`NYSCEF DOC. NO. 30
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`INDEX NO. 190140/2015
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`RECEIVED NYSCEF: 05/18/2015
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`IN RE
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`NEW YORK CITY
`ASBESTOS LITIGATION
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`THIS DOCUMENT RELATES TO:
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`VINCENZO VAVALLO
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`X
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`X
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`X
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`Index No. 190140/15
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`ANSWER AND
`ACKNOWLEDGMENT
`OF RECEIPT OF
`WARREN PUMPS LLC
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`Defendant Warren Pumps LLC, sued incorrectly as “Warren Pumps, Inc.”
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`(“Warren Pumps”) by its attorneys, Leader & Berkon LLP, hereby acknowledges receipt of the
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`summons and verified complaint of Plaintiff in the above-captioned action (“Complaint”) and
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`answers said Complaint as follows:
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`1.
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`Warren Pumps denies knowledge or information sufficient to form a belief
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`as to the truth of the allegations contained in paragraphs 1 through 3 of the Complaint.
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`Warren Pumps hereby further answers the Complaint by reference to its Standard
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`Answer filed pursuant to the governing NYCAL Case Management Order and raises against
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`Plaintiffs each affirmative defense contained in its Standard Answer.
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`Warren Pumps hereby raises the cross-claim contained in its Standard Answer.
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`Dated: New York, New York
`May 18, 2015
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`By:
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`LEADER & BERKON LLP
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`/s/ David J. Goodearl
`DAVID J. GOODEARL
`Attorneys for Defendant
`Warren Pumps LLC
`630 Third Avenue
`New York, New York 10017
`(212) 486-2400
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