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FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024
SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
MICHAEL MCGLATHERY; GINA MCGLYNN; TANGER
MCGRIFF; LISA MCGUIGAN; DEWEY MCKEE;
RICHARD MCKINNEY; STACIE MCKINNEY; ROBERT
JAMES GEORGE MCKNIGHT III; RUTH MCKOWN;
MICHAEL MCMANUS; MICHAEL MCMASTER;
CYNTHIA MCMILLAN; MURL MCMILLION; WILLIAM Index No. _________/2024
MCMULLIN; DAVID MCNAIR; MARK MCNEALY;
LYNETTE MCNEILL; DONNA MCPHERSON; GEORGE COMPLAINT AND DEMAND
FOR JURY TRIAL
MCPHERSON; ESTATE OF JAMES MCRAE; MICHAEL
MCVAY; GREGORY MEDARIS; ALAN MEDDERS; Trial by jury is desired in the
DAVID MEDLIN; CARMELITA MEDLOCK; JOHN County of New York
MEINERT; THERESA MELTON; TRAVIS MENDIOLA;
PEDRO MENENDEZ; DAVID MERRIMAN; ALFRED Venue is designated pursuant to
MEUNIER; DAVID MEYER; YVONNE MEYER; SCOTT CPLR § 503(a) & (c) in that the
MEZOFF; YVONNE MICKENS; REBECCA MIESUK; causes of action occurred in this
CHESTER MILBURN; DOUGLAS MILLER; GREGORY county.
MILLER; LORNE MILLER; EDWARD THOMAS
MILLER SR; JOHN MILLONIG; ROSA MILLS; TAYLOR
MILLS; EDWARD MILSTEAD; EMERY MILTON;
GREGORY L. MINIX; YOMARIE MIRANDA;
MELQUIADES MIRANDA JR; NICHOLAS MIRRO;
DENISE MITCHELL; DONNA MITCHELL; DORIS
MITCHELL; JOSEPH MITCHELL; MARK MITCHELL;
ROBERT MOBLEY; STEVEN MONAHAN; DONALD
MONROE; RICKEY MONSON; ABRAHAM MONTES;
WAYNE MOONEY; ESTATE OF BILLY MOORE;
CALVIN MOORE; EDWARD MOORE; LISA MOORE;
PATRICIA MOORE; ROBERT MOORE; CLAYTON
MOORE JR.; EXIE MORALES; ESTATE OF ELIZABETH
MORAN; MARK MORAN; SUE MORETZ; GREGORY
MORGAN; KELLY MORGAN; AND LEO MORIN,
Plaintiffs,
-vs -
THE 3M COMPANY, f/k/a Minnesota Mining and
Manufacturing Co.;
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AGC CHEMICALS AMERICAS INC.;
AMEREX CORPORATION;
ARKEMA INC.;
ARCHROMA U.S. INC.;
BUCKEYE FIRE EQUIPMENT COMPANY;
CHEMDESIGN PRODUCTS INC.;
CHEMGUARD INC.;
CHEMICALS, INC.;
CLARIANT CORPORATION, individually and as successor
in interest to Sandoz Chemical Corporation;
CORTEVA, INC., individually and as successor in interest to
DuPont Chemical Solutions Enterprise;
DEEPWATER CHEMICALS, INC.;
DUPONT DE NEMOURS INC., individually and as
successor in interest to DuPont Chemical Solutions
Enterprise;
DYNAX CORPORATION;
E. I. DUPONT DE NEMOURS AND COMPANY,
individually and as successor in interest to DuPont Chemical
Solutions Enterprise;
NATION FORD CHEMICAL COMPANY;
THE CHEMOURS COMPANY, individually and as
successor in interest to DuPont Chemical Solutions
Enterprise;
THE CHEMOURS COMPANY FC, LLC, individually and
as successor in interest to DuPont Chemical Solutions
Enterprise;
TYCO FIRE PRODUCTS, LP, individually and as successor
in interest to The Ansul Company; and
DOE DEFENDANTS 1-20, fictitious names whose present
identities are unknown,
Defendants.
