Complaint,Petition: Selby Harney, James Johnson, Thomas Reynolds, Geri Scroggins, Miguel Vazquez Martinez, Bill Yameen, Thomas Cordle, Gregory Lorence, Charlie Owens, Nicholas Zanella, Stephanie Caley, Gayle Dettmar, Rebecca Dowdy, Glen Frausto, Mark Freel, April Gutknecht, Rhonda Harrelson, Cheryl Harris, Linda Huscher, Ronda Mandel, Chariti Messer, Nancy Morelli, Adrianne Patterson, Cynthia Rule, Daniel Blake, Loreal Bouchee, Jody Huffman, Vermell Salmond, Suzanne Stafford, Phyllis Graybeal, Steven Heidbrider Sr., Kenneth Licker, Kelly Price, Richard Ruiz, Patra Sweeting, Connie Wilson, Steven Clesceri, Albert Katanov, Roy Lyle, Raymond Caouette, Donald Crites, Kathryn Martinez, Dennis Parker, John Mauller, Glenn Gerry, Leonardo Mangiaracina - Martinez, Daniel Carr, John Koppa, Debbie Worley, Frank Carpenter 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 Adrianne Patterson, Albert Katanov, April Gutknecht, Bill Yameen, Chariti Messer, Charlie Owens, Cheryl Harris, Connie Wilson, Cynthia Rule, Daniel Blake, Daniel Carr, Debbie Worley, Dennis Parker, Donald Crites, Frank Carpenter, Gayle Dettmar, Geri Scroggins, Glen Frausto, Glenn Gerry, Gregory Lorence, James Johnson, Jody Huffman, John Koppa, John Mauller, Kathryn Martinez, Kelly Price, Kenneth Licker, Leonardo Mangiaracina - Martinez, Linda Huscher, Loreal Bouchee, Mark Freel, Miguel Vazquez Martinez, Nancy Morelli, Nicholas Zanella, Patra Sweeting, Phyllis Graybeal, Raymond Caouette, Rebecca Dowdy, Rhonda Harrelson, Richard Ruiz, Ronda Mandel, Roy Lyle, Selby Harney, Stephanie Caley, Steven Clesceri, Steven Heidbrider Sr., Suzanne Stafford, Thomas Cordle, Thomas Reynolds, Vermell Salmond, 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.

Preview
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SUPREME COURT OF THE STATE OF NEW YORK
NEW YORK COUNTY
----------------------------------------------------------------------X
SELBY HARNEY; JAMES JOHNSON; THOMAS
REYNOLDS; GERI SCROGGINS; MIGUEL VAZQUEZ Index No. _________/2023
MARTINEZ; BILL YAMEEN; THOMAS CORDLE;
SUMMONS
GREGORY LORENCE; CHARLIE OWENS; NICHOLAS
ZANELLA; STEPHANIE CALEY; GAYLE DETTMAR; Venue is designated pursuant to
REBECCA DOWDY; GLEN FRAUSTO; MARK FREEL; CPLR § 503(a) & (c) in that
APRIL GUTKNECHT; RHONDA HARRELSON; NEW YORK in this county.
CHERYL HARRIS; LINDA HUSCHER; RONDA
MANDEL; CHARITI MESSER; NANCY MORELLI;
ADRIANNE PATTERSON; CYNTHIA RULE; DANIEL
BLAKE; LOREAL BOUCHEE; JODY HUFFMAN;
VERMELL SALMOND; SUZANNE
STAFFORDPHYLLIS GRAYBEAL; STEVEN
HEIDBRIDER, SR.; KENNETH LICKER; KELLY
PRICE; RICHARD RUIZ; PATRA SWEETING; CONNIE
WILSON; STEVEN CLESCERI; ALBERT KATANOV;
ROY LYLE; RAYMOND CAOUETTE; DONALD
CRITES; KATHRYN MARTINEZ; DENNIS PARKER;
JOHN MAULLER; GLENN GERRY; LEONARDO
MANGIARACINA - MARTINEZ; DANIEL CARR;
JOHN KOPPA; DEBBIE WORLEY; FRANK
CARPENTER;
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.;

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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;
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

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New York, New York 10017
212-397-1000
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
3

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Wilmington, New Castle, DE, 19808

