Adams et al v. 4520 Corp Inc et al
| Augustus A Adams and Diane Adams |
| 4520 Corp Inc, 3M Company, Air & Liquid Systems Corporation, Successor By Merger to Buffalo Pumps, Inc., Ametek, Inc., Armstrong International, Inc., Champlain Cable Corporation, Covil Corporation, Crane Co., Daniel International Corporation, The Dow Chemical Company, Fisher Controls International LLC, Flowserve US Inc., Fluor Constructors International, Fluor Constructors International Inc, Fluor Daniel Services Corporation, Fluor Enterprises, Inc., FMC Corporation, Foster Wheeler Energy Corporation, General Electric Company, Goulds Pumps, Incorporated, Grinnell LLC, Hercules LLC, HOK Group, Inc., Howden North America Inc., Metropolitan Life Insurance Company, Mine Safety Appliances Company, LLC, Rust Engineering & Construction, Inc., Rust International, Inc., Union Carbide Corporation, Viacomcbs Inc., Viking Pump, Inc., Vistra Corp, Vistra Intermediate Company LLC and The William Powell Company |
| 4:2021cv00151 |
| October 8, 2021 |
| US District Court for the Eastern District of North Carolina |
| Louise Wood Flanagan |
| P.I. : Asbestos |
| 28 U.S.C. § 1332 |
| Both |
Docket Report
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This docket was last retrieved on February 7, 2024. A more recent docket listing may be available from PACER.
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Filing 133
Notice of Special Appearance for non-district by Philip Reid on behalf of Fisher Controls International LLC. (Reid, Philip)
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Filing 132
RESPONSE in Opposition regarding #35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Augustus A Adams, Diane Adams. (Attachments: #1 Exhibit Exhibit A - Miller v. 3M, No. 5:12-CV-00620-BR, 2013 WL 1338694 (E.D.N.C. Apr. 1, 2013)) (Blumenfeld-James, Jordan)
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Filing 131
ORDER granting #126 Motion to Withdraw as Attorney. Attorney Brandon Michael Weaver terminated. Signed by District Judge Louise Wood Flanagan on 12/2/2021. (Collins, S.)
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Filing 130
Financial Disclosure Statement by Mine Safety Appliances Company, LLC (Chignell, Kevin)
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Filing 129
ANSWER to #1 Complaint with Jury Demand by Mine Safety Appliances Company, LLC. (Chignell, Kevin)
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Filing 128
Notice of Appearance filed by Kevin Lee Chignell on behalf of Mine Safety Appliances Company, LLC. (Chignell, Kevin)
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Filing 127
Notice of Appearance filed by Stacy Strickland Little on behalf of Mine Safety Appliances Company, LLC. (Little, Stacy)
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NOTICE OF DEFICIENCY regarding #125 Response in Opposition to Motion. Counsel did not properly identify exhibits pursuant to Section V.E. of the CM/ECF Policies and Procedures Manual (i.e., "Exhibit A" is not a sufficient description). Counsel is directed to refile. (Collins, S.)
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Filing 126
MOTION to Withdraw as Attorney by Brandon M. Weaver filed by Howden North America Inc.. (Attachments: #1 Text of Proposed Order) (Weaver, Brandon)
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Filing 125
**CORRECTED AND REFILED AT #132 ** RESPONSE in Opposition regarding #35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Augustus A Adams, Diane Adams. (Attachments: #1 Exhibit A) (Blumenfeld-James, Jordan) Modified on 12/3/2021 (Collins, S.).
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Filing 124
Financial Disclosure Statement by 4520 Corp Inc identifying Corporate Parent Blount International, Inc., Corporate Parent Oregon Tool, Inc. for 4520 Corp Inc. (Walters, Jason)
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Filing 123
Notice of Special Appearance for non-district by Paul Saxon Guerriere on behalf of Vistra Corp, Vistra Intermediate Company LLC. (Guerriere, Paul)
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Filing 122
Defendant Viking Pump, Inc.'s ANSWER to #1 Complaint with Jury Demand by Viking Pump, Inc.. (Drayton, Amy)
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Filing 121
Notice of Appearance filed by Amy C. Drayton on behalf of Viking Pump, Inc.. (Drayton, Amy)
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SECOND NOTICE OF DEFICIENCY - Failure to File Correct Financial Disclosure Statement as to 4520 Corp Inc. Pursuant to 7.1 of the Federal Rules of Civil Procedure and Local Civil Rule 7.3, all parties shall file a financial disclosure statement. A negative statement is required if a party has no disclosures to make. The disclosure statement must be on a form provided by the clerk. This form is available at the clerk's office and on the court's website. Counsel shall correct this deficiency within 7 days of the date of this notice. (Collins, S.)
