FILED: NEW YORK COUNTY CLERK 08/26/ :23 PM INDEX NO /2015 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/26/2015

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1 FILED: NEW YORK COUNTY CLERK 08/26/ :23 PM INDEX NO /2015 NYSCEF DOC. NO. 18 RECEIVED NYSCEF: 08/26/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X JOSEPH FLEIGNER, Index No.: /15 -against- Plaintiff, VERIFIED ANSWER TO PLAINTIFF S VERIFIED COMPLAINT A.W. CHESTERTON COMPANY, et al., Defendants X Defendant, GARDNER DENVER, INC. (hereinafter GARDNER DENVER ), by its attorneys, Segal McCambridge Singer & Mahoney, Ltd., for its Answer to Plaintiff s Verified Complaint, alleges the following upon information and belief: 1. Denies all material allegations in Plaintiff s Verified Complaint as they pertain to GARDNER DENVER. 2. Denies knowledge or information sufficient to form a belief as to the truth of each and every other allegation contained in Plaintiff s Verified Complaint. WHEREFORE, Defendant GARDNER DENVER demands dismissal of the Complaint and any and all Cross-Claims. AS AND FOR A FIRST SEPARATE AND COMPLETE DEFENSE The Verified Complaint fails to state a cause of action against GARDNER DENVER. AS AND FOR A SECOND SEPARATE AND COMPLETE DEFENSE This Court lacks jurisdiction over the subject matter of this action. AS AND FOR A THIRD SEPARATE AND COMPLETE DEFENSE This Court lacks personal jurisdiction over GARDNER DENVER. 1

2 AS AND FOR A FOURTH SEPARATE AND COMPLETE DEFENSE The lawsuit was not commenced by plaintiff within the time prescribed by law and the plaintiff, therefore, is barred from recovery pursuant to applicable statutes of limitations. AS AND FOR A FIFTH SEPARATE AND COMPLETE DEFENSE The claims of plaintiff are barred by the doctrine of laches. AS AND FOR A SIXTH SEPARATE AND COMPLETE DEFENSE The damages allegedly sustained by plaintiff were caused, in whole or in part, by the negligence or other culpable conduct of plaintiff and/or other defendants, which conduct constituted a supervening cause of plaintiff s alleged injuries. AS AND FOR A SEVENTH SEPARATE AND COMPLETE DEFENSE Insofar as the Verified Complaint and each cause of action considered separately allege a cause of action occurring after September 1, 1975, each such cause of action is barred by reason of the culpable conduct attributable to plaintiff, including contributory negligence and assumption of the risk. AS AND FOR A EIGHTH SEPARATE AND COMPLETE DEFENSE Any damages allegedly sustained by the plaintiff were the proximate result of an unforeseen occurrence and/or unforeseeable negligence, gross negligence, wanton, reckless or intentional conduct constituting an intervening or superseding act or omission or other conduct by third parties. AS AND FOR A NINTH SEPARATE AND COMPLETE DEFENSE The damages allegedly sustained by plaintiff were caused, in whole or in part, by the negligence or other culpable conduct of one or more persons or instrumentalities over which GARDNER DENVER had no control and with whom it had no legal relationship. 2

