Motion-Secondary: GERALD METALS, LLC Et Al v. CERTAIN UNDERWRITERS AT INTERNATIONAL UNDERWRITING

On January 26, 2017 a Motion-Secondary was filed involving a dispute between Gerald Metals, Llc, Gerald Metals S.A., and Certain Underwriters At International Underwriting Association Of London, for C20 - Contracts - Insurance Policy in the District Court of Fairfield County.

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DOCKET NO. FST-CV17-6031032-S

GERALD METALS LLC and : SUPERIOR COURT
GERALD METALS Sàrl, :
:
Plaintiffs, : JUDICIAL DISTRICT OF FAIRFIELD
: AT STAMFORD
v. :
:
CERTAIN UNDERWRITERS SUBSCRIBING :
TO MARINE CARGO INSURANCE POLICIES :
NOs. B07853PC1309890000, :
B0753PC1412113000, and :
B1353DC1501253000, : NOVEMBER 8, 2022
:
Defendants. :
:

PLAINTIFFS’ MEMORANDUM OF LAW IN REPLY
TO DEFENDANTS’ OPPOSITION TO MOTION FOR
APPEARANCE OF WITNESSES BY INTERACTIVE AUDIOVISUAL DEVICE

Gerald Metals LLC (a Connecticut based employer) and Gerald Metals Sàrl (collectively

“Gerald” or “Plaintiffs”), by their undersigned counsel, hereby submit this Memorandum of Law

In Reply to the Defendants’ Opposition to Motion for Appearance of Witnesses by Interactive

Audiovisual Device filed by Defendants Certain Underwriters Subscribing to Marine Cargo

Insurance Policies Nos. B07853PC1309890000, B0753PC1412113000, and

B1353DC1501253000 (“Underwriters” or “Defendants”) on November 1, 2022. Entry Nos.

317.00 and 318.00.

I. INTRODUCTION

Defendants have submitted a fourteen-page diatribe in response to a routine procedural

motion in which the Plaintiffs sought leave of this Court to present testimony from fact and expert

witnesses by remote interactive audiovisual device as expressly contemplated by Practice Book §

23-68. Defendants’ objection is scant on law, heavy on invective, and engages in impertinent and
self-serving characterization of the substance of the Plaintiffs’ claims and witnesses. Where the

Defendants do make legal arguments, such arguments are based upon cases in federal court

applying and interpreting Fed. R. Civ. P. 43(a) and not Connecticut Practice Book § 23-68. In fact,

the Defendants cite to only a single Connecticut case which was decided prior to the COVID-19

pandemic, and years before use of remote court proceedings that have followed, and under a prior

version of § 23-68.

In seeking permission to submit witness testimony via an interactive audiovisual device,

the Plaintiffs are merely asking to engage in an activity which has become extremely common-

place since the advent of the COVID-19 pandemic. Plaintiffs are also seeking to ensure that the

foreign witnesses 1 are not exposed to undue hardship or the very real risks of international travel

in the current age. To assuage Underwriters’ purported concerns regarding Chinese law related to

remote fact witness testimony, Gerald limits its motion to seeking only the ability to present live

remote testimony of expert witnesses from both parties. In light of this concession, it is clear that

the Defendants have presented no basis for denying the Plaintiffs’ request and have instead used

their opposition as an opportunity to malign the Plaintiffs, their claim, and the Plaintiffs’ witnesses.

As such, the Defendants’ objection should be overruled and the Plaintiffs should be granted

permission to present the specified witnesses via interactive audiovisual means.

II. ARGUMENT

Defendants’ opposition is almost entirely premised on Flame S.A. v. Industrial Carriers,

Inc., a decision from the Eastern District of Virginia, decided prior to the COVID-19 pandemic,

and applying the Federal Rules of Civil Procedure, not the Connecticut Practice Book. Defendants

argue that the request for remote testimony is a matter of convenience, rather than necessity, and

1
Notably, at the Trial Management Conference Defendants’ counsel indicated Defendants would stipulate to
presentation of expert witness trial testimony by remote means only to subsequently pivot and refuse to so stipulate.

