Case 3:20-Cv-05691 Document 1 Filed 07/16/20 Page 1 of 69
Case 3:20-cv-05691 Document 1 Filed 07/16/20 Page 1 of 69 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA LAKEWOOD WATER DISTRICT, Civil Action No.: _______________ Plaintiff, COMPLAINT AND JURY DEMAND v. THE UNITED STATES OF AMERICA; THE DEPARTMENT OF THE AIR FORCE; THE DEPARTMENT OF THE ARMY; THE DEPARTMENT OF DEFENSE; 3M COMPANY (f/k/a Minnesota Mining Manufacturing, Co.); TYCO FIRE PRODUCTS LP (successor-in-interest to the Ansul Company); ANGUS INTERNATIONAL SAFETY GROUP, LTD.; BUCKEYE FIRE EQUIPMENT COMPANY; CHEMGUARD, INC.; THE CHEMOURS COMPANY; CHUBB FIRE, LTD.; E.I. DU PONT DE NEMOURS AND COMPANY; KIDDE-FENWAL, INC.; KIDDE PLC, INC.; NATIONAL FOAM, INC. (successor-in- interest to Angus Fire Armour Corp.); RAYTHEON TECHNOLOGIES CORPORATION (f/k/a United Technologies Corporation); and UTC FIRE & SECURITY AMERICAS CORPORATION, INC., Defendants. Case 3:20-cv-05691 Document 1 Filed 07/16/20 Page 2 of 69 Lakewood Water District (“District”), by and through its attorneys, hereby alleges as follows: SUMMARY OF CLAIM 1. The District brings this action for injunctive relief, damages and reimbursement of costs incurred, and which continue to be incurred, to address the presence of per- and polyfluoroalkyl substances (“PFAS”)—including, but not limited to, perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonate (“PFOS”)—in the District’s groundwater supply wells. 2. PFAS, including PFOA and PFOS, are a group of toxic, extremely persistent, and bioaccumulative synthetic chemicals. When consumed, PFAS can cause serious health impacts. 3. The United States, the Department of the Air Force (“Air Force”), the Department of the Army (“Army”), and the Department of Defense (“DOD”) (together, “Federal Defendants,” or “United States”); as well as 3M Company, Angus International Safety Group, Ltd., Buckeye Fire Equipment Company, Chemguard, Inc., The Chemours Company, Chubb Fire, Ltd., E.I.
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