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  • Michael A Runyon v. Abb, Inc.       Individually And As Successor In Interest To Ite Circuit       Breakers, Inc, Air & Liquid Systems Corporation,      As Successor-By-Merger To Buffalo Pumps, Inc, Amchem Products, Inc.,       N/K/A Rhone Poulenc Ag Company,      N/K/A Bayer Cropscience Inc, American Honda Motor Co., Inc. (Ahm), Atwood & Morrill Company, Aurora Pump Company, Blackmer, Borgwarner Morse Tec Llc, Briggs & Stratton Corp, Bw/Ip, Inc. And Its Wholly Owned Subsidiaries, Carrier Corporation, Cbs Corporation, F/K/A Viacom Inc.,     Successor By Merger To     Cbs Corporation, F/K/A     Westinghouse Electric Corporation, Certainteed Corporation, Cleaver Brooks Company, Inc, Crane Co, Crosby Valve Llc, Dana Companies, Llc, Eaton Corporation, Individually And 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, Ford Motor Company, Foster Wheeler, L.L.C, General Electric Company, Goulds Pumps Llc, Honeywell International, Inc.,      F/K/A Allied Signal, Inc. / Bendix, Imo Industries, Inc, Itt Industries, Inc.     Individually And As Successor-In-Interest To Hoffman     Specialty, Itt Llc.,     Individually And As Successor To Bell & Gossett    And As Successor To Kennedy Valve     Manufacturing Co., Inc, Jenkins Bros, Kawasaki Motors Corporation, Kohler Co, Mccord Corporation, Milton Roy Company, Pfizer, Inc. (Pfizer), Standard Motor Products, Inc, Superior Lidgerwood Mundy Corporation, Taco, Inc, Tecumseh Products Company, The Nash Engineering Company, Tyco International (Us) Inc, U.S. Rubber Company (Uniroyal), Union Carbide Corporation, Velan Valve Corporation, Viking Pump, Inc, Warren Pumps, Llc, Weil-Mclain, A Division Of The Marley-Wylain Company,     A Wholly Owned Subsidiary Of The Marley Company, Llc, Gould Electronics Inc. Torts - Asbestos document preview
  • Michael A Runyon v. Abb, Inc.       Individually And As Successor In Interest To Ite Circuit       Breakers, Inc, Air & Liquid Systems Corporation,      As Successor-By-Merger To Buffalo Pumps, Inc, Amchem Products, Inc.,       N/K/A Rhone Poulenc Ag Company,      N/K/A Bayer Cropscience Inc, American Honda Motor Co., Inc. (Ahm), Atwood & Morrill Company, Aurora Pump Company, Blackmer, Borgwarner Morse Tec Llc, Briggs & Stratton Corp, Bw/Ip, Inc. And Its Wholly Owned Subsidiaries, Carrier Corporation, Cbs Corporation, F/K/A Viacom Inc.,     Successor By Merger To     Cbs Corporation, F/K/A     Westinghouse Electric Corporation, Certainteed Corporation, Cleaver Brooks Company, Inc, Crane Co, Crosby Valve Llc, Dana Companies, Llc, Eaton Corporation, Individually And 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, Ford Motor Company, Foster Wheeler, L.L.C, General Electric Company, Goulds Pumps Llc, Honeywell International, Inc.,      F/K/A Allied Signal, Inc. / Bendix, Imo Industries, Inc, Itt Industries, Inc.     Individually And As Successor-In-Interest To Hoffman     Specialty, Itt Llc.,     Individually And As Successor To Bell & Gossett    And As Successor To Kennedy Valve     Manufacturing Co., Inc, Jenkins Bros, Kawasaki Motors Corporation, Kohler Co, Mccord Corporation, Milton Roy Company, Pfizer, Inc. (Pfizer), Standard Motor Products, Inc, Superior Lidgerwood Mundy Corporation, Taco, Inc, Tecumseh Products Company, The Nash Engineering Company, Tyco International (Us) Inc, U.S. Rubber Company (Uniroyal), Union Carbide Corporation, Velan Valve Corporation, Viking Pump, Inc, Warren Pumps, Llc, Weil-Mclain, A Division Of The Marley-Wylain Company,     A Wholly Owned Subsidiary Of The Marley Company, Llc, Gould Electronics Inc. Torts - Asbestos document preview
