Preview
FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99
NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023
EXHIBIT A
FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99
NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
Index No. :
ROGER PAUL SPEZIO, SR. and KATHLEEN
SPEZIO, Date Filed:
Plaintiffs, Plaintiff designates
ULSTER
v. County as the place of trial
3M COMPANY, Individually and as Successor to The basis of the venue is
Minnesota Mining and Manufacturing Company, et DEFENDANTS’ PLACE OF
al., BUSINESS
Defendants. SUMMONS
See Attached Rider - FULL CAPTION
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve
a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice
of Appearance, on the Plaintiff’s Attorney within 20 days after the service of this Summons,
exclusive of the day of service (or within 30 days after the service is complete if this Summons is
not personally delivered to you within the State of New York). In the case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
Dated: New York, New York Yours etc.,
January 13, 2023
BELLUCK & FOX, LLP
Attorneys for Plaintiff
546 Fifth Avenue, 5th Floor
New York, New York 10036
(212) 681-1575
By:/s/ Joseph W. Belluck, Esq.
Joseph W. Belluck, Esq.
FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99
NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
Index No. :
ROGER PAUL SPEZIO, SR. and KATHLEEN
SPEZIO, FULL CAPTION RIDER
Plaintiffs,
- against -
3M COMPANY, Individually and as Successor to
Minnesota Mining and Manufacturing
Company;
A.O. SMITH WATER PRODUCTS;
AII ACQUISITION CORPORATION, LLC,
Individually and as Successor-in-Interest to
Athlone Industries, Inc. and Holland Furnace
Company;
AIR & LIQUID SYSTEMS CORPORATION, as
Successor by Merger to Buffalo Pumps, Inc.;
ALCOA INC., Individually and as successor in interest
to Tilo Roofing Co.;
AMERICAN OPTICAL CORPORATION;
ARMSTRONG INTERNATIONAL, INC.;
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves
& Controls USA Inc.;
AURORA PUMP COMPANY;
AVCO CORPORATION, A Textron Lycoming
Division, Individually and as Successor to
Lycoming Engines f/k/a Lycoming
Manufacturing, Spencer Heater Company,
and Spencer Heater Division of Lycoming;
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;
CLEAVER BROOKS COMPANY f/k/a Aqua Chem,
Inc.;
COLUMBIA BOILER COMPANY OF
POTTSTOWN;
COMPUDYNE CORPORATION, Individually and as
Successor to York-Shipley;
-2-
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CONTINENTAL MOTORS, INC.;
CONTINENTAL MOTORS INC. f/k/a Teledyne
Continental Motors, Inc., Individually and as
successor to Continental Motors Inc. and
Continental Motors Company;
CROWN BOILER CO.;
DEAN PUMP DIVISION;
EATON AEROQUIP, INC. f/k/a Aeroquip
Corporation;
ECR INTERNATIONAL, INC., Individually and as
Successor to Dunkirk, Dunkirk Boilers and
Utica Boilers and Pennco, Inc.;
ELECTROLUX HOME PRODUCTS, INC.,
Individually and as Successor to Tappan and
Copes Vulcan;
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;
GARDNER-DENVER, INC., Individually and as
Successor to Nash Engineering Company;
GARDNER-DENVER NASH LLC, Individually and
as Successor to Nash Engineering Company;
GENERAL ELECTRIC COMPANY;
GOULDS PUMPS INC.;
GRINNELL CORPORATION;
HOFFMAN/NEW YORKER, 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;
INTERNATIONAL COMFORT PRODUCTS LLC,
Individually and as Successor to Heil Heating
and Cooling;
KOHLER CO.;
LENNOX INDUSTRIES, INC., Individually and as
Successor to Lennox Furnace Company and
Ducane;
MARIO & DIBONO PLASTERING CO. INC.;
-3-
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METROPOLITAN LIFE INSURANCE COMPANY;
NEW YORKER BOILER COMPANY, INC.;
PARKER HANNIFIN CORPORATION, Individually
and as Successor by Merger to Stratoflex, Inc.
(Cleveland Brake Division) and EIS;
PRATT & WHITNEY MEASUREMENT SYSTEMS,
INC.;
PRATT & WHITNEY POWER SYSTEMS, INC.;
REDCO CORP., f/k/a Crane Co.;
RHEEM MANUFACTURING COMPANY, INC.;
ROCKWELL AUTOMATION INC., Individually
and as Successor to Timken Heating Business
and S. Co., Inc. f/k/a Scaife Company, as
Successor in Interest to Rockwell Spring &
Axle Company's Timken Silent Automatic
Division;
SID HARVEY INDUSTRIES, INC.;
SID HARVEY SUPPLY, INC.;
SPENCE ENGINEERING COMPANY, INC.;
SPENCER HEATER, a Lycoming division of AVCO
Corporation;
SPIRAX SARCO, INC.;
TACO, INC.;
TECHNIFY MOTOR (USA), INC., Individually
and as Successor to Teledyne Continental
Motors, Inc. f/k/a Continental Motors, Inc.,
and Continental Motors Company;
TELEDYNE TECHNOLOGIES INC., Individually
and as Successor to Teledyne Continental
Motors, Inc. f/k/a Continental Motors, Inc.,
Continental Motors Company;
TEXACO, INC.;
UNION CARBIDE CORPORATION;
UNITED TECHNOLOGIES CORPORATION,
Individually and as Successor to Pratt &
Whitney (Pratt & Whitney/Aircraft Division)
and Franklin Engine Company f/k/a Aircooled
Motors Company;
VELAN VALVE CORP.;
WARREN PUMPS, LLC, Individually and as
Successor to The Quimby Pump Company;
WEIL McLAIN, a division of Marley Wylain
Company;
WILLIAM POWELL COMPANY (THE);
YORK INTERNATIONAL CORPORATION,
Individually and as Successor to Frick
-4-
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Company.
Defendants.
-5-
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Defendants’ addresses:
ROGER PAUL SPEZIO, SR.’s DEFENDANT ADDRESS LIST
DEFENDANTS SERVICE
3M COMPANY, Individually and as Successor to Minnesota Registered Agent
Mining and Manufacturing Company Corporation Service Company
3M Center / BLDG 224-5N-40 2345 Rice Street, Suite 230
St Paul, Minnesota 55144-1000 St. Paul, MN 55113
A.O. SMITH WATER PRODUCTS Registered Agent:
A.O. Smith Corporation Corporation Service Company
Attn: Debra Schwanda 8040 Excelsior Drive, Ste 400
11270 W. Park Place Madison, Wisconsin 53717
Milwaukee, WI 53224-9502
AII ACQUISITION CORPORATION, LLC, Individually DIRECT
and as Successor-in-Interest to Athlone Industries, Inc. and
Holland Furnace Company
116 15th Street
Pittsburgh, Pennsylvania 15222
AIR & LIQUID SYSTEMS CORPORATION, as Successor CT Corporation System
by Merger to Buffalo Pumps, Inc. 4701 Cox Rd Ste 301
726 Bell Avenue, Suite 302 Glen Allen VA 32060
Carnegie, Pennsylvania, 15106
ALCOA INC., Individually and as successor in interest to DIRECT
Tilo Roofing Co.
