaintiff/s ever applied and been rejected for a lifeinsurance, medical insurance,
or disability insurance policy?
If your answer is yes, state with regard to each such event:
(a) The identity of the insurer to whom such application was made;
(b) The date of such application;
(c) The identity of any Physician conducting a physical examination with regard to such
application and the date thereof;
(d) The reason for such rejection; and
(e) Produce all documentation of said application and rejection.
ANSWER:
No.
C. EMPLOYMENT HISTORY
INTERROGATORY NO. 12
Have you or anyone on your behalf requested from the Social Security Administration a listing
of all of the injured plaintiff s/decedents employers and dates of employment?
-7-
202207080612 INDEX
Index NO.
#: E2021005118
E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
If your answer is yes, attach a copy of such listing to your responses to these interrogatories.
If not available, execute and provide a release in the form annexed as an exhibit.
ANSWER:
Plaintiff will supplement upon receipt of same.
INTERROGATORY NO. 13
Identify each and every employer that injured plaintiff/decedent had from the time he was
firstemployed to the present, or to the time of his death, including any and all military service, and as
to each, state:
(a) The period of time injured plaintiff/decedent worked for each such employer;
(b) Each position/job titlewhich injured plaintiff/decedent held with each such employer
and the dates each such position/job title was held by injured plaintiff/decedent;
(c) The nature of the work performed;
(d) The location(s) of injured plaintiffs/decedents particular jobsite(s);
(e) The nature of the materials or products injured plaintiff/decedent worked with; and
(f) Whether said activity involved working in the presence of dust, pollutants, or toxic
substances and, if so:
(i) Identify by name or type said dust, pollutants, or toxic substances;
(ii) State whether any suction device, fan, or other ventilation system was
present at the jobsite; and
(iii) State whether the employer or any govemmental agency or union took
air samplings at the jobsite and, ifso, identify the persons who took
the air samplings, the dates such samplings were taken and the persons
presently having possession or control of any documents relating to
such air samplings.
ANSWER:
-8-
202207080612 INDEX NO. E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
- Based on Personal Knowledge CHART A
22(a)
Name and Address Dates of Jobsite Ashestos Products used Other Asbestos
of Employers Employment by Plaintiff personally Products which
(Include name of Plaintiff
Manufacturer if contended he was
known) exposed to
(Include name of
Manufacturer if
known)
Xerox Corporation 1967-2003 Xerox " Boilers manufactured
by Cleaver-Brooks
" Pumps manufactured
by Buffalo Pumps,
Goulds, Bell &
Gossett, DeLaval,
Dutco, Union, and
Armstrong
" Valves manufactured
by Crane, Grinnell
Edward, Velan,
William Powell, and
Jamesbury
" Streamtraps
manufactured by
Armstrong, Sarco, and
Watts
" Insulation installed
by Rochester
Industrial Insulation,
R.E. Hebert, and
William Summerhays
" Gaskets
manufactured by
Garlock
-9-
202207080612 INDEX NO. E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
INTERROGATORY NO. 14
If injured plaintiff/decedent was self-employed at any time, identify each such business, and
as to each, state:
(a) The period during which injured plaintiff/decedent was self-employed;
(b) The nature of the work performed;
(c) The location(s) of injured plaintiffs/decedent's particular jobsite(s);
(d) The nature of the materials or products injured plaintiff/decedent worked with; and
(e) Whether said activity involved working in the presence of dust, pollutants, or toxic
substances and, ifso:
(i) Identify by name or type said dust, pollutants, or toxic substances;
(ii) State whether any suction device, fan, or other ventilation system was present
at the jobsite; and
(iii) State whether the employer, any governmental agency, any union or any other
person took air samplings at any jobsite at which injured plaintiff/decedent worked, and, ifso, identify
the person(s) who took the air samples, the dates such air samples were taken and the persons
presently having possession or control of any documents relating to such air samples.
ANSWER:
No.
INTERROGATORY NO. 15
Did injured plaintiff/decedent ever lose a job, change jobs or change his position with an
employer for health reasons?
If your answer is yes, state as to each such event:
(a) The employer and job position which injured plaintiff/decedent left;
-10-
202207080612 INDEX
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index NO.
#: E2021005118
E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(b) The date of such event;
(c) The health reason for such event; and
(d) The new employer and/or job position which injured plaintiff/decedent next assumed.
