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FILED: NEW YORK COUNTY CLERK 09/17/2014 04:24 PM
`NYSCEF DOC. NO. 6
`
`INDEX NO. 190292/2014
`
`RECEIVED NYSCEF: 09/17/2014
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`IN RE
`
`NEW YORK CITY
`ASBESTOS LITIGATION
`
`THIS DOCUMENT RELATES TO:
`
`JOSEPH F. SIMONS
`
`X
`
`X
`
`X
`
`Index No. 190292/14
`
`ANSWER AND
`ACKNOWLEDGMENT
`OF RECEIPT OF
`WARREN PUMPS LLC
`
`Defendant Warren Pumps LLC, (“Warren Pumps”) by its attorneys, Leader &
`
`Berkon LLP, hereby acknowledges receipt of the summons and verified complaint of Plaintiff in
`
`the above-captioned action (“Complaint”) and answers said Complaint as follows:
`
`1.
`
`Warren Pumps denies knowledge or information sufficient to form a
`
`belief as to the truth of the allegations contained in paragraphs 1 through 3 of the Complaint.
`
`Warren Pumps hereby further answers the Complaint by reference to its Standard
`
`Answer filed pursuant to the governing NYCAL Case Management Order and raises against
`
`Plaintiffs each affirmative defense contained in its Standard Answer.
`
`Warren Pumps hereby raises the cross-claim contained in its Standard Answer.
`
`Dated:
`
`New York, New York
`September 17, 2014
`
`By:
`
`LEADER & BERKON LLP
`
`/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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