`
`HENRY J. DOTSON and VENEDA
`
`CIVIL DIVISION - ASBESTOS
`
`DOTSON, his wife,
`
`v.
`
`Plaintiffs,
`
`GD No. 97-019688
`
`Issue No.
`
`MOTION FOR SUMMARY JUDGMENT
`
`ALLIED GLOVE CORPORATION, et al.,
`
`Defendants.
`
`Code: 012
`
`Filed on behalf of Defendant,
`ALLIED GLOVE CORPORATION
`
`Counsel of record for this party:
`
`Stephen R. Mlinac, Esquire
`PA ID. #23591
`
`Anne L. Wilcox, Esquire
`PA ID. #88828
`
`Kristy L. Eiter, Esquire
`PA ID. #94118
`
`SWARTZ CAMPBELL, LLC
`Firm #765
`
`4750 US. Steel Tower
`
`600 Grant Street
`
`Pittsburgh, PA 15219
`(412) 232-9800
`
`,.,. (I,
`,
`,
`,
`icing; SI NJ JL
`
`Bl
`
`JURY TRIAL DEMANDED
`
`
`
`IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
`CIVIL DIVISION — ASBESTOS
`
`HENRY J. DOTSON and VENEDA
`
`DOTSON, his wife,
`
`Plaintiffs,
`
`GD No. 97-019688
`
`v.
`
`ALLIED GLOVE CORPORATION,
`
`et aI.,
`
`Defendants.
`
`MOTION FOR SUMMARY JUDGMENT
`
`AND NOW, comes ALLIED GLOVE CORPORATION, a Defendant in the above-
`
`captioned matter, by and through their attorneys, Swartz Campbell, LLC, and moves this
`
`Honorable Court for summary judgment pursuant to Pa. R.C.P. 1035 and in support
`
`thereof avers as follows:
`
`1.
`
`Plaintiffs have filed
`
`a Complaint
`
`in
`
`this matter alleging that
`
`the
`
`Plaintiff/Husband was injured from his use and exposure to asbestos-containing products
`
`of the various Defendants during his employment as a laborer at US. Steel Duquesne
`
`Works from 1967 until 1985.
`
`2.
`
`This Defendant is a manufacturer of gloves primarily and it has been averred
`
`that said Defendant supplied certain asbestos gloves to the Plaintiff/Husband's work site.
`
`3.
`
`There is no evidence in the record ofthis matter of Plaintiff/Husband working
`
`with or around any gloves manufactured and/or supplied by Defendant, ALLIED GLOVE
`
`CORPORATION.
`
`
`
`4.
`
`Consequently, there exists no genuine issue of material fact and/or evidence
`
`indicating that the Plaintiff/Husband was exposed to any asbestos—containing product
`
`manufactured by Defendant, ALLIED GLOVE CORPORATION.
`
`WHEREFORE, Defendant, ALLIED GLOVE CORPORATION, respectfuin requests
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`that summary judgment be entered in its favor and that Plaintiffs' Complaint and all
`
`crossclaims against Defendant, ALLIED GLOVE CORPORATION, be dismissed with
`
`prejudice.
`
`Respectfully submitted,
`
`SWARTZ CAMPBELL, LLC
`
`By
`
`Anne L. Wilcox, Esquire
`
`Attorneys for Defendant,
`ALLIED GLOVE CORPORATION
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Anne L. Wilcox, Esquire, hereby certify that a true and correct copy of the
`
`foregoing Motion for Summary Judgment has been served this
`
`.
`
`day of October,
`
`2006, by hand delivery to the following counsel of record:
`
`Holly L. Deihl, Esquire
`Goldberg, Persky & White RC.
`1030 Fifth Avenue
`
`Pittsburgh, PA 15219-6295
`
`with notice of same via electronic mail to all known defense counsel.
`
`SWARTZ CAMPBELL, LLC
`
`331%”
`
`Anne L. Wilcox, Esquire
`
`Attorneys for Defendant.
`Allied Glove Corporation
`
`



