Preview
FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024
SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
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CRAIG ANTON; CARL ARMATO; DAVID BANKS SR;
ANIELLO BARRELLA; FRANCISCO CARRILLO; Index No. _________/2023
ZENOVIA CASTRO; GREG CHEW; JAMES DANIELS;
SUMMONS
MARTIN DANNER; JOSEPH DOUBRLEY; RON
ELDER; CASSANDRA FARINAS; TONY GAYLES; Venue is designated pursuant to
CLIFFORD HANSEN; EULYS HUNT JACKSON; CPLR § 503(a) & (c) in that
BRUCE JACKSON; MICHAEL JOHNSTON; JOSEPH NEW YORK in this county.
KERSEY; ALEX KRYKEWYCZ; JOHN KUPP; LES
LEVINE; MARTIN LIRA; DONALD LOFTIS; DAVID
MACLACHLAN; JOHN MAULDIN; DENISE
MAYNARD; KEVIN MOORE; EDWARD MOSS; JOHN
POMARICO; MERRIE REED; STEPHEN RUMBURG;
TAMMY SPERLING; MARK STEIN; PATRICIA
STROOPE; BETTY STUTES; JACK VAN; GILBERT
VEA; JAY WARREN; MICHAEL WHITE; ROBERT
ADAMKOSKI; GARY GLENN; DALE HOWELL;
WILLIAM LASWELL; JOSEPH MCHUGH; PHILIP
SCALISE; NANCY CUNNINGHAM; ETTA SMITH;
PATRICIA BRIGHT; SYLVIA CAPEL; DEBRA GORE;
Plaintiffs,
-against -
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
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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;
Defendants.
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To the above-named Defendant:
You are hereby summoned to answer the Complaint in this action, and to serve a copy of
your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of
Appearance on the Plaintiffs’ attorneys within twenty (20) days after the service of this Summons,
exclusive of the day of service, where service is made by delivery upon you personally within the
state, or, within thirty (30) days after completion of service where service is made in any other
manner. In case of your failure to appear or answer, judgment will be taken against you by default
for the relief demanded in the Complaint.
Dated: New York, New York
March 13, 2024
Napoli Shkolnik, PLLC
Attorneys for Plaintiff
/s/ Nicholas Mindicino
Nicholas Mindicino, Esq.
360 Lexington Avenue, 11th Floor
New York, New York 10017
212-397-1000
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NMindicino@napolilaw.com
To:
3M COMPANY
c/o Corporation Service Company
251 Little Falls Drive
Wilmington, New Castle, DE 19808
AGC CHEMICALS AMERICAS INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
AMEREX CORPORATION
c/o James M. Proctor II
2900 Highway 280
Suite 300
Birmingham, AL 35223
ARCHROMA U.S. INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
ARKEMA INC.
900 First Avenue
King of Prussia, PA 19406
BUCKEYE FIRE EQUIPMENT COMPANY
c/o A Haon Corporate Agent, Inc.
29225 Chagrin Blvd, Suite 350
Pepper Pike, OH 44122
CHEMDESIGN PRODUCTS INC.
c/o Corporation Service Company
251 Little Falls Drive
Wilmington, New Castle, DE, 19808
CHEMGUARD INC.
c/o The Prentice-Hall Corporation System, Inc.
251 Little Falls Drive
Wilmington, New Castle, DE, 19808
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CHEMICALS, INC.
c/o Ashok K. Moza
12321 Hatcherville
Baytown, TX 77520
CLARIANT CORPORATION
c/o Corporation Service Company
8040 Excelsior Drive, Suite 400
Madison, WI 53717
CORTEVA, INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
DEEPWATER CHEMICALS, INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
DUPONT DE NEMOURS INC.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
DYNAX CORPORATION
c/o Corporate Systems LLC
3500 S. Dupont Highway
Dover, DE 19901
E. I. DUPONT DE NEMOURS AND COMPANY
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
NATION FORD CHEMICAL COMPANY
c/o John A. Dickson, IV
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2300 Bank Street
Fort Mill, SC 29715
THE CHEMOURS COMPANY
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
THE CHEMOURS COMPANY FC, LLC
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
TYCO FIRE PRODUCTS LP
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
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SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
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CRAIG ANTON; CARL ARMATO; DAVID BANKS SR; Index No. _________/2023
ANIELLO BARRELLA; FRANCISCO CARRILLO;
ZENOVIA CASTRO; GREG CHEW; JAMES DANIELS; COMPLAINT AND DEMAND
FOR JURY TRIAL
MARTIN DANNER; JOSEPH DOUBRLEY; RON ELDER;
CASSANDRA FARINAS; TONY GAYLES; CLIFFORD Trial by jury is desired in the
HANSEN; EULYS HUNT JACKSON; BRUCE JACKSON; County of New York
MICHAEL JOHNSTON; JOSEPH KERSEY; ALEX
KRYKEWYCZ; JOHN KUPP; LES LEVINE; MARTIN Venue is designated pursuant to
LIRA; DONALD LOFTIS; DAVID MACLACHLAN; CPLR § 503(a) & (c) in that the
JOHN MAULDIN; DENISE MAYNARD; KEVIN causes of action occurred in this
MOORE; EDWARD MOSS; JOHN POMARICO; MERRIE county.