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

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c/o John A. Dickson, IV
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
------------------------------------------------------------------------X
SELBY HARNEY; JAMES JOHNSON; THOMAS Index No. _________/2023
REYNOLDS; GERI SCROGGINS; MIGUEL VAZQUEZ
MARTINEZ; BILL YAMEEN; THOMAS CORDLE; COMPLAINT AND DEMAND
FOR JURY TRIAL
GREGORY LORENCE; CHARLIE OWENS; NICHOLAS
ZANELLA; STEPHANIE CALEY; GAYLE DETTMAR; Trial by jury is desired in the
REBECCA DOWDY; GLEN FRAUSTO; MARK FREEL; County of New York
APRIL GUTKNECHT; RHONDA HARRELSON;
CHERYL HARRIS; LINDA HUSCHER; RONDA Venue is designated pursuant to
MANDEL; CHARITI MESSER; NANCY MORELLI; CPLR § 503(a) & (c) in that the
ADRIANNE PATTERSON; CYNTHIA RULE; DANIEL causes of action occurred in this
BLAKE; LOREAL BOUCHEE; JODY HUFFMAN; county.
VERMELL SALMOND; SUZANNE STAFFORDPHYLLIS
GRAYBEAL; STEVEN HEIDBRIDER, SR.; KENNETH
LICKER; KELLY PRICE; RICHARD RUIZ; PATRA
SWEETING; CONNIE WILSON; STEVEN CLESCERI;
ALBERT KATANOV; ROY LYLE; RAYMOND
CAOUETTE; DONALD CRITES; KATHRYN
MARTINEZ; DENNIS PARKER; JOHN MAULLER;
GLENN GERRY; LEONARDO MANGIARACINA -
MARTINEZ; DANIEL CARR; JOHN KOPPA; DEBBIE
WORLEY; FRANK CARPENTER;

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.;

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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;

Defendants.

------------------------------------------------------------------------X

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiffs SELBY HARNEY, JAMES JOHNSON, THOMAS REYNOLDS, GERI

SCROGGINS, MIGUEL VAZQUEZ MARTINEZ, BILL YAMEEN, THOMAS CORDLE,

GREGORY LORENCE, CHARLIE OWENS, NICHOLAS ZANELLA, STEPHANIE CALEY,

GAYLE DETTMAR, REBECCA DOWDY, GLEN FRAUSTO, MARK FREEL, APRIL

GUTKNECHT, RHONDA HARRELSON, CHERYL HARRISLINDA HUSCHER, RONDA

MANDEL, CHARITI MESSER, NANCY MORELLI, ADRIANNE PATTERSON, CYNTHIA

RULE, DANIEL BLAKE, LOREAL BOUCHEE, JODY HUFFMAN, VERMELL SALMOND,

SUZANNE STAFFORD, PHYLLIS GRAYBEAL, STEVEN HEIDBRIDER, SR., KENNETH

LICKER, KELLY PRICE, RICHARD RUIZ, PATRA SWEETING, CONNIE WILSON,

STEVEN CLESCERI, ALBERT KATANOV, ROY LYLE, RAYMOND CAOUETTE,

DONALD CRITES, KATHRYN MARTINEZ, DENNIS PARKER, JOHN MAULLER, GLENN

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GERRY, LEONARDO MANGIARACINA - MARTINEZ, DANIEL CARR, JOHN KOPPA,

DEBBIE WORLEY, AND FRANK CARPENTER, (“Plaintiffs”), by and through the undersigned

counsel, hereby files this Complaint against Defendants, 3M COMPANY, f/k/a Minnesota Mining

and Manufacturing Co., AGC CHEMICALS AMERICAS INC., AMEREX CORPORATION,

ARKEMA INC., ARCHROMA U.S INC., BUCKEYE FIRE EQUIPMENT COMPANY,

CHEMDESIGN PRODUCTS INC., CHEMGUARD INC., CHEMICALS, INC., CLARIANT

CORPORATION, CORTEVA, INC., DEEPWATER CHEMICALS, INC., DUPONT DE

NEMOURS INC., DYNAX CORPORATION, E. I. DUPONT DE NEMOURS AND COMPANY,

NATION FORD CHEMICAL COMPANY, THE CHEMOURS COMPANY, THE CHEMOURS

COMPANY FC, LLC, and TYCO FIRE PRODUCTS, LP, and DOE DEFENDANTS 1-20,

fictitious names whose present identifies are unknown (collectively “Defendants”) and alleges,

upon information and belief, as follows:

INTRODUCTION

1. This action arises from the foreseeable contamination of groundwater by the use of

aqueous film-forming foam (“AFFF”) products that contained per- and poly-fluoroalkyl

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
8

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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

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.

