On January 05, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Dan Albasry
As Trustee Of The Estate Of Newal Al Saad,
Firas Mohammad,
and
Barretts Minerals Inc.,
Beacon Cmp Corp.,
Brenntag Specialties Llc,
Charles B. Chrystal Company Inc.;,
Colgate Palmolive Co.;,
Conopco Inc.,
Glaxosmithkline Consumer Healthcare Holdings,
Glaxosmithkline Llc,
Gsk Consumer Health Inc.,
Lornamead Inc.,
Pfizer Inc.,
Port Jervis Laboratories Inc.,
The Procter & Gamble Co.,
Whittaker, Clark & Daniels Inc.,
Yardley Of London Inc.,
Yardley Of London Ltd.,,
for Torts - Asbestos
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/10/2023
EXHIBIT 1
FILED: NEW YORK COUNTY CLERK 07/10/2023
01/27/2023 10:29
05:30 PM INDEX NO. 190002/2023
190266/2022
NYSCEF DOC. NO. 86
34 RECEIVED NYSCEF: 07/10/2023
01/27/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------x
TIFFANY MACAULAY and DANIEL MACAULAY, AFFIDAVIT OF ROBERT
EDMONDS
Plaintiff,
-against-
Index No. 190266/2022
PORT JERVIS LABORATORIES INC. (f/k/a
KOLMAR LABORATORIES INC.)
Defendants.
------------------------------------------------------------------x
STATE OF CALIFORNIA }
} S.S.:
COUNTY OF LOS ANGELES }
Robert Edmonds, being duly sworn, deposes and says the following under the penalty of
perjury:
1. I am currently the head of North American Operations at KDC/One West Coast.
KDC/One is the parent company of Port Jervis Laboratories, Inc. ("Port Jervis"), formerly known
as Kolmar Laboratories, Inc. ("Kolmar"). From 2010 through 2015 I was the general manager of
witness"
Kolmar. I have served as Kolmar's "person most knowledgeable in tale-related litigation
on the company's behalf, and as such I am familiar with the facts set forth herein.
2. I submit this Affidavit in support of Kolmar's motion, pursuant to New York Civil
Practice Law & Rules § 511, for an Order changing the venue of this action from New York County
to Orange County.
3. Kolmar, now known as Port Jervis, is incorporated in the State of Delaware and
maintains its principal place of business at 20 King Street, Port Jervis, New York 12771.
4. The principal place of business for Kolmar has been in Orange County, New York
since the 1940's, and it does not have any employees, offices, or facilities in the Counties of New
York, Kings, Queens, Bronx, or Richmond.
FILED: NEW YORK COUNTY CLERK 07/10/2023
01/27/2023 10:29
05:30 PM INDEX NO. 190002/2023
190266/2022
NYSCEF DOC. NO. 86
34 RECEIVED NYSCEF: 07/10/2023
01/27/2023
Robert Edmonds
Sworn to before me this ___ ay of , 2023
S se Attachec( cortifïcctte
Notary Public
2
FILED: NEW YORK COUNTY CLERK 07/10/2023
01/27/2023 10:29
05:30 PM INDEX NO. 190002/2023
190266/2022
NYSCEF DOC. NO. 86
34 RECEIVED NYSCEF: 07/10/2023
01/27/2023
CALIFORNIA ACKNOWLEDGMENT CIVIL CODE § 1189
easasseasseammeseas
A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document
to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.
State of California
County of b
On 0 23 before me, Shm ShamSudeen, NcFary
T c
Date Here Insert Name and Title of the Officer
personally appeared Cher + 6à vY)cnò S
Name(s) of Signer(s)
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed
to the within instrument and acknowl dged to me that /she/they executed the same i i /her-/their
authorized capacity(ies), and that by isFherftheir-signature(s) on the instrument the person s), or the entity
upon behalf of which the person(s) acted, executed the instrument.
I certify under PENALTY OF PERJURY under the
laws of the State of California that the foregoing
paragraph is true and correct.
n e es c n and
WITNESS my hand official seal.
Signature
Place Notary Seal and/or Stamp Above Signature of Notary Public
OPTIONAL
Completing this information can deter alteration of the document or
fraudulent reattachment of this form to an unintended document.
