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FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024
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SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
DARIN EARL; DONNA EARLY; DAVID EARNEST;
GERALD EASLER; MARK JOHN EBBEN; BRIAN EBEL;
DANIEL EDEN; DAVID EDWARDS; NATHAN
EDWARDS; RONNIE EDWARDS; ESTATE OF JEFFREY
EDWARDSON; THOMAS EGAN; DAVID EGGEN;
BRANDON EISENACHER; REBECCA EISENACHER;
RONALD EISENACHER; CHERYL ELLIS; DEBRAH Index No. _________/2024
ELLIS; HERBERT ELLIS; JENNIFER ELLIS; WALTER
ELLIS; VALERIE ELLOINCHI; NICHOLAS ELMER; COMPLAINT AND DEMAND
JOAN ELPERS; TIMOTHY EMERSON; DEREK ENGELN; FOR JURY TRIAL
DONALD ENNIS; RANDALL EPSTEIN; STEVEN
EPSTEIN; CHRIS LEE ERBE; JOHN ERICKSON; FELIX Trial by jury is desired in the
ESPINOZA; MAX ESPINOZA; ALBERTO ESPINOZA JR; County of New York
LAWRENCE ESPOSITO; TOM ESTABROOK JR; JAVIER
P. ESTRADA; MISTY ESTRIDGE; PEGGY ETHERIDGE; Venue is designated pursuant to
JAMES EVANS; TAPIWA EVANS; ANTHONY CPLR § 503(a) & (c) in that the
EVERETT; SARAH EWERDS; WILLIAM EY; JAMES causes of action occurred in this
EYLER; FAITH FABER; CLINTON FAIRLESS; JANICE county.
FAISON; MARTIN FALCON; NICOLENA FALTER;
MICHAEL FANNING; JOHN FARLEY; TONY FARMER;
DANA FARNSWORTH; BELINDA FASSETT; JAMES
FAULKNER; CANDICE FAUNTLEROY; RONALD
FEHR; ROY FEIG; JAMES FELBER; WEYLIN
FELICILDA; ALAN FEREDAY; JOHN FERGUSON;
LARRY FERGUSON; WILBER FERREIRA; JACKSON
FIELDS; TECOLA FIELDS-MARTIN; GEORGE FINCH;
TODD FINGERLE; KEITH FINLEY; HORACE FISHER;
ESTATE OF JAMES FISHER; JAMIE FISHER; ARTHUR
SCOTT FITTON; AND JOHN FIXMER,
Plaintiffs,
-vs -
THE 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.;
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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; DARIN EARL; DONNA EARLY; DAVID EARNEST; GERALD EASLER;
MARK JOHN EBBEN; BRIAN EBEL; DANIEL EDEN; DAVID EDWARDS; NATHAN
EDWARDS; RONNIE EDWARDS; ESTATE OF JEFFREY EDWARDSON; THOMAS EGAN;
DAVID EGGEN; BRANDON EISENACHER; REBECCA EISENACHER; RONALD
EISENACHER; CHERYL ELLIS; DEBRAH ELLIS; HERBERT ELLIS; JENNIFER ELLIS;
WALTER ELLIS; VALERIE ELLOINCHI; NICHOLAS ELMER; JOAN ELPERS; TIMOTHY
EMERSON; DEREK ENGELN; DONALD ENNIS; RANDALL EPSTEIN; STEVEN EPSTEIN;
CHRIS LEE ERBE; JOHN ERICKSON; FELIX ESPINOZA; MAX ESPINOZA; ALBERTO
ESPINOZA JR; LAWRENCE ESPOSITO; TOM ESTABROOK JR; JAVIER P. ESTRADA;
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MISTY ESTRIDGE; PEGGY ETHERIDGE; JAMES EVANS; TAPIWA EVANS; ANTHONY
EVERETT; SARAH EWERDS; WILLIAM EY; JAMES EYLER; FAITH FABER; CLINTON
FAIRLESS; JANICE FAISON; MARTIN FALCON; NICOLENA FALTER; MICHAEL
FANNING; JOHN FARLEY; TONY FARMER; DANA FARNSWORTH; BELINDA FASSETT;
JAMES FAULKNER; CANDICE FAUNTLEROY; RONALD FEHR; ROY FEIG; JAMES
FELBER; WEYLIN FELICILDA; ALAN FEREDAY; JOHN FERGUSON; LARRY
FERGUSON; WILBER FERREIRA; JACKSON FIELDS; TECOLA FIELDS-MARTIN;
GEORGE FINCH; TODD FINGERLE; KEITH FINLEY; HORACE FISHER; ESTATE OF
JAMES FISHER; JAMIE FISHER; ARTHUR SCOTT FITTON; AND JOHN FIXMER,
(“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
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
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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”).
