`NYSCEF DOC. NO. 41
`
`INDEX NO. 190011/2024
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`RECEIVED NYSCEF: 02/22/2024
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`
`
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`New York City
`Asbestos Litigation (NYCAL)
`
`Index No. 190011/2024
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`ACKNOWLEDGEMENT OF
`SERVICE
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`
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`--------------------------------------------------------------x
`In Re: New York City
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`Asbestos Litigation
`--------------------------------------------------------------x
`This Document Relates To:
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`DENNIS KILKENNY and PATRICIA KILKENNY,
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`
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`Plaintiffs,
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`
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`vs.
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`
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`AII ACQUISITION, LLC, et al.,
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`Defendants.
`--------------------------------------------------------------x
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`Defendant Philips Electronics North America Corporation, named in the complaint as
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`
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`“Philips Electronics North America Corporation” and “Phillips Electronics North America Corp.
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`(Individually and as Successor to Magnavox)” by its attorneys, Morgan, Lewis & Bockius LLP,
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`acknowledges receipt of the summons and complaint in this action.
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`Defendant Philips Electronics North America Corporation answers the complaint by
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`reference to its standard answer to The Early Law Firm, LLC’s Standard Asbestos Complaint for
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`Personal Injury No. 1 filed pursuant to the NYCAL Case Management Order No. 1 and raises all
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`of the same affirmative defenses contained in it as if fully set forth.
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`WHEREFORE, Defendant Philips Electronics North America Corporationdenies liability
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`to the Plaintiffs in any matter or sum whatsoever. Defendant Philips Electronics North America
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`Corporation denies that the Plaintiffs are entitled to compensatory and punitive damages and
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`further requests that the Plaintiffs’ claims be dismissed with prejudice and any other relief this
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`Honorable Court deems just.
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`
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`1 of 2
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`
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`FILED: NEW YORK COUNTY CLERK 02/22/2024 09:07 AM
`NYSCEF DOC. NO. 41
`
`INDEX NO. 190011/2024
`
`RECEIVED NYSCEF: 02/22/2024
`
`Dated: February 22, 2024
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`
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`Respectfully submitted,
`
`PHILIPS ELECTRONICS
`NORTH AMERICA CORPORATION
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`By:
` Beth L. Hughes
`One of the attorneys for Philips Electronics
`North America Corporation
`
`
`
`
`Brady S. Edwards
`Beth L. Hughes
`Morgan, Lewis & Bockius LLP
`101 Park Avenue
`New York, NY 10178-0060
`Phone: (212) 309-6000
`Fax: (212) 309-6001
`beth.hughes@morganlewis.com
`
`To:
`
`
`
`
`The Early Law Firm, LLC
`360 Lexington Avenue, 20th Floor
`New York, NY 10017
`Attorneys for Plaintiffs
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`
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`2
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`2 of 2
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`
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