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Filing 120
Notice of Appearance filed by Shannon Strickland Frankel on behalf of Howden North America Inc.. (Frankel, Shannon)
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Filing 119
Amended ANSWER to #1 Complaint with Jury Demand by Rust International, Inc.. (Peck, Timothy)
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Filing 118
Amended ANSWER to #1 Complaint with Jury Demand by Rust Engineering & Construction, Inc.. (Peck, Timothy)
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Filing 117
Financial Disclosure Statement by Rust International, Inc. (Peck, Timothy)
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Filing 116
Financial Disclosure Statement by Rust Engineering & Construction, Inc. (Peck, Timothy)
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Filing 115
ANSWER to #1 Complaint with Jury Demand by Hercules LLC. (Rubel, Douglas)
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Filing 114
Financial Disclosure Statement by Hercules LLC identifying Corporate Parent Ashland Global Holdings Inc. for Hercules LLC. (Rubel, Douglas)
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Filing 113
Notice of Appearance filed by Douglas Andrew Rubel on behalf of Hercules LLC. (Rubel, Douglas)
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Filing 112
ANSWER to #1 Complaint with Jury Demand by Champlain Cable Corporation. (Rubel, Douglas)
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Filing 111
Financial Disclosure Statement by Champlain Cable Corporation identifying Corporate Parent CC Acquisition Corp. for Champlain Cable Corporation. (Rubel, Douglas)
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Filing 110
Notice of Appearance filed by Douglas Andrew Rubel on behalf of Champlain Cable Corporation. (Rubel, Douglas)
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Filing 109
ANSWER to #1 Complaint with Jury Demand by Ametek, Inc.. (Rubel, Douglas)
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Filing 108
Financial Disclosure Statement by Ametek, Inc. (Rubel, Douglas)
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Filing 107
Notice of Appearance filed by Douglas Andrew Rubel on behalf of Ametek, Inc.. (Rubel, Douglas)
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Filing 106
Financial Disclosure Statement by Armstrong International, Inc. (Peck, Timothy)
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Filing 105
ANSWER to #1 Complaint with Jury Demand by The William Powell Company. (Oakley, David)
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Filing 104
Financial Disclosure Statement by The William Powell Company (Oakley, David)
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Filing 103
Notice of Appearance filed by David B. Oakley on behalf of The William Powell Company. (Oakley, David)
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Filing 102
INITIAL ORDER REGARDING PLANNING AND SCHEDULING - Discovery Plan due by 12/15/21. Counsel should read attached order in its entirety for critical information and deadlines. Signed by District Judge Louise Wood Flanagan on 11/10/2021. (Collins, S.)
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Filing 101
Financial Disclosure Statement by FMC Corporation (Jones, Kelly)
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Filing 100
Financial Disclosure Statement identifying parent corporation The Down Chemical Company by Union Carbide Corporation (Major, Christopher) Modified on 11/10/2021 to revise docket text to identify parent corporation. (Collins, S.).
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Filing 99
Notice of Appearance filed by Peter A. Santos on behalf of FMC Corporation. (Santos, Peter)
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NOTICE OF DEFICIENCY regarding #98 Financial Disclosure Statement. Filing is not text searchable. Local Civil Rule 5.1 and Section IV(A) of the court's CM/ECF policies and procedures manual require that all documents submitted for filing be in a text searchable format. Counsel is directed to refile. Instructions for how to make a document text searchable is located on the courts website under the CM/ECF section in the instructional guides category. (Collins, S.)
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NOTICE OF DEFICIENCY - Failure to File Correct Financial Disclosure Statement as to 4520 Corp Inc, Armstrong International, Inc. Pursuant to 7.1 of the Federal Rules of Civil Procedure and Local Civil Rule 7.3, all parties shall file a financial disclosure statement. A negative statement is required if a party has no disclosures to make. The disclosure statement must be on a form provided by the clerk. This form is available at the clerk's office and on the court's website. (Collins, S.)