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
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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
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.
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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 DARIN EARL resides at 5 Center Street, Macedon, NY 14502. 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.
17. Plaintiff DONNA EARLY resides at 1636 PARKVIEW DR S, MONTGOMERY,
AL 36117. 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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18. Plaintiff DAVID EARNEST resides at 4311 Lodge Rd, Oscoda, MI 48750.
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 Prostate Cancer, Thyroid Nodules.
19. Plaintiff GERALD EASLER resides at 7144 Bimini dr., Port Richie, FL 34668.
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, Mass - Testicular,
Testicular Cancer.
20. Plaintiff MARK JOHN EBBEN resides at 43539 Castlewood Dr, Novi, MI 48375.
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 Hypertension, Kidney Cancer, Mass -
Kidney, Renal Cell Carcinoma.
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21. Plaintiff BRIAN EBEL resides at 552 Brimhall St, Saint Paul, MN 55116. 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.
22. Plaintiff DANIEL EDEN resides at 1926 Hodgson St, Eureka, CA 95503. 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 Ulcerative Colitis.
23. Plaintiff DAVID EDWARDS resides at 1665 E 1300 N, Layton, UT 84040.
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.
24. Plaintiff NATHAN EDWARDS resides at 415 Cross Creek Way, Warner Robins,
GA, GA 31088. Plaintiff was formerly stationed at a military base or installation where PFAS was
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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.
25. Plaintiff RONNIE EDWARDS resides at 5500 De Soto Street, Apartment #2814,
Houston, TX 77091. 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,
Testicular Cancer.
26. Plaintiff ESTATE OF JEFFREY EDWARDSON resided at 128 Isaac Millsaps Trl,
Bastrop, TX 78602. 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,
Ulcerative Colitis.
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27. Plaintiff THOMAS EGAN resides at 2256 Mariposa Ave, Port Orange, FL 32129.
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 Goiter, Graves Disease, Hyperlipidemia,
Hyperthyroidism, Hypothyroidism, Thyroid Disease, Thyroid Problems.
28. Plaintiff DAVID EGGEN resides at 13297 Old Highway 67, Biloxi, MS, MS 39532.
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.
29. Plaintiff BRANDON EISENACHER resides at 5555 ALLIE RAE ST, MILTON,
FL 32570. 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, Thyroid Disease, Thyroiditis.
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30. Plaintiff REBECCA EISENACHER resides at 5555 ALLIE RAE ST, MILTON,
FL 32570. 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,
Thyroid Cancer.
31. Plaintiff RONALD EISENACHER resides at 5555 Allie Rae Street, Milton, FL
32570. 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, Non-Hodgkins Lymphoma.
32. Plaintiff CHERYL ELLIS resides at 17033, E Rockbridge Ave, BATON ROUGE,
LA 70801. 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 Hyperlipidemia, Renal
Cell Carcinoma.
33. Plaintiff DEBRAH ELLIS resides at 1540 Silver Ridge Dr, Cantonment, FL 32533.
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.
34. Plaintiff HERBERT ELLIS resides at 6391 OLD GLORY 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 Kidney
Cancer, Mass - Kidney, Renal Cell Carcinoma.
