Good et al v. American Water Works Company, Inc. et al

Filing 1

CLASS ACTION COMPLAINT. Filing Fee $400.00. Receipt # 0425-2895740. (Attachment: # 1 Civil Cover Sheet)

CIVIL COVER SHEET
(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

Vantap, LLC; Hamra, Georgia; Sarver, John; Nitro Car Care Center,
LLC; Burdette, Carolyn; Colours Salon and Boutique, LLC; Goode
Crystal; Mannypenny, Michael

Freedom Industries, LLC; Eastman Chemical Company; West
Virginia American Water Corporation; Southern, Gary

Kanawha County

(b)

Kanawha

(EXCEPT IN U.S. PLAINTIFF CASES)

(c)

(IN U.S. PLAINTIFF CASES ONLY)

(If Known)

(Firm Name, Address, and Telephone Number)

(see attachment)

II. BASIS OF JURISDICTION (Place an “X” in One Box Only)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only)
PTF

and One Box for Defendant)
PTF
DEF

DEF

(U.S. Government Not a Party)

or

and
(Indicate Citizenship of Parties in Item III)

IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT

TORTS
PERSONAL INJURY

FORFEITURE/PENALTY

BANKRUPTCY

OTHER STATUTES

PERSONAL INJURY

PROPERTY RIGHTS

LABOR

SOCIAL SECURITY

PERSONAL PROPERTY

REAL PROPERTY

CIVIL RIGHTS

PRISONER PETITIONS
Habeas Corpus:

FEDERAL TAX SUITS

IMMIGRATION
Other:

V. ORIGIN (Place an “X” in One Box Only)
(specify)
(Do not cite jurisdictional statutes unless diversity)

VI. CAUSE OF ACTION

Clean Water Act 33USC1251; Rivers and Harbors Act of 1899 33USC401; Clean Air Act, 42USC7401
Admitted toxic release into public water supply in violation of law constituting prima facie negligence.

VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
01/13/2014
FOR OFFICE USE ONLY

CLASS ACTION

DEMAND $

100,000,000.00
(See instructions):

/s/ Kevin W. Thompson

JURY DEMAND: