Preview
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
PANTELIS KAMMAS and KLEO KAMMAS,
Date Filed:
Plaintiffs,
Plaintiff designates
V.
NEW YORK
County as the place of trial
A.O. SMITH WATER PRODUCTS, et al.,
The basis of the venue is
Defendants. DEFENDANTS'
PLACE OF
BUSINESS
See Attached Rider —FULL CAPTION
SUMMONS
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve
a copy of your Answer, or, ifthe Complaint is not served with this Summons, to serve a Notice
of Appearance, on the Plaintiff s Attorney 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). In the case of your failure to
appear or answer, judgment will be taken against you by default for the relief demanded in the
complaint.
Dated: New York, New York Yours etc.,
June 25, 2019
BELLUCK & FOX, LLP
Attorneys for Plaintiff
546 Fifth Avenue, 5th Floor
New York, New York 10036
(212) 681 1575
sq.
1 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Index No. :
PANTELIS KAMMAS and KLEO KAMMAS,
FULL CAPTION RIDER
Plaintiffs,
- against -
A.O. SMITH WATER PRODUCTS;
AII ACQUISITION CORPORATION, LLC,
Individually and as Successor-in-Interest to
Athlone Industries, Inc. and Holland Furnace
Company;
AMERICAN INTERNATIONAL INDUSTRIES,
INC.;
ARMSTRONG INTERNATIONAL, INC.;
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves
& Controls USA Inc.;
AURORA PUMP COMPANY;
BURNHAM CORPORATION;
CARRIER CORPORATION;
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;
CERTAIN-TEED CORPORATION;
CLEAVER BROOKS COMPANY f/k/a Aqua Chem,
Inc.;
COLUMBIA BOILER COMPANY OF
POTTSTOWN;
COMPUDYNE CORPORATION, Individually and as
Successor to York-Shipley;
CRANE CO.;
CROWN BOILER CO.;
ECR INTERNATIONAL, INC., Individually and as
Successor to Dunkirk, Dunkirk Boilers and
Utica Boilers and Pennco, Inc.;
FLOWSERVE US, INC., solely as Successor to
Rockwell Manufacturing Company, Edward
Valves, Inc., Nordstrom Valves, Inc. and
Edward Vogt Valve Company;
FOSTER WHEELER, LLC;
GENERAL ELECTRIC COMPANY;
GOULDS PUMPS INC.;
GRINNELL CORPORATION;
H.B. SMITH CO., INC.;
- 2 -
2 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
H.C. OSWALD SUPPLY CO., INC.;
HONEYWELL INTERNATIONAL, INC.,
Individually and f/k/a AlliedSignal, Inc., and as
Successor-in-Interest to The Bendix Corp.;
I.T.T. INDUSTRIES, INC., Individually and as
successor to Bell & Gossett;
INTERNATIONAL COMFORT PRODUCTS LLC,
Individually and as Successor to Heil Heating
and Cooling;
JENK1NS BROS.
KOHLER CO.;
LENNOX INDUSTRIES, INC., Individually and as
Successor to Lennox Furnace Company and
Ducane;
METROPOLITAN LIFE INSURANCE COMPANY;
N & S SUPPLY OF FISHKILL, INC.;
NASH ENGINEERING COMPANY (THE);
NEW YORKER BOILER COMPANY, INC.;
PECORA CORPORATION, Individually and as
Successor to Pecora Corporation, New
Pecora Corporation, and New Pecora
Corporation, Inc.;
PEERLESS INDUSTRIES, INC;
PENNCO, INC.;
RHEEM MANUFACTURING COMPANY, INC.;
RILEY POWER, INC. f/k/a Babcock Borsig Power,
Inc. and f/k/a Riley Stoker Corporation d/b/a
DB Riley, Inc.;
ROCKWELL AUTOMATION INC., Individually
and as Successor to Timken Heating Business
and S. Co., Inc. f/k/a Scaife Company, as
Successor in Interest to Rockwell Spring &
Axle Company's Timken Silent Automatic
Division;
SID HARVEY INDUSTRIES, INC.;
SID HARVEY SUPPLY, INC.;
SPENCE ENGINEERING COMPANY, INC.;
SPENCER HEATER, a Lycoming division of AVCO
Corporation;
TACO, INC.;
TEXACO, INC.;
UNION CARBIDE CORPORATION;
WARREN PUMPS, LLC, Individually and as
Successor to The Quimby Pump Company;
WEIL McLA1N, a division of Marley Wylain
Company;
- 3 -
3 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
WILLIAM POWELL COMPANY (THE);
YORK INTERNATIONAL CORPORATION,
Individually and as Successor to Frick
Company.
Defendants.
- 4 -
4 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
Defendants'
addresses:
PANTELIS KAMMAS'S DEFENDANT ADDRESS LIST
DEFENDANTS SERVICE
A.O. SMITH WATER PRODUCTS DIRECT
A.O. Smith Corporation
Attn: Debra Schwanda APS INTERNATIONAL
11270 W. Park Place
Milwaukee, WI 53224-9502
AH ACQUISITION CORPORATION, LLC, Individually DIRECT
and as Successor-in-Intered to Athlone Industries, Inc. and
Holland Furnace Company
c/o Allegheny Technologies Incorporated
1000 Six PPG Place
Pittsburgh, Pennsylvania 15222
AMERICAN INTERNATIONAL INDUSTRIES, INC. DIRECT
2220 Gaspar Avenue
Commerce, California 90040
ARMSTRONG INTERNATIONAL, INC. DIRECT
900 Maple Street
Three Rivers, Michigan 49093
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & DIRECT
Controls USA Inc.
c/o Weir Valves & Controls Usa Inc.
