FILED: NEW YORK COUNTY CLERK 07/23/ :46 PM INDEX NO /2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/23/2015

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1 FILED: NEW YORK COUNTY CLERK 07/23/ :46 PM INDEX NO /2015 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/23/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X GEORGE MARIDAKIS and KATHERINA MARIDAKIS, Index No.: Date Filed: -against- Plaintiff(s), Plaintiff Designates NEW YORK County as the Place of Trial AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., AMERICAN BILTRITE INC., AVOCET ENTERPRISES, INC. f/k/a VENTFABRICS INC., AZROCK INDUSTRIES, a Division of DOMCO, INC., BEAZER EAST, INC., f/k/a KOPPERS COMPANY INC., BIRD INCORPORATED, BORGWARNER MORSE TEC LLC., CERTAINTEED CORPORATION, CRANE CO., CUMMINS, INC., DANA COMPANIES, LLC, DAP, INC., FORD MOTOR COMPANY, GENERAL ELECTRIC COMPANY, GEORGIA PACIFIC LLC., GOODYEAR CANADA, INC., GOULDS PUMPS, INC., HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT COMPANY and as successor to KENNEDY VALVE MANUFACTURING Co., Inc.,, J-M MANUFACTURING COMPANY, INC., KAISER GYPSUM COMPANY, INC., KARNAK CORPORATION, KOHLER CO., MANNINGTON MILLS, INC., MAREMONT CORP., OWENS-ILLINOIS, INC., PFIZER, INC. (PFIZER), PNEUMO ABEX LLC, successor in interest to ABEX CORPORATION (ABEX), REYNOLDS METALS COMPANY, STANDARD MOTOR PRODUCTS, INC., THE B.F. GOODRICH COMPANY, (GOODRICH CORPORATION), The Basis of Venue is Defendants' Place of Business SUMMONS

2 THE GOODYEAR TIRE AND RUBBER COMPANY, U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, 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 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, 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, July 23, 2015 New York, New York Defendant's address: SEE ATTACHED DEFENDANTS RIDER WEITZ & LUXENBERG, P.C. Attorney(s) for Plaintiff Post Office Address 700 Broadway New York, New York (212)

3 DEFENDANTS' RIDER AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC. 41 State Street Albany, NY AMERICAN BILTRITE INC. 57 River Street Wellsley Hills, MA AVOCET ENTERPRISES, INC. f/k/a VENTFABRICS INC. 333 W. Wacker Dr., #1700 Chicago, IL AZROCK INDUSTRIES, a Division of DOMCO, INC. c/o CT Corporation Systems Corporate Trust Center 1209 Orange Street Wilmington, DE BEAZER EAST, INC., f/k/a KOPPERS COMPANY INC. c/o Three Rivers Management Manor Oak One, Suite Cochrane Road Pittsburgh, PA BIRD INCORPORATED CT Corporation Systems 111 Eighth Avenue New York, NY BORGWARNER MORSE TEC LLC. CT Corporation 1209 Orange Street Wilmington, DE CERTAINTEED CORPORATION CT Corporation System 111 8th Avenue New York, NY CRANE CO. 100 First Stamford Place Stamford, CT 06902

4 CUMMINS, INC. Corporation Service Company 2711 Centerville Road Wilmington, DE DANA COMPANIES, LLC 900 West South Boundary St., Bldg. 8A Perrysburg, OH DAP, INC. The Prentice-Hall Corporation System Maryland 11 East Chase Street Baltimore, MD FORD MOTOR COMPANY CT Corporation Systems 111 8th Avenue New York, NY GENERAL ELECTRIC COMPANY Electric Insurance Company 75 Sam Fonzo Drive Beverly, MA GEORGIA PACIFIC LLC. CT Corporation Systems 111 8th Avenue New York, NY GOODYEAR CANADA, INC. 450 Kipling Avenue Atobicoke, Ontario CANADA M8ZSE1 GOULDS PUMPS, INC E. Bayard Street Seneca Falls, NY HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX 101 Columbia Road and Park Avenue Morristown, NJ ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT COMPANY and as successor to KENNEDY VALVE MANUFACTURING Co., Inc., CT CORPORATION 111 8th Avenue New York, NY 10011