REED; STEPHEN RUMBURG; TAMMY SPERLING;
MARK STEIN; PATRICIA STROOPE; BETTY STUTES;
JACK VAN; GILBERT VEA; JAY WARREN; MICHAEL
WHITE; ROBERT ADAMKOSKI; GARY GLENN; DALE
HOWELL; WILLIAM LASWELL; JOSEPH MCHUGH;
PHILIP SCALISE; NANCY CUNNINGHAM; ETTA
SMITH; PATRICIA BRIGHT; SYLVIA CAPEL; DEBRA
GORE; Plaintiffs,
-against -
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;
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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;
Defendants.
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COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiffs CRAIG ANTON, CARL ARMATO, DAVID BANKS SR, ANIELLO
BARRELLA, FRANCISCO CARRILLO, ZENOVIA CASTRO, GREG CHEW, JAMES
DANIELS, MARTIN DANNER, JOSEPH DOUBRLEY, RON ELDER, CASSANDRA
FARINAS, TONY GAYLES, CLIFFORD HANSEN, EULYS HUNT JACKSON, BRUCE
JACKSON, MICHAEL JOHNSTON, JOSEPH KERSEY, ALEX KRYKEWYCZ, JOHN KUPP,
LES LEVINE, MARTIN LIRA, DONALD LOFTIS, DAVID MACLACHLAN, JOHN
MAULDIN, DENISE MAYNARD, KEVIN MOORE, EDWARD MOSS, JOHN POMARICO,
MERRIE REED, STEPHEN RUMBURG, TAMMY SPERLING, MARK STEIN, PATRICIA
STROOPE, BETTY STUTES, JACK VAN, GILBERT VEA, JAY WARREN, MICHAEL
WHITE, ROBERT ADAMKOSKI, GARY GLENN, DALE HOWELL, WILLIAM LASWELL,
JOSEPH MCHUGH, PHILIP SCALISE, NANCY CUNNINGHAM, ETTA SMITH, PATRICIA
BRIGHT, SYLVIA CAPEL, AND DEBRA GORE, (“Plaintiffs”), by and through the undersigned
counsel, hereby files this Complaint against Defendants, 3M COMPANY, f/k/a Minnesota Mining
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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
substances (“PFAS”), including perfluoro octane sulfonate (“PFOS”) and perfluorooctanoic acid
(“PFOA”).
2. PFOS and PFOA are fluorosurfactants 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.
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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
fluorosurfactants 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
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 have been unknowingly exposed to the PFAS through contamination of
their drinking water supply for many years at 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.
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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 part 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. Craig Anton resides at 19042 Gearhart Dr, Macomb MI 48042.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
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including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
17. Carl Armato resides at 6582 chartwell dr, ROCKFORD IL 61114.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
18. David Banks Sr resides at 17 Turner Dr, RANDOLPH MA 02368. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
19. Aniello Barrella resides at 505 Swartley Rd, Hatfield PA 19440.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
20. Francisco Carrillo resides at 12235 Henri Matisse, El Paso TX 79936.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
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been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
21. Zenovia Castro resides at 20 Preston Street, Bogota NJ 07603.Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
22. Greg Chew resides at 2108 E Poinsettia Ave, Tampa FL 33612.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
23. James Daniels resides at 3931 Water House Dr, DALLAS TX 75241.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
24. Martin Danner resides at 930 8th St, Rawlins WY 82301.Plaintiff was exposed to
PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
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which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
25. Joseph Doubrley resides at 4191 56th Ave N, St. Petersburg FL 33714.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
26. Ron Elder resides at 29021 Highway 99E, Shedd OR 97377.Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
27. Cassandra Farinas resides at 8810 SW 123rd Court M302, Miami FL
33186.Plaintiff was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS which upon information and belief was caused by use and
misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS
contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a
direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer.
