Preview
FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------------------X Index No.:
KAREN G. WYSONG and LOWELL WYSONG, 190069/2020
Plaintiffs, Date Filed: 3/5/2020
-against- Plaintiff Designates
NEW YORK
AERCO INTERNATIONAL, INC., County as the Place of
AIR & LIQUID SYSTEMS CORPORATION, Trial
as successor-by-merger to BUFFALO PUMPS, INC.,
ATWOOD & MORRILL COMPANY, The Basis of Venue is
AURORA PUMP COMPANY, Plaintiffs’ Place of
BMCE INC., Exposure
f/k/a UNITED CENTRIFUGAL PUMP,
BORG-WARNER MORSE TEC LLC, AMENDED
CBS CORPORATION, f/k/a VIACOM INC., SUMMONS
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., 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, INC.,
JOHNSON & JOHNSON CONSUMER, INC.,
MINNESOTA MINING & MANUFACTURING COMPANY,
a/k/a 3M COMPANY,
NASH ENGINEERING COMPANY (THE),
SPIRAX SARCO, INC.
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individually and as successor to SARCO COMPANY,
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,
BATH IRON WORKS CORPORATION,
Defendants.
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You are hereby summoned to answer the amended 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, March 5, 2020
New York, New York
MEIROWITZ & WASSERBERG, LLP
Defendant's address:
/S/ Daniel Wasserberg__________
Daniel Wasserberg, Esq.
Defendant's address: Attorney for Plaintiff
Post Office Address:
SEE ATTACHED DEFENDANTS RIDER 535 Fifth Ave, 23rd Floor
New York, New York 10017
(212) 897-1988
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DEFENDANTS' RIDER
GARDNER DENVER, INC.
1800 Gardner Expressway
AERCO INTERNATIONAL, INC., Quincy, IL 62301
100 Oritani Drive
Blauvelt, NY 10913 GENERAL DYNAMICS CORPORATION
CT Corporation
AIR & LIQUID SYSTEMS CORPORATION, 28 Liberty Street
as successor-by-merger to BUFFALO PUMPS New York, NY 10005
874 Oliver St.
N. Tonawanda, NY 14120 GENERAL ELECTRIC COMPANY
Electric Insurance Company
ATWOOD & MORRILL COMPANY 75 Sam Fonzo Drive
29 Old Right Road Beverly, MA 01915
Ipswich, MA 01938
GOULDS PUMPS, INC.
AURORA PUMP COMPANY 2881 E. Bayard Street
13320 Ballantyne Corporate Place Seneca Falls, NY 13148
Charlotte, NC 28277
GRINNELL LLC
BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP CT Corporation
Marshall Dennehy 28 Liberty Street
Anna M. DiLonardo New York, NY 10005
105 Maxess Rd.
Suite 303 HONEYWELL INTERNATIONAL, INC.,
Melville, NY 11747 f/k/a ALLIED SIGNAL, INC. / BENDIX
115 Tabor Road,
BORGWARNER MORSE TEC LLC Morris Plains, NJ 07950
CT Corporation
1209 Orange Street HOPEMAN BROTHERS, INC.,
Wilmington, Delaware 19801 CT Corporation Service
4701 Cox Road, Ste 285
CBS CORPORATION, f/k/a VIACOM INC., successor by merger Glen Allen, VA 23060
to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC
CORPORATION IMO INDUSTRIES, INC.
