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`MARILYN J. DUNCAN, Executrix of the
`Estate of WARD H. DUNCAN, deceased,
`and MARILYN J. DUNCAN, in her own
`right,
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` Plaintiffs,
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`vs.
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`A.O. SMITH CORPORATION, et al.,
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`Defendants.
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`CIVIL DIVISION – ASBESTOS
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`No. G.D. 22-000536
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`HOWDEN NORTH AMERICA INC.,
`FORMERLY KNOWN AS HOWDEN
`BUFFALO, INC.’S AMENDED ANSWER
`AND NEW MATTER PLEADING
`SETTLEMENT AGREEMENT WITH
`PLAINTIFF
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`Filed on behalf of:
`Howden North America Inc., formerly
`known as Howden Buffalo, Inc.
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`Counsel of Record for this Party:
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`Alba A. Romano, Esq.
`PA I.D. #51135
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`Sandra L. Alven, Esq.
`PA I.D. #86458
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`Mark E. Floyd, Esq.
`PA I.D. #208172
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`Anne M. McFadden, Esq.
`PA I.D. #324198
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`Joseph L. Orszulak, II, Esq.
`PA I.D. #63304
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`RILEY, HEWITT, WITTE & ROMANO,
`P.C.
`650 Washington Road, Suite 300
`Pittsburgh, PA 15228
`(412) 341-9300
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`Firm #987
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`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
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`CIVIL DIVISION – ASBESTOS
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`No. G.D. 22-000536
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`MARILYN J. DUNCAN, Executrix of the
`Estate of WARD H. DUNCAN, deceased,
`and MARILYN J. DUNCAN, in her own
`right,
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` Plaintiffs,
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`vs.
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`A.O. SMITH CORPORATION, et al.,
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`Defendants.
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`HOWDEN NORTH AMERICA INC., FORMERLY KNOWN AS
`HOWDEN BUFFALO, INC.’S AMENDED ANSWER AND
`NEW MATTER PLEADING SETTLEMENT AGREEMENT WITH PLAINTIFF
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`NOW COMES Howden North America Inc., formerly known as Howden Buffalo, Inc. and
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`files its Amended Answer and New Matter Pleading Settlement Agreement with Plaintiff and avers
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`as follows:
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`1.
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`Howden North America Inc., formerly known as Howden Buffalo, Inc. has
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`appeared and pleads the effects of Pennsylvania Rule of Civil Procedure 1041.1(c) as an
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`affirmative defense.
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`2.
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`Howden North America Inc., formerly known as Howden Buffalo, Inc. has reached
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`a settlement agreement with the plaintiff through her counsel and pleads the same as an affirmative
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`defense to all claims.
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`WHEREFORE, Howden North America Inc., formerly known as Howden Buffalo, Inc.
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`pleads release and satisfaction as an affirmative defense to all claims.
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`Dated: September 11, 2023
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`Respectfully Submitted,
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`By: /s/ Alba A. Romano
`Alba A. Romano, Esq.
`Sandra L. Alven, Esq.
`Mark E. Floyd, Esq.
`Anne M. McFadden, Esq.
`Joseph L. Orszulak, II, Esq.
`Riley, Hewitt, Witte & Romano, P.C.
`650 Washington Road, Suite 300
`Pittsburgh, PA 15228
`(412) 341-9300
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`Counsel for Howden North America Inc.,
`formerly known as Howden Buffalo, Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing pleading was served
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`upon the following counsel by e-mail, this 11th day of September, 2023.
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`Leif J. Ocheltree, Esqire
`Goldberg, Persky & White, P.C.
`11 Stanwix Street, Suite 1800
`Pittsburgh, PA 15222
`Counsel for Plaintiffs
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`and
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`All Known Defense Counsel of Record via E-mail
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`By: /s/ Alba A. Romano
`Alba A. Romano, Esq.
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