`NYSCEF DOC. NO. 50
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`INDEX NO. 190065/2016
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`RECEIVED NYSCEF: 04/28/2016
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`1 of 3
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`NYAL — Weitz & Luxenberg, P.C. Standard Asbestos Complaint for Wrongful Death N0. “7”,
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`as though same were set forth at length herein.
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`WHEREFORE, defendant VELAN VALVE CORR, requests judgment in its favo
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`dismissing the Verified Complaint, judgment in its favor and against all co-defendants for all 0
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`part of any sum awarded in favor of the plaintiffs and against VELAN VALVE CORP. and fo
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`such other and further relief as the Court may deem just and proper.
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`Yours, etc.
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`Maron Marvel Bradley & Anderson LLC
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` /
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`TIM HY C
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`AN
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`STEFAN G. BOURN
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`Attorneys for Defendant
`VELAN VALVE CORP.
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`328 Newman Springs Road
`Red Bank, New Jersey 07701
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`2 of 3
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`ATTORNEY'S VERIFICATION
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`The undersigned affirms the following statement to be true under penalties of perju
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`pursuant to Rule 2106 of the Civil Practice Law and Rules.
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`That he is an attorney at law and an associate of the firm of Maron Marvel Bradley
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`Anderson LLC attorneys for the defendant, VELAN VALVE CORP.
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`That he has read the foregoing document and knows the contents thereof, and that th
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`same is true to the knowledge of your affirmant except as to the matters therein alleged upo
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`information 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 th
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`defendant is that the defendant is a domestic corporation and does not maintain an office with a
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`officer having knowledge of the facts in the county where your aff1rmant’s firm maintains it
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`offices.
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`That the source of your aff1rmant’s information and the grounds of his belief as to all th
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`matters therein alleged upon information and belief is reports from and communication had wit
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`said corporation.
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`Dated: Red Bank, New Jersey
`April 28, 2016
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`s..—---'‘'''
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`T
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`TH
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`OUGHLAN
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`3 of 3
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