Sam Haschets,
202 Bradshaw Dr.
North Hills, PA 15143
AMERICAN OPTICAL CORPORATION c/o The Corporation Trust Company
14 Mechanic Street 1209 North Orange Street
Southbridge, Massachusetts 01550-1043 Wilmington, Delaware 19801
ARMSTRONG INTERNATIONAL, INC. DIRECT
900 Maple Street
Three Rivers, Michigan 49093
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & CT Corporation System
Controls USA Inc. 55 Federal St, Ste 700
c/o Weir Valves & Controls Usa Inc. Boston, MA 02110
29 Old Right Road
Ipswich, Massachusetts 01938
-6-
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AURORA PUMP COMPANY DIRECT - CERTIFIED MAIL RRR
800 Airport Road c/o Kevin Keyes
North Aurora, Illinois 60542 SPX Corporation
6325 Ardrey Kell Road, Suite 400
Charlotte, N.C. 28277
AVCO CORPORATION, A Textron Lycoming Division, c/o Corporate Trust Systems
Individually and as Successor to Lycoming Engines f/k/a 28 Liberty Street
Lycoming Manufacturing, Spencer Heater Company, and New York, New York
Spencer Heater Division of Lycoming
40 Westminster Street
Providence, Rhode Island 02903-2500
BW/IP INTERNATIONAL CO., formerly known as Borg DIRECT
Warner Industrial Products Inc., a former subsidiary of and
successor to Borg Warner Corp. and Byron Jackson Pumps
BW/IP International Inc.
Flowserve World Headquarters
5215 N. O'Connor Blvd., Suite 2300
Irving, Texas 75039
CARRIER CORPORATION c/o United Agent Group Inc.
13995 Pasteur Blvd 600 Mamaroneck Avenue, #400
Palm Beach Gardens, FL 33418 Harrison, NY 10528
CBS CORPORATION, a Delaware Corporation, f/k/a c/o Corporation Service Company
Viacom Inc, Successor by merger to CBS Corporation, a 80 State Street
Pennsylvania Corporation, f/k/a Westinghouse Electric Albany, New York 12207
Corporation
c/o Adrienne Harrington
51 West 52nd Street
New York, New York 10019
CLEAVER-BROOKS COMPANY f/k/a Aqua-Chem, Inc. DIRECT
11270 W. Park Place, Floor 4
Milwaukee, WI 53224
COLUMBIA BOILER COMPANY OF POTTSTOWN DIRECT
390 Old Reading Pike
Stowe, PA 19464
COMPUDYNE CORPORATION, Individually and as DIRECT
Successor to York-Shipley
CompuDyne Corporation
CSC Services of Nevada, Inc.
112 North Curry Street
Carson City, Nevada 89703
-7-
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CONTINENTAL MOTORS INC. DIRECT
c/o National Corporate Research LTD.
850 New Burton Road, Suite 201
Dover, Delaware 19904
CONTINENTAL MOTORS INC. f/k/a Teledyne Continental DIRECT
Motors, Inc., Individually and as successor to Continental
Motors Inc. and Continental Motors Company
c/o National Corporate Research LTD.
850 New Burton Road, Suite 201
Dover, Delaware 19904
CROWN BOILER CO. DIRECT
3633 I Street
Philadelphia, Pennsylvania 19134
DEAN PUMP DIVISION DIRECT
6040 Guion Road
Indianapolis, Indiana 46254
EATON AEROQUIP, INC. f/k/a Aeroquip Corporation DIRECT
CT Corporation
4400 Easton Cmns #125
Columbus, OH 43219
ECR INTERNATIONAL, INC., Individually and as c/o Secretary of State
Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Albany, New York 12207
Pennco, Inc.
2201 Dwyer Avenue
Utica, New York 13504
ELECTROLUX HOME PRODUCTS, INC., Individually c/o Corporate Trust Systems
and as Successor to Tappan and Copes-Vulcan Company 28 Liberty Street
10200 David Taylor Drive New York, New York
Charlotte NC 28262
FLOWSERVE US, INC., solely as Successor to Rockwell c/o Corporate Trust Systems
Manufacturing Company, Edward Valves, Inc., Nordstrom 28 Liberty Street
Valves, Inc. and Edward Vogt Valve Company New York, New York
Flowserve Corporation OR
General Counsel CMRRR
5215 North O’Connor Blvd, Ste 2300
Irving, Texas 75039
FMC CORPORATION, Individually and as Successor to c/o Corporate Trust Systems
Northern Pump Company, Coffin and Peerless Pump 28 Liberty Street
Company New York, New York
FMC Tower at Cira Centre South
2929 Walnut Street
Philadelphia, Pennsylvania 19104
-8-
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GARDNER DENVER, INC., Individually and as Successor Registered Agent:
to Nash Engineering Company c/o CT Corporation System
1800 Gardner Expressway 208 South LaSalle Street
Quincy, Illinois 62301 Chicago, Illinois 60604
GARDNER DENVER NASH, LLC, Individually and as Registered Agent:
Successor to Nash Engineering Company c/o CT Corporation System
2 Trefoil Drive 67 Burnside Avenue
Trumbull, CT 06611 East Hartford, CT 06108
GENERAL ELECTRIC COMPANY DIRECT
3135 Easton Turnpike Julie Klusza, Esq.
Fairfield, Connecticut 06432 Electric Insurance Company
75 Sam Fonzo Drive
Beverly, Massachusetts 01915-1000
GOULDS PUMPS, INC. DIRECT
ITT-Goulds Pumps Headquarters
240 Fall Street
Seneca Falls, NY 13148
GRINNELL CORPORATION DIRECT – CERTIFIED MAIL RRR
3 Tyco Park Brady Edwards, Esq.
Exeter, New Hampshire 03833 Morgan, Lewis & Bockius LLP
1000 Louisiana St., Suite 4200
Houston, Texas 77002-5006
HOFFMAN/NEW YORKER, INC. DIRECT
46 Clinton Place
Hackensack, New Jersey 07601
HONEYWELL INTERNATIONAL, INC., Individually and c/o Corporation Service Company
f/k/a Alliedsignal, Inc., and as Successor-in-interest to the 80 State Street
Bendix Corp. Albany, New York 12207-2543
115 Tabor Road
Morris Plains, New Jersey 07950
HOWDEN BUFFALO, INC., Individually and as Successor- Registered Agent:
In-Interest to FB Sturtevant, The Howden Buffalo Group C T Corporation System
and Buffalo Fan 2 Office Park Court, Suite 103
Columbia, South Carolina 29223
I.T.T. INDUSTRIES, INC., Individually and as successor to c/o IntelCo Management, Inc.
Bell & Gossett Tara Solanki, Paralegal
ITT Corporation 187 Danbury Road, Suite 2D
1133 Westchester Avenue, Suite N300 Wilton, CT 06897
White Plains, New York 10604
-9-
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INTERNATIONAL COMFORT PRODUCTS LLC,
Individually and as Successor to Heil Heating and Cooling
Lewisburg, Tennessee
KOHLER CO. DIRECT
Herbert V. Kohler, Jr.
