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Class Action Complaint

Class Action Complaint

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Published by Jose D. Duran

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Published by: Jose D. Duran on Aug 20, 2013
Copyright:Attribution Non-commercial

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07/04/2014

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IN
THE
CIRCUIT
COURT
OF
THE
FIFTEENTH
JUDICIAL
CIRCUIT
OF
FLORIDA,
IN
AND
FOR
PALM
BEACH
COUNTY.
CASE
O.:
RICHARD
COTROMANO,
BETHANY
COTROMANO, FRANK
DECARLO
PAULETTEDECARLO,
GREGORY
DUNSFORD,
JENNIFER
DUNSFORD,
JOYCEFEATHERSTON,
BILL
FEATHERSTON,
ROBERT
T.
NEWFIELD
and
TRACY
NEWFIELD,
ll
on
behalf
of
themselves
and
ll
otherssimilarly
situated
Plaintiffs
vs.
UNITED
TECHNOLOGIES
CORPORATION,
ratt
&
hitney
Group,
A
Connecticut
orporation,
and
PALM
BEACH
AGGREGATES,
LC,
lorida
Corporation.
Defendants.
/
CLASS ACTION
COMPLAINT
Plaintiffs,
RICHARD
COTROMANO,
BETHANY
COTROMANO,
FRANK
DeCARLO,PAULETTE
DeCARLO,
GREGORY
DUNSFORD,
JENNIFER
DUNSFORD,
JOYCE
FEATHERSTON,
ROBERT
.
NEWFIELD
nd
TRACY
NEWFIELD,
ll
on
behalf
of
themselves
and
all
others
similarly
situated,
sue
Defendants
UnitedTechnologies
Corporation,
Pratt
&
hitney
Group, nd
Palm
Beach
Aggregates,
nc.,
a
lorida
Corporation,
for
damages
s
prayed
or
specifically
below.
I.
This
s
an
ctionfor
damages
hat
exceed
Fifteen
Thousand
Dollars
($15,000.00).
 
JURISDICTION
nd
VENUE
2.
RICHARD
COTROMANO
and
BETHANY
COTROMANO
eside
in
Palm
Beach
County,
lorida.
Together
as
husband
and
wife,
they
owned
a
residence
on
76
h
 
Road
North
inthe
Acreage,
an
unincorporated
residential
community
in
Palm
Beach
County.
They
sold
it
through
a
short
sale
after
the
Florida
Department
of
Health
officially
declared
their
daughter to
be
a
member
of
ediatric
brain
tumor
luster
in
2010.
3.
FRANK
DeCARLO
nd
PAULETTE
DeCARLO
eside
in
Palm Beach
County,
Florida.
Together
s
husbandand
wife,
they
own
esidence
on
80
th
 
Lane
North
n
the
Acreage,
an
unincorporated
residential
community
in
Palm
Beach
County.
The
Florida
Department
of
Health
officially
declared
their
daughter
to
be
a
member
of a
pediatric
brain
tumor
cluster
in
2010.
4.
JOYCE
and
BILL
FEATHERSTON
reside
in
Palm
Beach
County,
Florida.
Together
as
husband
and
wife,
they
own
a
residence
on
80
th
 
Lane
North
in
the
Acreage,
an
unincorporated
residential
community
n
Palm
Beach
County.
The
lorida
Department
of
ealth
officially
declared
Joseph
Michael
Baratta,
Joyce's
deceased
son,
o
be
a
member
of a
pediatric
brain
tumor
luster
in
2010.
The
roperty
is
currently
subject
to
a
oreclosure
action.
5.
GREGORY
DUNSFORD
and
JENNIFER
DUNSFORD
eside
in
Tennessee.Together
as
husband
and
wife,
they
owned
a
esidence
on
85
th
 
Street
North
in
the
Acreage,
an
unincorporated
residential
community
n
Palm
Beach
County.
They
old
it
through
a
short
sale
after
the
Florida
Department
of
ealth
officially
declared
their
son
o
be
a
member
of
ediatricbrain
tumor
luster
in
2010.
6.
ROBERT
T.
NEWFIELD
and
TRACY
NEWFIELD
reside
in
Palm
Beach
County,
lorida.
Together
s
husband and
wife,
they
own
esidence
at
7309
Banyan
Boulevard
2
 
in
the
Acreage,
an
unincorporated
residential
community
in
Palm
Beach
County.
The
Florida
Department
of
ealth
officially
declared
their
daughter
to
be
member
of a
ediatric
brain
tumor
cluster
in
2010.
7.
PRATT
&
WHITNEY
is
a
division
of
UNITED
TECHNOLOGIES
CORPORATION,
Connecticut
corporation
that
possesses,
maintains,
and
runs
an
engineering
facility
in
northwest
Palm
Beach
County
adjacentto the
Corbett
Wildlife
area.
(Hereinafter
"Pratt
Whitney")
8.
PALM
BEACH
AGGREGATES,LC
s
a
lorida
Corporation
operating
mining
and
associated
interests
and
owning
land in
Palm
Beach
County.
(Hereinafter
"Aggregates").Aggregates
owned,
and
then
for
some
time
eased,
theland
that
is
currently
used
as
an
aquifer
impoundment by
he
South
lorida
Water
Management
istrict
- the
L8
eservoir.
THE
CLASS REPRESENTATIVES
9.
As
tated
in paragraphs
2-6
above,each
of
he
named
laintiffs is
or
has
been
an
Acreage
property
owner
s
a
parent
of
ictim
of
he
cancer
cluster.
Complaints
ddressingthe
injuries
to those
children
have
been
separately
filed.
The
remedies sought
hereinarelimitedto
compensation
for
thediminutioninvalue
of
roperty
caused
as
a
consequence
of
the
stigma
arising
from
the
cancer
cluster
designation
and
do
not
include
claims
for
physical
injuries
suffered
by
any
member
of
he
putative
class.
10.
The
named
laintiffs
seeking
to
represent
the
putativeclass
have
lready
sustained
a
eparate
significant
injury that
is
common
o
everyproposed
class
member. The
lass
sought
to
be
epresented
is
comprised
of
very
current
or
former
Acreage
area
landowner
who
wns
r
owned
an
Acreage
roperty
at
any
time
ince
August
4, 009.
3

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