Preview
FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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KURT R. HALLMAN and ANGELICA HALLMAN,
Date Filed:
Plaintiff(s), Plaintiff Designates
NEW YORK
-against- County as the Place of Trial
A.O. SMITH WATER PRODUCTS CO., The Basis of Venue is
ABB, INC. Defendants' Place of Business
Individually and as successor in interest to ITE CIRCUIT
BREAKERS, INC.,
AERCO INTERNATIONAL, INC., SUMMONS
AMCHEM PRODUCTS, INC.,
n/k/a RHONE POULENC AG COMPANY,
n/k/a BAYER CROPSCIENCE INC.,
ANCHOR DARLING VALVE COMPANY,
ARMSTRONG INTERNATIONAL, INC.,
ARMSTRONG PUMPS, INC.,
ATWOOD & MORRILL COMPANY,
AURORA PUMP COMPANY,
BMCE INC.,
f/k/a UNITED CENTRIFUGAL PUMP,
BURNHAM LLC,, Individually and as successor to
BURNHAM CORPORATION, and as alter ego to
BURNHAM HOLDINGS, INC.,
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION,
BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES,
CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN
COMPANY, LLC and CANVAS SX, LLC, f/k/a
SPX, LLC,
CARRIER CORPORATION,
CLEAVER- BROOKS, INC.,
COMPUDYNE CORPORATION,
Individually, and as successor to YORK SHIPLEY, INC.,
CROWN BOILER CO.,
f/k/a CROWN INDUSTRIES, INC.,
DAP, INC.,
EATON CORPORATION, as successor -in-interest to
CUTLER-HAMMER, INC.,
FLOWSERVE US, INC.
Individually and successor to Rockwell Manufacturing
Company, Edward Valve, Inc., Nordstrom Valves, Inc.,
Edward Vogt Valve Company, and Vogt Valve Company,
FMC CORPORATION,
on behalf of its former CHICAGO PUMP
& NORTHERN PUMP BUSINESSES,
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FORT KENT HOLDINGS, INC.,
FORMERLY KNOWN AS DUNHAM-BUSH, INC.,
G. DENVER and CO., LLC,
GENERAL ELECTRIC COMPANY,
GOULD ELECTRONICS INC.,
GOULDS PUMPS LLC,
GRINNELL LLC,
HUBBELL INCORPORATED, as successor in
interest to THE BRYANT ELECTRIC COMPANY,
and HUBBELL INCORPORATED, Individually,
IMO INDUSTRIES, INC.,,
INTERNATIONAL PAPER COMPANY,
Individually and as successor to CHAMPION
INTERNATIONAL CORPORATION, as successor
to UNITED STATES PLYWOOD CORPORATION,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
JENKINS BROS.,
KAISER GYPSUM COMPANY, INC.,
KAMCO SUPPLY CORP.,
KOHLER CO.,
LENNOX INDUSTRIES, INC.,
LEVITON MANUFACTURING CO., INC.,
PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc.,
f/k/a 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,
PFIZER, INC. (PFIZER),
REDCO CORPORATION f/k/a CRANE CO.,
RHEEM MANUFACTURING COMPANY,
S.A. ARMSTRONG LIMITED,
SCHNEIDER ELECTRIC USA, INC. formerly known as
SQUARE D COMPANY,
SPIRAX SARCO, INC.
Individually and as successor to SARCO COMPANY,
TACO, INC.,
U.S. RUBBER COMPANY (UNIROYAL),
UNION CARBIDE CORPORATION,
VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT
CO., Individually and as Successor in interest to
INTERNATIONAL TALC COMPANY, INC.,
GOUVERNEUR TALC COMPANY, INC.,
and INTERNATIONAL PULP COMPANY, INC.,
WARREN PUMPS, LLC,
WEYERHAEUSER COMPANY,
YORK INTERNATIONAL CORPORATION,
Defendants.
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To the above named Defendant(s)
You are hereby summoned to answer the verified 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(s) 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); and in case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
Dated, June 07, 2024
New York, New York
WEITZ & LUXENBERG, P.C.
Defendant's address: Attorney(s) for Plaintiff
Post Office Address
SEE ATTACHED DEFENDANTS RIDER 700 Broadway
New York, New York 10003
(212) 558-5500
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DEFENDANTS' RIDER
A.O. SMITH WATER PRODUCTS CO.
Corporation Service Company
33 East Main Street
Suite 610
Madison, WI 53703
ABB, INC.
Individually and as successor in interest to ITE CIRCUIT
BREAKERS, INC.
125 E. County Line
Warminster, PA 18974
and
Delaney & O'brien
325 Chestnut Street
Suite 1320
Philadelphia, PA 19106
Warminster, PA 18974
AERCO INTERNATIONAL, INC.
100 Oritani Drive
Blauvelt, NY 10913
AMCHEM PRODUCTS, INC.,
n/k/a RHONE POULENC AG COMPANY,
n/k/a BAYER CROPSCIENCE INC.
99 Washington Ave
Albany, NY 12207
ANCHOR DARLING VALVE COMPANY
1900 South Saunders Street
Raleigh, NC 27603
ARMSTRONG INTERNATIONAL, INC.
900 Maple St
Three Rivers, MI 49093
ARMSTRONG PUMPS, INC.
93 East Avenue
North Tonawanda, NY 14120
ATWOOD & MORRILL COMPANY
29 Old Right Road
Ipswich, MA 01938
AURORA PUMP COMPANY
The Corporation Trust Company
1209 Orange Street
Wilmington, DE 19801
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BMCE INC.,
f/k/a UNITED CENTRIFUGAL PUMP
175 Pinelawn Road
Suite 250
Meville, NY 11747
BURNHAM LLC,, Individually and as successor to
BURNHAM CORPORATION, and as alter ego to
BURNHAM HOLDINGS, INC.
1241 Harrisburg Pike
Lancaster, PA 17603
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION
1239 Harrisburg Pike
Lancaster, PA 17603
BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES
5215 North O'Conner Blvd
Suite 2300
Irving, TX 75039
CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN
COMPANY, LLC and CANVAS SX, LLC, f/k/a
SPX, LLC
The Corporation Trust Company
1209 Orange Street
Wilmington, DE 19801
CARRIER CORPORATION
600 Mamaroneck Avenue, #400
Harrison, NY 10528
CLEAVER- BROOKS, INC.
CSC Company
80 State Street
Albany, NY 12207
COMPUDYNE CORPORATION,
Individually, and as successor to YORK SHIPLEY, INC.