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Notice to Counsel. Numerous filings have been made that do not contain the division in the caption of the case. Previous notice has been issued regarding this. In future filings, ALL counsel should indicate the division in accordance with Local Civil Rule 10.1(b) and 40.1(b) and (c). (Collins, S.)
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SECOND NOTICE OF DEFICIENCY regarding #25 Financial Disclosure Statement. This document is for party Daniel International Corporation rather than Union Carbine Corporation. Counsel shall refile. (Collins, S.)
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Filing 98
**CORRECTED AND REFILED AT #101 ** Financial Disclosure Statement by FMC Corporation (Jones, Kelly) Modified on 11/10/2021 (Collins, S.).
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Filing 97
Financial Disclosure Statement by Flowserve US Inc. (Hawkins, Eric)
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Filing 96
ANSWER to #1 Complaint with Jury Demand by Flowserve US Inc.. (Hawkins, Eric)
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Filing 95
Notice of Appearance filed by Eric T. Hawkins on behalf of Flowserve US Inc.. (Hawkins, Eric)
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Filing 94
Notice of Appearance filed by Kelly Brooks Jones on behalf of FMC Corporation. (Jones, Kelly)
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Filing 93
FMC Corporation's ANSWER to #1 Complaint with Jury Demand by FMC Corporation. (Jones, Kelly)
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Filing 92
Financial Disclosure Statement by 3M Company (Schulz, Jonathan)
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Filing 91
ANSWER to #1 Complaint with Jury Demand by 3M Company. (Schulz, Jonathan)
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Filing 90
Notice of Appearance filed by Jonathan Edward Schulz on behalf of 3M Company. (Schulz, Jonathan)
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Filing 89
Notice of Special Appearance for non-district by Stephanie G. Flynn on behalf of Armstrong International, Inc., HOK Group, Inc., Rust Engineering & Construction, Inc., Rust International, Inc.. (Flynn, Stephanie)
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Filing 88
Financial Disclosure Statement by Armstrong International, Inc. (Peck, Timothy)
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Filing 87
ANSWER to #1 Complaint with Jury Demand by Armstrong International, Inc.. (Peck, Timothy)
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Filing 86
Notice of Appearance filed by Timothy Peck on behalf of Armstrong International, Inc.. (Peck, Timothy)
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Filing 85
Notice of Appearance filed by Timothy Peck on behalf of Rust International, Inc.. (Peck, Timothy)
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Filing 84
Notice of Appearance filed by Timothy Peck on behalf of Rust Engineering & Construction, Inc.. (Peck, Timothy)
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Filing 83
Notice of Appearance filed by Timothy Peck on behalf of HOK Group, Inc.. (Peck, Timothy)
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Filing 82
**Amended at DE [119** ANSWER to #1 Complaint with Jury Demand by Rust International, Inc.. (Peck, Timothy) Modified on 11/18/2021 (Collins, S.).
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Filing 81
**Amended at DE #118 ** ANSWER to #1 Complaint with Jury Demand by Rust Engineering & Construction, Inc.. (Peck, Timothy) Modified on 11/18/2021 (Collins, S.).
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Filing 80
ANSWER to #1 Complaint with Jury Demand by HOK Group, Inc.. (Peck, Timothy)
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Filing 79
Notice of Appearance filed by Curtis J. Shipley on behalf of Covil Corporation. (Shipley, Curtis)
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Filing 78
Notice of Appearance filed by Scottie Forbes Lee on behalf of Covil Corporation. (Lee, Scottie)
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Filing 77
Notice of Appearance filed by Leslie C. Packer on behalf of Covil Corporation. (Packer, Leslie)
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Filing 76
Financial Disclosure Statement by Covil Corporation (Brathwaite, Ashley)
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Filing 75
Notice of Appearance filed by Ashley Kamphaus Brathwaite on behalf of Covil Corporation. (Brathwaite, Ashley)
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Filing 74
ANSWER to #1 Complaint with Jury Demand by Covil Corporation. (Brathwaite, Ashley)
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Filing 73
Notice of Appearance filed by H. Lee Davis, Jr on behalf of 4520 Corp Inc. (Davis, H.)
