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`STATE OF CONNECTICUT
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`DOCKET NO.: ASB-FBT-CV23-6120092-S
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`CONRAD JOHNS AND ELIZABETH JOHNS
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`Plaintiffs
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`Defendants
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`ALFA LAVAL INC., ET UX., et al.,
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`SUPERIOR COURT
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`J.D. OF FAIRFIELD
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`AT BRIDGEPORT
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`May 12, 2023
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`ANSWER, SPECIAL DEFENSES AND CROSS CLAIM OF DEFENDANT,
`DAP, INC. K/N/A LA MIRADA PRODUCTS CO., INC.,
`TO PLAINTIFFS’ THIRD AMENDED COMPLAINT
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`Defendant, DAP, INC. K/N/A LA MIRADA PRODUCTS CO., INC., (hereinafter “DAP”
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`or “Defendant”), plead as DAP, Inc., hereby responds to Plaintiffs, Conrad Johns and Elizabeth
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`Johns, Complaint, dated March 29,2023, (hereinafter “Plaintiffs’ Complaint” or the “Complaint”)
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`as follows:
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`COUNT I
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`1.
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`Defendant, DAP, denies any knowledge or information sufficient to form a belief
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`as to each and every allegation contained in Paragraph “1” of Plaintiffs’ Complaint and therefore
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`leaves Plaintiffs to their proof.
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`2.
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`Defendant, DAP, denies any knowledge or information sufficient to form a belief
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`as to each and every allegation contained in Paragraph “2” of Plaintiffs’ Complaint and therefore
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`leaves Plaintiffs to their proof.
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`3.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “3” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`4.
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`Defendant, DAP, denies any knowledge or information sufficient to form a belief
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`as to each and every allegation contained in Paragraph “4” of Plaintiffs’ Complaint and therefore
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`leaves Plaintiffs to their proof.
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`5.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “5” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`6.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “6” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`7.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “7” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`8.
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`Defendant, DAP, denies any knowledge or information sufficient to form a belief
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`as to each and every allegation contained in Paragraph “8” of Plaintiffs’ Complaint and therefore
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`leaves Plaintiffs to their proof.
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`9.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “9” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`10.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “10”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`11.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “11”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`12.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “12”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`13.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “13”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`14.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “14”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`15.
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`The allegations in Paragraph “15” of Plaintiffs’ Complaint call for a legal
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`conclusion, and DAP refers all legal conclusions to the Court. To the extent that any further
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`response is required of DAP, DAP denies each and every allegation contained in Paragraph “15”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`16.
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`Defendant, DAP, denies each and every allegation contained in Paragraphs
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`“16(a)” through “16(d)” of Plaintiffs’ Complaint as it pertains to this answering Defendant and
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`denies any knowledge or information sufficient to form a belief as to the truth of the allegations
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`contained in the aforesaid paragraphs as they pertain to the remaining Defendants in Plaintiffs’
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`Complaint.
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`17.
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`Defendant, DAP, denies any knowledge or information sufficient to form a belief
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`as to each and every allegation contained in Paragraph “17” of Plaintiffs’ Complaint and therefore
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`leaves Plaintiffs to their proof.
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`18.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “18”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`19.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “19”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`20.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “20”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`21.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “21”
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`of Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`22.
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`The allegations in Paragraph “22” of Plaintiffs’ Complaint state legal conclusions
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`to which no response is required. To the extent that a response is required of DAP, DAP denies
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`the allegations that are asserted in Paragraph “22” of Plaintiffs’ Complaint to the extent they are
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`directed towards it. DAP is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations asserted in Paragraph “22” of Plaintiffs’ Complaint that are not directed
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`towards it, therefore leaving Plaintiffs to their proof.
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`23.
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`The allegations in Paragraph “23” of Plaintiffs’ Complaint state legal conclusions
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`to which no response is required. To the extent that a response is required of DAP, DAP denies
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`the allegations that are asserted in Paragraph “23” of Plaintiffs’ Complaint to the extent they are
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`directed towards it. DAP is without sufficient knowledge or information to form a belief as to the
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`truth of the allegations asserted in Paragraph “23” of Plaintiffs’ Complaint that are not directed
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`towards it, therefore leaving Plaintiffs to their proof.
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`COUNT II
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`1-23. Defendant, DAP, herein repeats, reiterates and realleges each and every answer to
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`Paragraphs 1 through 23 of Plaintiffs’ Complaint, dated March 29, 2023.
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`24. Defendant, DAP, denies each and every allegation contained in Paragraph “24” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraph as it pertains to the remaining Defendants in Plaintiffs’ Complaint.