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiffs; MICHAEL MCGLATHERY; GINA MCGLYNN; TANGER MCGRIFF; LISA
MCGUIGAN; DEWEY MCKEE; RICHARD MCKINNEY; STACIE MCKINNEY; ROBERT
JAMES GEORGE MCKNIGHT III; RUTH MCKOWN; MICHAEL MCMANUS; MICHAEL
MCMASTER; CYNTHIA MCMILLAN; MURL MCMILLION; WILLIAM MCMULLIN;
DAVID MCNAIR; MARK MCNEALY; LYNETTE MCNEILL; DONNA MCPHERSON;
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GEORGE MCPHERSON; ESTATE OF JAMES MCRAE; MICHAEL MCVAY; GREGORY
MEDARIS; ALAN MEDDERS; DAVID MEDLIN; CARMELITA MEDLOCK; JOHN
MEINERT; THERESA MELTON; TRAVIS MENDIOLA; PEDRO MENENDEZ; DAVID
MERRIMAN; ALFRED MEUNIER; DAVID MEYER; YVONNE MEYER; SCOTT MEZOFF;
YVONNE MICKENS; REBECCA MIESUK; CHESTER MILBURN; DOUGLAS MILLER;
GREGORY MILLER; LORNE MILLER; EDWARD THOMAS MILLER SR; JOHN
MILLONIG; ROSA MILLS; TAYLOR MILLS; EDWARD MILSTEAD; EMERY MILTON;
GREGORY L. MINIX; YOMARIE MIRANDA; MELQUIADES MIRANDA JR; NICHOLAS
MIRRO; DENISE MITCHELL; DONNA MITCHELL; DORIS MITCHELL; JOSEPH
MITCHELL; MARK MITCHELL; ROBERT MOBLEY; STEVEN MONAHAN; DONALD
MONROE; RICKEY MONSON; ABRAHAM MONTES; WAYNE MOONEY; ESTATE OF
BILLY MOORE; CALVIN MOORE; EDWARD MOORE; LISA MOORE; PATRICIA MOORE;
ROBERT MOORE; CLAYTON MOORE JR.; EXIE MORALES; ESTATE OF ELIZABETH
MORAN; MARK MORAN; SUE MORETZ; GREGORY MORGAN; KELLY MORGAN; AND
LEO MORIN, (“Plaintiffs”), by and through the undersigned counsel, hereby files this Complaint
against Defendants, 3M COMPANY, f/k/a Minnesota Mining and Manufacturing Co., AGC
CHEMICALS AMERICAS INC., AMEREX CORPORATION, ARKEMA INC., ARCHROMA
U.S. INC., BUCKEYE FIRE EQUIPMENT COMPANY, CHEMDESIGN PRODUCTS INC.,
CHEMGUARD INC., CHEMICALS, INC., CLARIANT CORPORATION, CORTEVA, INC.,
DEEPWATER CHEMICALS, INC., DUPONT DE NEMOURS INC., DYNAX
CORPORATION, E. I. DUPONT DE NEMOURS AND COMPANY, NATION FORD
CHEMICAL COMPANY, THE CHEMOURS COMPANY, THE CHEMOURS COMPANY FC,
LLC, and TYCO FIRE PRODUCTS, LP, and DOE DEFENDANTS 1-20, fictitious names whose
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present identifies are unknown (collectively “Defendants”) and alleges, upon information and
belief, as follows:
INTRODUCTION
1. This action arises from the foreseeable contamination of groundwater by the use of
aqueous film-forming foam (“AFFF”) products that contained per- and poly-fluoroalkyl
substances (“PFAS”), including perfluoro octane sulfonate (“PFOS”) and perfluorooctanoic acid
(“PFOA”).
2. PFOS and PFOA are fluor surfactants that repel oil, grease, and water. PFOS,
PFOA, and/or their chemical precursors, are or were components of AFFF products, which are
firefighting suppressant agents used in training and firefighting activities for fighting Class B fires.
Class B fires include fires involving hydrocarbon fuels such as petroleum or other flammable
liquids.
3. PFOS and PFOA are mobile, persist indefinitely in the environment, bioaccumulate
in individual organisms and humans, and biomagnify up the food chain. PFOS and PFOA are also
associated with multiple and significant adverse health effects in humans, including but not limited
to kidney cancer, testicular cancer, high cholesterol, thyroid disease, ulcerative colitis, and
pregnancy-induced hypertension.
4. At various times from the 1960s through today, Defendants designed,
manufactured, marketed, distributed, and/or sold AFFF products containing PFOS, PFOA, and/or
their chemical precursors, and/or designed, manufactured, marketed, distributed, and/or sold the
fluor surfactants and/or per fluorinated chemicals (“PFCs”) contained in AFFF (collectively,
“AFFF/Component Products”).
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5. Defendants designed, manufactured, marketed, distributed, and/or sold
AFFF/Component Products with the knowledge that these toxic compounds would be released
into the environment during fire protection, training, and response activities, even when used as
directed and intended by Defendants.
6. Since its creation in the 1960s, AFFF designed, manufactured, marketed,
distributed, and/or sold by Defendants, and/or that contained fluorosurfactants and/or PFCs
designed, manufactured, marketed, distributed, and/or sold by Defendants, used as directed and
intended by Defendants, and subsequently released into the environment during fire protection,
training, and response activities, resulting in widespread PFAS contamination.
7. Due to this contamination, Plaintiffs have suffered real personal injuries,
bioaccumulation of PFAS in their bodies, property damage and the diminution in value of their
properties as a result of the release of PFAS to their water supplies.