CSC Services of Nevada, Inc.
112 North Curry Street
Carson City, NV 89703
CROWN BOILER CO.,
f/k/a CROWN INDUSTRIES, INC.
3633 I Street
Philadelphia, PA 19134-0000
DAP, INC.
The Prentice-Hall Corporation System Maryland
7 St. Paul Street, Suite 1600
Baltimore, MD 21202
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EATON CORPORATION, as successor -in-interest to
CUTLER-HAMMER, INC.
CT Corporation System
28 Liberty Street
New York, NY 10005
FLOWSERVE US, INC.
Individually and successor to Rockwell Manufacturing
Company, Edward Valve, Inc., Nordstrom Valves, Inc.,
Edward Vogt Valve Company, and Vogt Valve Company
c/o Corporate Trust Systems
1999 Bryan Street, Suite 900
Dallas, TX 75201
FMC CORPORATION,
on behalf of its former CHICAGO PUMP
& NORTHERN PUMP BUSINESSES
600 North 2nd Street, Suite 401A
Harrisburg, PA 17101
FORT KENT HOLDINGS, INC.,
FORMERLY KNOWN AS DUNHAM-BUSH, INC.
The Corporation Trust Company
1209 Orange Street
Wilmington, DE 19801
G. DENVER and CO., LLC
1800 Gardner Expressway
Quincy, IL 62301
GENERAL ELECTRIC COMPANY
Electric Insurance Company
75 Sam Fonzo Drive
Beverly, MA 01915
GOULD ELECTRONICS INC.
CT Corp
4400 Easton CMNS
Columbus, OH 43219
and
CT Corp
3800 N Central Ave, Suite 460
Phoenix, AZ 85012
Columbus, OH 43219
GOULDS PUMPS LLC
CT Corporation System
28 Liberty St, 42nd Fl
New York, NY 10005
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GRINNELL LLC
CT Corporation
28 Liberty St, 42nd Fl
New York, NY 10005
HUBBELL INCORPORATED, as successor in
interest to THE BRYANT ELECTRIC COMPANY,
and HUBBELL INCORPORATED, Individually
CSC
225 Asylum Street, 20th Flr
Hartford, CT 06103
IMO INDUSTRIES, INC.,
CT Corporation
1209 Orange Street
Wilmington, DE 19801
INTERNATIONAL PAPER COMPANY,
Individually and as successor to CHAMPION
INTERNATIONAL CORPORATION, as successor
to UNITED STATES PLYWOOD CORPORATION
CT Corporation
67 Burnside Ave
East Hartford, CT 06108
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.
187 Danbury Road
Ste 2D
Wilton, CT 06897
JENKINS BROS.
LIBERTY MUTUAL GROUP INC.,
84 State Street,
Boston, MA 02109
KAISER GYPSUM COMPANY, INC.
Corporation Service Company
2626 Glenwood Avenue, Suite 550
Raleigh, NC 27608
and
c/o Three Rivers Management, Inc.
600 River Avenue, Suite 200
Pittsburgh, PA 15212
Raleigh, NC 27608
KAMCO SUPPLY CORP.
80 21st Street
Brooklyn, NY 11232
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KOHLER CO.
CT Corporation System
28 Liberty St, 42nd Fl
New York, NY 10005
LENNOX INDUSTRIES, INC.
80 State Street
Albany, NY 12207
LEVITON MANUFACTURING CO., INC.
201 North Service Road
Melville, NY 11747
PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc.,
f/k/a 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
Asbestos Litigation Support Manager
ECKERT SEAMANS CHERIN & MELLOTT, LLC
Case Management & Technology Center
USX Towers
600 Grant Street
Pittsburgh, PA 15219
PFIZER, INC. (PFIZER)
CT Corporation Systems
28 Liberty st, 42nd Fl
New York, NY 10005
REDCO CORPORATION f/k/a CRANE CO.
The Corporation Trust Company
1209 Orange Street
or
Redco Corporation
1000 N. West Street, Suite 1200
Wilmington, Delaware 19801
Wilmington, DE 19801
RHEEM MANUFACTURING COMPANY
80 State Street
Albany, NY 12207
S.A. ARMSTRONG LIMITED
23 Bertrand Ave
Scarborough, ON M1L2P3
SCHNEIDER ELECTRIC USA, INC. formerly known as
SQUARE D COMPANY
Corporation Service Company
801 Adlai Stevenson Dr
Springfield, IL 62703
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SPIRAX SARCO, INC.
Individually and as successor to SARCO COMPANY
CT Corporation
2 Office Park Court
Suite 103
Columbia , SC 29223
TACO, INC.
Corporation Service Company
222 Jefferson Boulevard
Suite 200
Warwick, RI 02888
and
CSC
225 Asylum Street, 20th Floor
Hartford, CT 06103
Hartford, CT 06103
U.S. RUBBER COMPANY (UNIROYAL)
Greenfield, Stein & Senior
(Agent for Service of Process)
600 Third Avenue, 11th Floor
New York, NY 10016-1903
UNION CARBIDE CORPORATION
CT Corporation Systems
28 Liberty st, 42nd Fl
New York, NY 10005
VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO.,
Individually and as Successor in interest to
INTERNATIONAL TALC COMPANY, INC.,
GOUVERNEUR TALC COMPANY, INC.,
and INTERNATIONAL PULP COMPANY, INC.
Corporation Service Company
80 State Street
Albany, NY 12207
WARREN PUMPS, LLC
CT Corporation
1209 Orange Street
Wilmington, DE 19801
WEYERHAEUSER COMPANY
Corporation Service Company
80 State Street
Albany, NY 12207
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YORK INTERNATIONAL CORPORATION
CT Corp
28 Liberty St, 42nd Fl
New York, NY 10005
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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KURT R. HALLMAN and ANGELICA HALLMAN,
Date Filed:
Plaintiff(s),
-against- VERIFIED
COMPLAINT
A.O. SMITH WATER PRODUCTS CO.,
ABB, INC. PLAINTIFF DEMANDS
Individually and as successor in interest to ITE CIRCUIT TRIAL BY JURY
BREAKERS, INC.,
AERCO INTERNATIONAL, INC.,
AMCHEM PRODUCTS, INC.,
n/k/a RHONE POULENC AG COMPANY,
n/k/a BAYER CROPSCIENCE INC.,
ANCHOR DARLING VALVE COMPANY,
ARMSTRONG INTERNATIONAL, INC.,
ARMSTRONG PUMPS, INC.,
ATWOOD & MORRILL COMPANY,
AURORA PUMP COMPANY,
BMCE INC.,
f/k/a UNITED CENTRIFUGAL PUMP,
BURNHAM LLC,, Individually and as successor to
BURNHAM CORPORATION, and as alter ego to
BURNHAM HOLDINGS, INC.,
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION,
BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES,
CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN
COMPANY, LLC and CANVAS SX, LLC, f/k/a
SPX, LLC,
CARRIER CORPORATION,
CLEAVER- BROOKS, INC.,
COMPUDYNE CORPORATION,
Individually, and as successor to YORK SHIPLEY, INC.,
CROWN BOILER CO.,
f/k/a CROWN INDUSTRIES, INC.,
DAP, INC.,
EATON CORPORATION, as successor -in-interest to
CUTLER-HAMMER, INC.,
FLOWSERVE US, INC.