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Filing 72
**CORRECTED AND REFILED AT #124 ** Financial Disclosure Statement by 4520 Corp Inc (Walters, Jason) Modified on 12/2/2021 (Collins, S.).
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Filing 71
ANSWER to #1 Complaint with Jury Demand by 4520 Corp Inc. (Walters, Jason)
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Filing 70
Notice of Appearance filed by Jason Larry Walters on behalf of 4520 Corp Inc. (Walters, Jason)
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Filing 69
Financial Disclosure Statement identifying parent corporation National Amusements, Inc. by Viacomcbs Inc. (Techman, Jennifer) Modified on 11/10/2021 to revise docket text to identify parent corporation. (Collins, S.).
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Filing 68
Financial Disclosure Statement, identifying parent corporation John Wood Group, PLC by Foster Wheeler Energy Corporation (Techman, Jennifer) Modified on 11/10/2021 to revise docket text to identify parent corporation. (Collins, S.).
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Filing 67
Financial Disclosure Statement by General Electric Company (Techman, Jennifer)
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Filing 66
Notice of Appearance filed by Jennifer M. Techman on behalf of Viacomcbs Inc.. (Techman, Jennifer)
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Filing 65
Notice of Appearance filed by Jennifer M. Techman on behalf of Foster Wheeler Energy Corporation. (Techman, Jennifer)
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Filing 64
Notice of Appearance filed by Jennifer M. Techman on behalf of General Electric Company. (Techman, Jennifer)
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Filing 63
Financial Disclosure Statement by Fisher Controls International LLC identifying Corporate Parent Emerson Electric Co. for Fisher Controls International LLC. (O'Neill, Mary)
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Filing 62
ANSWER to #1 Complaint with Jury Demand by Viacomcbs Inc.. (Techman, Jennifer)
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Filing 61
ANSWER to #1 Complaint with Jury Demand by Foster Wheeler Energy Corporation. (Techman, Jennifer)
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Filing 60
ANSWER to #1 Complaint with Jury Demand by General Electric Company. (Techman, Jennifer)
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Filing 59
ANSWER to #1 Complaint with Jury Demand by Fisher Controls International LLC. (O'Neill, Mary)
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Filing 58
Notice of Appearance filed by Kimberly Sullivan on behalf of Fisher Controls International LLC. (Sullivan, Kimberly)
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Filing 57
Notice of Appearance filed by Mary Elizabeth O'Neill on behalf of Fisher Controls International LLC. (O'Neill, Mary)
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Filing 56
Financial Disclosure Statement by Howden North America Inc. (Weaver, Brandon)
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Filing 55
ANSWER to #1 Complaint with Jury Demand and Answer to All Cross-Claims by Howden North America Inc.. (Weaver, Brandon)
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Filing 54
Notice of Appearance filed by Brandon Michael Weaver on behalf of Howden North America Inc.. (Weaver, Brandon)
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Notice to Counsel. In future filings, counsel should indicate the division in accordance with Local Civil Rule 10.1(b) and 40.1(b) and (c). (Collins, S.)
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NOTICE OF DEFICIENCY regarding #32 Notice of Special Appearance, #31 Notice of Special Appearance. Pursuant to Section VI.C.2 of the CM/ECF Policies and Procedures Manual, each attorney making an appearance in the case must be a registered CM/ECF filer with this court and must file his or her own Notice of Appearance. (Collins, S.)
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NOTICE OF DEFICIENCY regarding #25 Financial Disclosure Statement. This document is for party Daniel International Corporation rather than Union Carbine Corporation. Counsel shall refile. (Collins, S.)
