Green Petition

E-FILED 2017 JUL 12 12:03 PM JASPER - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT FOR JASPER COUNTY
ZARPKA GREEN, )
)
Plaintiffs, )
)
) No. LACV120370
)
vs. )
) AMENDED PETITION AT LAW
RYAN HOENICKE, DANIELLE WILLIAMS, ) and JURY DEMAND
CLEO BOYD, ALLEN FINCHUM, )
TERRY VAN HUYSEN, JIM BAILEY )
TPI IOWA, LLC, TPI COMPOSITES, INC. )
And INSURANCE COMPANY STATE OF )
PENNSYLVANIA )
)
Defendants. )
COMES NOW, Plaintiff Zarpka Green, by and through the undersigned counsel, and
hereby files her Petition at Law against Defendants TPI Composites, Inc., TPI Iowa, LLC, Ryan
Hoenicke, Danielle Williams, Cleo Boyd, Allen Finchum, Terry Van Huysen, Jim Bailey and
Insurance Company State of Pennsylvania (Defendants). Plaintiff alleges upon personal
knowledge as to himself and her own acts, and upon information and belief based upon the
investigation of counsel as to all other matters, as follows:
PARTIES
1. At all times material hereto, Plaintiff Zarpka Green (Green) was a resident of
Polk County, Iowa, and employed by Defendant TPI Iowa, LLC a Delaware limited liability
company.
2. At all times material hereto, and upon information and belief, Defendant TPI
Composites, Inc. (TPI Composites) was a corporation registered with the Secretary of State of
Arizona, and the parent company of TPI Iowa, LLC.

3. Upon information and belief, at all times material hereto, Defendant Ryan
Hoenicke was employed by TPI Iowa as an Environmental Health and Safety Manager, and a
resident of Polk County, Iowa.
4. Upon information and belief, at all times material hereto, Defendant Danielle
Williams was employed by TPI Iowa as a Human Resources Manager.
5. Upon information and belief, at all times material hereto, Defendant Cleo Boyd
was employed by TPI Iowa as a Human Resources Manager.
6. Upon information and belief, at all times material hereto, Defendant Terry Van
Huysen was employed by TPI Iowa as the general manager, and a resident of Polk County, Iowa.
7. Upon information and belief, at all times material hereto, Defendant Allen
Finchum was employed by TPI Iowa as the operations manager.
8. Upon information and belief, at times material hereto, Defendant Jim Bailey was
employed by TPI Iowa as an Environmental Health and Safety Manager.
JURISDICTION AND VENUE

9. Plaintiff incorporates by reference paragraphs 1 through 8 of her Petition as if
fully set forth herein.
10. These are gross negligence, civil rights, public policy, fraud, breach of contract,
breach of duty of good faith and fair dealing, negligence, joint venture and punitive damage
claims, and her court has jurisdiction over the subject matter and the parties to her cause of
action.
11. Venue is proper in Jasper County pursuant to Iowa Code Section 616.18.
12. Damages exceed the threshold for small claims court.
FACTUAL BACKGROUND
13. Green incorporates by reference paragraphs 1 through 12 of her Petition as if fully
set forth herein.
14. TPI Composites is a wind blade manufacturing business having one of its
business addresses at 2300 N. 33rd Ave., Newton, IA.
15. TPI Iowa is a wind blade manufacturing business located at 2300 N. 33rd Ave.,
Newton, Iowa.
16. TPI Composites holds itself out as the largest U.S. based independent
manufacturer of wind blades in the wind energy market.
17. In 2015, TPI Composites reported revenue of $586,000,000.00.
18. TPI Iowa employs hundreds of employees at the Newton, Iowa manufacturing
plant.
19. At all material times hereto, Green was a prospective, current or former employee
of TPI Iowa.
20. As a part of the wind blade manufacturing process, TPI Iowas employees work
with hazardous chemicals while manufacturing the wind blades.
21. During her employment at TPI Iowa, Green worked with hazardous chemicals
while manufacturing the wind blades.
22. TPI Iowas employees work with Dry Layup Adhesives while manufacturing the
wind blades.
23. TPI Iowas employees work with a hazardous Curing Agent while manufacturing
the wind blades.
24. TPI Iowas employees work with a hazardous Resin while manufacturing the
wind blades.
25. In addition to the Adhesives, Curing Agent and Resin, TPI Employees work with
oher toxic chemicals (Adhesives, Resin, Curing Agent & oher chemicals collectively referred to
as Chemicals).
26. The Dry Layup Adhesives are flammable liquefied gases and/or vapors.
27. The Dry Layup Adhesives are known to cause adverse target organ effects, birth
defects, oher reproductive harm, eye irritation, skin irritation, respiratory tract irritation, cardiac
sensitization, simple asphyxiation, gastrointestinal irritation, central nervous system depression,
liver effects, kidney effects and bladder effects or peripheral neuropathy.
28. The Resin is known to cause skin corrosion or irritation, serious eye damage, skin
sensitization, cancer, damage to fertility, damage to the unborn child, respiratory irritation, and
damage to the reproduction system.
29. The Curing Agent is can be toxic following a single oral or dermal exposure.
30. The Curing Agent is classified can cause skin corrosion or irritation, serious eye
damage or eye irritation, respiratory sensitization, skin sensitization, reproductive system
damage, damage to fertility, and allergy or asthma symptoms or breathing difficulties if inhaled.
31. Personal Protective equipment (PPE) is required to be worn to avoid the
adverse health effects of the Adhesives, Resin and Curing Agent.
32. Since August 13, 2008, TPI Iowa, LLC has documented approximately three
hundred fifty (350) injuries on its Iowa OSHA logs caused by Chemical exposure to its
employees at the Newton, IA manufacturing plant.
33. Green was employed by Defendants in or around May 2015.
34. As of May 1, 2016, hundreds of Chemical injuries had been documented by TPI
Iowa in their Iowa OSHA logs.

