On August 10, 2018 a DEMAND FOR: - Demand for Discovery on McKesson Corp. was filed involving a dispute between Sinar Seen Individually And As Administrator Of The Estate Of Munir Seen, Deceased, and 84 Lumber Company, Aerco International, Inc., Algoma Hardwoods, Inc., Benjamin Moore & Company, Bmce Inc., In Itself And As Successor To United Centrifugal Pump Co., 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, Conwed Corporation, Crane Co., Dap, Inc. N K A La Mirada Products, Inc., Foster Wheeler Energy Corporation, General Electric Company, Industrial Holdings Corporation F K A The Carborundum Company, Ingersoll-Rand Company, Ipa Systems, Inc., John Crane Inc., John Doe 1 Through John Doe 75, Kaiser Gypsum Company, Inc., Kelly Moore Paint Company Inc., Mario & Dibono Fireproofing Corp., Mario & Dibono Plastering Co. Inc., Mckesson Corporation, Metropolitan Life Insurance Company, Pfizer, Inc., Sherwin-Williams Automotive Finishes Corporation, Simpson Timber Company, Tishman Construction Company, Turner Construction Company, Union Carbide Corporation, U.S. Plywood A K A International Paper Company, Weyerhaeuser Company, for Torts - Asbestos in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 09/09/2019 04:17 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 273 RECEIVED NYSCEF: 09/09/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK IN RE: NEW YORK COUNTY ASBESTOS LITIGATION MUNIR SEEN, Plaintiff, -against- Index No.: 190225/2018 84 LUMBER COMPANY, et al., DEMAND FOR DISCOVERY Defendants. IPA SYSTEMS, INC., Third-Party Plaintiff, -against- KAISER GYPSUM COMPANY, INC., Third-Party Defendant. PLEASE TAKE NOTICE, that defendant, IPA SYSTEMS INC., hereby demands that defendant MCKESSON CORPORATION (McKesson), within twenty (20) days of the date of this demand, and pursuant to the Civil Practice Law and Rules, serve on the undersigned the following: 1. Complete and certified New York City Asbestos Litigation (“NYCAL”) Interrogatories prepared by McKesson, or in the event that no NYCAL Interrogatories exist, any complete and certified McKesson Interrogatories, including but not limited to those served on Plaintiff in this matter; 2. A NYCAL deposition transcript taken of a McKesson corporate representative, or in the event that no NYCAL deposition has been conducted, a deposition transcript from a McKesson corporate representative from any jurisdiction. {N0908541-1} 1 of 2 FILED: NEW YORK COUNTY CLERK 09/09/2019 04:17 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 273 RECEIVED NYSCEF: 09/09/2019 PLEASE TAKE NOTICE, that the foregoing is a continuing demand, and, that if any of the above items are obtained after the return date of this demand, they are to be furnished to McGIVNEY, KLUGER, & COOK P.C., pursuant to these demands. Dated: New York, New York September 9, 2019 Respectfully submitted, _______________________ Nicholas P Iannuzzi, Esq. Attorney for Defendant IPA SYSTEMS INC. MCGIVNEY & KLUGER, P.C. 80 Broad Street – 23rd Floor New York, New York 10004 (212) 509-3456 TO: David Schaffer, Esq. Malaby & Bradley LLC Attorney for Defendant MCKESSON CORPORATION 150 Broadway, # 600 New York, NY 10038 {N0908541-1} 2 of 2