Preview
FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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KEVIN K. MALONEY,
Date Filed:
Plaintiff(s), Plaintiff Designates
NEW YORK
-against- as the Place of Trial
County
AMCHEM PRODUCTS, INC., The Basis of Venue is
Defendants'
n/lda RHONE POULENC AG COMPANY, Place of Business
n/lda BAYER CROPSCIENCE INC.,
ARMSTRONG PUMPS, INC.,
BURNHAM, LLC, SUMMONS
Individually, and as successor to
BURNHAM CORPORATION,
CBS CORPORATION, f/k/a VIACOM INC.,
successor by merger to
CBS CORPORATION, f/k/a
WESTINGHOUSE ELECTRIC CORPORATION,
CRANE CO.
Individually and as Successor to PACIFIC VALVES,
FLOWSERVE US, INC.
Solely as Successor to Rockwell Manufacturing Company,
Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt
Valve Company, and Vogt Valve Company,
GENERAL ELECTRIC COMPANY,
GOULDS PUMPS LLC,
HONEYWELL INTERNATIONAL, INC.,
f/k/a ALLIED SIGNAL, INC. / BENDIX,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
OWENS-ILLINOIS, INC.,
PEERLESS INDUSTRIES, INC.,
PFIZER, INC. (PFIZER),
U.S. RUBBER COMPANY (UNIROYAL),
UNION CARBIDE CORPORATION,
WEIL-MCLAIN, a division of The Marley-Wylain Company,
a wholly owned subsidiary of The Marley Company, LLC,
Defendants.
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To the above named Defendant(s)
You are hereby summoned to answer the 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,
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exclusive of the day of service (or within 30 days after the service is complete if thissummons 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, May 01, 2018
New York, New York
WEITZ & LUXENBERG, P.C.
Defendant's address: Attorney(s) for Plaintiff
Post Office Address
SEE ATTACHED DEFENDANTS RIDER 700 Broadway
New York, New York 10003
(212) 558-5500
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DEFENDANTS'
RIDER
AMCHEM PRODUCTS, INC.,
n/k/a RHONE POULENC AG COMPANY,
n/k/a BAYER CROPSCIENCE INC.
99 Washington Ave
Albany, NY 12207
ARMSTRONG PUMPS, INC.
93 East Avenue
North Tonawanda, NY 14120
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION
1239 Harrisburg Pike
Lancaster, PA 17603
CBS CORPORATION, f/k/a VIACOM INC.,
successor by merger to
CBS CORPORATION, f/k/a
WESTINGHOUSE ELECTRIC CORPORATION
Asbestos Litigation Support Manager
ECKERT SEAMANS CHERIN & MELLOTT, LLC
Case Management & Technology Center
USX Towers
600 Grant Street
Pittsburgh, PA 15219
CRANE CO.
Individually and as Successor to PACIFIC VALVES
100 First Stamford Place
Stamford, CT 06902
FLOWSERVE US, INC.
Solely as Successor to Rockwell Manufacturing Company,
Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt
Valve Company, and Vogt Valve Company
c/o Corporate Trust Systems
1999 Bryan Street, Suite 900
Dallas, TX 75201
GENERAL ELECTRIC COMPANY
Electric Insurance Company
75 Sam Fonzo Drive
Beverly, MA 01915
GOULDS PUMPS LLC
CT Corporation System
111 Eighth Avenue
New York, NY 10011
1QQ11
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HONEYWELL INTERNATIONAL, INC.,
f/k/a ALLIED SIGNAL, INC. / BENDIX
115 Tabor Road
Morris Plains, NJ 07950
ITT LLC.,
Individually and as successor to BELL 4 GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.
1133 Westchester Avenue
White Plains, NY 10605
OWENS-ILLINOIS, INC.
One Michael Owens Way
Perrysburg, OH 43551
PEERLESS INDUSTRIES, INC.
c/o Ariana J. Seidel, Esq.
Delany McBride, P.C.
1500 JFK Blvd., Suite 415
Philadelphia, PA 19102
PFIZER, INC. (PFIZER)
CT Corporation Systems
111 8th Avenue
New York, NY 10011
U.S. RUBBER COMPANY (UNIROYAL)
Greenfield, Stein & Senior
(Agent for Service of Process)
600 Third Avenue, 11th Floor
New York, NY 10016-1903
UNION CARBIDE CORPORATION
CT Corporation Systems
111 8th Avenue
New York, NY 10011
WEIL-MCLAIN, a division of The Marley-Wylain Company,
a wholly owned subsidiary of The Marley Company, LLC
13320 Ballantyne Corporate Place
Charlotte, NC 28277
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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KEVIN K. MALONEY,
Date Filed:
Plaintiff(s),
-against- VERIFIED
COMPLAINT
AMCHEM PRODUCTS, INC.,
n/lda RHONE POULENC AG COMPANY, PLAINTIFF DEMANDS
n/lda BAYER CROPSCIENCE INC., TRIAL BY JURY
ARMSTRONG PUMPS, INC.,
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION,
CBS CORPORATION, f/lda VIACOM INC.,
successor by merger to
CBS CORPORATION, f/lda
WESTINGHOUSE ELECTRIC CORPORATION,
CRANE CO.
