EXHIBIT A
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`[
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`IN RE: ASBESTOS LITIGATION
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`RETURN DATE: JANUARY03, 2023
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`CONRAD JOHNSand ELIZABETH JOHNS
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`VS.
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`; SUPERIOR COURT
`
`. J.D, OF FAIRFIELD
`
`- AT BRIDGEPORT
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`ALFA LAVAL,INC.; individually and as successor in
`interest to DeLaval Purifier and Sharples Corp.,;
`AURORA PUMPCO.;
`CARRIER CORP., individually and as successorin interest
`to Elliott Company;
`CLEAVER BROOKS, a division of Aqua-Chem,Inc.;
`EATON CORP; individually and as successorin interest
`to Cutler Hammer and Vickers Pump;
`ECKEL INDUSTRIES, INC.;
`EMERSON ELECTRIC CoO., individually and as successor
`in interest to E.L. Wiegand Company, Alco Valve, and
`Asco Valve;
`FMCCORPORATION?individuallyand-as-successor-m
`interest to Northern Pump, Coffin Pump, and John Beam;
`FORD MOTOR CO.;
`GENUINE PARTS COMPANY;
`HONEYWELLINTERNATIONAL,INC., individually
`and as successorin interest to Minneapolis Honeywell
`Regulator Co., Allied Signal Inc., Allied Corporation and
`Bendix Corporation;
`IMO INDUSTRIES, INC., individually and as successor in
`interest to DeLaval Steam Turbine Company;
`INTERNATIONAL BUSINESS MACHINES
`CORPORATION;
`ITT CORPORATION,individually and as successorin
`interest to Bell & Gossett, Foster Engineering, Kennedy
`Valve, Lunkenheimer, Fabre Valve, ITT Hoffman,
`HammerDahl, and ITT Fluid Products;
`JOHNSON CONTROLS, INC., individually and as
`successorin interest to Kieley & Mueller;
`METROPOLITAN LIFE INSURANCE COMPANY;
`MORSE TECLLC, f/k/a BorgWamer Morse TEC LLC,
`and successor by merger to Borg Wamer Corporation;
`NASH ENGINEERINGCO.;
`NEW ENGLANDINSULATION CO.;
`PNEUMO-ABEX CORP., individually and as successor in
`interest to Abex Corporation, American Brake Shoe, and
`American Brake Block;
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER « Ilth FLOOR © 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 = JURIS. NO. 409080
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`SPIRAX SARCO, INC.;
`SQUARE D COMPANY;
`TYCO INTERNATIONAL,
`UNION CARBIDE CORPORATION,individually and as
`successor to Amchem and Benjamin Foster;
`VIKING PUMP, INC., a unit of IDEX Corp.
`WARD LEONARD ELECTRIC COMPANY, INC.;
`WARREN PUMPS, LLC, individually and as successorin
`interest to Quimby Pump;
`WEIR VALVES & CONTROLSUSA,INC., individually
`and as successorin interest to Atwood & Morrill;
`WM. POWELL CO.;
`YORK INTERNATIONAL CORP.
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`COUNT I: (Productliability against all defendants)
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`COMPLAINT
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`: DECEMBER13, 2022
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`l.
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`The Plaintiff, CONRAD JOHNS, is a citizen of the State of Florida and
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`resides at 220 South Federal Highway, #2, Lake Worth, FL.
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`2.
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`The Plaintiff, ELIZABETH JOHNS,is a citizen of the State of Florida and
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`resides at 220 South Federal Highway, #2, Lake Worth, FL.
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`3.
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`Eachof the defendants, and/or their predecessors in interest (hereinafter
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`referred to as the “Defendants”), namedin the caption above conducted business in thestate
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`of Connecticut, has produced, manufactured or distributed asbestos and/or asbestos products
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`with the reasonable expectation that such products were so used or consumed,and/or has
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`committedthetortious acts set forth below.
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`4.
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`The employer or employersofthe Plaintiff were engaged in variousactivities
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`in which it bought and/or installed asbestos and/or asbestos products and materials.
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`5).
