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  • Stacey Lynn Brown as Administratrix of the Estate of STEVEN L. HALL, deceased v. A.O. Smith Water Products, Air & Liquid Systems Corporation, as Successor by Merger to Buffalo Pumps, Inc., Alfa Laval, Inc., Allegheny Teledyne Incorporated, Individually and as Successor to Allegheny Technologies Incorporated and Farris Valves and/or Sprague Pumps, Amec Construction Management, Inc., Amtrol, Inc., Individually and as Successor to Thrush Products, Inc., Armstrong International, Inc., Auburn Technology, Inc. f/k/a Alco Power, Inc., Atwood & Morrill Co., Inc. d/b/a Weir Valves & Controls USA Inc., Aurora Pump Company, Bechtel Corporation, Blackmer Pump, Borgwarner Morse Tec Llc, Bw/Ip International Co., formerly known as Borg Warner Industrial Products Inc., a former subsidiary of and successor to Borg Warner Corp. and Byron Jackson Pumps, Carrier Corporation, 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, Certain-Teed Corporation, Clark-Reliance Corporation, Individually and as Successor to Jerguson, Cleaver-Brooks Company f/k/a Aqua-Chem, Inc., Courter & Company, Inc., Crane Co., Individually and as Successor to Cochrane, Croll-Reynolds Engineering Company, Inc., Crosby Valve And Gage Company, Crosby Valve, Inc., Cytec Engineered Materials, Inc. f/k/a Fiberite Corporation and a/k/a ICI Composites, Inc., Cytec Industries Inc., Individually and as successor to American Cyanamid Company, Dean Pump Division, Dezurik, Inc., Durez Corporation, E.I. Team, Inc. f/k/a J.L. Murphy, Inc., Electrolux Home Products, Inc., Individually and as Successor to Tappan and Copes-Vulcan, Elliott Turbomachinery Co., Inc., Fairbanks Company (The), Individually and as Successor to Fairbanks Valves, 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 to Northern Pump Company, Coffin and Peerless Pump Company, Foster Wheeler, Llc, Gardner Denver, Inc., General Electric Company, Genuine Partscompany, George A. Fuller Company, Georgia-Pacific Corporation, Individually and as successor to Bestwall Gypsum Company, Gg Of Florida, Inc., f/k/a Higbee, Inc., Goodall Rubber Co., Goulds Pumps, Inc., Greene, Tweed & Co., Llp, Individually and as Successor to Palmetto Packings, Grinnell Corporation, Henry Technologies, Inc., Honeywell International, Inc., Individually and f/k/a AlliedSignal, Inc., and as Successor-in-interest to the Bendix Corp., Howden Buffalo, Inc., Individually and as Successor-In-Interest to FB Sturtevant, The Howden Buffalo Group and Buffalo Fan, I.T.T. Industries, Inc., Individually and as successor to Bell & Gossett, Imo Industries, Inc. f/k/a Delaval, Inc., Individually and as Successor to Turbine Equipment Company, Jenkins Bros., John Crane, Inc., Koppers Company, Inc., Koppers Industries, Inc., Maremont Corporation, Individually and as Successor to Grizzly, Metropolitan Life Insurance Co., Morse Diesel, Inc., Morse Diesel International, Inc., Napa Auto Parts a/k/a National Automotive Parts Association, Nash Engineering Company (The), Northrop Grumman Corporation, Individually and as Successor to George A. Fuller Company, Occidental Chemical Corporation, Individually and as Successor to Durez Corporation, Owens-Illinois, Inc., Patterson Pump Company, a Subsidiary of the Gorman-Rupp Company and Individually and as successor to C.H. Wheeler Manufacturing and Griscom Russell, Plastics Engineering Company, Individually and as Successor to Plenco, Pneumo Abex Corporation, Pneumo-Abex Llc, Individually and as Successor to Abex Corporation, a Delaware Corporation, Research-Cottrell, Inc. n/k/a AWT Air Company, Inc., Riley Power, Inc. f/k/a Babcock Borsig Power, Inc. and f/k/a Riley Stoker Corporation d/b/a DB Riley, Inc., Rogers Corporation, Spence Engineering Company, Inc., Spirax Sarco, Inc., Spx Cooling Technologies, Inc., Individually as successor to Marley Cooling Technologies and Marley Cooling Towers, Superior Lidgerwood Mundy Corp., a/k/a Lidgerwood Manufacturing Co., Individually and as Successor to M.T. Davidson Co., Thomas O'Connor & Company, Inc., Currently known as O'Connor