`IN RE: BRIDGEPORT ASBESTOS LITIGATION _
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`I
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`DOCKET NO.: ASB- FBT-CV—l 8-6079494—S
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`ALBERT BEAUDOIN AND ELLEN BEAUDOIN
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`VS.
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`84 LUMBER COMPANY, ET AL
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`SUPERIOR COURT
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`J .D. OF FAIRFIELD
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`AT BRIDGEPORT
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`NOVEMBER 4, 2019
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`DEFENDANT, H. B. FULLER COMPANY’S, MOTION FOR SUMMARY
`JUDGMENT AS TO PLAINTIFFS’ COMPLAINT AND ALL CROSS-CLAIMS
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`Defendant, H.B. Fuller Company, pursuant to §17-44 tat—seq. of the Connecticut
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`Practice Book hereby moves for summary judgment in its favor on the plaintiffs’ Complaint,
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`dated October 5, 2018, which was amended on November 28, 2018, December 13, 2018 and
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`October 11, 2019, as to Count One for products liability, Count Two for loss of consortium,
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`and Count Three for grossly negligent, willful, wanton, malicious and outrageous misconduct.
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`The Defendant, H. B. Fuller Company, also moves for summary judgment as to any cross-
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`claims pending in connection with the model cross-claims.
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`ORAL ARGUMENT IS REQUESTED
`TESTIMONY NOT REQUIRED
`JURYSELECTION/TRIAL SCHEDULED FOR JANUARY22, 2020
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`{00929308;v1}
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`O’CONNELL, ATTMORE 8L MORRIS, LLC
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`280 TRUMBULL STREET - HARTFORD, CONNECTICUT 06103—3598 - (860) 548—1300
`IURIS NO. 104083 - FAX NO. (860) 548—0023
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`1
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`In support of this motion, the defendant represents that there exists no issue as to any
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`material fact, and that it is entitled to a judgment as a matter of law for the reason that the
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`plaintiffs and cross-claim defendants have failed to identify any exposure to an H.B. Fuller
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`product that contain asbestos, and therefore there is no question of material fact as to whether
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`the plaintiff, Albert Beaudoin, was ever exposed to asbestos and/or asbestos containing
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`products manufactured, distributed, or sold by the H.B. Fuller Company. The defendant, H.B.
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`Fuller Company, is entitled to summary judgment as a matter of law. A supporting
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`Memorandum of Law accompanies this motion.
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`DEFENDANT, H. B. FULLER CO.
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`Susan L. Millet
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`O’Connell, Attmore, & Morris, LLC
`280 Trumbull Street, 23rd Floor
`Hartford, CT 06103
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`Tel. (860) 548-1300
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`Fax (860) 548-0023
`Juris No.: 104083
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`3mi1Iel'u'floamlaw.com
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`{00929308;vl}
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`O’CONNELL, ATTMORE 8L MORRIS, LLC
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`280 TRUMBULL STREET - HARTFORD. CONNECTICUT 06103—3598 - (860) 548—1300
`JURIS NO. 104083 - FAX NO. (860) 548—0023
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`2
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`CERTIFICATION
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`I certify that a copy of the above was or will immediately be mailed or delivered
`electronically or non-electronically on November 4, 2019 to all counsel and self represented
`parties of record and that written consent for electronic delivery was received from all counsel
`and self-represented parties of record who were or will immediately be electronically served.
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`Christopher Meisenkothen, Esq.
`Early, Lucarelli, Sweeney & Meisenkothen, LLC
`One Century Tower, 11th Floor
`265 Church Street
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`New Haven, CT 06510
`Phone: 1-203-777—7799
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`Fax: 1-203- 785-1671
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`John J. Robinson, Esq.
`Gordon & Rees, LLP
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`95 Glastonbury Boulevard
`Suite 206
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`Glastonbury, CT 06033
`Phone: 860—278- 7448
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`Fax: 860-560-0185
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`Hm 5131.5;931(59ngrdom'ges.com
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`and electronically transmitted to defense counsel of record on this day.
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`mpro/724%
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`Susi-m L Miller
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`SLM/sjp
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`{00929308;vl}
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`O’CONNELL, ATTMORE 8L MORRIS, LLC
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`280 TRUMBULL STREET ~ HARTFORD, CONNECTICUT 06103—3598 ~ (860) 548—1300
`jURlS NO. 104083 - FAX NO (860) 548-0023
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`3
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