Individually and as Successor to PACIFIC VALVES,
FLOWSERVE US, INC.
Solely as Successor to Rockwell Manufacturing Company,
Edward Valve, Inc.,Nordstrom Valves, Inc., Edward Vogt
Valve Company, and Vogt Valve Company,
GENERAL ELECTRIC COMPANY,
GOULDS PUMPS LLC,
HONEYWELL INTERNATIONAL, INC.,
f/lda ALLIED SIGNAL, INC. / BENDIX,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
OWENS-ILLINOIS, INC.,
PEERLESS INDUSTRIES, INC.,
PFIZER, INC. (PFIZER),
U.S. RUBBER COMPANY (UNIROYAL),
UNION CARBIDE CORPORATION,
WEIL-MCLAIN, a division of The Marley-Wylain Company,
a wholly owned subsidiary of The Marley Company, LLC,
Defendants.
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Plaintiff(s), KEVIN K. MALONEY, by their attorneys WEITZ &
LUXENBERG, P.C., upon information and belief, at alltimes hereinafter mentioned alleges as
follows:
1. Plaintiff(s), KEVIN K. MALONEY, by their attorneys, WEITZ &
LUXENBERG, P.C., for their verified complaint respectfully alleges:
2. Defendant ARMSTRONG PUMPS, INC., was and stillis a duly
organized domestic corporation doing business in the State of New York.
3. Defendant ARMSTRONG PUMPS, INC., was and stillis 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.
4. Defendant CRANE CO. Individually and as Successor to PACIFIC
VALVES, was and stillis a duly organized domestic corporation doing business in the State of
New York.
5. 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 stillis a duly organized domestic corporation
doing business in the State of New York.
6. Defendant ITT LLC, Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., was and stillis a duly
organized domestic corporation doing business in the State of New York.
KEVIN K. repeats and realleges NYCAL - WEITZ &
Plaintiff(s), MALONEY,
LUXENBERG, P.C. STANDARD ASBESTOS COMPLAINT FOR PERSONAL INJURY No.
7 as if fully incorporated herein as it pertains to the defendants in the aforementioned caption.
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Dated: May 01, 2018
New York, New York
Yours, etc.,
WEITZ & LUXENBERG, P.C
.
Attorneys for Plaintiff(s)
700 Broadway
New York, NY 10003
(212) 558-5500
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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 Associate of the firm WEITZ & LUXENBERG, P.C., Counsel for the
plaintiff(s) in the within action; deponent has read the foregoing 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 itto be true. This verification is made by deponent and not by
plaintiffs'
plaintiff(s) because plaintiff(s) resides outside of the County of New York where
counsel and deponent maintain their office.
Dated: May 01, 2018
New York, New York
/S/
LIND SAY DECICCO
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Index No.:
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
====================================================================================
KEVIN K. MALONEY,
Plaintiff(s),
-against-
AMCHEM PRODUCTS, INC.,
n/lda RHONE POULENC AG COMPANY,
n/lda BAYER CROPSCIENCE INC., et. al.,
Defendants.
====================================================================================
SUMMONS and COMPLAINT
====================================================================================
WEITZ & LUXENBERG, P.C.
Attorneys for PLAINTIFFS
700 Broadway
New York, NY 10003
212-558-5500
====================================================================================
To
Attorney(s) for
====================================================================================
Service of a copy of the within
is hereby admitted.
Dated, May 01, 2018
..............................................................................................................................................
Attorney(s) for
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------------------X
KEVIN K. MALONEY,
Plaintiff(s), FULL CAPTION
RIDER
-against-
AMCHEM PRODUCTS, INC.,
n/lda RHONE POULENC AG COMPANY,
n/lda BAYER CROPSCIENCE INC.,
ARMSTRONG PUMPS, INC.,
BURNHAM, LLC,
Individually, and as successor to
BURNHAM CORPORATION,
CBS CORPORATION, f/k/a VIACOM INC.,
successor by merger to
CBS CORPORATION, f/k/a
WESTINGHOUSE ELECTRIC CORPORATION,
CRANE CO.
Individually and as Successor to PACIFIC VALVES,
FLOWSERVE US, INC.
