On April 07, 2021 a Letter,Correspondence was filed involving a dispute between Harry J Hampson, and Amchem Products, Inc., N K A Rhone Poulenc Ag Company, N K A Bayer Cropscience Inc, Arvinmeritor, Inc., Individually And As Successor-In-Interest To Rockwell Automotive, Cbs Corporation, F K A Viacom Inc., Successor By Merger To Cbs Corporation, F K A Westinghouse Electric Corporation, Cummins, Inc, Dco Llc F K A Dana Companies, Llc, Eaton Corporation, Individually And As Successor -In-Interest To Cutler-Hammer, Inc, General Electric Company, Grizzly Friction Products, A Division Of Nuturn Corporation, Hennessy Industries, Inc. Individually And As Successor-In-Interest To Ammco, Honeywell International, Inc., F K A Allied Signal, Inc. Bendix, Mack Trucks, Inc, Mccord Corporation, Morse Tec Llc, F K A Borg Warner Morse Tec Llc And Successor-By-Merger To Borg-Warner Corporation, Navistar, Inc., A K A International Truck & Engine Corp. F K A International Harvester, Inc, Paccar, Inc., Individually And Through Its Division, Peterbilt Motors Co, Pfizer, Inc., Pneumo Abex Llc, Successor In Interest To Abex Corporation, Standard Motor Products, Inc, Union Carbide Corporation, U.S. Rubber Company, for Torts - Asbestos in the District Court of Suffolk County.
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NUNZIO MOUDATSOS DIRECT: (212) 453-0776 NMOUDATSOS@GRSM.COM ATTORNEYS AT LAW 1 BATTERY PARK PLAZA, 28TH FLOOR NEW YORK, NY 10004 WWW .GRSM.COM May 4, 2021 VIA NYSCEF Hon. Jerry Garguilo J.S.C Suffolk County Supreme Court 400 Carleton Avenue Central Islip, NY 11722 Re: Harry J. Hampson v. Amchem Products Inc., et al. Supreme Court of the State of New York, Suffolk County Index No.: 606219/2021 Dear Justice Garguilo: Our office represents defendant Hennessy Industries, LLC (“Hennessy”) in the above-referenced action. Please be advised that, pursuant to the enclosed executed Stipulation of Discontinuance, annexed hereto as “Exhibit A,” plaintiffs have agreed to discontinue this action against Hennessy. Accordingly, we hereby submit the enclosed proposed Order of Discontinuance based on the Stipulation, which serves to dismiss all claims and cross-claims against our client. We are notifying all counsel in this matter and, absent a written objection, we ask that the court execute this Order of Dismissal and Stipulation and arrange for filing via NYSCEF. Should you have any questions or require additional information, please contact our office at your convenience. Respectfully, GORDON REES SCULLY MANSUKHANI, LLP Nunzio Moudatsos Practice Group Manager – NY Toxic Tort Enclosures cc: All Counsel via NYSCEF 1235959/58172121v.1 EXHIBIT A SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK – – – – – – – – – – – – – – – – – – – – – – – – – – – – –– – – x HARRY J. HAMPSON, Index No.: 606219/2021 Plaintiff(s), -against- STIPULATION OF DISCONTINUANCE AMCHEM PRODUCTS, INC., et al., Defendants. – – – – – – – – – – – – – – – – – – – – – – – – – – – – –– – – x IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned, the attorneys of record for the plaintiff and the defendant HENNESSY INDUSTRIES, LLC, incorrectly s/h/a “HENNESSY INDUSTRIES, INC. Individually and as successor-in-interest to AMMCO” (hereinafter “HENNESSY INDUSTRIES, LLC”), in the above-entitled action, that whereas no party hereto is an infant or incompetent person for whom a committee has been appointed and no person not a party has an interest in the subject matter of the action, the above-entitled action be, and the same hereby is discontinued with prejudice. IT IS ORDERED, that upon notice to all co-defendants, all claims and cross claims as to HENNESSY INDUSTRIES, LLC are hereby dismissed with prejudice and without costs to either party as against each other. May 4, 2021 Dated: ______________________ New York, New York _____________________________________ _____________________________________ Michael Fanelli, Esq. Virginia Squitieri, Esq. WEITZ & LUXENBERG P.C. GORDON REES SCULLY MANSUKHANI LLP Attorneys for Plaintiffs Attorneys for Defendant 700 Broadway HENNESSY INDUSTRIES, LLC New York, NY 10003 One Battery Park Plaza, 28th Floor New York, NY 10004 SO ORDERED this _____ day of _________, 2021 ___________________________________ 1235959/58132593v.1 HON. JERRY GARGUILO, J.S.C.