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`The Plaintiff, CONRAD JOHNS, was exposed to asbestos-containing
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`products while servingin the Navy from approximately 1959-1963, during his employment
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`with International Business Machines Corporation (“IBM”) in the mid-to-late 1960s, and
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER « llth FLOOR ¢ 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 * (203) 777-7799 © JURIS. NO. 409080
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`through the performance of automotive repair work on his family’s persona] vehicles. Such
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`exposure contributedin part or totally to the Plaintiff's contraction of asbestos-related
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`mesothelioma and otherasbestos-related pathologies.
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`6.
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`During the period of time set forth above, the Plaintiff was exposed to and did
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`inhale and/or ingest asbestos dust, fibers, and particles, which dust fibers, and particles came
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`from the asbestos products which were contracted for, mined, milled, processed,
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`manufactured, designed, tested, assembled, fashioned, fabricated, packaged, supplied,
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`distributed, delivered, marketed and/or sold by the defendants.
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`an
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`Uponinformation and belief, the defendants, through their agents and
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`employees, mined, processed, manufactured, designed, tested and/or packaged various
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`asbestosfibers-and/or-asbestos=containing-products-and-supphed;-distributed-delivered,
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`marketed and/or sold said asbestos-containing products and materials to such employers or to
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`others working at such jobsites for use by employees, including the Plaintiff.
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`8.
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`At all relevant times that the Plaintiff was working, the Plaintiff was exposed
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`to asbestos materials and products which, as part of the Plaintiff's employment, the Plaintiff
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`was forced to comeinto contact with and breathe, inhale, and ingest asbestos fibers and
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`particles coming from said asbestos products and materials.
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`a
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`At all times pertinent hereto, the defendants were engagedin the business of
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`contracting for, mining, milling, processing, manufacturing, designing, testing, assembling,
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`fashioning, fabricating, packaging, supplying, distributing, delivering, marketing, and/or
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`selling asbestos and asbestos products.
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`10.
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`At all times pertinent hereto, the asbestos products contracted for, mined,
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`milled, processed, manufactured, designed, tested, assembled, fashioned, fabricated,
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER « I]th FLOOR ¢ 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 ® (203) 777-7799 * JURIS. NO. 409080
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
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`packaged, supplied, distributed, delivered, marketed, and/or sold by the defendants reached
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`the Plaintiff without any substantial changein their condition from the time they were sold.
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`11.
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`The defendants have been possessed of medical and scientific data, studies
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`and reports since approximately 1929, which information clearly indicated that asbestos and
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`asbestos-containing products were hazardous to the health and safety of the Plaintiff and
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`other human beings.
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`12.
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`The defendants, during the 1930's, 1940's, 1950's, and 1960's became
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`possessed of voluminous medical and scientific data, studies and reports, which information
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`conclusively established that asbestos and asbestos-containing products were hazardousto
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`the health and safety of the Plaintiff and al] humans exposed to the products.
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`is
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`Fhe-defendants-have-since-the-1930's-had-numerous-werkers-compensation
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`claims filed against them by former asbestos workers/employees.
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`14.
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`The defendants, since the 1920's, have consistently failed to acknowledge,
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`publish, or in any way advise of studies and reports known throughoutthe industry, including
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`studies conducted by or on behalf of various defendants in the asbestos industry.
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`15.|Notwithstandingthat the defendants possessed the foregoing information, the
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`defendants wrongfully contracted for, mined milled, processed, manufactured, designed,
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`tested, assembled, fashioned, fabricated, packaged, supplied, distributed, delivered,
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`marketed, sold, handled, shipped, received, used, and/or stored asbestos products and
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`materials to the Plaintiff's employer(s) and the defendants failed to render proper, adequate
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`and correct warnings, advice, instruction and information and so acted in a grossly negligent,
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`reckless, malicious, willful and wanton manner, failed to use reasonable care underall
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`circumstances, and wrongfully acted in other respects.
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`EARLY, LUCARELL!I, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MELISENKOTHEN, LLC
`ONE CENTURY TOWER e
`I}th FLOOR © 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 ¢ (203) 777-7799 © JURIS. NO. 409080
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`16.