Constructors, Inc., Treadwell Corporation, Thrush Co., Inc., Turner Construction Company, Tuthill Corporation, Individually and as Successor to Kinney Vacuum Pump Company, Kinney Pump Company and Murray Turbine, Tyco Flow Control, Inc., Individually and as Successor to Keystone and Grinnell Corporation, Tyco International (Us) Inc., Individually and as Successor to Hancock Valves, Keystone, Lonergan Valves, Union Carbide Corporation, United Conveyor Corporation, Velan Valve Corp., Warren Pumps, Llc, Individually and as Successor to The Quimby Pump Company, Wolff & Munier, Inc., William Powell Company (The), York International Corporation, Individually and as Successor to Frick Company, Yuba Heat Transfer, a division of Connell Limited Partnership n/k/a SPX Heat Transfer LLC, Zurn Industries, Inc. a/k/a and Successor-in-Interest to Erie City Iron Works, R.T Vanderbilt Company, Inc., Individually And As Successor To International Tale Co., International Pulp Co., And Governeur Tale Co., Inc., Ace Hardware, Ace Hardware Corporation, Duro Dyne Corporation, Hexion Specialty Chemicals, Inc. F/K/A Borden Chemical, Inc., I.T.T. Industries, Inc., Individually And As Successor To Hoffman Specialty, Bell & Gossett, And Foster Engineering, Lighttolier Incorporated, Progress Lighting, Inc., Sid Harvey Industries, Inc., Sid Harvey Supply, Inc., Union Pumps, As A Textron Company, American Biltrite, Inc., Individually And Successor To Amtico Floors, Dap, Inc. K/N/A La Mirada Products Co., Inc., Kaiser Gypsum Company, Inc. Torts - Asbestos document preview
  • Stacey Lynn Brown as Administratrix of the Estate of STEVEN L. HALL, deceased v. A.O. Smith Water Products, Air & Liquid Systems Corporation, as Successor by Merger to Buffalo Pumps, Inc., Alfa Laval, Inc., Allegheny Teledyne Incorporated, Individually and as Successor to Allegheny Technologies Incorporated and Farris Valves and/or Sprague Pumps, Amec Construction Management, Inc., Amtrol, Inc., Individually and as Successor to Thrush Products, Inc., Armstrong International, Inc., Auburn Technology, Inc. f/k/a Alco Power, Inc., Atwood & Morrill Co., Inc. d/b/a Weir Valves & Controls USA Inc., Aurora Pump Company, Bechtel Corporation, Blackmer Pump, Borgwarner Morse Tec Llc, Bw/Ip International Co., formerly known as Borg Warner Industrial Products Inc., a former subsidiary of and successor to Borg Warner Corp. and Byron Jackson Pumps, Carrier Corporation, 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, Certain-Teed Corporation, Clark-Reliance Corporation, Individually and as Successor to Jerguson, Cleaver-Brooks Company f/k/a Aqua-Chem, Inc., Courter & Company, Inc., Crane Co., Individually and as Successor to Cochrane, Croll-Reynolds Engineering Company, Inc., Crosby Valve And Gage Company, Crosby Valve, Inc., Cytec Engineered Materials, Inc. f/k/a Fiberite Corporation and a/k/a ICI Composites, Inc., Cytec Industries Inc., Individually and as successor to American Cyanamid Company, Dean Pump Division, Dezurik, Inc., Durez Corporation, E.I. Team, Inc. f/k/a J.L. Murphy, Inc., Electrolux Home Products, Inc., Individually and as Successor to Tappan and Copes-Vulcan, Elliott Turbomachinery Co., Inc., Fairbanks Company (The), Individually and as Successor to Fairbanks Valves, 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 to Northern Pump Company, Coffin and Peerless Pump Company, Foster Wheeler, Llc, Gardner Denver, Inc., General Electric Company, Genuine Partscompany, George A. Fuller Company, Georgia-Pacific Corporation, Individually and as successor to Bestwall Gypsum Company, Gg Of Florida, Inc., f/k/a Higbee, Inc., Goodall Rubber Co., Goulds Pumps, Inc., Greene, Tweed & Co., Llp, Individually and as Successor to Palmetto Packings, Grinnell Corporation, Henry Technologies, Inc., Honeywell International, Inc., Individually and f/k/a AlliedSignal, Inc., and as Successor-in-interest to the Bendix Corp., Howden Buffalo, Inc., Individually and as Successor-In-Interest to FB Sturtevant, The Howden Buffalo Group and Buffalo Fan, I.T.T. Industries, Inc., Individually and as successor to Bell & Gossett, Imo