ANSWER:
No.
INTERROGATORY NO. 16
Are you aware of, have you ever seen or do you or your attorney possess or have access to
any photographs, charts, drawings, diagrams or other graphic representations depicting work
conditions at work sites where you claim injured plaintiff/decedent was exposed to asbestos materials
and/or asbestos-containing products?
If your answer is yes, with respect to each:
(a) Identify each such photograph or other document, including a statement as to which
views, scenes or objects itpurports to depict, the person who took or prepared each such photograph
or other document, and the date taken or prepared;
(b) State whether the photograph or other document was prepared on your behalf or on
behalf of other persons allegedly exposed to asbestos or as a result of circumstances relating to this
or any other lawsuit; and
(c) Attach a copy.
-11-
202207080612
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118
Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
ANSWER:
Plaintiff will supplement as we proceed through discovery in this action.
INTERROGATORY NO. 17
During the period of time for which you claim injured plaintiff/decedent was exposed to
asbestos materials and/or asbestos-containing products, did injured plaintiff/decedent share a
household with any other person(s) who worked or was employed outside the household?
If your answer is yes, identify:
(a) Each such other person;
(b) The period(s) of time each such other person shared such household;
(c) The period(s) of time each such other person worked or was so employed;
(d) The nature of each job held or job titlefor each such other person in each such period
of time; and
(e) Each and every employer of each such other person in each such period of time.
ANSWER:
Upon information and belief, no. Plaintiff reserves the right to supplement this
response.
INTERROGATORY NO. 18
Was injured plaintiff/decedent ever exposed to or did injured plaintiff/decedent ever use,
inhale or ingest any of the following substances on a regular basis or at work?
If your answer is yes, state the date(s), place(s), and circumstances thereof:
(a) Acids;
(b) Aluminum;
(c) Ammonia;
(d) Arsenic;
(e) Barium;
(f) Beryllium;
-12-
202207080612 INDEX
Index NO. E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM #:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(g) Butanol;
(h) Cadmium;
(i) Carborundum;
(j) Chloreothylene;
(k) Chlorine;
(1) Chromate;
(m) Chromite;
(n) Chromium;
(0) Coal and/or coal dust;
(p) Coal tar;
(q) Cotton dust;
(r) Creosote;
(s) Epoxy;
(t) Ethanol;
(u) Formaldehyde;
(v) Grinding dust;
(w) Iron;
(x) Isocyanates;
(y) Isopropanol;
(z) Lead;
(aa) Live chickens;
(bb) Manganese;
(cc) Nickel;
(dd) Nitrogen dioxide;
(ee) Nuclear radiation;
(ff) Ozone;
(gg) Petroleum distillates;
(hh) Phosgene;
(ii) Radiation;
(jj) Silica;
(kk) Titanium;
(11) Toluene;
(mm) Welding smoke or fumes;
(nn) Zylene;
(oo) Zinc.
ANSWER:
Upon information and belief, plaintiff was not exposed to any of the substances identified
in Interrogatory No. 18. However, to the extent that plaintiff suffers from severe asbestosis,
plaintiff alleges that his disease was caused by exposure to asbestos.
-13-
202207080612 INDEX
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index NO.
#: E2021005118
E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
INTERROGATORY NO. 19
From the time of his birth to the present or to the time of his death, did injured
plaintiff/decedent ever use cigarettes, cigars, pipes, smokeless tobacco, or any other tobacco
substance?
If your answer is yes, state the following:
(a) The brand and type of tobacco products(s) used (e.g., filter, non-filter, chewing
tobacco);
(b) The period(s) during which she used each such product;
(c) The amount of the product used per day, during each period of time (e.g., 2 packs of
cigarettes per day for 2 years);
(d) Whether injured plaintiff/decedent was ever told that she was suffering from any
disease or illness contributed to or caused by tobacco, and ifso, identify each person who gave injured
plaintiff/decedent any such advice, the dates on which the advice was given, and state exactly what,
ifanything, injured plaintiff/decedent did in response to that advice;
(e) Whether the injured plaintiff/decedent was ever advised that use of tobacco products
could adversely affect his health, and ifso, identify each person who gave injured plaintiff/decedent
any such advice, the dates on which the advice was given, and state exactly what, ifanything, injured
plaintiff/decedent did in response to that advice; and
(f) Whether injured plaintiff/decedent was ever advised to stop using tobacco products,
and ifso, identify each person who gave injured plaintiff/decedent any such advice, the dates on which
the advice was given, and state exactly what, ifanything, injured plaintiff/decedent did in response to
that advice.