35. Plaintiff JENNIFER ELLIS resides at 19702 Tt Clark Rd., Opp, AL 36467. 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 Hyperthyroidism.
36. Plaintiff WALTER ELLIS resides at 11638 White Water Trail, Houston, TX 77013.
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, Testicular Cancer.
37. Plaintiff VALERIE ELLOINCHI resides at 106 S Trotman Rd, Camden, NC 27921.
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 Hyperthyroidism, Hypothyroidism.
38. Plaintiff NICHOLAS ELMER resides at P.O. Box 1927, Evanston, WY 82931.
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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39. Plaintiff JOAN ELPERS resides at 498 White Oak Court, Villa Ridge, MO 63089.
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, Thyroid
Cancer, Thyroid Nodules.
40. Plaintiff TIMOTHY EMERSON resides at 8120 Richfield Dr, Norfolk, VA 23518.
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 Mass - Testicular, Testicular Cancer.
41. Plaintiff DEREK ENGELN resides at 26013 W Forrester Dr, Plainfield, IL 60585.
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, Hypothyroidism.
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42. Plaintiff DONALD ENNIS resides at 52 Pecan Lane, Eastman, GA 31023. 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, Hypercholesteremia,
Kidney Cancer, Mass - Kidney, Renal Cell Carcinoma.
43. Plaintiff RANDALL EPSTEIN resides at 1634 Vermont St, Quincy, IL 62301.
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, Hypercholesteremia,
Hypothyroidism.
44. Plaintiff STEVEN EPSTEIN resides at 9617 AUSTIN AVE, OAK LAWN, IL
60453. 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.
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45. Plaintiff CHRIS LEE ERBE resides at 5420 Hilltop Ave, Panama City, FL 32408.
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 Cancer, Renal Cell Carcinoma,
Testicular Cancer.
46. Plaintiff JOHN ERICKSON resides at 7924 46th Ave, Kenosha, WI 53142.
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, Leukemia, Renal Cell
Carcinoma.
47. Plaintiff FELIX ESPINOZA resides at 4727 COFFEE TREE DR,
FAYETTEVILLE, NC 28314. 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
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health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with
Graves Disease, Hyperthyroidism.
48. Plaintiff MAX ESPINOZA resides at 4205 Laguna Seca Ct, Modesto, CA 95356.
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, Thyroid
Cancer, Thyroidectomy.
49. Plaintiff ALBERTO ESPINOZA JR resides at 4601-52Nd Street, Apt 5C, Lubbock,
TX 79414. 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.
50. Plaintiff LAWRENCE ESPOSITO resides at 17002 N 96th Ave, Sun City, AZ, AZ
85373. 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 Hyperlipidemia, Mass
- Kidney, Renal Cell Carcinoma.
51. Plaintiff TOM ESTABROOK JR resides at 55 Roberts Pond Lane, Chicopee, MA
01020-. 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, Prostate Cancer.
52. Plaintiff JAVIER P. ESTRADA resides at 8469 Spring Creek Loop, Salado, TX
76571. 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.
53. Plaintiff MISTY ESTRIDGE resides at 19031 FM850, Arp, TX 75750. 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 Hypothyroidism, Ulcerative Colitis.
54. Plaintiff PEGGY ETHERIDGE resides at 3846 WINDRIDGE CT,
JACKSONVILLE, FL 32257. 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
Breast Cancer, Hypothyroidism.
55. Plaintiff JAMES EVANS resides at 913 Corntassel Rd, Vonore, TN 37885-.
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, Prostate Cancer, Thyroid
Nodules.
56. Plaintiff TAPIWA EVANS resides at 7211 Hoffman Dr, Evans, GA 30809.
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, Renal Cell Carcinoma.
57. Plaintiff ANTHONY EVERETT resides at 3727 S Atlantic Ave Unit 224, Daytona
Beach, FL 32218. 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, Testicular Cancer.
