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Elizabeth M. Lautenbach | Special Counsel
`Direct 973.681.7008 | elautenbach@goldbergsegalla.com
`
`February 28, 2024
`
`
`
`
`
`
`
`
`
`
`Matthew Park, Esq.
`The Early Law Firm, LLC
`360 Lexington Avenue, 20th Floor
`New York, NY 10017
`mpark@elslaw.com
`
`
`Re: Dennis Kilkenny and Patricia Kilkenny v. AII Acquisition, LLC, et al.,
`Index number: 190011/2024
`GS File No.: 14696-0001
`
`Dear Counsel:
`
`Enclosed please find an Unopposed Summary Judgment Motion and Order for the above
`
`referenced case on behalf of my client, Sony Electronics Inc.
`
`We kindly request that you sign the enclosed an Unopposed Summary Judgment Motion
`
`and Order dismissing defendant Sony Electronics Inc. and return the signed original to my
`attention for filing. Should you decline to sign the order, please advise as to the basis of plaintiff's
`claims against Sony Electronics Inc. as soon as possible. Please note, pursuant to the said CMO, a
`response should be tendered.
`
`
`
`Thank you for your attention to this matter. Should you need any additional information,
`I can be contacted at (973) 681-7000.
`
`
`
`Sincerely,
`
`
`
`Elizabeth M. Lautenbach
`
`
`
`
`
`
`
`
`
`
`
`EML:pmp
`Enc.
`Cc: All known defense counsel via NYSCEF
`
`
`
`
`
`
`
`Please send mail to our scanning center at: PO Box , Buffalo, NY 14201
`
`
`
`
`
`
`
`Office Location: 711 3rd Avenue, Suite 1900, New York, NY 10017-4013 | 646-292-8700 | Fax: 973-681-7101 | www.goldbergsegalla.com
`CALIFORNIA | CONNECTICUT | FLORIDA | ILLINOIS | NEW JERSEY | NEW YORK | NORTH CAROLINA | MARYLAND | MISSOURI | PENNSYLVANIA | UNITED KINGDOM
`34677097.v1
`
`

`

`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF NEW YORK
`
`IN RE: NEW YORK CITY
` ASBESTOS LITIGATION
`
`
`THIS DOCUMENT RELATES TO:
`
`
`DENNIS KILKENNY AND PATRICIA KILKENNY
`
`
`
`
`
`
`
`NYCAL
`I.A.S. Part 13
`
`Index No.: 190011/2024
`
`UNOPPOSED SUMMARY
`JUDGMENT MOTION
`AND ORDER
`
`
`
`
`
`WHEREFORE, Defendant Sony Electronics Inc., hereby requests summary judgment in
`
`the above entitled action, pursuant to Civil Practice Law and Rules § 3212, dismissing the
`
`complaint and cross-claims against Sony Electronics Inc., with prejudice, and after notice to all
`
`co-defendants there is no opposition, it is
`
`
`
`ORDERED that all claims and cross claims against defendant Sony Electronics Inc., are
`
`dismissed with prejudice and without costs.
`
`Dated: Newark, NJ
`
`February ____, 2024
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Matthew Park, Esq.
`Attorney for Plaintiffs
`Dennis Kilkenny and Patricia Kilkenny
`The Early Law Firm, LLC
`360 Lexington Avenue, 20th Floor
`New York, NY 10017
`(212) 986-2233
`
`
`
`
`
`
`_____________________________
`Elizabeth M. Lautenbach, Esq.
`Attorneys for Defendant
`Sony Electronics Inc.
`GOLDBERG SEGALLA, LLP
`1037 Raymond Boulevard, Suite 1010
`Newark, NJ 07102-5423
`(973) 681-7000
`
`
`
`
`
`SO ORDERED,
`
`
`
`
`34677097.v1
`
`
`
`
`
`Hon. Adam Silvera, J.S.C.
`
`
`
`
`
`

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