Solely as Successor to Rockwell Manufacturing Company,
Edward Valve, Inc.,Nordstrom Valves, Inc., Edward Vogt
Valve Company, and Vogt Valve Company,
GENERAL ELECTRIC COMPANY,
GOULDS PUMPS LLC,
HONEYWELL INTERNATIONAL, INC.,
f/k/a ALLIED SIGNAL, INC. / BENDIX,
ITT LLC.,
Individually and as successor to BELL & GOSSETT
and as successor to KENNEDY VALVE
MANUFACTURING CO., Inc.,
OWENS-ILLINOIS, INC.,
PEERLESS INDUSTRIES, INC.,
PFIZER, INC. (PFIZER),
U.S. RUBBER COMPANY (UNIROYAL),
UNION CARBIDE CORPORATION,
WEIL-MCLAIN, a division of The Marley-Wylain Company,
a wholly owned subsidiary of The Marley Company, LLC,
Defendants.
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Preview
FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X -----------------------------------------------------------------------------X Index No.: KEVIN K. MALONEY, Date Filed: Plaintiff(s), Plaintiff Designates NEW YORK -against- as the Place of Trial County AMCHEM PRODUCTS, INC., The Basis of Venue is Defendants' n/lda RHONE POULENC AG COMPANY, Place of Business n/lda BAYER CROPSCIENCE INC., ARMSTRONG PUMPS, INC., BURNHAM, LLC, SUMMONS Individually, and as successor to BURNHAM CORPORATION, CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION, CRANE CO. Individually and as Successor to PACIFIC VALVES, FLOWSERVE US, INC. Solely as Successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, GENERAL ELECTRIC COMPANY, GOULDS PUMPS LLC, HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., OWENS-ILLINOIS, INC., PEERLESS INDUSTRIES, INC., PFIZER, INC. (PFIZER), U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, WEIL-MCLAIN, a division of The Marley-Wylain Company, a wholly owned subsidiary of The Marley Company, LLC, Defendants. X -----------------------------------------------------------------------------X To the above named Defendant(s) You are hereby summoned to answer the 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, 1 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 exclusive of the day of service (or within 30 days after the service is complete if thissummons 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, May 01, 2018 New York, New York WEITZ & LUXENBERG, P.C. Defendant's address: Attorney(s) for Plaintiff Post Office Address SEE ATTACHED DEFENDANTS RIDER 700 Broadway New York, New York 10003 (212) 558-5500 2 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 DEFENDANTS' RIDER AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC. 99 Washington Ave Albany, NY 12207 ARMSTRONG PUMPS, INC. 93 East Avenue North Tonawanda, NY 14120 BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION 1239 Harrisburg Pike Lancaster, PA 17603 CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION Asbestos Litigation Support Manager ECKERT SEAMANS CHERIN & MELLOTT, LLC Case Management & Technology Center USX Towers 600 Grant Street Pittsburgh, PA 15219 CRANE CO. Individually and as Successor to PACIFIC VALVES 100 First Stamford Place Stamford, CT 06902 FLOWSERVE US, INC. Solely as Successor to Rockwell Manufacturing Company, Edward Valve, Inc., Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company c/o Corporate Trust Systems 1999 Bryan Street, Suite 900 Dallas, TX 75201 GENERAL ELECTRIC COMPANY Electric Insurance Company 75 Sam Fonzo Drive Beverly, MA 01915 GOULDS PUMPS LLC CT Corporation System 111 Eighth Avenue New York, NY 10011 1QQ11 3 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX 115 Tabor Road Morris Plains, NJ 07950 ITT LLC., Individually and as successor to BELL 4 GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc. 1133 Westchester Avenue White Plains, NY 10605 OWENS-ILLINOIS, INC. One Michael Owens Way Perrysburg, OH 43551 PEERLESS INDUSTRIES, INC. c/o Ariana J. Seidel, Esq. Delany McBride, P.C. 1500 JFK Blvd., Suite 415 Philadelphia, PA 19102 PFIZER, INC. (PFIZER) CT Corporation Systems 111 8th Avenue New York, NY 10011 U.S. RUBBER COMPANY (UNIROYAL) Greenfield, Stein & Senior (Agent for Service of Process) 600 Third Avenue, 11th Floor New York, NY 10016-1903 UNION CARBIDE CORPORATION CT Corporation Systems 111 8th Avenue New York, NY 10011 WEIL-MCLAIN, a division of The Marley-Wylain Company, a wholly owned subsidiary of The Marley Company, LLC 13320 Ballantyne Corporate Place Charlotte, NC 28277 4 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X -----------------------------------------------------------------------------X Index No.: KEVIN K. MALONEY, Date Filed: Plaintiff(s), -against- VERIFIED COMPLAINT AMCHEM PRODUCTS, INC., n/lda RHONE POULENC AG COMPANY, PLAINTIFF DEMANDS n/lda BAYER CROPSCIENCE INC., TRIAL BY JURY ARMSTRONG PUMPS, INC., BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, CBS CORPORATION, f/lda VIACOM INC., successor by merger to CBS CORPORATION, f/lda WESTINGHOUSE ELECTRIC CORPORATION, CRANE CO. Individually and as Successor to PACIFIC VALVES, FLOWSERVE US, INC. Solely as Successor to Rockwell Manufacturing Company, Edward Valve, Inc.,Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, GENERAL ELECTRIC COMPANY, GOULDS PUMPS LLC, HONEYWELL INTERNATIONAL, INC., f/lda ALLIED SIGNAL, INC. / BENDIX, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., OWENS-ILLINOIS, INC., PEERLESS INDUSTRIES, INC., PFIZER, INC. (PFIZER), U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, WEIL-MCLAIN, a division of The Marley-Wylain Company, a wholly owned subsidiary of The Marley Company, LLC, Defendants. 