-2-
that Plaintiffs, in seeking the Court’s permission, have failed to establish that there is good cause

for the remote testimony. In support of this argument, Defendants rely heavily on Flame S.A. and

Fed. R. Civ. P. 43(a) and the commentaries thereto. It goes without saying, however, that a

decision from the Eastern District of Virginia applying the Federal Rules of Civil Procedure is of

no moment in a proceeding in a court of the State of Connecticut governed by the Connecticut

Practice Book. The risibility of Defendants’ reliance on Flame S.A. and Fed. R. Civ. P. 43(a) is

made immediately apparent upon a cursory comparison of Fed. R. Civ. P. 43(a) and Connecticut

Practice Book § 23-68, despite Defendants attempts to hand-wave significant substantive

differences by referring to it as the “federal practice corollary.”

The Federal Rules of Civil Procedure provide that remote testimony may be permitted

“[f]or good cause in compelling circumstances and with appropriate safeguards.” In apposition to

this, the Practice Book § 23-68 merely provides, in pertinent part, that “[u]pon motion of any party,

and at the discretion of the judicial authority, any party, counsel, witness, or other participant in

any proceeding may appear by means of an interactive audiovisual device” and contains no further

requirements, commending the decision exclusively to the discretion of the Court. Given the

significant substantive difference between Fed. R. Civ. P. 43(a) and Practice Book § 23-68,

Defendants’ reliance on Flame S.A. is untenable and its insistence that this Court ignore the holding

in Lynch v. State—a Connecticut Superior Court interpreting § 23-68 in the context of the COVID-

19 pandemic—in favor of Flame S.A.— a federal court decision interpreting an inapplicable

federal rule prior to the advent of COVID-19—is patently untenable.

The sole reference Defendants make to a Connecticut case, Washburn v. Washburn, was a

dissolution action decided prior to the COVID-19 pandemic, under a prior version of § 23-68, 2

2
It should be noted that Defendants themselves may be working with an outdated version of the Practice Book. They
argue that Plaintiffs’ reliance on § 23-68(b) is misplaced as it “usually” applies to incarcerated individuals. While the

-3-
and involved a situation in which the plaintiff sought leave to appear at trial remotely after

allegedly leaving the state with the parties’ children in contravention of a prior court order. Again,

the decision in Lynch v. State is far more instructive than the decision in Washburn, as the Court

in Lynch was interpreting the current version of § 23-68 3 and was dealing with the realities of

judicial proceedings during the COVID-19 pandemic.

The Defendants go on to argue that the named witnesses would not be restricted from

entering the United States and that this matter has been pending for years and, as such, Plaintiffs

should have anticipated the need for in-person testimony and the attendant visa, health, and travel

documents and preparations. Despite Defendants’ assertions that there are no prohibitions on

travelling to the United States from China, Defendants fail to consider that the witnesses would be

subjected to unnecessary hardships upon their return from the United States, including increased

health screening related to COVID-19, a mandatory minimum 10-day quarantine in a government

designated hotel, with potential additional local restrictions, upon returning home, and potential

restrictions on travel within China. 4 In addition, China specifies that foreign travel for business

must be necessary, 5 which forces a subject determination of whether it is “necessary” for any of

the Chinese witnesses that have been deposed to travel to the U.S. for trial, particularly to provide

testimony that is permitted to be provided by remote audio visual device, and may last for only an

hour or two. The foregoing does not even contemplate the time, cost, and difficulties of the process

of applying for, interviewing for, and the potential receipt of a non-immigrant visa for travel to the

United States for each of the subject witnesses. While Defendants argue that this matter has been

prior version of § 23-68(b) analyzed by the court in Washburn v. Washburn referred to incarcerated individuals, the
current version of § 23-68(b) makes no such reference.
3
Indeed, the current version of § 23-68 even vitiates some of the concerns raised by the court in Washburn in that it
provides for the remote swearing in of the witness.
4
See, COVID-19 INFORMATION, U.S. Mission China, china.usembassy-china.org-cn/covid-19-information/ (last
accessed November 8, 2022). A printout is attached hereto as Exhibit A.
5
See Affidavit of Defendants’ Expert, Mr. Song. Entry No. 318.00, at page 1, ¶ 3.

-4-
scheduled for trial since December 14, 2021, it cannot escape this Court’s notice that this matter

has been subjected to years of delays and continuances, and in arguing that Plaintiffs should have

made prior accommodations, Defendants prescribe a level of prescience to the Plaintiffs that they

simply do not have.

Defendants also argue that they will be prejudiced by the use of interactive audiovisual

means for the presentation of witnesses as they will effectively be denied their right to effective

cross-examination. This argument is undercut by the court’s holding in Lynch v. State, wherein the

court addressed these exact concerns and held that there was a “minimal imposition on the

defendants’ right to confront witnesses in person,” and finding that, on balance, testimony via

remote audiovisual means was preferrable to testimony done in court through masking and social

distancing rules. 6Furthermore, the actuality of several years of remote testimony and judicial

proceedings following the onset of the COVID-19 have evidenced the usefulness and efficacy of

same.