Individually and successor to Rockwell Manufacturing
Company, Edward Valve, Inc., Nordstrom Valves, Inc.,
Edward Vogt Valve Company, and Vogt Valve Company,
FMC CORPORATION,
on behalf of its former CHICAGO PUMP
& NORTHERN PUMP BUSINESSES,
FORT KENT HOLDINGS, INC.,
FORMERLY KNOWN AS DUNHAM-BUSH, INC.,
G. DENVER and CO., LLC,
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GENERAL ELECTRIC COMPANY,
GOULD ELECTRONICS INC.,
GOULDS PUMPS LLC,
GRINNELL LLC,
HUBBELL INCORPORATED, as successor in
interest to THE BRYANT ELECTRIC COMPANY,
and HUBBELL INCORPORATED, Individually,
IMO INDUSTRIES, INC.,,
INTERNATIONAL PAPER COMPANY,
Individually and as successor to CHAMPION
INTERNATIONAL CORPORATION, as successor
to UNITED STATES PLYWOOD CORPORATION,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
JENKINS BROS.,
KAISER GYPSUM COMPANY, INC.,
KAMCO SUPPLY CORP.,
KOHLER CO.,
LENNOX INDUSTRIES, INC.,
LEVITON MANUFACTURING CO., INC.,
PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc.,
f/k/a 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,
PFIZER, INC. (PFIZER),
REDCO CORPORATION f/k/a CRANE CO.,
RHEEM MANUFACTURING COMPANY,
S.A. ARMSTRONG LIMITED,
SCHNEIDER ELECTRIC USA, INC. formerly known as
SQUARE D COMPANY,
SPIRAX SARCO, INC.
Individually and as successor to SARCO COMPANY,
TACO, INC.,
U.S. RUBBER COMPANY (UNIROYAL),
UNION CARBIDE CORPORATION,
VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO.,
Individually and as Successor in interest to
INTERNATIONAL TALC COMPANY, INC.,
GOUVERNEUR TALC COMPANY, INC.,
and INTERNATIONAL PULP COMPANY, INC.,
WARREN PUMPS, LLC,
WEYERHAEUSER COMPANY,
YORK INTERNATIONAL CORPORATION,
Defendants.
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Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, by
their attorneys WEITZ & LUXENBERG, P.C., upon information and belief, at all times
hereinafter mentioned alleges as follows:
Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, by
their attorneys, WEITZ & LUXENBERG, P.C., for their verified complaint respectfully
alleges:
1. The terms ‘Defendant’ or ‘Defendants’ as used herein shall apply to all
named business and/or corporate entities and/or such company’s predecessor(s) and/or
successor(s) in interest.
2. Upon information and belief, Plaintiff KURT R. HALLMAN is suffering
from Lung Cancer.
3. Plaintiff has provided an authorization to obtain plaintiff’s social security
records to recordtrak contemporaneously with this complaint.
4. Defendant A.O. SMITH WATER PRODUCTS CO., was and still is a
duly organized domestic corporation doing business in the State of New York.
5. Defendant ABB, INC. Individually and as successor in interest to ITE
CIRCUIT BREAKERS, INC., was and still is a duly organized domestic corporation doing
business in the State of New York.
6. Defendant AERCO INTERNATIONAL, INC., was and still is a duly
organized domestic corporation doing business in the State of New York.
7. Defendant AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG
COMPANY, n/k/a BAYER CROPSCIENCE INC., was and still is a duly organized domestic
corporation doing business in the State of New York.
8. Defendant ANCHOR DARLING VALVE COMPANY, was and still is a
duly organized domestic corporation doing business in the State of New York.
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9. Defendant ARMSTRONG INTERNATIONAL, INC., was and still is a
duly organized domestic corporation doing business in the State of New York.
10. Defendant ARMSTRONG PUMPS, INC., was and still is a duly
organized domestic corporation doing business in the State of New York.
11. Defendant ARMSTRONG PUMPS, INC., was and still 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.
12. Defendant ATWOOD & MORRILL COMPANY, was and still is a duly
organized domestic corporation doing business in the State of New York.
13. Defendant AURORA PUMP COMPANY, was and still is a duly
organized domestic corporation doing business in the State of New York.
14. Defendant BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP, was and
still is a duly organized domestic corporation doing business in the State of New York.
15. Defendant BURNHAM LLC,, Individually and as successor to
BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC., was and still
is a duly organized domestic corporation doing business in the State of New York.
16. Defendant BURNHAM, LLC, Individually, and as successor to
BURNHAM CORPORATION, was and still is a duly organized domestic corporation doing
business in the State of New York.
17. Defendant BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES,
was and still is a duly organized domestic corporation doing business in the State of New York.
18. Defendant CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN
COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC, was and still is a duly organized
domestic corporation doing business in the State of New York.
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19. Defendant CARRIER CORPORATION, was and still is a duly organized
domestic corporation doing business in the State of New York.
20. Defendant CLEAVER- BROOKS, INC., was and still is a duly organized
domestic corporation doing business in the State of New York.
21. Defendant COMPUDYNE CORPORATION, Individually, and as
successor to YORK SHIPLEY, INC., was and still is a duly organized domestic corporation
doing business in the State of New York.
22. Defendant CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC.,
was and still is a duly organized domestic corporation doing business in the State of New York.
23. Defendant DAP, INC., was and still is a duly organized domestic
corporation doing business in the State of New York.
24. Defendant EATON CORPORATION, as successor -in-interest to
CUTLER-HAMMER, INC., was and still is a duly organized domestic corporation doing
business in the State of New York.
