FILED: NEW YORK COUNTY CLERK 05/14/2015 12:00 PM INDEX NO. 190163/2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/14/2015 THIS IS AN ASBESTOS LITIGATION CASE FILED UNDER N.Y.C.A.L.
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------------X NORMAN HUNT, Index No.: Date Filed: 05/14/2015 -against- Plaintiff(s), Plaintiff Designates NEW YORK County as the Place of Trial The Basis of Venue is Defendants Place of Business AERCO INTERNATIONAL, AIR & LIQUID SYSTEMS CORPORATION as successor by merger to BUFFALO PUMPS, INC., AMERICAN BILTRITE, SUMMONS Individually and as successor to AMTICO FLOORS, ARMSTRONG INTERNATIONAL INC., ATWOOD & MORRILL CO. INC., AURORA PUMP COMPANY, BLACKMER, a division of DOVER CORPORATION, f/k/a BLACKMER PUMP POWER & MANUFACTURING COMPANY, BORG-WARNER, by its successor-in-interest BORG WARNER MORSE TEC, INC., BW/IP INTERNATIONAL, INC., f/k/a BORG WARNER INDUSTRIAL PRODUCTS successor to BYRON JACKSON PUMPS, BYRON JACKSON PUMPS, CARRIER CORPORATION, Individually, and as successor in interest to BRYANT HEATING & COOLING SYSTEMS, CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION, CERTAIN TEED CORPORATION, CROSBY VALVE, LLC, EMPIRE-ACE INSULATION MFG. CORP., FLOWSERVE CORPORATION, FLOWSERVE US, INC., Solely as Successor to ROCKWELL MANUFACTURING COMPANY, EDWARD VALVE, INC., NORDSTROM VALVES, INC., EDWARD VOGT VALVE COMPANY, and VOGT VALVE COMPANY
FMC CORPORATION, Individually and as successor through acquisition of CHICAGO PUMP COMPANY, NORTHERN PUMP COMPANY and COFFIN and PEERLESS PUMP COMPANY, FOSTER WHEELER CORPORATION, GARDNER DENVER, INC., GATES CORPORATION, GENERAL ELECTRIC COMPANY, GEORGIA PACIFIC CO., Individually and as successor to BESTWALL GYPSUM COMPANY, GOULDS PUMPS, INC., GRINNELL, LLC, HONEYWELL CORP., f/k/a ALLIED SIGNAL, INC.,/ BENDIX IMO INDUSTRIES, INC., INGERSOLL-RAND COMPANY, ITT CORPORATION, ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT CO., and as successor to KENNEDY VALVE MANUFACTURING CO., INC., KAISER GYPSUM COMPANY, INC., OWENS-ILLINOIS, INC., SPIRAX SARCO, INC., Individually, and as successor to SARCO COMPANY, THE FAIRBANKS COMPANY, TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC., Individually, and as successor in interest to KEWANEE BOILER CORPORATION, UNION CARBIDE CORPORATION, VELAN VALVE CORPORATION, WARREN PUMPS, INC., WEIL-McLAIN, A DIVISION OF THE MARLEY-WYLAIN COMPANY WEINMAN PUMP AND SUPPLY CO., ZY-TECH GLOBAL INDUSTRIES, INC., Defendants, ---------------------------------------------------------------------------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 compliant 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, 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); 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, 05/14/2015 New York, New York Defendant s address: THE WILLIAMS LAW FIRM, P.C. Attorney(s) for Plaintiff 245 Park Ave 39 th Floor SEE ATTACHED DEFENDANTS RIDER New York, NY 10167 (212) 668-1122
DEFENDANTS RIDER AERCO INTERNATIONAL 100 Oritani Drive Blauvelt, NY 10913 AIR & LIQUID SYSTEMS CORPORATION as successor by merger to BUFFALO PUMPS, INC. 874 Oliver Street N. Tonawanda, NY 14120 AMERICAN BILTRITE, Individually and as successor to AMTICO FLOORS 84 State Street Boston, MA 02109 ARMSTRONG INTERNATIONAL INC. 900 Maple Street Three Rivers, MI 49093 ATWOOD & MORRILL CO. INC. C/o Secretary of State Albany, NY 12207 AURORA PUMP COMPANY 13515 Ballantyne Corporate Place Charlotte, NC 28277 BLACKMER, a division of DOVER CORPORATION, f/k/a BLACKMER PUMP POWER & MANUFACTURING COMPANY BLACKMER, World Headquarters 1809 Century Avenue SW Grand Rapids, MI 49503-1530 Attn: CEO/ Legal Department BORG-WARNER, by its successor-in-interest BORG WARNER MORSE TEC, INC., 200 South Michigan Avenue Chicago, IL 60604 BW/IP INTERNATIONAL, INC., f/k/a BORG WARNER INDUSTRIAL PRODUCTS, successor to BYRON JACKSON PUMPS 200 South Michigan Avenue Chicago, IL 60604