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`The actions of the defendants described and alleged above were wrongful
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`under Section 52-572m, et seq., in one or moreof the following ways:
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`(a)
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`Strict liability - The defendantsare strictly liable for the Plaintiffs’
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`injuries in that said asbestos-containing products were unreasonably
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`defective in one or more ofthe following ways:
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`1.
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`in that said products were and are unreasonably dangerous and
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`unavoidably unsafe, and failed to carry proper, adequate and
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`correct warnings about their hazards about which the defendant
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`knew or should have known;
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`in that said products were and are unreasonably dangerous, in
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`that-they-were-and-are-dangerous-to-an-extent-beyond-that
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`which the ordinary personin the position ofthe Plaintiff would
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`contemplate;
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`(b)
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`Negligence — The defendants knew or should have known thatsaid
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`asbestos-containing products were inherently dangerous to those who
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`were exposed to them, yet the defendants failed to use reasonable
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`and/or ordinary care in one or more ofthe following ways:
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`the defendants failed to provide proper, adequate and correct
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`warnings of the dangers of said products;
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`the defendants failed to test their products to determinethe full
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`extent of the health hazards posed by asbestos;
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`il.
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`the defendants failed to removetheir products from market
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`upon learning of the health hazards of asbestos;
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
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`
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER®llth FLOOR ® 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 » JURIS. NO. 409080
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`iv.
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`the defendants failed to find reasonably safer alternatives
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`and/or substitutes for asbestos;
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`Vv.
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`the defendants failed to market, labe] or otherwise package
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`their products in a reasonably safe mannerto prevent
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`mishandling and to prevent the release of asbestos during
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`packaging, shipping,transportation, delivery, handling and use.
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`(c)
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`Failure to warn — The defendants’ products failed to carry proper,
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`adequate and correct warnings of the hazards about which the
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`defendants knew or should have known andthat, to the extent such
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`products did carry warnings, any such warnings, information,
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`packaging;cautionsand/or’safetymstructionswereimproper-and——_}
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`inadequate.
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`i.
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`Any wamings, information and/orinstructions ofsafety
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`precautions were improper and inadequate in that, among other
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`things, they failed adequately and reasonably to apprise users,
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`handlers and persons coming into contact with said products
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`and materials of the full scope and danger to their health of
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`contact with asbestos products and materials, includingthe risk
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`of cancer and mesothelioma.
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`il.
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`It was the continuing duty of the defendants to advise and warn
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`purchasers, consumers, users and/or other persons cominginto
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`contact with their products, and all pnor purchasers,
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`consumers, users and/or other persons who cameinto contact
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER « 1Ith FLOOR ¢« 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 © JURIS. NO. 409080
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`with their products, of all dangers, characteristics, potentialities
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`and/or defects discovered subsequentto their initial marketing
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`or sale of said asbestos and asbestos products.
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`ill.
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`The defendants breached their duties to warn by:
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`a.
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`b.
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`c,
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`d.
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`€.
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`f.
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`g.
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`h,
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`failing to warn the Plaintiff and the surrounding
`communities of the dangers, characteristics, and/or
`potentialities of the product or products when they
`knew or should have knownthat the exposure to the
`product(s) would cause disease and injury;
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`failing to warn the Plaintiff and the surrounding
`communities of the dangers to whichthe Plaintiff was
`exposed when they knew or should have knownofthe
`dangers;
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`failing to exercise reasonable care to warn the Plaintiff
`and-the-surrounding-communities-ofwhat-would-be
`safe, sufficient, and properly protective clothing,
`equipment, and appliances when working with, near or
`during exposure to asbestos and asbestos products;
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`supplying asbestos or asbestos products that were
`packaged, bagged, boxed and/or supplied in packaging,
`bagging, boxes or other containers that were inadequate
`and/or improper;
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`supplying asbestos or asbestos products that were
`delivered to and reachedthe Plaintiff without adequate
`or proper handling instructions, face masks and/or
`respirators;
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`failing to test the asbestos and asbestos products in
`order to ascertain the extent of dangers involved upon
`exposure;
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`failing to conduct such research that should have been
`conducted in the exercise of reasonable care in order to
`ascertain the dangers involved upon exposure;
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`failing to removethe productor products from the
`market when the defendants knew or should have
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER »® llth FLOOR * 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 « JURIS. NO. 409080
`
`

`

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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER ° J!th FLOOR ¢ 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 « JURIS. NO. 409080
`
`
`
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`i,
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`it
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`knownof the hazards of exposure to asbestos and
`asbestos products;
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`failing upon discovery of the dangers, hazards, and
`potentialities of exposure to asbestos adequately to
`warn and apprise the Plaintiff and the surrounding
`communities of the dangers, hazards, and potentialities
`discovered;
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`generally using unreasonable, careless, negligent and
`reckless conduct in the contracting for, mining, milling
`processing, manufacturing, designing, testing,
`assembling, fashioning, fabricating, packaging,
`supplying, distributing, delivering, marketing, and/or
`selling of their asbestos and asbestos products.