444 Highland Drive
Kohler, Wisconsin 53044
LENNOX INDUSTRIES, INC., Individually and as Corporation Service Company
Successor to Lennox Furnace Company and Ducane 80 State Street
2100 Lake Park Boulevard Albany, New York 12207-2543
Richardson, Texas 75080
MARIO & DIBONO PLASTERING CO. INC. DIRECT – CERTIFIED MAIL RRR
Jeffrey C. Fegan, Esq.
Clyde & Co. US LLP
The Chrysler Building
405 Lexington Avenue, 16th Floor
New York, New York 10174
METROPOLITAN LIFE INSURANCE COMPANY c/o Corporate Trust Systems
200 Park Avenue 28 Liberty Street
New York, New York 10166 New York, New York
NEW YORKER BOILER COMPANY, INC. Corporation Service Company
2595 Interstate Drive, Suite 103
Harrisburg, Pennsylvania 17110
PARKER HANNIFIN CORPORATION, Individually and as c/o Corporate Trust Systems
Successor by Merger to Stratoflex, Inc. (Cleveland Brake 28 Liberty Street
Division) and EIS New York, New York
6035 Parkland Boulevard
Cleveland, Ohio 44124-4141
PRATT & WHITNEY MEASUREMENT SYSTEMS, INC. Registered agent:
66 Douglas Street Scott B. Franklin, Esq.
Bloomfield, CT 06002 68 South Main Street
West Hartford, CT 06107
PRATT & WHITNEY POWER SYSTEMS, INC. c/o Corporate Trust Systems
80 Lamberton Road 28 Liberty Street
MS 191-11 New York, New York
Windsor, Connecticut 06095
REDCO CORP. f/k/a Crane Co. Registered Agent
Redco Corporation The Corporation Trust Company
1000 N. West Street, Suite 1200 1209 Orange Street
Wilmington, Delaware 19801 Corporation Trust Center
Wilmington, Delaware 19801
- 10 -
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RHEEM MANUFACTURING COMPANY, INC. Registered Agent:
1100 Abernathy Road, Suite 1700 Corporation Service Company
Atlanta, GA 30328 40 Technology Parkway South, Suite 300
Norcross, GA 30092
ROCKWELL AUTOMATION, INC., Individually and as c/o Corporate Trust Systems
Successor to Allen Bradley, Timken Heating Business and S. 28 Liberty Street
Co., Inc. f/k/a Scaife Company, as Successor in Interest to New York, New York
Rockwell Spring & Axle Company’s Timken Silent
Automatic Division
Allen-Bradley & Rockwell Software Brands
1201 South Second Street
Milwaukee, Wisconsin 53204-2496
SID HARVEY INDUSTRIES, INC. c/o Secretary of State
605 Locust Street Albany, New York 12207
Garden City, New York 11530-6597
SID HARVEY SUPPLY, INC. c/o Secretary of State
Albany, New York 12207
SPENCE ENGINEERING COMPANY, INC. Corporation Service Company
1241 Old Temescal Road, Unit 101 80 State Street
Corona, CA 92881 Albany, NY 12207-2543
SPENCER HEATER, a Lycoming division of AVCO DIRECT
Corporation
c/o AVCO Corporation
40 Westminster Street
Providence, Rhode Island 02903
SPIRAX SARCO, INC. c/o CT Corporation System
1150 Northpoint Boulevard 2 Office Park Court, Suite 103
Blythewood, South Carolina 29016 Columbia, South Carolina 29223
TACO, INC. Corporation Service Company
1160 Cranston Street 100 Pearl Street, 16th Floor
Cranston, Rhode Island 02920 Hartford, CT 06103
TECHNIFY MOTOR (USA), INC., Individually and as c/o National Corporate Research LTD
Successor to Teledyne Continental Motors, Inc. f/k/a 850 New Burton Road, Suite 201
Continental Motors, Inc. and Continental Motors Company Dover, Delaware 19904
TELEDYNE TECHNOLOGIES INC., Individually and as c/o National Corporate Research, Ltd.
Successor to Teledyne Continental Motors, Inc. f/k/a 523 W. 6th Street, Suite 544
Continental Motors, Inc., Continental Motors Company Los Angeles, California 90014
- 11 -
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TEXACO, INC. c/o The Prentice Hall Corp. Systems
2000 Westchester Avenue 80 State Street
White Plains, New York Albany, New York 12207
UNION CARBIDE CORPORATION c/o Corporate Trust Systems
28 Liberty Street
New York, New York
UNITED TECHNOLOGIES CORPORATION, Individually c/o Corporate Trust Systems
and as Successor to Pratt & Whitney (Pratt & 28 Liberty Street
Whitney/Aircraft Division) and Franklin Engine Company New York, New York
f/k/ Aircooled Motors Company
United Technologies Building
400 Main Street
East Hartford, CT 06108
VELAN VALVE CORP. c/o Corporation Service Company
94 Avenue C 80 State Street
Williston, Vermont 05495-9732 Albany, New York 12207-2543
WARREN PUMPS LLC, Individually and as Successor to c/o The Corporation Trust Company