25. Defendant FLOWSERVE US, INC. Individually and successor to
Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt
Valve Company, and Vogt Valve Company, was and still is a duly organized domestic
corporation doing business in the State of New York.
26. Defendant FMC CORPORATION, on behalf of its former CHICAGO
PUMP & NORTHERN PUMP BUSINESSES, was and still is a duly organized domestic
corporation doing business in the State of New York.
27. Defendant FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS
DUNHAM-BUSH, INC., was and still is a duly organized domestic corporation doing business
in the State of New York.
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28. Defendant G. DENVER and CO., LLC, was and still is a duly organized
domestic corporation doing business in the State of New York.
29. Defendant GENERAL ELECTRIC COMPANY, was and still is a duly
organized domestic corporation doing business in the State of New York.
30. Defendant GOULD ELECTRONICS INC., was and still is a duly
organized domestic corporation doing business in the State of New York.
31. Defendant GOULDS PUMPS LLC, was and still is a duly organized
domestic corporation doing business in the State of New York.
32. Defendant GRINNELL LLC, was and still is a duly organized domestic
corporation doing business in the State of New York.
33. Defendant HUBBELL INCORPORATED, as successor in interest to THE
BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually, was and
still is a duly organized domestic corporation doing business in the State of New York.
34. Defendant IMO INDUSTRIES, INC.,, was and still is a duly organized
domestic corporation doing business in the State of New York.
35. Defendant INTERNATIONAL PAPER COMPANY, Individually and as
successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED
STATES PLYWOOD CORPORATION, was and still is a duly organized domestic corporation
doing business in the State of New York.
36. Defendant ITT LLC., Individually and as successor to BELL &
GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., was and
still is a duly organized domestic corporation doing business in the State of New York.
37. Defendant JENKINS BROS., was and still is a duly organized domestic
corporation doing business in the State of New York.
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38. Defendant KAISER GYPSUM COMPANY, INC., was and still is a duly
organized domestic corporation doing business in the State of New York.
39. Defendant KAMCO SUPPLY CORP., was and still is a duly organized
domestic corporation doing business in the State of New York.
40. Defendant KOHLER CO., was and still is a duly organized domestic
corporation doing business in the State of New York.
41. Defendant LENNOX INDUSTRIES, INC., was and still is a duly
organized domestic corporation doing business in the State of New York.
42. Defendant LEVITON MANUFACTURING CO., INC., was and still is a
duly organized domestic corporation doing business in the State of New York.
43. Defendant PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc.,
f/k/a 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 still is a duly organized domestic
corporation doing business in the State of New York.
44. Defendant PFIZER, INC. (PFIZER), was and still is a duly organized
domestic corporation doing business in the State of New York.
45. Defendant REDCO CORPORATION f/k/a CRANE CO., was and still is a
duly organized domestic corporation doing business in the State of New York.
46. Defendant RHEEM MANUFACTURING COMPANY, was and still is a
duly organized domestic corporation doing business in the State of New York.
47. Defendant S.A. ARMSTRONG LIMITED, was and still is a duly
organized domestic corporation doing business in the State of New York.
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48. Defendant SCHNEIDER ELECTRIC USA, INC. formerly known as
SQUARE D COMPANY, was and still is a duly organized domestic corporation doing business
in the State of New York.
49. Defendant SPIRAX SARCO, INC. Individually and as successor to
SARCO COMPANY, was and still is a duly organized domestic corporation doing business in
the State of New York.
50. Defendant TACO, INC., was and still is a duly organized domestic
corporation doing business in the State of New York.
51. Defendant U.S. RUBBER COMPANY (UNIROYAL), was and still is a
duly organized domestic corporation doing business in the State of New York.
52. Defendant UNION CARBIDE CORPORATION, was and still is a duly
organized domestic corporation doing business in the State of New York.
53. Defendant VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT
CO., Individually and as Successor in interest to INTERNATIONAL TALC COMPANY, INC.,
GOUVERNEUR TALC COMPANY, INC., and INTERNATIONAL PULP COMPANY, INC.,
was and still is a duly organized domestic corporation doing business in the State of New York.
54. Defendant WARREN PUMPS, LLC, was and still is a duly organized
domestic corporation doing business in the State of New York.
55. Defendant WEYERHAEUSER COMPANY, was and still is a duly
organized domestic corporation doing business in the State of New York.
56. Defendant YORK INTERNATIONAL CORPORATION , was and still is
a duly organized domestic corporation doing business in the State of New York.
Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, repeats and realleges
NYCAL - WEITZ & LUXENBERG, P.C. STANDARD ASBESTOS COMPLAINT FOR
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PERSONAL INJURY No. 8 as if fully incorporated herein as it pertains to the defendants in the
aforementioned caption.
Dated: June 07, 2024
New York, New York
Yours, etc.,
WEITZ & LUXENBERG, P.C
.
Attorneys for Plaintiff(s)
700 Broadway
New York, NY 10003
(212) 558-5500
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STATE OF NEW YORK )
SS:
COUNTY OF NEW YORK )
The undersigned, an attorney admitted to practice in the Courts of New York State,
shows:
Deponent is an Associate of the firm WEITZ & LUXENBERG, P.C., Counsel for the
plaintiff(s) in the within action; deponent has read the foregoing summons and verified
complaint and knows the contents thereof; the same is true to deponent's own knowledge, except
as to the matters therein stated to be alleged on information and belief, and that as to those
matters deponent believes it to be true. This verification is made by deponent and not by
plaintiff(s) because plaintiff(s) resides outside of the County of New York where plaintiffs'
counsel and deponent maintain their office.
Dated: June 07, 2024
New York, New York
/S/
AMBRE BRANDIS
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Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
====================================================================================
KURT R. HALLMAN and ANGELICA HALLMAN,
Plaintiff(s),
-against-
A.O. SMITH WATER PRODUCTS CO., et. al.,
Defendants.
====================================================================================
SUMMONS and COMPLAINT
====================================================================================
WEITZ & LUXENBERG, P.C.
Attorneys for PLAINTIFFS
700 Broadway
New York, NY 10003
212-558-5500
====================================================================================
To
Attorney(s) for
====================================================================================
Service of a copy of the within
is hereby admitted.
Dated, June 07, 2024
…………………………………………………………………………………………………………………………….
Attorney(s) for
===================================================================================
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------------------X
KURT R. HALLMAN and ANGELICA HALLMAN,
Plaintiff(s), FULL CAPTION
RIDER
-against-
A.O. SMITH WATER PRODUCTS CO.,
ABB, INC.