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`(d)
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`Breach of warranty — The defendants breached warranties, either
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`implied or expressed, in that these products were notfit and/or safe for
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`their-known-and-intended-purposes-and-uses:
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`17.
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`As aresult of the above, the Plaintiff was caused to sustain severe, painful and
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`permanentinjuries referred to above and/or other asbestos-related pathologies caused by the
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`Plaintiff coming into contact with and breathing, inhaling and/or ingesting asbestos fibers.
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`The injuries and diseases from which the plaintiff suffered caused the Plaintiff to suffer great
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`pain, suffering, mental anxiety, distress of mind, humihation, emotional trauma and mental
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`anguish.
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`18.
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`The disease, diseases or injuries from which the Plaintiff suffered were
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`directly and proximately caused by the Plaintiff's exposure to asbestos and asbestos products
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`which were mined, milled, manufactured, designed, assembled, distributed, supplied,
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`constructed, processed, packaged, distributed, delivered, purchased and/or sold by the
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`defendants.
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
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`19.
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`As a result thereof, the Plaintiff's life span has been shortened and the
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`Plaintiff's capacity to carry on life's activities is impaired along with the Plaintiff's capacity
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`to enjoy life and family, to engage tn any gainful employment, and to participate in civic
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`affairs.
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`20.
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` Asaresult of said illness, the Plaintiff was obligated to incur expensesfor
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`medical, hospital and surgical treatment, drugs, medicines, x-rays and medical apparatus, and
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`funeral expenses.
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`21.
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`Asa furtherresult of said illness, the Plaintiffs earning capacity was
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`impaired.
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`22.
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`The foregoing acts and omissions of the defendants constitute a reckless
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`“disregardforthesafetyofproductusers;consumers-or-others-who-wereinjured-by-the
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`products, pursuant to General Statutes § 52-240b.
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`23.
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`The Plaintiffs bring this Count pursuant to Connecticut General Statutes
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`Sections 52-240a, 52-240b, and 52-572m et seq.
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`COUNTII: (Recklessness as to all Defendants)
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`].- 23. Plaintiff(s) repeat and reallege all allegations contained in all paragraphs above
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`as is fully set forth herein.
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`24.
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`The defendants have been possessed of medical and scientific data, studies
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`and reports since approximately 1929, which information indicated that asbestos and
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`asbestos-containing products were hazardous to their health and safety of the Plaintiff and
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`other humanbeings.
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`25.
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`The defendants, during the 1930’s, 1940's, 1950’s and 1960’s became
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`possessed of medical and scientific data, studies and reports, which information established
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER ® \lth FLOOR © 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 » JURIS. NO. 409080
`
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`that asbestos and asbestos-containing products were hazardousto the health and safety of the
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`Plaintiff and all humans exposed to those products.
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`26.
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`The defendants, since the 1920’s, have failed to acknowledge, publish,or in
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`any way advise of studies and reports known throughoutthe industry, including studies
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`conducted by or on behalf of various defendants in the asbestos industry.
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`27.
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`Notwithstanding that the defendants possess the foregoing information the
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`defendants committed some orall of the wrongful acts and/or omissions described and
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`alleged in paragraph 11 of the First Count.
