Complaint,Petition: Dale Saxon, Thomas Sayers, Andrew Scalf, Dennis Henry Schafhuizen, Claudette Scheitel, James Schiefer, Richard Schilling, Ronald Schlecht, Dennis Schlechtweg, Jocelynn Schmalzer, Jerry Schmidt, Philip Schmitten, Tim Schmitz, Daryl Schossow, Gregory Schwab, Mark Schwarzer, Kathlyn Scuderi, David Seaman, Seaman Seitz, William Selby, Donald Seo, Glenda Shannon, Gregory Sharps, James Shegstad, Michael Shephard, Bernard Sherman, Todd Sherman Jr, James Sherrow, Wade Shoemaker, Ronald Short, Ruth Shultz, Anthony Shumaker, Joe Shuttleworth, Erich Siebel, Michael Sigg, Kenneth Sikorsky, Ester Simmons, John Simmons, Ronnie Simmons ESTATE OF, Sonya Simmons, Adrienne Simpson, Joseph Simpson, Joshua Simpson, Lena Simrell, Bryan Sims, Gary Sims, Jamie Sims, Matthew Sims, Russell Sims, Mark Sitterding, William Skeean, William Skeens, Robert Skiff, Franklin Skym Jr, Scott Slaydon, Annette Annette, David Smaby, Tyrone Small, Alan Smith, Anthony Smith, Candace Smith, Carlos Smith, Carolyn Smith, Charles Smith, Daniel Smith, Danny Smith, David Smith, Elijah Manuel Smith, Gary Lynn Smith, George Smith, Heidi Smith, Jeffery Smith, John Smith, Kenneth Smith, Marie Smith v. 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., 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, Doe Defendants 1-20 fictitious names whose present identities are unknown

On March 13, 2024 a Complaint,Petition was filed involving a dispute between Adrienne Simpson, Alan Smith, Andrew Scalf, Annette Annette, Anthony Shumaker, Anthony Smith, Bernard Sherman, Bryan Sims, Candace Smith, Carlos Smith, Carolyn Smith, Charles Smith, Claudette Scheitel, Dale Saxon, Daniel Smith, Danny Smith, Daryl Schossow, David Seaman, David Smaby, David Smith, Dennis Henry Schafhuizen, Dennis Schlechtweg, Donald Seo, Elijah Manuel Smith, Erich Siebel, Ester Simmons, Franklin Skym Jr, Gary Lynn Smith, Gary Sims, George Smith, Glenda Shannon, Gregory Schwab, Gregory Sharps, Heidi Smith, James Schiefer, James Shegstad, James Sherrow, Jamie Sims, Jeffery Smith, Jerry Schmidt, Jocelynn Schmalzer, Joe Shuttleworth, John Simmons, John Smith, Joseph Simpson, Joshua Simpson, Kathlyn Scuderi, Kenneth Sikorsky, Kenneth Smith, Lena Simrell, Marie Smith, Mark Schwarzer, Mark Sitterding, Matthew Sims, Michael Shephard, Michael Sigg, Philip Schmitten, Richard Schilling, Robert Skiff, Ronald Schlecht, Ronald Short, Ronnie Simmons Estate Of, Russell Sims, Ruth Shultz, Scott Slaydon, Seaman Seitz, Sonya Simmons, Thomas Sayers, Tim Schmitz, Todd Sherman Jr, Tyrone Small, Wade Shoemaker, William Selby, William Skeean, William Skeens, and Agc Chemicals Americas Inc., Amerex Corporation, Archroma U.S. Inc., Arkema 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., Doe Defendants 1-20 Fictitious Names Whose Present Identities Are Unknown, 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 3M Company F K A Minnesota Mining And Manufacturing Co., The Chemours Company Fc, Llc Individually And As Successor In Interest To Dupont Chemical Solutions Enterprise, The Chemours Company 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, for Torts - Environmental (Water Contamination) in the District Court of New York County.