Preview
FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY DARIN EARL; DONNA EARLY; DAVID EARNEST; GERALD EASLER; MARK JOHN EBBEN; BRIAN EBEL; DANIEL EDEN; DAVID EDWARDS; NATHAN EDWARDS; RONNIE EDWARDS; ESTATE OF JEFFREY EDWARDSON; THOMAS EGAN; DAVID EGGEN; BRANDON EISENACHER; REBECCA EISENACHER; RONALD EISENACHER; CHERYL ELLIS; DEBRAH Index No. _________/2024 ELLIS; HERBERT ELLIS; JENNIFER ELLIS; WALTER ELLIS; VALERIE ELLOINCHI; NICHOLAS ELMER; COMPLAINT AND DEMAND JOAN ELPERS; TIMOTHY EMERSON; DEREK ENGELN; FOR JURY TRIAL DONALD ENNIS; RANDALL EPSTEIN; STEVEN EPSTEIN; CHRIS LEE ERBE; JOHN ERICKSON; FELIX Trial by jury is desired in the ESPINOZA; MAX ESPINOZA; ALBERTO ESPINOZA JR; County of New York LAWRENCE ESPOSITO; TOM ESTABROOK JR; JAVIER P. ESTRADA; MISTY ESTRIDGE; PEGGY ETHERIDGE; Venue is designated pursuant to JAMES EVANS; TAPIWA EVANS; ANTHONY CPLR § 503(a) & (c) in that the EVERETT; SARAH EWERDS; WILLIAM EY; JAMES causes of action occurred in this EYLER; FAITH FABER; CLINTON FAIRLESS; JANICE county. FAISON; MARTIN FALCON; NICOLENA FALTER; MICHAEL FANNING; JOHN FARLEY; TONY FARMER; DANA FARNSWORTH; BELINDA FASSETT; JAMES FAULKNER; CANDICE FAUNTLEROY; RONALD FEHR; ROY FEIG; JAMES FELBER; WEYLIN FELICILDA; ALAN FEREDAY; JOHN FERGUSON; LARRY FERGUSON; WILBER FERREIRA; JACKSON FIELDS; TECOLA FIELDS-MARTIN; GEORGE FINCH; TODD FINGERLE; KEITH FINLEY; HORACE FISHER; ESTATE OF JAMES FISHER; JAMIE FISHER; ARTHUR SCOTT FITTON; AND JOHN FIXMER, Plaintiffs, -vs - THE 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.; 1 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 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; DARIN EARL; DONNA EARLY; DAVID EARNEST; GERALD EASLER; MARK JOHN EBBEN; BRIAN EBEL; DANIEL EDEN; DAVID EDWARDS; NATHAN EDWARDS; RONNIE EDWARDS; ESTATE OF JEFFREY EDWARDSON; THOMAS EGAN; DAVID EGGEN; BRANDON EISENACHER; REBECCA EISENACHER; RONALD EISENACHER; CHERYL ELLIS; DEBRAH ELLIS; HERBERT ELLIS; JENNIFER ELLIS; WALTER ELLIS; VALERIE ELLOINCHI; NICHOLAS ELMER; JOAN ELPERS; TIMOTHY EMERSON; DEREK ENGELN; DONALD ENNIS; RANDALL EPSTEIN; STEVEN EPSTEIN; CHRIS LEE ERBE; JOHN ERICKSON; FELIX ESPINOZA; MAX ESPINOZA; ALBERTO ESPINOZA JR; LAWRENCE ESPOSITO; TOM ESTABROOK JR; JAVIER P. ESTRADA; 2 2 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 MISTY ESTRIDGE; PEGGY ETHERIDGE; JAMES EVANS; TAPIWA EVANS; ANTHONY EVERETT; SARAH EWERDS; WILLIAM EY; JAMES EYLER; FAITH FABER; CLINTON FAIRLESS; JANICE FAISON; MARTIN FALCON; NICOLENA FALTER; MICHAEL FANNING; JOHN FARLEY; TONY FARMER; DANA FARNSWORTH; BELINDA FASSETT; JAMES FAULKNER; CANDICE FAUNTLEROY; RONALD FEHR; ROY FEIG; JAMES FELBER; WEYLIN FELICILDA; ALAN FEREDAY; JOHN FERGUSON; LARRY FERGUSON; WILBER FERREIRA; JACKSON FIELDS; TECOLA FIELDS-MARTIN; GEORGE FINCH; TODD FINGERLE; KEITH FINLEY; HORACE FISHER; ESTATE OF JAMES FISHER; JAMIE FISHER; ARTHUR SCOTT FITTON; AND JOHN FIXMER, (“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 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 3 3 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 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”). 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 4 4 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 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 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. 5 5 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 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 DARIN EARL resides at 5 Center Street, Macedon, NY 14502. 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. 17. Plaintiff DONNA EARLY resides at 1636 PARKVIEW DR S, MONTGOMERY, AL 36117. 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. 6 6 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 18. Plaintiff DAVID EARNEST resides at 4311 Lodge Rd, Oscoda, MI 48750. 