`NYSCEF DOC. NO. 164
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`INDEX NO. 003929/2023
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`RECEIVED NYSCEF: 05/22/2024
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`McGivne
`MKCI
`Klu er
`8
`Clark & In occia,
`P.C.
`A COMMATMENTTO EXCELLENCE
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`AXA TOWER - 1
`100 MADISON STREET, SUITE 1640
`SYRACUSE, NEW YORK 13202
`(315) 473-9648 – TELEPHONE
`(315) 473-9654 – FACSIMILE
`www.mkcilaw.us.com
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`March 6, 2024
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`Re:
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`Ronald J. Sullivan and Rebecca Jean Sullivan, his spouse v. Air & Liquid
`Systems Corporation as successor by merger to Buffalo Pumps, Inc., et al.
`Index No.: 003929/2023 (Onondaga County)
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`Via: Electronic mail
`Joseph T. Kremer, Esq.
`LIPSITZ, PONTERIO & COMERFORD, LLC
`424 Main Street, Suite 1500
`Buffalo, NY 14202
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`Dear Joseph:
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`Our office represents Defendant, Sid Harvey Industries, Inc., in the above referenced matter. Based on
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`the scheduling order, all discovery and depositions are completed in this matter. My review of the entire
`discovery to date demonstrates that my client is entitled to a No Opposition Summary Judgment Motion/Order
`or consent to dismissal based on the lack of product identification.
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`Accordingly, per Court direction, I request that you execute the attached proposed No Opposition
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`Summary Judgment Motion/Order by March 27, 2024 or provide my office the basis for your denial of our
`request by telephone or in writing. Per Court direction, please be advised that a failure to respond to this request
`will result in the submission to the Court for execution of an Order of Dismissal for each Defendant.
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`By this letter, all co-defendants are given notice that we seek dismissal of any and all cross claims. Any
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`objections shall be made in writing, stating the basis of objection, to the Court and all parties by March 27, 2024.
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`Very truly yours,
`McGIVNEY KLUGER CLARK & INTOCCIA, P.C.
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`Meagan E. Dean, Esq.
`medean@mkcilaw.us.com
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`MED/rm
`cc:
`All Defense Counsel (via: electronic mail)
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`FLORHAM
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`PARK, NJ
`(973) 822-1110
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`SYRACUSE, NY
`(315) 473-9648
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`BUFFALO, NY
` (315) 473-9648
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`HARTFORD, CT
`WILMINGTON, DE
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`(860) 404-3000 (315) 656-1200
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`PHILADELPHIA, PA
`(215) 557-1990
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`FRISCO, TX
`(469) 287-5500
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`NEW YORK, NY
`(212) 509-3456
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`MIAMI, FL
`(786) 696-9851
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`Meagan E. Dean, Esq.
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