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  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
  • Brooks, Seth vs. 3m Company et al Asbestos document preview
						
                                

Preview

Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number 1 12/30/2022 HG COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, SS. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT SETH BROOKS, as Personal Representative of the ESTATE OF SUSAN G. BROOKS, Plaintiff, v. Civil Action No. 3M COMPANY, f/k/a MINNESOTA MINING AND MANUFACTURING; AIR & LIQUID SYSTEMS CORPORATION, COMPLAINT successor by merger to BUFFALO PUMPS, INC.; PLAINTIFF ALFA LAVAL, INC., individually and as DEMANDS TRIAL successor-in-interest to DeLAVAL BY JURY SEPARATOR COMPANY and SHARPLES, INC.; ANCHOR/DARLING VALVE COMPANY; ATWOOD & MORRILL CO., INC. d/b/a WEIR VALVES & CONTROLS USA INC.; AURORA PUMP COMPANY; A.W. CHESTERTON COMPANY; BELL & GOSSETT CO.; BW/IP, INC., f/k/a BORG WARNER INDUSTRIAL PRODUCTS, INC., successor to BORG WARNER CORP. and BYRON JACKSON PUMPS; CARRIER CORPORATION f/k/a BRYANT HEATING AND COOLING SYSTEMS; CARVER PUMP COMPANY, INC.; 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; CLEAVER-BROOKS COMPANY, f/k/a AQUA CHEM, INC.; CLIFTON ASSOCIATES, INC., f/k/a JOHNSON ASBESTOS CORPORATION; 1 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number CURTISS-WRIGHT FLOW CONTROL CORPORATION, individually and as successor-in-interest to Farris Valves and Sprague Pumps; EATON AEROQUIP LLC, individually and as successor-in-interest to AEROQUIP CORPORATION and as successor-in- interest to VICKERS INCORPORATED; ECKEL INDUSTRIES, INC.; ELECTROLUX HOME PRODUCTS, INC., individually and as successor-in-interest to COPES-VULCAN; EXOMET, INC.; FERRO ENGINEERING, a division of OGLEBAY NORTON MARINE SERVICES COMPANY; FLOWSERVE US, INC., solely as successor to ROCKWELL MANUFACTURING COMPANY, EDWARD VALVES, INC., NORDSTROM VALVES, INC., and EDWARD VOGT VALVE COMPANY; FMC CORPORATION, individually and as successor-in-interest to NORTHERN PUMP COMPANY and NORTHERN ORDINANCE; FOSECO, INC.; GARDNER DENVER, INC.; GENERAL ELECTRIC COMPANY; GORMAN-RUPP COMPANY (THE), individually and as successor-in-interest to C.H. WHEELER MANUFACTURING COMPANY; GOULDS PUMPS, INCORPORATED; GRINNELL LLC, f/k/a GRINNELL FIRE PROTECTION SYSTEMS COMPANY, INC.; H.M. ROYAL, INC.; HOWDEN NORTH AMERICA, INC., f/k/a HOWDEN BUFFALO INC., individually and as successor-in-interest to BUFFALO FORGE COMPANY; IMO INDUSTRIES, INC., f/k/a/ DELAVAL, INC.; INDUCTOTHERM INDUSTRIES, INC.; 2 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number ITT LLC, individually and as successor-in-interest to BELL & GOSSETT, MARLOW PUMPS, and FOSTER VALVES; JENKIN BROS.; MALCOLM G. STEVENS, INC.; MODERN EQUIPMENT COMPANY; NASH ENGINEERING COMPANY (THE); NEW ENGLAND INSULATION COMPANY; OCCIDENTAL CHEMICAL CORPORATION, individually and as successor-in-interest to DUREZ; O.C. KECKLEY COMPANY; REDCO CORP., individually and as successor-in- interest to NATIONAL BOILER CO., NATIONAL RADIATOR CORPORATION, NATIONAL-US RADIATOR CORPORATION and PACIFIC STEEL BOILER; R.T. VANDERBILT COMPANY, INC.; ROGERS CORPORATION; SPENCE ENGINEERING COMPANY, INC.; SUPERIOR BOILER WORKS, INC.; SUPERIOR LIDGERWOOD MUNDY CORP., a/k/a LIDGERWOOD MANUFACTURING CO., individually and as successor to M.T. DAVIDSON CO.; TACO, INC.; UNION CARBIDE CORPORATION; VELAN VALVE CORP.; VIKING PUMP, INC.; WARREN PUMPS, LLC, individually and as successor-in-interest to QUIMBY PUMP COMPANY, INC.; WHITING CORPORATION; WT/HRC CORPORATION; and YORK INTERNATIONAL CORPORATION. Defendants. 3 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number PARTY PLAINTIFFS 1. The Plaintiff, SETH BROOKS, as Personal Representative of the ESTATE OF SUSAN G. BROOKS, resides at 482 Hanover Center Road, Etna, New Hampshire 03750. PARTY DEFENDANTS 2A. Defendant 3M COMPANY, f/k/a MINNESOTA MINING AND MANUFACTURING, is a Delaware corporation with its principal place of business at 3M Center, Tax Building 224-5N40, St. Paul, Minnesota 55101 and a registered agent in Massachusetts. 3M COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer defendant. 