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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.

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.

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PARTIES

A. Plaintiffs

16. Selby Harney resides at 75 Main Street, Morven NC 28119. 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. James Johnson resides at 287 Briarfield Rd, Warrior AL 35180. 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. Thomas Reynolds resides at 312 Gibson Rd, Lexington SC 29072. 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. Geri Scroggins resides at 435 Woodmont Dr, Brewton AL 36426. 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.

20. Miguel Vazquez Martinez resides at 346 Prestige Ct., Reno NV 89506. 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.

21. Bill Yameen resides at 15 Farmington ave, Haverhill MA 1832. 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. Thomas Cordle resides in Westlake LA 70669. 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.

23. Gregory Lorence resides at 1200 W Mariposa Road, Nogales AZ 85621. 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.

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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.

24. Charlie Owens resides at 100 Magnolia Drive, Blounts Creek NC 27814. 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.

25. Nicholas Zanella resides at 3976 Loch Meade Dr, Lakeland TN 38002. 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. Stephanie Caley resides at 26792 Carmenita Ln, Mission Viejo CA 92691. 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 Thyroid Disease.

27. Gayle Dettmar resides at 1017 NE 124th Ave, Vancouver WA 98684. Plaintiff was

exposed to PFAS through daily activity and regularly consumed water containing elevated levels

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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 Thyroid Disease.

28. Rebecca Dowdy resides at 144 Avendale Ave NE, Roanoke VA 24012. 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 Thyroid Disease.

29. Glen Frausto resides at 3621 Birmingham Ln, North Port FL 34288. 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 Thyroid Disease.

30. Mark Freel resides at 10970 E Pear Tree Dr, Cornville AZ 86325. 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 Thyroid Disease.

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31. April Gutknecht resides at 6740 Davidson St #325, The Colony TX 75056. 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 Thyroid Disease.

32. Rhonda Harrelson resides at 10146 Highway 905 South, Longs SC 29568. 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 Thyroid Disease.

33. Cheryl Harris resides at 8305 Windsor Forest Dr, Fort Worth TX 76120. 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 Thyroid Disease.

34. Linda Huscher resides at 1510 Tahlequah Dr, Colorado Springs CO 80915 .

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

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caused by AFFF, including at concentrations hazardous to Plaintiff's health. As a direct and

proximate result of Plaintiff has suffered from injuries including Thyroid Disease.

35. Ronda Mandel resides at 15 Prince St Apt C, Killingly CT 06239. 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 Thyroid Disease.

36. Chariti Messer resides in Armona CA 93202. 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 Thyroid Disease.

37. Nancy Morelli resides at 6 Starr St, Port Jefferson Station NY 11776. 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 Thyroid Disease.

38. Adrianne Patterson resides at 1602 Bryan St Apt 3, Normal IL 61761. 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 Thyroid Disease.

39. Cynthia Rule resides at 2843 Dulaney Rd, Tunica MS 38676. 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 Thyroid Disease.

40. Daniel Blake resides at 11323 Wesley Rd, Abbeville LA 70510. 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 Ulcerative Colitis.

41. Loreal Bouchee resides at 239 Grand Ave, Billings MT 59101. 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 Thyroid Disease.

42. Jody Huffman resides at 325 Woodrow Hoyle Rd, Casar NC 28020. Plaintiff was

exposed to PFAS through daily activity and regularly consumed water containing elevated levels

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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 Ulcerative Colitis.

43. Vermell Salmond resides at 515 Long Creek Pkwy, Charlotte NC 28214. 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 Ulcerative Colitis.

44. Suzanne Stafford resides at 1100 Sunnybrook Rd, Washington PA 15301. 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 Thyroid Disease.