The Quimby Pump Company 1209 North Orange Street
82 Bridges Avenue Wilmington, Delaware 19801
Warren, Massachusetts 01083-0969
WEIL McLAIN, A Division of Marley-Wylain Company DIRECT
6325 Ardrey Kell Road, Suite 400
Charlotte, N.C. 28277
WILLIAM POWELL COMPANY (THE) DIRECT
3261 Spring Grove Ave.
Cincinnati, OH 45225
YORK INTERNATIONAL CORPORATION, Individually c/o CT Corporation System
and as Successor to Frick Company 301 S. Bedford St. Suite 1
5757 N. Green Bay Avenue Madison, WI 53703
PO Box 591
Milwaukee, Wisconsin 53201
- 12 -
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ULSTER
Index No. :
ROGER PAUL SPEZIO, SR. and KATHLEEN
SPEZIO, VERIFIED COMPLAINT
Plaintiffs,
- against -
3M COMPANY, Individually and as Successor to
Minnesota Mining and Manufacturing
Company;
A.O. SMITH WATER PRODUCTS;
AII ACQUISITION CORPORATION, LLC,
Individually and as Successor-in-Interest to
Athlone Industries, Inc. and Holland Furnace
Company;
AIR & LIQUID SYSTEMS CORPORATION, as
Successor by Merger to Buffalo Pumps, Inc.;
ALCOA INC., Individually and as successor in interest
to Tilo Roofing Co.;
AMERICAN OPTICAL CORPORATION;
ARMSTRONG INTERNATIONAL, INC.;
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves
& Controls USA Inc.;
AURORA PUMP COMPANY;
AVCO CORPORATION, A Textron Lycoming
Division, Individually and as Successor to
Lycoming Engines f/k/a Lycoming
Manufacturing, Spencer Heater Company,
and Spencer Heater Division of Lycoming;
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;
CLEAVER BROOKS COMPANY f/k/a Aqua Chem,
Inc.;
COLUMBIA BOILER COMPANY OF
POTTSTOWN;
COMPUDYNE CORPORATION, Individually and as
Successor to York-Shipley;
- 13 -
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CONTINENTAL MOTORS, INC.;
CONTINENTAL MOTORS INC. f/k/a Teledyne
Continental Motors, Inc., Individually and as
successor to Continental Motors Inc. and
Continental Motors Company;
CROWN BOILER CO.;
DEAN PUMP DIVISION;
EATON AEROQUIP, INC. f/k/a Aeroquip
Corporation;
ECR INTERNATIONAL, INC., Individually and as
Successor to Dunkirk, Dunkirk Boilers and
Utica Boilers and Pennco, Inc.;
ELECTROLUX HOME PRODUCTS, INC.,
Individually and as Successor to Tappan and
Copes Vulcan;
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;
GARDNER-DENVER, INC., Individually and as
Successor to Nash Engineering Company;
GARDNER-DENVER NASH LLC, Individually and
as Successor to Nash Engineering Company;
GENERAL ELECTRIC COMPANY;
GOULDS PUMPS INC.;
GRINNELL CORPORATION;
HOFFMAN/NEW YORKER, 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;
INTERNATIONAL COMFORT PRODUCTS LLC,
Individually and as Successor to Heil Heating
and Cooling;
KOHLER CO.;
LENNOX INDUSTRIES, INC., Individually and as
Successor to Lennox Furnace Company and
Ducane;
MARIO & DIBONO PLASTERING CO. INC.;
- 14 -
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METROPOLITAN LIFE INSURANCE COMPANY;
NEW YORKER BOILER COMPANY, INC.;
PARKER HANNIFIN CORPORATION, Individually
and as Successor by Merger to Stratoflex, Inc.
(Cleveland Brake Division) and EIS;
PRATT & WHITNEY MEASUREMENT SYSTEMS,
INC.;
PRATT & WHITNEY POWER SYSTEMS, INC.;
REDCO CORP., f/k/a Crane Co.;
RHEEM MANUFACTURING COMPANY, INC.;
ROCKWELL AUTOMATION INC., Individually
and as Successor to Timken Heating Business
and S. Co., Inc. f/k/a Scaife Company, as
Successor in Interest to Rockwell Spring &
Axle Company's Timken Silent Automatic
Division;
SID HARVEY INDUSTRIES, INC.;
SID HARVEY SUPPLY, INC.;
SPENCE ENGINEERING COMPANY, INC.;
SPENCER HEATER, a Lycoming division of AVCO
Corporation;
SPIRAX SARCO, INC.;
TACO, INC.;
TECHNIFY MOTOR (USA), INC., Individually
and as Successor to Teledyne Continental
Motors, Inc. f/k/a Continental Motors, Inc.,
and Continental Motors Company;
TELEDYNE TECHNOLOGIES INC., Individually
and as Successor to Teledyne Continental
Motors, Inc. f/k/a Continental Motors, Inc.,
Continental Motors Company;
TEXACO, INC.;
UNION CARBIDE CORPORATION;
UNITED TECHNOLOGIES CORPORATION,
Individually and as Successor to Pratt &
Whitney (Pratt & Whitney/Aircraft Division)
and Franklin Engine Company f/k/a Aircooled
Motors Company;
VELAN VALVE CORP.;
WARREN PUMPS, LLC, Individually and as
Successor to The Quimby Pump Company;
WEIL McLAIN, a division of Marley Wylain
Company;
WILLIAM POWELL COMPANY (THE);
YORK INTERNATIONAL CORPORATION,
Individually and as Successor to Frick
- 15 -
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Company.
Defendants.
Plaintiffs by their attorneys, BELLUCK & FOX LLP, upon information and belief, at all
times hereinafter mentioned allege as follows:
THE PARTIES
1. Plaintiffs are residents of the State of New York unless otherwise specified in
individual complaints.
2. Plaintiffs allege that plaintiff, ROGER PAUL SPEZIO, SR. has been diagnosed
with Mesothelioma as a result of his exposure to asbestos.
3. At this time, Plaintiffs are alleging that there is no Post-1980 exposure, but should
evidence be produced to the contrary, the evidence controls over this preliminary allegation, and
this allegation is presumptively modified to conform to the evidence.
4. The term “Defendants” shall apply to all corporate and business entities, and/or
their predecessors and/or successors in interest as more fully described and enumerated in the
captions of individual complaints subsequently filed in the "short form" in accordance with the
applicable case management order of this Court.
5. The Defendants have done business in this State, have conducted or transacted
business in this State, have committed one or more tortious acts within this state, or have
otherwise performed acts within and/or without this State giving rise to injuries and losses within
this State, which acts subject each Defendant to the jurisdiction of the Courts of this State.
6. Defendant 3M COMPANY, Individually and as Successor to Minnesota
Mining and Manufacturing Company was and is a duly organized foreign and/or domestic
corporation doing business and/or transacting business in the State of New York and/or should
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have expected its acts to have consequences within the State of New York. At all times relevant,
it has engaged in the sale and distribution of materials and products containing the substance
asbestos.
7. Defendant A.O. SMITH WATER PRODUCTS was and is a duly organized
foreign corporation doing business and/or transacting business in the State of New York and/or
should have expected its acts to have consequences within the State of New York. At all times
relevant, it has engaged in the sale and distribution of materials and products containing the
substance asbestos.
8. Defendant AII ACQUISITION CORPORATION, LLC, Individually and as
Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company was and is
a duly organized foreign and/or domestic corporation doing business and/or transacting business
in the State of New York and/or should have expected its acts to have consequences within the
State of New York. At all times relevant, it has engaged in the sale and distribution of materials
and products containing the substance asbestos.
9. Defendant AIR & LIQUID SYSTEMS CORPORATION, as Successor by
Merger to Buffalo Pumps, Inc. was and is a duly organized foreign corporation doing business
and/or transacting business in the State of New York and/or should have expected its acts to have
consequences within the State of New York. At all times relevant, it has engaged in the sale and
distribution of materials and products containing the substance asbestos.
10. Defendant ALCOA INC., Individually and as successor in interest to Tilo
Roofing Co. was and is a duly organized foreign and/or domestic corporation doing business
and/or transacting business in the State of New York and/or should have expected its acts to have
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consequences within the State of New York. At all times relevant, it has engaged in the sale and
distribution of materials and products containing the substance asbestos.
11. Defendant AMERICAN OPTICAL CORPORATION was and is a duly
organized foreign and/or domestic corporation doing business and/or transacting business in the
State of New York and/or should have expected its acts to have consequences within the State of
New York. At all times relevant, it has engaged in the sale and distribution of materials and
products containing the substance asbestos.
12. Defendant ARMSTRONG INTERNATIONAL, INC. was and is a duly
organized foreign and/or domestic corporation doing business and/or transacting business in the
State of New York and/or should have expected its acts to have consequences within the State of
New York. At all times relevant, it has engaged in the sale and distribution of materials and
products containing the substance asbestos.
13. Defendant ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls
USA Inc. was and is a duly organized foreign corporation doing business and/or transacting
business in the State of New York and/or should have expected its acts to have consequences
within the State of New York. At all times relevant, it has engaged in the sale and distribution of
materials and products containing the substance asbestos.
