IN THE CIRCUIT COURT OF SULLIVAN COUNTY, TENNESSEE,
‘SECOND JUDICIAL DISTRICT
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: FILED
EASTMAN CHEMICAL CO. Alvfoal
Defendant events veh cou ie
SULWAN COUNTY. TN,
(CLASS ACTION COMPLAINT
Plaintiff Sharon Weatherly brings this action against Eastman Chemical Co. (“Eastman”),
‘both on behalf of herself and on behalf ofall others similarly situated, for diminution in propecty
value,
1. OnJanvary 31,2022, a pipe operated by Eastman burst, eausing debris and various
contaminants, including asbestos and other toxins, to be released into the surrounding area,
including residential community.
2. The incident caused these substances to be sprayed into the air over a large area and
spreading into the surrounding community. Residents inthe surrounding community noted thet
the debris could be seen raining dowm from the sky, coming to rest on and covering houses,
vehicles, properties, and, in some eases, people.
3. The contaminants released are dangerous and pose significant risks to human
health.
4, By virtue of ter close proximity o the Eastman plant where this incident occurred,
Plaintiff's property values heve diminished, in part due to the ongoing tsk to health caused by thecontaminants that covered ier entire neighborhood, and duc to the ongoing risk that similar
incidents will occur in the fire.
PARTIES
5. Plaintiff Shanon Weatherly is a citizen and resident of Tennesse, At all times
sclevant,Plisff Weathely resided a 816 Oakdale Road, Kingsport, Tennessee 37664, in close
proximity tothe Eastman plant located nearby.
6. Defendant Bastman Chemical Co. is a Delaware corporation with its corporate
headquarters in Tennesse. Specifically, Defendants headquarters are located at 200 South Wiloox
Drive, Kingsport, Tennesse 37660. Thus, for purposes of jurisdiction, Defendant is a citizen of
the State of Delaware and the State of Tennessee
JURISDICTION AND VENUE
7. This Cour bus subject matter juistiction pursuant to Tenn, Code Ann, §§ 20-2-
222 and 20.2-228,
8 Defendant astman Chemical Co. is subject to jurisition inthe State of Tennessee
because it maintains is principal place of business in Kingsport, Tennessee, Further, Eastman
engages in substantial business activity within the State of Tennessee, which activity caused the
claimed injuries inthis case.
‘Venue is proger inthis Court pursuant to Tenn. Cade Ann, § 20-4-101(a) and (b),
10. Venue is proper in Sullivan County because both Plaintiff and Eastman reside in
Sullivan County, Further, the facts and injuries giving rise to the claims all occurred in Sullivan
CountyGENERAL FACTS
11, Eastman is aplobal specialty materials company tht produces a broad ange of
products."' Sine its founding, Eastman bes produced chemicals for use in other product,
applications. Eastman maintns eumerous manufacturing pants worldwide
12, Eastman maintains one such manufacturing plant in Kingsport, Tennessee This
‘manufacturing ste produces a “broad range of chemicals, fibers and pasties” which are wsed in
“products such as paint, adhesives, textiles, sports hotles, pharmaceuticals, meal devices and
smut more”?
13, On the morning of January 31, 2022, at approximstely 7:30 am. stam line (oF
Pipe) at Eastman’s Kingspot manufacturing plant burst. Upon information and bei, this pipe
carted stam 1o and throughout the plant, siding in the production of Eestman’s various chemical
prodvets. The incident occured a the northeast side ofthe plant
14, Reports later ndicated that five peopl suffered injures as a result ofthe steam line
future
15, When the steam line burs, it caused a loud noise; released a massive plume of
debris into the air; and the blast reportedly shook homes nearest to the plant. Some residents
reported feting tremors fom the incident, lasting for approximately five minutes, Immediately
afer the pipe burst, it released steam and pariculate debris contsining various contaminants,
including asbestos and other toxins, into the ait—and into the surrounding communities.
" bntps:/wwo-eastman.comCompany/About Eastman/Pages/Profile aspx (last visited Feb. 10,
2022).
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spi~:text~Eastman 20 ingsport%2C%20T ennessee%20manufacturing®20site medical 942
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316. Notably, upon information and belief, Eastman failed to sound any alarm warning
the surrounding community of the incident and failed to ask the City of Kingsport to issue
emergency messages to the community
17. When the steam line burst on the morning of January 31, 2022, it immediately
released a massive plume of steam, debris, and various contaminants, including asbestos and other
toxins, into the air. This plume extended high into the sky and continued to release debris and
‘contaminants into the air—znd into the surrounding communities—for some time. Photographs
ilustrate the sizeof these plumes of debris:
changes/artcle_aB81b812-885del1ee-95b5-0756 (last visited Feb, 10,2022).
418 Inpartcuar, some residents reported that debris could be sen falling fom te sky,
similar to rif, coming toes on thet homes, vehicles, and properties.
19, Residents in the surounding communities were understandably wortied and
concemed for their and ther fais safety.
20, Almost immediately after the incident, residents called emergency services,