The balance of Defendants’ motion is largely a harangue of the Plaintiffs’ claims and

witnesses, which is patently immaterial to the motion at issue. The sole remaining argument that

Defendants make is that it is illegal under Chinese law for a person to participate in a foreign court

proceeding from mainland China. In support of this position, Defendants provide a self-serving

affidavit from their previously disclosed expert that fails to include the alleged law upon which

they premise their argument, which in any event applies only to lay witness and not experts

according to Defendants’ expert, Mr. Song. See Entry No. 318.00, at page 2, ¶ 7. Regardless,

Chinese laws do not operate to bind the Connecticut judiciary and that, even if there existed such

6
While such rules are no longer mandatory, the Connecticut judiciary encourages the utilization of masking and social
distancing. See, FREQUENTLY ASKED QUESTIONS – COVID-19 AND COURT BUSINESS, General Court Information n.
3 (last accessed November 8, 2022) (a printout is attached hereto as Exhibit B).

-5-
a Chinese law, it would have no force or effect upon this Court’s ability to order that Plaintiff be

permitted to present testimony at trial by interactive audiovisual means. See, e.g., Societe

Nationale Industrielle Aerospatiale v. United States Dist. Court for S. Dist., 482 U.S. 522, 544 n.

29 (1987) (holding that foreign statutes “do not deprive an American court of the power to order a

party subject to its jurisdiction to produce evidence even though the act of production may violate

that statute.”).

In sum, the Plaintiffs are seeking permission to present witness testimony via interactive

audiovisual means in a manner that has become customary and routine. The Defendants ask this

Court to ignore directly relevant decisions from during the ongoing COVID-19 pandemic

interpreting the current version of Practice Book § 23-68 in favor of extra-jurisdictional decisions

interpreting inapplicable federal rules and a single Connecticut decision interpreting an outdated

version of Practice Book § 23-68. The realities, risks, and hardships imposed upon the world by

COVID-19 are still present and Practice Book § 23-68 was expressly modified in order to combat

these risks and permit remote testimony in situations exactly like the one present here. As such,

this Court should grant permission for the Plaintiffs to present witness testimony via an interactive

audiovisual device.

III. CONCLUSION

WHEREFORE, in light of the foregoing, this Court should overule the

Defendants’objection and grant Plaintiffs’ Motion for Permission for Appearance of Witnesses By

Interactive Audiovisual Device.

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The Plaintiffs,

GERALD METALS, LLC and
GERALD METALS S.a.r.l.

By: /s/ 440168
Steven R. Winters (Juris No. 440168)
Patrick F. Lennon (Juris No. 407086)
LENNON, MURPHY & PHILLIPS, LLC
(Juris No. 427089)
1599 Post Road East
Westport, Connecticut 06880
Tel. (203) 256-8600
Fax (203) 256-8615
Email: pfl@lmplaw.net / srw@lmplaw.net
- and –
John B. Berringer, Esq. (pro hac vice)
Anthony B. Crawford, Esq. (pro hac vice)
Reed Smith LLP
599 Lexington Avel, 22nd Floor
New York, NY 10022

-7-
CERTIFICATION

I hereby certify that on November 8, 2022, a copy of the foregoing was sent via

electronic mail to all counsel of record, to wit:

Thomas Tisdale
Tisdale & Nast Law Offices LLC
10 Spruce Street
Southport, CT 06890

Anthony B. Crawford - pro hac vice
Reed Smith LLP
599 Lexington Ave, 22nd Floor
New York, NY 10022

John B. Berringer - pro hac vice
Reed Smith LLP
599 Lexington Ave, 22nd Floor
New York, NY 10022

By: /s/ 440168
Steven R. Winters

-8-
Exhibit A

Exhibit A
11/8/22, 2:38 PM COVID-19 Information - U.S. Embassy & Consulates in China

U.S. EMBASSY & CONSULATES
IN CHINA

COVID-19 INFORMATION
By U.S. MISSION CHINA

NOVEMBER 4, 2022

Last updated: [11/4/2022]

The CDC’s Order requiring proof of vaccination for non-U.S. citizen nonimmigrants to travel to the United States is still in effect.
For more information see Requirement for Proof of COVID-19 Vaccination for Air Passengers .