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`28.
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`Said acts and omissions thus constitute misconductthat is grossly negligent,
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`willful, wanton, malicious and/or outrageous.
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`COUNTHE-(As-te-PlaintifPELI4ABEFH-IOHNS-and-all-_Defendants)
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`1.-28. Plaintiff(s) repeat and reallegeall allegations contained in all paragraphs above
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`as 1s fully set forth herein.
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`29.
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`As a result of the foregoing injuries and damages suffered by the Plaintiff, the
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`said Plaintiff's spouse has and will sustain damages by virtue ofhis/herloss of consortium with
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`the Plaintiff and the loss and impairmentofthe Plaintiffs services, protection, care and
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`assistance, society, companionship,affection, love, comfort, support, guidance, and kindly
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`offices and advice, and other benefits of the marital relationship.
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`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER «
`lIIth FLOOR » 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 © JURIS. NO. 409080
`
`

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`WHEREFORE,the Plaintiff, ELIZABETH JOHNS, claims damages.
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`WHEREFORE, CONRAD JOHNSand ELIZABETH JOHNS, demand judgment and
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`damages against the Defendant(s), jointly and severally, plus interest, costs, and whatever
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`other furtherrelief this Honorable Court deems right and just.
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`—
`
`THE PLAINTIFFS
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`
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`
`
`
`
`BY:
`/s/43819]
`Kyle R. Navin, Esq.
`Early, Lucarelli, Sweeney & Meisenkothen, LLC
`One Century Tower, Suite 1101
`265 Church Street
`New Haven, CT 06510
`
`(203)-779-7799
`Juris No. 409080
`Their Attorneys
`
`
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER © 1]th FLOOR © 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 © JURIS. NO. 409080
`
`
`
`
`

`

`IN RE: ASBESTOS LITIGATION
`
`RETURN DATE: JANUARY03, 2023
`CONRAD JOHNSand ELIZABETH JOHNS
`VS.
`ALFA LAVALINC., ET UX., ET AL.
`
`: SUPERIOR COURT
`| J.D. OF FAIRFIELD
`| AT BRIDGEPORT
`. DECEMBER13, 2022
`
`AD DAMNUM
`
`WHEREFORE,the Plaintiffs, CONRAD JOHNSand ELIZABETH JOGNS, claim as
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`to the defendants:
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`1. Full, fair and just money damages;
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`2. Punitive and exemplary damages,including attorney's fees;
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`
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`3-—Statutory-punitive-damages-and-reasonable-attomey's-fees-pursuant-to-Generat————_|
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`Statutes Sections 52-240a and 52-240b (First Count); and
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`4. Costs of this action.
`
`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
`
` 4
`
`Z
`CONKERSSUT STATE MAA
`INDIFFERENT PERSON ane
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER ® Ilth FLOOR ® 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 ® (203) 777-7799 ¢ JURIS. NO. 409080
`
`
`
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`
`
`

`

`
`
`
`
`IN RE: ASBESTOS LITIGATION |
`
`RETURN DATE: JANUARY03, 2023
`CONRAD JOHNS and ELIZABETH JOHNS
`VS.
`ALFA LAVAL INC., ET UX., ET AL,
`
`: SUPERIOR COURT
`, J.D. OF FAIRFIELD
`) AT BRIDGEPORT
`: DECEMBER13, 2022
`
`STATEMENT OF AMOUNT IN DEMAND
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`The amount, legal interest and property in demandis not less than $15,000.00, exclusive of
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`interest and costs.
`
`THE PLAINTIFFS
`
`
`BY—/s/438+91
`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
`
`
`
`EARLY, LUCARELL], SWEENEY & MEISENKOTHEN
`An Association of Professional LLCs
`EARLY, LUCARELLI, SWEENEY & MEISENKOTHEN, LLC
`ONE CENTURY TOWER ® 1]th FLOOR ¢ 265 CHURCH STREET
`NEW HAVEN, CONNECTICUT 06510 © (203) 777-7799 © JURIS. NO. 409080
`
`