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28. Tony Gayles resides at 3608 Tarragon Road , Louisville KY 40219.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
29. Clifford Hansen resides at 6650 E. Russell Road, Las Vegas NV 89122.Plaintiff
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS which upon information and belief was caused by use and misuse of AFFF.
Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused
by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate
result of Plaintiff has suffered from injuries including Testicular Cancer.
30. Eulys Hunt Jackson resides at 3704 Trafalgar Way, Montgomery AL
36116.Plaintiff was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS which upon information and belief was caused by use and
misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS
contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a
direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer.
31. Bruce Jackson resides at 25354 Ember Rd, Middleton ID 83644.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
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including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
32. Michael Johnston resides at 511 Timberlake Trail, Jacksonville NC 28546.Plaintiff
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS which upon information and belief was caused by use and misuse of AFFF.
Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused
by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate
result of Plaintiff has suffered from injuries including Kidney Cancer.
33. Joseph Kersey resides at 37294 Gene Hughes Rd, Walker LA 70785.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
34. Alex Krykewycz resides at 35 South Browning Ave, Somerdale NJ 8083.Plaintiff
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS which upon information and belief was caused by use and misuse of AFFF.
Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused
by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate
result of Plaintiff has suffered from injuries including Kidney Cancer.
35. John Kupp resides at 57 N Pampas Street, Cortland IL 60112. Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
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exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
36. Les Levine resides at 8 Linden Dr., Highland Mills NY 10930.Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
37. Martin Lira resides at 4162 CALLE LIBERTAD, LAS CRUCES NM
88005.Plaintiff was exposed to PFAS through daily activity and regularly consumed water
containing elevated levels of PFAS which upon information and belief was caused by use and
misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS
contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a
direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer.
38. Donald Loftis resides at 311 S Lake St, Ponca City OK 74601.Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
39. David MacLachlan resides at 238 Pine Grove Dr., Brockton MA 02301. Plaintiff
was exposed to PFAS through daily activity and regularly consumed water containing elevated
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levels of PFAS which upon information and belief was caused by use and misuse of AFFF.
Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused
by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate
result of Plaintiff has suffered from injuries including Kidney Cancer.
40. John Mauldin resides at 156 Winston Drive, Pikeville KY 41501. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
41. Denise Maynard resides at 4141 RITA DR, MARTINEZ CA 94553. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
42. Kevin Moore resides at 1029 SE 101 Rd, Deepwater MO 64740. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
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43. Edward Moss resides at 521 Graydon Ave, Norfolk VA 23507. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
44. John Pomarico resides at 4323 Cobleskill Drive, Leland NC 28451.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Testicular Cancer.
45. Merrie Reed resides at 158 Convent Road, Nanuet NY 10954.Plaintiff was exposed
to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
46. Stephen Rumburg resides at 907 3rd Avenue, Silvis IL 61282 .Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
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including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
47. Tammy Sperling resides at 4393 67th Ave N, Pinellas Park FL 33781.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
48. Mark Stein resides at 5820 Lincoln Ave, Morton Grove IL 60053.Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
49. Patricia Stroope resides at 1128 W Washington St, Sherman TX 75092 .Plaintiff
was exposed to PFAS through daily activity and regularly consumed water containing elevated
levels of PFAS which upon information and belief was caused by use and misuse of AFFF.
Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused
by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate
result of Plaintiff has suffered from injuries including Kidney Cancer.
50. Betty Stutes resides at 315 Willa Lane, Vidor TX 77662 .Plaintiff was exposed to
PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
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exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
51. Jack Van resides at 4721 James Dr, Metairie LA 70003. Plaintiff was exposed to
PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
52. Gilbert Vea resides at 6504 Franciscan Road, Carlsbad CA 92011. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
53. Jay Warren resides at 7857 DUSTMAN RD, WORDEN IL 62097. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Kidney Cancer.
54. Michael White resides in Safetyharbor FL 34695. Plaintiff was exposed to PFAS
through daily activity and regularly consumed water containing elevated levels of PFAS which
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upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed
for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at
concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Kidney Cancer.