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 Prostate Cancer, Thyroid Nodules. 19. Plaintiff GERALD EASLER resides at 7144 Bimini dr., Port Richie, FL 34668. 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, Mass - Testicular, Testicular Cancer. 20. Plaintiff MARK JOHN EBBEN resides at 43539 Castlewood Dr, Novi, MI 48375. 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 Hypertension, Kidney Cancer, Mass - Kidney, Renal Cell Carcinoma. 7 7 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 21. Plaintiff BRIAN EBEL resides at 552 Brimhall St, Saint Paul, MN 55116. 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. 22. Plaintiff DANIEL EDEN resides at 1926 Hodgson St, Eureka, CA 95503. 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 Ulcerative Colitis. 23. Plaintiff DAVID EDWARDS resides at 1665 E 1300 N, Layton, UT 84040. 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. 24. Plaintiff NATHAN EDWARDS resides at 415 Cross Creek Way, Warner Robins, GA, GA 31088. Plaintiff was formerly stationed at a military base or installation where PFAS was 8 8 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 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. 25. Plaintiff RONNIE EDWARDS resides at 5500 De Soto Street, Apartment #2814, Houston, TX 77091. 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, Testicular Cancer. 26. Plaintiff ESTATE OF JEFFREY EDWARDSON resided at 128 Isaac Millsaps Trl, Bastrop, TX 78602. 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, Ulcerative Colitis. 9 9 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 27. Plaintiff THOMAS EGAN resides at 2256 Mariposa Ave, Port Orange, FL 32129. 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 Goiter, Graves Disease, Hyperlipidemia, Hyperthyroidism, Hypothyroidism, Thyroid Disease, Thyroid Problems. 28. Plaintiff DAVID EGGEN resides at 13297 Old Highway 67, Biloxi, MS, MS 39532. 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. 29. Plaintiff BRANDON EISENACHER resides at 5555 ALLIE RAE ST, MILTON, FL 32570. 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, Thyroid Disease, Thyroiditis. 10 10 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 30. Plaintiff REBECCA EISENACHER resides at 5555 ALLIE RAE ST, MILTON, FL 32570. 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, Thyroid Cancer. 31. Plaintiff RONALD EISENACHER resides at 5555 Allie Rae Street, Milton, FL 32570. 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, Non-Hodgkins Lymphoma. 32. Plaintiff CHERYL ELLIS resides at 17033, E Rockbridge Ave, BATON ROUGE, LA 70801. 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 11 11 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Renal Cell Carcinoma. 33. Plaintiff DEBRAH ELLIS resides at 1540 Silver Ridge Dr, Cantonment, FL 32533. 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. 34. Plaintiff HERBERT ELLIS resides at 6391 OLD GLORY 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 Kidney Cancer, Mass - Kidney, Renal Cell Carcinoma. 35. Plaintiff JENNIFER ELLIS resides at 19702 Tt Clark Rd., Opp, AL 36467. 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 12 12 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 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 Hyperthyroidism. 36. Plaintiff WALTER ELLIS resides at 11638 White Water Trail, Houston, TX 77013. 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, Testicular Cancer. 37. Plaintiff VALERIE ELLOINCHI resides at 106 S Trotman Rd, Camden, NC 27921. 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 Hyperthyroidism, Hypothyroidism. 38. Plaintiff NICHOLAS ELMER resides at P.O. Box 1927, Evanston, WY 82931. 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. 