`FILED: NEW YORK COUNTY CLERK 02 11 2014
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`NYSCEF DOC. NO. 299
`NYSCEF DOC. NO. 299
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`«
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`190402/2012
`INDEX NO. 190402/2012
`INDEX NO'
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`R*.C*.IV*.D \IYSCEF:
`02/11/2014
`RECEIVED NYSCEF: 02/11/2014
`
`
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`g
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORKWWWWW
`IN RE: NEW YORK CITY
`E
`ASBESTOS LITIGATION
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`I
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`III.
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`THIS DOCUMENT RELATES TO:
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`MARK A. COATS and ELAINE COATS,
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`Plaintiffs,
`
`-against-
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`AIR & LIQUID SYSTEMS CORR, et aI.,
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`NYCAL
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`Index No.: 190402/2012
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`PLAINTIFFS' GENERAL EXHIBIT
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`s LIST
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`I
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`Defendants.
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`PLAINTIFF’S GENERAL EXHIBIT LIST
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`(Anglicable to All Defendantsl
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`COME now, Plaintiffs, MARK COATS and ELAINE COATSPI, through their attorneys, The
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`Lanier Law Firm PLLC, pursuant to the NYCAL April 2013 Accelerated Trial Cluster Discovery
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`Schedule, submit the following:
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`Any and all medical records and/or reports pertaining to p Iaintiff
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`Plaintiff’s discovery deposition testimony
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`694316~1
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`P-Coats -8
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`Plaintiff's Day In The Life Video
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` THE FOLLOWING EXHiBiTS RELATE T0 MARK COATS AND ELAINE COATS
` EXHlBiT NO.
`EXHlBlT
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`P- Coats -15
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`All exhibits marked at plaintiff’s discovery deposition and videotaped
`de bene esse deposition
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`P- Coats ~16
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`Plaintiff’s social security earnings records
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`Any and all statements and/or records reflecting Plaintiff’s income,
`including federal and state tax returns
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`P- Coats »17
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`P» Coats —18
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`Summary of medical and health-care bills and expenses
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`Any and all lost wages data, reports and documents
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`P~ Coats ’21
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`P— Coats -22
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`Any and all documents Defendants have produced in discovery in this
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`case (including any documents Defendant produces in this litigation
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`subsequent to the date of this exhibit list, as discovery is ongoing)
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` Any and all documents Plaintiffs have produced in discovery in this
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`case (including any documents Plaintiffs produce in this litigation
`subsequent to the date of this exhibit list, as discovery is ongoing)
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`P- Coats -23
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`Any and ail documents Defendant has produced in discovery in other
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`694316-1
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`THE FOLLOWING EXHIBITS RELATE T0 MARK COATS AND ELAINE COATS
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`EXHIBIT NO.
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`EXHIBIT
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`P— Coats ~24
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`Any and all discovery responses and productions Defendant has
`made in this case
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`
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`Any and all discovery responses and productions Defendant has
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`Any and all documents produced at or in connection with
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`Any and all documents attached as exhibits to any deposition taken
`in this case
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`Any and all publications and/or trade journals which contain pictures
`and/or ads for Defendant’s product(s)
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`P» Coats -28
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`P— Coats ~29
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`Any and all brochures or documents depicting Defendant’s product(s)
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`-—
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`made in other asbestos—related cases
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`Defendant’s corporate representative’s deposition(s)
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`Any and all asbestos—related workers compensation claims filed
`against Defendant
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`Any and all asbestos—related governmental or regulatory citations or
`investigations of Defendant
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`Any and all financial information, reports and/or filings pertaining to
`Defendant, its corporate predecessors or success*ors filed with the
`Securities and Exchange Commission
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`of sworn statements and/or exhibits at such hearings
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`P- Coats —30
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`P— Coats «31
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`P- Coats —32
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`P- Coats ~33
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`P-Coats ~34
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`P- Coats ~35
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`Any and all transcripts of hearings held by any federal or state
`governmental entity pertaining to asbestos, including any submission
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`Any and all documents pertaining to US Naval vessels and/or the
`decedent’s military service.
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`Any and all patents filed with the United States Patent and
`Trademark Office by Defendant or any other entity for which it has
`legal liability for asbestos-related claims
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`694316-1
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`
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`Plaintiffs reserve the right to amend 0r supplement this exhibit list in the future,
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`including at the time of trial.
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`Dated:
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`March 29, 2013
`New York, New York
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`The Lanier Law Firm PLLC
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`‘
`
`By; D I
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`Darron E. Berquis Esq.
`Attorneys for Plaintiffs
`126 East 56th Street, 6th Floor
`New York, NY 10022
`Tel.: (212) 421-2800
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`TO:
`
`ALL COUNSEL
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`694316-1
`
`
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