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`25. Defendant, DAP, denies each and every allegation contained in Paragraph “25” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`26.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “26” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`27.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “27” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`28.
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`Defendant, DAP, denies each and every allegation contained in Paragraph “28” of
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`Plaintiffs’ Complaint as it pertains to this answering Defendant and denies any knowledge or
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`information sufficient to form a belief as to the truth of the allegations contained in the aforesaid
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`paragraphs as they pertain to the remaining Defendants in Plaintiffs’ Complaint.
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`COUNT III
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`1-28. Defendant, DAP, herein repeats, reiterates and realleges each and every answer to
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`Paragraphs 1 through 28 of Plaintiffs’ Complaint.
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`29.
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`The allegations in Paragraph “29” of Plaintiffs’ Complaint call for a legal
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`conclusion, and DAP refers all legal conclusions to the Court. To the extent that any furthers
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`response is required of DAP, DAP denies the allegations that are asserted in Paragraph “29” of
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`Plaintiffs’ Complaint to the extent they are directed towards it. DAP is without sufficient
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`knowledge or information to form a belief as to the truth of the allegations asserted in Paragraph
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`“29” of Plaintiffs’ Complaint that are not directed towards it, therefore leaving Plaintiffs to their
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`proof.
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`SPECIAL DEFENSES TO ALL COUNTS
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`FIRST SPECIAL DEFENSE
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`Each and every material allegation of Plaintiffs’ Complaint is denied except as specifically
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`admitted.
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`SECOND SPECIAL DEFENSE
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`Plaintiffs are not entitled to the damages claimed or to the relief requested.
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`THIRD SPECIAL DEFENSE
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`Plaintiffs’ Complaint is barred by the applicable statute of limitations.
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`FOURTH SPECIAL DEFENSE
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`Plaintiffs’ Complaint is barred by the applicable statute of repose.
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`FIFTH SPECIAL DEFENSE
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`Plaintiffs’ breach of warranty claims are barred for lack of privity.
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`SIXTH SPECIAL DEFENSE
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`Plaintiffs’ warranty claims are barred by reason of the failure of Plaintiffs to give
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`reasonable notice of the alleged breaches.
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`SEVENTH SPECIAL DEFENSE
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`Plaintiffs’ alleged injury or damage was not caused by any act or omission of this
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`Defendant. Such injury or damage, if any, was caused by the intervening act(s) or omission(s) of
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`persons or entities other than this Defendant.
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`EIGHTH SPECIAL DEFENSE
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`The Court lacks personal jurisdiction over this Defendant.
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`NINTH SPECIAL DEFENSE
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`The Court lacks subject matter jurisdiction over the causes of action in Plaintiffs’
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`Complaint.
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`TENTH SPECIAL DEFENSE
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`Each and every count of Plaintiffs’ Complaint fails to state a cause of action for which
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`relief can be granted.
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`ELEVENTH SPECIAL DEFENSE
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`Plaintiffs have failed to join all necessary parties for the just adjudication of this matter and
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`has further omitted reason for such failure.
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`TWELFTH SPECIAL DEFENSE
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`Service of process on this Defendant was improper and insufficient.
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`THIRTEENTH SPECIAL DEFENSE
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`The doctrine of strict liability in tort is inapplicable to Plaintiffs’ claims against this
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`Defendant.
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`FOURTEENTH SPECIAL DEFENSE
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`Plaintiffs willingly, knowingly and voluntarily assumed the risk of the alleged injuries
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`for which relief is now sought.
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`FIFTEENTH SPECIAL DEFENSE
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`Plaintiffs are not in the exercise of due care and the negligence of Plaintiffs contributed to
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`or caused the injury or damage complained of in whole or in part.
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`SIXTEENTH SPECIAL DEFENSE
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`If Plaintiffs have settled with and/or released other defendants or entities who are
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`tortfeasors, this Defendant is entitled to a reduction of any judgment, either in the total of all the
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`settlement amounts or the pro-rata share of fault of said tortfeasors as determined by the Court or
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`jury - whichever is greater.
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`SEVENTEENTH SPECIAL DEFENSE
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`The products of this Defendant from which Plaintiffs claims injury or damage were
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`materially altered after the sale of said product.
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`EIGHTEENTH SPECIAL DEFENSE
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`This Defendant is not liable as a matter of law because its product was manufactured in
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`accordance with contract specifications of a third-party.
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`NINETEENTH SPECIAL DEFENSE
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`This Defendant is not liable as a matter of law because its product was manufactured in
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`accordance with contract specification of the United States government.
