`NYSCEF DOC. NO. 7
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`INDEX NO. 190038/2015
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`RECEIVED NYSCEF: 03/03/2015
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`MANUEL N. OLIVEIRA,
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`AIR & LIQUID SYSTEMS CORPORATION, et al.
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`Plaintiff(s),
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`Index No.: 190038/2015
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`ANSWER TO VERIFIED
`COMPLAINT
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`Defendants.
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`Defendant, TRANE US, INC. f/k/a AMERICAN STANDARD INC., i/s/h/a Successor in Interest
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`to KEWANEE BOILER CORPORATION, hereinafter referred to as “TRANE”, by its attorneys,
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`Pascarella DiVita, PLLC, for its Answer to plaintiffs’ Verified Complaint states as follows:
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`1. Defendant hereby answers the complaint in this action by reference to their answer to Joseph P.
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`Williams & Associates, P.C.’s New York Asbestos Litigation Standard Complaint No. 1 and raises
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`each of the affirmative defenses and cross-claims contained therein.
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`2. Denies each and every allegation contained in paragraph of the Complaint numbered “1”.
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`WHEREFORE, defendant, TRANE US, INC., requests judgment in its favor dismissing the
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`Complaint, judgment in its favor and against all co-defendants for all or part of any sum awarded in favor
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`of the plaintiff and against TRANE US, INC. and for such other and further relief as the Court may deem
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`just and proper.
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`Yours, etc.
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` Pascarella DiVita, PLLC
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`______________________________
`Lisa M. Pascarella, Esq.
`Attorneys for Defendant
`2137 Route 35, Suite 290
`Holmdel, N.J. 07733
`732-837-9019
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`ATTORNEY'S VERIFICATION
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` The undersigned affirms the following statement to be true under penalties of perjury
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`pursuant to Rule 2106 of the Civil Practice Law and Rules.
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`That she is an attorney at law and a member of the firm of Pascarella DiVita, PLLC attorneys for
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`the defendant, TRANE US, INC.
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` That she has read the foregoing document and knows the contents thereof, and that the same
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`is true to the knowledge of your affirmant except as to the matters therein alleged upon information
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`and belief and that as to those matters he believes them to be true.
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` That the reason why this affirmation is being made by your affirmant and not the defendant is
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`that the defendant is a domestic corporation and does not maintain an office with an officer having
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`knowledge of the facts in the county where your affirmant's firm maintains its offices.
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` That the source of your affirmant's information and the grounds of his belief as to all the
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`matters therein alleged upon information and belief is reports from and communication had with said
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`corporation.
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`Dated: New York, New York
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` March 3, 2015
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` ___________________________
`LISA M. PASCARELLA
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`AFFIDAVIT OF SERVICE BY MAIL
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`STATE OF NEW JERSEY
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`COUNTY OF MONMOUTH
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`SS.:
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`JEANNINE CARANDOLA, being duly sworn, deposes and says:
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`That deponent is not a party to the action; is over the age of 18 years, and resides within Staten
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`Island, New York.
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`That on the 3rd day of March, 2015, deponent served the within ACKNOWLEDGMENT OF
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`RECEIPT AND CROSS CLAIMS, VERIFIED ANSWER on the following attorney(s) for
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`defendant(s), as listed below, at the address designated by said attorney(s) for that purpose, by
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`depositing a true copy of same enclosed in a post-office depository, under the exclusive care and
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`custody of the United States Postal Service within New Jersey State:
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`Joseph P. Williams & Associates, P.C.
`245 Park Avenue, 39th Floor
`New York, NY 10167
`Attorneys for Plaintiff
`212-668-1122
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`Sworn to before me to this
`3rd day of March, 2015
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`________________________
`JEANNINE CARANDOLA
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`_______________________
` Notary Public
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`MEGHANN P. CHASE
`Notary Public of New Jersey
`My Commission Expires April 11, 2017
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`-against-
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`MANUEL N. OLIVEIRA,
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`AIR & LIQUID SYSTEMS CORPORATION, et al.
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`Plaintiff(s),
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`Defendants.
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`VERIFIED ANSWER TO VERIFIED COMPLAINT
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`Pascarella DiVita, PLLC
`Attorneys for Defendant
`2137 Route 35, Suite 290
`Holmdel, N.J. 07733
`732-837-9019
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