14. Defendant AURORA PUMP COMPANY was and is a duly organized foreign
and/or domestic corporation doing business and/or transacting business in the State of New York
and/or should have expected its acts to have consequences within the State of New York. At all
times relevant, it has engaged in the sale and distribution of materials and products containing
the substance asbestos.
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15. Defendant AVCO CORPORATION, A Textron Lycoming Division,
Individually and as Successor to Lycoming Engines f/k/a Lycoming Manufacturing,
Spencer Heater Company and Spencer Heater Division of Lycoming was and is a duly
organized foreign and/or domestic corporation doing business and/or transacting business in the
State of New York and/or should have expected its acts to have consequences within the State of
New York. At all times relevant, it has engaged in the sale and distribution of materials and
products containing the substance asbestos.
16. Defendant 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 was and is a duly organized foreign corporation doing business and/or
transacting business in the State of New York and/or should have expected its acts to have
consequences within the State of New York. At all times relevant, it has engaged in the sale and
distribution of materials and products containing the substance asbestos.
17. Defendant CARRIER CORPORATION was and is a duly organized foreign
corporation doing business and/or transacting business in the State of New York and/or should
have expected its acts to have consequences within the State of New York. At all times relevant,
it has engaged in the sale and distribution of materials and products containing the substance
asbestos.
18. 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 was and is a duly organized foreign corporation doing business and/or
transacting business in the State of New York and/or should have expected its acts to have
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consequences within the State of New York. At all times relevant, it has engaged in the sale and
distribution of materials and products containing the substance asbestos.
19. Defendant CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc. was and
is a duly organized foreign corporation doing business and/or transacting business in the State of
New York and/or should have expected its acts to have consequences within the State of New
York. At all times relevant, it has engaged in the sale and distribution of materials and products
containing the substance asbestos.
20. Defendant COLUMBIA BOILER COMPANY OF POTTSTOWN was and is
a duly organized domestic corporation doing business and/or transacting business in the State of
New York and/or should have expected its acts to have consequences within the State of New
York. At all times relevant, it has engaged in the sale and distribution of materials and products
containing the substance asbestos.
21. Defendant COMPUDYNE CORPORATION, Individually and as Successor
to York-Shipley was and is a duly organized domestic corporation doing business and/or
transacting business in the State of New York and/or should have expected its acts to have
consequences within the State of New York. At all times relevant, it has engaged in the sale and
distribution of materials and products contain
Preview
FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 EXHIBIT A FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER Index No. : ROGER PAUL SPEZIO, SR. and KATHLEEN SPEZIO, Date Filed: Plaintiffs, Plaintiff designates ULSTER v. County as the place of trial 3M COMPANY, Individually and as Successor to The basis of the venue is Minnesota Mining and Manufacturing Company, et DEFENDANTS’ PLACE OF al., BUSINESS Defendants. SUMMONS See Attached Rider - FULL CAPTION TO THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance, on the Plaintiff’s Attorney within 20 days after the service of this Summons, exclusive of the day of service (or within 30 days after the service is complete if this Summons is not personally delivered to you within the State of New York). In the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: New York, New York Yours etc., January 13, 2023 BELLUCK & FOX, LLP Attorneys for Plaintiff 546 Fifth Avenue, 5th Floor New York, New York 10036 (212) 681-1575 By:/s/ Joseph W. Belluck, Esq. Joseph W. Belluck, Esq. FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER Index No. : ROGER PAUL SPEZIO, SR. and KATHLEEN SPEZIO, FULL CAPTION RIDER Plaintiffs, - against - 3M COMPANY, Individually and as Successor to Minnesota Mining and Manufacturing Company; A.O. SMITH WATER PRODUCTS; AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company; AIR & LIQUID SYSTEMS CORPORATION, as Successor by Merger to Buffalo Pumps, Inc.; ALCOA INC., Individually and as successor in interest to Tilo Roofing Co.; AMERICAN OPTICAL CORPORATION; ARMSTRONG INTERNATIONAL, INC.; ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc.; AURORA PUMP COMPANY; AVCO CORPORATION, A Textron Lycoming Division, Individually and as Successor to Lycoming Engines f/k/a Lycoming Manufacturing, Spencer Heater Company, and Spencer Heater Division of Lycoming; 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; CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc.; COLUMBIA BOILER COMPANY OF POTTSTOWN; COMPUDYNE CORPORATION, Individually and as Successor to York-Shipley; -2- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 CONTINENTAL MOTORS, INC.; CONTINENTAL MOTORS INC. f/k/a Teledyne Continental Motors, Inc., Individually and as successor to Continental Motors Inc. and Continental Motors Company; CROWN BOILER CO.; DEAN PUMP DIVISION; EATON AEROQUIP, INC. f/k/a Aeroquip Corporation; ECR INTERNATIONAL, INC., Individually and as Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Pennco, Inc.; ELECTROLUX HOME PRODUCTS, INC., Individually and as Successor to Tappan and Copes Vulcan; 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; GARDNER-DENVER, INC., Individually and as Successor to Nash Engineering Company; GARDNER-DENVER NASH LLC, Individually and as Successor to Nash Engineering Company; GENERAL ELECTRIC COMPANY; GOULDS PUMPS INC.; GRINNELL CORPORATION; HOFFMAN/NEW YORKER, 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; INTERNATIONAL COMFORT PRODUCTS LLC, Individually and as Successor to Heil Heating and Cooling; KOHLER CO.; LENNOX INDUSTRIES, INC., Individually and as Successor to Lennox Furnace Company and Ducane; MARIO & DIBONO PLASTERING CO. INC.; -3- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 METROPOLITAN LIFE INSURANCE COMPANY; NEW YORKER BOILER COMPANY, INC.; PARKER HANNIFIN CORPORATION, Individually and as Successor by Merger to Stratoflex, Inc. (Cleveland Brake Division) and EIS; PRATT & WHITNEY MEASUREMENT SYSTEMS, INC.; PRATT & WHITNEY POWER SYSTEMS, INC.; REDCO