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`TWENTIETH SPECIAL DEFENSE
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`Plaintiffs’ claims against this Defendant are barred by the exclusivity provision of the
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`Connecticut Workers’ Compensation Act, Conn. Gen. Stat. § 31-284.
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`TWENTY-FIRST SPECIAL DEFENSE
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`Plaintiffs’ alleged injuries and damages were cause by the abnormal and unintended use
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`of this Defendant's product(s).
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`TWENTY-SECOND SPECIAL DEFENSE
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`Plaintiffs’ employer and/or the purchaser of this Defendant’s product(s) possessed a high
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`degree of knowledge and sophistication and had equal or superior means and ability to appreciate
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`and warn of any hazards concerning the use of this Defendant’s product(s).
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`TWENTY-THIRD SPECIAL DEFENSE
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`At all relevant times the state of medical and scientific knowledge and the state of art and
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`design and manufacture of Defendant’s products was such that this Defendant neither knew nor
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`should have known that any of its products presented a health risk.
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`TWENTY-FOURTH SPECIAL DEFENSE
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`Plaintiffs have released, settled, entered into an accord and satisfaction or otherwise
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`compromised the claims herein.
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`TWENTY-FIFTH SPECIAL DEFENSE
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`Plaintiffs’ claims are barred by the doctrine of laches.
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`TWENTY-SIXTH SPECIAL DEFENSE
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`The imposition of punitive damages as to this Defendant would violate public policy and
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`our United States Constitution as the imposition of punitive damages will serve no deterrent effect
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`and would be duplicative and excessive in nature.
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`TWENTY-SEVENTH SPECIAL DEFENSE
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`Plaintiffs failed to mitigate or otherwise act to lessen or reduce the injuries and damages
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`alleged in Plaintiffs’ Complaint.
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`TWENTY-EIGHTH SPECIAL DEFENSE
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`This Defendant gave no warranties, express or implied, to Plaintiffs or to anyone acting on
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`Plaintiffs’ behalf.
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`TWENTY-NINTH SPECIAL DEFENSE
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`As a bulk supplier of a product, this Defendant reasonably relied on purchasers and/or
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`intermediaries to warn of risks or hazards associated with the product.
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`THIRTIETH SPECIAL DEFENSE
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`This Defendant cannot be held responsible for products manufactured, sold and
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`distributed by third-parties over which This Defendant had no responsibility or control.
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`THIRTY-FIRST SPECIAL DEFENSE
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`Plaintiffs knew or reasonably should have known of the potential dangers associated with
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`This Defendant’s products and therefore This Defendant's alleged failure to warn Plaintiffs has no
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`causal connection to Plaintiffs’ injuries.
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`THIRTY-SECOND SPECIAL DEFENSE
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`Plaintiffs’ alleged exposure to asbestos as a result of working with or around this
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`Defendant’s product(s) - which this Defendant vigorously denies - was so minimal as to be
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`insufficient to establish a reasonable degree of probability that the product(s) caused Plaintiffs’
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`alleged injuries.
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`THIRTY-THIRD SPECIAL DEFENSE
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`This Defendant is entitled to a set-off of any verdict in the amount of compensation
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`Plaintiffs have received as a result of any claim for workers' compensation benefits.
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`THIRTY-FOURTH SPECIAL DEFENSE
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`Plaintiffs’ claims are barred by the doctrines of estoppel and waiver.
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`THIRTY-FIFTH SPECIAL DEFENSE
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`This Defendant denies that it manufactured, sold, or distributed any products which
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`allegedly caused Plaintiffs’ injuries.
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`THIRTY-SIXTH SPECIAL DEFENSE
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`Plaintiffs’ employer was in control and possession of Plaintiffs’ worksite and responsible
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`for maintaining a safe work environment, to the exclusion of this Defendant, and failed to do so,
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`thereby breaking the chain of causation between this Defendant and Plaintiffs’ alleged injuries.
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`THIRTY-SEVENTH SPECIAL DEFENSE
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`Each Plaintiff is a user of tobacco products despite being aware of the dangers of using
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`such products and such use caused or contributed to any injuries or damages Plaintiffs seek
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`compensation for in this matter.
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`THIRTY-EIGHTH SPECIAL DEFENSE
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`Plaintiffs’ Complaint should be dismissed because it was filed in an improper venue.
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`THIRTY-NINTH SPECIAL DEFENSE
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`Plaintiffs’ Complaint should be dismissed pursuant to the doctrine of forum non-
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`conveniens.