Asbestos Litigation Support Manager The Corporation Trust Company
ECKERT SEAMANS CHERIN & MELLOTT, LLC 1209 North Orange Street
USX Towers Wilmington, DE 19801
600 Grant Street
Pittsburgh, PA 15219 INGERSOLL-RAND COMPANY
c/o Illinois Corporation Service Co
CRANE CO. 801 Adlai Stevenson Drive, Springfield, IL 62703
100 First Stamford Place
Stamford, CT 06902 INTERNATIONAL PAPER COMPANY
CT Corporation
ELECTROLUX HOME PRODUCTS, INC. 28 Liberty Street
Individually, and as Successor to Tappan and Copes-Vulcan New York, NY 10005
20445 Emerald Parkway,
Cleveland, OH 44135 ITT CORPORATION, individually, and as successor in interest to
BELL & GOSSETT, KENNEDY VALVE MFG. CO., INC., and
FLOWSERVE US, INC. solely as Successor to Rockwell HOFFMAN SPECIALTY,
Manufacturing Company, Edward Valve, Inc., Nordstrom Valves,CT Corporation
CT Corporation 28 Liberty Street
28 Liberty Street New York, NY 10005
New York, NY 10005
JOHNSON & JOHNSON, INC.,
FMC CORPORATION, individually, and as successor to One Johnson & Johnson Plaza
CHICAGO PUMP COMPANY, NORTHERN PUMP New Brunswick, NJ 08933
COMPANY, and PEERLESS PUMP COMPANY,
CT Corporation System JOHNSON & JOHNSON CONSUMER, INC.,
101 Federal Street One Johnson & Johnson Plaza
Boston, MA 02110 New Brunswick, NJ 08933
FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS MINNESOTA MINING & MANUFACTURING COMPANY,
DUNHAM-BUSH, INC. a/k/a 3M COMPANY,
Peter C. Langenus, Esq. Corporation Service Company
Schnader Harrison Segal & Lewis LLP 801 Adlai Stevenson Drive
140 Broadway, Suite 3100 Springfield, IL 62703
New York, NY 10005
NASH ENGINEERING COMPANY (THE),
FOSTER WHEELER, L.L.C. United States Corporation Company (CT)
Route 173 at Frontage Road 50 Weston Street
Clinton, NJ 08809 Hartford, CT 06120-1537
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SPIRAX SARCO, INC ZURN INDUSTRIES, LLC.
1150 Northpoint Blvd. CT Corporation
Blythewood, SC 29016 28 Liberty Street
New York, NY 10005
TRANE U.S. INC., f/k/a AMERICAN STANDARD INC.
CT Corporation NEWLY ADDED DEFENDANT:
208 S. La Salle Street, #814 BATH IRON WORKS CORPORATION
Chicago, IL 60604 c/o Jon A. Fitzgerald
700 Washington Street
UNION CARBIDE CORPORATION Bath, ME 04530
CT Corporation
28 Liberty Street
New York, NY 10005
VELAN VALVE CORPORATION
94 Avenue C
Williston, VT 05495
WARREN PUMPS LLC,
The Corporation Trust Company
1209 North Orange Street
Wilmington, DE 19801
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------------------X Index No.:
KAREN G. WYSONG and LOWELL WYSONG, 190069/2020
Plaintiffs, Date Filed:
March 5, 2020
-against-
Plaintiff Designates
AERCO INTERNATIONAL, INC., NEW YORK
AIR & LIQUID SYSTEMS CORPORATION, County as the Place of
as successor-by-merger to BUFFALO PUMPS, INC., Trial
ATWOOD & MORRILL COMPANY,
AURORA PUMP COMPANY, The Basis of Venue is
BMCE INC., Defendants' Place of
f/k/a UNITED CENTRIFUGAL PUMP, Business
BORG-WARNER MORSE TEC LLC,
CBS CORPORATION, f/k/a VIACOM INC., AMENDED
successor by merger to CBS CORPORATION, f/k/a VERIFIED
WESTINGHOUSE ELECTRIC CORPORATION, COMPLAINT
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., 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, INC.,
JOHNSON & JOHNSON CONSUMER, INC.,
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MINNESOTA MINING & MANUFACTURING COMPANY,
a/k/a 3M COMPANY,
NASH ENGINEERING COMPANY (THE),
SPIRAX SARCO, INC.
individually and as successor to SARCO COMPANY,
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,
BATH IRON WORKS CORPORATION,
Defendants.
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To the above-named Defendant(s)
Plaintiff, KAREN G. WYSONG and LOWELL WYSONG, by their attorneys,
MEIROWITZ & WASSERBERG, LLP, for their amended verified complaint respectfully
allege:
1. Plaintiff, KAREN G. WYSONG was diagnosed with Mesothelioma.
2. Defendant AERCO INTERNATIONAL, INC., was and still is a duly organized
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.
3. Defendant AIR & LIQUID SYSTEMS CORPORATION, as successor-by-merger
to BUFFALO PUMPS, INC., was and still is a duly organized 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.
