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. 87 RECEIVED NYSCEF: 07/10/2023
EXHIBIT 2
FILED: NEW YORK COUNTY CLERK 07/10/2023
03/13/2023 10:29
06:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 87
46 RECEIVED NYSCEF: 07/10/2023
03/13/2023
FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
IN RE: NEW YORK CITY
ASBESTOS LITIGATION NYCAL
THIS DOCUMENT RELATES TO:
Index No.:
DAN ALBASRY, as Trustee of the Estate of NEWAL AL
SAAD, and FIRAS MOHAMMAD,
Plaintiffs, PLAINTIFFS’ INITIAL FACT SHEET
‐against‐
BARRETTS MINERALS INC., et al.,
Defendants.
1. Full name: Newal Al Saad
2. Address: 2201‐51 East Liberty Street, Toronto, Ontario (Canada) (Estate)
3. Date of birth: August 17, 1955
4. Social security number: N/A
5. Union/local/years of membership: N/A
6. Date of claimant’s first claimed asbestos exposure: Approximately August 1955
7. Smoking history:
For all cigarettes, pipes, cigars, please state the inclusive dates of claimant’s smoking
history, the products smoked, and the amount of product consumed per day: Newal Al Saad
was a never smoker.
8. At this preliminary stage of the proceedings, please provide as much of the following
information as is presently available: worksites, inclusive dates, and trade or occupation for
each site (each worksite should be identified as specifically as possible (i.e., ships worked on
in a given shipyard)):
Upon current information and belief, Newal Al Saad was not occupationally exposed to
asbestos. Ms. Al Saad was exposed to asbestos through personal use of talc‐containing
cosmetic products used by herself and those around her from childhood through
approximately 2021. Based upon available information, Ms. Al Saad was a retired teacher
and occasionally worked at a restaurant.
Page1
2524855_1
1 of 3
FILED: NEW YORK COUNTY CLERK 07/10/2023
03/13/2023 10:29
06:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 87
46 RECEIVED NYSCEF: 07/10/2023
03/13/2023
FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023
9. Claimed asbestos‐related disease, including date of diagnosis and name of diagnosing
physician or institution if known (an attached medical report would be helpful but is
optional): Newal Al Saad was diagnosed with malignant mesothelioma by Dr. Yunru Li at
Markham Souffville Hospital on or about January 26, 2021.
10. Plaintiffs are impressed with the need for accuracy in completing this form and are
reminded of the court’s inherent power to sanction for the filing of inaccurate information.
Dated: January 5, 2023 Yours etc.,
New York, New York
LANIER LAW FIRM PLLC
Attorneys for Plaintiffs
126 East 56th Street, 6th Floor
New York, New York 10022
Tel.: (212) 421‐2800
By: ______________________________
Darron E. Berquist, Esq.
Page2
2524855_1
2 of 3
FILED: NEW YORK COUNTY CLERK 07/10/2023
03/13/2023 10:29
06:29 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 87
46 RECEIVED NYSCEF: 07/10/2023
03/13/2023
FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
IN RE: NEW YORK CITY
ASBESTOS LITIGATION NYCAL
THIS DOCUMENT RELATES TO:
Index No.:
DAN ALBASRY, as Trustee of the Estate of NEWAL AL
SAAD, and FIRAS MOHAMMAD,
Plaintiffs, CERTIFICATION
‐against‐
BARRETT MINERALS INC., et al.,
Defendants.
Darron E. Berquist, an attorney duly admitted to practice before the Courts of the State of
New York, hereby certify, in accordance with 22 NYCRR Part 130‐1.1‐a of the Rules of the Chief
Administrator, that to the best of my knowledge, information and belief, which was formed after a
reasonable inquiry under the circumstances, the presentation of the foregoing Initial Fact Sheet and
its content are not frivolous, as the term is defined in Part 130.
Dated: January 5, 2023 Yours etc.,
New York, New York
LANIER LAW FIRM PLLC
Attorneys for Plaintiffs
126 East 56th Street, 6th Floor
New York, New York 10022
Tel.: (212) 421‐2800
By: ______________________________
Darron E. Berquist, Esq.