3 AS AND FOR AN TENTH SEPARATE AND COMPLETE DEFENSE The damages allegedly sustained by plaintiff were caused, in whole or in part, through unavoidable natural consequences. AS AND FOR A ELEVENTH SEPARATE AND COMPLETE DEFENSE If the plaintiff sustained damages as alleged, such damages occurred while they engaged in activities into which they entered, knowing the hazard, risk and danger of the activities and they assumed the risks incidental to and attendant to the activities. AS AND FOR AN TWELFTH SEPARATE AND COMPLETE DEFENSE All claims brought under New York Law, L c. 682 Section 4 (enacted July 31, 1986) are time-barred in that said statute is in violation of the Constitution of the United States and the Constitution of the State of New York. AS AND FOR A THIRTEENTH SEPARATE AND COMPLETE DEFENSE This action cannot be maintained, as there is another action pending for the same relief. AS AND FOR A FOURTEENTH SEPARATE AND COMPLETE DEFENSE To the extent that any injury relating to plaintiff occurred in the context of an employeremployee relationship, claims for said injuries are preempted by the Workers Compensation Act. AS AND FOR A FIFTEENTH SEPARATE AND COMPLETE DEFENSE No acts or omissions of GARDNER DENVER proximately caused Plaintiff s damages. AS AND FOR A SIXTEENTH SEPARATE AND COMPLETE DEFENSE Any asbestos-containing product of or used in conjunction with products sold by GARDNER DENVER that may have been present at plaintiff s job locations were installed or configured on the basis of the specifications, approval or at the instruction of governmental or legislative agencies or other regulatory bodies. 3

4 AS AND FOR A SEVENTEENTH SEPARATE AND COMPLETE DEFENSE The damages sustained by plaintiff arising from their alleged exposure to asbestoscontaining products while working on or near the equipment or other product allegedly manufactured or sold by GARDNER DENVER (the Product ), were caused, in whole or in part, by the improper use and operation of the Product, rather than any defect in the design, manufacture, production, assemblage, installation, testing, labeling, marketing, distribution, sale or inspection of the Product by GARDNER DENVER. AS AND FOR A EIGHTEENTH SEPARATE AND COMPLETE DEFENSE The damages sustained by the plaintiff which allegedly arose from the Product were caused by its alteration, misuse and/or improper maintenance by one or more persons or instrumentalities other than GARDNER DENVER, rather than any defect in the design, manufacture, production, assemblage, installation, testing, labeling, marketing, distribution, sale or inspection of the Product by GARDNER DENVER. AS AND FOR AN NINETEENTH SEPARATE AND COMPLETE DEFENSE GARDNER DENVER is not liable for the damages allegedly sustained by plaintiff because plaintiff is not in privity of contract with GARDNER DENVER at any time and the Product was not inherently dangerous. AS AND FOR A TWENTIETH SEPARATE AND COMPLETE DEFENSE The Product was in all respects fit and suitable for its intended and reasonably foreseeable uses and was not in a defective or dangerous condition when it left GARDNER DENVER s possession and control. AS AND FOR A TWENTY-FIRST SEPARATE AND COMPLETE DEFENSE No implied warranties, including the warranties of merchantability and fitness for a particular purpose, became a part of the basis of the bargain in the sale of the Product. 4

5 AS AND FOR A TWENTY-SECOND SEPARATE AND COMPLETE DEFENSE Oral warranties upon which plaintiff allegedly relied are unavailable as violative of the provisions of the applicable Statute of Frauds. AS AND FOR A TWENTY-THIRD SEPARATE AND COMPLETE DEFENSE To the extent that plaintiff sustained injuries from the use of a product sold by GARDNER DENVER that is alleged to have contained asbestos, which is denied, plaintiff, plaintiff s decedents, other defendants or other parties not under the control of GARDNER DENVER misused, abused, misapplied and otherwise mishandled the part of the product alleged to have been asbestos material. Therefore, the amount of damages must be diminished by the proportion, which said misuse, abuse, misapplication and mishandling bears to the conduct, which allegedly caused plaintiff s damage or injury. AS AND FOR A TWENTY-FOURTH SEPARATE AND COMPLETE DEFENSE In the event it should be proven at the time of trial that all the defendants are subject to market share liability, then GARDNER DENVER s share of such liability would be of such a de minimis amount as to make its contribution for damages negligible, and GARDNER DENVER would be entitled to contribution, either in whole or in part, from co-defendants. AS AND FOR A TWENTY-FIFTH SEPARATE AND COMPLETE DEFENSE GARDNER DENVER denies that the asbestos products alleged in Plaintiff s Verified Complaint are products within the meaning and scope of the Restatement of Torts Section 402A and as such the Verified Complaint fails to state a cause of action in strict liability. AS AND FOR A TWENTY-SIXTH SEPARATE AND COMPLETE DEFENSE GARDNER DENVER had no knowledge or reason to know of any alleged risks associated with asbestos and/or asbestos-containing products at the time of sale or at any other time during plaintiff s alleged exposure. 5