13 13 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 39. Plaintiff JOAN ELPERS resides at 498 White Oak Court, Villa Ridge, MO 63089. 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, Thyroid Cancer, Thyroid Nodules. 40. Plaintiff TIMOTHY EMERSON resides at 8120 Richfield Dr, Norfolk, VA 23518. 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 Mass - Testicular, Testicular Cancer. 41. Plaintiff DEREK ENGELN resides at 26013 W Forrester Dr, Plainfield, IL 60585. 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, Hypothyroidism. 14 14 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 42. Plaintiff DONALD ENNIS resides at 52 Pecan Lane, Eastman, GA 31023. 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, Hypercholesteremia, Kidney Cancer, Mass - Kidney, Renal Cell Carcinoma. 43. Plaintiff RANDALL EPSTEIN resides at 1634 Vermont St, Quincy, IL 62301. 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, Hypercholesteremia, Hypothyroidism. 44. Plaintiff STEVEN EPSTEIN resides at 9617 AUSTIN AVE, OAK LAWN, IL 60453. 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. 15 15 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 45. Plaintiff CHRIS LEE ERBE resides at 5420 Hilltop Ave, Panama City, FL 32408. 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 Cancer, Renal Cell Carcinoma, Testicular Cancer. 46. Plaintiff JOHN ERICKSON resides at 7924 46th Ave, Kenosha, WI 53142. 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, Leukemia, Renal Cell Carcinoma. 47. Plaintiff FELIX ESPINOZA resides at 4727 COFFEE TREE DR, FAYETTEVILLE, NC 28314. 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 16 16 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 health. As a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Graves Disease, Hyperthyroidism. 48. Plaintiff MAX ESPINOZA resides at 4205 Laguna Seca Ct, Modesto, CA 95356. 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, Thyroid Cancer, Thyroidectomy. 49. Plaintiff ALBERTO ESPINOZA JR resides at 4601-52Nd Street, Apt 5C, Lubbock, TX 79414. 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. 50. Plaintiff LAWRENCE ESPOSITO resides at 17002 N 96th Ave, Sun City, AZ, AZ 85373. 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 17 17 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/12/2024 proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Hyperlipidemia, Mass - Kidney, Renal Cell Carcinoma. 51. Plaintiff TOM ESTABROOK JR resides at 55 Roberts Pond Lane, Chicopee, MA 01020-. 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, Prostate Cancer. 52. Plaintiff JAVIER P. ESTRADA resides at 8469 Spring Creek Loop, Salado, TX 76571. 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. 53. Plaintiff MISTY ESTRIDGE resides at 19031 FM850, Arp, TX 75750. 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 18 18 of 71 FILED: NEW YORK COUNTY CLERK 03/12/2024 02:02 PM INDEX NO. 152251/2024 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 Hypothyroidism, Ulcerative Colitis. 54. Plaintiff PEGGY ETHERIDGE resides at 3846 WINDRIDGE CT, JACKSONVILLE, FL 32257. 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 Breast Cancer, Hypothyroidism. 55. Plaintiff JAMES EVANS resides at 913 Corntassel Rd, Vonore, TN 37885-. 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, Prostate Cancer, Thyroid Nodules. 56. Plaintiff TAPIWA EVANS resides at 7211 Hoffman Dr, Evans, GA 30809. 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 02:02 PM INDEX NO. 152251/2024 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, Renal Cell Carcinoma. 57. Plaintiff ANTHONY EVERETT resides at 3727 S Atlantic Ave Unit 224, Daytona Beach, FL 32218. 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, Testicular Cancer.