5 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 Plaintiff(s), KEVIN K. MALONEY, by their attorneys WEITZ & LUXENBERG, P.C., upon information and belief, at alltimes hereinafter mentioned alleges as follows: 1. Plaintiff(s), KEVIN K. MALONEY, by their attorneys, WEITZ & LUXENBERG, P.C., for their verified complaint respectfully alleges: 2. Defendant ARMSTRONG PUMPS, INC., was and stillis a duly organized domestic corporation doing business in the State of New York. 3. Defendant ARMSTRONG PUMPS, INC., was and stillis 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. 4. Defendant CRANE CO. Individually and as Successor to PACIFIC VALVES, was and stillis a duly organized domestic corporation doing business in the State of New York. 5. 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 stillis a duly organized domestic corporation doing business in the State of New York. 6. Defendant ITT LLC, Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., was and stillis a duly organized domestic corporation doing business in the State of New York. KEVIN K. repeats and realleges NYCAL - WEITZ & Plaintiff(s), MALONEY, LUXENBERG, P.C. STANDARD ASBESTOS COMPLAINT FOR PERSONAL INJURY No. 7 as if fully incorporated herein as it pertains to the defendants in the aforementioned caption. 6 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 Dated: May 01, 2018 New York, New York Yours, etc., WEITZ & LUXENBERG, P.C . Attorneys for Plaintiff(s) 700 Broadway New York, NY 10003 (212) 558-5500 7 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 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 Associate of the firm WEITZ & LUXENBERG, P.C., Counsel for the plaintiff(s) in the within action; deponent has read the foregoing 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 itto be true. This verification is made by deponent and not by plaintiffs' plaintiff(s) because plaintiff(s) resides outside of the County of New York where counsel and deponent maintain their office. Dated: May 01, 2018 New York, New York /S/ LIND SAY DECICCO 8 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ==================================================================================== KEVIN K. MALONEY, Plaintiff(s), -against- AMCHEM PRODUCTS, INC., n/lda RHONE POULENC AG COMPANY, n/lda BAYER CROPSCIENCE INC., et. al., Defendants. ==================================================================================== SUMMONS and COMPLAINT ==================================================================================== WEITZ & LUXENBERG, P.C. Attorneys for PLAINTIFFS 700 Broadway New York, NY 10003 212-558-5500 ==================================================================================== To Attorney(s) for ==================================================================================== Service of a copy of the within is hereby admitted. Dated, May 01, 2018 .............................................................................................................................................. Attorney(s) for 9 of 10 FILED: NEW YORK COUNTY CLERK 05/01/2018 12:33 PM INDEX NO. 190142/2018 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/01/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------------X KEVIN K. MALONEY, Plaintiff(s), FULL CAPTION RIDER -against- AMCHEM PRODUCTS, INC., n/lda RHONE POULENC AG COMPANY, n/lda BAYER CROPSCIENCE INC., ARMSTRONG PUMPS, INC., BURNHAM, LLC, Individually, and as successor to BURNHAM CORPORATION, CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION, CRANE CO. Individually and as Successor to PACIFIC VALVES, FLOWSERVE US, INC. Solely as Successor to Rockwell Manufacturing Company, Edward Valve, Inc.,Nordstrom Valves, Inc., Edward Vogt Valve Company, and Vogt Valve Company, GENERAL ELECTRIC COMPANY, GOULDS PUMPS LLC, HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, ITT LLC., Individually and as successor to BELL & GOSSETT and as successor to KENNEDY VALVE MANUFACTURING CO., Inc., OWENS-ILLINOIS, INC., PEERLESS INDUSTRIES, INC., PFIZER, INC. (PFIZER), U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, WEIL-MCLAIN, a division of The Marley-Wylain Company, a wholly owned subsidiary of The Marley Company, LLC, Defendants. 10 of 10