`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION - ASBESTOS
`
`Case No.: GD-23-008748
`
`
`ANN L. ROCKWELL,
`Administratrix of the Estate of
`ROBERT W. EARLEY, deceased
`and ANN L. ROCKWELL, in her
`own right,
`
`Plaintiff,
`
`v.
`
`
`
`PRAECIPE FOR ENTRY OF
`APPEARANCE
`
`A.O. SMITH CORPORATION, et
`al.,
`
`Defendants.
`
`
`
`Filed on behalf of Defendant
`CARVER PUMP COMPANY
`
`Counsel of Record for This Party:
`Liza A. Stagliano, Esquire
`PA I.D. #90396
`
`LEWIS BRISBOIS BISGAARD &
`SMITH LLP
`550 E. Swedesford Road, Suite 270
`Wayne, PA 19087
`Telephone: (215) 97-.4100
`Facsimile: (215) 977-4101
`Liza.Stagliano@lewisbrisbois.com
`
`
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION - ASBESTOS
`
`
`
`
`Case No.: GD-23-008748
`
`
`
`
`
`
`ANN L. ROCKWELL,
`Administratrix of the Estate of
`ROBERT W. EARLEY, deceased
`and ANN L. ROCKWELL, in her
`own right,
`
` Plaintiff,
`
`
`
`
`v.
`
`A.O. SMITH CORPORATION, et
`al.,
`
`Defendants.
`
`
`
`PRAECIPE FOR ENTRY OF APPEARANCE
`
`TO: DEPARTMENT OF COURT RECORDS
`
`The undersigned herby enters an appearance as counsel of record for Defendant,
`
`Carver Pump Company, in the above-captioned case.
`
`Pursuant to Rule 1041.1 of the Pennsylvania Rules of Court, this Praecipe of
`
`Appearance also constitutes this Defendant’s denial of all averments alleged in the complaint,
`
`any and all amended complaints, any third party complaints and/or cross-claims asserted by any
`
`Plaintiff or Defendant.
`
`This Praecipe of Appearance also constitutes assertions of all affirmative defenses
`
`available to this Defendant in the defense of these matters.
`
`Defendant also reserves the right to seek contribution and/or indemnity against any
`
`party and to pursue all rights or remedies available to it.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`
` By: /s/ Liza A. Stagliano
`Liza A. Stagliano, Esquire
`
`Attorney for Defendant,
`Carver Pump Company
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of within PRAECIPE FOR ENTRY OF
`
`APPEARANCE was served this 1st day of August, 2023, on the following Plaintiff’s counsel of
`
`record via electronic mail, with notice of service of the same provided to all defense counsel of
`
`record by electronic mail, as follows:
`
`
`Leif J. Ocheltree, Esquire
`Goldberg Persky & White, PC
`11 Stanwix Street, Suite 1800
`Pittsburgh, PA 15222
`pghgroup@gpwlaw.com
`
`Attorneys for Plaintiff
`
`
`
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`
` By: /s/ Liza A. Stagliano
`Liza A. Stagliano, Esquire
`
`Attorney for Defendant,
`Carver Pump Company
`
`
`
`
`
`
`
`
`
`
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