-14-
202207080612 INDEX NO. E2021005118
Index#:E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
ANSWER:
Plaintiff occasionally smoked a pipe after dinner from approximately 1975 to 1985.
Plaintiff has not used tobacco products in the last 35 years.
INTERROGATORY NO. 20
For each spouse and member of injured plaintiff s/decedent's household, from injured
plaintiffs/decedents birth until the present time, state whether each individual ever used cigarettes,
cigars, pipes, smokeless tobacco, or any other tobacco substance, and if so, state the following for
each:
(a) The brand and type of tobacco product(s) used (e.g., filter,non-filter, chewing
tobacco);
(b) The period(s) during which he used each such product; and
(c) Whether he was ever told by a doctor that he isor was suffering from any disease or
illness caused or contributed to by his use of tobacco, and if so,when and by whom.
ANSWER:
Plaintiff will supplement as we proceed through discovery in this action.
INTERROGATORY NO, 21
If injured plaintiff/decedent ever worked in an office or other enclosed space, state whether
injured plaintiff/decedent shared a room with anyone who used or smoked cigarettes, cigars or pipes.
ANSWER:
Plaintiff will supplement as we proceed through discovery in this action.
INTERROGATORY NO. 22
Did injured plaintiff/decedent consume alcoholic beverages?
If your answer is yes, state the following:
-15-
202207080612 INDEX NO. E2021005118
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118
NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022
(a) The type of alcoholic beverages consumed;
(b) The periods during which injured plaintiff/decedent consumed such alcoholic
beverage;
(c) The amount of such beverage injured plaintiff/decedent consumed each day during
each period of use; and
(d) Whether injured plaintiff/decedent was ever treated for any illness or disease related
to his consumption of alcoholic beverages or was ever advised to reduce his consumption.
ANSWER:
Plaintiff occasionally will drink a glass of wine or beer,
INTERROGATORY NO. 23
Did injured plaintiff/decedent ever take any prescription medication, any non-prescription
medication, or any other drugs for the treatment of respiratory problems, cardiac problems,
gastrointestinal problems, cancer, or any chronic health condition or illness?
If your answer is yes, state for each:
(a) The medication or drug taken;
(b) The amount of medication or drug taken and the period over which itwas taken;
(c) The reason fortaking the medication or drug; and
(d) If the medication was prescribed:
(i) Identify the person prescribing the medication;
(ii) Identify the pharmacy filling the prescription; and
(iii) Produce any document reflecting the prescribing, filling or payment
of any prescription medication.
-16-
202207080612 INDEX
Index NO. E2021005118
#:E2021005118
FILED: MONROE COUNTY
Preview
FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3129443 Book Page CIVIL Return To: No. Pages: 67 JASON ANTHONY BOTTICELLI Instrument: EXHIBIT(S) Control #: 202207080612 Index #: E2021005118 Date: 07/08/2022 Karnisky, Robert A. Time: 12:17:00 PM 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 202207080612 Index # INDEX : E2021005118 NO. E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 Exhibit C 202207080612 INDEX NO. E2021005118 Index#:E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 SUPREME COURT OF THE STATE OF NEW YORK SEVENTH JUDICIAL DISTRICT PLAINTIFFS' VERIFIED DEFENDANTS' In re: Seventh Judicial District Asbestos Litigation ANSWERS TO STANDARD SET OF INTERROGATORIES This Document Applies to: SUPREME COURT OF THE STATE OF NEW YORK Index No.: E2021005118 COUNTY OF MONROE ROBERT A. KARNISKY and PAULA A. KARNISKY, his spouse, Plaintiffs, vs. AIR & LIQUID SYSTEMS CORPORATION as successor by merger to BUFFALO PUMPS, INC., et al. Defendants. i A. PERSONAL BACKGROUND OF PLAINTIFF AS REPRESENTATIVE OF DECEDENT'S ESTATE INTERROGATORY NO. 1 If you represent decedents estate, state the following for yourself: (a) Full name and allother names by which you have been known; (b) Relationship to the decedent; (c) Date and place of birth; (d) Address; recommended (e) Social security number; (f) Present marital status and, ifapplicable, name of present spouse and date of marriage; and 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 spouses' (g) Dates of all prior marriages, names, and dates of termination of marriages. ANSWER: Not applicable. B. PERSONAL BACKGROUND OF INJURED PLAINTIFF/DECEDENT INTERROGATORY NO. 2 State the following for injured plaintiff/decedent: (a) Full name and allother names by which injured plaintiff/decedent has been known; (b) Date and place of biith; (c) Whether