55. Robert Adamkoski resides at 5 Robin Cir 5D2, Johnstown NY 12095. Plaintiff was
exposed to PFAS through daily activity and regularly consumed water containing elevated levels
of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has
been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF,
including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of
Plaintiff has suffered from injuries including Testicular Cancer.
56. Gary Glenn resides at 3416 Calico Dr, Irving TX 75038. Plaintiff was exposed to
PFAS through daily activity and regularly consumed water containing elevated levels of PFAS
which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been
exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including
at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has
suffered from injuries including Testicular Cancer.
57. Dale Howell resides at 201 Old Tippecanoe Dr, Springfield IL 62711. Plaintiff was
exposed to PFAS through daily
Preview
FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY ----------------------------------------------------------------------X CRAIG ANTON; CARL ARMATO; DAVID BANKS SR; ANIELLO BARRELLA; FRANCISCO CARRILLO; Index No. _________/2023 ZENOVIA CASTRO; GREG CHEW; JAMES DANIELS; SUMMONS MARTIN DANNER; JOSEPH DOUBRLEY; RON ELDER; CASSANDRA FARINAS; TONY GAYLES; Venue is designated pursuant to CLIFFORD HANSEN; EULYS HUNT JACKSON; CPLR § 503(a) & (c) in that BRUCE JACKSON; MICHAEL JOHNSTON; JOSEPH NEW YORK in this county. KERSEY; ALEX KRYKEWYCZ; JOHN KUPP; LES LEVINE; MARTIN LIRA; DONALD LOFTIS; DAVID MACLACHLAN; JOHN MAULDIN; DENISE MAYNARD; KEVIN MOORE; EDWARD MOSS; JOHN POMARICO; MERRIE REED; STEPHEN RUMBURG; TAMMY SPERLING; MARK STEIN; PATRICIA STROOPE; BETTY STUTES; JACK VAN; GILBERT VEA; JAY WARREN; MICHAEL WHITE; ROBERT ADAMKOSKI; GARY GLENN; DALE HOWELL; WILLIAM LASWELL; JOSEPH MCHUGH; PHILIP SCALISE; NANCY CUNNINGHAM; ETTA SMITH; PATRICIA BRIGHT; SYLVIA CAPEL; DEBRA GORE; Plaintiffs, -against - 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 1 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 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; Defendants. ----------------------------------------------------------------------X To the above-named Defendant: You are hereby summoned to answer the Complaint in this action, and to serve a copy of your Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance on the Plaintiffs’ attorneys within twenty (20) days after the service of this Summons, exclusive of the day of service, where service is made by delivery upon you personally within the state, or, within thirty (30) days after completion of service where service is made in any other manner. In case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the Complaint. Dated: New York, New York March 13, 2024 Napoli Shkolnik, PLLC Attorneys for Plaintiff /s/ Nicholas Mindicino Nicholas Mindicino, Esq. 360 Lexington Avenue, 11th Floor New York, New York 10017 212-397-1000 2 2 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 NMindicino@napolilaw.com To: 3M COMPANY c/o Corporation Service Company 251 Little Falls Drive Wilmington, New Castle, DE 19808 AGC CHEMICALS AMERICAS INC. c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 AMEREX CORPORATION c/o James M. Proctor II 2900 Highway 280 Suite 300 Birmingham, AL 35223 ARCHROMA U.S. INC. c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 ARKEMA INC. 900 First Avenue King of Prussia, PA 19406 BUCKEYE FIRE EQUIPMENT COMPANY c/o A Haon Corporate Agent, Inc. 29225 Chagrin Blvd, Suite 350 Pepper Pike, OH 44122 CHEMDESIGN PRODUCTS INC. c/o Corporation Service Company 251 Little Falls Drive Wilmington, New Castle, DE, 19808 CHEMGUARD INC. c/o The Prentice-Hall Corporation System, Inc. 251 Little Falls Drive Wilmington, New Castle, DE, 19808 3 3 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 CHEMICALS, INC. c/o Ashok K. Moza 12321 Hatcherville Baytown, TX 77520 CLARIANT CORPORATION c/o Corporation Service Company 8040 Excelsior Drive, Suite 400 Madison, WI 53717 CORTEVA, INC. c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 DEEPWATER CHEMICALS, INC. c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 DUPONT DE NEMOURS INC. c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 DYNAX CORPORATION c/o Corporate Systems LLC 3500 S. Dupont Highway Dover, DE 19901 E. I. DUPONT DE NEMOURS AND COMPANY c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 NATION FORD CHEMICAL COMPANY c/o John A. Dickson, IV 4 4 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 2300 Bank Street Fort Mill, SC 29715 THE CHEMOURS COMPANY c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 THE CHEMOURS COMPANY FC, LLC c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 TYCO FIRE PRODUCTS LP