4. Defendant ATWOOD & MORRILL COMPANY, was and still is a corporation
doing business and/or transacting business in the State of New York and should have expected
its acts to have consequences within the State of New York.
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5. Defendant AURORA PUMP COMPANY, was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
6. Defendant BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP 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.
7. Defendant BORG-WARNER MORSE TEC LLC, was and still is a duly
organized domestic corporation doing business in the State of New York.
8. Defendant CBS CORPORATION, f/k/a VIACOM INC., successor by merger to
CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION was and still is a
duly organized domestic corporation doing business in the State of New York.
9. Defendant CRANE CO, was and still is a corporation doing business and/or
transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
10. Defendant ELECTROLUX HOME PRODUCTS, INC., individually, and as
successor to Tappan and Copes-Vulcan, was and still is a duly organized 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.
11. Defendant FLOWSERVE US, INC., solely as Successor to Rockwell
Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve
Company, and Vogt Valve Company, was and still is a corporation doing business and/or
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transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
12. Defendant FMC CORPORATION, individually, and as successor to CHICAGO
PUMP COMPANY, NORTHERN PUMP COMPANY, and PEERLESS PUMP COMPANY,
was and still is a corporation doing business and/or transacting business in the State of New York
and should have expected its acts to have consequences within the State of New York.
13. Defendant FORT KENT HOLDINGS, INC., f/k/a DUNHAM-BUSH INC., was
and still is a duly organized 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.
14. Defendant FOSTER WHEELER, L.L.C., was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
15. Defendant GARDNER DENVER, INC., was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
16. Defendant GENERAL DYNAMICS CORPORATION, Individually and as
Successor in Interest to BATH IRON WORKS, was and still is a corporation doing business
and/or transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
17. Defendant GENERAL ELECTRIC COMPANY, was and still is a corporation
doing business and/or transacting business in the State of New York and should have expected
its acts to have consequences within the State of New York.
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18. Defendant GOULDS PUMPS, INC., was and still is a corporation doing business
and/or transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
19. Defendant GRINNELL LLC, was and still is a corporation doing business and/or
transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
20. Defendant HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL,
INC. / BENDIX, was and still is a corporation doing business and/or transacting business in the
State of New York and should have expected its acts to have consequences within the State of
New York.
21. Defendant HOPEMAN BROTHERS, INC., was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
22. Defendant IMO INDUSTRIES, INC., was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
23. Defendant INGERSOLL RAND COMPANY, was and still is a duly organized
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.
24. Defendant INTERNATIONAL PAPER COMPANY, was and still is a
corporation doing business and/or transacting business in the State of New York and should have
expected its acts to have consequences within the State of New York.
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25. Defendant ITT CORPORATION, individually, and as successor in interest to
BELL & GOSSETT, KENNEDY VALVE MFG. CO. INC., and HOFFMAN SPECIALTY, 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.
26. Defendant JOHNSON & JOHNSON, INC., was and still is a corporation doing
business and/or transacting business in the State of New York and should have expected its acts
to have consequences within the State of New York.
27. Defendant JOHNSON & JOHNSON CONSUMER, INC., was and still is a
corporation doing business and/or transacting business in the State of New York and should have
expected its acts to have consequences within the State of New York.
28. Defendant MINNESOTA MINING & MANUFACTURING COMPANY, a/k/a
3M COMPANY, was and still is a duly organized 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.
29. Defendant NASH ENGINEERING COMPANY (THE), was and still is a duly
organized 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.
30. Defendant SPIRAX SARCO, INC. individually and as successor to SARCO
COMPANY, was and still is a corporation doing business and/or transacting business in the State
of New York and should have expected its acts to have consequences within the State of New
York.
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31. Defendant TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC., was and
still is a duly organized domestic corporation doing business in the State of New York.
32. Defendant UNION CARBIDE CORPORATION, was and still is a corporation
doing business and/or transacting business in the State of New York and should have expected
its acts to have consequences within the State of New York.
33. Defendant VELAN VALVE CORPORATION, was and still is a duly organized
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.
34. Defendant WARREN PUMPS LLC, was and still is a corporation doing business
and/or transacting business in the State of New York and should have expected its acts to have
consequences within the State of New York.
35. Defendant ZURN INDUSTRIES, INC., Individually and as Successor in Interest
to ERIE CITY IRON WORKS, was and still is a duly organized 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.