Individually and as successor in interest to ITE CIRCUIT
BREAKERS, INC.,
AERCO INTERNATIONAL, INC.,
AMCHEM PRODUCTS, INC.,
n/k/a RHONE POULENC AG COMPANY,
n/k/a BAYER CROPSCIENCE INC.,
ANCHOR DARLING VALVE COMPANY,
ARMSTRONG INTERNATIONAL, INC.,
ARMSTRONG PUMPS, INC.,
ATWOOD & MORRILL COMPANY,
AURORA PUMP COMPANY,
BMCE INC.,
f/k/a UNITED CENTRIFUGAL PUMP,
BURNHAM LLC,, Individually and as successor to
BURNHAM CORPORATION, and as alter ego to
BURNHAM HOLDINGS, INC.,
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION,
BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES,
CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN
COMPANY, LLC and CANVAS SX, LLC, f/k/a
SPX, LLC,
CARRIER CORPORATION,
CLEAVER- BROOKS, INC.,
COMPUDYNE CORPORATION,
Individually, and as successor to YORK SHIPLEY, INC.,
CROWN BOILER CO.,
f/k/a CROWN INDUSTRIES, INC.,
DAP, INC.,
EATON CORPORATION, as successor -in-interest to
CUTLER-HAMMER, INC.,
FLOWSERVE US, INC.
Individually and successor to Rockwell Manufacturing
Company, Edward Valve, Inc., Nordstrom Valves, Inc.,
Edward Vogt Valve Company, and Vogt Valve Company,
FMC CORPORATION,
on behalf of its former CHICAGO PUMP
& NORTHERN PUMP BUSINESSES,
FORT KENT HOLDINGS, INC.,
FORMERLY KNOWN AS DUNHAM-BUSH, INC.,
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G. DENVER and CO., LLC,
GENERAL ELECTRIC COMPANY,
GOULD ELECTRONICS INC.,
GOULDS PUMPS LLC,
GRINNELL LLC,
HUBBELL INCORPORATED, as successor in
interest to THE BRYANT ELECTRIC COMPANY,
and HUBBELL INCORPORATED, Individually,
IMO INDUSTRIES, INC.,,
INTERNATIONAL PAPER COMPANY,
Individually and as successor to CHAMPION
INTERNATIONAL CORPORATION, as successor
to UNITED STATES PLYWOOD CORPORATION,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
JENKINS BROS.,
KAISER GYPSUM COMPANY, INC.,
KAMCO SUPPLY CORP.,
KOHLER CO.,
LENNOX INDUSTRIES, INC.,
LEVITON MANUFACTURING CO., INC.,
PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc.,
f/k/a 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,
PFIZER, INC. (PFIZER),
REDCO CORPORATION f/k/a CRANE CO.,
RHEEM MANUFACTURING COMPANY,
S.A. ARMSTRONG LIMITED,
SCHNEIDER ELECTRIC USA, INC. formerly known as
SQUARE D COMPANY,
SPIRAX SARCO, INC.
Individually and as successor to SARCO COMPANY,
Preview
FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X Index No.: KURT R. HALLMAN and ANGELICA HALLMAN, Date Filed: Plaintiff(s), Plaintiff Designates NEW YORK -against- County as the Place of Trial A.O. SMITH WATER PRODUCTS CO., The Basis of Venue is ABB, INC. Defendants' Place of Business Individually and as successor in interest to ITE CIRCUIT BREAKERS, INC., AERCO INTERNATIONAL, INC., SUMMONS AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., ANCHOR DARLING VALVE COMPANY, ARMSTRONG INTERNATIONAL, INC., ARMSTRONG PUMPS, INC., ATWOOD & MORRILL COMPANY, AURORA PUMP COMPANY, BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP, BURNHAM LLC,, Individually and as successor to BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC., BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES, CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC, CARRIER CORPORATION, CLEAVER- BROOKS, INC., COMPUDYNE CORPORATION, Individually, and as successor to YORK SHIPLEY, INC., CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC., DAP, INC., EATON CORPORATION, as successor -in-interest to CUTLER-HAMMER, INC., FLOWSERVE US, INC. Individually and successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, FMC CORPORATION, on behalf of its former CHICAGO PUMP & NORTHERN PUMP BUSINESSES, 1 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS DUNHAM-BUSH, INC., G. DENVER and CO., LLC, GENERAL ELECTRIC COMPANY, GOULD ELECTRONICS INC., GOULDS PUMPS LLC, GRINNELL LLC, HUBBELL INCORPORATED, as successor in interest to THE BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually, IMO INDUSTRIES, INC.,, INTERNATIONAL PAPER COMPANY, Individually and as successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED STATES PLYWOOD CORPORATION, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., JENKINS BROS., KAISER GYPSUM COMPANY, INC., KAMCO SUPPLY CORP., KOHLER CO., LENNOX INDUSTRIES, INC., LEVITON MANUFACTURING CO., INC., PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc., f/k/a 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, PFIZER, INC. (PFIZER), REDCO CORPORATION f/k/a CRANE CO., RHEEM MANUFACTURING COMPANY, S.A. ARMSTRONG LIMITED, SCHNEIDER ELECTRIC USA, INC. formerly known as SQUARE D COMPANY, SPIRAX SARCO, INC. Individually and as successor to SARCO COMPANY, TACO, INC., U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO., Individually and as Successor in interest to INTERNATIONAL TALC COMPANY, INC., GOUVERNEUR TALC COMPANY, INC., and INTERNATIONAL PULP COMPANY, INC., WARREN PUMPS, LLC, WEYERHAEUSER COMPANY, YORK INTERNATIONAL CORPORATION, Defendants. 2 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 -----------------------------------------------------------------------------X To the above named Defendant(s) You are hereby summoned to answer the verified 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(s) 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); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated, June 07, 2024 New York, New York WEITZ & LUXENBERG, P.C. Defendant's address: Attorney(s) for Plaintiff Post Office Address SEE ATTACHED DEFENDANTS RIDER 700 Broadway New York, New York 10003 (212) 558-5500 3 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 DEFENDANTS' RIDER A.O. SMITH WATER PRODUCTS CO. Corporation Service Company 33 East Main Street Suite 610 Madison, WI 53703 ABB, INC. Individually and as successor in interest to ITE CIRCUIT BREAKERS, INC. 125 E. County Line Warminster, PA 18974 and Delaney & O'brien 325 Chestnut Street Suite 1320 Philadelphia, PA 19106 Warminster, PA 18974 AERCO INTERNATIONAL, INC. 100 Oritani Drive Blauvelt, NY 10913 AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC. 99 Washington Ave Albany, NY 12207 ANCHOR DARLING VALVE COMPANY 1900 South Saunders Street Raleigh, NC 27603 ARMSTRONG INTERNATIONAL, INC. 900 Maple St Three Rivers, MI 49093 ARMSTRONG PUMPS, INC. 93 East Avenue North Tonawanda, NY 14120 ATWOOD & MORRILL COMPANY 29 Old Right Road Ipswich, MA 01938 AURORA PUMP COMPANY The Corporation Trust Company 1209 Orange Street Wilmington, DE 19801 4 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP 175 Pinelawn Road Suite 250 Meville, NY 11747 BURNHAM LLC,, Individually and as successor to BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC. 1241 Harrisburg Pike Lancaster, PA 17603 BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION 1239 Harrisburg Pike