5 J-M MANUFACTURING COMPANY, INC. Corporation Service Company d/b/a CSC - Lawyers Incorporating Service Company 2730 Gateway Oaks Dr., Ste. 100, Sacramento, CA KAISER GYPSUM COMPANY, INC. Manor Oak One 1910 Cochran Road Pittsburgh, PA and TRMI 301 Grant Street Suite 3000 One Oxford Centre Pittsburgh, PA Attention: Rezwan Mogri KARNAK CORPORATION 330 Central Avenue Clark, NJ KOHLER CO. HOAGLAND, LONGO, MORAN, DUNST, & DOUKAS, LLP Marc S. Gaffrey, Esq. 40 Patterson Street New Brunswick, NJ MANNINGTON MILLS, INC. Corporation Service Company 80 State Street, 6th Floor Albany, NY MAREMONT CORP. CT Corporation Telegraph Bingham Farms, MI OWENS-ILLINOIS, INC. One Michael Owens Way Perrysburg, OH PFIZER, INC. (PFIZER) CT Corporation Systems 111 8th Avenue New York, NY 10011

6 PNEUMO ABEX LLC, successor in interest to ABEX CORPORATION (ABEX) 80 State Street Albany, NY REYNOLDS METALS COMPANY CT Corporation 4701 Cox Road Glen Allen, VA STANDARD MOTOR PRODUCTS, INC Northern Blvd. Long Island City, NY THE B.F. GOODRICH COMPANY, (GOODRICH CORPORATION) CT Corporation System 111 8th Avenue New York, NY THE GOODYEAR TIRE AND RUBBER COMPANY Corporation Service Company 80 State Street Albany, NY U.S. RUBBER COMPANY (UNIROYAL) Greenfield, Stein & Senior (Agent for Service of Process) 600 Third Avenue, 11th Floor New York, NY UNION CARBIDE CORPORATION CT Corporation Systems 111 8th Avenue New York, NY 10019

7 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X GEORGE MARIDAKIS and KATHERINA MARIDAKIS, Index No.: Date Filed: Plaintiff(s), -against- AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., AMERICAN BILTRITE INC., AVOCET ENTERPRISES, INC. f/k/a VENTFABRICS INC., AZROCK INDUSTRIES, a Division of DOMCO, INC., BEAZER EAST, INC., f/k/a KOPPERS COMPANY INC., BIRD INCORPORATED, BORGWARNER MORSE TEC LLC., CERTAINTEED CORPORATION, CRANE CO., CUMMINS, INC., DANA COMPANIES, LLC, DAP, INC., FORD MOTOR COMPANY, GENERAL ELECTRIC COMPANY, GEORGIA PACIFIC LLC., GOODYEAR CANADA, INC., GOULDS PUMPS, INC., HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT COMPANY and as successor to KENNEDY VALVE MANUFACTURING Co., Inc.,, J-M MANUFACTURING COMPANY, INC., KAISER GYPSUM COMPANY, INC., KARNAK CORPORATION, KOHLER CO., MANNINGTON MILLS, INC., MAREMONT CORP., OWENS-ILLINOIS, INC., PFIZER, INC. (PFIZER), PNEUMO ABEX LLC, successor in interest to ABEX CORPORATION (ABEX), REYNOLDS METALS COMPANY, STANDARD MOTOR PRODUCTS, INC., THE B.F. GOODRICH COMPANY, (GOODRICH CORPORATION), THE GOODYEAR TIRE AND RUBBER COMPANY, U.S. RUBBER COMPANY (UNIROYAL), VERIFIED COMPLAINT PLAINTIFF DEMANDS TRIAL BY JURY

8 UNION CARBIDE CORPORATION, Defendants X Plaintiff(s), GEORGE MARIDAKIS and KATHERINA MARIDAKIS, by their attorneys WEITZ & LUXENBERG, P.C., upon information and belief, at all times hereinafter mentioned alleges as follows: 1. Plaintiff(s), GEORGE MARIDAKIS and KATHERINA MARIDAKIS, by their attorneys, WEITZ & LUXENBERG, P.C., for their verified complaint respectfully alleges: 2. Defendant AMERICAN BILTRITE INC., was and still is a duly organized domestic corporation doing business in the State of New York. 3. Defendant AVOCET ENTERPRISES, INC. f/k/a VENTFABRICS INC., was and still is a duly organized domestic corporation doing business in the State of New York. 4. Defendant AZROCK INDUSTRIES, a Division of DOMCO, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 5. Defendant AZROCK INDUSTRIES, a Division of DOMCO, INC., was and still 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. 6. Defendant BEAZER EAST, INC., f/k/a KOPPERS COMPANY INC., was and still is a duly organized domestic corporation doing business in the State of New York. 7. Defendant BIRD INCORPORATED, was and still is a duly organized domestic corporation doing business in the State of New York.

