On June 25, 2019 a Answer was filed involving a dispute between Kleo Kammas, Pantelis Kammas, and Aii Acquisition Corporation, Llc, Individually And As Successor-In-Interest To Athlone Industries, Inc. And Holland Furnace Company, American International Industries, Inc., A.O. Smith Water Products, 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, 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., 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., International Comfort Products Llc, Individually And As Successor To Heil Heating And Cooling, I.T.T. Industries, Inc., Individually And As Successor To Bell & Gossett, Jenkins Bros., J.H. France Refractories Company, Individually And As Successor To Greenpoint Firebrick, Kohler Co., Lennox Industries, Inc., Individually And As Successor To Lennox Furnace Company And Ducane, Metropolitan Life Insurance Co., Nash Engineering Company, New Yorker Boiler Company, Inc., N & S Supply Of Fishkill, 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 Allen Bradley, 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, William Powell Company, York International Corporation, Individually And As Successor To Frick Company, for Torts - Asbestos in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 08/14/2019 04:45 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/14/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK PANTELIS KAMMAS AND KLEO Index No.: 190153/2019 KAMMAS, Plaintiffs ' VERIFIED ANSWER TO - - FIRST AMENDED VERIFIED against COMPLAINT A.O. SMITH WATER PRODUCTS, et al., Defendants. Defendant A.O. SMITH WATER PRODUCTS COMPANY, (herein after "A.O. SMITH" or "Defendant") by its attorneys Eckert Seamans Cherin & Mellott, LLC answering the Plaintiffs' First Amended Verified Complaint upon information and belief, alleges as follows: Defendant A.O. SMITH, herein repeats, reiterates and re-alleges each and every answer Plaintiffs' and affirmative defense set forth in Defendants Answer to the Initial Complaint dated June 25, 2019, with the same force and effect as if fully set forth at length herein in responding to Plaintiffs' the allegations set forth in the First Amended Verified Complaint. Plaintiffs' Defendant A.O. SMITH in the First Amended Verified Complaint in the third Paragraph in the First Amended Verified Complaint the contains no factual allegations to which a response would be required. To the extent in the third Paragraph in the First Amended Verified Complaint could be interpreted as an allegation that A.O. SMITH is responsible for any products or services as a predecessor and/or successor-in-interest to any another party to this case, A.O. SMITH denies the allegations contained in the third Paragraph of the First Amended Verified Complaint. {solo5827.1} 1 of 5 FILED: NEW YORK COUNTY CLERK 08/14/2019 04:45 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/14/2019 Daf-dant SMITH judgment WHEREFORE, A.O. requests in its Plaintiffs' First Amended Verified Complant against it together with the costs of this action and for any expenses incurred in the defense thereof, including attorneys' fees. FURTHERMORE, Defendant A.O. SMITH d-ands judgment over daS=dssts on its cross-claim for the amount of any judgmcñt or verdict which herein the Plaintiffs against this defr=d=st together with costs and disbursements by attorneys' plus any and all fees, costs of investigation and disbursements. Dated: WHITE PLAINS, NEW YORK August 14, 2019 Yours, etc. ECKERT SEAMANS CHERIN & MELL Attorneys for Defendant A.O. SMITH WATER PRODUCTS COM By: LAURA B. HOLLMAN, ESQ. 10 Bank Street, Suite 700 White Plains, New York 10606 (914) 949-2909 2 of 5 FILED: NEW YORK COUNTY CLERK 08/14/2019 04:45 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/14/2019 CERTIFICATION OF SERVICE I HEREBY CERTIFY that on the 14 day of August, 2019, a copy of the foregoing Answer A. O. Smith Water Products Company to Plaintiffs First Amended Summons and First Amended Verified Complaint was filed electronically this day and is available viewing from the Court's NYSCEF system. Notice of this filing will be sent to all counsel of record via the court's NYSCEF system. Marilyn Mercado MARILYN MERCADO {solo5827.1} 3 3 of 5 FILED: NEW YORK COUNTY CLERK 08/14/2019 04:45 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/14/2019 ATTORNEY'S VERIFICATION STATE OF NEW YORK ) : ss.: COUNTY OF WESTCHESTER ) LAURA B. HOLLMAN, ESQ., being duly sworn, deposes and says that with the law firm of Eckert Seamans Cherin & Mellott LLC, that I have Verified Answer by A.O. SMITH and knows the contents thereof, and that the own knowledge, except as to matters therein stated to be alleged upon information that as to those matters, I believe them to be true. The sources of my informa conversations with agents of the def--=d==t The reason this verification is made not defendant is because defendant does not reside within the wher by County have an office. Dated: WHITE PLAINS, NEW YORK August 14, 2019 LAURA B. HOLLMAN, 4 of 5 FILED: NEW YORK COUNTY CLERK 08/14/2019 04:45 PM INDEX NO. 190153/2019 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 08/14/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK PANTELIS KAMMAS AND KLEO KAMMAS, Index No.: 190153/2019 Plaintiffs', - against - A.O. SMITH WATER PRODUCTS, et al., Defendants. VERIFIED ANSWER TO FIRST AMENDED SUMMONS AND FIRST AMENDED COMPLAINT Attorneys for Defendant: A.O. SMITH WATER PRODUCTS COMPANY ECKERT SEAMANS CHERIN & MELLOTT, LLC 10 Bank Street, Suite 700 White Plains, New York 10606 (914) 949-2909 {solo5827.1} 5 5 of 5