FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 10/30/2019
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` Plaintiffs,
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` -against-
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`Index No.:
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`Date Filed:
`October 30, 2019
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`Plaintiffs Designates
`NEW YORK
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`County as the Place of
`Trial
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`The Basis of Venue is
`Plaintiff’s Place of
`Exposure
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`SUMMONS
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`-----------------------------------------------------------------------------X
`ASLAM QAMARUDDIN and SALMA QAMARUDDIN,
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`CBS CORPORATION, f/k/a VIACOM INC.,
` successor by merger to CBS CORPORATION, f/k/a
` WESTINGHOUSE ELECTRIC CORPORATION,
`FOSTER WHEELER, L.L.C.,
`GENERAL ELECTRIC COMPANY,
`GRINNELL LLC,
`HONEYWELL INTERNATIONAL, INC.,
` f/k/a ALLIED SIGNAL, INC. / BENDIX,
`IMO INDUSTRIES, INC.,
`INGERSOLL-RAND COMPANY,
`MINNESOTA MINING & MANUFACTURING COMPANY,
` a/k/a 3M COMPANY,
`TRANE U.S. INC., f/k/a AMERICAN STANDARD INC.,
`UNION CARBIDE CORPORATION,
`U.S. RUBBER COMPANY (UNIROYAL)
`WARREN PUMPS LLC,
`
`
` Defendants
`-----------------------------------------------------------------------------x
`To the above-named Defendant(s)
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`You are hereby summoned to answer the verified complaint in this action and to serve
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`a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of
`appearance, on the Plaintiff's Attorney(s) within 20 days after the service of this summons, exclusive
`of the day of service (or within 30 days after the service is complete if this summons is not personally
`delivered to you within the State of New York); and in case of your failure to appear or answer,
`judgment will be taken against you by default for the relief demanded in the complaint.
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`Dated: October 30, 2019
`New York, NY
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`MEIROWITZ & WASSERBERG, LLP
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`Defendant's address:
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`SEE ATTACHED DEFENDANTS RIDER
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` /S/ Daniel Wasserberg__________
`Daniel Wasserberg, Esq.
`Attorney for Plaintiff
`Post Office Address:
`535 Fifth Ave, 23rd Floor
`New York, New York 10017
`(212) 897-1988
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`1 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 10/30/2019
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`DEFENDANTS' RIDER
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`CBS CORPORATION, f/k/a VIACOM INC., successor
`by merger to CBS CORPORATION, f/k/a WESTINGHOUSE
`ELECTRIC CORPORATION
`Asbestos Litigation Support Manager
`ECKERT SEAMANS CHERIN & MELLOTT, LLC
`Case Management & Technology Center
`USX Towers
`600 Grant Street
`Pittsburgh, PA 15219
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`FOSTER WHEELER, L.L.C.
`Route 173 at Frontage Road
`Clinton, NJ 08809
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`GENERAL ELECTRIC COMPANY
`Electric Insurance Company
`75 Sam Fonzo Drive
`Beverly, MA 01915
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`GRINNELL LLC
`CT Corporation System
`28 Liberty St.
`New York, New York, 10005
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`HONEYWELL INTERNATIONAL, INC.,
` f/k/a ALLIED SIGNAL, INC. / BENDIX
`115 Tabor Road,
`Morris Plains, NJ 07950
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`IMO INDUSTRIES, INC.
`Corporation Service Company,
`2711 Centerville Road, Suite 400,
`Wilmington, DE 19808
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`INGERSOLL-RAND COMPANY
`CT Corporation System
`28 Liberty St.
`New York, New York, 10005
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`MINNESOTA MINING & MANUFACTURING COMPANY,
`a/k/a 3M COMPANY,
`The Corporation Trust Incorporated
`351 West Camden Street
`Baltimore, Maryland 21201
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`TRANE U.S. INC., f/k/a AMERICAN STANDARD INC.
`CT Corporation System
`28 Liberty St.
`New York, New York, 10005
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`UNION CARBIDE CORPORATION
`CT Corporation System
`28 Liberty St.