8. Plaintiffs have suffered an assortment of diseases and medical conditions as a direct
result of their exposure to the PFAS contamination of their water supply.
9. Plaintiffs, as residents and those who visited, worked, or otherwise dwelled in the
Site area, have been unknowingly exposed for many years to PFAS, including concentrations
hazardous to their health.
10. Plaintiffs’ unwitting exposure to PFAS in their water supply as a result of the
Defendants’ conduct, is the direct and proximate cause of Plaintiffs’ injuries.
11. Plaintiffs’ property has been damaged as a result of the presence of the PFAS in
their water supply.
12. Plaintiffs seek recovery from Defendants for injuries, damages, and losses
suffered by the Plaintiffs as a result of exposure to the introduction of PFAS and other toxic
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substance into their water supply, and then into their properties and bodies, in an amount to be
determined at trial, exclusive of interest, costs, and attorneys’ fees.
JURISDICTION AND VENUE
13. This Court has jurisdiction because Defendant Dynax Corporation’s principal place
of business is located at 103 Fairview Park Drive, Elmsford, New York 10523.
14. Venue is proper in this District under CPLR §503 (a) because the events, omissions
and harms that are the basis of Plaintiffs claims occurred in substantial party in this District.
15. This Court has personal jurisdiction over Defendants by virtue of each Defendants’
regular and systematic contacts with New York, including, among other things, purposefully
marketing, selling and/or distributing their AFFF/Component Products to and within New York,
and because they have the requisite minimum contacts with New York necessary to
constitutionally permit the Court to exercise jurisdiction over them consistent with traditional
notions of fair play and substantial justice.
PARTIES
A. Plaintiffs
16. Plaintiff MICHAEL MCGLATHERY resides at 12324 SE 44th St, Choctaw, OK
73020. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Testicular Cancer.
17. Plaintiff GINA MCGLYNN resides at 1825 Poggi St APT # 214 A, Alameda, CA
94501. Plaintiff was formerly stationed at a military base or installation where PFAS was used
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(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Breast Cancer,
Hypothyroidism.
18. Plaintiff TANGER MCGRIFF resides at 721 Hemenway Dr NE, Winter Haven, FL
33881. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease,
Hyperthyroidism, Hypothyroidism.
19. Plaintiff LISA MCGUIGAN resides at 3433 3rd Ave South, Apt 12, St. Petersburg,
FL 33711. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism,
Thyroid Disease, Thyroid Problems.
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20. Plaintiff DEWEY MCKEE resides at 14533 Lee Hwy, Bristol, VA, VA 24202.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Mass - Kidney, Pancreatic
Cancer, Renal Cancer, Renal Cell Carcinoma.
21. Plaintiff RICHARD MCKINNEY resides at 1418 Antioch Rd, Wilmington, OH
45177. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Mass
- Kidney, Renal Cancer.
22. Plaintiff STACIE MCKINNEY resides at 23430 Stratford Ct, Southfield, MI 48033.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism.
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23. Plaintiff ROBERT JAMES GEORGE MCKNIGHT III resides at 22523 E Piccolo
Way, Aurora, CO 80016. Plaintiff was formerly stationed at a military base or installation where
PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working
on base, Claimant was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result
of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As
a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with
Hyperlipidemia, Renal Cell Carcinoma.
24. Plaintiff RUTH MCKOWN resides at 4320 Rustic Drive, New Port Richey, FL
34652-. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia,
Hypothyroidism.
25. Plaintiff MICHAEL MCMANUS resides at PO box 364, Somerset Center, MI
49282. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
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proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hodgkins Lymphoma,
Hypothyroidism.
26. Plaintiff MICHAEL MCMASTER resides at 6135 Hickory Creek Road, High Point,
NC 27263. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Kidney Cancer.
27. Plaintiff CYNTHIA MCMILLAN resides at 1300 Belle Meade Cir SW, Mableton,
GA 30126-. Plaintiff was formerly stationed at a military base or installation where PFAS was
used (hereinafter the “Sites”) and was living on base during that time. While working on base,
Claimant was exposed to PFAS through daily activity and regularly consumed water containing
elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the
PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct
and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol,
Hyperlipidemia, Hypothyroidism, Kidney Cancer, Pregnancy Problems, Renal Cell Carcinoma,
Thyroid Cancer.
28. Plaintiff MURL MCMILLION resides at 126 Crandall Dr, Culloden, WV 25510.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
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Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism, Prostate
Cancer, Thyroiditis.
29. Plaintiff WILLIAM MCMULLIN resides at 5148 Tonti Rd., Salem, IL 62881-.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Bladder Cancer, High Cholesterol,
Hypothyroidism, Thyroid Problems.
30. Plaintiff DAVID MCNAIR resides at 6009 RIXEY DR, ALEXANDRIA, VA
22303. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypercholesteremia,
Hypothyroidism.