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FILED: NEW YORK COUNTY CLERK 03/13/2024 10:13 AM INDEX NO. 152274/2024
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/13/2024

SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY

DALE SAXON; THOMAS SAYERS; ANDREW SCALF;
DENNIS HENRY SCHAFHUIZEN; CLAUDETTE
SCHEITEL; JAMES SCHIEFER; RICHARD SCHILLING;
RONALD SCHLECHT; DENNIS SCHLECHTWEG;
JOCELYNN SCHMALZER; JERRY SCHMIDT; PHILIP
SCHMITTEN; TIM SCHMITZ; DARYL SCHOSSOW; Index No. _________/2024
GREGORY SCHWAB; MARK SCHWARZER; KATHLYN
SCUDERI; DAVID SEAMAN; SUSAN SEITZ; WILLIAM COMPLAINT AND DEMAND
FOR JURY TRIAL
SELBY; DONALD SEO; GLENDA SHANNON;
GREGORY SHARPS; JAMES SHEGSTAD; MICHAEL Trial by jury is desired in the
SHEPHARD; BERNARD SHERMAN; TODD SHERMAN County of New York
SR; JAMES SHERROW; WADE SHOEMAKER;
RONALD SHORT; RUTH SHULTZ; ANTHONY Venue is designated pursuant to
SHUMAKER; JOE SHUTTLEWORTH; ERICH SIEBEL; CPLR § 503(a) & (c) in that the
MICHAEL SIGG; KENNETH SIKORSKY; ESTER causes of action occurred in this
SIMMONS; JOHN SIMMONS; ESTATE OF RONNIE county.
SIMMONS; SONYA SIMMONS; ADRIENNE SIMPSON;
JOSEPH SIMPSON; JOSHUA SIMPSON; LENA
SIMRELL; BRYAN SIMS; GARY SIMS; JAMIE SIMS;
MATTHEW SIMS; RUSSELL SIMS; MARK
SITTERDING; WILLIAM SKEEAN; WILLIAM SKEENS;
ROBERT SKIFF; FRANKLIN SKYM JR; SCOTT
SLAYDON; ANNETTE SLISH; DAVID SMABY;
TYRONE SMALL; ALAN SMITH; ANTHONY SMITH;
CANDACE SMITH; CARLOS SMITH; CAROLYN
SMITH; CHARLES SMITH; DANIEL SMITH; DANNY
SMITH; DAVID SMITH; ELIJAH MANUEL SMITH;
GARY LYNN SMITH; GEORGE SMITH; HEIDI SMITH;
JEFFERY SMITH; JOHN SMITH; KENNETH SMITH;
AND MARIE SMITH,

Plaintiffs,

-vs -

THE 3M COMPANY, f/k/a Minnesota Mining and
Manufacturing Co.;
AGC CHEMICALS AMERICAS INC.;

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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; DALE SAXON; THOMAS SAYERS; ANDREW SCALF; DENNIS HENRY

SCHAFHUIZEN; CLAUDETTE SCHEITEL; JAMES SCHIEFER; RICHARD SCHILLING;

RONALD SCHLECHT; DENNIS SCHLECHTWEG; JOCELYNN SCHMALZER; JERRY

SCHMIDT; PHILIP SCHMITTEN; TIM SCHMITZ; DARYL SCHOSSOW; GREGORY

SCHWAB; MARK SCHWARZER; KATHLYN SCUDERI; DAVID SEAMAN; SUSAN SEITZ;

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WILLIAM SELBY; DONALD SEO; GLENDA SHANNON; GREGORY SHARPS; JAMES

SHEGSTAD; MICHAEL SHEPHARD; BERNARD SHERMAN; TODD SHERMAN SR;

JAMES SHERROW; WADE SHOEMAKER; RONALD SHORT; RUTH SHULTZ; ANTHONY

SHUMAKER; JOE SHUTTLEWORTH; ERICH SIEBEL; MICHAEL SIGG; KENNETH

SIKORSKY; ESTER SIMMONS; JOHN SIMMONS; ESTATE OF RONNIE SIMMONS;