36. Defendant BATH IRON WORKS CORPORATION, was and still is a duly
organized 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.
37. Plaintiff’s counsel requested Social Security Records from the Social Security
Administration on March 4, 2020.
38. Plaintiff’s counsel uploaded a Social Security Authorization to RecordTrak on
March 4, 2020.
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Plaintiff, KAREN G. WYSONG and LOWELL WYSONG, repeats and realleges
NYCAL - MEIROWITZ & WASSERBERG, LLP’s STANDARD ASBESTOS COMPLAINT
FOR PERSONAL INJURY No. 1 as if fully incorporated herein as it pertains to the defendants
in the aforementioned caption.
Dated: March 5, 2020
New York, New York
MEIROWITZ & WASSERBERG, LLP
/S/ Daniel Wasserberg
Daniel Wasserberg
535 Fifth Ave, 23rd Floor
New York, New York 10017
(212) 897-1988
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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 Attorney of the law firm MEIROWITZ & WASSERBERG, LLP,
Counsel for the plaintiff(s) in the within action; deponent has read the foregoing amended
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: March 5, 2020
New York, New York
/S/ Daniel Wasserberg
DANIEL WASSERBERG
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Index No.: 190069/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
====================================================================================
KAREN G. WYSONG and LOWELL WYSONG,
Plaintiffs,
-against-
AERCO INTERNATIONAL, INC., et. al.,
Defendants.
====================================================================================
AMENDED SUMMONS and COMPLAINT
====================================================================================
MEIROWITZ & WASSERBERG, LLP
Attorneys for PLAINTIFFS
535 Fifth Ave, 23rd Floor
New York, NY 10017
212-897-1988
====================================================================================
To
Attorney(s) for
====================================================================================
Service of a copy of the within
is hereby admitted.
Dated, March 5, 2020
…………………………………………………………………………………………………………………………….
Attorney(s) for KAREN G. WYSONG and LOWELL WYSONG
===================================================================================
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------------------X Index No.:
KAREN G. WYSONG and LOWELL WYSONG, 190069/2020
Plaintiffs, Date Filed: 3/5/2020
-against-
AMENDED
AERCO INTERNATIONAL, INC., FULL CAPTION
AIR & LIQUID SYSTEMS CORPORATION, RIDER
as successor-by-merger to BUFFALO PUMPS, INC.,
ATWOOD & MORRILL COMPANY,
AURORA PUMP COMPANY,
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., 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, INC.,
JOHNSON & JOHNSON CONSUMER, INC.,
MINNESOTA MINING & MANUFACTURING COMPANY,
a/k/a 3M COMPANY,
NASH ENGINEERING COMPANY (THE),
SPIRAX SARCO, INC.
individually and as successor to SARCO COMPANY,
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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,
BATH IRON WORKS CORPORATION,
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Preview
FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X Index No.: KAREN G. WYSONG and LOWELL WYSONG, 190069/2020 Plaintiffs, Date Filed: 3/5/2020 -against- Plaintiff Designates NEW YORK AERCO INTERNATIONAL, INC., County as the Place of AIR & LIQUID SYSTEMS CORPORATION, Trial as successor-by-merger to BUFFALO PUMPS, INC., ATWOOD & MORRILL COMPANY, The Basis of Venue is AURORA PUMP COMPANY, Plaintiffs’ Place of BMCE INC., Exposure f/k/a UNITED CENTRIFUGAL PUMP, BORG-WARNER MORSE TEC LLC, AMENDED CBS CORPORATION, f/k/a VIACOM INC., SUMMONS 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., 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, INC., JOHNSON & JOHNSON CONSUMER, INC., MINNESOTA MINING & MANUFACTURING COMPANY, a/k/a 3M COMPANY, NASH ENGINEERING COMPANY (THE), SPIRAX SARCO, INC. 1 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 individually and as successor to SARCO COMPANY, 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, BATH IRON WORKS CORPORATION, Defendants. -----------------------------------------------------------------------------X You are hereby summoned to answer the amended 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, March 5, 2020 New York, New York MEIROWITZ & WASSERBERG, LLP Defendant's address: /S/ Daniel Wasserberg__________ Daniel Wasserberg, Esq. Defendant's address: Attorney for Plaintiff Post Office Address: SEE ATTACHED DEFENDANTS RIDER 535 Fifth Ave, 23rd Floor New York, New York 10017 (212) 897-1988 2 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 DEFENDANTS' RIDER GARDNER DENVER, INC. 1800 Gardner Expressway AERCO INTERNATIONAL, INC., Quincy, IL 62301 100 Oritani Drive Blauvelt, NY 10913 GENERAL DYNAMICS CORPORATION CT Corporation AIR & LIQUID SYSTEMS CORPORATION, 28 Liberty Street as successor-by-merger to BUFFALO PUMPS New York, NY 10005 874 Oliver St. N. Tonawanda, NY 14120 GENERAL ELECTRIC COMPANY Electric Insurance Company ATWOOD & MORRILL COMPANY 75 Sam Fonzo Drive 29 Old Right Road Beverly, MA 01915 Ipswich, MA 01938 GOULDS PUMPS, INC. AURORA PUMP COMPANY 2881 E. Bayard Street 13320 Ballantyne Corporate Place Seneca Falls, NY 13148 Charlotte, NC 28277 GRINNELL LLC BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP CT Corporation Marshall Dennehy 28 Liberty Street Anna M. DiLonardo New York, NY 10005 105 Maxess Rd. Suite 303 HONEYWELL INTERNATIONAL, INC., Melville, NY 11747 f/k/a ALLIED SIGNAL, INC. / BENDIX 115 Tabor Road, BORGWARNER MORSE TEC LLC Morris Plains, NJ 07950 CT Corporation 1209 Orange Street HOPEMAN BROTHERS, INC., Wilmington, Delaware 19801 CT Corporation Service 4701 Cox Road, Ste 285 CBS CORPORATION, f/k/a VIACOM INC., successor by merger Glen Allen, VA 23060 to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION IMO INDUSTRIES, INC. Asbestos Litigation Support Manager The Corporation Trust Company ECKERT SEAMANS CHERIN & MELLOTT, LLC 1209 North Orange Street USX Towers Wilmington, DE 19801 600 Grant Street Pittsburgh, PA 15219 INGERSOLL-RAND COMPANY c/o Illinois Corporation Service Co CRANE CO. 801 Adlai Stevenson Drive, Springfield, IL 62703 100 First Stamford Place Stamford, CT 06902 INTERNATIONAL PAPER COMPANY CT Corporation ELECTROLUX HOME PRODUCTS, INC. 28 Liberty Street Individually, and as Successor to Tappan and Copes-Vulcan New York, NY 10005 20445 Emerald Parkway, Cleveland, OH 44135 ITT CORPORATION, individually, and as successor in interest to BELL & GOSSETT, KENNEDY VALVE MFG. CO., INC., and FLOWSERVE US, INC. solely as Successor to Rockwell HOFFMAN SPECIALTY, Manufacturing Company, Edward Valve, Inc., Nordstrom Valves,CT Corporation CT Corporation 28 Liberty Street 28 Liberty Street New York, NY 10005 New York, NY 10005 JOHNSON & JOHNSON, INC., FMC CORPORATION, individually, and as successor to One Johnson & Johnson Plaza CHICAGO PUMP COMPANY, NORTHERN PUMP New Brunswick, NJ 08933 COMPANY, and PEERLESS PUMP COMPANY, CT Corporation System JOHNSON & JOHNSON CONSUMER, INC., 101 Federal Street One Johnson & Johnson Plaza Boston, MA 02110 New Brunswick, NJ 08933 FORT KENT HOLDINGS, INC., FORMERLY KNOWN AS MINNESOTA MINING & MANUFACTURING COMPANY, DUNHAM-BUSH, INC. a/k/a 3M COMPANY, Peter C. Langenus, Esq. Corporation Service Company Schnader Harrison Segal & Lewis LLP 801 Adlai Stevenson Drive 140 Broadway, Suite 3100 Springfield, IL 62703 New York, NY 10005 NASH ENGINEERING COMPANY (THE), FOSTER WHEELER, L.L.C. United States Corporation Company (CT) Route 173 at Frontage Road 50 Weston Street Clinton, NJ 08809 Hartford, CT 06120-1537 3 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 SPIRAX SARCO, INC ZURN INDUSTRIES, LLC. 1150 Northpoint Blvd. CT Corporation Blythewood, SC 29016 28 Liberty Street New York, NY 10005 TRANE U.S. INC., f/k/a AMERICAN STANDARD INC. CT Corporation NEWLY ADDED DEFENDANT: 208 S. La Salle Street, #814 BATH IRON WORKS CORPORATION Chicago, IL 60604 c/o Jon A. Fitzgerald 700 Washington Street UNION CARBIDE CORPORATION Bath, ME 04530 CT Corporation 28 Liberty Street New York, NY 10005 VELAN VALVE CORPORATION 94 Avenue C Williston, VT 05495 WARREN PUMPS LLC, The Corporation Trust Company 1209 North Orange Street Wilmington, DE 19801 4 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X Index No.: KAREN G. WYSONG and LOWELL WYSONG, 190069/2020 Plaintiffs, Date Filed: March 5, 2020 -against- Plaintiff Designates AERCO INTERNATIONAL, INC., NEW YORK AIR & LIQUID SYSTEMS CORPORATION, County as the Place of as successor-by-merger to BUFFALO PUMPS, INC., Trial ATWOOD & MORRILL COMPANY, AURORA PUMP COMPANY, The Basis of Venue is BMCE INC., Defendants' Place of f/k/a