2B. Defendant AIR & LIQUID SYSTEMS CORPORATION, successor-by-merger to BUFFALO PUMPS, INC., is a Pennsylvania corporation with its registered agent at CT Corporation System, 116 Pine Street, Suite 320, Harrisburg, Pennsylvania 17101. AIR & LIQUID SYSTEMS CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2C. Defendant ALFA LAVAL, INC., sued individually and as successor-in-interest to DeLAVAL SEPARATOR CO., is a New Jersey corporation with its principal place of business at 5400 International Trade Dr., Richmond, Virginia 23231 and a registered agent in Massachusetts. ALFA LAVAL, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2D. Defendant ANCHOR/DARLING VALVE COMPANY is a Pennsylvania corporation with its principal place of business at 2300 Computer Avenue Suite L-61, Willow Grove, Pennsylvania 19090. ANCHOR/DARLING VALVE COMPANY has conducted business 4 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2E. Defendant ATWOOD & MORRILL CO., INC. d/b/a WEIR VALVES 7 CONTROLS USA INC., is a domestic corporation with its principal place of business at 29 Old Right Road, Ipswich, MA 01938 and a registered agent in Massachusetts. ATWOOD & MORRILL CO., INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2F. Defendant AURORA PUMP COMPANY is a foreign corporation with its principal place of business at 800 Airport Road, North Aurora, Illinois 60542. AURORA PUMP COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2G. Defendant A.W. CHESTERTON COMPANY is a domestic corporation with its principal place of business at 500 Unicorn Park Drive, Woburn, Massachusetts 01801-3345. A.W. CHESTERTON COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer and equipment defendant. 2H. Defendant BELL & GOSSETT CO. is a duly organized foreign corporation with its principal place of business at 8200 N. Austin Avenue, Morton Grove, Illinois 60053. BELL & GOSSETT CO. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2I. Defendant BW/IP, INC., formerly known as BORG WARNER INDUSTRIAL PRODUCTS, INC., successor to BORG WARNER CORP., ALDRICH PUMPS and BYRON JACKSON PUMPS, was and is a duly organized foreign corporation with its principal place of 5 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number business at 5215 North O’Connor Boulevard, Suite 2300, Irving, Texas 75039. BW/IP, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2J. Defendant CARRIER CORPORATION is a foreign corporation with its principal place of business at One Carrier Place, Farmington, Connecticut 06032 and a registered agent in Massachusetts. CARRIER CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2K. Defendant CARVER PUMP COMPANY, INC. is a Delaware corporation with its principal place of business at 2415 Park Avenue, Muscatine, Iowa 52761. CARVER PUMP COMPANY, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2L. Defendant CBS CORPORATION, f/k/a VIACOM, INC., successor by merger to CBS CORPORATION, a Pennsylvania corporation, f/k/a WESTINGHOUSE ELECTRIC CORPORATION, is a Delaware corporation with its principal place of business at 1515 Broadway, New York, New York 10036 and a registered agent in Massachusetts. CBS CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2M. Defendant CLEAVER-BROOKS COMPANY, f/k/a AQUA CHEM, INC. is a foreign corporation with its principal place of business at 11950 West Lake Park Drive, Milwaukee, WI 53224. CLEAVER-BROOKS COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 6 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number 2N. Defendant CLIFTON ASSOCIATES, INC., f/k/a JOHNSON ASBESTOS CORPORATION, is a Massachusetts corporation with its principal place of business at 1434 Memorial Avenue in West Springfield, MA. CLIFTON ASSOCIATES, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as a supplier Defendant. 2O. Defendant CURTISS WRIGHT FLOW CONTROL CORPORATION, individually and as successor-in-interest to FARRIS VALVES and SPRAGUE PUMPS, is a New York corporation with its principal place of business at 15801 Brixham Hill Avenue, Suite 200, Charlotte, North Carolina 28277. CURTISS-WRIGHT FLOW CONTROL CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2P. Defendant EATON AEROQUIP LLC, individually and as successor-in-interest to AEROQUIP CORPORATION and as successor-in-interest to VICKERS INCORPORATED, is an Ohio corporation with its principal place of business at 1000 Eaton Boulevard, Cleveland, Ohio 44122 and a registered agent in Massachusetts. EATON AEROQUIP LLC has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer defendant. 2Q. Defendant ECKEL INDUSTRIES, INC. is a Massachusetts corporation with registered agent Joe Tunnera located at its principal place of business of 155 Fawcett Street, Cambridge, Massachusetts 02138. ECKEL INDUSTRIES, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant is being sued as a supplier defendant. 