`New York, New York, 10005
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`U.S. Rubber Company (Uniroyal)
`Greenfield, Stein & Senior,
`600 Third Ave, 11th Floor,
`New York, NY 10016
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`WARREN PUMPS LLC,
`Corporation Service Company
`2711 Centerville Road
`Wilmington, DE 19808
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`2 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 10/30/2019
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`
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`Index No.:
`
`Date Filed:
`October 30, 2019
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`Plaintiff Designates
`NEW YORK
`County as the Place of
`Trial
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`The Basis of Venue is
`Plaintiff’s Place of
`Exposure
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`VERIFIED
`COMPLAINT
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` Plaintiffs,
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` -against-
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`-----------------------------------------------------------------------------X
`ASLAM QAMARUDDIN and SALMA QAMARUDDIN,
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`
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`
`
`CBS CORPORATION, f/k/a VIACOM INC.,
` successor by merger to CBS CORPORATION, f/k/a
` WESTINGHOUSE ELECTRIC CORPORATION,
`FOSTER WHEELER, L.L.C.,
`GENERAL ELECTRIC COMPANY,
`GRINNELL LLC,
`HONEYWELL INTERNATIONAL, INC.,
` f/k/a ALLIED SIGNAL, INC. / BENDIX,
`IMO INDUSTRIES, INC.,
`INGERSOLL-RAND COMPANY,
`MINNESOTA MINING & MANUFACTURING COMPANY,
` a/k/a 3M COMPANY,
`TRANE U.S. INC., f/k/a AMERICAN STANDARD INC.,
`UNION CARBIDE CORPORATION,
`U.S. RUBBER COMPANY (UNIROYAL)
`WARREN PUMPS LLC,
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` Defendants
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`-----------------------------------------------------------------------------X
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`To the above-named Defendant(s):
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`Plaintiff, ASLAM QAMARUDDIN and SALMA QAMARUDDIN, by his attorneys,
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`MEIROWITZ & WASSERBERG, LLP, for their verified complaint respectfully allege:
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`1.
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`Plaintiff, Aslam Qamaruddin, was diagnosed with Malignant
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`Mesothelioma.
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`2.
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`Defendant CBS CORPORATION, f/k/a VIACOM INC., successor by
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`merger to CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC CORPORATION was
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`and still is a duly organized domestic corporation doing business in the State of New York.
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`3.
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`Defendant FOSTER WHEELER, L.L.C., was and still is a corporation
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`3 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 10/30/2019
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`doing business and/or transacting business in the State of New York and should have expected
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`its acts to have consequences within the State of New York.
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`4.
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`Defendant GENERAL ELECTRIC COMPANY, was and still is a
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`corporation doing business and/or transacting business in the State of New York and should have
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`expected its acts to have consequences within the State of New York.
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`5.
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`Defendant GRINNELL LLC, was and still is a corporation doing
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`business and/or transacting business in the State of New York and should have expected its acts
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`to have consequences within the State of New York.
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`6.
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`Defendant HONEYWELL INTERNATIONAL, INC., f/k/a ALLIED
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`SIGNAL, INC. / BENDIX, was and still is a corporation doing business and/or transacting
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`business in the State of New York and should have expected its acts to have consequences within
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`the State of New York.
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`7.
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`Defendant IMO INDUSTRIES, INC., was and still is a corporation
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`doing business and/or transacting business in the State of New York and should have expected
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`its acts to have consequences within the State of New York.
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`8.
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`Defendant INGERSOLL RAND COMPANY, was and still is a duly
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`organized corporation doing business and/or transacting business in the State of New York
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`and/or should have expected its acts to have consequences within the State of New York.
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`9.
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`Defendant MINNESOTA MINING & MANUFACTURING
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`COMPANY, a/k/a 3M COMPANY, was and still is a duly organized corporation doing business
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`and/or transacting business in the State of New York and/or should have expected its acts to have
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`consequences within the State of New York.
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`10.
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`Defendant TRANE U.S. INC., f/k/a AMERICAN STANDARD, INC.,
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`4 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 10/30/2019
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`was and still is a duly organized domestic corporation doing business in the State of New York.
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`11.
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`Defendant UNION CARBIDE CORPORATION, was and still is a
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`corporation doing business and/or transacting business in the State of New York and should have
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`expected its acts to have consequences within the State of New York.
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`12.
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`Defendant U.S. RUBBER COMPANY (UNIROYAL), was and still is a
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`corporation doing business and/or transacting business in the State of New York and should have
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`expected its acts to have consequences with the State of New York.
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`13.
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`Defendant WARREN PUMPS LLC, was and still is a corporation
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` doing business and/or transacting business in the State of New York and should have expected
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`its acts to have consequences within the State of New York.