c/o The Corporation Trust Company Corporation Trust Center 1209 Orange Street Wilmington, DE 19801 5 5 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY ------------------------------------------------------------------------X CRAIG ANTON; CARL ARMATO; DAVID BANKS SR; Index No. _________/2023 ANIELLO BARRELLA; FRANCISCO CARRILLO; ZENOVIA CASTRO; GREG CHEW; JAMES DANIELS; COMPLAINT AND DEMAND FOR JURY TRIAL MARTIN DANNER; JOSEPH DOUBRLEY; RON ELDER; CASSANDRA FARINAS; TONY GAYLES; CLIFFORD Trial by jury is desired in the HANSEN; EULYS HUNT JACKSON; BRUCE JACKSON; County of New York MICHAEL JOHNSTON; JOSEPH KERSEY; ALEX KRYKEWYCZ; JOHN KUPP; LES LEVINE; MARTIN Venue is designated pursuant to LIRA; DONALD LOFTIS; DAVID MACLACHLAN; CPLR § 503(a) & (c) in that the JOHN MAULDIN; DENISE MAYNARD; KEVIN causes of action occurred in this MOORE; EDWARD MOSS; JOHN POMARICO; MERRIE county. REED; STEPHEN RUMBURG; TAMMY SPERLING; MARK STEIN; PATRICIA STROOPE; BETTY STUTES; JACK VAN; GILBERT VEA; JAY WARREN; MICHAEL WHITE; ROBERT ADAMKOSKI; GARY GLENN; DALE HOWELL; WILLIAM LASWELL; JOSEPH MCHUGH; PHILIP SCALISE; NANCY CUNNINGHAM; ETTA SMITH; PATRICIA BRIGHT; SYLVIA CAPEL; DEBRA GORE; Plaintiffs, -against - 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; 6 6 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 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; Defendants. ------------------------------------------------------------------------X COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiffs CRAIG ANTON, CARL ARMATO, DAVID BANKS SR, ANIELLO BARRELLA, FRANCISCO CARRILLO, ZENOVIA CASTRO, GREG CHEW, JAMES DANIELS, MARTIN DANNER, JOSEPH DOUBRLEY, RON ELDER, CASSANDRA FARINAS, TONY GAYLES, CLIFFORD HANSEN, EULYS HUNT JACKSON, BRUCE JACKSON, MICHAEL JOHNSTON, JOSEPH KERSEY, ALEX KRYKEWYCZ, JOHN KUPP, LES LEVINE, MARTIN LIRA, DONALD LOFTIS, DAVID MACLACHLAN, JOHN MAULDIN, DENISE MAYNARD, KEVIN MOORE, EDWARD MOSS, JOHN POMARICO, MERRIE REED, STEPHEN RUMBURG, TAMMY SPERLING, MARK STEIN, PATRICIA STROOPE, BETTY STUTES, JACK VAN, GILBERT VEA, JAY WARREN, MICHAEL WHITE, ROBERT ADAMKOSKI, GARY GLENN, DALE HOWELL, WILLIAM LASWELL, JOSEPH MCHUGH, PHILIP SCALISE, NANCY CUNNINGHAM, ETTA SMITH, PATRICIA BRIGHT, SYLVIA CAPEL, AND DEBRA GORE, (“Plaintiffs”), by and through the undersigned counsel, hereby files this Complaint against Defendants, 3M COMPANY, f/k/a Minnesota Mining 7 7 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 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 substances (“PFAS”), including perfluoro octane sulfonate (“PFOS”) and perfluorooctanoic acid (“PFOA”). 2. PFOS and PFOA are fluorosurfactants 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. 8 8 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 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 fluorosurfactants 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 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 have been unknowingly exposed to the PFAS through contamination of their drinking water supply for many years at 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. 9 9 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 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 part 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. Craig Anton resides at 19042 Gearhart Dr, Macomb MI 48042.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, 10 10 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 17. Carl Armato resides at 6582 chartwell dr, ROCKFORD IL 61114.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 18. David Banks Sr resides at 17 Turner Dr, RANDOLPH MA 02368. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 19. Aniello Barrella resides at 505 Swartley Rd, Hatfield PA 19440.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 20. Francisco Carrillo resides at 12235 Henri Matisse, El Paso TX 79936.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has 11 11 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 21. Zenovia Castro resides at 20 Preston Street, Bogota NJ 07603.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 22. Greg Chew resides at 2108 E Poinsettia Ave, Tampa FL 33612.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 23. James Daniels resides at 3931 Water House Dr, DALLAS TX 75241.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 24. Martin Danner resides at 930 8th St, Rawlins WY 82301.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS 12 12 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 25. Joseph Doubrley resides at 4191 56th Ave N, St. Petersburg FL 33714.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 26. Ron Elder resides at 29021 Highway 99E, Shedd OR 97377.