2R. Defendant ELECTROLUX HOME PRODUCTS, INC., individually and as 7 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number successor-in-interest to COPES-VULCAN, is a Delaware corporation with its principal place of business at 10200 David Taylor Drive, Charlotte, NC 28262, and a registered agent in Massachusetts. ELECTROLUX HOME PRODUCTS, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment and supplier Defendant. 2S. Defendant EXOMET, INC. is an Ohio corporation with its principal place of business in Ohio and its registered agent located at CT Corp System, 1300 E 9th Street, Cleveland, Ohio 44144. EXOMET, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer defendant. 2T. Defendant FERRO ENGINEERING, a division of ON MARINE SERVICES COMPANY, a Delaware corporation with a registered agent at National Registered Agents, Inc., 160 Greentree Drive, Suite 101, Dover DE. FERRO ENGINEERING has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer defendant. 2U. Defendant FLOWSERVE US, INC., solely as successor to ROCKWELL MANUFACTURING COMPANY f/k/a ROCKWELL AUTOMATION, INC., DURCO INTERNATIONAL, EDWARD VALVES, INC., EDWARD VOGT VALVE COMPANY and NORDSTROM VALVES, INC. was and is a foreign corporation with its principal place of business at 2515 N. O’Connor Boulevard, Suite 2300, Irving, TX 75039 and a registered agent in Massachusetts. FLOWSERVE US, INC., through the above-named predecessors, has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2V. Defendant FMC CORPORATION, individually and as successor-in-interest to 8 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number NORTHERN PUMP COMPANY, is a foreign corporation with its principal place of business at 1735 Market Street, Philadelphia, Pennsylvania 19103 and a registered agent in Massachusetts. FMC CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2W. Defendant FOSECO, INC., individually and as successor-in-interest to EXOMET, INC., is a Delaware corporation with its principal place of business in Ohio and its registered agent at The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801. FOSECO, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer defendant. 2X. Defendant GARDNER DENVER, INC. is a foreign corporation with its principal place of business at 1800 Gardner Expressway, Quincy Illinois 62301. GARDNER DENVER, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2Y. Defendant GENERAL ELECTRIC COMPANY is a New York corporation with its principal place of business at 3135 Easton Turnpike, Fairfield, Connecticut 06828 and a registered agent in Massachusetts. GENERAL ELECTRIC COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2Z. Defendant GORMAN-RUPP COMPANY (THE), sued individually and as successor-in-interest to C.H. WHEELER MANUFACTURING, is an Ohio corporation with its principal place of business at 600 S. Airport Road, Mansfield, OH 44903. GORMAN-RUPP COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 9 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number 2AA. Defendant GOULDS PUMPS INCORPORATED. is a New York corporation with its principal place of business at 240 Fall Street, Seneca Falls, NY 13148 and a registered agent in Massachusetts. GOULDS PUMPS, INCORPORATED has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2BB. Defendant GRINNELL LLC, f/k/a GRINNELL FIRE PROTECTION SYSTEMS COMPANY, INC. is a foreign corporation with its principal place of business at 1501 Yamato Road, Boca Raton, FL 33431 and a registered agent in Massachusetts. GRINNELL LLC has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2CC. Defendant H.M. ROYAL, INC. is a New Jersey corporation with its principal place of business at 689 Pennington Avenue, Trenton, NJ 08618 and a registered agent in Massachusetts. H.M. ROYAL, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a supplier defendant. 2DD. Defendant HOWDEN NORTH AMERICA, INC., f/k/a HOWDEN BUFFALO INC., sued individually and as successor-in-interest to BUFFALO FORGE COMPANY, is a Delaware corporation with its principal place of business at 2475 George Urban Boulevard, Suite 120, Depew, NY 14043 and a registered agent in Massachusetts. HOWDEN NORTH AMERICA, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2EE. Defendant IMO INDUSTRIES, INC., sued individually and as successor-in- interest to DELAVAL STEAM TURBINE COMPANY, is a Delaware corporation with its principal place of business at 200 American Metro Blvd., Suite 111, Hamilton, New Jersey 08619 10 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number and a registered agent in Massachusetts. IMO INDUSTRIES, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2FF. Defendant INDUCTOTHERM INDUSTRIES, INC. is a New Jersey corporation with its principal place of business at 10 Indel Ave., P.O. Box 157, Rancocas, NJ 08073. INDUCTOTHERM INDUSTRIES, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2GG. Defendant ITT LLC, individually and as successor-in-interest to BELL & GOSSETT, MARLOW PUMPS and FOSTER VALVES, is a foreign corporation with its principal place of business at 1133 Westchester Avenue, Suite N300, White Plains, NY 10604. ITT LLC has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2HH. Defendant JENKINS BROS. was a New Jersey corporation with its principal place of business at 510 Main Street, Bridgeport, Connecticut 06609. JENKINS BROS. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment defendant. 2II. Defendant MALCOLM G. STEVENS, INC. is a domestic corporation incorporated under the laws of the Commonwealth of Massachusetts with registered agent William Stevens located at its principal place of business at 12 Progress Avenue, Tyngsboro, MA 01879. MALCOLM G. STEVENS, INC. conducts business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a supplier defendant. 2JJ. Defendant MODERN EQUIPMENT COMPANY is a Wisconsin corporation 11 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number with its registered agent at CT Corporation System, 301 S Bedford Street, Suite 1, Madison, WI MODERN EQUIPMENT COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment and supplier defendant. 2KK. Defendant NASH ENGINEERING COMPANY (THE) is a Connecticut corporation with its principal place of business at 9 Trefoil Drive, Trumball, CT 06611 and a registered agent in Massachusetts. NASH ENGINEERING COMPANY conducts business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2LL. Defendant NEW ENGLAND INSULATION COMPANY is a Massachusetts corporation with its principal place of business at 960 Turnpike Street #27, Canton, MA 02021. NEW ENGLAND INSULATION COMPANY has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a supplier defendant. 2MM. Defendant OCCIDENTAL CHEMICAL CORPORATION, individually and as successor-in-interest to DUREZ, is a New York corporation with its principal place of business at 5005 LBJ Freeway, Dallas, TX 75244 and a registered agent in Massachusetts. OCCIDENTAL CHEMICAL CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer and supplier defendant. 2NN. Defendant O.C. KECKLEY COMPANY is a foreign corporation with its principal place of business at 3400 Cleveland Street, Skokie, IL 60076. O.C. KECKLEY COMPANY conducts business in and has derived substantial revenue from the Commonwealth of 12 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number Massachusetts. This defendant has been sued as an equipment defendant. 2OO. Defendant REDCO CORP. sued individually and as successor-in-interest to CRANE CO.; NATIONAL BOILER CO., NATIONAL RADIATOR CORPORATION, NATIONAL-US RADIATOR CORPORATION and PACIFIC STEEL BOILER, is a Delaware corporation with its principal place of business at 100 First Stamford Place, Stamford, Connecticut 06902 and a registered agent of the Corporation Trust Company located at 1209 Orange Street, Corporation Trust Center, Wilmington, Delaware 19801. REDCO CORP. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2PP. Defendant R.T. VANDERBILT COMPANY, INC. is a New York corporation with its principal place of business at 30 Winfield Street, Norwalk, Connecticut 06856. R.T. VANDERBILT COMPANY, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer and supplier defendant. 2QQ. Defendant ROGERS CORPORATION is a Massachusetts corporation with its principal place of business in Arizona and its registered agent for service at Corporation Service Company, 84 State Street, Boston, MA 02109. ROGERS CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer and supplier defendant. 2RR. Defendant SPENCE ENGINEERING COMPANY, INC. is a foreign corporation with its principal place of business at 150 Coldenham Road, Walden, NY 12586. SPENCE ENGINEERING COMPANY, INC. has conducted business in and derived substantial revenue 13 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2SS. Defendant SUPERIOR BOILER WORKS, INC. is a corporation based in Kansas, with its principal place of business at 3524 E 4th Ave., Hutchinson, KS 67501-1960, and a registered of R. Doug Wright, 3524 E 4th Ave., Hutchinson, KS 67501. SUPERIOR BOILER WORKS, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment and supplier Defendant. 