injured plaintiff/decedent was an adopted child and, ifadopted, state date of adoption; (d) Present age; or date and place of death; (e) Present marital status and, ifapplicable, name of present spouse and date of marriage, or marital status at the time of death, and ifapplicable, the name of spouse at the time of death and date of marriage; spouses' (f) Dates of all prior marriages, names, and dates of termination of marriages; (g) Present home address, or home address at time of death; and (b) Social security number. ANSWER: (a) Robert A, Karnisky; (b) Date of Birth: October 8, 1945; Place of Birth: Rochester, NY; (c) Not adopted; (d) Plaintiff is 76 years old; . -2- 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEXIndex NO. #: E2021005118 E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (e) Married to Paula A. Karnisky; The two were wed on June 10, 1967 and remain married; (f) Not applicable; (g) Plaintiff resides at 624 Atlantic Avenue, Macedon, New York 14502; (h) INTERROGATORY NO. 3 State the following with regard to injured plaintiffs/decedent's father, mother and each sibling: (a) Name, relationship and date of birth; (b) Current address (if deceased, state lastknown address); (c) Current condition of each one's health, including any specific medical problems; (d) If either of injured plaintiffs/decedent's parents is deceased, please state for each deceased parent: (i) Specific medical problems; (ii) Date and place of death; and (iii) Cause of death. (e) If injured plaintiffs/decedenes grandparent, aunt, uncle, great aunt, great uncle or first cousin has had any respiratory illness (other than common colds), cardiac problem, or any cancer, state as to each: (i) Name, relationship and date of birth; (ii) Cunent address (if deceased, state lastknown address); and (iii) The specific respiratory illness, cardiac problem, or cancer the individual had or has. ANSWER: Plaintiff's father died in 1987 at the age of 72 from a heart attack and diabetes. Plaintiff's mother died in 1979 at the age of 60 from heart disease. -3- zuzzurunuu12 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 INTERROGATORY NO. 4 State the following with regard to each of injured plaintiff's/decedents children: (a) Name; (b) Date of biith; (c) Sex; (d) Current address (if deceased, state the last known address); (e) Whether natural child or adopted child and, ifadopted, state date of adoption; (f) Current state of health, including a statement of specific medical problems; (g) Ifany ofinjured plaintiffs/decedents children are deceased, statefor each deceased child: (i) Specific medical problems; (ii) Date and place of death; and (iii) Cause of death. ANSWER: Plaintiff's son, Jon Karnisky is 51 years old, lives in Macedon, New York, and enjoys good health. Plaintiff s twin sons, Kevin and Keith Karnisky are 48 years old, both live in Webster, New York, and enjoy good health, INTERROGATORY NO. 5 List allinjured plaintiff s/decedents residences, the dates injured plaintiff/decedent resided at each, and with respect to each state: (a) Whether such residence contained asbestos insulation; (b) Whether any improvements were made to the residence (i.e., insulation, rewiring, etc.); (c) The type of fuel used for heating; (d) The type of fuel us ed for cooking; and -4- 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (e) Whether injured plaintiff/decedent ever changed residence for health reasons, and if so, the residence left and the health reason for leaving. ANSWER: (a) Upon information and belief, plaintiff is unaware ifany residences listed below contained asbestos insulation; (b) Plaintiff did substantial work constructing his current home. (c)- (d) ADDRESS DATES FUEL/ FUEL/ HEATING COOIGNG 179 Mosley Road 1945-1967 Gas Gas Greece, New York 624 Atlantic Avenue 1967-Present Gas Gas Macedon, New York (e) Plaintiff has never changed residences for health reasons. INTERROGATORY NO. 6 Identify each member of the injured plaintiffs/decedents household in the last five years, or during the last five years prior to death, and also state as to each: (a) His age, occupation, and relationship to the injured plaintiff/decedent; and (b) The portion of the last 12 months, or the last 12 months of the decedents life, during which he was a member of the household. ANSWER: Plaintiff lives with his wife, Paula. INTERROGATORY NO. 7 List injured plaintiffs/decedents hobbies or the major leisure activities in which she engaged during the last twenty years, or the last twenty years of his life. If the injured plaintiff/decedent did not have hobbies or participate in leisure activities, describe how she spent his leisure time. -5- 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 