CORP., f/k/a Crane Co.; RHEEM MANUFACTURING COMPANY, INC.; ROCKWELL AUTOMATION INC., Individually and as Successor to Timken Heating Business and S. Co., Inc. f/k/a Scaife Company, as Successor in Interest to Rockwell Spring & Axle Company's Timken Silent Automatic Division; SID HARVEY INDUSTRIES, INC.; SID HARVEY SUPPLY, INC.; SPENCE ENGINEERING COMPANY, INC.; SPENCER HEATER, a Lycoming division of AVCO Corporation; SPIRAX SARCO, INC.; TACO, INC.; TECHNIFY MOTOR (USA), INC., Individually and as Successor to Teledyne Continental Motors, Inc. f/k/a Continental Motors, Inc., and Continental Motors Company; TELEDYNE TECHNOLOGIES INC., Individually and as Successor to Teledyne Continental Motors, Inc. f/k/a Continental Motors, Inc., Continental Motors Company; TEXACO, INC.; UNION CARBIDE CORPORATION; UNITED TECHNOLOGIES CORPORATION, Individually and as Successor to Pratt & Whitney (Pratt & Whitney/Aircraft Division) and Franklin Engine Company f/k/a Aircooled Motors Company; VELAN VALVE CORP.; WARREN PUMPS, LLC, Individually and as Successor to The Quimby Pump Company; WEIL McLAIN, a division of Marley Wylain Company; WILLIAM POWELL COMPANY (THE); YORK INTERNATIONAL CORPORATION, Individually and as Successor to Frick -4- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 Company. Defendants. -5- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 Defendants’ addresses: ROGER PAUL SPEZIO, SR.’s DEFENDANT ADDRESS LIST DEFENDANTS SERVICE 3M COMPANY, Individually and as Successor to Minnesota Registered Agent Mining and Manufacturing Company Corporation Service Company 3M Center / BLDG 224-5N-40 2345 Rice Street, Suite 230 St Paul, Minnesota 55144-1000 St. Paul, MN 55113 A.O. SMITH WATER PRODUCTS Registered Agent: A.O. Smith Corporation Corporation Service Company Attn: Debra Schwanda 8040 Excelsior Drive, Ste 400 11270 W. Park Place Madison, Wisconsin 53717 Milwaukee, WI 53224-9502 AII ACQUISITION CORPORATION, LLC, Individually DIRECT and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company 116 15th Street Pittsburgh, Pennsylvania 15222 AIR & LIQUID SYSTEMS CORPORATION, as Successor CT Corporation System by Merger to Buffalo Pumps, Inc. 4701 Cox Rd Ste 301 726 Bell Avenue, Suite 302 Glen Allen VA 32060 Carnegie, Pennsylvania, 15106 ALCOA INC., Individually and as successor in interest to DIRECT Tilo Roofing Co. Sam Haschets, 202 Bradshaw Dr. North Hills, PA 15143 AMERICAN OPTICAL CORPORATION c/o The Corporation Trust Company 14 Mechanic Street 1209 North Orange Street Southbridge, Massachusetts 01550-1043 Wilmington, Delaware 19801 ARMSTRONG INTERNATIONAL, INC. DIRECT 900 Maple Street Three Rivers, Michigan 49093 ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & CT Corporation System Controls USA Inc. 55 Federal St, Ste 700 c/o Weir Valves & Controls Usa Inc. Boston, MA 02110 29 Old Right Road Ipswich, Massachusetts 01938 -6- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 AURORA PUMP COMPANY DIRECT - CERTIFIED MAIL RRR 800 Airport Road c/o Kevin Keyes North Aurora, Illinois 60542 SPX Corporation 6325 Ardrey Kell Road, Suite 400 Charlotte, N.C. 28277 AVCO CORPORATION, A Textron Lycoming Division, c/o Corporate Trust Systems Individually and as Successor to Lycoming Engines f/k/a 28 Liberty Street Lycoming Manufacturing, Spencer Heater Company, and New York, New York Spencer Heater Division of Lycoming 40 Westminster Street Providence, Rhode Island 02903-2500 BW/IP INTERNATIONAL CO., formerly known as Borg DIRECT Warner Industrial Products Inc., a former subsidiary of and successor to Borg Warner Corp. and Byron Jackson Pumps BW/IP International Inc. Flowserve World Headquarters 5215 N. O'Connor Blvd., Suite 2300 Irving, Texas 75039 CARRIER CORPORATION c/o United Agent Group Inc. 13995 Pasteur Blvd 600 Mamaroneck Avenue, #400 Palm Beach Gardens, FL 33418 Harrison, NY 10528 CBS CORPORATION, a Delaware Corporation, f/k/a c/o Corporation Service Company Viacom Inc, Successor by merger to CBS Corporation, a 80 State Street Pennsylvania Corporation, f/k/a Westinghouse Electric Albany, New York 12207 Corporation c/o Adrienne Harrington 51 West 52nd Street New York, New York 10019 CLEAVER-BROOKS COMPANY f/k/a Aqua-Chem, Inc. DIRECT 11270 W. Park Place, Floor 4 Milwaukee, WI 53224 COLUMBIA BOILER COMPANY OF POTTSTOWN DIRECT 390 Old Reading Pike Stowe, PA 19464 COMPUDYNE CORPORATION, Individually and as DIRECT Successor to York-Shipley CompuDyne Corporation CSC Services of Nevada, Inc. 112 North Curry Street Carson City, Nevada 89703 -7- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 CONTINENTAL MOTORS INC. DIRECT c/o National Corporate Research LTD. 850 New Burton Road, Suite 201 Dover, Delaware 19904 CONTINENTAL MOTORS INC. f/k/a Teledyne Continental DIRECT Motors, Inc., Individually and as successor to Continental Motors Inc. and Continental Motors Company c/o National Corporate Research LTD. 850 New Burton Road, Suite 201 Dover, Delaware 19904 CROWN BOILER CO. DIRECT 3633 I Street Philadelphia, Pennsylvania 19134 DEAN PUMP DIVISION DIRECT 6040 Guion Road Indianapolis, Indiana 46254 EATON AEROQUIP, INC. f/k/a Aeroquip Corporation DIRECT CT Corporation 4400 Easton Cmns #125 Columbus, OH 43219 ECR INTERNATIONAL, INC., Individually and as c/o Secretary of State Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Albany, New York 12207 Pennco, Inc. 2201 Dwyer Avenue Utica, New York 13504 ELECTROLUX HOME PRODUCTS, INC., Individually c/o Corporate Trust Systems and as Successor to Tappan and Copes-Vulcan Company 28 Liberty Street 10200 David Taylor Drive New York, New York Charlotte NC 28262 FLOWSERVE US, INC., solely as Successor to Rockwell c/o Corporate Trust Systems Manufacturing Company, Edward Valves, Inc., Nordstrom 28 Liberty Street Valves, Inc. and Edward Vogt Valve Company New York, New York Flowserve Corporation OR General Counsel CMRRR 5215 North O’Connor Blvd, Ste 2300 Irving, Texas 75039 FMC CORPORATION, Individually and as Successor to c/o Corporate Trust Systems Northern Pump Company, Coffin and Peerless Pump 28 Liberty Street Company New York, New York FMC Tower at Cira Centre South 2929 Walnut Street Philadelphia, Pennsylvania 19104 -8- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 GARDNER DENVER, INC., Individually and as Successor Registered Agent: to Nash Engineering Company c/o CT Corporation System 1800 Gardner Expressway 208 South LaSalle Street Quincy, Illinois 62301 Chicago, Illinois 60604 GARDNER DENVER NASH, LLC, Individually and as Registered Agent: Successor to Nash Engineering Company c/o CT Corporation System 2 Trefoil Drive 67 Burnside Avenue Trumbull, CT 06611 East Hartford, CT 06108 GENERAL ELECTRIC COMPANY DIRECT 3135 Easton Turnpike Julie Klusza, Esq. Fairfield, Connecticut 06432 Electric Insurance Company 75 Sam Fonzo Drive Beverly, Massachusetts 01915-1000 GOULDS PUMPS, INC. DIRECT ITT-Goulds Pumps Headquarters 240 Fall Street Seneca