35. Greens work duties at TPI included, but were not limited to the molding
department, where Green would enter wind blades and apply chemicals to the wind blades.
36. Green worked directly with the Chemicals on a daily basis.
37. Green was not provided with sufficient PPE to protect her from the known
hazards of the Chemicals he worked with at TPI Iowa.
38. The PPE provided to the Green did not prevent exposure, inhalation, or ingestion,
of the Chemicals.
39. Defendants knew that Green was not provided with sufficient protective
equipment to avoid a Chemical injury.
40. While employed at TPI Iowa, Green reported to Defendants that her skin was
breaking out with bumps and rashes.
41. At the time Green initially reported her symptoms, Green was not sent to a doctor.
42. Instead, Defendants instructed Green to participate in a three-step program that
was administered by non-medical professionals, and consisted of applying lotions and bandages
to her open rashes and wounds.
43. At the time Green reported her symptoms, employees at TPI Iowa also instructed
Green to continue working.
44. On or about January 4, 2016, Green suffered a horrific breakout of rashes and
burns all over her body.
45. Greens eyes swelled shut.
46. Greens suffered opened wounds on her eyelids.
47. The January 2016 reaction was months after she experienced and reported initial
symptoms to Defendants.
48. In January 2016, Defendants sent Green to a physician named Dr. Miller.
49. Dr. Miller concluded that Green had a permanent allergy to epoxy resin and told
Nyonne that she was to avoid epoxy resin.
50. Green did not have an allergy to epoxy resin prior to being exposed to the
Chemicals while working at TPI Iowa.
51. Green requested an accommodation from TPI Iowa to comply with Dr. Millers
restrictions.
52. Upon receipt of Greens request for an accommodation, TPI Iowa did not engage
Green in an interactive process with Green to attempt to accommodate her disability.
53. TPI Iowa denied Green request and terminated her.
54. To date, Green continues to suffer adverse symptoms from the Chemicals.
55. Green itches all over her body as a result of the Chemical exposure.
COUNT I: GROSS NEGLIGENCE

(Green vs. Hoenicke, Williams, Boyd, Finchum, Van Huysen, Bailey)
56. Green incorporates by reference paragraphs 1 through 55 of the Petition as if fully
set forth herein.
57. Defendants each owed a duty of care to Green while Green was working in the
scope of her employment at TPI Iowa.
58. Defendants each violated their duty of care to the Green.
59. Defendants each had knowledge and understood that the Chemicals used by
Green in the scope of her employment at TPI Iowa caused injury.
60. Defendants each knew that it was probable, and not merely possible, that Green
would suffer injuries as a result of her exposure to the dangerous Chemicals.

