`
`ASB-FBT-CV23-6120092-S
`
`CONRAD JOHNS and ELIZABETH
`JOHNS
`
`VS.
`
`
`
`ALFA LAVAL INC., ET UX., ET AL.
`
`:
`:
`:
`:
`:
`:
`:
`:
`:
`
`SUPERIOR COURT
`
`JUDICIAL DISTRICT
`
`OF FAIRFIELD
`AT BRIDGEPORT
`
`MARCH 6, 2023
`
`MOTION TO CITE IN PARTY DEFENDANT
`
`The undersigned represents as follows:
`
`1.
`
` This action was commenced by summons and complaint returnable to this Court on
`
`January 03, 2023.
`
`2. There are thirty (30) party defendants named in the original complaint.
`
`3. The plaintiffs allege that said party defendants manufactured or supplied asbestos
`
`containing products that caused the injuries for which the plaintiffs seek compensation.
`
`4. Plaintiffs seek to name the ONE (1) entity listed below as an additional party defendant
`in this action:
`
`SCHNEIDER ELECTRIC USA INC., individually and as successor to Square D
`
`ORAL ARGUMENT NOT REQUESTED
`TESTIMONY NOT REQUIRED
`
`
`
`5. It will be alleged that the entity below engaged in the same tortious acts or omissions
`
`toward the plaintiffs as the current defendants in the case, thereby proximately causing the plaintiff’s
`
`injuries.
`
`Wherefore, the undersigned moves that the plaintiffs’ complaint be amended to state
`
`facts showing the interests of the defendant listed below in this action, and that they be summoned to
`
`appear herein as a co-defendant.
`
`SCHNEIDER ELECTRIC USA INC., individually and as successor to Square D
`
` THE PLAINTIFFS
`
`BY: /s/438191
`Kyle R. Navin, Esq.
`Early, Lucarelli, Sweeney & Meisenkothen, LLC
`One Century Tower, Suite 1101
`265 Church Street
`New Haven, CT 06510
`(203) 777-7799
`Juris No. 409080
`Their Attorneys
`
`
`
`ORDER
`
`It appearing that the foregoing motion should be granted, it is hereby
`
`ORDERED that on or before
`
` , the plaintiffs amend their
`
`complaint to state facts showing the interests of the entities listed below to appear as defendants in
`
`this action on or before the second day following
`
`
`
`, by causing some
`
`proper officer to serve on them in the manner prescribed by law, a true and attested copy of this
`
`Order, a true and attested or certified copy of the complaint in this action, as amended, and a
`
`Summons-Civil Form 103.1 and due return make.
`
`SCHNEIDER ELECTRIC USA INC., individually and as successor to Square D
`
`.
`
`BY THE COURT (
`
`
`
`, J.)
`
`Clerk / Assistant Clerk
`
`
`
`CERTIFICATION
`
`This is to certify that a copy of the foregoing was served, via electronic mail, to all counsel of
`
`record on this 6th day of March, 2023.
`
`BY
`
`s/438191
`Kyle R. Navin
`
`
`
` IN RE: ASBESTOS LITIGATION
`
`ASB-FBT-CV23-6120092-S
`
`CONRAD JOHNS and ELIZABETH
`JOHNS
`
`VS.
`
`
`
`ALFA LAVAL INC., ET UX., ET AL.
`
`:
`:
`:
`:
`:
`:
`:
`:
`:
`
`SUPERIOR COURT
`
`JUDICIAL DISTRICT
`
`OF FAIRFIELD
`AT BRIDGEPORT
`
`MARCH 6, 2023
`
`MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF’S
`MOTION TO CITE IN PARTY DEFENDANT
`
`The above captioned plaintiffs, pursuant to Practice Book Section 9-22, are seeking to add
`
`the following one (1) additional defendant, listed on the following page, to the pending lawsuit for
`
`plaintiffs’ injuries due to asbestos exposure. The plaintiffs allege that said party defendant also
`
`manufactured or supplied asbestos containing products that caused the injuries for which this action
`
`seeks damages.
`
`All persons with an interest in the subject of an action may be joined as defendants. Conn.
`
`Gen. Stat. Section 52-101. The party that plaintiffs seek to add is similarly situated to all the other
`
`defendants in this pending lawsuit. All other defendants manufactured or supplied asbestos
`
`containing products which caused the plaintiffs injuries and are named pursuant to the Connecticut
`
`Product Liability Action (P.A. 79-483) Conn. Gen. Stat. Section 52-572m et seq.
`
`
`
`Wherefore, the undersigned moves that the plaintiffs’ complaint be amended to state facts showing
`
`the interests of the one (1) entity listed below, in this action, and that they be summoned to appear as
`
`co-defendant.
`
`SCHNEIDER ELECTRIC USA INC., individually and as successor to Square D
`
`.
`
`THE PLAINTIFFS
`
`BY: /s/438191
`Kyle R. Navin, Esq.
`Early, Lucarelli, Sweeney & Meisenkothen, LLC
`One Century Tower, Suite 1101
`265 Church Street
`New Haven, CT 06510
`(203) 777-7799
`Juris No. 409080
`Their Attorneys
`
`
`
`CERTIFICATION
`
`This is to certify that a copy of the foregoing was served, via electronic mail, to all counsel of
`
`record on this 6th day of March, 2023.
`
`
` s/438191
`Kyle R. Navin
`
`
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