Falls, NY 13148 GRINNELL CORPORATION DIRECT – CERTIFIED MAIL RRR 3 Tyco Park Brady Edwards, Esq. Exeter, New Hampshire 03833 Morgan, Lewis & Bockius LLP 1000 Louisiana St., Suite 4200 Houston, Texas 77002-5006 HOFFMAN/NEW YORKER, INC. DIRECT 46 Clinton Place Hackensack, New Jersey 07601 HONEYWELL INTERNATIONAL, INC., Individually and c/o Corporation Service Company f/k/a Alliedsignal, Inc., and as Successor-in-interest to the 80 State Street Bendix Corp. Albany, New York 12207-2543 115 Tabor Road Morris Plains, New Jersey 07950 HOWDEN BUFFALO, INC., Individually and as Successor- Registered Agent: In-Interest to FB Sturtevant, The Howden Buffalo Group C T Corporation System and Buffalo Fan 2 Office Park Court, Suite 103 Columbia, South Carolina 29223 I.T.T. INDUSTRIES, INC., Individually and as successor to c/o IntelCo Management, Inc. Bell & Gossett Tara Solanki, Paralegal ITT Corporation 187 Danbury Road, Suite 2D 1133 Westchester Avenue, Suite N300 Wilton, CT 06897 White Plains, New York 10604 -9- FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 INTERNATIONAL COMFORT PRODUCTS LLC, Individually and as Successor to Heil Heating and Cooling Lewisburg, Tennessee KOHLER CO. DIRECT Herbert V. Kohler, Jr. 444 Highland Drive Kohler, Wisconsin 53044 LENNOX INDUSTRIES, INC., Individually and as Corporation Service Company Successor to Lennox Furnace Company and Ducane 80 State Street 2100 Lake Park Boulevard Albany, New York 12207-2543 Richardson, Texas 75080 MARIO & DIBONO PLASTERING CO. INC. DIRECT – CERTIFIED MAIL RRR Jeffrey C. Fegan, Esq. Clyde & Co. US LLP The Chrysler Building 405 Lexington Avenue, 16th Floor New York, New York 10174 METROPOLITAN LIFE INSURANCE COMPANY c/o Corporate Trust Systems 200 Park Avenue 28 Liberty Street New York, New York 10166 New York, New York NEW YORKER BOILER COMPANY, INC. Corporation Service Company 2595 Interstate Drive, Suite 103 Harrisburg, Pennsylvania 17110 PARKER HANNIFIN CORPORATION, Individually and as c/o Corporate Trust Systems Successor by Merger to Stratoflex, Inc. (Cleveland Brake 28 Liberty Street Division) and EIS New York, New York 6035 Parkland Boulevard Cleveland, Ohio 44124-4141 PRATT & WHITNEY MEASUREMENT SYSTEMS, INC. Registered agent: 66 Douglas Street Scott B. Franklin, Esq. Bloomfield, CT 06002 68 South Main Street West Hartford, CT 06107 PRATT & WHITNEY POWER SYSTEMS, INC. c/o Corporate Trust Systems 80 Lamberton Road 28 Liberty Street MS 191-11 New York, New York Windsor, Connecticut 06095 REDCO CORP. f/k/a Crane Co. Registered Agent Redco Corporation The Corporation Trust Company 1000 N. West Street, Suite 1200 1209 Orange Street Wilmington, Delaware 19801 Corporation Trust Center Wilmington, Delaware 19801 - 10 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 RHEEM MANUFACTURING COMPANY, INC. Registered Agent: 1100 Abernathy Road, Suite 1700 Corporation Service Company Atlanta, GA 30328 40 Technology Parkway South, Suite 300 Norcross, GA 30092 ROCKWELL AUTOMATION, INC., Individually and as c/o Corporate Trust Systems Successor to Allen Bradley, Timken Heating Business and S. 28 Liberty Street Co., Inc. f/k/a Scaife Company, as Successor in Interest to New York, New York Rockwell Spring & Axle Company’s Timken Silent Automatic Division Allen-Bradley & Rockwell Software Brands 1201 South Second Street Milwaukee, Wisconsin 53204-2496 SID HARVEY INDUSTRIES, INC. c/o Secretary of State 605 Locust Street Albany, New York 12207 Garden City, New York 11530-6597 SID HARVEY SUPPLY, INC. c/o Secretary of State Albany, New York 12207 SPENCE ENGINEERING COMPANY, INC. Corporation Service Company 1241 Old Temescal Road, Unit 101 80 State Street Corona, CA 92881 Albany, NY 12207-2543 SPENCER HEATER, a Lycoming division of AVCO DIRECT Corporation c/o AVCO Corporation 40 Westminster Street Providence, Rhode Island 02903 SPIRAX SARCO, INC. c/o CT Corporation System 1150 Northpoint Boulevard 2 Office Park Court, Suite 103 Blythewood, South Carolina 29016 Columbia, South Carolina 29223 TACO, INC. Corporation Service Company 1160 Cranston Street 100 Pearl Street, 16th Floor Cranston, Rhode Island 02920 Hartford, CT 06103 TECHNIFY MOTOR (USA), INC., Individually and as c/o National Corporate Research LTD Successor to Teledyne Continental Motors, Inc. f/k/a 850 New Burton Road, Suite 201 Continental Motors, Inc. and Continental Motors Company Dover, Delaware 19904 TELEDYNE TECHNOLOGIES INC., Individually and as c/o National Corporate Research, Ltd. Successor to Teledyne Continental Motors, Inc. f/k/a 523 W. 6th Street, Suite 544 Continental Motors, Inc., Continental Motors Company Los Angeles, California 90014 - 11 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 TEXACO, INC. c/o The Prentice Hall Corp. Systems 2000 Westchester Avenue 80 State Street White Plains, New York Albany, New York 12207 UNION CARBIDE CORPORATION c/o Corporate Trust Systems 28 Liberty Street New York, New York UNITED TECHNOLOGIES CORPORATION, Individually c/o Corporate Trust Systems and as Successor to Pratt & Whitney (Pratt & 28 Liberty Street Whitney/Aircraft Division) and Franklin Engine Company New York, New York f/k/ Aircooled Motors Company United Technologies Building 400 Main Street East Hartford, CT 06108 VELAN VALVE CORP. c/o Corporation Service Company 94 Avenue C 80 State Street Williston, Vermont 05495-9732 Albany, New York 12207-2543 WARREN PUMPS LLC, Individually and as Successor to c/o The Corporation Trust Company The Quimby Pump Company 1209 North Orange Street 82 Bridges Avenue Wilmington, Delaware 19801 Warren, Massachusetts 01083-0969 WEIL McLAIN, A Division of Marley-Wylain Company DIRECT 6325 Ardrey Kell Road, Suite 400 Charlotte, N.C. 28277 WILLIAM POWELL COMPANY (THE) DIRECT 3261 Spring Grove Ave. Cincinnati, OH 45225 YORK INTERNATIONAL CORPORATION, Individually c/o CT Corporation System and as Successor to Frick Company 301 S. Bedford St. Suite 1 5757 N. Green Bay Avenue Madison, WI 53703 PO Box 591 Milwaukee, Wisconsin 53201 - 12 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ULSTER Index No. : ROGER PAUL SPEZIO, SR. and KATHLEEN SPEZIO, VERIFIED COMPLAINT Plaintiffs, - against - 3M COMPANY, Individually and as Successor to Minnesota Mining and Manufacturing Company; A.O. SMITH WATER PRODUCTS; AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company; AIR & LIQUID SYSTEMS CORPORATION, as Successor by Merger to Buffalo Pumps, Inc.; ALCOA INC., Individually and as successor in interest to Tilo Roofing Co.; AMERICAN OPTICAL CORPORATION; ARMSTRONG INTERNATIONAL, INC.; ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc.; AURORA PUMP COMPANY; AVCO CORPORATION, A Textron Lycoming Division, Individually and as Successor to Lycoming Engines f/k/a Lycoming Manufacturing, Spencer Heater Company, and Spencer Heater Division of Lycoming; 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; CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc.; COLUMBIA