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 27. Cassandra Farinas resides at 8810 SW 123rd Court M302, Miami FL 33186.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 13 13 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 28. Tony Gayles resides at 3608 Tarragon Road , Louisville KY 40219.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 29. Clifford Hansen resides at 6650 E. Russell Road, Las Vegas NV 89122.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Testicular Cancer. 30. Eulys Hunt Jackson resides at 3704 Trafalgar Way, Montgomery AL 36116.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 31. Bruce Jackson resides at 25354 Ember Rd, Middleton ID 83644.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, 14 14 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 32. Michael Johnston resides at 511 Timberlake Trail, Jacksonville NC 28546.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 33. Joseph Kersey resides at 37294 Gene Hughes Rd, Walker LA 70785.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 34. Alex Krykewycz resides at 35 South Browning Ave, Somerdale NJ 8083.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 35. John Kupp resides at 57 N Pampas Street, Cortland IL 60112. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been 15 15 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 36. Les Levine resides at 8 Linden Dr., Highland Mills NY 10930.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 37. Martin Lira resides at 4162 CALLE LIBERTAD, LAS CRUCES NM 88005.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 38. Donald Loftis resides at 311 S Lake St, Ponca City OK 74601.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 39. David MacLachlan resides at 238 Pine Grove Dr., Brockton MA 02301. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated 16 16 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 40. John Mauldin resides at 156 Winston Drive, Pikeville KY 41501. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 41. Denise Maynard resides at 4141 RITA DR, MARTINEZ CA 94553. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 42. Kevin Moore resides at 1029 SE 101 Rd, Deepwater MO 64740. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 17 17 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 43. Edward Moss resides at 521 Graydon Ave, Norfolk VA 23507. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 44. John Pomarico resides at 4323 Cobleskill Drive, Leland NC 28451.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Testicular Cancer. 45. Merrie Reed resides at 158 Convent Road, Nanuet NY 10954.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 46. Stephen Rumburg resides at 907 3rd Avenue, Silvis IL 61282 .Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, 18 18 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 47. Tammy Sperling resides at 4393 67th Ave N, Pinellas Park FL 33781.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 48. Mark Stein resides at 5820 Lincoln Ave, Morton Grove IL 60053.Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 49. Patricia Stroope resides at 1128 W Washington St, Sherman TX 75092 .Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 50. Betty Stutes resides at 315 Willa Lane, Vidor TX 77662 .Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been 19 19 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 51. Jack Van resides at 4721 James Dr, Metairie LA 70003. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 52. Gilbert Vea resides at 6504 Franciscan Road, Carlsbad CA 92011. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 53. Jay Warren resides at 7857 DUSTMAN RD, WORDEN IL 62097. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 54. Michael White resides in Safetyharbor FL 34695. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which 20 20 of 64 FILED: NEW YORK COUNTY CLERK 03/13/2024 08:33 PM INDEX NO. 152338/2024 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/13/2024 upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Kidney Cancer. 55. Robert Adamkoski resides at 5 Robin Cir 5D2, Johnstown NY 12095. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Testicular Cancer. 56. Gary Glenn resides at 3416 Calico Dr, Irving TX 75038. Plaintiff was exposed to PFAS through daily activity and regularly consumed water containing elevated levels of PFAS which upon information and belief was caused by use and misuse of AFFF. Plaintiff has been exposed for many years to PFAS as a result of the PFAS contamination caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and proximate result of Plaintiff has suffered from injuries including Testicular Cancer. 57. Dale Howell resides at 201 Old Tippecanoe Dr, Springfield IL 62711. Plaintiff was exposed to PFAS through daily