31. Plaintiff MARK MCNEALY resides at 1200 Long Road, Centralia, WA 98531.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
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Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Ulcerative Colitis.
32. Plaintiff LYNETTE MCNEILL resides at 2424 E 35th Ave, Spokane, WA 99223.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Hypothyroidism.
33. Plaintiff DONNA MCPHERSON resides at 708 Teal Ln, Altamonte Springs, FL
32701. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hashimotos Disease,
Hyperlipidemia, Hypothyroidism, Mass - Kidney, Renal Cell Carcinoma.
34. Plaintiff GEORGE MCPHERSON resides at 2473 Adams Farm Court, Snow Camp,
NC 27349. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
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contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hashimotos Disease,
Hypothyroidism, Ulcerative Colitis.
35. Plaintiff ESTATE OF JAMES MCRAE resided at 9555 River Court, Jonesboro,
GA 30238. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Leukemia, Thyroid
Disease, Thyroid Problems.
36. Plaintiff MICHAEL MCVAY resides at 15009 Adelman Run Ct, Woodbridge, VA
22193. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease,
Hyperthyroidism.
37. Plaintiff GREGORY MEDARIS resides at 3332 Hartshire N Dr, Apt 15,
Bargersville, IN 46106. Plaintiff was formerly stationed at a military base or installation where
PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working
on base, Claimant was exposed to PFAS through daily activity and regularly consumed water
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containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result
of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As
a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with
Hyperlipidemia, Hypothyroidism.
38. Plaintiff ALAN MEDDERS resides at 7820 Arlington Rd., Brookbill, OH 45309.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, High Cholesterol,
Hyperthyroidism.
39. Plaintiff DAVID MEDLIN resides at 2050 Crossgate Blvd, Unit 201, Myrtle Beach,
SC 29575. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell Carcinoma.
40. Plaintiff CARMELITA MEDLOCK resides at 3802 W Francis Ave, Spokane, WA
99205. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
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levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia,
Ulcerative Colitis.
41. Plaintiff JOHN MEINERT resides at 1100 South 1st St, Apt 4, Milwaukee, WI
53204. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism.
42. Plaintiff THERESA MELTON resides at 6371 COLLINS RD, APT 118,
JACKSONVILLE, FL 32244. Plaintiff was formerly stationed at a military base or installation
where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While
working on base, Claimant was exposed to PFAS through daily activity and regularly consumed
water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as
a result of the PFAS contamination at the Sites, including at concentrations hazardous to their
health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with
Hypothyroidism.
43. Plaintiff TRAVIS MENDIOLA resides at 7568 FM 536, Floessvile, TX 78114.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
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Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism.
44. Plaintiff PEDRO MENENDEZ resides at 528 E 43rd St, Apt 3, Chicago, IL 60653.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell Carcinoma.
45. Plaintiff DAVID MERRIMAN resides at 3500 Slapton Ave, North Las Vegas, NV
89031. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Kidney
Cancer.
46. Plaintiff ALFRED MEUNIER resides at 652 Wellhouse Dr, Jacksonville, FL
32220. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
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contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Kidney Cancer, Prostate
Cancer.
47. Plaintiff DAVID MEYER resides at 206 GRANADA ST, REPUBLIC, MO 65738.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism.
48. Plaintiff YVONNE MEYER resides at 1677 SIGNALMAN CT, ODENTON, MD
21113. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism,
Thyroid Cancer, Thyroidectomy.
49. Plaintiff SCOTT MEZOFF resides at 11 Toledo Ave, Westfield, MA 01085-.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
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Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, High Cholesterol,
Hyperthyroidism.
50. Plaintiff YVONNE MICKENS resides at 7815 51st Ave, Sacramento, CA 95828.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Thyroid Cancer.
51. Plaintiff REBECCA MIESUK resides at 4234 Wintergreen Circle #285,
Bellingham, WA 98226-. Plaintiff was formerly stationed at a military base or installation where
PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working
on base, Claimant was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result
of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As
a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High
Cholesterol, Ulcerative Colitis.
52. Plaintiff CHESTER MILBURN resides at 719 south 900th east, Spanish fort, UT
84660. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
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contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypercholesteremia,
Prostate Cancer, Thyroid Nodules.
53. Plaintiff DOUGLAS MILLER resides at 10550 Silver Stirrup Dr, Colorado Springs,
CO 80925. Plaintiff was formerly stationed at a military base or installation where PFAS was used
(hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS
contamination at the Sites, including at concentrations hazardous to their health. As a direct and
proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol,
Hyperthyroidism.
54. Plaintiff GREGORY MILLER resides at 5369 Chalker Rd, Molino, FL 32577.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism.