SONYA SIMMONS; ADRIENNE SIMPSON; JOSEPH SIMPSON; JOSHUA SIMPSON; LENA

SIMRELL; BRYAN SIMS; GARY SIMS; JAMIE SIMS; MATTHEW SIMS; RUSSELL SIMS;

MARK SITTERDING; WILLIAM SKEEAN; WILLIAM SKEENS; ROBERT SKIFF;

FRANKLIN SKYM JR; SCOTT SLAYDON; ANNETTE SLISH; DAVID SMABY; TYRONE

SMALL; ALAN SMITH; ANTHONY SMITH; CANDACE SMITH; CARLOS SMITH;

CAROLYN SMITH; CHARLES SMITH; DANIEL SMITH; DANNY SMITH; DAVID SMITH;

ELIJAH MANUEL SMITH; GARY LYNN SMITH; GEORGE SMITH; HEIDI SMITH;

JEFFERY SMITH; JOHN SMITH; KENNETH SMITH; AND MARIE SMITH, (“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:

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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”).

5. Defendants designed, manufactured, marketed, distributed, and/or sold

AFFF/Component Products with the knowledge that these toxic compounds would be released

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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

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.

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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 DALE SAXON resides at 114 Crestmont Lane, Pelham, AL 35124.

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, Renal Cell Carcinoma.

17. Plaintiff THOMAS SAYERS resides at 307 West 1450 north, Layton, UT 84041.

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 Hypercholesteremia, Hypothyroidism,

Renal Cell Carcinoma.

18. Plaintiff ANDREW SCALF resides at 138 THORNTON CT, SAINT

AUGUSTINE, FL 32092. 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.

19. Plaintiff DENNIS HENRY SCHAFHUIZEN resides at 411 Gold Finch Ln,

Fountain Valley, CA 92708. 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.

20. Plaintiff CLAUDETTE SCHEITEL resides at 200 East Main Street, Po Box 418,

Larimore, ND 58251. 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,

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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.

21. Plaintiff JAMES SCHIEFER resides at 6833 Mickylee Run, The Villages, FL

34762. 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.

22. Plaintiff RICHARD SCHILLING resides at 302 N Market St, Waterloo, IL 62298.

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, Liver Cancer.

23. Plaintiff RONALD SCHLECHT resides at 4118 Silvery Minnow Pl NW,

Albuquerque, NM 87120. 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

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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, Leukemia, Thyroid Disease.

24. Plaintiff DENNIS SCHLECHTWEG resides at 20846 Grapevine Lane, Mabelvale,

AR 72103. 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.

25. Plaintiff JOCELYNN SCHMALZER resides at 287 Zion Hill Rd, Milford, CT

06461-. 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, Leukemia, Non-Hodgkins Lymphoma, Thyroid Disease.

26. Plaintiff JERRY SCHMIDT resides at 508 N Church Street, Elkhoran, WI 53121.

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

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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.

27. Plaintiff PHILIP SCHMITTEN resides at 11740 NORTHPOINTE BLVD, APT

2203, TOMBALL, TX 77377. 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, Leukemia, Prostate Cancer.

28. Plaintiff TIM SCHMITZ resides at 333 NW 95th St, Oklahoma City, OK 73114.

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.

29. Plaintiff DARYL SCHOSSOW resides at 3018 Brambls Crest Dr, Southaven, MS

38672. 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, Kidney

Cancer, Mass - Kidney, Renal Cell Carcinoma.

30. Plaintiff GREGORY SCHWAB resides at PO Box 506, Greencastle, IN 46135.

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.

31. Plaintiff MARK SCHWARZER resides at 86 Elm St, North Brookfield, MA

01535-. 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.

32. Plaintiff KATHLYN SCUDERI resides at 5805 W Harmon Ave Unit 316, Las

Vegas, NV 89103. 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

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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,

Graves Disease, Hypothyroidism.

33. Plaintiff DAVID SEAMAN resides at 4202 N 20th Ave, Apt 129 B, Phoenix, AZ

85015. 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, Renal

Cancer.