Lancaster, PA 17603 BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES 5215 North O'Conner Blvd Suite 2300 Irving, TX 75039 CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC The Corporation Trust Company 1209 Orange Street Wilmington, DE 19801 CARRIER CORPORATION 600 Mamaroneck Avenue, #400 Harrison, NY 10528 CLEAVER- BROOKS, INC. CSC Company 80 State Street Albany, NY 12207 COMPUDYNE CORPORATION, Individually, and as successor to YORK SHIPLEY, INC. CSC Services of Nevada, Inc. 112 North Curry Street Carson City, NV 89703 CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC. 3633 I Street Philadelphia, PA 19134-0000 DAP, INC. The Prentice-Hall Corporation System Maryland 7 St. Paul Street, Suite 1600 Baltimore, MD 21202 5 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 EATON CORPORATION, as successor -in-interest to CUTLER-HAMMER, INC. CT Corporation System 28 Liberty Street New York, NY 10005 FLOWSERVE US, INC. Individually and successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company c/o Corporate Trust Systems 1999 Bryan Street, Suite 900 Dallas, TX 75201 FMC CORPORATION, on behalf of its former CHICAGO PUMP & NORTHERN PUMP BUSINESSES 600 North 2nd Street, Suite 401A Harrisburg, PA 17101 FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS DUNHAM-BUSH, INC. The Corporation Trust Company 1209 Orange Street Wilmington, DE 19801 G. DENVER and CO., LLC 1800 Gardner Expressway Quincy, IL 62301 GENERAL ELECTRIC COMPANY Electric Insurance Company 75 Sam Fonzo Drive Beverly, MA 01915 GOULD ELECTRONICS INC. CT Corp 4400 Easton CMNS Columbus, OH 43219 and CT Corp 3800 N Central Ave, Suite 460 Phoenix, AZ 85012 Columbus, OH 43219 GOULDS PUMPS LLC CT Corporation System 28 Liberty St, 42nd Fl New York, NY 10005 6 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 GRINNELL LLC CT Corporation 28 Liberty St, 42nd Fl New York, NY 10005 HUBBELL INCORPORATED, as successor in interest to THE BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually CSC 225 Asylum Street, 20th Flr Hartford, CT 06103 IMO INDUSTRIES, INC., CT Corporation 1209 Orange Street Wilmington, DE 19801 INTERNATIONAL PAPER COMPANY, Individually and as successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED STATES PLYWOOD CORPORATION CT Corporation 67 Burnside Ave East Hartford, CT 06108 ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc. 187 Danbury Road Ste 2D Wilton, CT 06897 JENKINS BROS. LIBERTY MUTUAL GROUP INC., 84 State Street, Boston, MA 02109 KAISER GYPSUM COMPANY, INC. Corporation Service Company 2626 Glenwood Avenue, Suite 550 Raleigh, NC 27608 and c/o Three Rivers Management, Inc. 600 River Avenue, Suite 200 Pittsburgh, PA 15212 Raleigh, NC 27608 KAMCO SUPPLY CORP. 80 21st Street Brooklyn, NY 11232 7 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 KOHLER CO. CT Corporation System 28 Liberty St, 42nd Fl New York, NY 10005 LENNOX INDUSTRIES, INC. 80 State Street Albany, NY 12207 LEVITON MANUFACTURING CO., INC. 201 North Service Road Melville, NY 11747 PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc., f/k/a 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 Asbestos Litigation Support Manager ECKERT SEAMANS CHERIN & MELLOTT, LLC Case Management & Technology Center USX Towers 600 Grant Street Pittsburgh, PA 15219 PFIZER, INC. (PFIZER) CT Corporation Systems 28 Liberty st, 42nd Fl New York, NY 10005 REDCO CORPORATION f/k/a CRANE CO. The Corporation Trust Company 1209 Orange Street or Redco Corporation 1000 N. West Street, Suite 1200 Wilmington, Delaware 19801 Wilmington, DE 19801 RHEEM MANUFACTURING COMPANY 80 State Street Albany, NY 12207 S.A. ARMSTRONG LIMITED 23 Bertrand Ave Scarborough, ON M1L2P3 SCHNEIDER ELECTRIC USA, INC. formerly known as SQUARE D COMPANY Corporation Service Company 801 Adlai Stevenson Dr Springfield, IL 62703 8 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 SPIRAX SARCO, INC. Individually and as successor to SARCO COMPANY CT Corporation 2 Office Park Court Suite 103 Columbia , SC 29223 TACO, INC. Corporation Service Company 222 Jefferson Boulevard Suite 200 Warwick, RI 02888 and CSC 225 Asylum Street, 20th Floor Hartford, CT 06103 Hartford, CT 06103 U.S. RUBBER COMPANY (UNIROYAL) Greenfield, Stein & Senior (Agent for Service of Process) 600 Third Avenue, 11th Floor New York, NY 10016-1903 UNION CARBIDE CORPORATION CT Corporation Systems 28 Liberty st, 42nd Fl New York, NY 10005 VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO., Individually and as Successor in interest to INTERNATIONAL TALC COMPANY, INC., GOUVERNEUR TALC COMPANY, INC., and INTERNATIONAL PULP COMPANY, INC. Corporation Service Company 80 State Street Albany, NY 12207 WARREN PUMPS, LLC CT Corporation 1209 Orange Street Wilmington, DE 19801 WEYERHAEUSER COMPANY Corporation Service Company 80 State Street Albany, NY 12207 9 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 YORK INTERNATIONAL CORPORATION CT Corp 28 Liberty St, 42nd Fl New York, NY 10005 10 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X Index No.: KURT R. HALLMAN and ANGELICA HALLMAN, Date Filed: Plaintiff(s), -against- VERIFIED COMPLAINT A.O. SMITH WATER PRODUCTS CO., ABB, INC. PLAINTIFF DEMANDS Individually and as successor in interest to ITE CIRCUIT TRIAL BY JURY BREAKERS, INC., AERCO INTERNATIONAL, INC., AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., ANCHOR DARLING VALVE COMPANY, ARMSTRONG INTERNATIONAL, INC., ARMSTRONG PUMPS, INC., ATWOOD & MORRILL COMPANY, AURORA PUMP COMPANY, BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP, BURNHAM LLC,, Individually and as successor to BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC., BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES, CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC, CARRIER CORPORATION, CLEAVER- BROOKS, INC., COMPUDYNE CORPORATION, Individually, and as successor to YORK SHIPLEY, INC., CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC., DAP, INC., EATON CORPORATION, as successor -in-interest to CUTLER-HAMMER, INC., FLOWSERVE US, INC. Individually and successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, FMC CORPORATION, on behalf of its former CHICAGO PUMP & NORTHERN PUMP BUSINESSES, FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS DUNHAM-BUSH, INC., G. DENVER and CO., LLC, 11 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 GENERAL ELECTRIC COMPANY, GOULD ELECTRONICS INC., GOULDS PUMPS LLC, GRINNELL LLC, HUBBELL INCORPORATED, as successor in interest to THE BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually, IMO INDUSTRIES, INC.,, INTERNATIONAL PAPER COMPANY, Individually and as successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED STATES PLYWOOD