55. Plaintiff LORNE MILLER resides at 6099 Barrows Road, Athens, OH 45701.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
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Sites, including at concentrations hazardous to their health. As a direct and proximate result of
Plaintiff’s exposure, Plaintiff has been diagnosed with Testicular Cancer.
56. Plaintiff EDWARD THOMAS MILLER SR resides at 1943 Artane Place,
Columbus, OH 43219. Plaintiff was formerly stationed at a military base or installation where
PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working
on base, Claimant was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result
of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As
a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell
Carcinoma.
57. Plaintiff JOHN MILLONIG resides at 5739 River Oak Dr, Savage, MN 55378.
Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter
the “Sites”) and was living on base during that time. While working on base, Claimant was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS.
Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the
Sites, including at concentrations hazardous to
Preview
FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY MICHAEL MCGLATHERY; GINA MCGLYNN; TANGER MCGRIFF; LISA MCGUIGAN; DEWEY MCKEE; RICHARD MCKINNEY; STACIE MCKINNEY; ROBERT JAMES GEORGE MCKNIGHT III; RUTH MCKOWN; MICHAEL MCMANUS; MICHAEL MCMASTER; CYNTHIA MCMILLAN; MURL MCMILLION; WILLIAM Index No. _________/2024 MCMULLIN; DAVID MCNAIR; MARK MCNEALY; LYNETTE MCNEILL; DONNA MCPHERSON; GEORGE COMPLAINT AND DEMAND FOR JURY TRIAL MCPHERSON; ESTATE OF JAMES MCRAE; MICHAEL MCVAY; GREGORY MEDARIS; ALAN MEDDERS; Trial by jury is desired in the DAVID MEDLIN; CARMELITA MEDLOCK; JOHN County of New York MEINERT; THERESA MELTON; TRAVIS MENDIOLA; PEDRO MENENDEZ; DAVID MERRIMAN; ALFRED Venue is designated pursuant to MEUNIER; DAVID MEYER; YVONNE MEYER; SCOTT CPLR § 503(a) & (c) in that the MEZOFF; YVONNE MICKENS; REBECCA MIESUK; causes of action occurred in this CHESTER MILBURN; DOUGLAS MILLER; GREGORY county. MILLER; LORNE MILLER; EDWARD THOMAS MILLER SR; JOHN MILLONIG; ROSA MILLS; TAYLOR MILLS; EDWARD MILSTEAD; EMERY MILTON; GREGORY L. MINIX; YOMARIE MIRANDA; MELQUIADES MIRANDA JR; NICHOLAS MIRRO; DENISE MITCHELL; DONNA MITCHELL; DORIS MITCHELL; JOSEPH MITCHELL; MARK MITCHELL; ROBERT MOBLEY; STEVEN MONAHAN; DONALD MONROE; RICKEY MONSON; ABRAHAM MONTES; WAYNE MOONEY; ESTATE OF BILLY MOORE; CALVIN MOORE; EDWARD MOORE; LISA MOORE; PATRICIA MOORE; ROBERT MOORE; CLAYTON MOORE JR.; EXIE MORALES; ESTATE OF ELIZABETH MORAN; MARK MORAN; SUE MORETZ; GREGORY MORGAN; KELLY MORGAN; AND LEO MORIN, Plaintiffs, -vs - THE 3M COMPANY, f/k/a Minnesota Mining and Manufacturing Co.; 1 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 AGC CHEMICALS AMERICAS INC.; AMEREX CORPORATION; ARKEMA INC.; ARCHROMA U.S. INC.; BUCKEYE FIRE EQUIPMENT COMPANY; CHEMDESIGN PRODUCTS INC.; CHEMGUARD INC.; CHEMICALS, INC.; CLARIANT CORPORATION, individually and as successor in interest to Sandoz Chemical Corporation; CORTEVA, INC., individually and as successor in interest to DuPont Chemical Solutions Enterprise; DEEPWATER CHEMICALS, INC.; DUPONT DE NEMOURS INC., individually and as successor in interest to DuPont Chemical Solutions Enterprise; DYNAX CORPORATION; E. I. DUPONT DE NEMOURS AND COMPANY, individually and as successor in interest to DuPont Chemical Solutions Enterprise; NATION FORD CHEMICAL COMPANY; THE CHEMOURS COMPANY, individually and as successor in interest to DuPont Chemical Solutions Enterprise; THE CHEMOURS COMPANY FC, LLC, individually and as successor in interest to DuPont Chemical Solutions Enterprise; TYCO FIRE PRODUCTS, LP, individually and as successor in interest to The Ansul Company; and DOE DEFENDANTS 1-20, fictitious names whose present identities are unknown, Defendants. COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiffs; MICHAEL MCGLATHERY; GINA MCGLYNN; TANGER MCGRIFF; LISA MCGUIGAN; DEWEY MCKEE; RICHARD MCKINNEY; STACIE MCKINNEY; ROBERT JAMES GEORGE MCKNIGHT III; RUTH MCKOWN; MICHAEL MCMANUS; MICHAEL MCMASTER; CYNTHIA MCMILLAN; MURL MCMILLION; WILLIAM MCMULLIN; DAVID MCNAIR; MARK MCNEALY; LYNETTE MCNEILL; DONNA MCPHERSON; 2 2 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 GEORGE MCPHERSON; ESTATE OF JAMES MCRAE; MICHAEL MCVAY; GREGORY MEDARIS; ALAN MEDDERS; DAVID MEDLIN; CARMELITA MEDLOCK; JOHN MEINERT; THERESA MELTON; TRAVIS MENDIOLA; PEDRO MENENDEZ; DAVID MERRIMAN; ALFRED MEUNIER; DAVID MEYER; YVONNE MEYER; SCOTT MEZOFF; YVONNE MICKENS; REBECCA MIESUK; CHESTER MILBURN; DOUGLAS MILLER; GREGORY MILLER; LORNE MILLER; EDWARD THOMAS