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`FORTIETH SPECIAL DEFENSE
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`To the extent that there is a prior pending action between the parties, this case should be
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`dismissed as a matter of law.
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`FORTY-FIRST SPECIAL DEFENSE
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`Pursuant to Connecticut choice of law principles, the law of Connecticut is inapplicable
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`and the law of an alternate forum should be applied.
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`FORTY-SECOND SPECIAL DEFENSE
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`This Defendant reserves the right to assert any and all applicable special defenses that
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`discovery may reveal as appropriate.
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`FORTY-THIRD SPECIAL DEFENSE
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`This Defendant avails itself of and adopts such other defenses as raised by any other
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`Defendant as may be appropriate.
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`DEFENDANT / CROSS-CLAIM PLAINTIFF, DAP, CROSS-CLAIMS
`AGAINST ALL DEFENDANTS AND THIRD-PARTY DEFENDANTS
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`Plaintiffs in this action have filed a Complaint against the Defendant/Cross Claim
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`1.
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`Plaintiff alleging that Plaintiffs sustained certain asbestos-related diseases and other injuries, and
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`all said allegations have been denied by Defendant/Cross-Claim Plaintiff.
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`2.
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`Although the Defendant, DAP, denies all the claims set forth in Plaintiffs’
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`Complaint, in the event that this Defendant is found liable to Plaintiffs, then all other Cross-Claim
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`Defendants in this matter are liable for equitable contribution and/or statutory contribution
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`pursuant to Conn. Gen. Stat § 52-572o, and/or allocation of fault.
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`3.
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`Only in the event Defendant, DAP, is found liable to Plaintiffs for purposes of this
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`cross-claim, all allegations set forth in Plaintiffs’ Complaint or related Third-Party Complaints
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`against said Defendants are adopted and incorporated as set forth fully herein.
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`4.
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`Only in the event that Defendant, DAP, is found liable to Plaintiffs, in whole or in
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`part, then the Cross-Claim Defendants are liable to this Defendant for all or part of Plaintiffs’
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`claimed damages.
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`WHEREFORE, the Defendant/Cross-Claim Plaintiff claims:
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`a. contribution for Plaintiffs’ alleged damages pursuant to Conn. Gen. Stat. § 52-572o;
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`b. equitable contribution from the Cross-Claim Defendants for their share of any
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`judgment rendered in favor of Plaintiff;
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`c. an allocation of responsibility among Defendants; and
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`d. such other relief as the Court may deem just and proper.
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`ANSWER TO ANY AND ALL CURRENT AND FUTURE CROSS-CLAIMS
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`DAP denies each and every allegation of each and every cross-claim that was or hereinafter
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`may be filed against it, refers all questions of law to the Court, and leaves the Cross-Claim
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`Plaintiff(s) to their proof.
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`WHEREFORE, DAP demands judgment dismissing Plaintiffs’ Complaint with costs,
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`disbursements and attorneys’ fees; awarding judgment against Plaintiffs and/or Co-Defendants for
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`the full amount of any verdict judgment or for a proportionate share thereof that Plaintiffs may
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`recover against DAP; and for such other relief as this Court may deem just and proper.
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`LANDMAN CORSI BALLAINE & FORD P.C.
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`By:
` Andrew J. Kornblau, Esq.
` Attorneys for Defendant - DAP, Inc. k/n/a La
` Mirada Products Co., Inc.
` 1617 JFK Boulevard, Suite 955
` Philadelphia, PA 19103
` -and-
` One Gateway Center, 22nd Floor
` Newark, NJ 07102
` -and-
` 120 Broadway, 13th Floor
` New York, NY 10271
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`CERTIFICATION
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`This is to certify that a copy of the foregoing delivered via electronic mail, on this 12 May
`2023, to the following counsel of record:
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`Christoptheir Meisenkothen, Esq.
`Early, Lucarelli, Sweeney & Meisenkothen, LLC
`One Century Tower, 11th Floor
`265 Church Street
`New Haven, CT 06508-1866
`cmeisenkothen@elslaw.com
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`and served via CTServList to all defense counsel of record.
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`LANDMAN CORSI BALLAINE & FORD P.C.
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`By:
` Andrew J. Kornblau, Esq.
` Attorneys for Defendant - DAP, Inc. k/n/a La
` Mirada Products Co., Inc.
` 1617 JFK Boulevard, Suite 955
` Philadelphia, PA 19103
` -and-
` One Gateway Center, 22nd Floor
` Newark, NJ 07102
` -and-
` 120 Broadway, 13th Floor
` New York, NY 10271
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