29 Old Right Road
Ipswich, Massachusetts 01938
AURORA PUMP COMPANY DIRECT - CERTIFIED MAIL RRR
800 Airport Road c/o Kevin Keyes
North Aurora, Illinois60542 SPX Corporation
13320-A-A Ballantyne Corporate Place
Charlotte, North Carolina 28277
BURNHAM CORPORATION c/o Secretary of State
Albert Morrison III Albany, New York
1241 Harrisburg Pike
Lancaster, Pennsylvania 17603
- 5 -
5 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
CARRIER CORPORATION c/o Corporate Trust Systems
One Carrier Place 28 Liberty Street
Farmington, Connecticut 06032-4015 New York, New York
CBS CORPORATION, a Delaware Corporation, f/k/a c/o Corporation Service Company
Viacom Inc, Successor by merger to CBS Corporation, a 80 State Street
Pennsylvania Corporation, f/k/a Westiñghan::e Electric Albany, New York 12207
Corporation
c/o Adrienne Harrington
52nd
51 West Street
New York, New York 10019
CERTAIN-TEED CORPORATION c/o Corporate Trust Systems
750 East Swedesford Road 28 Liberty Street
Valley Forge, Pennsylvania 19482 New York, New York
CLEAVER-BROOKS COMPANY f/k/a Aqua-Chem, Inc. DIRECT
Headquarters
221 Law Street
Thomasville, GA 31792
COLUMBIA BOILER COMPANY OF POTTSTOWN DIRECT
390 Old Reading Pike
Stowe, PA 19464
COMPUDYNE CORPORATION, Individually and as DIRECT
Successor to York-Shipley
CompuDyne Corporation
CSC Services of Nevada, Inc.
2215-B Renaissance Drive
Las Vegas, Nevada 89119
CRANE CO. c/o Corporate Trust Systems
Robert S. Evans 28 Liberty Street
100 FirstStamford Place New York, New York
Stamford, Connecticut 06902
CROWN BOILER CO. DIRECT
3633 I Street
Philadelphia, Pennsylvania 19134
- 6 -
6 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
ECR INTERNATIONAL, INC., Individually and as c/o Secretary of State
Successor to Dunkirk, Dunkirk Boilers and Utica Boilers Albany, New York 12207
2201 Dwyer Avenue
Utica, New York 13504
FLOWSERVE US, INC., solely as Successor to Rockwell c/o Corporate Trust Systems
Manufacturing Company, Edward Valves, Inc., Nordstrom 28 Liberty Street
Valves, Inc. and Edward Vogt Valve Company New York, New York
Flowserve Corporation
General Counsel
5215 North O'Connor Blvd, Ste 2300
Irving, Texas 75039
FOSTER WHEELER, LLC Registered Agent:
Perryville, Corporate Park United Agent Group, Inc.
Route 173 atFrontage Road 3411 Silverside Road #104
Clinton, New Jersey 08809 Tatnall Buildings
Wilmington, DE 19810
GENERAL ELECTRIC COMPANY DIRECT - EMAIL ONLY
3135 Easton Turnpike Julie Klusza, Esq.
Fairfield, Connecticut 06432 Electric Insurance Company
75 Sam Fonzo Drive
Beverly, Massachusetts 01915-1000
GOULDS PUMPS, INC. DIRECT
ITT-Goulds Pumps Headquarters
240 Fall Street
Seneca Falls, NY 13148
GRINNELL CORPORATION DIRECT - CERTIFIED MAIL RRR
3 Tyco Park Brady Edwards, Esq.
Exeter, New Hampshire 03833 Morgan, Lewis & Bockius LLP
1000 Louisiana St.,Suite 4200
Houston, Texas 77002-5006
H.B. SMITH CO., INC. Certified MaiL RRR
The H. B. Smith Company, Inc. c/o Peter Stasz, Esq.
61 Union Street,Suite 201 The H. B. Smith Company, Inc.
Westfield, Massachusetts 01085 61 Union Street, Suite 201
Westfield, Massachusetts 01085
- 7 -
7 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
H.C. OSWALD SUPPLY CO., INC. DIRECT
725 Whittier Street
Bronx, New York 10474
HONEYWELL INTERNATIONAL, INC., Indkidually and c/o Corporation Service Company
f/k/a Alliedsignal, Inc., and as Successor-in-interest to the 80 State Street
Bendix Corp. Albany, New York 12207-2543
115 Tabor Road
Morris Plains, New Jersey 07950
I.T.T. INDUSTRIES, INC., Individually and as successor to DIRECT
Bell & Gossett
ITT Corporation
1133 Westchester Avenue
Suite N300
White Plains, New York 10604
INGERSOLL-RAND COMPANY DIRECT - CERTIFIED MAIL RRR
200 Chestnut Ridge Road Lisa M. Pascarella, Esq.
Woodcliff Lake, New Jersey 07675 Forman Perry Watkins Krutz & Tardy
328 Newman Springs Road
Red Bank, New Jersey 07701
INTERNATIONAL COMFORT PRODUCTS LLC, c/o Corporate Trust Systems
Individually and as Successor to Heil Heating and Cooling 28 Liberty Street
Lewisburg, Tennessee New York, New York
JENKINS BROS. Department of Financial Services
-AND-
Corporation Service Company
84 State Street
Boston, Massachusetts
-AND-
Liberty Mutual Insurance
175 Berkley Street
Boston, Massachusetts
- 8 -
8 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
KOHLER CO. DIRECT
Herbert V. Kohler, Jr. Marc S. Gaffrey, Esq.