MILLER SR; JOHN MILLONIG; ROSA MILLS; TAYLOR MILLS; EDWARD MILSTEAD; EMERY MILTON; GREGORY L. MINIX; YOMARIE MIRANDA; MELQUIADES MIRANDA JR; NICHOLAS MIRRO; DENISE MITCHELL; DONNA MITCHELL; DORIS MITCHELL; JOSEPH MITCHELL; MARK MITCHELL; ROBERT MOBLEY; STEVEN MONAHAN; DONALD MONROE; RICKEY MONSON; ABRAHAM MONTES; WAYNE MOONEY; ESTATE OF BILLY MOORE; CALVIN MOORE; EDWARD MOORE; LISA MOORE; PATRICIA MOORE; ROBERT MOORE; CLAYTON MOORE JR.; EXIE MORALES; ESTATE OF ELIZABETH MORAN; MARK MORAN; SUE MORETZ; GREGORY MORGAN; KELLY MORGAN; AND LEO MORIN, (“Plaintiffs”), by and through the undersigned counsel, hereby files this Complaint against Defendants, 3M COMPANY, f/k/a Minnesota Mining and Manufacturing Co., AGC CHEMICALS AMERICAS INC., AMEREX CORPORATION, ARKEMA INC., ARCHROMA U.S. INC., BUCKEYE FIRE EQUIPMENT COMPANY, CHEMDESIGN PRODUCTS INC., CHEMGUARD INC., CHEMICALS, INC., CLARIANT CORPORATION, CORTEVA, INC., DEEPWATER CHEMICALS, INC., DUPONT DE NEMOURS INC., DYNAX CORPORATION, E. I. DUPONT DE NEMOURS AND COMPANY, NATION FORD CHEMICAL COMPANY, THE CHEMOURS COMPANY, THE CHEMOURS COMPANY FC, LLC, and TYCO FIRE PRODUCTS, LP, and DOE DEFENDANTS 1-20, fictitious names whose 3 3 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 present identifies are unknown (collectively “Defendants”) and alleges, upon information and belief, as follows: INTRODUCTION 1. This action arises from the foreseeable contamination of groundwater by the use of aqueous film-forming foam (“AFFF”) products that contained per- and poly-fluoroalkyl substances (“PFAS”), including perfluoro octane sulfonate (“PFOS”) and perfluorooctanoic acid (“PFOA”). 2. PFOS and PFOA are fluor surfactants that repel oil, grease, and water. PFOS, PFOA, and/or their chemical precursors, are or were components of AFFF products, which are firefighting suppressant agents used in training and firefighting activities for fighting Class B fires. Class B fires include fires involving hydrocarbon fuels such as petroleum or other flammable liquids. 3. PFOS and PFOA are mobile, persist indefinitely in the environment, bioaccumulate in individual organisms and humans, and biomagnify up the food chain. PFOS and PFOA are also associated with multiple and significant adverse health effects in humans, including but not limited to kidney cancer, testicular cancer, high cholesterol, thyroid disease, ulcerative colitis, and pregnancy-induced hypertension. 4. At various times from the 1960s through today, Defendants designed, manufactured, marketed, distributed, and/or sold AFFF products containing PFOS, PFOA, and/or their chemical precursors, and/or designed, manufactured, marketed, distributed, and/or sold the fluor surfactants and/or per fluorinated chemicals (“PFCs”) contained in AFFF (collectively, “AFFF/Component Products”). 4 4 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 5. Defendants designed, manufactured, marketed, distributed, and/or sold AFFF/Component Products with the knowledge that these toxic compounds would be released into the environment during fire protection, training, and response activities, even when used as directed and intended by Defendants. 6. Since its creation in the 1960s, AFFF designed, manufactured, marketed, distributed, and/or sold by Defendants, and/or that contained fluorosurfactants and/or PFCs designed, manufactured, marketed, distributed, and/or sold by Defendants, used as directed and intended by Defendants, and subsequently released into the environment during fire protection, training, and response activities, resulting in widespread PFAS contamination. 7. Due to this contamination, Plaintiffs have suffered real personal injuries, bioaccumulation of PFAS in their bodies, property damage and the diminution in value of their properties as a result of the release of PFAS to their water supplies. 8. Plaintiffs have suffered an assortment of diseases and medical conditions as a direct result of their exposure to the PFAS contamination of their water supply. 9. Plaintiffs, as residents and those who visited, worked, or otherwise dwelled in the Site area, have been unknowingly exposed for many years to PFAS, including concentrations hazardous to their health. 10. Plaintiffs’ unwitting exposure to PFAS in their water supply as a result of the Defendants’ conduct, is the direct and proximate cause of Plaintiffs’ injuries. 11. Plaintiffs’ property has been damaged as a result of the presence of the PFAS in their water supply. 