34. Plaintiff SUSAN SEITZ resides at 1920 S 8th St, Apt 6C, St. Louis, MO 63104.

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.

35. Plaintiff WILLIAM SELBY resides at 5381 Marquette Drive, Coloma, MI 49038.

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 Thyroid Disease.

36. Plaintiff DONALD SEO resides at 20865 PSC 80, APO, AP 96367. 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.

37. Plaintiff GLENDA SHANNON resides at 5993 NE Highland Rd, Otis, OR 97368.

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.

38. Plaintiff GREGORY SHARPS resides at 11910 MARY CATHERINE DR,

CLINTON, MD 20735. 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

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a direct and proximate result of Plaintiff’s exposure, Plaintiff has been diagnosed with Kidney

Cancer.

39. Plaintiff JAMES SHEGSTAD resides at 2940 119th Ln NW, Coon Rapids, MN

55433. 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.

40. Plaintiff MICHAEL SHEPHARD resides at 2680 Cypress Dome Ct, St Cloud, FL

34772. 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 Neoplasm,

Hypercholesteremia, Hyperlipidemia, Hypothyroidism.

41. Plaintiff BERNARD SHERMAN resides at 15506 Cadiz Lane, Naples, FL 34110.

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, Ulcerative Colitis.

42. Plaintiff TODD SHERMAN SR resides at 185 Plantation Trace Dr, Longville, LA

70652. 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, Renal Cell Carcinoma.

43. Plaintiff JAMES SHERROW resides at 12 Holly Lane, Richmond, IN 47374.

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, Renal Cell

Carcinoma.

44. Plaintiff WADE SHOEMAKER resides at 8150 N Stemmons Fwy Suite 1131,

Dallas, TX 75247. 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

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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.

45. Plaintiff RONALD SHORT resides at 1323, Cormorant Ct, St Johns, FL 32259.

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, Leukemia.

46. Plaintiff RUTH SHULTZ resides at 207 Oak Rd, Powell, TN 37849. 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.

47. Plaintiff ANTHONY SHUMAKER resides at 48 4th Ave W, Dalls, GA 30157.

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 High Cholesterol, Kidney Cancer.

48. Plaintiff JOE SHUTTLEWORTH resides at 454 bisctown road, Lost Creek, WV

26385. 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.

49. Plaintiff ERICH SIEBEL resides at 8416 Barbeque Spur, Catlettsburg, KY 41129.

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.

50. Plaintiff MICHAEL SIGG resides at Po Box 95, Crook, CO 80726. 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

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exposure, Plaintiff has been diagnosed with Hyperlipidemia, Hypernephroma, Mass - Liver, Renal

Cell Carcinoma.

51. Plaintiff KENNETH SIKORSKY resides at 61 East Main Street, Stony Point, NY

10980. 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.

52. Plaintiff ESTER SIMMONS resides at 230 Debra Ct, Satellite Beach, FL 32937.

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, Goiter, Hyperlipidemia,

Thyroid Nodules.

53. Plaintiff JOHN SIMMONS resides at 106 Deerwood Trl, Havelock, NC 28532.

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, Thyroid Cancer, Thyroid

Problems.

54. Plaintiff ESTATE OF RONNIE SIMMONS resided at 3008 N 42nd St, Tampa, FL

33605. 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.

55. Plaintiff SONYA SIMMONS resides at 6418 Haskell St, Houston, TX 77007.

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.

56. Plaintiff ADRIENNE SIMPSON resides at 597 Frayser Dr, Memphis, TN 38127.

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.

57. Plaintiff JOSEPH SIMPSON resides at 160 James Roberts Rd, Downsville, LA

71234. 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.

58. Plaintiff JOSHUA SIMPSON resides at PO Box 315, East Carbon, UT 84520.

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 regula

Case Info

Case No.