CORPORATION, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., JENKINS BROS., KAISER GYPSUM COMPANY, INC., KAMCO SUPPLY CORP., KOHLER CO., LENNOX INDUSTRIES, INC., LEVITON MANUFACTURING CO., INC., PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc., f/k/a 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, PFIZER, INC. (PFIZER), REDCO CORPORATION f/k/a CRANE CO., RHEEM MANUFACTURING COMPANY, S.A. ARMSTRONG LIMITED, SCHNEIDER ELECTRIC USA, INC. formerly known as SQUARE D COMPANY, SPIRAX SARCO, INC. Individually and as successor to SARCO COMPANY, TACO, INC., U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO., Individually and as Successor in interest to INTERNATIONAL TALC COMPANY, INC., GOUVERNEUR TALC COMPANY, INC., and INTERNATIONAL PULP COMPANY, INC., WARREN PUMPS, LLC, WEYERHAEUSER COMPANY, YORK INTERNATIONAL CORPORATION, Defendants. -----------------------------------------------------------------------------X 12 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, by their attorneys WEITZ & LUXENBERG, P.C., upon information and belief, at all times hereinafter mentioned alleges as follows: Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, by their attorneys, WEITZ & LUXENBERG, P.C., for their verified complaint respectfully alleges: 1. The terms ‘Defendant’ or ‘Defendants’ as used herein shall apply to all named business and/or corporate entities and/or such company’s predecessor(s) and/or successor(s) in interest. 2. Upon information and belief, Plaintiff KURT R. HALLMAN is suffering from Lung Cancer. 3. Plaintiff has provided an authorization to obtain plaintiff’s social security records to recordtrak contemporaneously with this complaint. 4. Defendant A.O. SMITH WATER PRODUCTS CO., was and still is a duly organized domestic corporation doing business in the State of New York. 5. Defendant ABB, INC. Individually and as successor in interest to ITE CIRCUIT BREAKERS, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 6. Defendant AERCO INTERNATIONAL, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 7. Defendant AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., was and still is a duly organized domestic corporation doing business in the State of New York. 8. Defendant ANCHOR DARLING VALVE COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 13 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 9. Defendant ARMSTRONG INTERNATIONAL, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 10. Defendant ARMSTRONG PUMPS, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 11. Defendant ARMSTRONG PUMPS, INC., was and still 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. 12. Defendant ATWOOD & MORRILL COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 13. Defendant AURORA PUMP COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 14. Defendant BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP, was and still is a duly organized domestic corporation doing business in the State of New York. 15. Defendant BURNHAM LLC,, Individually and as successor to BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 16. Defendant BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, was and still is a duly organized domestic corporation doing business in the State of New York. 17. Defendant BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES, was and still is a duly organized domestic corporation doing business in the State of New York. 18. Defendant CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 14 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 19. Defendant CARRIER CORPORATION, was and still is a duly organized domestic corporation doing business in the State of New York. 20. Defendant CLEAVER- BROOKS, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 21. Defendant COMPUDYNE CORPORATION, Individually, and as successor to YORK SHIPLEY, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 22. Defendant CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 23. Defendant DAP, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 24. Defendant EATON CORPORATION, as successor -in-interest to CUTLER-HAMMER, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 25. Defendant FLOWSERVE US, INC. Individually and successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, was and still is a duly organized domestic corporation doing business in the State of New York. 26. Defendant FMC CORPORATION, on behalf of its former CHICAGO PUMP & NORTHERN PUMP BUSINESSES, was and still is a duly organized domestic corporation doing business in the State of New York. 27. Defendant FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS DUNHAM-BUSH, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 15 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 28. Defendant G. DENVER and CO., LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 29. Defendant GENERAL ELECTRIC COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 30. Defendant GOULD ELECTRONICS INC., was and still is a duly organized domestic corporation doing business in the State of New York. 31. Defendant GOULDS PUMPS LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 32. Defendant GRINNELL LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 33. Defendant HUBBELL INCORPORATED, as successor in interest to THE BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually, was and still is a duly organized domestic corporation doing business in the State of New York. 34. Defendant IMO INDUSTRIES, INC.,, was and still is a duly organized domestic corporation doing business in the State of New York. 35. Defendant INTERNATIONAL PAPER COMPANY, Individually and as successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED STATES PLYWOOD CORPORATION, was and still is a duly organized domestic corporation doing business in the State of New York. 36. Defendant ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., was and still is a duly organized domestic corporation doing business in the State of New York. 37. Defendant JENKINS BROS., was and still is a duly organized domestic corporation doing business in the State of New York. 16 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 38. Defendant KAISER GYPSUM COMPANY, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 39. Defendant KAMCO SUPPLY CORP., was and still is a duly organized domestic corporation doing business in the State of New York. 40. Defendant KOHLER CO., was and still is a duly organized domestic corporation doing business in the State of New York. 41. Defendant LENNOX INDUSTRIES, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 42. Defendant LEVITON MANUFACTURING CO., INC., was and still is a duly organized