Document NNNR8GZ3RxOjyvDBrxqZj6yzE

STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF MACOMB KENNETH GRIMM, Personal Representative of the ESTATE OF HELEN GRIMM, Deceased, Plaintiff, vs . FORD MOTOR COMPANY, a foreign corporation, et a I , Def endants. / Case No. 83-2072 NO Hon. Raymond R. Cashen DEFENDANT STAUFFER CHEMICAL COMPANY'S JOINDER IN CO-DEFENDANTSr MOTION FOR SUMMARY^ JUDGMENT Defendant Stauffer Chemical Company, by its attorneys, Meyer, Kirk, Snyder & Safford, joins its Co-Defendants' Motion for Summary Judgment for the following reasons: URL 09813 1. Plaintiff filed this products liability action on August 15, 1983 to recover damages from Stauffer, among others, as a re sult of the alleged exposure of Plaintiff's Decedent to polyvinyl chloride products supplied by Stauffer to Ford Motor Company. 2. Stauffer answered Plaintiff's Complaint in part by as serting the affirmative defense that Plaintiff's claim was barred by the applicable statute of limitations. 3. Stauffer incorporates byreference the arguments and briefs previously filed by Co-Defendants in connection with this Motion, Plaintiff's deposition, and the medical records produced thus far. 4. In Count I, Paragraph 10 of his Complaint, Plaintiff states: "That the Defendant, STAUFFER CHEMICAL COMPANY, supplied to Defendant, FORD MOTOR COMPANY, polyvinyl chloride, resin specification 96F181 for the year 1976 and 96F51A for the years 1974 through 1976." 5. As to Stauffer, the applicable statute of limitations began to run no later than 1 976 , the latest possible date of Stauffer's alleged wrongful activity. 6. The three year statute of limitations barred Plaintiff's claim against Stauffer in this matter after 1979. WHEREFORE, Stauffer Chemical Company requests that Plaintiff's Complaint be dismissed with prejudice as to Stauffer. Dated: February U , 1985 MEYER, KIRK, SNYDER & SAFFORD 'jU Cl RaTpf%-- R7"5a77ord/ (P-2 4 6J 3T sn i / // 'J i. r / - '______ PStrTck K. RoEe Attorneys for Defendant Stauffer Chemical Company 100 W. Long Lake Road, Suite 100 Bloomfield Hills, Michiaan 48013 Telephone: (313) 674-5111 URL 09814 -2- STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF MACOMB KENNETH GRIMM. Personal Representative of the ESTATE OF HELEN GRIMM, Deceased, Plaintiff, vs . FORD MOTOR COMPANY, a foreign corporation, et al , Defendants. I Case No. 83-2872 NO Hon. Raymond R. Cashen PROOF OF SERVICE STATE OF MICHIGAN) )ss. COUNTY OF OAKLAND) Kathleen Wilson, being duly sworn, deposes and says that on the 11th day of February, 1985, she served copies of Defendant Stauffer Chemical Company's Joinder in Co-Defendants' Motion for Summary Judgment and Proof of Service upon: Mr. Francis P. Hughes Bebout, Potere, Cox Hughes, P.C. 1 000 V,'. University Drive, Ste. 314 Rochester, Michigan 48063 Mr. Dennis M. Haffey Dykema, Gossett, Spencer, Goodnow $ Trigg 35th Floor 400 Renaissance Center Detroit, Michigan 48243 Mr. Steven C. Nadeau Dickinson, Wright, Moon, Van Dusen 8 Freeman 800 First National Building Detroit, Michigan 48226 Mr. John J. Lynch, III Vandeveer, Garzia, Tonkin, Kerr, Heaphy, Moore, Sills and Poling, P.C. 1550 N. Woodward Avenue Birmingham, MI 48011 Mr. Ralph W. Barbier, Jr. Barbier, Coulet 8 Petersmarck, 34820 Harper Avenue Mount Clemens, Michigan 48043 P C. Mr. Ralph F. Valitutti, Jr. Kitch, Saurbier 8 Drutchas 2000 Buhl Building Detroit, Michigan 48226 by placing the documents in fully addressed, stamped envelopes and by depositing the envelopes in a United States Mail Receptacle. URL 09815 Subscribed and sworn to before me this 11th day'of February, 1985. ___ / r ____________ ______________ FatrTcE^K. RoHe, No ta ry~PuETTi c Oakland County, Michigan My commission expires: 1/9/88 RaThleen WTlson "