444 Highland Drive Hoagland Longo Moran Dunst & Doukas
Kohler, Wisconsin 53044 40 Patterson Street
New Brunswick, New Jersey 08903
LENNOX INDUSTRIES, INC., Individually and as Corporation Service Company
Successor to Lennox Furnace Company and Ducane 80 State Street
2100 Lake Park Boulevard Albany, New York 12207-2543
Richardson, Texas 75080
METROPOLITAN LIFE INSURANCE CO. DIRECT
200 Park Avenue
New York, New York 10166
N & S SUPPLY OF FISHKILL, INC. c/o Secretary of State
205 Old Route 9 Albany, New York 12207
Fishkill, New York 12524
NASH ENGINEERING COMPANY (THE) c/o Secretary of State
9 Trefoil Drive Albany, New York 12207
Trumbull, Connecticut 06611
NEW YORKER BOILER COMPANY, INC. DIRECT
1175 Manheim Pike
Lancaster, PA 17601
PECORA CORPORATION, IndividnâIly and as Successor to DIRECT
Pecora Corporation, New Pecora Corperâtión, and New
Pecora Corporation, Inc.
165 Wambold Road
Harleysville, Pennsylvania 19438
PEERLESS INC. DIRECT - CERTIFIED MAIL RRR
INDUSTRIES,
2300 White Oak Circle Ariana J. Seidel, Esq.
Aurora, Illinois 60502 DELANY MCBRIDE, P.C.
Attention: John Logerquist 36 Euclid Street
Woodbury, NJ 08096
PENNCO INC. DIRECT
c/o ECR International, Inc.
2201 Dwyer Avenue
Utica, New York 13504
- 9 -
9 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
RHEEM MANUFACTURING COMPANY, INC. Registered Agent:
1100 Abernathy Road, Suite 1700 Corporation Service Company
Atlanta, GA 30328 40 Technology Parkway South, Suite 300
Norcross, GA 30092
RILEY POWER, INC. f/k/a Babcock Borsig Power, Inc. and c/o Corporate Trust Systems
f/k/aRiley-Stoker Carparation d/b/a DB Riley, Inc. 28 Liberty Street
Thomas F Barile New York, New York
5 Neponset Street
Worcester, Massachusetts 01606
ROCKWELL AUTOMATION, INC., Individually and as c/o Corporate Trust Systems
Successor to Allen Bradley, Timken Business and S. 28 Liberty Street
Heating
Co., Inc. f/k/a Scaife Campañy, as Successor in Interest to New York, New York
Rockwell Spring & Axle Company's Timken Silent
Automatic Division
Allen-Bradley & Rockwell Software Brands
1201 South Second Street
Milwaukee, Wisconsin 53204-2496
SID HARVEY INDUSTRIES, INC. c/o Secretary of State
605 Locust Street Albany, New York 12207
Garden City, New York 11530-6597
SID HARVEY SUPPLY, INC. c/o Secretary of State
Albany, New York 12207
SPENCE ENGINEERING COMPANY, INC. c/o Secretary of State
150 Coldenham Road Albany, New York 12207
Walden, New York 12586
SPENCER HEATER, a Lycoming division of AVCO DIRECT
Corporation
AVCO Corporation
201 Lowell Street
Wilmington, MA 01887
TACO, INC. Corporation Service Company
1160 Cranston Street 50 Weston Street
Cranston, Rhode Island 02920 Hartford, CT 06120
- 10 -
10 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
DEFENDANTS SERVICE
TEXACO, INC. c/o The Prentice Hall Corp. Systems
2000 Westchester Avenue 80 State Street
White Plains, New York Albany, New York 12207
UNION CARBIDE CORPORATION c/o Corporate Trust Systems
28 Liberty Street
New York, New York
WARREN PUMPS LLC, Individually and as Successor to c/o The Corporation Trust Company
The Quimby Pump Cc,mpany 1209 North Orange Street
82 Bridges Avenue Wilmington, Delaware 19801
Warren, Massachusetts 01083-0969
WEIL McLAIN, A Division of Marley-Wylain Company DIRECT
500 Blaine Street
Michigan City, Indiana 46360-2388
WILLIAM POWELL COMPANY (THE) DIRECT
2503 Spring Grove Avenue
Cincinnati, Ohio 45214
YORK INTERNATIONAL CORPORATION, Individ-ally c/o CT Corporation System
and as Successor to Frick Company 301 S. Bedford St. Suite 1
5757 N. Green Bay Avenue Madison, WI 53703
PO Box 591
Milwaukee, Wisconsin 53201
- 11 -
11 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Index No. :
PANTELIS KAMMAS and KLEO KAMMAS,
VERIFIED COMPLAINT
Plaintiffs,
- against -
A.O. SMITH WATER PRODUCTS;
AII ACQUISITION CORPORATION, LLC,
Individually and as Successor-in-Interest to
Athlone Industries, Inc. and Holland Furnace
Company;
AMERICAN INTERNATIONAL INDUSTRIES,
INC.;
ARMSTRONG INTERNATIONAL, INC.;
ATWOOD & MORRILL CO., INC. d/b/a Weir Valves
& Controls USA Inc.;
AURORA PUMP COMPANY;
BURNHAM CORPORATION;
CARRIER CORPORATION;
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;
CERTAIN-TEED CORPORATION;
CLEAVER BROOKS COMPANY f/k/a Aqua Chem,
Inc.;
COLUMBIA BOILER COMPANY OF