ANSWER: Plaintiff enjoys gardening and spending time with his grandchildren. INTERROGATORY NO. 8 Did injured plaintiff/decedent or his spouse ever filefor divorce against the other? If your answer is yes, state the date of suit, itsdisposition, and the date of disposition. ANSWER: No. INTERROGATORY NO. 9 Were injured plaintiff/decedent and his spouse ever separated for any period of more than 48 hours because of a marital disagreement? If your answer is yes, indicate every such incident, stating the reason for the separation and the length of time of each separation. ANSWER: No. INTERROGATORY NO. 10 Was injured plaintiff/decedent ever a party to or a witness in any lawsuit, court or administrative proceeding? If your answer is yes,state: (a) Whether injured plaintiff/decedent was a party or a witness and, if a party, whether she was a plaintiff or a defendant; (b) The titleof the lawsuit or proceeding, the court or agency in which itwas brought and the docket number; -6- 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (c) The nature of the charges or claims and, if injured plaintiff/decedent was a witness, the substance of his testimony. (d) The disposition of the case; and (e) Identify all insurance carriers or administrative agencies that either made payment or declined to make payment with respect to each such lawsuit or claim. ANSWER: Upon information and belief, no. INTERROGATORY NO. 11 Has injured plaintiff/s ever applied and been rejected for a lifeinsurance, medical insurance, or disability insurance policy? If your answer is yes, state with regard to each such event: (a) The identity of the insurer to whom such application was made; (b) The date of such application; (c) The identity of any Physician conducting a physical examination with regard to such application and the date thereof; (d) The reason for such rejection; and (e) Produce all documentation of said application and rejection. ANSWER: No. C. EMPLOYMENT HISTORY INTERROGATORY NO. 12 Have you or anyone on your behalf requested from the Social Security Administration a listing of all of the injured plaintiff s/decedents employers and dates of employment? -7- 202207080612 INDEX Index NO. #: E2021005118 E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 If your answer is yes, attach a copy of such listing to your responses to these interrogatories. If not available, execute and provide a release in the form annexed as an exhibit. ANSWER: Plaintiff will supplement upon receipt of same. INTERROGATORY NO. 13 Identify each and every employer that injured plaintiff/decedent had from the time he was firstemployed to the present, or to the time of his death, including any and all military service, and as to each, state: (a) The period of time injured plaintiff/decedent worked for each such employer; (b) Each position/job titlewhich injured plaintiff/decedent held with each such employer and the dates each such position/job title was held by injured plaintiff/decedent; (c) The nature of the work performed; (d) The location(s) of injured plaintiffs/decedents particular jobsite(s); (e) The nature of the materials or products injured plaintiff/decedent worked with; and (f) Whether said activity involved working in the presence of dust, pollutants, or toxic substances and, if so: (i) Identify by name or type said dust, pollutants, or toxic substances; (ii) State whether any suction device, fan, or other ventilation system was present at the jobsite; and (iii) State whether the employer or any govemmental agency or union took air samplings at the jobsite and, ifso, identify the persons who took the air samplings, the dates such samplings were taken and the persons presently having possession or control of any documents relating to such air samplings. ANSWER: -8- 202207080612 INDEX NO. E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 - Based on Personal Knowledge CHART A 22(a) Name and Address Dates of Jobsite Ashestos Products used Other Asbestos of Employers Employment by Plaintiff personally Products which (Include name of Plaintiff Manufacturer if contended he was known) exposed to (Include name of Manufacturer if known) Xerox Corporation 1967-2003 Xerox " Boilers manufactured by Cleaver-Brooks " Pumps manufactured by Buffalo Pumps, Goulds, Bell & Gossett, DeLaval, Dutco, Union, and Armstrong " Valves manufactured by Crane, Grinnell Edward, Velan, William Powell, and Jamesbury " Streamtraps manufactured by Armstrong, Sarco, and Watts " Insulation installed by Rochester Industrial Insulation, R.E. Hebert, and William Summerhays " Gaskets manufactured by Garlock -9- 202207080612 INDEX NO. E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 