61. Defendants each consciously failed to avoid the danger of Green suffering injuries
from the Chemicals.
62. Green suffered damages as a result of her injuries caused by the Chemicals.
COUNT II: VIOLATION OF THE IOWA CIVIL RIGHTS ACT (IOWA CODE
CHAPTER 216) DIABILITY DISCRIMINATION
(Green vs. TPI Iowa)
63. Green incorporates by reference paragraphs 1 through 62 of the Petition as if fully
set forth herein.
64. Within three hundred (300) days of the acts which she complains, Green filed
charges of discrimination with the Iowa Civil Rights Commission against the above-named
Defendant TPI Iowa, LLC.
65. On February 8, 2017, less than ninety (90) days prior to the filing her Petition, the
Iowa Civil Rights Commission issued to Green, pursuant to Iowa Code Chapter 216.16, a Notice
of Right to Sue with respect to such charges.
66. Greens physical conditions covered by the Iowa Civil Rights Act which qualify
as disabilities include permanent injuries as a result of her exposure to Chemicals while working
in the scope of her employment at TPI Iowa.
67. Greens permanent injuries due to Chemical exposure substantially limit one or
more of Greens life functions.
68. Greens physical conditions require reasonable accommodation.
69. Greens physical impairments at the time of her employment with TPI Iowa
qualified him under the Iowa Civil Rights Act as he was substantially limited in one or more
major life activities, were regarded as having a physical and/or mental impairment that
substantially limited one or more major life activities, or had a record of a physical or mental
impairment that substantially limited one or more major life activities.
70. TPI Iowa violated the Iowa Civil Rights Act by failing to accommodate Green
conditions and by terminating him because of her conditions covered by the Iowa Civil Rights
Act.
71. Greens termination in violation of the Iowa Civil Rights Act was a proximate
cause of her damages.
COUNT III: WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY
72. Green incorporates by reference paragraphs 1 through 71 of the Petition as of
73. Greens employment was terminated in contravention to one or more clearly
defined public policies.
74. Greens employment was terminated because she filed a workers compensation
claim.
75. Greens employment was terminated after TPI Iowa knowingly infected her with
a health condition that allegedly precluded him from continuing her employment at TPI Iowa for
safety reasons.
76. Greens discharge from employment was a proximate cause of damages suffered
by Green.
77. As a result of TPI Iowas actions as set forth above, Green has suffered emotional
distress, mental anguish, pain and suffering, inconvenience, humiliation, loss of the enjoyment of
life, medical expenses, and lost past and future wages and benefits.
COUNT IV FRAUD
(Green vs. TPI Composites and TPI Iowa)
79. TPI Composites and TPI Iowa represented to Green that as an employee, Green
was their most valuable asset.
80. TPI Composites and TPI Iowa represented to Green that her health and safety was
a primary consideration in every company decision and plan made by TPI Composites and TPI
Iowa.
81. TPI Composites and TPI Iowa represented to Green that they were committed to
protecting her from injury.
82. TPI Composites and TPI Iowa represented to Green that they would provide her
with a safe work environment.
83. TPI Composites and TPI Iowa represented to Green that they had established
safety rules, programs and procedures that assured safe operations.
84. TPI Composites and TPI Iowa represented to Green that they provide training to
everyone in their organization to help them do their job safely.
85. TPI Composites and TPI Iowa represented to Green that they would ensure that
she would work in an environment that is free from recognized hazards that are likely to cause
serious physical harm.
86. TPI Composites and TPI Iowa represented to Green that if she suffered an injury,
they would send her to a doctor to determine if the injury was work-related.
87. TPI Composites and TPI Iowa represented to Green that they had established a
safety committee to enforce safety policies and prevent accidents and injuries in areas of safety
concern.
88. TPI Composites and TPI Iowa represented to Green that the materials she worked
with were not dangerous if he wore the PPE provided by TPI Composites and TPI Iowa.
89. TPI Composites and TPI Iowa represented to Green that allergic contact
dermatitis was avoidable if he followed their recommended safety practices.
90. The representations made by TPI and TPI Iowa in paragraphs seventy-nine (79)
through eighty-nine (89) were false.
91. The misrepresentations made by TPI and TPI Iowa in paragraphs seventy-nine
(79) through eighty-nine (89) are material.
92. TPI Composites and TPI Iowa made the misrepresentations to Green with the
intent to deceive her into accepting employment at TPI Iowa.
intent to deceive her so that she would continue to work at TPI Iowa after he accepted
employment.
intent to deceive her so that they could employ her and fulfill production expectations for which
they were contractually bound.
intent to deceive her so that they could make a monetary profit at the expense of Greens
livelihood and health.