6 AS AND FOR A TWENTY-SEVENTH SEPARATE AND COMPLETE DEFENSE Plaintiff did not directly or indirectly purchase any asbestos-containing products from GARDNER DENVER and, therefore, was not the recipient of an express or implied warranty made by GARDNER DENVER. AS AND FOR A TWENTY-EIGHT SEPARATE AND COMPLETE DEFENSE To the extent plaintiff was exposed to any product containing asbestos as a result of conduct by GARDNER DENVER, which is denied, said exposure was de minimis and not a substantial contributing factor to any asbestos-related disease which plaintiff may have developed, such that plaintiff s claim is not actionable at law or equity. AS AND FOR A TWENTY-NINTH SEPARATE AND COMPLETE DEFENSE Exposure to asbestos fibers allegedly attributable to GARDNER DENVER was so de minimis so as to be insufficient as a matter of law to enable plaintiff to establish to a reasonable degree of probability that the Products are capable of causing injury or damages and must be considered speculative as a matter of law. AS AND FOR A THIRTIETH SEPARATE AND COMPLETE DEFENSE Finished or otherwise encapsulated asbestos-containing products are not unreasonably dangerous as a matter of law. AS AND FOR A THIRTY-FIRST SEPARATE AND COMPLETE DEFENSE If GARDNER DENVER was on notice of any hazard or defect for which plaintiff seeks relief, which GARDNER DENVER denies, plaintiff also had such notice of the existing hazard at or about the same time as GARDNER DENVER, and is thereby is barred from recovery. AS AND FOR A THIRTY-SECOND SEPARATE AND COMPLETE DEFENSE There is no justiciable issue or controversy. 6

7 AS AND FOR A THIRTY-THIRD SEPARATE AND COMPLETE DEFENSE The claims for damages have not accrued, are purely speculative, uncertain and contingent. AS AND FOR A THIRTY-FOURTH SEPARATE AND COMPLETE DEFENSE Plaintiff s claim is barred under applicable state and federal law. AS AND FOR A THIRTY-FIFTH SEPARATE AND COMPLETE DEFENSE Plaintiff voluntarily assumed the risk of injury. AS AND FOR A THIRTY-SIXTH SEPARATE AND COMPLETE DEFENSE Plaintiff s injury was not foreseeable. AS AND FOR A THIRTY-SEVENTH SEPARATE AND COMPLETE DEFENSE GARDNER DENVER was under no duty to warn purchasers, their employees, other independent contractors, or those under their control. If such warning was required, purchaser or plaintiff s employer owed a duty to warn and their failure to do so was a superseding proximate cause of injury. AS AND FOR A THIRTY-EIGHTH SEPARATE AND COMPLETE DEFENSE Plaintiff were warned of risk of exposure to use of asbestos-containing materials and failed to take necessary or recommended precautions to prevent against the risk of injury. AS AND FOR A THIRTY-NINTH SEPARATE AND COMPLETE DEFENSE Plaintiff s claims are barred under applicable law pursuant to public policy, since social utility and benefit of asbestos-containing products outweighed the risk at the time of plaintiff s alleged exposure. AS AND FOR A FORTIETH SEPARATE AND COMPLETE DEFENSE To the extent plaintiff seeks to maintain a claim for relief on behalf of any decedent, said plaintiff lacks capacity and/or standing to maintain such claim for relief against GARDNER DENVER. 7

