FILED: NEW YORK COUNTY CLERK 12/26/2019 10:37 AM
`NYSCEF DOC. NO. 7
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 12/26/2019
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
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`ASLAM QAMARUDDIN and SALMA
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`QAMARUDDIN,
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` Plaintiffs,
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`-against-
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`CBS CORPORATION,, et al.,
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` Defendants.
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`Index No.: 190287/2019
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`VERIFIED ANSWER TO
`VERIFIED COMPLAINT
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`----------------------------------------------------------------x
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`Defendant, Trane U.S. Inc. f/k/a American Standard Inc., hereinafter “TRANE” by its
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`attorneys, Pascarella DiVita, PLLC, for its Answer to Plaintiff’s Verified Complaint states as
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`follows:
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`1.
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`Denies any knowledge or information sufficient to form a belief as to the
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`allegations contained in paragraph of the Complaint numbered “1”.
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`2.
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`Denies each and every allegation contained in paragraphs of the Complaint
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`numbered “2”, “3”, “4”, “5”, “6”, “7”, “8”, “9”, “10”, “11”, “12”, and “13” as to this answering
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`defendant and denies any knowledge or information sufficient to form a belief as to the allegations
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`as to all other defendants.
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`3.
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`TRANE hereby answers the Plaintiff’s Verified Complaint by reference to it’s
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`Answer to New York Asbestos Litigation – Meirowitz & Wasserberg, LLP’s Standard Asbestos
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`Complaint for Personal Injury No. 1 and raises each of the affirmative defenses and cross-claims
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`contained therein and further adds the following affirmative defenses and further adds the following
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`affirmative defenses.
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`AS AND FOR A FIRST ADDITIONAL AFFIRMATIVE DEFENSE
`THIS ANSWERING DEFENDANT ALLEGES UPON INFORMATION AND BELIEF
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`1. This Court lacks specific jurisdiction over defendant in this matter.
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`1 of 5
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`NYSCEF DOC. NO. 7
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 12/26/2019
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`----------------------------------------------------------------x
`ASLAM QAMARUDDIN and SALMA
`
`QAMARUDDIN,
`
`
` Plaintiffs,
`
`-against-
`
`CBS CORPORATION,, et al.,
`
` Defendants.
`
`
`
`Index No.: 190287/2019
`
`
`VERIFIED ANSWER TO
`VERIFIED COMPLAINT
`
`
`
`----------------------------------------------------------------x
`
`
`
`Defendant, Trane U.S. Inc. f/k/a American Standard Inc., hereinafter “TRANE” by its
`
`attorneys, Pascarella DiVita, PLLC, for its Answer to Plaintiff’s Verified Complaint states as
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`follows:
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`1.
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`Denies any knowledge or information sufficient to form a belief as to the
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`allegations contained in paragraph of the Complaint numbered “1”.
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`2.
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`Denies each and every allegation contained in paragraphs of the Complaint
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`numbered “2”, “3”, “4”, “5”, “6”, “7”, “8”, “9”, “10”, “11”, “12”, and “13” as to this answering
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`defendant and denies any knowledge or information sufficient to form a belief as to the allegations
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`as to all other defendants.
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`3.
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`TRANE hereby answers the Plaintiff’s Verified Complaint by reference to it’s
`
`Answer to New York Asbestos Litigation – Meirowitz & Wasserberg, LLP’s Standard Asbestos
`
`Complaint for Personal Injury No. 1 and raises each of the affirmative defenses and cross-claims
`
`contained therein and further adds the following affirmative defenses and further adds the following
`
`affirmative defenses.
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`AS AND FOR A FIRST ADDITIONAL AFFIRMATIVE DEFENSE
`THIS ANSWERING DEFENDANT ALLEGES UPON INFORMATION AND BELIEF
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`1. This Court lacks specific jurisdiction over defendant in this matter.
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`1 of 5
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`FILED: NEW YORK COUNTY CLERK 12/26/2019 10:37 AM
`NYSCEF DOC. NO. 7
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 12/26/2019
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`AS AND FOR A SECOND ADDITIONAL AFFIRMATIVE DEFENSE
`THIS ANSWERING DEFENDANT ALLEGES UPON INFORMATION AND BELIEF
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`2. The Court lacks general jurisdiction over defendant in this matter.
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`WHEREFORE, defendant TRANE U.S. 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
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`in favor of the plaintiff and against TRANE U.S. INC., and for such other and further relief as the
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`Court may deem 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
`TRANE U.S. INC.
`2137 Route 35, Suite 290
`Holmdel, N.J. 07733
`732-837-9019
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`2 of 5
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`FILED: NEW YORK COUNTY CLERK 12/26/2019 10:37 AM
`NYSCEF DOC. NO. 7
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 12/26/2019
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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
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`attorneys for the defendant, TRANE U.S. INC.
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` That she has read the foregoing document and knows the contents thereof, and that the
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`same is true to the knowledge of your affirmant except as to the matters therein alleged upon
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`information and belief and that as to those matters she believes them to be true.
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` That the reason why this affirmation is being made by your affirmant and not the
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`defendant is that the defendant is a domestic corporation and does not maintain an office with an
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`officer having knowledge of the facts in the county where your affirmant's firm maintains its
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`offices.
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` That the source of your affirmant's information and the grounds of her belief as to all
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`the matters therein alleged upon information and belief are reports from and communication had
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`with said corporation.
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`Dated: New York, New York
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` December 26, 2019
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`___________________________
` LISA M. PASCARELLA
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`3 of 5
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`FILED: NEW YORK COUNTY CLERK 12/26/2019 10:37 AM
`NYSCEF DOC. NO. 7
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`INDEX NO. 190287/2019
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`RECEIVED NYSCEF: 12/26/2019
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`STATE OF NEW JERSEY
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`COUNTY OF MONMOUTH)
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`AFFIDAVIT OF SERVICE
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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
`Island, New York.
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`That on the 26th day of December 2019, deponent filed the within Answer to Plaintiff’s
`Complaint electronically. True and correct copies of the attached Verified were electronically
`filed with the Clerk of New York State Unified Court System.
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`Deponent further states that true and correct copies thereof were forwarded on December 26,
`2019 to the following plaintiff’s counsel via the court’s ECF system at the electronic address
`designated by said attorney:
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`Meirowitz & Wasserberg, LLP
`Attorneys for Plaintiff
`535 Fifth Avenue, 23rd Floor
`New York, NY 10017
`(212)897-1988
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`Sworn to before me to this
`26th day of December 2019
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`_________________________________
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`JEANNINE CARANDOLA
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`______________________________
`Notary Public
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`ANGELICA GEARY
`NOTARY PUBLIC OF NEW JERSEY
`My Commission Expires April 6, 2022
`Commission # 50056271
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`4 of 5
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`FILED: NEW YORK COUNTY CLERK 12/26/2019 10:37 AM
`NYSCEF DOC. NO. 7
`
`INDEX NO. 190287/2019
`
`RECEIVED NYSCEF: 12/26/2019
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`-----------------------------------------------------------------x
`
`ASLAM QAMARUDDIN and SALMA QAMARUDDIN,
`
`
` Plaintiffs,
`Index No.: 190287/2019
`
`
`-against-
`
`
`
`CBS CORPORATION,, et al.,
`
` Defendants.
`
`
`
`
`
`
`---------------------------------------------------------------x
`
`
`
`
`
`
`
`
`VERIFIED ANSWER TO VERIFIED COMPLAINT
`
`
`
`
`
`
`
`
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`
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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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`5 of 5
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