Document MMbrar6LKOkzGpXLd28O6EKVy

r RECE!VED I I; JUL-91986 liGAl OEPT, i:TlGAT,0 v URL 13077 Pitney. Hardin. Kipp &. Szuch i3 MADISON AVENUE CN 1945 MORRISTOWN. N J. 07960-1945 12011 257*3333 attorneys for Defendant Vista Chemical Company SUPERIOR COURT OF NEW JERSEY LAW DIVISION - PASSAIC COUNTY DOCKET NO. L-020509-86 LOTTIE MEMICE, Individually and as Executrix of the Estate of JOSEPH MEMICE, Deceased, Civil Action Plaintiff , -vs PPG INDUSTRIES, INC., et al.. NOTICE OF MOTION FOR SUMMARY JUDGMENT Defendants . TO: S. ROBERT PRINCIOTTO, ESQ. Marcus & Levy Attorneys for Plaintiff 80 Broadway (Route 4) Elmwood Park, N.J. 07407 PLEASE TAKE NOTICE that on Friday * July 18, 1986, at 9:00 o'clock in the forenoon or as soon thereafter as counsel may be heard, the undersigned, attorneys for defendant, Vista Chemical Company, shall make application to the Superior Court of New Jersey, Law Division, Passaic County for an Order, pursuant to R. 4:46 for summary judgment dismissing the Second Amended Complaint as against the defendant Vista Chemical Company on the grounds that there is no genuine issue as to any material fact and that Vista Chemical Company is entitled to judgment as a matter of law. PLEASE TAKE FURTHER NOTICE that, in support of this application, defendant Vista Chemical Company will rely upon the Affidavit of W.C. Kolar and the letter memorandum submitted herewith. PLEASE TAKE FURTHER NOTICE that the undersigned does not request oral argument on this application at this time. PITNEY, HARDIN, KIPP & S2UCH Attorneys for Defendant Vista Chemical Company 3D o-J CD --J 00 By. A Member of the Firm DATED: June 20, 1986. Status Conference: Calendar Call: Trial Date: CERTIFICATION I hereby Certify that on this date two copies of the within Notice of Motion for Summary Judgment together with all supporting papers were hand delivered for filing to the Clerk of Passaic County, Court House, Paterson, New Jersey. I further certify that on this date the originals of the within Notice of Motion for Summary Judgment and support ing Affidavit were forwarded to the Clerk of the Superior Court, Trenton, New Jersey for filing. URL 13079 CERTIFICATE OF SERVICE I hereby certify that on this date copies of the within Notice of Motion for Summary Judgment and supporting papers were served upon all counsel of record by delivering the same by Federal Express courier service, at Morristown, New Jersey to the following: S. ROBERT PRINCIOTTO, ESQ. Marcus & Levy 80 Broadway (Route 4) Elmwood Park, N.J. 07407 WILLIAM B. MCQUIRE, ESQ. Tompkins, McGuire & Wachenfeld 550 Broad Street Newark, N.J. 07102 RAYMOND M. TIERNEY, JR., Shanley & Fisher 131 Madison Avenue Morristown, N.J. 07960 ESQ. JOHN A. RIDLEY, ESQ. Crummy, Del Deo, Dolan, Vecchione Gateway I Newark, N.J. 07102 Griffinger & EDWIN R. MATTHEWS, ESQ. Budd, Earner, Kent, Gross, Piccillo, Rosenbaum, Greenberg & Sade 150 J.F. Kennedy Parkway Short Hills, N.J. 07078 URL 13080 Dated: June 20, 1986