POTTSTOWN;
COMPUDYNE CORPORATION, Individually and as
Successor to York-Shipley;
CRANE CO.;
CROWN BOILER CO.;
ECR INTERNATIONAL, INC., Individually and as
Successor to Dunkirk, Dunkirk Boilers and
Utica Boilers and Pennco, Inc.;
FLOWSERVE US, INC., solely as Successor to
Rockwell Manufacturing Company, Edward
Valves, Inc., Nordstrom Valves, Inc. and
Edward Vogt Valve Company;
FOSTER WHEELER, LLC;
GENERAL ELECTRIC COMPANY;
GOULDS PUMPS INC.;
GRINNELL CORPORATION;
H.B. SMITH CO., INC.;
- 12 -
12 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
H.C. OSWALD SUPPLY CO., INC.;
HONEYWELL INTERNATIONAL, INC.,
Individually and f/k/a AlliedSignal, Inc., and as
Successor-in-Interest to The Bendix Corp.;
I.T.T. INDUSTRIES, INC., Individually and as
successor to Bell & Gossett;
INTERNATIONAL COMFORT PRODUCTS LLC,
Individually and as Successor to Heil Heating
and Cooling;
JENKINS BROS.
KOHLER CO.;
LENNOX INDUSTRIES, INC., Individually and as
Successor to Lennox Furnace Company and
Ducane;
METROPOLITAN LIFE INSURANCE COMPANY;
N & S SUPPLY OF FISHKILL, INC.;
NASH ENGINEERING COMPANY (THE);
NEW YORKER BOILER COMPANY, INC.;
PECORA CORPORATION, Individually and as
Successor to Pecora Corporation, New
Pecora Corporation, and New Pecora
Corporation, Inc.;
PEERLESS INDUSTRIES, INC;
PENNCO, INC.;
RHEEM MANUFACTURING COMPANY, INC.;
RILEY POWER, INC. f/k/a Babcock Borsig Power,
Inc. and f/k/a Riley Stoker Corporation d/b/a
DB Riley, Inc.;
ROCKWELL AUTOMATION INC., Individually
and as Successor to Timken Heating Business
and S. Co., Inc. f/k/a Scaife Company, as
Successor in Interest to Rockwell Spring &
Axle Company's Timken Silent Automatic
Division;
SID HARVEY INDUSTRIES, INC.;
SID HARVEY SUPPLY, INC.;
SPENCE ENGINEERING COMPANY, INC.;
SPENCER HEATER, a Lycoming division of AVCO
Corporation;
TACO, INC.;
TEXACO, INC.;
UNION CARBIDE CORPORATION;
WARREN PUMPS, LLC, Individually and as
Successor to The Quimby Pump Company;
WEIL McLAIN, a division of Marley Wylain
Company;
- 13 -
13 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
WILLIAM POWELL COMPANY (THE);
YORK INTERNATIONAL CORPORATION,
Individually and as Successor to Frick
Company.
Defendants.
Plaintiffs by their attorneys BELLUCK & FOX LLP, upon information and belief, at all
times hereinafter mentioned allege as follows:
THE PARTIES
1. Plaintiffs are residents of the State of New York unless otherwise specified in
individual complaints.
2. Plaintiffs allege that plaintiff, PANTELIS KAMMAS has been diagnosed with
Lung Cancer as a result of his exposure to asbestos.
3. At this time, Plaintiffs are alleging that there is no Post 1980 exposure.
"Defendants"
4. The term shall apply to all corporate and business entities, and/or
their predecessors and/or successors in interest as more fully described and enumerated in the
form"
captions of individual complaints subsequently filed in the "short in accordance with the
applicable case management order of this Court.
5. The Defendants have done business in this State, have conducted or transacted
business in this State, have committed one or more tortious acts within this state, or have
otherwise performed acts within and/or without this State giving rise to injuries and losses within
this State, which acts subject each Defendant to the jurisdiction of the Courts of this State.
6. Defendant A.O. SMITH WATER PRODUCTS was and 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. At alltimes
- 14 -
14 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
relevant, it has engaged in the sale and distribution of materials and products containing the
substance asbestos.
7. Defendant AII ACQUISITION CORPORATION, LLC, Individually and as
Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company was and is
a duly organized foreign and/or domestic 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. At all times relevant, it has engaged in the sale and distribution of materials
and products containing the substance asbestos.
8. Defendant AMERICAN INTERNATIONAL INDUSTRIES, INC. was and is a
duly organized foreign and/or domestic 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. At all times relevant, it has engaged in the sale and distribution of materials
and products containing the substance asbestos.