INTERROGATORY NO. 14 If injured plaintiff/decedent was self-employed at any time, identify each such business, and as to each, state: (a) The period during which injured plaintiff/decedent was self-employed; (b) The nature of the work performed; (c) The location(s) of injured plaintiffs/decedent's particular jobsite(s); (d) The nature of the materials or products injured plaintiff/decedent worked with; and (e) Whether said activity involved working in the presence of dust, pollutants, or toxic substances and, ifso: (i) Identify by name or type said dust, pollutants, or toxic substances; (ii) State whether any suction device, fan, or other ventilation system was present at the jobsite; and (iii) State whether the employer, any governmental agency, any union or any other person took air samplings at any jobsite at which injured plaintiff/decedent worked, and, ifso, identify the person(s) who took the air samples, the dates such air samples were taken and the persons presently having possession or control of any documents relating to such air samples. ANSWER: No. INTERROGATORY NO. 15 Did injured plaintiff/decedent ever lose a job, change jobs or change his position with an employer for health reasons? If your answer is yes, state as to each such event: (a) The employer and job position which injured plaintiff/decedent left; -10- 202207080612 INDEX FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index NO. #: E2021005118 E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (b) The date of such event; (c) The health reason for such event; and (d) The new employer and/or job position which injured plaintiff/decedent next assumed. ANSWER: No. INTERROGATORY NO. 16 Are you aware of, have you ever seen or do you or your attorney possess or have access to any photographs, charts, drawings, diagrams or other graphic representations depicting work conditions at work sites where you claim injured plaintiff/decedent was exposed to asbestos materials and/or asbestos-containing products? If your answer is yes, with respect to each: (a) Identify each such photograph or other document, including a statement as to which views, scenes or objects itpurports to depict, the person who took or prepared each such photograph or other document, and the date taken or prepared; (b) State whether the photograph or other document was prepared on your behalf or on behalf of other persons allegedly exposed to asbestos or as a result of circumstances relating to this or any other lawsuit; and (c) Attach a copy. -11- 202207080612 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM INDEX NO. E2021005118 Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 ANSWER: Plaintiff will supplement as we proceed through discovery in this action. INTERROGATORY NO. 17 During the period of time for which you claim injured plaintiff/decedent was exposed to asbestos materials and/or asbestos-containing products, did injured plaintiff/decedent share a household with any other person(s) who worked or was employed outside the household? If your answer is yes, identify: (a) Each such other person; (b) The period(s) of time each such other person shared such household; (c) The period(s) of time each such other person worked or was so employed; (d) The nature of each job held or job titlefor each such other person in each such period of time; and (e) Each and every employer of each such other person in each such period of time. ANSWER: Upon information and belief, no. Plaintiff reserves the right to supplement this response. INTERROGATORY NO. 18 Was injured plaintiff/decedent ever exposed to or did injured plaintiff/decedent ever use, inhale or ingest any of the following substances on a regular basis or at work? If your answer is yes, state the date(s), place(s), and circumstances thereof: (a) Acids; (b) Aluminum; (c) Ammonia; (d) Arsenic; (e) Barium; (f) Beryllium; -12- 202207080612 INDEX Index NO. E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM #:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (g) Butanol; (h) Cadmium; (i) Carborundum; (j) Chloreothylene; (k) Chlorine; (1) Chromate; (m) Chromite; (n) Chromium; (0) Coal and/or coal dust; (p) Coal tar; (q) Cotton dust; (r) Creosote; (s) Epoxy; (t) Ethanol; (u) Formaldehyde; (v) Grinding dust; (w) Iron; (x) Isocyanates; (y) Isopropanol; (z) Lead; (aa) Live chickens; (bb) Manganese; (cc) Nickel; (dd) Nitrogen dioxide; (ee) Nuclear radiation; (ff) Ozone; (gg) Petroleum distillates; (hh) Phosgene; (ii) Radiation; (jj) Silica; (kk) Titanium; (11) Toluene; (mm) Welding smoke or fumes; (nn) Zylene; (oo) Zinc. ANSWER: Upon information and belief, plaintiff was not exposed to any of the substances identified in Interrogatory No. 