Page3
2524855_1
3 of 3
Preview
FILED: NEW YORK COUNTY CLERK 07/10/2023 10:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 07/10/2023 EXHIBIT 2 FILED: NEW YORK COUNTY CLERK 07/10/2023 03/13/2023 10:29 06:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 87 46 RECEIVED NYSCEF: 07/10/2023 03/13/2023 FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK CITY ASBESTOS LITIGATION NYCAL THIS DOCUMENT RELATES TO: Index No.: DAN ALBASRY, as Trustee of the Estate of NEWAL AL SAAD, and FIRAS MOHAMMAD, Plaintiffs, PLAINTIFFS’ INITIAL FACT SHEET ‐against‐ BARRETTS MINERALS INC., et al., Defendants. 1. Full name: Newal Al Saad 2. Address: 2201‐51 East Liberty Street, Toronto, Ontario (Canada) (Estate) 3. Date of birth: August 17, 1955 4. Social security number: N/A 5. Union/local/years of membership: N/A 6. Date of claimant’s first claimed asbestos exposure: Approximately August 1955 7. Smoking history: For all cigarettes, pipes, cigars, please state the inclusive dates of claimant’s smoking history, the products smoked, and the amount of product consumed per day: Newal Al Saad was a never smoker. 8. At this preliminary stage of the proceedings, please provide as much of the following information as is presently available: worksites, inclusive dates, and trade or occupation for each site (each worksite should be identified as specifically as possible (i.e., ships worked on in a given shipyard)): Upon current information and belief, Newal Al Saad was not occupationally exposed to asbestos. Ms. Al Saad was exposed to asbestos through personal use of talc‐containing cosmetic products used by herself and those around her from childhood through approximately 2021. Based upon available information, Ms. Al Saad was a retired teacher and occasionally worked at a restaurant. Page1 2524855_1 1 of 3 FILED: NEW YORK COUNTY CLERK 07/10/2023 03/13/2023 10:29 06:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 87 46 RECEIVED NYSCEF: 07/10/2023 03/13/2023 FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023 9. Claimed asbestos‐related disease, including date of diagnosis and name of diagnosing physician or institution if known (an attached medical report would be helpful but is optional): Newal Al Saad was diagnosed with malignant mesothelioma by Dr. Yunru Li at Markham Souffville Hospital on or about January 26, 2021. 10. Plaintiffs are impressed with the need for accuracy in completing this form and are reminded of the court’s inherent power to sanction for the filing of inaccurate information. Dated: January 5, 2023 Yours etc., New York, New York LANIER LAW FIRM PLLC Attorneys for Plaintiffs 126 East 56th Street, 6th Floor New York, New York 10022 Tel.: (212) 421‐2800 By: ______________________________ Darron E. Berquist, Esq. Page2 2524855_1 2 of 3 FILED: NEW YORK COUNTY CLERK 07/10/2023 03/13/2023 10:29 06:29 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 87 46 RECEIVED NYSCEF: 07/10/2023 03/13/2023 FILED: NEW YORK COUNTY CLERK 01/05/2023 02:28 PM INDEX NO. 190002/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/05/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK CITY ASBESTOS LITIGATION NYCAL THIS DOCUMENT RELATES TO: Index No.: DAN ALBASRY, as Trustee of the Estate of NEWAL AL SAAD, and FIRAS MOHAMMAD, Plaintiffs, CERTIFICATION ‐against‐ BARRETT MINERALS INC., et al., Defendants. Darron E. Berquist, an attorney duly admitted to practice before the Courts of the State of New York, hereby certify, in accordance with 22 NYCRR Part 130‐1.1‐a of the Rules of the Chief Administrator, that to the best of my knowledge, information and belief, which was formed after a reasonable inquiry under the circumstances, the presentation of the foregoing Initial Fact Sheet and its content are not frivolous, as the term is defined in Part 130. Dated: January 5, 2023 Yours etc., New York, New York LANIER LAW FIRM PLLC Attorneys for Plaintiffs 126 East 56th Street, 6th Floor New York, New York 10022 Tel.: (212) 421‐2800 By: ______________________________ Darron E. Berquist, Esq. Page3 2524855_1 3 of 3