45. Phyllis Graybeal resides at 10657 OAK GROVE RD, BRISTOL VA 24202.

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 Thyroid Disease and Thyroid

Cancer.

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46. Steven Heidbrider, Sr. resides at 352 Broad St, Struthers OH 44471. 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 Thyroid Disease.

47. Kenneth Licker resides at 3178 Blue Oak Dr, Frisco TX 75033. 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. Kelly Price resides at 3958 E Baywood Ave, Mesa AZ 85206. 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 Thyroid Disease.

49. Richard Ruiz resides at 535 Greenbay Ave, Calumet City IL 60409. 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 Thyroid Disease.

50. Patra Sweeting resides at 2275 W Bunche Park Dr, Opa-locka FL 33054. 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 Thyroid Disease.

51. Connie Wilson resides in Summerfield FL 34492. 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 Thyroid Disease.

52. Steven Clesceri resides at 1400 Fallen Leaf St., La Habra CA 90631. 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. Albert Katanov resides at 68 W Oak St, Farmingdale NY 11735. 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.

54. Roy Lyle resides at 4736 Dorsey St., Forest Hill TX 76119. 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.

55. Raymond Caouette resides at #4 Lyons St, NEW BRITAIN CT 06052. 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. Donald Crites resides at 8933 Split Stone Ct, Byron Center MI 49315. 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. Pl

Case Info

Case No.

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Document Filed Date

March 13, 2024

Case Filing Date

March 13, 2024

County

Parties

Adrianne Patterson Plaintiff
AGC CHEMICALS AMERICAS INC. Defendant
Albert Katanov Plaintiff
AMEREX CORPORATION Defendant
April Gutknecht Plaintiff
ARCHROMA U.S. INC. Defendant
ARKEMA INC. Defendant
Bill Yameen Plaintiff
BUCKEYE FIRE EQUIPMENT COMPANY Defendant
Chariti Messer Plaintiff
Charlie Owens Plaintiff
CHEMDESIGN PRODUCTS INC. Defendant
CHEMGUARD INC. Defendant
CHEMICALS, INC. Defendant
Cheryl Harris Plaintiff
CLARIANT CORPORATION individually and as successor in interest to Sandoz Chemical Corporation Defendant
Connie Wilson Plaintiff
CORTEVA, INC. individually and as successor in interest to DuPont Chemical Solutions Enterprise Defendant
Cynthia Rule Plaintiff
Daniel Blake Plaintiff
Daniel Carr Plaintiff
Debbie Worley Plaintiff
DEEPWATER CHEMICALS, INC. Defendant
Dennis Parker Plaintiff
DOE DEFENDANTS 1-20 fictitious names whose present identities are unknown Defendant
Donald Crites 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
Frank Carpenter Plaintiff
Gayle Dettmar Plaintiff
Geri Scroggins Plaintiff
Glen Frausto Plaintiff
Glenn Gerry Plaintiff
Gregory Lorence Plaintiff
James Johnson Plaintiff
Jody Huffman Plaintiff
John Koppa Plaintiff
John Mauller Plaintiff
Kathryn Martinez Plaintiff
Kelly Price Plaintiff
Kenneth Licker Plaintiff
Leonardo Mangiaracina - martinez Plaintiff
Linda Huscher Plaintiff
Loreal Bouchee Plaintiff
Mark Freel Plaintiff
Miguel Vazquez martinez Plaintiff
MINDICINO, NICHOLAS HENRY Attorney for the Plaintiff
Nancy Morelli Plaintiff
NATION FORD CHEMICAL COMPANY Defendant
Nicholas Zanella Plaintiff
Patra Sweeting Plaintiff
Phyllis Graybeal Plaintiff
Raymond Caouette Plaintiff
Rebecca Dowdy Plaintiff
Rhonda Harrelson Plaintiff
Richard Ruiz Plaintiff
Ronda Mandel Plaintiff
Roy Lyle Plaintiff
Selby Harney Plaintiff
Stephanie Caley Plaintiff
Steven Clesceri Plaintiff
Steven Heidbrider SR. Plaintiff
Suzanne Stafford 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 Cordle Plaintiff
Thomas Reynolds Plaintiff
TYCO FIRE PRODUCTS, LP individually and as successor in interest to The Ansul Company Defendant
Vermell Salmond Plaintiff

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