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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY,
`PENNSYLVANIA
`
`
`
`
`PATRICIA JEAN OTWELL, Executrix of the
`Estate of KENT W. OTWELL, and PATRICIA
`JEAN OTWELL, in her own right,
`
`
`
`
`
`A.O. SMITH CORPORATION, et al.
`
`
`
`
`JURY TRIAL DEMANDED
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`Plaintiffs,
`
`v.
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`Defendants.
`
`CIVIL DIVISION-ASBESTOS
`
`G.D. 19-002707
`
`
`
`DEFENDANT RAIN BIRD
`CORPORATION, AS SUCCESSOR TO
`HAMMOND VALVE CORPORATION’S
`NOTICE OF SERVICE OF DISCOVERY
`TO PLAINTIFF
`
`Filed on behalf of Defendant,
`RAIN BIRD CORPORATION, as successor to
`Hammond Valve Corporation
`
`Counsel of Record for this party:
`
`JONI M. MANGINO, ESQUIRE
`Pa. I.D. #43586
`
`
`MATTHEW G. BRENEMAN, ESQUIRE
`Pa. I.D. #89607
`
`
`ZIMMER KUNZ, PLLC
`310 Grant Street, Suite 3000
`Pittsburgh, PA 15219
`412-281-8000
`
`
`
`
`
`
`
`
`
`01883952.DOCX 0861-0276
`0860.0074
`
`1288136
`
`

`

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`
`DEFENDANT RAIN BIRD CORPORATION, AS SUCCESSOR TO HAMMOND VALVE
`CORPORATION’S NOTICE OF SERVICE OF DISCOVERY TO PLAINTIFF
`
`NOTICE is hereby given to the court, that on the 7th day of May, 2020 the
`
`Defendant, Rain Bird Corporation, as Successor to Hammond Valve Corporation served its
`
`Request for Admission, Interrogatories and Request for Production of Documents Directed to
`
`Plaintiff upon Plaintiff’s counsel by United States mail, first class, postage fully prepaid at their
`
`office located at Suite 3626, Gulf Tower Pittsburgh, PA 15219 by United States mail, first class,
`
`postage fully prepaid.
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`Respectfully submitted,
`
`ZIMMER KUNZ, PLLC
`
`BY:
`
`
`
`
`s/Matthew G. Breneman
`JONI M. MANGINO, ESQUIRE
`MATTHEW G. BRENEMAN, ESQUIRE
`Attorneys for Defendant, RAIN BIRD
`CORPORATION, as successor to Hammond
`Valve Corporation
`
`01883952.DOCX 0861-0276
`0860.0074
`
`1288136
`
`

`

`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the within NOTICE OF SERVICE has been
`
`mailed to plaintiffs’ counsel, as addressed below, with notice being served upon all remaining counsel
`
`of record, by mailing same by United States First class mail, postage prepared this 7th day of May,
`
`2020.
`
`
`
`
`
`Michael J. Gallucci, Esquire
`Savinis, Kane & Gallucci, L.L.C.
`Suite 3626, Gulf Tower
`Pittsburgh, PA 15219
`
`
`ZIMMER KUNZ, PLLC
`
`
`
`s/Matthew G. Breneman
`____
`MATTHEW G. BRENEMAN, ESQUIRE
`
`BY:
`
`
`
`01883952.DOCX 0861-0276
`0860.0074
`
`1288136
`
`

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