On March 04, 2020 a Answer was filed involving a dispute between Karen G. Wysong, Lowell Wysong, and Aerco International, Inc., Air & Liquid Corporation, As Successor-By-Merger To Buffalo Pumps, Inc., Atwood & Morrill Company, Aurora Pump Company, Bath Iron Works Corporation, Bmce Inc., F K A United Centrifugal Pump, Borg Warner Morse Tec Llc, Cbs Corporation F K A Viacom Inc., Successor By Merger To Cbs Corporation F K A Westinghouse Electric Corporation, Crane Co., Electrolux Home Products, Inc., Individually, And As Successor To Tappan And Copes Vulcan, Flowserve Us, Inc., Solely As Successor To Rockwell Manufacturing Company, Edward Valve, Inc., And Nordstrom Valves, Inc., Fmc Corporation, Individually, And As Successor To Chicago Pump Company, Northern Pump Company, And Peerless Pump Company, Fort Kent Holdings, Inc., F K A Dunham-Bush, Inc., Foster Wheeler L.L.C., Gardner Denver, Inc., General Dynamics Corporation, Individually And As Successor In Interest To Bath Iron Works, General Electric Company, Goulds Pumps, Inc., Grinnell Llc, Honeywell International, Inc., F K A Allied Signal, Inc. Bendix, Hopeman Brothers, Inc., Imo Industries, Inc., Ingersoll-Rand Company, International Paper Company, Itt Corporation, Individually, And As Successor In Interest To Bell & Gossett, Kennedy Valve Mfg. Co. Inc., And Hoffman Specialty, Johnson & Johnson Consumer, Inc., Johnson & Johnson, Inc., Minnesota Mining & Manufacturing Company, A K A 3M Company, Nash Engineering Company, Spirax Sarco, Inc., Trane U.S. Inc., F K A American Standard, Inc., Union Carbide Corporation, Velan Valve Corporation, Warren Pumps Llc, Zurn Industries, Inc., Individually And As Successor In Interest To Erie City Iron Works, for Torts - Asbestos in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 06/11/2020 03:15 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/11/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------------X KAREN G. WYSONG and LOWELL WYSONG, Index No. 190069/2020 Plaintiff(s), - against - ANSWER WITH CROSS-CLAIMS AERCO INTERNATIONAL, INC., et al., Defendants. --------------------------------------------------------------------------X Defendant, BMCE, Inc., by its attorneys, Marshall Dennehey Warner Coleman & Goggin, hereby acknowledges receipt of an amended summons and a copy of plaintiff(s) amended verified complaint in this action. 1. Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to the truth of the allegations contained in paragraph "1" of the amended verified complaint. 2. Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to the truth of the allegations contained in paragraphs "2" through "5" of the amended verified complaint which pertain to other defendants. 3. Defendant, BMCE, Inc., denies each and every allegation contained in paragraph "6" of the amended verified complaint, except admits it has transacted business in the State of New York. 4. Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to the truth of the allegations contained in paragraphs "7" through "36" of the amended verified complaint which pertain to other defendants. 5. Defendant, BMCE, Inc., denies knowledge and information sufficient to form a belief as to the truth of the allegations contained in paragraphs "37" and "38" of the amended verified complaint. 1 of 5 FILED: NEW YORK COUNTY CLERK 06/11/2020 03:15 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/11/2020 Defendant, BMCE, Inc., hereby further answers the amended verified complaint in this action by reference to its corresponding Standard Answer filed pursuant to NYCAL Case Management Order and raises each of the affirmative defenses and cross-claims contained in its corresponding Standard Answer. Dated: Melville, New York April 29, 2020 Yours, etc. MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Anna M. DiLonardo Anna M. DiLonardo Attorneys for Defendant BMCE, Inc 105 Maxess Road, Suite 303 Melville, New York 11747 (631) 232-6130 TO: MEIROWITZ & WASSERBERG, LLP Attorneys for Plaintiffs ALL DEFENSE COUNSEL TO RECORD Via the Court's ECF System ~2~ 2 of 5 FILED: NEW YORK COUNTY CLERK 06/11/2020 03:15 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/11/2020 ATTORNEY VERIFICATION ANNA M. DILONARDO, the undersigned, an attorney duly admitted to practice law before all the Courts of the State of New York, a member of the firm, MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN, attorneys for the defendant, BMCE, Inc., in the within action states that she has read the contents of the foregoing Answer with Cross-Claims and that the same is true to her knowledge except as to the matters, stated upon information and belief, she believes them to be true. Deponent further says that the grounds for her belief, as to all matters therein not stated upon her own knowledge, are investigations and reports which have been made concerning the subject matter of the within action, which are in possession of the aforementioned Attorneys-of-Record and with which Deponent is familiar. The reason this Verification is made by Deponent, instead of by the aforementioned Defendant, is because said Defendant is not within the County of Suffolk where Deponents and the aforementioned Attorneys-of-Record have their office. The undersigned affirms that the foregoing statements are true, under penalties of perjury. Dated: Melville, New York April 29, 2020 Anna M. DiLonardo ANNA M. DILONARDO ~3~ 3 of 5 FILED: NEW YORK COUNTY CLERK 06/11/2020 03:15 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/11/2020 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 11th day of June, 2020, a copy of the foregoing Answer with Cross-Claims was filed electronically this day and is available for viewing from the Court’s ECF system. Notice of this filing will be sent to all counsel of record via the Court’s ECF system. Anna M. DiLonardo Anna M. DiLonardo ~4~ 4 of 5 FILED: NEW YORK COUNTY CLERK 06/11/2020 03:15 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/11/2020 AFFlDAViT OF SERVICE STATE OF NEW YORK ) :ss. COUNTY OF SUFFOLK ) SUSAN R. CANTWELL, being duly sworn, deposes and says that deponent is not a party to the action, is over 18 years of age and resides in Greer lawn, New York. That on the 29th day of Apri!, 2020, deponent served the within Verified Answer upon : |vIeirowitz & Wasserberg 535 5th Avenue, 23rd Floor New York, New York 10017 Counsel for Plaintiffs the attorney(s) for the respective parties in this action, via electronic mail at the addressed noted therein by said attorney(s) for that purpose. `\ ......... sWAn R. An \ `E'LII5 M \ Sworn to before me on this 29"' day of April, 2020 c Public ABEUR-RASHEEI3 JASUR Nugiary Public, State of New Ycxrk No. 0HA6134563 Qualified in Suffolk County Commission Expires October 3, 2021 5 of 5