Check the CDC website for additional information and Frequently Asked Questions .

Entry and Exit Requirements

Are there COVID-related entry requirements for U.S. citizens? Yes, China currently allows foreign nationals with valid residence
permits and visas to enter the country under certain very limited conditions. The U.S. Embassy is not involved in the creation of
these policies, and they are subject to change at any time.
Is a negative COVID-19 test (PCR and/or serology) required for entry? Yes, please follow guidance on the PRC Embassy website to
identify approved labs.
Are health screening procedures in place at airports and other ports of entry? Yes

Quarantine Information

Are U.S. citizens required to quarantine? Yes, all travelers, including U.S. citizens who enter China, are screened upon arrival and
subject to a minimum 10-day quarantine. While restrictions around domestic travel within China have eased, local quarantine
requirements can vary significantly between cities, and regulations can change very quickly. All international arrivals should be
prepared to complete quarantine at a government-selected facility or hotel at their own expense, with no control over the amenities,
even if they maintain a residence in China. Cities and provinces within China may also require quarantine for domestic travelers,
regardless of nationality.
U.S. citizens may also be required to install and use location-tracking software on their phones to access public spaces and
businesses. Some private hospitals may refuse admittance to travelers who have been in the United States 14 days prior to entering
China. Please consult local authorities on specific quarantine requirements.
U.S. citizens in China should follow the U.S. Centers for Disease Control and Prevention (CDC) and Chinese health authorities’
guidance for prevention, signs and symptoms, and treatment.

COVID-19 Testing

Are PCR and/or antigen tests available for U.S. citizens in China? Yes
For a nationwide list of COVID testing centers, please see here (Mandarin)
For WeChat users, users can select “official accounts (公众号)” and then press the “+” key to search for “city name (本地宝)”.
Follow the account, type “核酸检测” into the search bar at the bottom of the screen, and then click the hyperlink that leads to
a list of all testing locations.
For a list that includes testing centers with English service, please see here.
If so, are test results reliably available within 24 hours? Yes
COVID-19 tests are widely available throughout China. COVID-19 tests are available at most hospitals and clinics. Test results are
often returned within 12-24 hours. The cost of the COVID-19 test is about $3 US dollars.
Test results can be delivered by a variety of methods: email, text, or an update to the local COVID-19 monitoring app are the most
common delivery methods.
Please refer to your local health authorities for more information on COVID-19 testing.
For information on limited humanitarian exemptions to CDC’s requirement that all U.S. bound travelers present a negative COVID
test, please review the following page .
Humanitarian exemptions to this order will be granted on an extremely limited basis and will only be considered when the country
of departure lacks adequate COVID-19 testing capacity. To submit information in support of an exemption, email:
Beijing Consular District: BeijingACS@state.gov
Guangzhou Consular District: GuangzhouACS@state.gov
Shanghai Consular District: ShanghaiACS@state.gov
Shenyang Consular District: ShenyangACS@state.gov

COVID-19 Vaccine Information:

Are vaccines available in China for U.S. citizens to receive? Yes
The Chinese government has conditionally authorized several different vaccines that are currently available to foreigners residing in
China. The two most commonly available, Sinopharm and Sinovac, have not yet received approval by the Food and Drug
Administration of the United States. Sinopharm and Sinovac have received approval for emergency use by the World Health
Organization (WHO). Please contact your local health authorities for information on available vaccines.

https://china.usembassy-china.org.cn/covid-19-information/ 1/2
11/8/22, 2:38 PM COVID-19 Information - U.S. Embassy & Consulates in China

Visit the FDA’s website to learn more about FDA-approved vaccines in the United States.

Movement Restrictions

Is a curfew in place? No
Are there restrictions on intercity or interstate travel? Yes, movement restriction revolve around places where cases are detected.
Cities with even small outbreaks may restrict travel out of the city, and other cities may not allow travelers to enter from cities where
cases are detected.

Fines for Non-Compliance

failure to comply with movement restrictions or other pandemic controls can cause a person to be subject to additional
quarantine/testing, detention, fines, or arrest.

Local Resources:

State Council of PRC COVID-19 Webpage
Other links:
COVID-19 crisis page on travel.state.gov
CDC page on COVID-19
China Travel Information
Map of Number of Daily New COVID-19 Cases by Province – Last updated on 11/4/2022 (PDF 339 KB)

https://china.usembassy-china.org.cn/covid-19-information/ 2/2
Exhibit B

Exhibit B
11/8/22, 2:58 PM Frequently Asked Questions - Covid-19 and Court Business

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General Court Information

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The Judicial Branch has a COVID-19 Updates web page with the latest information, which can be used to update any information in this
FAQ.