2TT. Defendant SUPERIOR LIDGERWOOD MUNDY CORP., a/k/a LIDGERWOOD MANUFACTURING CO., individually and as successor to M.T. DAVIDSON CO., is a foreign corporation with its principal place of business at 302 Grand Avenue, Superior, WI 54880. SUPERIOR LIDGERWOOD MUNDY CORP has conducted business in and derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2UU. Defendant TACO, INC. is a Rhode Island corporation with its principal place of business at 1160 Cranston Street, Cranston, Rhode Island 02920 and a registered agent in Massachusetts. TACO, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2VV. Defendant UNION CARBIDE CORPORATION is a New York corporation with its principal place of business at 39 Old Ridgebury Road, Danbury, CT 06817 and a registered agent in Massachusetts. UNION CARBIDE CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as a manufacturer and supplier defendant. 14 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number 2WW. Defendant VELAN VALVE CORP. is a foreign corporation with its principal place of business at 94 Avenue C, Williston, VT 05495. VELAN VALVE CORP. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2XX. Defendant VIKING PUMP, INC. is a Delaware corporation with its principal place of business at 406 State Street, Cedar Falls, IA 50613. VIKING PUMP, INC. has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 2YY. Defendant WARREN PUMPS, LLC, individually and as successor to THE QUIMBY PUMP COMPANY, is a Delaware limited liability corporation with its principal place of business at 82 Bridges Avenue, PO Box 969, Warren, MA and a registered agent in Massachusetts. WARREN PUMPS, LLC has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2ZZ. Defendant WHITING CORPORATION is a foreign corporation with its registered agent of Illinois Corporation Service Company, 801 Adlai Stevenson Drive, Springfield, IL 62703. WHITING CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as an equipment defendant. 2AAA. Defendant WT/HRC CORPORATION is an Illinois corporation based on Illinois, with its registered agent of National Registered Agents, Inc., 208 SO Lasalle Street, Suite 814, Chicago, IL 60604. WT/HRC CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This defendant has been sued as 15 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number an equipment defendant. 2BBB. Defendant YORK INTERNATIONAL CORPORATION is a Delaware corporation with its principal place of business at 507 East Michigan Street, Milwaukee, WI 53202 and a registered agent in Massachusetts. YORK INTERNATIONAL CORPORATION has conducted business in and has derived substantial revenue from the Commonwealth of Massachusetts. This Defendant has been sued as an equipment Defendant. 3. As used in this Complaint, the terms “defendant,” “defendants,” or “defendant corporations” shall include the party defendants identified in paragraphs 2A-2BBB hereof, and their predecessors and successors, which shall include, but not be limited to, any person, corporation, company of business entity which formed part of any combination, consolidation, merger or reorganization from which any party defendant was created or was the surviving corporation of other entity, or into which any party defendant was merged, consolidated, or reorganized; whose assets, stock, property, employees, customers, good will, products, or product line was acquired by or from any party defendant; or which was dominated or controlled by any party defendant to such an extent that said party defendant was the “alter ego” of said corporation. 4. The Plaintiff’s causes of action arise from the defendants: (a) transacting business in the Commonwealth of Massachusetts; (b) contracting to supply and/or sell goods in the Commonwealth of Massachusetts; (c) doing or causing a tortious act to be done within the Commonwealth of Massachusetts; and/or (d) causing the consequence of a tortious act to occur within the Commonwealth of Massachusetts. FACTUAL BACKGROUND 5. The asbestos, and asbestos-containing and/or asbestos-laden products to which SUSAN G. BROOKS (hereinafter referred to as “Plaintiff’s Decedent”), was exposed were mined, 16 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number milled, manufactured, fabricated, contracted, installed, supplied, distributed, sold, and/or used by the defendant corporations, acting through their duly authorized agents, servants, and employees, who were then and there acting in the course and scope of their employment and in furtherance of the business of the defendants. 