`NYSCEF DOC. NO. 129
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`INDEX NO. 190046/2022
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`RECEIVED NYSCEF: 09/21/2022
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`NUNZIO MOUDATSOS
`DIRECT: (212) 453-0776
`NMOUDATSOS@GRSM.COM
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`September 21, 2022
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`ATTORNEYS AT LAW
`1 BATTERY PARK PLAZA, 28TH FLOOR
`NEW YORK, NY 10004
`WWW.GRSM.COM
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`VIA NYSCEF
`Suzanne Ratcliffe, Esq.
`Maune Raichle Hartley French & Mudd LLC
`150 W. 30th Street, Suite 201
`New York, NY 10001
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`Re: Thomas R. & Lillian McLaughlin v. Air & Liquid Systems Corp., et al.
`New York City Asbestos Litigation
`Index No.: 190046/2022
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`Dear Ms. Ratcliffe:
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`We have reviewed the above-referenced matter and find no basis for plaintiffs to pursue their claims
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`against our client, FLSmidth Inc. As you know, depositions have concluded without identification of our
`client as a source of plaintiff’s alleged asbestos exposure.
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`Accordingly, we request that you kindly execute the enclosed Unopposed Summary Judgment
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`Motion and Order and remit the original to our office for filing. Should you decline to sign the order, please
`advise as to the basis of plaintiff’s claims against defendant.
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`Thank you for your anticipated cooperation. If you have any questions, please do not hesitate to
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`contact us.
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`Sincerely,
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`GORDON REES SCULLY MANSUKHANI, LLP
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`Nunzio Moudatsos
`Practice Group Manager – NY Toxic Tort
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`cc: All Co-Defendants (via NYSCEF)
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`Enclosures
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`1270431/70936103v.1
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`1 of 2
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`FILED: NEW YORK COUNTY CLERK 09/21/2022 05:29 PM
`NYSCEF DOC. NO. 129
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`INDEX NO. 190046/2022
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`RECEIVED NYSCEF: 09/21/2022
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`IN RE NEW YORK CITY
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`ASBESTOS LITIGATION
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`This Document Relates To:
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`Thomas R. McLaughlin and Lillian McLaughlin
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`NYCAL
`I.A.S. Part 13
`(Silvera, J.)
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` Index No: 190046/2022
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` UNOPPOSED
` SUMMARY
` JUDGMENT
` MOTION AND
` ORDER
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`- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
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`WHEREFORE, defendant FLSMIDTH INC. formerly known as FULLER
`COMPANY, requests summary judgment in the above-entitled action, pursuant to Civil Practice
`Law and Rules § 3212, dismissing the complaint and cross-claims against FLSMIDTH INC.
`formerly known as FULLER COMPANY, with prejudice, and after notice to all co-defendants
`there is no opposition, it is
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`ORDERED, that all claims and cross-claims against defendant FLSMIDTH INC.
`formerly known as FULLER COMPANY are hereby dismissed with prejudice and without
`costs.
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`New York, New York
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`__________________
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`Dated:
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`______________________________
`Suzanne Ratcliffe, Esq.
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`MAUNE RAICHLE HARTLEY
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`FRENCH & MUDD LLC
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`Attorney for Plaintiffs
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`150 W. 30th Street, Suite 201
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`New York, New York 10001
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`SO ORDERED, _________________________________
` HON. ADAM SILVERA, J.S.C.
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`______________________________
`Virginia Squitieri, Esq.
`GORDON REES SCULLY
`MANSUKHANI, LLP
`Attorney for Defendant
`FLSMIDTH INC. formerly known
`as FULLER COMPANY
`1 Battery Park Plaza, 28th Floor
`New York, New York 10004
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`2 of 2
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`1277975/70935503v.1
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