9. Defendant ARMSTRONG INTERNATIONAL, INC. was and is a duly
organized domestic 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.
At all times relevant, it has engaged in the sale and distribution of materials and products
containing the substance asbestos.
10. Defendant ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls
USA Inc. was and is a duly organized foreign and/or domestic 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. At all times relevant, ithas engaged in the sale and
distribution of materials and products containing the substance asbestos.
- 15 -
15 of 54
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019
11. Defendant AURORA PUMP COMPANY was and is a duly organized foreign
and/or domestic 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. At all
times relevant, it has engaged in the sale and distribution of materials and products containing
the substance asbestos.
12. Defendant BURNHAM CORPORATION was and is a duly organized foreign
corporation doing business and/or transacting business in the State of New York and/or should
have expected itsacts to have consequences within the State of New York. At alltimes relevant,
Preview
FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK PANTELIS KAMMAS and KLEO KAMMAS, Date Filed: Plaintiffs, Plaintiff designates V. NEW YORK County as the place of trial A.O. SMITH WATER PRODUCTS, et al., The basis of the venue is Defendants. DEFENDANTS' PLACE OF BUSINESS See Attached Rider —FULL CAPTION SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a copy of your Answer, or, ifthe Complaint is not served with this Summons, to serve a Notice of Appearance, on the Plaintiff s Attorney 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). In the case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: New York, New York Yours etc., June 25, 2019 BELLUCK & FOX, LLP Attorneys for Plaintiff 546 Fifth Avenue, 5th Floor New York, New York 10036 (212) 681 1575 sq. 1 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. : PANTELIS KAMMAS and KLEO KAMMAS, FULL CAPTION RIDER Plaintiffs, - against - A.O. SMITH WATER PRODUCTS; AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company; AMERICAN INTERNATIONAL INDUSTRIES, INC.; ARMSTRONG INTERNATIONAL, INC.; ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc.; AURORA PUMP COMPANY; BURNHAM CORPORATION; CARRIER CORPORATION; 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; CERTAIN-TEED CORPORATION; CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc.; COLUMBIA BOILER COMPANY OF POTTSTOWN; COMPUDYNE CORPORATION, Individually and as Successor to York-Shipley; CRANE CO.; CROWN BOILER CO.; ECR INTERNATIONAL, INC., Individually and as Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Pennco, Inc.; FLOWSERVE US, INC., solely as Successor to Rockwell Manufacturing Company, Edward Valves, Inc., Nordstrom Valves, Inc. and Edward Vogt Valve Company; FOSTER WHEELER, LLC; GENERAL ELECTRIC COMPANY; GOULDS PUMPS INC.; GRINNELL CORPORATION; H.B. SMITH CO., INC.; - 2 - 2 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 H.C. OSWALD SUPPLY CO., INC.; HONEYWELL INTERNATIONAL, INC., Individually and f/k/a AlliedSignal, Inc., and as Successor-in-Interest to The Bendix Corp.; I.T.T. INDUSTRIES, INC., Individually and as successor to Bell & Gossett; INTERNATIONAL COMFORT PRODUCTS LLC, Individually and as Successor to Heil Heating and Cooling; JENK1NS BROS. KOHLER CO.; LENNOX INDUSTRIES, INC., Individually and as Successor to Lennox Furnace Company and Ducane; METROPOLITAN LIFE INSURANCE COMPANY; N & S SUPPLY OF FISHKILL, INC.; NASH ENGINEERING COMPANY (THE); NEW YORKER BOILER COMPANY, INC.; PECORA CORPORATION, Individually and as Successor to Pecora Corporation, New Pecora Corporation, and New Pecora Corporation, Inc.; PEERLESS INDUSTRIES, INC; PENNCO, INC.; RHEEM MANUFACTURING COMPANY, INC.; RILEY POWER, INC. f/k/a Babcock Borsig Power, Inc. and f/k/a Riley Stoker Corporation d/b/a DB Riley, Inc.; ROCKWELL AUTOMATION INC., Individually and as Successor to Timken Heating Business and S. Co., Inc. f/k/a Scaife Company, as Successor in Interest to Rockwell Spring & Axle Company's Timken Silent Automatic Division; SID HARVEY INDUSTRIES, INC.; SID HARVEY SUPPLY, INC.; SPENCE ENGINEERING COMPANY, INC.; SPENCER HEATER, a Lycoming division of AVCO Corporation; TACO, INC.; TEXACO, INC.; UNION CARBIDE CORPORATION; WARREN PUMPS, LLC, Individually and as Successor to The Quimby Pump Company; WEIL McLA1N, a division of Marley Wylain Company; - 3 - 3 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 WILLIAM POWELL COMPANY (THE); YORK INTERNATIONAL CORPORATION, Individually and as Successor to Frick Company. Defendants. - 4 - 4 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 Defendants' addresses: PANTELIS KAMMAS'S DEFENDANT ADDRESS LIST DEFENDANTS SERVICE A.O. SMITH WATER PRODUCTS DIRECT A.O. Smith Corporation Attn: Debra Schwanda APS INTERNATIONAL 11270 W. Park Place Milwaukee, WI 53224-9502 AH ACQUISITION CORPORATION, LLC, Individually DIRECT and as Successor-in-Intered to Athlone Industries, Inc. and Holland Furnace Company c/o Allegheny Technologies Incorporated 1000 Six PPG Place Pittsburgh, Pennsylvania 15222 AMERICAN INTERNATIONAL INDUSTRIES, INC. DIRECT 2220 Gaspar Avenue Commerce, California 90040 ARMSTRONG INTERNATIONAL, INC. DIRECT 900 Maple Street Three Rivers, Michigan 49093 ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & DIRECT Controls USA Inc. c/o Weir Valves & Controls Usa Inc. 29 Old Right Road Ipswich, Massachusetts 01938 AURORA PUMP COMPANY DIRECT - CERTIFIED MAIL RRR 800 Airport Road c/o Kevin Keyes North Aurora, Illinois60542 SPX Corporation 13320-A-A Ballantyne Corporate Place Charlotte, North Carolina 28277 BURNHAM CORPORATION c/o Secretary of State Albert Morrison III Albany, New York 1241 Harrisburg Pike Lancaster, Pennsylvania 17603 - 5 - 5 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE CARRIER CORPORATION c/o Corporate Trust Systems One Carrier Place 28 Liberty Street Farmington, Connecticut 06032-4015 New York, New York CBS CORPORATION, a Delaware Corporation, f/k/a c/o Corporation Service Company Viacom Inc, Successor by merger to CBS Corporation, a 80 State Street Pennsylvania Corporation, f/k/a Westiñghan::e Electric Albany, New York 12207 Corporation c/o Adrienne Harrington 52nd 51 West Street New York, New York 10019 CERTAIN-TEED CORPORATION c/o Corporate Trust Systems 750 East Swedesford Road 28 Liberty Street Valley Forge, Pennsylvania 19482 New York, New York CLEAVER-BROOKS COMPANY f/k/a Aqua-Chem, Inc. DIRECT Headquarters 221 Law Street Thomasville, GA 31792 COLUMBIA BOILER COMPANY OF POTTSTOWN DIRECT 390 Old Reading Pike Stowe, PA 19464 COMPUDYNE CORPORATION, Individually and as DIRECT Successor to York-Shipley CompuDyne Corporation CSC Services of Nevada, Inc. 2215-B Renaissance Drive Las Vegas, Nevada 89119 CRANE CO. c/o Corporate Trust Systems Robert S. Evans 28 Liberty Street 100 FirstStamford Place New York, New York Stamford, Connecticut 06902 CROWN BOILER CO. DIRECT 3633 I Street Philadelphia, Pennsylvania 19134 - 6 - 6 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE ECR INTERNATIONAL, INC., Individually and as c/o Secretary of State Successor to Dunkirk, Dunkirk Boilers and Utica Boilers Albany, New York 12207 2201 Dwyer Avenue Utica, New York 13504 FLOWSERVE US, INC., solely as Successor to Rockwell c/o Corporate Trust Systems Manufacturing Company, Edward Valves, Inc., Nordstrom 28 Liberty Street Valves, Inc. and Edward Vogt Valve Company New York, New York Flowserve Corporation General Counsel 5215 North O'Connor Blvd, Ste 2300 Irving, Texas 75039 FOSTER WHEELER, LLC Registered Agent: Perryville, Corporate Park United Agent Group, Inc. Route 173 atFrontage Road 3411 Silverside Road #104 Clinton, New Jersey 08809 Tatnall Buildings Wilmington, DE 19810 GENERAL ELECTRIC COMPANY DIRECT - EMAIL ONLY 3135 Easton Turnpike Julie Klusza, Esq. Fairfield, Connecticut 06432 Electric Insurance Company 75 Sam Fonzo Drive Beverly, Massachusetts 01915-1000 GOULDS PUMPS, INC. DIRECT ITT-Goulds Pumps Headquarters 240 Fall Street Seneca Falls, NY 13148 GRINNELL CORPORATION DIRECT - CERTIFIED MAIL RRR 3 Tyco Park Brady Edwards, Esq. Exeter, New Hampshire 03833 Morgan, Lewis & Bockius LLP 1000 Louisiana St.,Suite 4200 Houston, Texas 77002-5006 H.B. SMITH CO., INC. Certified MaiL RRR The H. B. Smith Company, Inc. c/o Peter Stasz, Esq. 61 Union Street,Suite 201 The H. B. Smith Company, Inc. Westfield, Massachusetts 01085 61 Union Street, Suite 201 Westfield, Massachusetts 01085 - 7 - 7 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE H.C. OSWALD SUPPLY CO., INC. DIRECT 725 Whittier Street Bronx, New York 10474 HONEYWELL INTERNATIONAL, INC., Indkidually and c/o Corporation Service Company f/k/a Alliedsignal, Inc., and as Successor-in-interest to the 80 State Street Bendix Corp. Albany, New York 12207-2543 115 Tabor Road Morris Plains, New Jersey 07950 I.T.T. INDUSTRIES, INC., Individually and as successor to DIRECT Bell & Gossett ITT Corporation 1133 Westchester Avenue Suite N300 White Plains, New York 10604 INGERSOLL-RAND COMPANY DIRECT - CERTIFIED MAIL RRR 200 Chestnut Ridge Road Lisa M. Pascarella, Esq. Woodcliff Lake, New Jersey 07675 Forman Perry Watkins Krutz & Tardy 328 Newman Springs Road Red Bank, New Jersey 07701 INTERNATIONAL COMFORT PRODUCTS LLC, c/o Corporate Trust Systems Individually and as Successor to Heil Heating and Cooling 28 Liberty Street Lewisburg, Tennessee New York, New York JENKINS BROS. Department of Financial Services -AND- Corporation Service Company 84 State Street Boston, Massachusetts -AND- Liberty Mutual Insurance 175 Berkley Street Boston, Massachusetts - 8 - 8 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE KOHLER CO. DIRECT Herbert V. Kohler, Jr. Marc S. Gaffrey, Esq. 444 Highland Drive Hoagland Longo Moran Dunst & Doukas Kohler, Wisconsin 53044 40 Patterson Street New Brunswick, New Jersey 08903 LENNOX INDUSTRIES, INC., Individually and as Corporation Service Company Successor to Lennox Furnace Company and Ducane 80 State Street 2100 Lake Park Boulevard Albany, New York 12207-2543 Richardson, Texas 75080 METROPOLITAN LIFE INSURANCE CO. DIRECT 200 Park Avenue New York, New York 10166 N & S SUPPLY OF FISHKILL, INC. c/o Secretary of State 205 Old Route 9 Albany, New York 12207 Fishkill, New York 12524 NASH ENGINEERING COMPANY (THE) c/o Secretary of State 9 Trefoil Drive Albany, New York 12207 Trumbull, Connecticut 06611 NEW YORKER BOILER COMPANY, INC. DIRECT 1175 Manheim Pike Lancaster, PA 17601 PECORA CORPORATION, IndividnâIly and as Successor to DIRECT Pecora Corporation, New Pecora Corperâtión, and New Pecora Corporation, Inc. 165 Wambold Road Harleysville, Pennsylvania 19438 PEERLESS INC. DIRECT - CERTIFIED MAIL RRR INDUSTRIES, 2300 White Oak Circle Ariana J. Seidel, Esq. Aurora, Illinois 60502 DELANY MCBRIDE, P.C. Attention: John Logerquist 36 Euclid Street Woodbury, NJ 08096 PENNCO INC. DIRECT c/o ECR International, Inc. 2201 Dwyer Avenue Utica, New York 13504 - 9 - 9 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE RHEEM MANUFACTURING COMPANY, INC. Registered Agent: 1100 Abernathy Road, Suite 1700 Corporation Service Company Atlanta, GA 30328 40 Technology Parkway South, Suite 300 Norcross, GA 30092 RILEY POWER, INC. f/k/a Babcock Borsig Power, Inc. and c/o Corporate Trust Systems f/k/aRiley-Stoker Carparation d/b/a DB Riley, Inc. 28 Liberty Street Thomas F Barile New York, New York 5 Neponset Street Worcester, Massachusetts 01606 ROCKWELL AUTOMATION, INC., Individually and as c/o Corporate Trust Systems Successor to Allen Bradley, Timken Business and S. 28 Liberty Street Heating Co., Inc. f/k/a Scaife Campañy, as Successor in Interest to New York, New York Rockwell Spring & Axle Company's Timken Silent Automatic Division Allen-Bradley & Rockwell Software Brands 1201 South Second Street Milwaukee, Wisconsin 53204-2496 SID HARVEY INDUSTRIES, INC. c/o Secretary of State 605 Locust Street Albany, New York 12207 Garden City, New York 11530-6597 SID HARVEY SUPPLY, INC. c/o Secretary of State Albany, New York 12207 SPENCE ENGINEERING COMPANY, INC. c/o Secretary of State 150 Coldenham Road Albany, New York 12207 Walden, New York 12586 SPENCER HEATER, a Lycoming division of AVCO DIRECT Corporation AVCO Corporation 201 Lowell Street Wilmington, MA 01887 TACO, INC. Corporation Service Company 1160 Cranston Street 50 Weston Street Cranston, Rhode Island 02920 Hartford, CT 06120 - 10 - 10 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 DEFENDANTS SERVICE TEXACO, INC. c/o The Prentice Hall Corp. Systems 2000 Westchester Avenue 80 State Street White Plains, New York Albany, New York 12207 UNION CARBIDE CORPORATION c/o Corporate Trust Systems 28 Liberty Street New York, New York WARREN PUMPS LLC, Individually and as Successor to c/o The Corporation Trust Company The Quimby Pump Cc,mpany 1209 North Orange Street 82 Bridges Avenue Wilmington, Delaware 19801 Warren, Massachusetts 01083-0969 WEIL McLAIN, A Division of Marley-Wylain Company DIRECT 500 Blaine Street Michigan City, Indiana 46360-2388 WILLIAM POWELL COMPANY (THE) DIRECT 2503 Spring Grove Avenue Cincinnati, Ohio 45214 YORK INTERNATIONAL CORPORATION, Individ-ally c/o CT Corporation System and as Successor to Frick Company 301 S. Bedford St. Suite 1 5757 N. Green Bay Avenue Madison, WI 53703 PO Box 591 Milwaukee, Wisconsin 53201 - 11 - 11 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. : PANTELIS KAMMAS and KLEO KAMMAS, VERIFIED COMPLAINT Plaintiffs, - against - A.O. SMITH WATER PRODUCTS; AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company; AMERICAN INTERNATIONAL INDUSTRIES, INC.; ARMSTRONG INTERNATIONAL, INC.; ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc.; AURORA PUMP COMPANY; BURNHAM CORPORATION; CARRIER CORPORATION; 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; CERTAIN-TEED CORPORATION; CLEAVER BROOKS COMPANY f/k/a Aqua Chem, Inc.; COLUMBIA BOILER COMPANY OF POTTSTOWN; COMPUDYNE CORPORATION, Individually and as Successor to York-Shipley; CRANE CO.; CROWN BOILER CO.; ECR INTERNATIONAL, INC., Individually and as Successor to Dunkirk, Dunkirk Boilers and Utica Boilers and Pennco, Inc.; FLOWSERVE US, INC., solely as Successor to Rockwell Manufacturing Company, Edward Valves, Inc., Nordstrom Valves, Inc. and Edward Vogt Valve