Certain provisions related to Court Operations and Associated Requirements that were suspended by Executive Order No. 7G will no longer
be suspended, effective March 1, 2021. See Executive Order No. 10A, issued on February 8, 2021.

2. Which courthouses are currently open, what are the hours, and where can I find the contact information?
Please see this list of courthouses and phone numbers and this directories web page. The days and hours of court business at all open
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Effective Monday, March 7, 2022, the Judicial Branch will suspend the requirement of wearing a mask when entering a Judicial Branch
facility. If COVID-19 activity increases in the state, mask use by individuals may again be required. Also effective March 7, 2022, the Judicial
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Please see this pamphlet on Accessing Judicial Branch Resources from Home The pamphlet points you to contact information and services
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Please see this pamphlet on Accessing Judicial Branch Resources from Home. The pamphlet points you to contact information and services
available online and by email.

5. What types of court matters are being handled remotely?
For information about the types of matters being scheduled for in-person or remote proceedings, see the General Guidelines for the Use of
Remote Proceedings Post-Covid. The Judicial Branch has been conducting court business using alternatives to in-person presence since
March 30, 2020. Jury trials resumed on June 1, 2021.

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The Probate Courts are open. You can contact your local probate court with questions about availability and hours.

Jury Duty Information

7. Do I need to appear for jury duty during the COVID-19 public health emergency?
Jury trials resumed effective June 1, 2021. If you have received a juror summons, please respond to the notice. You may call Jury
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Court Filing and Pending Cases

8. I have a pending case or trial. Do I need to go to court?
Currently all matters are being heard in Connecticut state courts. If you have an attorney, please contact your attorney. If you do not have
an attorney, look up your case on the Judicial Branch's case look up section.

For information on virtual court proceedings, go to https://jud.ct.gov/RemoteJustice/. If a remote court hearing is scheduled and you receive
an e-mail invitation to join a Microsoft Teams meeting, see this Connecticut Guide to Remote Hearings For Attorneys and Self-Represented
Parties for information and guidance. For further information about the types of matters being scheduled for in-person or remote
proceedings, see the General Guidelines for the Use of Remote Proceedings Post-Covid.

9. Are civil short calendars being held?
Yes. For more information on short calendar markings and marking periods, see the Civil Short Calendar Standing Order at
https://www.jud.ct.gov/external/super/Standorders/ElectronicCivil.htm.

10. Are civil pre-trials, trial management conferences, and status conferences being held?
Yes. Civil pretrials, status conferences, trial management conferences, and judicial mediations are being conducted.

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There are instructions on how to join a Teams Meeting scheduled by the Court. For family matters case dates, pre-trials, and status
conferences, see question 18 and question 19.

11. Where can I find information about filing documents with the Superior Court?
Each court location has a Clerk's Office and many locations also have a Court Service Center and a Law Library that can give you
information about filing documents with the Superior Court. Please visit the Judicial Branch's E-Services web page for information on E-
Filing.

Please note that the process for a Self-Represented Party to be approved to E-File their documents has been simplified so that a party no
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12. Where can I find online court forms?
Forms can be found on the Official Court Webforms page. The Probate Courts have a separate Probate Court Forms page.

13. How can I get court documents notarized?
The Court Service Centers provide notary public services at each of their locations. The Executive Order of Governor Ned Lamont
authorizing the use of remote notarization expired on July 1, 2021. Remote notarization is no longer authorized under Connecticut law.

Foreclosures and Evictions

14. Where can I find information concerning foreclosures and evictions?
This Law About Landlord/Tenant web page has links to information concerning evictions. And the Law About Foreclosures web page has
links to information concerning foreclosures.

Restraining Orders and Civil Protection Orders

15. What is the procedure for filing of restraining orders and civil protection orders during the COVID-19 public health emergency?
Please see this web page on the Procedure for the Remote Filing of Temporary Restraining Orders.

Effective July 1, 2021, and consistent with the Governor's Executive Order 12B, section 3 and sections 46b-15 and 46b-16a of the
Connecticut General Statutes, any application for a Temporary Restraining Order/Relief From Abuse or a Civil Protection order must be
accompanied by an affidavit made under oath that includes the specific facts that form the basis for relief. After 5:00 PM on June 30, 2021, it
is no longer adequate to file the application documents under penalty of false statement.