BOILER COMPANY OF POTTSTOWN; COMPUDYNE CORPORATION, Individually and as Successor to York-Shipley; - 13 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 CONTINENTAL MOTORS, INC.; CONTINENTAL MOTORS INC. f/k/a Teledyne Continental Motors, Inc., Individually and as successor to Continental Motors Inc. and Continental Motors Company; CROWN BOILER CO.; DEAN PUMP DIVISION; EATON AEROQUIP, INC. f/k/a Aeroquip Corporation; ECR INTERNATIONAL, INC., Individually and as Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Pennco, Inc.; ELECTROLUX HOME PRODUCTS, INC., Individually and as Successor to Tappan and Copes Vulcan; 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; GARDNER-DENVER, INC., Individually and as Successor to Nash Engineering Company; GARDNER-DENVER NASH LLC, Individually and as Successor to Nash Engineering Company; GENERAL ELECTRIC COMPANY; GOULDS PUMPS INC.; GRINNELL CORPORATION; HOFFMAN/NEW YORKER, 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; INTERNATIONAL COMFORT PRODUCTS LLC, Individually and as Successor to Heil Heating and Cooling; KOHLER CO.; LENNOX INDUSTRIES, INC., Individually and as Successor to Lennox Furnace Company and Ducane; MARIO & DIBONO PLASTERING CO. INC.; - 14 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 METROPOLITAN LIFE INSURANCE COMPANY; NEW YORKER BOILER COMPANY, INC.; PARKER HANNIFIN CORPORATION, Individually and as Successor by Merger to Stratoflex, Inc. (Cleveland Brake Division) and EIS; PRATT & WHITNEY MEASUREMENT SYSTEMS, INC.; PRATT & WHITNEY POWER SYSTEMS, INC.; REDCO CORP., f/k/a Crane Co.; RHEEM MANUFACTURING COMPANY, INC.; ROCKWELL AUTOMATION INC., Individually and as Successor to Timken Heating Business and S. Co., Inc. f/k/a Scaife Company, as Successor in Interest to Rockwell Spring & Axle Company's Timken Silent Automatic Division; SID HARVEY INDUSTRIES, INC.; SID HARVEY SUPPLY, INC.; SPENCE ENGINEERING COMPANY, INC.; SPENCER HEATER, a Lycoming division of AVCO Corporation; SPIRAX SARCO, INC.; TACO, INC.; TECHNIFY MOTOR (USA), INC., Individually and as Successor to Teledyne Continental Motors, Inc. f/k/a Continental Motors, Inc., and Continental Motors Company; TELEDYNE TECHNOLOGIES INC., Individually and as Successor to Teledyne Continental Motors, Inc. f/k/a Continental Motors, Inc., Continental Motors Company; TEXACO, INC.; UNION CARBIDE CORPORATION; UNITED TECHNOLOGIES CORPORATION, Individually and as Successor to Pratt & Whitney (Pratt & Whitney/Aircraft Division) and Franklin Engine Company f/k/a Aircooled Motors Company; VELAN VALVE CORP.; WARREN PUMPS, LLC, Individually and as Successor to The Quimby Pump Company; WEIL McLAIN, a division of Marley Wylain Company; WILLIAM POWELL COMPANY (THE); YORK INTERNATIONAL CORPORATION, Individually and as Successor to Frick - 15 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 Company. Defendants. Plaintiffs by their attorneys, BELLUCK & FOX LLP, upon information and belief, at all times hereinafter mentioned allege as follows: THE PARTIES 1. Plaintiffs are residents of the State of New York unless otherwise specified in individual complaints. 2. Plaintiffs allege that plaintiff, ROGER PAUL SPEZIO, SR. has been diagnosed with Mesothelioma as a result of his exposure to asbestos. 3. At this time, Plaintiffs are alleging that there is no Post-1980 exposure, but should evidence be produced to the contrary, the evidence controls over this preliminary allegation, and this allegation is presumptively modified to conform to the evidence. 4. The term “Defendants” shall apply to all corporate and business entities, and/or their predecessors and/or successors in interest as more fully described and enumerated in the captions of individual complaints subsequently filed in the "short form" in accordance with the applicable case management order of this Court. 5. The Defendants have done business in this State, have conducted or transacted business in this State, have committed one or more tortious acts within this state, or have otherwise performed acts within and/or without this State giving rise to injuries and losses within this State, which acts subject each Defendant to the jurisdiction of the Courts of this State. 6. Defendant 3M COMPANY, Individually and as Successor to Minnesota Mining and Manufacturing Company was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should - 16 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 7. Defendant A.O. SMITH WATER PRODUCTS was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 8. Defendant AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 9. Defendant AIR & LIQUID SYSTEMS CORPORATION, as Successor by Merger to Buffalo Pumps, Inc. was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 10. Defendant ALCOA INC., Individually and as successor in interest to Tilo Roofing Co. was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have - 17 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 11. Defendant AMERICAN OPTICAL CORPORATION was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 12. Defendant ARMSTRONG INTERNATIONAL, INC. was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 13. Defendant ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc. was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 14. Defendant AURORA PUMP COMPANY was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. - 18 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 15. Defendant AVCO CORPORATION, A Textron Lycoming Division, Individually and as Successor to Lycoming Engines f/k/a Lycoming Manufacturing, Spencer Heater Company and Spencer Heater Division of Lycoming was and is a duly organized foreign and/or domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 16. Defendant 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 was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 17. Defendant CARRIER CORPORATION was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 18. 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 was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have - 19 - FILED: ULSTER COUNTY CLERK 11/16/2023 04:05 PM INDEX NO. EF2023-99 NYSCEF DOC. NO. 241 RECEIVED NYSCEF: 11/16/2023 consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 19. Defendant CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc. was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 20. Defendant COLUMBIA BOILER COMPANY OF POTTSTOWN was and is a duly organized domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 21. Defendant COMPUDYNE CORPORATION, Individually and as Successor to York-Shipley was and is a duly organized domestic corporation doing business and/or transacting business in the State of New York and/or should have expected its acts to have consequences within the State of New York. At all times relevant, it has engaged in the sale and distribution of materials and products contain