Industries, Inc. f/k/a Delaval, Inc., Individually and as Successor to Turbine Equipment Company, Jenkins Bros., John Crane, Inc., Koppers Company, Inc., Koppers Industries, Inc., Maremont Corporation, Individually and as Successor to Grizzly, Metropolitan Life Insurance Co., Morse Diesel, Inc., Morse Diesel International, Inc., Napa Auto Parts a/k/a National Automotive Parts Association, Nash Engineering Company (The), Northrop Grumman Corporation, Individually and as Successor to George A. Fuller Company, Occidental Chemical Corporation, Individually and as Successor to Durez Corporation, Owens-Illinois, Inc., Patterson Pump Company, a Subsidiary of the Gorman-Rupp Company and Individually and as successor to C.H. Wheeler Manufacturing and Griscom Russell, Plastics Engineering Company, Individually and as Successor to Plenco, Pneumo Abex Corporation, Pneumo-Abex Llc, Individually and as Successor to Abex Corporation, a Delaware Corporation, Research-Cottrell, Inc. n/k/a AWT Air Company, Inc., Riley Power, Inc. f/k/a Babcock Borsig Power, Inc. and f/k/a Riley Stoker Corporation d/b/a DB Riley, Inc., Rogers Corporation, Spence Engineering Company, Inc., Spirax Sarco, Inc., Spx Cooling Technologies, Inc., Individually as successor to Marley Cooling Technologies and Marley Cooling Towers, Superior Lidgerwood Mundy Corp., a/k/a Lidgerwood Manufacturing Co., Individually and as Successor to M.T. Davidson Co., Thomas O'Connor & Company, Inc., Currently known as O'Connor Constructors, Inc., Treadwell Corporation, Thrush Co., Inc., Turner Construction Company, Tuthill Corporation, Individually and as Successor to Kinney Vacuum Pump Company, Kinney Pump Company and Murray Turbine, Tyco Flow Control, Inc., Individually and as Successor to Keystone and Grinnell Corporation, Tyco International (Us) Inc., Individually and as Successor to Hancock Valves, Keystone, Lonergan Valves, Union Carbide Corporation, United Conveyor Corporation, Velan Valve Corp., Warren Pumps, Llc, Individually and as Successor to The Quimby Pump Company, Wolff & Munier, Inc., William Powell Company (The), York International Corporation, Individually and as Successor to Frick Company, Yuba Heat Transfer, a division of Connell Limited Partnership n/k/a SPX Heat Transfer LLC, Zurn Industries, Inc. a/k/a and Successor-in-Interest to Erie City Iron Works, R.T Vanderbilt Company, Inc., Individually And As Successor To International Tale Co., International Pulp Co., And Governeur Tale Co., Inc., Ace Hardware, Ace Hardware Corporation, Duro Dyne Corporation, Hexion Specialty Chemicals, Inc. F/K/A Borden Chemical, Inc., I.T.T. Industries, Inc., Individually And As Successor To Hoffman Specialty, Bell & Gossett, And Foster Engineering, Lighttolier Incorporated, Progress Lighting, Inc., Sid Harvey Industries, Inc., Sid Harvey Supply, Inc., Union Pumps, As A Textron Company, American Biltrite, Inc., Individually And Successor To Amtico Floors, Dap, Inc. K/N/A La Mirada Products Co., Inc., Kaiser Gypsum Company, Inc. Torts - Asbestos document preview
  • Stacey Lynn Brown as Administratrix of the Estate of STEVEN L. HALL, deceased v. A.O. Smith Water Products, Air & Liquid Systems Corporation, as Successor by Merger to Buffalo Pumps, Inc., Alfa Laval, Inc., Allegheny Teledyne Incorporated, Individually and as Successor to Allegheny Technologies Incorporated and Farris Valves and/or Sprague Pumps, Amec Construction Management, Inc., Amtrol, Inc., Individually and as Successor to Thrush Products, Inc., Armstrong International, Inc., Auburn Technology, Inc. f/k/a Alco Power, Inc., Atwood & Morrill Co., Inc. d/b/a Weir Valves & Controls USA Inc., Aurora Pump Company, Bechtel Corporation, Blackmer Pump, Borgwarner Morse Tec Llc, Bw/Ip International Co., formerly known as Borg Warner Industrial Products Inc., a former subsidiary of and successor to Borg Warner Corp. and Byron Jackson Pumps, Carrier Corporation, 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, Certain-Teed Corporation, Clark-Reliance Corporation, Individually and as Successor to Jerguson, Cleaver-Brooks Company f/k/a