8 AS AND FOR A FORTY-FIRST SEPARATE AND COMPLETE DEFENSE Plaintiff s claims are barred because of Plaintiff s failure to join necessary and indispensable parties. AS AND FOR A FORTY-SECOND SEPARATE AND COMPLETE DEFENSE Plaintiff may not bring this action as they have failed to exhaust all of their administrative remedies. AS AND FOR A FORTY-THIRD SEPARATE AND COMPLETE DEFENSE Plaintiff and/or plaintiff s decedents failed to mitigate or otherwise act to lessen or reduce the injuries alleged in the Verified Complaint. AS AND FOR A FORTY-FOURTH SEPARATE AND COMPLETE DEFENSE Plaintiff s cause of action for exemplary or punitive damages is barred because such damages are not recoverable under applicable law or otherwise unwarranted in this action. AS AND FOR A FORTY-FIFTH SEPARATE AND COMPLETE DEFENSE Plaintiff s demands for punitive damages are barred by the due process clauses of the Fourteenth Amendment to the United States Constitution and the New York State Constitution. AS AND FOR A FORTY-SIXTH SEPARATE AND COMPLETE DEFENSE Plaintiff s demands for punitive damages are barred by the proscription of the Eighth Amendment to the United States Constitution, as applied to the states through the Fourteenth Amendment, and Article I, Section 5 of the New York State Constitution prohibiting the imposition of excessive fines. AS AND FOR A FORTY-SEVENTH SEPARATE AND COMPLETE DEFENSE Plaintiff s demands for punitive damages are barred by the "double jeopardy" clause of the Fifth Amendment to the United States Constitution, as applied to the states through the Fourteenth Amendment, and Article I, Section 6 of the New York State Constitution. 8

9 AS AND FOR A FORTY-EIGHTH SEPARATE AND COMPLETE DEFENSE If plaintiff sustained injuries in the manner alleged, all of which has been denied by GARDNER DENVER, the liability of GARDNER DENVER, if any, shall be limited in accordance with Article 16 of the Civil Practice Law and Rules. AS AND FOR A FORTY-NINTH SEPARATE AND COMPLETE DEFENSE At all times relevant to this litigation, GARDNER DENVER complied with all applicable law, regulations and standards. AS AND FOR A FIFTIETH SEPARATE AND COMPLETE DEFENSE Relief is barred by virtue of the doctrines of estoppel, collateral estoppel, and waiver. AS AND FOR A FIFTY-FIRST SEPARATE AND COMPLETE DEFENSE That at all times relevant to this litigation, the agents, servants and/or employees of GARDNER DENVER utilized proper methods in the conduct of its operations, in conformity with the available knowledge and research of the scientific and industrial communities, and thereby complied with the state of the art existing at all relevant times. AS AND FOR A FIFTY-SECOND SEPARATE AND COMPLETE DEFENSE Plaintiff contributed to the illness, either in whole or in part, by exposure to or the use of tobacco products and/or other substances, products, medications or drugs. AS AND FOR A FIFTY-THIRD SEPARATE AND COMPLETE DEFENSE Upon information and belief, some or all of the causes of action may not be maintained because of arbitration and award. AS AND FOR A FIFTY-FOURTH SEPARATE AND COMPLETE DEFENSE Upon information and belief, some or all of the causes of action may not be maintained because of discharge in bankruptcy. 9

10 AS AND FOR A FIFTY-FIFTH SEPARATE AND COMPLETE DEFENSE Upon information and belief, some or all of the causes of action may not be maintained because of payment. AS AND FOR A FIFTY-SIXTH SEPARATE AND COMPLETE DEFENSE Upon information and belief, some or all of the causes of action may not be maintained because of release. AS AND FOR A FIFTY-SEVENTH SEPARATE AND COMPLETE DEFENSE Upon information and belief, some or all of the causes of action may not be maintained because of res judicata. AS AND FOR A FIFTY-EIGHTH SEPARATE AND COMPLETE DEFENSE All defenses which have been or will be asserted by other defendants and/or any thirdparty defendants in this action are adopted and incorporated by reference as if fully set forth at length herein as defenses to Plaintiff s Verified Complaint. In addition, GARDNER DENVER will rely upon any and all other further defenses which become available or appear during discovery proceedings in this action and hereby specifically reserves the right to amend its answer for the purposes of asserting any such additional defenses. AS AND FOR A FIFTY-NINTH SEPARATE AND COMPLETE DEFENSE To the extent plaintiff brings suit in a representative capacity, such plaintiff has failed to allege sufficient facts to demonstrate legal capacity to sue pursuant to New York Estate Powers and Trusts Law to