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Filing 53
Notice of Appearance filed by William Michael Starr on behalf of Air & Liquid Systems Corporation, Successor By Merger to Buffalo Pumps, Inc.. (Starr, William)
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Filing 52
Notice of Appearance filed by William Michael Starr on behalf of Grinnell LLC. (Starr, William)
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Filing 51
Notice of Appearance filed by William Michael Starr on behalf of Goulds Pumps, Incorporated. (Starr, William)
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Filing 50
Financial Disclosure Statement by Air & Liquid Systems Corporation, Successor By Merger to Buffalo Pumps, Inc. (Tomlin, Tracy)
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Filing 49
ANSWER to #1 Complaint by Air & Liquid Systems Corporation, Successor By Merger to Buffalo Pumps, Inc.. (Tomlin, Tracy)
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Filing 48
Financial Disclosure Statement by Metropolitan Life Insurance Company (Coltrain, Keith)
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Filing 47
Notice of Appearance filed by Tracy E. Tomlin on behalf of Air & Liquid Systems Corporation, Successor By Merger to Buffalo Pumps, Inc.. (Tomlin, Tracy)
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Filing 46
ANSWER to #1 Complaint with Jury Demand and to Cross-Claims of any and all other Defendants and Third-Party Defendants by Metropolitan Life Insurance Company. (Coltrain, Keith)
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Filing 45
Financial Disclosure Statement identifying parent corporation Simplex Time Recorder, LLC by Grinnell LLC (Tomlin, Tracy) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 44
Notice of Appearance filed by Keith E. Coltrain on behalf of Metropolitan Life Insurance Company. (Coltrain, Keith)
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Filing 43
ANSWER to #1 Complaint by Grinnell LLC. (Tomlin, Tracy)
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Filing 42
Notice of Appearance filed by Tracy E. Tomlin on behalf of Grinnell LLC. (Tomlin, Tracy)
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Filing 41
Financial Disclosure Statement by Goulds Pumps, Incorporated (Tomlin, Tracy)
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Filing 40
ANSWER to #1 Complaint by Goulds Pumps, Incorporated. (Tomlin, Tracy)
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Filing 39
Notice of Appearance filed by Tracy E. Tomlin on behalf of Goulds Pumps, Incorporated. (Tomlin, Tracy)
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Filing 38
ANSWER to #1 Complaint by Vistra Corp. (Becker, Allison)
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Filing 37
ANSWER to #1 Complaint by Vistra Intermediate Company LLC. (Becker, Allison)
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Filing 36
Memorandum in Support regarding #35 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Vistra Intermediate Company LLC. (Becker, Allison)
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Filing 35
MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Vistra Intermediate Company LLC. (Becker, Allison)
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Filing 34
Financial Disclosure Statement identifying parent corporation Vistra Corp by Vistra Intermediate Company LLC (Becker, Allison) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 33
Financial Disclosure Statement by Vistra Corp (Becker, Allison)
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Filing 32
Notice of Special Appearance on behalf of Attorney P. Saxon Guerriere for non-district by Allison J. Becker on behalf of Vistra Corp, Vistra Intermediate Company LLC. (Becker, Allison) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 31
Notice of Special Appearance on behalf of Attorney Nathan White for non-district by Allison J. Becker on behalf of Vistra Corp, Vistra Intermediate Company LLC. (Becker, Allison) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 30
Notice of Appearance filed by Allison J. Becker on behalf of Vistra Corp, Vistra Intermediate Company LLC. (Becker, Allison)
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Filing 29
Notice of Appearance filed by Kendra N. Stark on behalf of Vistra Corp, Vistra Intermediate Company LLC. (Stark, Kendra)
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Filing 28
Notice of Special Appearance for non-district by Scott E. Frick on behalf of Daniel International Corporation, Fluor Constructors International, Fluor Constructors International Inc, Fluor Daniel Services Corporation, Fluor Enterprises, Inc., The Dow Chemical Company, Union Carbide Corporation. (Frick, Scott)
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Filing 27
Notice of Special Appearance for non-district by William David Conner on behalf of Daniel International Corporation, Fluor Constructors International, Fluor Constructors International Inc, Fluor Daniel Services Corporation, Fluor Enterprises, Inc., The Dow Chemical Company, Union Carbide Corporation. (Conner, William)
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Filing 26
Notice of Special Appearance for non-district by Moffatt G. McDonald on behalf of Daniel International Corporation, Fluor Constructors International, Fluor Constructors International Inc, Fluor Daniel Services Corporation, Fluor Enterprises, Inc., The Dow Chemical Company, Union Carbide Corporation. (McDonald, Moffatt)
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Filing 25
**CORRECTED AND REFILED AT #100 ** Financial Disclosure Statement by Union Carbide Corporation (Major, Christopher) Modified on 11/10/2021 (Collins, S.).