Company; FOSTER WHEELER, LLC; GENERAL ELECTRIC COMPANY; GOULDS PUMPS INC.; GRINNELL CORPORATION; H.B. SMITH CO., INC.; - 12 - 12 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 H.C. OSWALD SUPPLY CO., INC.; HONEYWELL INTERNATIONAL, INC., Individually and f/k/a AlliedSignal, Inc., and as Successor-in-Interest to The Bendix Corp.; I.T.T. INDUSTRIES, INC., Individually and as successor to Bell & Gossett; INTERNATIONAL COMFORT PRODUCTS LLC, Individually and as Successor to Heil Heating and Cooling; JENKINS BROS. KOHLER CO.; LENNOX INDUSTRIES, INC., Individually and as Successor to Lennox Furnace Company and Ducane; METROPOLITAN LIFE INSURANCE COMPANY; N & S SUPPLY OF FISHKILL, INC.; NASH ENGINEERING COMPANY (THE); NEW YORKER BOILER COMPANY, INC.; PECORA CORPORATION, Individually and as Successor to Pecora Corporation, New Pecora Corporation, and New Pecora Corporation, Inc.; PEERLESS INDUSTRIES, INC; PENNCO, INC.; RHEEM MANUFACTURING COMPANY, INC.; RILEY POWER, INC. f/k/a Babcock Borsig Power, Inc. and f/k/a Riley Stoker Corporation d/b/a DB Riley, Inc.; ROCKWELL AUTOMATION INC., Individually and as Successor to Timken Heating Business and S. Co., Inc. f/k/a Scaife Company, as Successor in Interest to Rockwell Spring & Axle Company's Timken Silent Automatic Division; SID HARVEY INDUSTRIES, INC.; SID HARVEY SUPPLY, INC.; SPENCE ENGINEERING COMPANY, INC.; SPENCER HEATER, a Lycoming division of AVCO Corporation; TACO, INC.; TEXACO, INC.; UNION CARBIDE CORPORATION; WARREN PUMPS, LLC, Individually and as Successor to The Quimby Pump Company; WEIL McLAIN, a division of Marley Wylain Company; - 13 - 13 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 WILLIAM POWELL COMPANY (THE); YORK INTERNATIONAL CORPORATION, Individually and as Successor to Frick Company. Defendants. Plaintiffs by their attorneys BELLUCK & FOX LLP, upon information and belief, at all times hereinafter mentioned allege as follows: THE PARTIES 1. Plaintiffs are residents of the State of New York unless otherwise specified in individual complaints. 2. Plaintiffs allege that plaintiff, PANTELIS KAMMAS has been diagnosed with Lung Cancer as a result of his exposure to asbestos. 3. At this time, Plaintiffs are alleging that there is no Post 1980 exposure. "Defendants" 4. The term shall apply to all corporate and business entities, and/or their predecessors and/or successors in interest as more fully described and enumerated in the form" captions of individual complaints subsequently filed in the "short in accordance with the applicable case management order of this Court. 5. The Defendants have done business in this State, have conducted or transacted business in this State, have committed one or more tortious acts within this state, or have otherwise performed acts within and/or without this State giving rise to injuries and losses within this State, which acts subject each Defendant to the jurisdiction of the Courts of this State. 6. Defendant A.O. SMITH WATER PRODUCTS was and 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. At alltimes - 14 - 14 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 7. Defendant AII ACQUISITION CORPORATION, LLC, Individually and as Successor-in-Interest to Athlone Industries, Inc. and Holland Furnace Company was and is a duly organized foreign and/or domestic 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. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 8. Defendant AMERICAN INTERNATIONAL INDUSTRIES, INC. was and is a duly organized foreign and/or domestic 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. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 9. Defendant ARMSTRONG INTERNATIONAL, INC. was and is a duly organized domestic 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. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 10. Defendant ATWOOD & MORRILL CO., INC. d/b/a Weir Valves & Controls USA Inc. was and is a duly organized foreign and/or domestic 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. At all times relevant, ithas engaged in the sale and distribution of materials and products containing the substance asbestos. - 15 - 15 of 54 FILED: NEW YORK COUNTY CLERK 06/25/2019 02:55 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/25/2019 11. Defendant AURORA PUMP COMPANY was and is a duly organized foreign and/or domestic 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. At all times relevant, it has engaged in the sale and distribution of materials and products containing the substance asbestos. 12. Defendant BURNHAM CORPORATION was and is a duly organized foreign corporation doing business and/or transacting business in the State of New York and/or should have expected itsacts to have consequences within the State of New York. At alltimes relevant,