96. Green relied on TPI Composites misrepresentations and TPI Iowas
misrepresentations by accepting employment at TPI Iowa.
97. Green relied on TPI Composites misrepresentations and TPI Iowas
misrepresentations by continuing to work at TPI Iowa for several months.
98. TPI Composites and TPI Iowa knew that their misrepresentations were false given
that they had reported hundreds of chemical injuries in their Iowa OSHA logs prior to Greens
injury.
99. TPI Composites and TPI Iowa knew that their misrepresentations were false given
their systematic practice of hiring healthy employees and then terminating them from
employment after their employees sustained a Chemical injury.
100. TPI Iowa used Iowas workers compensation statute to perpetrate the fraud
against Green in order to avoid liability.
101. Green suffered damages when he was permanently injured due to exposure to the
Chemicals she worked with while employed at TPI Iowa.
102. Green suffered damages when she was terminated by TPI Iowa from employment.
COUNT V BREACH OF CONTRACT
103. Green incorporates by reference paragraphs 1 through 102 of the Petition as if
104. TPI Iowas offer of employment to Green communicated to Green that it would
provide her with a safe and hazard free work environment.
105. TPI Iowas offer of employment to Green communicated to Green that TPI Iowa
had established safety procedures to ensure safe business operations.

would comply with its established safety procedures.
would provide her with a work environment that was free from recognized hazards that result in
serious physical harm.
108. Green accepted TPI Iowas offer for employment by commencing employment in
or around May 2016 and working continuously at TPI Iowa for several months.
109. TPI Iowa breached its agreement with Green by failing to provide Green with a
hazard free work environment.
110. TPI Iowa breached its agreement with Green by failing to establish and/or comply
with safety procedures that assured safe business operations.
111. TPI Iowa breached its agreement with Green by failing to provide Green with a
work environment that was free from recognized hazards that result in serious harm.
112. Green suffered damages as a result of TPI Iowas breach.
113. The damages sustained by Green were proximately caused by TPI Iowa.
COUNT VI BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR

DEALING
115. TPI Iowa failed to act in good faith with respect to its offer for employment to
Green.
116. TPI Iowa failed to act in good faith with respect to its employment relationship
with Green.
117. TPI Iowa evaded its obligation of good faith in performance by failing to provide
Green with a safe work environment due to a lack of diligence.
118. TPI Iowa evaded its obligation of good faith in performance by failing to provide
Green with a safe work environment by willfully rendering imperfect performance.
119. Green suffered damages as a result of TPI Iowas breach of implied covenant of
good faith and fair dealing.
120. The damages sustained by Green were proximately caused by TPI Iowa.
COUNT VII JOINT VENTURE
(Green vs. TPI Composites)
122. TPI Composites and TPI Iowa are an association of two entities engaged in the
business of wind blade manufacturing.
123. TPI Composites and TPI Iowa are engaged in a common undertaking.
124. TPI Composites and TPI Iowas wind blade manufacturing business enterprises
are for profit.
125. TPI Composites and TPI Iowa have a joint proprietary interest in their for profit
business enterprises.
126. TPI Composites and TPI Iowa have a mutual right to control their for profit
127. TPI Composites and TPI Iowa have a right to share in the profits of their for profit
128. TPI Composites and TPI Iowa have a duty to share in the losses of their for profit
129. TPI Composites and TPI Iowa are a joint venture.
130. TPI Composites and TPI Iowa share tort liability.
131. TPI Iowa was negligent in facility to provide Green with a safe workplace
environment.
132. TPI Iowa was generally negligent under the circumstances.
133. TPI Iowas negligence caused Green to suffer injuries.
134. TPI Composites is liable to Green for her damages proximately caused by TPI
Iowas negligence.
COUNT VIII NEGLIGENCE
(Green vs. TPI Composites)
136. TPI Composites owed Green a duty to provide her with a safe workplace.
137. TPI Composites was negligent in failing to provide Green with a safe workplace
environment.
138. TPI Composites was generally negligent under the circumstances.
139. TPI Composites negligence caused Green to suffer injuries.
COUNT IX PIERCING
141. TPI Iowa is a mere instrumentality of TPI Composites.