12. Plaintiffs seek recovery from Defendants for injuries, damages, and losses suffered by the Plaintiffs as a result of exposure to the introduction of PFAS and other toxic 5 5 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 substance into their water supply, and then into their properties and bodies, in an amount to be determined at trial, exclusive of interest, costs, and attorneys’ fees. JURISDICTION AND VENUE 13. This Court has jurisdiction because Defendant Dynax Corporation’s principal place of business is located at 103 Fairview Park Drive, Elmsford, New York 10523. 14. Venue is proper in this District under CPLR §503 (a) because the events, omissions and harms that are the basis of Plaintiffs claims occurred in substantial party in this District. 15. This Court has personal jurisdiction over Defendants by virtue of each Defendants’ regular and systematic contacts with New York, including, among other things, purposefully marketing, selling and/or distributing their AFFF/Component Products to and within New York, and because they have the requisite minimum contacts with New York necessary to constitutionally permit the Court to exercise jurisdiction over them consistent with traditional notions of fair play and substantial justice. PARTIES A. Plaintiffs 16. Plaintiff MICHAEL MCGLATHERY resides at 12324 SE 44th St, Choctaw, OK 73020. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Testicular Cancer. 17. Plaintiff GINA MCGLYNN resides at 1825 Poggi St APT # 214 A, Alameda, CA 94501. Plaintiff was formerly stationed at a military base or installation where PFAS was used 6 6 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Breast Cancer, Hypothyroidism. 18. Plaintiff TANGER MCGRIFF resides at 721 Hemenway Dr NE, Winter Haven, FL 33881. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, Hyperthyroidism, Hypothyroidism. 19. Plaintiff LISA MCGUIGAN resides at 3433 3rd Ave South, Apt 12, St. Petersburg, FL 33711. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Thyroid Disease, Thyroid Problems. 7 7 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 20. Plaintiff DEWEY MCKEE resides at 14533 Lee Hwy, Bristol, VA, VA 24202. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Mass - Kidney, Pancreatic Cancer, Renal Cancer, Renal Cell Carcinoma. 21. Plaintiff RICHARD MCKINNEY resides at 1418 Antioch Rd, Wilmington, OH 45177. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Mass - Kidney, Renal Cancer. 22. Plaintiff STACIE MCKINNEY resides at 23430 Stratford Ct, Southfield, MI 48033. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism. 8 8 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 23. Plaintiff ROBERT JAMES GEORGE MCKNIGHT III resides at 22523 E Piccolo Way, Aurora, CO 80016. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Renal Cell Carcinoma. 24. Plaintiff RUTH MCKOWN resides at 4320 Rustic Drive, New Port Richey, FL 34652-. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism. 25. Plaintiff MICHAEL MCMANUS resides at PO box 364, Somerset Center, MI 49282. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and 9 9 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hodgkins Lymphoma, Hypothyroidism. 26. Plaintiff MICHAEL MCMASTER resides at 6135 Hickory Creek Road, High Point, NC 27263. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Kidney Cancer. 27. Plaintiff CYNTHIA MCMILLAN resides at 1300 Belle Meade Cir SW, Mableton, GA 30126-. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Hyperlipidemia, Hypothyroidism, Kidney Cancer, Pregnancy Problems, Renal Cell Carcinoma, Thyroid Cancer. 28. Plaintiff MURL MCMILLION resides at 126 Crandall Dr, Culloden, WV 25510. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the 10 10 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism, Prostate Cancer, Thyroiditis. 29. Plaintiff WILLIAM MCMULLIN resides at 5148 Tonti Rd., Salem, IL 62881-. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Bladder Cancer, High Cholesterol, Hypothyroidism, Thyroid Problems. 30. Plaintiff DAVID MCNAIR resides at 6009 RIXEY DR, ALEXANDRIA, VA 22303. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypercholesteremia, Hypothyroidism. 31. Plaintiff MARK MCNEALY resides at 1200 Long Road, Centralia, WA 98531. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. 11 11 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Ulcerative Colitis. 32. Plaintiff LYNETTE MCNEILL resides at 2424 E 35th Ave, Spokane, WA 99223. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Hypothyroidism. 33. Plaintiff DONNA MCPHERSON resides at 708 Teal Ln, Altamonte Springs, FL 32701. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hashimotos Disease, Hyperlipidemia, Hypothyroidism, Mass - Kidney, Renal Cell Carcinoma. 34. Plaintiff GEORGE MCPHERSON resides at 2473 Adams Farm Court, Snow Camp, NC 27349. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS 12 12 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hashimotos Disease, Hypothyroidism, Ulcerative Colitis. 35. Plaintiff ESTATE OF JAMES MCRAE resided at 9555 River Court, Jonesboro, GA 30238. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Leukemia, Thyroid Disease, Thyroid Problems. 36. Plaintiff MICHAEL MCVAY resides at 15009 Adelman Run Ct, Woodbridge, VA 22193. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, Hyperthyroidism. 37. Plaintiff GREGORY MEDARIS resides at 3332 Hartshire N Dr, Apt 15, Bargersville, IN 46106. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water 13 13 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism. 38. Plaintiff ALAN MEDDERS resides at 7820 Arlington Rd., Brookbill, OH 45309. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, High Cholesterol, Hyperthyroidism. 39. Plaintiff DAVID MEDLIN resides at 2050 Crossgate Blvd, Unit 201, Myrtle Beach, SC 29575. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell Carcinoma. 40. Plaintiff CARMELITA MEDLOCK resides at 3802 W Francis Ave, Spokane, WA 99205. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated 14 14 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Ulcerative Colitis. 41. Plaintiff JOHN MEINERT resides at 1100 South 1st St, Apt 4, Milwaukee, WI 53204. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism. 42. Plaintiff THERESA MELTON resides at 6371 COLLINS RD, APT 118, JACKSONVILLE, FL 32244. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism. 43. Plaintiff TRAVIS MENDIOLA resides at 7568 FM 536, Floessvile, TX 78114. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. 15 15 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypothyroidism. 44. Plaintiff PEDRO MENENDEZ resides at 528 E 43rd St, Apt 3, Chicago, IL 60653. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell Carcinoma. 45. Plaintiff DAVID MERRIMAN resides at 3500 Slapton Ave, North Las Vegas, NV 89031. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Kidney Cancer. 46. Plaintiff ALFRED MEUNIER resides at 652 Wellhouse Dr, Jacksonville, FL 32220. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS 16 16 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Kidney Cancer, Prostate Cancer. 47. Plaintiff DAVID MEYER resides at 206 GRANADA ST, REPUBLIC, MO 65738. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism. 48. Plaintiff YVONNE MEYER resides at 1677 SIGNALMAN CT, ODENTON, MD 21113. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Thyroid Cancer, Thyroidectomy. 49. Plaintiff SCOTT MEZOFF resides at 11 Toledo Ave, Westfield, MA 01085-. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the 17 17 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, High Cholesterol, Hyperthyroidism. 50. Plaintiff YVONNE MICKENS resides at 7815 51st Ave, Sacramento, CA 95828. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism, Thyroid Cancer. 51. Plaintiff REBECCA MIESUK resides at 4234 Wintergreen Circle #285, Bellingham, WA 98226-. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Ulcerative Colitis. 52. Plaintiff CHESTER MILBURN resides at 719 south 900th east, Spanish fort, UT 84660. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS 18 18 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypercholesteremia, Prostate Cancer, Thyroid Nodules. 53. Plaintiff DOUGLAS MILLER resides at 10550 Silver Stirrup Dr, Colorado Springs, CO 80925. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with High Cholesterol, Hyperthyroidism. 54. Plaintiff GREGORY MILLER resides at 5369 Chalker Rd, Molino, FL 32577. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hypothyroidism. 55. Plaintiff LORNE MILLER resides at 6099 Barrows Road, Athens, OH 45701. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the 19 19 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 04:45 PM INDEX NO. 152260/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Testicular Cancer. 56. Plaintiff EDWARD THOMAS MILLER SR resides at 1943 Artane Place, Columbus, OH 43219. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to their health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Renal Cell Carcinoma. 57. Plaintiff JOHN MILLONIG resides at 5739 River Oak Dr, Savage, MN 55378. Plaintiff was formerly stationed at a military base or installation where PFAS was used (hereinafter the “Sites”) and was living on base during that time. While working on base, Claimant was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS. Claimant has been exposed for many years to PFAS as a result of the PFAS contamination at the Sites, including at concentrations hazardous to