9 8. Defendant DAP, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 9. Defendant GEORGIA PACIFIC LLC., was and still is a duly organized domestic corporation doing business in the State of New York. 10. Defendant ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT COMPANY and as successor to KENNEDY VALVE MANUFACTURING Co., Inc.,, was and still is a duly organized domestic corporation doing business in the State of New York. 11. Defendant J-M MANUFACTURING COMPANY, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 12. Defendant KAISER GYPSUM COMPANY, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 13. Defendant KARNAK CORPORATION, was and still is a duly organized domestic corporation doing business in the State of New York. 14. Defendant MANNINGTON MILLS, INC., was and still is a duly organized domestic corporation doing business in the State of New York. 15. Defendant THE B.F. GOODRICH COMPANY, (GOODRICH CORPORATION), was and still is a duly organized domestic corporation doing business in the State of New York. Plaintiff(s), GEORGE MARIDAKIS and KATHERINA MARIDAKIS, repeats and realleges NYAL - WEITZ & 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.

10 Dated: July 23, 2015 New York, New York. Yours, etc., WEITZ & LUXENBERG, P.C Attorneys for Plaintiff(s) 700 Broadway New York, NY (212)

11 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 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 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: July 23, 2015 New York, New York /S/ LINDSAY DECICCO

12 Index No.: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ==================================================================================== GEORGE MARIDAKIS and KATHERINA MARIDAKIS, -against- AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., et. al., Plaintiff(s), Defendants. ==================================================================================== SUMMONS and COMPLAINT ==================================================================================== WEITZ & LUXENBERG, P.C. Attorneys for PLAINTIFFS 700 Broadway New York, NY ==================================================================================== To Attorney(s) for ==================================================================================== Service of a copy of the within is hereby admitted. Dated, July 23, Attorney(s) for ===================================================================================

13 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X GEORGE MARIDAKIS and KATHERINA MARIDAKIS, -against- Plaintiff(s), FULL CAPTION RIDER AMCHEM PRODUCTS, INC., n/k/a RHONE POULENC AG COMPANY, n/k/a BAYER CROPSCIENCE INC., AMERICAN BILTRITE INC., AVOCET ENTERPRISES, INC. f/k/a VENTFABRICS INC., AZROCK INDUSTRIES, a Division of DOMCO, INC., BEAZER EAST, INC., f/k/a KOPPERS COMPANY INC., BIRD INCORPORATED, BORGWARNER MORSE TEC LLC., CERTAINTEED CORPORATION, CRANE CO., CUMMINS, INC., DANA COMPANIES, LLC, DAP, INC., FORD MOTOR COMPANY, GENERAL ELECTRIC COMPANY, GEORGIA PACIFIC LLC., GOODYEAR CANADA, INC., GOULDS PUMPS, INC., HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED SIGNAL, INC. / BENDIX, ITT INDUSTRIES, INC., Individually, and as successor to BELL & GOSSETT COMPANY and as successor to KENNEDY VALVE MANUFACTURING Co., Inc.,, J-M MANUFACTURING COMPANY, INC., KAISER GYPSUM COMPANY, INC., KARNAK CORPORATION, KOHLER CO., MANNINGTON MILLS, INC., MAREMONT CORP., OWENS-ILLINOIS, INC., PFIZER, INC. (PFIZER), PNEUMO ABEX LLC, successor in interest to ABEX CORPORATION (ABEX), REYNOLDS METALS COMPANY, STANDARD MOTOR PRODUCTS, INC., THE B.F. GOODRICH COMPANY, (GOODRICH CORPORATION), THE GOODYEAR TIRE AND RUBBER COMPANY,

14 U.S. RUBBER COMPANY (UNIROYAL), UNION CARBIDE CORPORATION, Defendants X