LETTER / CORRESPONDENCE TO JUDGE - Letter re: Eli Lilly and Co. proposed nosjm

On May 17, 2016 torts - asbestos case was filed by Mary R Tinley, and Roger Tinley, represented by Block, Jerome Howard, and Ellis, Robert Ian, against Brenntag North America, As A Successor-In-Interest To Mineral Pigment Solutions, Inc., As A Successor-In Interest To Whittaker, Clark & Daniels, Inc.;, Brenntag Specialties, Inc., Flkla Mineral Pigment Solutions, Inc., As A Successor-In Interest To Whittaker, Clark & Daniels, Inc, Colgate-Palmolive Company et al. represented by Abbot, Edward Pierce, Dimarco, Erik Christopher, Echeverria, Jorkeell et al. in the jurisdiction of New York County. Judge Peter Moulton presiding.

                        
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BARRY MCTIERNAN & Moore LLC COUNSELORS AT LAW WESTCHESTER OFFICE 2 RECTOR STREET, | 4TH FLOOR New JERSEY OFFICE, 55 CHURCH STREET New YorK, N.Y. 10006 15 QUAKER HILL LANE, WHITE PLAINS, N.Y. 10601 RANDOLPH, N.J. O7869 Tet: 212-313-3600 TeL: 914-946-1030 Fax: 212-608-890! TEL: 973-366-1004 Fax: 914-946-3814 Fax: 2 | 2-GO8-8902 (Toxic TorT) Fax: 21 2-GO8-8901 PLEASE REFER TO February 14, 2017 James Kramer, Esq. Levy Konigsberg 800 Third Avenue New York, New York 10022 Re: — Mary Tinley Index No.: 190153/16 Our File No.: ELC62222 Dear Counselor : We attended the deposition of plaintiff on September 7, 2016, September 8, 2016, October 18, 2016 and October 19, 2016. During the deposition the plaintiff did not identify our client Eli Lilly and Co. Accordingly, we have prepared the enclosed No Opposition Summary Judgment Motion in compliance with Paragraph XVI.1.C of the Amended Case Management Order. We are serving a copy of this letter and enclosure on all known defense counsel.…

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