142. TPI Iowa serves no legitimate business purpose.
143. TPI Composites used TPI Iowa as a means of perpetrating fraud against Green.
144. TPI Composites used TPI Iowa as an unfair device to perpetrate fraud against
Green.
145. TPI Composites used TPI Iowa as a means to attempt to avoid its legal obligation
to Green and other employees.
146. TPI Composites used TPI Iowa to circumvent liability under Iowas
discrimination statutes.
147. TPI Composites used TPI Iowa to circumvent liability under Iowas workers
compensation statutes.
TPI Iowa was used primarily by TPI Composites as a means to promote fraud and injustice.
COUNT X - NEGLIGENT INSPECTION
(Green vs. Insurance Company State of Pennsylvania)
149. While Green was employed at TPI Iowa, Insurance Company State of
Pennsylvania was TPI Iowas workers compensation insurer.
150. Insurance Company State of Pennsylvania undertook, gratuitously or for
consideration, an inspection(s) that it should have recognized as necessary for the protection of
Green.
151. Insurance Company State of Pennsylvania is liable to Green for physical harm
resulting from its failure to exercise reasonable care to protect his undertaking because its failure
to exercise reasonable care increased the risk of the harm to Green.

resulting from its failure to exercise reasonable care to protect his undertaking because the harm
to Green was suffered because of reliance of TPI Composites, TPI Iowa or Green upon the
undertaking.
resulting from its failure to exercise reasonable care to protect his undertaking because it
undertook to perform a duty owed by TPI Composites and TPI Iowa to Green.
COUNT XI FAILURE TO INSPECT
(Green vs. Insurance Company State of Pennsylvania)
154. Green incorporates paragraphs 1 through 153 of the Petition as if fully set forth
herein.
155. Insurance Company State of Pennsylvania owed a duty to Green to inspect the
premises at TPI Iowa.
156. Insurance Company State of Pennsylvania failed to inspect the premises at TPI
Iowa.
157. Insurance Company State of Pennsylvanias failure to inspect the premises at TPI
Iowa caused injury and damages to Green.
158. Insurance Company State of Pennsylvania is liable to Green for the damages
suffered by Green as a result of its failure to inspect the premises at TPI Iowa.
COUNT XII PUNITIVE DAMAGES
159. Defendants took the actions in paragraphs 1 through 158 above with the willful
and wanton disregard for the rights and safety of Green.

160. The actions described in paragraphs 1 through 158, except those averments
pertaining to TPI Iowas violations of the Iowa Civil Rights Act, entitle Green to punitive
damages.
RELIEF (Count II & III)
WHEREFORE, Plaintiff Green requests judgment be entered in her favor and against
Defendant TPI Iowa, LLC, and that the Court order the following:
A. That TPI Iowas conduct complained herein be declared to be in violation of
Plaintiffs rights as secured by Iowa Code Chapter 216, and the public policy of the state of
Iowa;
B. That TPI Iowa be enjoined from any conduct violating Plaintiffs rights or the
rights of others similarly situated as secured by Iowa Code Chapter 216, the public policy of the
state of Iowa, and such injunctive and other relief as will prevent TPI Iowa from continuing their
discriminatory practices;
C. That judgment for compensatory damages be awarded in Plaintiff Greens favor
against Defendants;
D. That judgment for lost earnings and benefits with interest and other affirmative
relieve be awarded in Plaintiff Greens favor against Defendants.
E. That Plaintiff Green be awarded emotional distress damages;
F. That Plaintiff Green be awarded reasonable attorney fees and costs; and
G. That Plaintiff Green be awarded such other additional and further relief as the
Court deems proper.
RELIEF (Count I, IV, V, VI, VII, VIII, IX, X, XI, XII)