  • Michael A Runyon v. Abb, Inc.       Individually And As Successor In Interest To Ite Circuit       Breakers, Inc, Air & Liquid Systems Corporation,      As Successor-By-Merger To Buffalo Pumps, Inc, Amchem Products, Inc.,       N/K/A Rhone Poulenc Ag Company,      N/K/A Bayer Cropscience Inc, American Honda Motor Co., Inc. (Ahm), Atwood & Morrill Company, Aurora Pump Company, Blackmer, Borgwarner Morse Tec Llc, Briggs & Stratton Corp, Bw/Ip, Inc. And Its Wholly Owned Subsidiaries, Carrier Corporation, Cbs Corporation, F/K/A Viacom Inc.,     Successor By Merger To     Cbs Corporation, F/K/A     Westinghouse Electric Corporation, Certainteed Corporation, Cleaver Brooks Company, Inc, Crane Co, Crosby Valve Llc, Dana Companies, Llc, Eaton Corporation, Individually And 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, Ford Motor Company, Foster Wheeler, L.L.C, General Electric Company, Goulds Pumps Llc, Honeywell International, Inc.,      F/K/A Allied Signal, Inc. / Bendix, Imo Industries, Inc, Itt Industries, Inc.     Individually And As Successor-In-Interest To Hoffman     Specialty, Itt Llc.,     Individually And As Successor To Bell & Gossett    And As Successor To Kennedy Valve     Manufacturing Co., Inc, Jenkins Bros, Kawasaki Motors Corporation, Kohler Co, Mccord Corporation, Milton Roy Company, Pfizer, Inc. (Pfizer), Standard Motor Products, Inc, Superior Lidgerwood Mundy Corporation, Taco, Inc, Tecumseh Products Company, The Nash Engineering Company, Tyco International (Us) Inc, U.S. Rubber Company (Uniroyal), Union Carbide Corporation, Velan Valve Corporation, Viking Pump, Inc, Warren Pumps, Llc, Weil-Mclain, A Division Of The Marley-Wylain Company,     A Wholly Owned Subsidiary Of The Marley Company, Llc, Gould Electronics Inc. Torts - Asbestos document preview
  • Michael A Runyon v. Abb, Inc.       Individually And As Successor In Interest To Ite Circuit       Breakers, Inc, Air & Liquid Systems Corporation,      As Successor-By-Merger To Buffalo Pumps, Inc, Amchem Products, Inc.,       N/K/A Rhone Poulenc Ag Company,      N/K/A Bayer Cropscience Inc, American Honda Motor Co., Inc. (Ahm), Atwood & Morrill Company, Aurora Pump Company, Blackmer, Borgwarner Morse Tec Llc, Briggs & Stratton Corp, Bw/Ip, Inc. And Its Wholly Owned Subsidiaries, Carrier Corporation, Cbs Corporation, F/K/A Viacom Inc.,     Successor By Merger To     Cbs Corporation, F/K/A     Westinghouse Electric Corporation, Certainteed Corporation, Cleaver Brooks Company, Inc, Crane Co, Crosby Valve Llc, Dana Companies, Llc, Eaton Corporation, Individually And 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, Ford Motor Company, Foster Wheeler, L.L.C, General Electric Company, Goulds Pumps Llc, Honeywell International, Inc.,      F/K/A Allied Signal, Inc. / Bendix, Imo Industries, Inc, Itt Industries, Inc.     Individually And As Successor-In-Interest To Hoffman     Specialty, Itt Llc.,     Individually And As Successor To Bell & Gossett    And As Successor To Kennedy Valve     Manufacturing Co., Inc, Jenkins Bros, Kawasaki Motors Corporation, Kohler Co, Mccord Corporation, Milton Roy Company, Pfizer, Inc. (Pfizer), Standard Motor Products, Inc, Superior Lidgerwood Mundy Corporation, Taco, Inc, Tecumseh Products Company, The Nash Engineering Company, Tyco International (Us) Inc, U.S. Rubber Company (Uniroyal), Union Carbide Corporation, Velan Valve Corporation, Viking Pump, Inc, Warren Pumps, Llc, Weil-Mclain, A Division Of The Marley-Wylain Company,     A Wholly Owned Subsidiary Of The Marley Company, Llc, Gould Electronics Inc. Torts - Asbestos document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 01/30/2020 04:30 PM INDEX NO. 190296/2019 NYSCEF DOC. NO. 98 RECEIVED NYSCEF: 01/30/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK MICHAEL A. RUNYON Index No.: 190296/2019 Plaintiffs, -against- VERIFIED ANSWER ABB, INC., Individually and as successor in interest to ITE CIRCUIT BREAKERS, INC., et al., Defendants. Defendant, SUPERIOR LIDGERWOOD MUNDY CORPORATION, by its attorneys Eckert Seamans Cherin & Mellott, LLC, hereby ackilowledges the receipt of a Summons and copy of the Plaintiff's Verified Complaint in this action. 1. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION does not "1" answer the statement in Paragraph of the Plaintiff's Verified Complaint because it does not contain any allegations. 2. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION denies the "2" allegations contained in Paragraph of the Plaintiff's Verified Complaint, and refers all questions of law to this Court for detennination, and Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION denies any knowledge or information sufficient to form a belief as "2" to the truth of the allegations contained in Paragraph of the Plaintiff's Verified Complaint as itpertains to the remaining defendants in the Verified Complaint. 3. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION does not "3" answer the statement in Paragraph of the Plaintiff's Verified Complaint because it does not contain any allegations. {S0117103.1} 1 of 4 FILED: NEW YORK COUNTY CLERK 01/30/2020 04:30 PM INDEX NO. 190296/2019 NYSCEF DOC. NO. 98 RECEIVED NYSCEF: 01/30/2020 4. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION does not "4" "22" answer the allegations in Paragraphs through of the Plaintiff's Verified Complaint because the same do not apply to it. 23. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION denies the "23" allegations in Paragraph of the Plaintiff's Verified Complaint and leaves Plaintiffs to their proofs. 24. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION does not "24" "30" answer the allegations in Paragraphs through of the Plaintiff's Verified Complaint because the same do not apply to it. Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION repeats and re- alleges its Standard Answer to Weitz & Luxenberg, P.C.'s Standard Asbestos Complaint for Personal Injury No. 7 as if fully incorporated herein and raises each of the affirmative defenses contained in its standard answer with cross claims. WHEREFORE, Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION requests judgment in its favor dismissing Plaintiff's Complaint against it together with the costs and disbursements of this action and for any expenses incurred in the defense thereof, including attorneys' this defendant's fees. {S0117103.1} 2 2 of 4 FILED: NEW YORK COUNTY CLERK 01/30/2020 04:30 PM INDEX NO. 190296/2019 NYSCEF DOC. NO. 98 RECEIVED NYSCEF: 01/30/2020 FURTHERMORE, Defendant SUPERIOR LIDGERWOOD MUNDY CORPORATION demands judgment over and against co-defendants on its cross-claim for the amount of any judgment or verdict which may be obtained herein by the Plaintiffs against this attorneys' defendant, together with costs and disbursements of this action, plus any and all fees, costs ofinvestigation and disbursements. Dated: WHITE PLAINS, NEW YORK , 2020 Yours, etc. ECKERT SEAMANS CHERIN & MELLOTT, LLC Attorneys for Defendant ' SUPE R LID ER O fUND COR RATION By: MICHELLE D. GRADY, ESQ. 10 Bank Street, Suite 700 White Plains, New York (914) 949-2909 TO: Weitz & Luxenberg Attorneys for Plaintiff 700 Broadway New York, New York 10003 (212) 558-5500 All defense attorneys of record {S0117103.1} 3 3 of 4 FILED: NEW YORK COUNTY CLERK 01/30/2020 04:30 PM INDEX NO. 190296/2019 NYSCEF DOC. NO. 98 RECEIVED NYSCEF: 01/30/2020 ATTORNEY'S VERIFICATION STATE OF NEW YORK ) : ss.: COUNTY OF WESTCHESTER ) MICHELLE D. GRADY, ESQ., being duly sworn, deposes and says that I am an attorney with the law firm of Eckert Seamans Cherin & Mellott LLC, that I have read the foregoing Verified Answer by SUPERIOR LIDGERWOOD MUNDY CORPORATION and knows the contents thereof, and that the same is trueto my own knowledge, except as to matters therein stated to be alleged upon information and belief, and that as to those matters, I believe them to be true. The sources of my information are phone conversations with agents of the defendant. The reason this verification is made by deponent and not by defendant is because defendant does not reside within the County where their attorneys have an office. Dated: WHITE PLAINS, NEW YORK MICHELLE D. GRADY, ESQ. {S0117103.1} 4 4 of 4