Aqua-Chem, Inc., Courter & Company, Inc., Crane Co., Individually and as Successor to Cochrane, Croll-Reynolds Engineering Company, Inc., Crosby Valve And Gage Company, Crosby Valve, Inc., Cytec Engineered Materials, Inc. f/k/a Fiberite Corporation and a/k/a ICI Composites, Inc., Cytec Industries Inc., Individually and as successor to American Cyanamid Company, Dean Pump Division, Dezurik, Inc., Durez Corporation, E.I. Team, Inc. f/k/a J.L. Murphy, Inc., Electrolux Home Products, Inc., Individually and as Successor to Tappan and Copes-Vulcan, Elliott Turbomachinery Co., Inc., Fairbanks Company (The), Individually and as Successor to Fairbanks Valves, 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 to Northern Pump Company, Coffin and Peerless Pump Company, Foster Wheeler, Llc, Gardner Denver, Inc., General Electric Company, Genuine Partscompany, George A. Fuller Company, Georgia-Pacific Corporation, Individually and as successor to Bestwall Gypsum Company, Gg Of Florida, Inc., f/k/a Higbee, Inc., Goodall Rubber Co., Goulds Pumps, Inc., Greene, Tweed & Co., Llp, Individually and as Successor to Palmetto Packings, Grinnell Corporation, Henry Technologies, Inc., Honeywell International, Inc., Individually and f/k/a AlliedSignal, Inc., and as Successor-in-interest to the Bendix Corp., Howden Buffalo, Inc., Individually and as Successor-In-Interest to FB Sturtevant, The Howden Buffalo Group and Buffalo Fan, I.T.T. Industries, Inc., Individually and as successor to Bell & Gossett, Imo Industries, Inc. f/k/a Delaval, Inc., Individually and as Successor to Turbine Equipment Company, Jenkins Bros., John Crane, Inc., Koppers Company, Inc., Koppers Industries, Inc., Maremont Corporation, Individually and as Successor to Grizzly, Metropolitan Life Insurance Co., Morse Diesel, Inc., Morse Diesel International, Inc., Napa Auto Parts a/k/a National Automotive Parts Association, Nash Engineering Company (The), Northrop Grumman Corporation, Individually and as Successor to George A. Fuller Company, Occidental Chemical Corporation, Individually and as Successor to Durez Corporation, Owens-Illinois, Inc., Patterson Pump Company, a Subsidiary of the Gorman-Rupp Company and Individually and as successor to C.H. Wheeler Manufacturing and Griscom Russell, Plastics Engineering Company, Individually and as Successor to Plenco, Pneumo Abex Corporation, Pneumo-Abex Llc, Individually and as Successor to Abex Corporation, a Delaware Corporation, Research-Cottrell, Inc. n/k/a AWT Air Company, Inc., Riley Power, Inc. f/k/a Babcock Borsig Power, Inc. and f/k/a Riley Stoker Corporation d/b/a DB Riley, Inc., Rogers Corporation, Spence Engineering Company, Inc., Spirax Sarco, Inc., Spx Cooling Technologies, Inc., Individually as successor to Marley Cooling Technologies and Marley Cooling Towers, Superior Lidgerwood Mundy Corp., a/k/a Lidgerwood Manufacturing Co., Individually and as Successor to M.T. Davidson Co., Thomas O'Connor & Company, Inc., Currently known as O'Connor Constructors, Inc., Treadwell Corporation, Thrush Co., Inc., Turner Construction Company, Tuthill Corporation, Individually and as Successor to Kinney Vacuum Pump Company, Kinney Pump Company and Murray Turbine, Tyco Flow Control, Inc., Individually and as Successor to Keystone and Grinnell Corporation, Tyco International (Us) Inc., Individually and as Successor to Hancock Valves, Keystone, Lonergan Valves, Union Carbide Corporation, United Conveyor Corporation, Velan Valve Corp., Warren Pumps, Llc, Individually and as Successor to The Quimby Pump Company, Wolff & Munier, Inc., William Powell Company (The), York International Corporation, Individually and as Successor to Frick Company, Yuba Heat Transfer, a division of Connell Limited Partnership n/k/a SPX Heat Transfer LLC, Zurn Industries, Inc. a/k/a and Successor-in-Interest to Erie City Iron Works, R.T Vanderbilt Company, Inc., Individually And As Successor To International Tale Co., International Pulp Co., And Governeur Tale Co., Inc., Ace Hardware, Ace Hardware Corporation, Duro Dyne Corporation, Hexion Specialty Chemicals, Inc. F/K/A Borden