18. However, to the extent that plaintiff suffers from severe asbestosis, plaintiff alleges that his disease was caused by exposure to asbestos. -13- 202207080612 INDEX FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index NO. #: E2021005118 E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 INTERROGATORY NO. 19 From the time of his birth to the present or to the time of his death, did injured plaintiff/decedent ever use cigarettes, cigars, pipes, smokeless tobacco, or any other tobacco substance? If your answer is yes, state the following: (a) The brand and type of tobacco products(s) used (e.g., filter, non-filter, chewing tobacco); (b) The period(s) during which she used each such product; (c) The amount of the product used per day, during each period of time (e.g., 2 packs of cigarettes per day for 2 years); (d) Whether injured plaintiff/decedent was ever told that she was suffering from any disease or illness contributed to or caused by tobacco, and ifso, identify each person who gave injured plaintiff/decedent any such advice, the dates on which the advice was given, and state exactly what, ifanything, injured plaintiff/decedent did in response to that advice; (e) Whether the injured plaintiff/decedent was ever advised that use of tobacco products could adversely affect his health, and ifso, identify each person who gave injured plaintiff/decedent any such advice, the dates on which the advice was given, and state exactly what, ifanything, injured plaintiff/decedent did in response to that advice; and (f) Whether injured plaintiff/decedent was ever advised to stop using tobacco products, and ifso, identify each person who gave injured plaintiff/decedent any such advice, the dates on which the advice was given, and state exactly what, ifanything, injured plaintiff/decedent did in response to that advice. -14- 202207080612 INDEX NO. E2021005118 Index#:E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 ANSWER: Plaintiff occasionally smoked a pipe after dinner from approximately 1975 to 1985. Plaintiff has not used tobacco products in the last 35 years. INTERROGATORY NO. 20 For each spouse and member of injured plaintiff s/decedent's household, from injured plaintiffs/decedents birth until the present time, state whether each individual ever used cigarettes, cigars, pipes, smokeless tobacco, or any other tobacco substance, and if so, state the following for each: (a) The brand and type of tobacco product(s) used (e.g., filter,non-filter, chewing tobacco); (b) The period(s) during which he used each such product; and (c) Whether he was ever told by a doctor that he isor was suffering from any disease or illness caused or contributed to by his use of tobacco, and if so,when and by whom. ANSWER: Plaintiff will supplement as we proceed through discovery in this action. INTERROGATORY NO, 21 If injured plaintiff/decedent ever worked in an office or other enclosed space, state whether injured plaintiff/decedent shared a room with anyone who used or smoked cigarettes, cigars or pipes. ANSWER: Plaintiff will supplement as we proceed through discovery in this action. INTERROGATORY NO. 22 Did injured plaintiff/decedent consume alcoholic beverages? If your answer is yes, state the following: -15- 202207080612 INDEX NO. E2021005118 FILED: MONROE COUNTY CLERK 07/08/2022 12:15 PM Index#:E2021005118 NYSCEF DOC. NO. 145 RECEIVED NYSCEF: 07/08/2022 (a) The type of alcoholic beverages consumed; (b) The periods during which injured plaintiff/decedent consumed such alcoholic beverage; (c) The amount of such beverage injured plaintiff/decedent consumed each day during each period of use; and (d) Whether injured plaintiff/decedent was ever treated for any illness or disease related to his consumption of alcoholic beverages or was ever advised to reduce his consumption. ANSWER: Plaintiff occasionally will drink a glass of wine or beer, INTERROGATORY NO. 23 Did injured plaintiff/decedent ever take any prescription medication, any non-prescription medication, or any other drugs for the treatment of respiratory problems, cardiac problems, gastrointestinal problems, cancer, or any chronic health condition or illness? If your answer is yes, state for each: (a) The medication or drug taken; (b) The amount of medication or drug taken and the period over which itwas taken; (c) The reason fortaking the medication or drug; and (d) If the medication was prescribed: (i) Identify the person prescribing the medication; (ii) Identify the pharmacy filling the prescription; and (iii) Produce any document reflecting the prescribing, filling or payment of any prescription medication. -16- 202207080612 INDEX Index NO. E2021005118 #:E2021005118 FILED: MONROE COUNTY