11 AS AND FOR A SIXTIETH SEPARATE AND COMPLETE DEFENSE This Court lacks jurisdiction over Defendant GARDNER DENVER by reason of improper service of process. AS AND FOR A SIXTY-FIRST SEPARATE AND COMPETE DEFENSE Any alleged liability of Defendant GARDNER DENVER must be reduced by operation of GOL AS AND FOR A FIRST CROSS-CLAIM AGAINST CO-DEFENDANTS FOR INDEMNIFICATION 1. GARDNER DENVER alleges that if Plaintiffs are able to prove the existence and cause of any injuries as alleged in Plaintiff s Verified Complaint, such injuries were caused solely as a result of the negligence, carelessness, recklessness, strict liability, breach of warranty, breach of contract or other agreements and/or affirmative acts of one or more of the Co- Defendants in this matter and was not due to any culpable conduct by GARDNER DENVER. 2. If plaintiffs recover judgment and/or verdict against Defendant, GARDNER DENVER such recovery will have come about solely due to the negligence, carelessness, recklessness, strict liability, breach of contract or other agreements and/or affirmative acts of the Co-Defendants, as stated above, and not due to any culpable conduct on the part of GARDNER DENVER. 3. Co-Defendants are liable to Defendant, GARDNER DENVER for indemnification under common law and/or contract or other agreements for any and all of the judgment and/or verdict that the Plaintiffs may recover from this Defendant, GARDNER DENVER. 11

12 AS AND FOR A SECOND CROSS-CLAIM AGAINST CO-DEFENDANTS FOR CONTRIBUTION If Plaintiffs recover judgment and/or verdict from the Defendant, GARDNER DENVER, Defendant will be entitled to contribution from Co-Defendants for all or part of the damages the plaintiffs may recover against GARDNER DENVER. ANSWERS TO ALL CROSS-CLAIMS GARDNER DENVER answers all cross-claims of co-defendants, saying: All cross-claims for contribution alleged are denied. All cross-claims for indemnification alleged are denied. WHEREFORE, defendant GARDNER DENVER requests judgment in its favor dismissing the Verified Complaint, judgment in its favor and against all co-defendants for all or part of any sum awarded in favor of the plaintiff and against GARDNER DENVER and for such other and further relief as the Court may deem just and proper. Dated: New York, New York August 26, 2015 Segal McCambridge Singer & Mahoney, Ltd. Attorneys for Defendant GARDNER DENVER, INC. By: _s/nisha S. Lakhani Nisha S. Lakhani, Esq. 850 Third Avenue, 11 th Floor New York, New York (212)

13 V E R I F I C A T I O N NISHA S. LAKHANI, an attorney duly admitted to practice in the Courts of the State of New York and designated as attorney for the defendant GARDNER DENVER, INC. (hereinafter GARDNER DENVER ), affirms the following statements to be true under the penalties of perjury, pursuant to Rule 2106 of the CPLR: That she has read the foregoing ANSWER and knows the contents thereof; that the same is true to her own knowledge, except as to the matters therein stated to be alleged upon information and belief, and that as to those matters she believes them to be true. Affiant further says that the source of her information and the grounds of her belief are derived from the files, books and records maintained in the normal course of business of the Law Offices of Segal McCambridge Singer & Mahoney, Ltd., and statements made to him by officers or agents of GARDNER DENVER. This Verification is made by affiant and not by defendant because defendant resides outside the County of New York where affiant maintains his office. Dated: New York, New York August 26, 2015 By s/nisha S. Lakhani Nisha S. Lakhani, Esq. 13

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