UNITED CENTRIFUGAL PUMP, Business BORG-WARNER MORSE TEC LLC, CBS CORPORATION, f/k/a VIACOM INC., AMENDED successor by merger to CBS CORPORATION, f/k/a VERIFIED WESTINGHOUSE ELECTRIC CORPORATION, COMPLAINT 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., 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, INC., JOHNSON & JOHNSON CONSUMER, INC., 5 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 MINNESOTA MINING & MANUFACTURING COMPANY, a/k/a 3M COMPANY, NASH ENGINEERING COMPANY (THE), SPIRAX SARCO, INC. individually and as successor to SARCO COMPANY, 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, BATH IRON WORKS CORPORATION, Defendants. -----------------------------------------------------------------------------X To the above-named Defendant(s) Plaintiff, KAREN G. WYSONG and LOWELL WYSONG, by their attorneys, MEIROWITZ & WASSERBERG, LLP, for their amended verified complaint respectfully allege: 1. Plaintiff, KAREN G. WYSONG was diagnosed with Mesothelioma. 2. Defendant AERCO INTERNATIONAL, INC., was and still is a duly organized 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. 3. Defendant AIR & LIQUID SYSTEMS CORPORATION, as successor-by-merger to BUFFALO PUMPS, INC., was and still is a duly organized 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. 4. Defendant ATWOOD & MORRILL COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 6 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 5. Defendant AURORA PUMP COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 6. Defendant BMCE INC., f/k/a UNITED CENTRIFUGAL PUMP 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. 7. Defendant BORG-WARNER MORSE TEC LLC, was and still is a duly organized domestic corporation doing business in the State of New York. 8. Defendant CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION was and still is a duly organized domestic corporation doing business in the State of New York. 9. Defendant CRANE CO, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 10. Defendant ELECTROLUX HOME PRODUCTS, INC., individually, and as successor to Tappan and Copes-Vulcan, was and still is a duly organized 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. 11. Defendant FLOWSERVE US, INC., solely as Successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, was and still is a corporation doing business and/or 7 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 12. Defendant FMC CORPORATION, individually, and as successor to CHICAGO PUMP COMPANY, NORTHERN PUMP COMPANY, and PEERLESS PUMP COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 13. Defendant FORT KENT HOLDINGS, INC., f/k/a DUNHAM-BUSH INC., was and still is a duly organized 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. 14. Defendant FOSTER WHEELER, L.L.C., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 15. Defendant GARDNER DENVER, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 16. Defendant GENERAL DYNAMICS CORPORATION, Individually and as Successor in Interest to BATH IRON WORKS, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 17. Defendant GENERAL ELECTRIC COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 8 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 18. Defendant GOULDS PUMPS, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 19. Defendant GRINNELL LLC, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 20. Defendant HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 21. Defendant HOPEMAN BROTHERS, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 22. Defendant IMO INDUSTRIES, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 23. Defendant INGERSOLL RAND COMPANY, was and still is a duly organized 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. 24. Defendant INTERNATIONAL PAPER COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 9 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 25. Defendant ITT CORPORATION, individually, and as successor in interest to BELL & GOSSETT, KENNEDY VALVE MFG. CO. INC., and HOFFMAN SPECIALTY, 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. 26. Defendant JOHNSON & JOHNSON, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 27. Defendant JOHNSON & JOHNSON CONSUMER, INC., was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 28. Defendant MINNESOTA MINING & MANUFACTURING COMPANY, a/k/a 3M COMPANY, was and still is a duly organized 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. 