WHEREFORE, Plaintiff Green requests judgment be entered in her favor and against
Defendant TPI Composites, TPI Iowa, LLC, Hoenicke, Williams, Boyd, Finchum, Van Huysen,
Bailey, and Insurance Company State of Pennsylvania, and that the Court order the Defendants
to pay the following damages sustained by Green:
A. Past medical expenses;
B. Future medical expenses;
C. Past loss of full mind and body;
D. Future loss of full mind and body;
E. Past lost wages;
F. Future lost wages and loss of earning capacity;
G. Past physical pain and mental suffering;
H. Future physical pain and mental suffering;
I. Punitive damages;
J. Any other element of loss recognized by Iowa law not specifically set forth
herein;
K. Any other additional and further relief that the Court deems proper.
JURY DEMAND
Plaintiff Green demands a trial by jury of all issues herein.

Respectfully Submitted,
/s/ Matthew M. Sahag

Matthew M. Sahag
ATTORNEY FOR PLAINTIFF
AT# 0008849
301 East Walnut Street, Suite 1
Des Moines, Iowa 50309
PHONE: 515.288.5008
FAX: 515.288.5010
E-MAIL: matthew@dickeycampbell.com

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E-FILED 2017 JUL 12 12:03 PM JASPER - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR JASPER COUNTY

Insurance Company State of Pennsylvania (Defendants). Plaintiff alleges upon personal

investigation of counsel as to all other matters, as follows:

Arizona, and the parent company of TPI Iowa, LLC.

resident of Polk County, Iowa.

Williams was employed by TPI Iowa as a Human Resources Manager.

was employed by TPI Iowa as a Human Resources Manager.

Finchum was employed by TPI Iowa as the operations manager.

employed by TPI Iowa as an Environmental Health and Safety Manager.

JURISDICTION AND VENUE

fully set forth herein.

12. Damages exceed the threshold for small claims court.

13. Green incorporates by reference paragraphs 1 through 12 of her Petition as if fully

set forth herein.

business addresses at 2300 N. 33rd Ave., Newton, IA.

manufacturer of wind blades in the wind energy market.

17. In 2015, TPI Composites reported revenue of $586,000,000.00.

with hazardous chemicals while manufacturing the wind blades.

while manufacturing the wind blades.

the wind blades.

sensitization, simple asphyxiation, gastrointestinal irritation, central nervous system depression,

liver effects, kidney effects and bladder effects or peripheral neuropathy.

damage to the reproduction system.

damage or eye irritation, respiratory sensitization, skin sensitization, reproductive system

31. Personal Protective equipment (PPE) is required to be worn to avoid the

adverse health effects of the Adhesives, Resin and Curing Agent.

employees at the Newton, IA manufacturing plant.

33. Green was employed by Defendants in or around May 2015.

Iowa in their Iowa OSHA logs.

36. Green worked directly with the Chemicals on a daily basis.

hazards of the Chemicals he worked with at TPI Iowa.

equipment to avoid a Chemical injury.

breaking out with bumps and rashes.

42. Instead, Defendants instructed Green to participate in a three-step program that

to her open rashes and wounds.

Green to continue working.

burns all over her body.

45. Greens eyes swelled shut.

46. Greens suffered opened wounds on her eyelids.

Nyonne that she was to avoid epoxy resin.

Chemicals while working at TPI Iowa.

Green in an interactive process with Green to attempt to accommodate her disability.

53. TPI Iowa denied Green request and terminated her.

COUNT I: GROSS NEGLIGENCE

set forth herein.

scope of her employment at TPI Iowa.

58. Defendants each violated their duty of care to the Green.

Green in the scope of her employment at TPI Iowa caused injury.

would suffer injuries as a result of her exposure to the dangerous Chemicals.

from the Chemicals.

set forth herein.

Defendant TPI Iowa, LLC.

of Right to Sue with respect to such charges.

in the scope of her employment at TPI Iowa.

more of Greens life functions.

68. Greens physical conditions require reasonable accommodation.

impairment that substantially limited one or more major life activities.

cause of her damages.

COUNT III: WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY

(Green vs. TPI Iowa)

72. Green incorporates by reference paragraphs 1 through 71 of the Petition as of

fully set forth herein.

73. Greens employment was terminated in contravention to one or more clearly