BYRON JACKSON PUMPS 5215 N. O Connor Boulevard Suite 2300 Irving, TX 75039 CARRIER CORPORATION, Individually, and as successor in interest to BRYANT HEATING & COOLING SYSTEMS, CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION 31 52 ND Street New York, NY 10019 CERTAIN TEED CORPORATION CROSBY VALVE, LLC, 101 Federal Street Boston, MA 02110 EMPIRE-ACE INSULATION MFG. CORP. C/o Secretary of State 41 State Street Albany, NY 12207 FLOWSERVE CORPORATION Flowserve Corporation General Counsel 5215 N. O Connor Blvd., Suite 2300 Irving, TX 75039 FLOWSERVE US, INC., Solely as Successor to ROCKWELL MANUFACTURING COMPANY, EDWARD VALVE, INC., NORDSTROM VALVES, INC., EDWARD VOGT VALVE COMPANY, and VOGT VALVE COMPANY 101 Federal Street Boston, MA 02110
FMC CORPORATION, Individually and as successor through acquisition of CHICAGO PUMP COMPANY, NORTHERN PUMP COMPANY and COFFIN and PEERLESS PUMP COMPANY 1735 Market Street Philadelphia, PA 19103 FOSTER WHEELER CORPORATION Route 173 at Frontage Road Clinton, NJ 08809 GARDNER DENVER, INC., 1800 Gardner Expressway Quincy, IL 62301 GATES CORPORATION GENERAL ELECTRIC COMPANY Electric Insurance Company 75 Sam Fonzo Drive Beverly, MA 01915 GEORGIA PACIFIC CO., Individually and as successor to BESTWALL GYPSUM COMPANY GOULDS PUMPS, INC. 240 Fall Street Seneca Falls, NY 13148 GRINNELL LLC HONEYWELL CORP., f/k/a ALLIED SIGNAL, INC.,/BENDIX 101 Columbia Road and Park Avenue Morristown, NJ 07962
IMO INDUSTRIES, INC., IBIS Plaza 3525 Quakerbridge Road Suite 912 Hamilton, NJ 08619 INGERSOLL-RAND COMPANY ITT CORPORATION ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT CO., and as successor to KENNEDY VALVE MANUFACTURING Co., INC., and as successor to GRINNELL VALVE Co., Inc., KAISER GYPSUM COMPANY, INC., TRMI 301 Grant Street Suite 3000 One Oxford Centre Pittsburgh, PA 15219 OWENS-ILLINOIS, INC. One Michael Owens Way Perrysburg, OH 43551 SPIRAX SARCO, INC., Individually, and as successor to SARCO COMPANY 111 Eighth Avenue THE FAIRBANKS COMPANY (GA) 1201 Peachtree Street NE Atlanta, GA 30361
TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC., Individually, and as successor in interest to KEWANEE BOILER CORPORATION C/o 111 Eighth Avenue UNION CARBIDE CORPORATION, nue VELAN VALVE CORPORATION C/o Corporation Service Company 80 State Street Albany, NY 12207-2543 WARREN PUMPS, INC. 82 Bridges Avenue Warren, MA 01083 WEIL-McLAIN, A DIVISION OF THE MARLEY-WYLAIN COMPANY 500 Blaine Street Michigan City, IN 46360 ~and~ 1315 Ballantyne Corporate Place Charlotte, NC 28277 WEINMAN PUMP AND SUPPLY CO., 100 First Stamford Place Stamford, CT 06902 ~and~ James Abraham, Esq. 5001 Baum Blvd Suite 419 Pittsburgh, PA 15213 ZY-TECH GLOBAL INDUSTRIES, INC. 10600 Corporate Drive Stafford, TX 77477