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` Plaintiff, ASLAM QAMARUDDIN and SALMA QAMARUDDIN, repeats and
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`realleges NYCAL - MEIROWITZ & WASSERBERG, LLP’s STANDARD ASBESTOS
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`COMPLAINT FOR PERSONAL INJURY No. 1 as if fully incorporated herein as it pertains to
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`the defendants in the aforementioned caption.
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`Dated: October 30, 2019
`New York, New York
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`Yours, etc.,
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`MEIROWITZ & WASSERBERG, LLP
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`/S/ Daniel Wasserberg
`Daniel Wasserberg
`Attorney(s) for Plaintiff
`Post Office Address:
`535 Fifth Ave, 23rd Floor
`New York, New York 10017
`(212) 897-1988
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`5 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 10/30/2019
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`STATE OF NEW YORK )
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`COUNTY OF NEW YORK )
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`SS:
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`The undersigned, an attorney admitted to practice in the Courts of New York State,
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`shows:
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`Deponent is an Attorney of the law firm MEIROWITZ & WASSERBERG, LLP,
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`Counsel for the plaintiff(s) in the within action; deponent has read the foregoing summons and
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`verified complaint and knows the contents thereof; the same is true to deponent's own
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`knowledge, except as to the matters therein stated to be alleged on information and belief, and
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`that as to those matters deponent believes it to be true. This verification is made by deponent
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`and not by plaintiff(s) because plaintiff(s) resides outside of the County of New York where
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`plaintiffs' counsel and deponent maintain their office.
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`Dated: October 30, 2019
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`New York, NY
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`/S/ Daniel Wasserberg
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` DANIEL WASSERBERG
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`6 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 10/30/2019
`
`
`
`
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`Index No.:
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`============================================================================================
`ASLAM QAMARUDDIN and SALMA QAMARUDDIN
`
`
`
`
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`CBS CORPORATION, f/k/a VIACOM INC., successor by merger to
`CBS CORPORATION, f/k/a WESTINGHOUSE ELECTRIC
`CORPORATION, et. al.,
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`Defendants.
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`============================================================================================
`
`
`
`
`-against-
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`Plaintiffs,
`
`SUMMONS and COMPLAINT
`
`
`============================================================================================
`MEIROWITZ & WASSERBERG, LLP
`Attorneys for PLAINTIFFS
`535 Fifth Ave, 23rd Floor
`New York, NY 10017
`212-897-1988
`============================================================================================
`To
`Attorney(s) for
`============================================================================================
`Service of a copy of the within
`is hereby admitted.
`Dated: October 30, 2019
`…………………………………………………………………………………………………………………………….…………….
`Attorney(s) for ASLAM QAMARUDDIN and SALMA QAMARUDDIN
`============================================================================================
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`7 of 8
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`FILED: NEW YORK COUNTY CLERK 10/30/2019 05:07 PM
`NYSCEF DOC. NO. 1
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 10/30/2019
`
`
`
`Index No.:
`
`Date Filed:
`October 30, 2019
`
`Plaintiff Designates
`NEW YORK
`County as the Place of
`Trial
`
`The Basis of Venue is
`Plaintiff’s Place of
`Exposure
`
`
`FULL CAPTION
`RIDER
`
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`
`
`
`
` Plaintiffs,
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`-----------------------------------------------------------------------------X
`ASLAM QAMARUDDIN and SALMA QAMARUDDIN,
`
`
`
`
`
`CBS CORPORATION, f/k/a VIACOM INC.,
` successor by merger to CBS CORPORATION, f/k/a
` WESTINGHOUSE ELECTRIC CORPORATION,
`FOSTER WHEELER, L.L.C.,
`GENERAL ELECTRIC COMPANY,
`GRINNELL LLC,
`HONEYWELL INTERNATIONAL, INC.,
` f/k/a ALLIED SIGNAL, INC. / BENDIX,
`IMO INDUSTRIES, INC.,
`INGERSOLL-RAND COMPANY,
`MINNESOTA MINING & MANUFACTURING COMPANY,
` a/k/a 3M COMPANY,
`TRANE U.S. INC., f/k/a AMERICAN STANDARD INC.,
`UNION CARBIDE CORPORATION,
`U.S. RUBBER COMPANY (UNIROYAL)
`WARREN PUMPS LLC,
`
` Defendants
`
`
`-----------------------------------------------------------------------------X
`
` -against-
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`8 of 8
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