Answer: John Sullivan and GAIL SULLIVAN v. A.O. Smith Water Products Co.,, Amchem Products, Inc.,, Atwood & Morrill Company, Bw/Ip, Inc. And Its Wholly Owned Subsidiaries, Cbs Corporation, F/K/A Viacom Inc.,, Certainteed Corporation,, Cleaver Brooks Company, Inc, Columbia Boiler Company Of Pottstown, Crown Boiler Co.,, Electrolux Home Products, Inc., Flowserve Us, Inc., Fmc Corporation,, Fort Kent Holdings, Inc.,, Foster Wheeler, L.L.C.,, General Electric Company, Georgia Pacific Llc.,, Goulds Pumps, Inc.,, Grinnell Llc,, Honeywell International, Inc.,, Itt Industries, Inc., Itt Industries, Inc.,, Mack Trucks, Inc.,, Morse Diesel, Inc.,, Navistar, Inc., A/K/A International, Owens-Illinois, Inc.,, Peerless Industries, Inc.,, Pfizer, Inc. (Pfizer),, Rheem Manufacturing Company, Tishman Liquidating Corp, Tishman Realty & Construction Co., Inc.,, U.S. Rubber Company (Uniroyal),, Union Carbide Corporation, Utica Boilers, Inc.,, Warren Pumps, Llc, Weil-Mclain, A Division Of The Marley-Wylain Company,

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                                FILED:         NEW     YORK       COUNTY        CLERK        12/29/2016             02:00        PM                 INDEX    NO.   190384/2016
   NYSCEF     DOC.   NO.   2                                                                                  RECEIVED      NYSCEF:     12/29/2016




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF NEW YORK
                                                                                      X
                  IN RE            NEW YORK CITY
                                   ASBESTOS         LITIGATION
                                                                                      X
                  THIS DOCUMENT RELATES TO:
                                                                                                Index No.     190384/16

                             JOHN SULLIVAN                                                      ANSWER         AND
                                                                                                ACKNOWLEDGMENT
                                                                                                OF RECEIPT          OF
                                                                                                WARREN         PUMPS       LLC

                                                                                      X

                                    Defendant Warren Pumps LLC, (“Warren Pumps”) by its attorneys, Leader &

                  Berkon LLP, hereby acknowledges receipt of the summons and verified complaint of Plaintiff in

                  the above-captioned action (“Complaint”) and answers said Complaint as follows:

                                    1.       Warren Pumps denies knowledge or information sufficient to form a belief

                  as to the truth of the allegations contained in paragraphs 1 through 15 of the Complaint.

                                    2.       Warren Pumps denies the allegations contained in paragraph 16 of the

                  Complaint.

                                    Warren Pumps hereby further answers the Complaint by reference to its Standard

                  Answer filed pursuant to the governing NYCAL Case Management Order and raises against

                  Plaintiffs each affirmative defense contained in its Standard Answer.




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                                    Warren Pumps hereby raises the cross-claim contained in its Standard Answer.

                  Dated:   New York, New York
                            December 29, 2016


                                                                                 LEADER & BERKON LLP


                                                                        By:      /s/ David J. Goodearl
                                                                                 DAVID J. GOODEARL
                                                                                 Attorneys for Defendant
                                                                                 Warren Pumps LLC
                                                                                 630 Third Avenue
                                                                                 New York, New York 10017
                                                                                 (212) 486-2400




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