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ---------------------------------------------------------------------------X NORMAN HUNT, Index No.: Date Filed: 05/14/2015 -against- Plaintiff(s), Plaintiff Designates NEW YORK County as the Place of Trial The Basis of Venue is Defendants Place of Business AERCO INTERNATIONAL, AIR & LIQUID SYSTEMS CORPORATION as successor by merger to BUFFALO PUMPS, INC., AMERICAN BILTRITE, Individually and as successor to AMTICO FLOORS, ARMSTRONG INTERNATIONAL INC., ATWOOD & MORRILL CO. INC., AURORA PUMP COMPANY, BLACKMER, a division of DOVER CORPORATION, f/k/a BLACKMER PUMP POWER & MANUFACTURING COMPANY, BORG-WARNER, by its successor-in-interest BORG WARNER MORSE TEC, INC., BW/IP INTERNATIONAL, INC., f/k/a BORG WARNER INDUSTRIAL PRODUCTS successor to BYRON JACKSON PUMPS, BYRON JACKSON PUMPS, CARRIER CORPORATION, Individually, and as successor in interest to BRYANT HEATING & COOLING SYSTEMS, CBS CORPORATION, f/k/a VIACOM INC., successor by merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION, CERTAIN TEED CORPORATION, CROSBY VALVE, LLC, EMPIRE-ACE INSULATION MFG. CORP., FLOWSERVE CORPORATION, FLOWSERVE US, INC., Solely as Successor to ROCKWELL MANUFACTURING COMPANY, EDWARD VALVE, INC., NORDSTROM VALVES, INC., EDWARD VOGT VALVE COMPANY, and VOGT VALVE COMPANY VERIFIED COMPLAINT
FMC CORPORATION, Individually and as successor through acquisition of CHICAGO PUMP COMPANY, NORTHERN PUMP COMPANY and COFFIN and PEERLESS PUMP COMPANY, FOSTER WHEELER CORPORATION, GARDNER DENVER, INC., GATES CORPORATION, GENERAL ELECTRIC COMPANY, GEORGIA PACIFIC CO., Individually and as successor to BESTWALL GYPSUM COMPANY, GOULDS PUMPS, INC., GRINNELL, LLC, HONEYWELL CORP., f/k/a ALLIED SIGNAL, INC.,/ BENDIX IMO INDUSTRIES, INC., INGERSOLL-RAND COMPANY, ITT CORPORATION, ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT CO., and as successor to KENNEDY VALVE MANUFACTURING CO., INC., KAISER GYPSUM COMPANY, INC., OWENS-ILLINOIS, INC., SPIRAX SARCO, INC., Individually, and as successor to SARCO COMPANY, THE FAIRBANKS COMPANY, TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC., Individually, and as successor in interest to KEWANEE BOILER CORPORATION, UNION CARBIDE CORPORATION, VELAN VALVE CORPORATION, WARREN PUMPS, INC., WEIL-McLAIN, A DIVISION OF THE MARLEY-WYLAIN COMPANY WEINMAN PUMP AND SUPPLY CO., ZY-TECH GLOBAL INDUSTRIES, INC., Defendants, ---------------------------------------------------------------------------X Plaintiff(s), NORMAN HUNT, by their attorneys THE WILLIAMS LAW FIRM, P.C., upon information and belief, at all times hereinafter mentioned alleges as follows:
1. Plaintiff(s), NORMAN HUNT, by their attorneys, THE WILLIAMS LAW FIRM, P.C., for their verified complaint respectfully alleges: Plaintiff(s), NORMAN HUNT, repeats and realleges NYAL- THE WILLIAMS LAW FIRM, P.C., STANDARD ASBESTOS COMPLAINT FOR PERSONAL INJURY NO. 1 as fully incorporated herein as it pertains to the defendants in the aforementioned caption Dated: 05/14/2015 New York, New York Yours, etc., THE WILLIAMS LAW FIRM, P.C. Attorneys for Plaintiff(s) 245 Park Ave 39 th Floor New York, NY 10167
STATE OF NEW YORK ) COUNTY OF NEW YORK ) SS: The undersigned, an attorney admitted to practice in the Courts of New York State, shows: Deponent is a member of the firm THE WILLIAMS LAW FIRM, 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 the 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 it to be true. This verification is made by deponent and not by plaintiff(s) because plaintiff(s) resides outside of the County of New York where plaintiffs counsel and deponent maintain their office. Dated: 05/14/2015 New York, New York /S/ JOSEPH P. WILLIAMS