29. Defendant NASH ENGINEERING COMPANY (THE), was and still is a duly organized 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. 30. Defendant SPIRAX SARCO, INC. individually and as successor to SARCO COMPANY, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 10 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 31. Defendant TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 32. Defendant UNION CARBIDE CORPORATION, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 33. Defendant VELAN VALVE CORPORATION, was and still is a duly organized 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. 34. Defendant WARREN PUMPS LLC, was and still is a corporation doing business and/or transacting business in the State of New York and should have expected its acts to have consequences within the State of New York. 35. Defendant ZURN INDUSTRIES, INC., Individually and as Successor in Interest to ERIE CITY IRON WORKS, was and still is a duly organized 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. 36. Defendant BATH IRON WORKS CORPORATION, was and still is a duly organized 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. 37. Plaintiff’s counsel requested Social Security Records from the Social Security Administration on March 4, 2020. 38. Plaintiff’s counsel uploaded a Social Security Authorization to RecordTrak on March 4, 2020. 11 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 Plaintiff, KAREN G. WYSONG and LOWELL WYSONG, repeats and realleges NYCAL - MEIROWITZ & WASSERBERG, LLP’s STANDARD ASBESTOS COMPLAINT FOR PERSONAL INJURY No. 1 as if fully incorporated herein as it pertains to the defendants in the aforementioned caption. Dated: March 5, 2020 New York, New York MEIROWITZ & WASSERBERG, LLP /S/ Daniel Wasserberg Daniel Wasserberg 535 Fifth Ave, 23rd Floor New York, New York 10017 (212) 897-1988 12 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 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 Attorney of the law firm MEIROWITZ & WASSERBERG, LLP, Counsel for the plaintiff(s) in the within action; deponent has read the foregoing amended 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: March 5, 2020 New York, New York /S/ Daniel Wasserberg DANIEL WASSERBERG 13 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 Index No.: 190069/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ==================================================================================== KAREN G. WYSONG and LOWELL WYSONG, Plaintiffs, -against- AERCO INTERNATIONAL, INC., et. al., Defendants. ==================================================================================== AMENDED SUMMONS and COMPLAINT ==================================================================================== MEIROWITZ & WASSERBERG, LLP Attorneys for PLAINTIFFS 535 Fifth Ave, 23rd Floor New York, NY 10017 212-897-1988 ==================================================================================== To Attorney(s) for ==================================================================================== Service of a copy of the within is hereby admitted. Dated, March 5, 2020 ……………………………………………………………………………………………………………………………. Attorney(s) for KAREN G. WYSONG and LOWELL WYSONG =================================================================================== 14 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X Index No.: KAREN G. WYSONG and LOWELL WYSONG, 190069/2020 Plaintiffs, Date Filed: 3/5/2020 -against- AMENDED AERCO INTERNATIONAL, INC., FULL CAPTION AIR & LIQUID SYSTEMS CORPORATION, RIDER as successor-by-merger to BUFFALO PUMPS, INC., ATWOOD & MORRILL COMPANY, AURORA PUMP COMPANY, 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., 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, INC., JOHNSON & JOHNSON CONSUMER, INC., MINNESOTA MINING & MANUFACTURING COMPANY, a/k/a 3M COMPANY, NASH ENGINEERING COMPANY (THE), SPIRAX SARCO, INC. individually and as successor to SARCO COMPANY, 15 of 16 FILED: NEW YORK COUNTY CLERK 03/05/2020 04:43 PM INDEX NO. 190069/2020 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 03/05/2020 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, BATH IRON WORKS CORPORATION, -----------------------------------------------------------------------------X 16 of 16