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Document Filed Date

March 13, 2024

Case Filing Date

March 13, 2024

County

Parties

Adrienne Simpson Plaintiff
AGC CHEMICALS AMERICAS INC. Defendant
Alan Smith Plaintiff
AMEREX CORPORATION Defendant
Andrew Scalf Plaintiff
Annette Annette Plaintiff
Anthony Shumaker Plaintiff
Anthony Smith Plaintiff
ARCHROMA U.S. Inc. Defendant
ARKEMA INC. Defendant
Bernard Sherman Plaintiff
Bryan Sims Plaintiff
BUCKEYE FIRE EQUIPMENT COMPANY Defendant
Candace Smith Plaintiff
Carlos Smith Plaintiff
Carolyn Smith Plaintiff
Charles Smith Plaintiff
CHEMDESIGN PRODUCTS INC. Defendant
CHEMGUARD INC. Defendant
CHEMICALS, INC. Defendant
CLARIANT CORPORATION individually and as successor in interest to Sandoz Chemical Corporation Defendant
Claudette Scheitel Plaintiff
CORTEVA, INC. individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
Dale Saxon Plaintiff
Daniel Smith Plaintiff
Danny Smith Plaintiff
Daryl Schossow Plaintiff
David Seaman Plaintiff
David Smaby Plaintiff
David Smith Plaintiff
DEEPWATER CHEMICALS, INC. Defendant
Dennis Henry Schafhuizen Plaintiff
Dennis Schlechtweg Plaintiff
DOE DEFENDANTS 1-20 fictitious names whose present identities are unknown Defendant
Donald Seo Plaintiff
DUPONT DE NEMOURS INC. individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
DYNAX CORPORATION Defendant
E. I. DUPONT DE NEMOURS AND COMPANY individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
Elijah Manuel Smith Plaintiff
Erich Siebel Plaintiff
Ester Simmons Plaintiff
Franklin Skym JR Plaintiff
Gary lynn Smith Plaintiff
Gary Sims Plaintiff
George Smith Plaintiff
Glenda Shannon Plaintiff
Gregory Schwab Plaintiff
Gregory Sharps Plaintiff
Heidi Smith Plaintiff
James Schiefer Plaintiff
James Shegstad Plaintiff
James Sherrow Plaintiff
Jamie Sims Plaintiff
Jeffery Smith Plaintiff
Jerry Schmidt Plaintiff
Jocelynn Schmalzer Plaintiff
Joe Shuttleworth Plaintiff
John Simmons Plaintiff
John Smith Plaintiff
Joseph Simpson Plaintiff
Joshua Simpson Plaintiff
Kathlyn Scuderi Plaintiff
Kenneth Sikorsky Plaintiff
Kenneth Smith Plaintiff
LANCIOTTI, PATRICK JAMES Attorney for the Plaintiff
Lena Simrell Plaintiff
Marie Smith Plaintiff
Mark Schwarzer Plaintiff
Mark Sitterding Plaintiff
Matthew Sims Plaintiff
Michael Shephard Plaintiff
Michael Sigg Plaintiff
NATION FORD CHEMICAL COMPANY Defendant
Philip Schmitten Plaintiff
Richard Schilling Plaintiff
Robert Skiff Plaintiff
Ronald Schlecht Plaintiff
Ronald Short Plaintiff
Ronnie Simmons ESTATE OF Plaintiff
Russell Sims Plaintiff
Ruth Shultz Plaintiff
Scott Slaydon Plaintiff
Seaman Seitz Plaintiff
Sonya Simmons Plaintiff
THE 3M COMPANY f/k/a Minnesota Mining and Manufacturing Co. Defendant
THE CHEMOURS COMPANY FC, LLC individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
THE CHEMOURS COMPANY individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
Thomas Sayers Plaintiff
Tim Schmitz Plaintiff
Todd Sherman JR Plaintiff
TYCO FIRE PRODUCTS, LP individually and as successor in interest to The Ansul Company Defendant
Tyrone Small Plaintiff
Wade Shoemaker Plaintiff
William Selby Plaintiff
William Skeean Plaintiff
William Skeens Plaintiff

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