domestic corporation doing business in the State of New York. 43. Defendant PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc., f/k/a 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 still is a duly organized domestic corporation doing business in the State of New York. 44. Defendant PFIZER, INC. (PFIZER), was and still is a duly organized domestic corporation doing business in the State of New York. 45. Defendant REDCO CORPORATION f/k/a CRANE CO., was and still is a duly organized domestic corporation doing business in the State of New York. 46. Defendant RHEEM MANUFACTURING COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 47. Defendant S.A. ARMSTRONG LIMITED, was and still is a duly organized domestic corporation doing business in the State of New York. 17 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 48. Defendant SCHNEIDER ELECTRIC USA, INC. formerly known as SQUARE D COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 49. Defendant SPIRAX SARCO, INC. Individually and as successor to SARCO COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 50. Defendant TACO, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 51. Defendant U.S. RUBBER COMPANY (UNIROYAL), was and still is a duly organized domestic corporation doing business in the State of New York. 52. Defendant UNION CARBIDE CORPORATION, was and still is a duly organized domestic corporation doing business in the State of New York. 53. Defendant VANDERBILT MINERALS, LLC., f/k/a R.T. VANDERBILT CO., Individually and as Successor in interest to INTERNATIONAL TALC COMPANY, INC., GOUVERNEUR TALC COMPANY, INC., and INTERNATIONAL PULP COMPANY, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 54. Defendant WARREN PUMPS, LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 55. Defendant WEYERHAEUSER COMPANY, was and still is a duly organized domestic corporation doing business in the State of New York. 56. Defendant YORK INTERNATIONAL CORPORATION , was and still is a duly organized domestic corporation doing business in the State of New York. Plaintiff(s), KURT R. HALLMAN and ANGELICA HALLMAN, repeats and realleges NYCAL - WEITZ & LUXENBERG, P.C. STANDARD ASBESTOS COMPLAINT FOR 18 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 PERSONAL INJURY No. 8 as if fully incorporated herein as it pertains to the defendants in the aforementioned caption. Dated: June 07, 2024 New York, New York Yours, etc., WEITZ & LUXENBERG, P.C . Attorneys for Plaintiff(s) 700 Broadway New York, NY 10003 (212) 558-5500 19 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 STATE OF NEW YORK ) SS: COUNTY OF NEW YORK ) The undersigned, an attorney admitted to practice in the Courts of New York State, shows: Deponent is an Associate of the firm WEITZ & LUXENBERG, P.C., Counsel for the plaintiff(s) in the within action; deponent has read the foregoing summons and verified complaint and knows the contents thereof; the same is true to deponent's own knowledge, except as to the matters therein stated to be alleged on information and belief, and that as to those matters deponent believes it to be true. This verification is made by deponent and not by plaintiff(s) because plaintiff(s) resides outside of the County of New York where plaintiffs' counsel and deponent maintain their office. Dated: June 07, 2024 New York, New York /S/ AMBRE BRANDIS 20 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ==================================================================================== KURT R. HALLMAN and ANGELICA HALLMAN, Plaintiff(s), -against- A.O. SMITH WATER PRODUCTS CO., et. al., Defendants. ==================================================================================== SUMMONS and COMPLAINT ==================================================================================== WEITZ & LUXENBERG, P.C. Attorneys for PLAINTIFFS 700 Broadway New York, NY 10003 212-558-5500 ==================================================================================== To Attorney(s) for ==================================================================================== Service of a copy of the within is hereby admitted. Dated, June 07, 2024 ……………………………………………………………………………………………………………………………. Attorney(s) for =================================================================================== 21 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X KURT R. HALLMAN and ANGELICA HALLMAN, Plaintiff(s), FULL CAPTION RIDER -against- A.O. SMITH WATER PRODUCTS CO., ABB, INC. Individually and as successor in interest to ITE CIRCUIT BREAKERS, INC., AERCO INTERNATIONAL, INC., AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., ANCHOR DARLING VALVE COMPANY, ARMSTRONG INTERNATIONAL, INC., ARMSTRONG PUMPS, INC., ATWOOD & MORRILL COMPANY, AURORA PUMP COMPANY, BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP, BURNHAM LLC,, Individually and as successor to BURNHAM CORPORATION, and as alter ego to BURNHAM HOLDINGS, INC., BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, BW/IP, INC. AND ITS WHOLLY OWNED SUBSIDIARIES, CANVAS MW, LLC, f/k/a THE MARLEY-WYLAIN COMPANY, LLC and CANVAS SX, LLC, f/k/a SPX, LLC, CARRIER CORPORATION, CLEAVER- BROOKS, INC., COMPUDYNE CORPORATION, Individually, and as successor to YORK SHIPLEY, INC., CROWN BOILER CO., f/k/a CROWN INDUSTRIES, INC., DAP, INC., EATON CORPORATION, as successor -in-interest to CUTLER-HAMMER, INC., FLOWSERVE US, INC. Individually and successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, FMC CORPORATION, on behalf of its former CHICAGO PUMP & NORTHERN PUMP BUSINESSES, FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS DUNHAM-BUSH, INC., 22 of 23 FILED: NEW YORK COUNTY CLERK 06/07/2024 10:39 AM INDEX NO. 190154/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/07/2024 G. DENVER and CO., LLC, GENERAL ELECTRIC COMPANY, GOULD ELECTRONICS INC., GOULDS PUMPS LLC, GRINNELL LLC, HUBBELL INCORPORATED, as successor in interest to THE BRYANT ELECTRIC COMPANY, and HUBBELL INCORPORATED, Individually, IMO INDUSTRIES, INC.,, INTERNATIONAL PAPER COMPANY, Individually and as successor to CHAMPION INTERNATIONAL CORPORATION, as successor to UNITED STATES PLYWOOD CORPORATION, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., JENKINS BROS., KAISER GYPSUM COMPANY, INC., KAMCO SUPPLY CORP., KOHLER CO., LENNOX INDUSTRIES, INC., LEVITON MANUFACTURING CO., INC., PARAMOUNT GLOBAL, f/k/a VIACOMCBS Inc., f/k/a 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, PFIZER, INC. (PFIZER), REDCO CORPORATION f/k/a CRANE CO., RHEEM MANUFACTURING COMPANY, S.A. ARMSTRONG LIMITED, SCHNEIDER ELECTRIC USA, INC. formerly known as SQUARE D COMPANY, SPIRAX SARCO, INC. Individually and as successor to SARCO COMPANY,