For applications for relief from abuse and related forms, go to https://www.jud.ct.gov/forms/grouped/family/restraining_order.htm.

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11/8/22, 2:58 PM Frequently Asked Questions - Covid-19 and Court Business

For civil protection order applications and related forms, go to https://jud.ct.gov/forms/grouped/civil/civil_protect_order.htm.

Divorce and Custody

16. If we have an agreement, may we have our family court case resolved without having to come to court?
This web page on how to request that certain family matters be handled remotely states that "[d]uring the COVID-19 public health
emergency, the Judicial Branch has established a procedure for parties with full written agreements in family court matters to request
approval of their agreements without having to come to the courthouse for a hearing. The procedure is available to request the entry of final
judgment in any action for custody, visitation between parents, dissolution of marriage, or legal separation, or a final order on any motion in
such a case, as long as the parties are in complete agreement and file all necessary documents." Click here for explanations of the
procedures and the necessary documents.

17. I have a trial or a specially assigned hearing for a pending case. Do I need to go to court?
Currently all matters are being heard in Connecticut state courts. If you have an attorney, please contact your attorney. If you do not have
an attorney, look up your case on the Judicial Branch's case look up section.

Please see this notice, issued on Sept. 21, 2021, about Upcoming Developments in Family Court, including the expansion of in-person
proceedings. If you have a remote court hearing scheduled and you receive an e-mail invitation to join a Microsoft Teams meeting, see this
Connecticut Guide to Remote Hearings For Attorneys and Self-Represented Parties for information and guidance. For more information on
virtual court proceedings, go to https://jud.ct.gov/RemoteJustice/.

For further information about the types of matters being scheduled for in-person or remote proceedings, see the General Guidelines for the
Use of Remote Proceedings Post-Covid.

18. My family case has a "case evaluation hearing," a "resolution plan date," or a "case date" hearing. What does that mean?

Please read this document, The Pathways Process in Your Divorce, Custody, or Visitation Case, to review the new process for family cases
in 2022. Additionally, see this explanation of the new motion dockets in family courts. There is also this Pathways Process web page.

Case Evaluation Hearings are intended primarily for pending matters that have not had previous court dates. The purpose of a Case
Evaluation Hearing is to determine the specific issues in the case, the likelihood of the parties reaching an agreement, the amount of court
involvement needed, and the scheduling of further proceedings. More information about Case Evaluation Hearings can be found here:
https://www.jud.ct.gov/HomePDFs/CaseEvaluationHearingsFamilyMatters.pdf.

Resolution Plan Date: Connecticut has a new process, The Pathways Process in Your Divorce, Custody, or Visitation Case, for custody,
visitation, dissolution of marriage, and legal separation cases. It was developed with the help of the National Center for State Courts based
h d i i th t t Th i d i dt ti t t t l i th i b
https://jud.ct.gov/LawLib/covid19-faqs.htm#3 6/10
11/8/22, 2:58 PM Frequently Asked Questions - Covid-19 and Court Business
on research and experience in other states. The process is designed to encourage parties to concentrate on resolving their cases by
agreement, instead of engaging in lengthy litigation. It seeks to give each case the level of court resources it needs sooner than was
possible under the old process, and reduce the number of necessary court appearances. More information about Resolution Plan Dates can
be found on the Pathways Process web page. See also: Notice, issued on Sept. 21, 202

Case Info

Judge

Charles T. Lee Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

November 09, 2022

Case Filing Date

January 26, 2017

County

Parties

CARMODY TORRANCE SANDAK & HENNESSEY LLP Attorney for the Plaintiff
CERTAIN UNDERWRITERS AT INTERNATIONAL UNDERWRITING ASSOCIATION OF LONDON Defendant
DANIEL CRISPIN FORD Attorney
GERALD METALS, LLC Plaintiff
GERALD METALS S.A. Plaintiff
LENNON MURPHY & PHILLIPS LLC Attorney for the Plaintiff
PATRICK F LENNON Attorney for the Plaintiff
PHV BERRINGER JOHN B. 4/6/04 Attorney for the Plaintiff
PHV CRAWFORD ANTHONY B 10/5/17 Attorney for the Plaintiff
ROXANNE KHAZARIAN Witness
TISDALE & NAST LAW OFFICES LLC Attorney for the Defendant
Thomas Tisdale Attorney
JOHN BARTON Attorney
Timothy Nast Attorney

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