Description of Attached Document
Title or Type of Document: f\ )
d Av 0 fW st>be H ÛdpCn
Document Date: bG/ A Number of Pages:
Signer(s) Other Than Named Above:
Capacity(ies) Claimed by Signer(s)
Signer's Name: Signer's Name:
O Corporate Officer - Title(s): ¡ Corporate Officer - Title(s):
O Partner - O Limited ¡ General ¡ Partner - o Limited o General
O Individual « Attorney in Fact ¡ Individual o Attorney in Fact
o Trustee o Guardian or Conservator o Trustee o Guardian or Conservator
O Other: O Other:
Signer is Representing: Signer is Representing:
©2019 National Notary Association
Document Filed Date
July 10, 2023
Case Filing Date
January 05, 2023
Category
Torts - Asbestos
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/10/2023 EXHIBIT 1 FILED: NEW YORK COUNTY CLERK 07/10/2023 01/27/2023 10:29 05:30 PM INDEX NO. 190002/2023 190266/2022 NYSCEF DOC. NO. 86 34 RECEIVED NYSCEF: 07/10/2023 01/27/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------x TIFFANY MACAULAY and DANIEL MACAULAY, AFFIDAVIT OF ROBERT EDMONDS Plaintiff, -against- Index No. 190266/2022 PORT JERVIS LABORATORIES INC. (f/k/a KOLMAR LABORATORIES INC.) Defendants. ------------------------------------------------------------------x STATE OF CALIFORNIA } } S.S.: COUNTY OF LOS ANGELES } Robert Edmonds, being duly sworn, deposes and says the following under the penalty of perjury: 1. I am currently the head of North American Operations at KDC/One West Coast. KDC/One is the parent company of Port Jervis Laboratories, Inc. ("Port Jervis"), formerly known as Kolmar Laboratories, Inc. ("Kolmar"). From 2010 through 2015 I was the general manager of witness" Kolmar. I have served as Kolmar's "person most knowledgeable in tale-related litigation on the company's behalf, and as such I am familiar with the facts set forth herein. 2. I submit this Affidavit in support of Kolmar's motion, pursuant to New York Civil Practice Law & Rules § 511, for an Order changing the venue of this action from New York County to Orange County. 3. Kolmar, now known as Port Jervis, is incorporated in the State of Delaware and maintains its principal place of business at 20 King Street, Port Jervis, New York 12771. 4. The principal place of business for Kolmar has been in Orange County, New York since the 1940's, and it does not have any employees, offices, or facilities in the Counties of New York, Kings, Queens, Bronx, or Richmond. FILED: NEW YORK COUNTY CLERK 07/10/2023 01/27/2023 10:29 05:30 PM INDEX NO. 190002/2023 190266/2022 NYSCEF DOC. NO. 86 34 RECEIVED NYSCEF: 07/10/2023 01/27/2023 Robert Edmonds Sworn to before me this ___ ay of , 2023 S se Attachec( cortifïcctte Notary Public 2 FILED: NEW YORK COUNTY CLERK 07/10/2023 01/27/2023 10:29 05:30 PM INDEX NO. 190002/2023 190266/2022 NYSCEF DOC. NO. 86 34 RECEIVED NYSCEF: 07/10/2023 01/27/2023 CALIFORNIA ACKNOWLEDGMENT CIVIL CODE § 1189 easasseasseammeseas A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of b On 0 23 before me, Shm ShamSudeen, NcFary T c Date Here Insert Name and Title of the Officer personally appeared Cher + 6à vY)cnò S Name(s) of Signer(s) who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowl dged to me that /she/they executed the same i i /her-/their authorized capacity(ies), and that by isFherftheir-signature(s) on the instrument the person s), or the entity upon behalf of which the person(s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. n e es c n and WITNESS my hand official seal. Signature Place Notary Seal and/or Stamp Above Signature of Notary Public OPTIONAL Completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document. Description of Attached Document Title or Type of Document: f\ ) d Av 0 fW st>be H ÛdpCn Document Date: bG/ A Number of Pages: Signer(s) Other Than Named Above: Capacity(ies) Claimed by Signer(s) Signer's Name: Signer's Name: O Corporate Officer - Title(s): ¡ Corporate Officer - Title(s): O Partner - O Limited ¡ General ¡ Partner - o Limited o General O Individual « Attorney in Fact ¡ Individual o Attorney in Fact o Trustee o Guardian or Conservator o Trustee o Guardian or Conservator O Other: O Other: Signer is Representing: Signer is Representing: ©2019 National Notary Association