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Filing 24
ANSWER to #1 Complaint with Jury Demand by Union Carbide Corporation. (Major, Christopher)
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Filing 23
Financial Disclosure Statement by The Dow Chemical Company (Major, Christopher)
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Filing 22
ANSWER to #1 Complaint with Jury Demand by The Dow Chemical Company. (Major, Christopher)
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Filing 21
Financial Disclosure Statement by Fluor Constructors International, Fluor Constructors International Inc. identifying Fluor Corporation as parent corporation. (Major, Christopher) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 20
ANSWER to #1 Complaint with Jury Demand by Fluor Constructors International, Fluor Constructors International Inc. (Major, Christopher)
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Filing 19
Financial Disclosure Statement by Fluor Enterprises, Inc. identifying Fluor Corporation as parent corporation. (Major, Christopher) Modified on 11/5/2021 to revise docket text. (Collins, S.).
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Filing 18
ANSWER to #1 Complaint with Jury Demand by Fluor Enterprises, Inc.. (Major, Christopher)
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Filing 17
Financial Disclosure Statement by Fluor Daniel Services Corporation (Major, Christopher)
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Filing 16
ANSWER to #1 Complaint with Jury Demand by Fluor Daniel Services Corporation. (Major, Christopher)
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Filing 15
Financial Disclosure Statement by Daniel International Corporation (Major, Christopher)
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Filing 14
ANSWER to #1 Complaint with Jury Demand by Daniel International Corporation. (Major, Christopher)
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Filing 13
Notice of Appearance filed by Christopher Barton Major on behalf of Daniel International Corporation, Fluor Constructors International, Fluor Constructors International Inc, Fluor Daniel Services Corporation, Fluor Enterprises, Inc., The Dow Chemical Company, Union Carbide Corporation. (Major, Christopher)
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Filing 12
ANSWER to #1 Complaint by Crane Co.. (Mather, Emily)
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Filing 11
Financial Disclosure Statement by Crane Co. (Mather, Emily)
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Filing 10
Notice of Appearance filed by Emily Mather on behalf of Crane Co.. (Mather, Emily)
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Filing 9
Notice of Appearance filed by Marla Tun Reschly on behalf of Crane Co.. (Reschly, Marla)
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Filing 8
Notice of Special Appearance for non-district by Jordan Blumenfeld-James on behalf of All Plaintiffs. (Blumenfeld-James, Jordan)
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NOTICE OF DEFICIENCY regarding #7 Notice of Appearance. Wrong event used. Counsel shall refile using the event "Notice of Special Appearance." In addition, in future filings, counsel should indicate the division in accordance with Local Civil Rule 10.1(b) and 40.1(b) and (c). (Collins, S.)
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Filing 7
**CORRECTED AND REFILED AT #8 ** Notice of Appearance filed by Jordan Blumenfeld-James on behalf of All Plaintiffs. (Blumenfeld-James, Jordan) Modified on 10/27/2021 (Collins, S.).
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Case Selected for Mediation - A printable list of certified mediators for the Eastern District of North Carolina is available on the court's Website, http://www.nced.uscourts.gov/attorney/mediators.aspx. Please serve this list on all parties. (Collins, S.)
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Filing 6
Summons Issued as to All Defendants. (*NOTICE: Counsel shall print the attached summons and serve with other case opening documents in accordance with Fed.R.Civ.P. 4.*) (Collins, S.)
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Filing 5
Financial Disclosure Statement by Augustus A Adams, Diane Adams (Graham, William)
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Filing 4
Financial Disclosure Statement by Augustus A Adams, Diane Adams (Graham, William)
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Filing 3
Notice filed by Augustus A Adams, Diane Adams regarding #1 Complaint Notice of Filing Summons. (Attachments: #1 Proposed Summons Proposed Combined Summons) (Graham, William)
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Filing 2
Notice of Appearance filed by William M. Graham on behalf of Augustus A Adams, Diane Adams. (Graham, William)
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Filing 1
COMPLAINT CIVIL ACTION COMPLAINT against All Defendants ( Filing fee $ 402 receipt number 0417-6268208.), filed by Diane Adams, Augustus A Adams. (Attachments: #1 Civil Cover Sheet Civil Cover Sheet) (Graham, William)
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