6. At all times pertinent hereto, the defendant corporations were engaged in the business of mining, milling, manufacturing, fabricating, contracting, installing, supplying, distributing, selling, and/or using asbestos and asbestos-containing products. 7. At all times pertinent hereto, the asbestos products were products mined, milled, manufactured, fabricated, contracted, installed, supplied, distributed, sold, and/or used by the defendant corporations and reached Plaintiff’s Decedent without any substantial change in the condition of the product or products from the time that they were sold. 8. Plaintiff’s Decedent was exposed to Defendants’ asbestos and asbestos-containing products on a take-home basis from her father based on his work at industrial worksites in Massachusetts in the 1950s and 1960s. 9. During the periods of time set forth in Paragraph 8, Plaintiff’s Decedent was exposed to and did inhale and/or ingest asbestos dust, fibers, and particles, which dust, fibers, and particles came from the asbestos or asbestos-containing products which were manufactured, fabricated, supplied, sold, distributed, installed, serviced, maintained, repaired, and/or used by the defendant corporations. 10. As a direct and proximate result of working with, around, and/or near asbestos materials utilized, mined, milled, manufactured, designed, tested, packaged, furnished, sold, supplied, distributed, delivered, installed, and otherwise placed in the stream of commerce by the defendants, Plaintiff’s Decedent SUSAN G. BROOKS developed malignant mesothelioma, an 17 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number asbestos-related injury, and was diagnosed with this disease on or about April of 2022. 11. Plaintiff’s Decedent suffered serious personal injuries, endured great pain of body and mind, suffered severe mental anguish and distress, and required to undergo medical treatment, care, and expense, until her death caused by malignant mesothelioma on July 12, 2022. COUNT ONE: ALLEGATIONS AGAINST MANUFACTURING DEFENDANTS 12. All of the allegations contained in the previous paragraphs are re-alleged. 13. Plaintiff alleges that Plaintiff’s Decedent was exposed to asbestos-containing products and/or machinery requiring or calling for the use of asbestos and/or asbestos-containing products in his occupation. Defendants, 3M COMPANY; A.W. CHESTERTON COMPANY; EATON AEROQUIP LLC; EXOMET, INC.; FERRO ENGINEERING; FOSECO, INC.; OCCIDENTAL CHEMICAL CORPORATION; R.T. VANDERBILT COMPANY, INC.; ROGERS CORPORATION; and UNION CARBIDE CORPORATION (hereinafter referred to as the “Manufacturer Defendants”), or their predecessors-in-interest, are, or at times material hereto have been, engaged in the mining, processing and/or manufacturing, sale and distribution of asbestos and asbestos-containing products and/or machinery requiring or calling for the use of asbestos and/or asbestos-containing products. Plaintiff will show that Plaintiff’s Decedent had been exposed, on numerous occasions, to asbestos-containing products and/or machinery requiring or calling for the use of asbestos and/or asbestos-containing products produced and/or sold by defendants and, in so doing, had inhaled great quantities of asbestos fibers. Further, Plaintiff alleges, as more specifically set out below, that Plaintiff’s Decedent suffered injuries proximately caused by his exposure to asbestos-containing products designed, manufactured, and sold by defendants. In that each exposure to such products caused or contributed to Plaintiff’s Decedent’s 18 Date Filed 12/30/2022 2:49 PM Superior Court - Middlesex Docket Number injuries, Plaintiff says that the doctrine of joint and several liability should be extended to apply to each defendant herein. 14. Plaintiff’s Decedent was exposed to asbestos-containing products and/or machinery requiring or calling for the use of asbestos and/or asbestos-containing products that were manufactured, designed, and/or distributed by the Manufacturer Defendants and/or their predecessors-in-interest. Plaintiff will show that the defective design and condition of the products rendered such products unreasonably dangerous, and that the asbesto