Chemical, Inc., I.T.T. Industries, Inc., Individually And As Successor To Hoffman Specialty, Bell & Gossett, And Foster Engineering, Lighttolier Incorporated, Progress Lighting, Inc., Sid Harvey Industries, Inc., Sid Harvey Supply, Inc., Union Pumps, As A Textron Company, American Biltrite, Inc., Individually And Successor To Amtico Floors, Dap, Inc. K/N/A La Mirada Products Co., Inc., Kaiser Gypsum Company, Inc. Torts - Asbestos document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 02/10/2017 04:48 PM INDEX NO. 190012/2017 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/10/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------x STEVEN LEROY HALL, Index No. 190012-2017 Plaintiff, ACKNOWLEDGEMENT OF -against- RECEIPT and VERIFIED ANSWER TO PLAINTIFF’S AIR & LIQUID SYSTEMS CORPORATION, et al., VERIFIED COMPLAINT Defendants. -----------------------------------------------------------------------x Defendant, 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 (hereinafter "Westinghouse"), hereby acknowledges receipt of a Summons and a copy of Plaintiff’s Verified Complaint (hereinafter “Complaint”) in the above-captioned action. Westinghouse hereby answers the verified complaint in this action by reference to its Standard Answer filed pursuant to NYCAL Case Management Order No. 1 and raises each plaintiff named herein each affirmative defense contained in its Standard Answer. Dated: Newark, New Jersey /s/ Michael A. Tanenbaum February 10, 2017 Michael A. Tanenbaum, Esq. Tanenbaum Keale LLP Attorneys for Defendant 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 One Newark Center 1085 Raymond Boulevard – 16th Floor Newark, NJ 07102 (973) 242-0002 TO: BELLUCK & FOX, LLP Attorneys for Plaintiff 546 Fifth Avenue, 4th Floor New York, New York 10036 (212) 681-1575 1 of 3 FILED: NEW YORK COUNTY CLERK 02/10/2017 04:48 PM INDEX NO. 190012/2017 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/10/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------x STEVEN LEROY HALL, Index No. 190012-2017 Plaintiff, ATTORNEY’S -against- VERIFICATION AIR & LIQUID SYSTEMS CORPORATION, et al., Defendants. -----------------------------------------------------------------------x The undersigned affirms the following statements to be true under penalties of perjury pursuant to Rule 2106 of the Civil Practice Law and Rules: That he is an attorney at law and a member of the firm of Tanenbaum Keale LLP, attorneys for the defendant 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. That he has read the foregoing document and knows the contents thereof, and that the same is true to the knowledge of affirmant except as to the matters therein alleged upon information and belief and that as to those matters he believes them to be true. That the reason why this affirmation is being made by affirmant and not the defendant is that the defendant does not maintain an office in the county where affirmant maintains his offices. That the source of affirmant’s information and the grounds of his belief as to all the matters therein alleged upon information and belief are reports from and communication had with said corporation. Dated: Newark, New Jersey /s/ Michael A. Tanenbaum February 10, 2017 Michael A. Tanenbaum, Esq. -2- 2 of 3 FILED: NEW YORK COUNTY CLERK 02/10/2017 04:48 PM INDEX NO. 190012/2017 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 02/10/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------x STEVEN LEROY HALL, Index No. 190012-2017 Plaintiff, CERTIFICATE OF -against- SERVICE AIR & LIQUID SYSTEMS CORPORATION, et al., Defendants. -----------------------------------------------------------------------x I HEREBY CERTIFY that on the 10th day February, 2017, a copy of the foregoing Acknowledgement of Receipt and Verified Answer to Plaintiff’s Verified Complaint was filed electronically this day and is available for viewing from the Court’s ECF system. Notice of this filing will be sent to all counsel of record via the Court’s ECF system. Dated: Newark, New Jersey /s/ Michael A. Tanenbaum February 10, 2017 Michael A. Tanenbaum, Esq. -3- 3 of 3