SLUDGE VICTIMS

I, John Ceriello, being first duly sworn, do hereby depose and state as follows:
1. My name is John Ceriello and I reside at 138 Deer Meadow Road in Webster, New Hampshire.
2. I am a member of the Sierra Club.
3. Approximately 2 years ago, Wheelabrator came with sludge from Lowell, Massachusetts and dumped it on a field across the brook and behind my house.
4. The odors and smell from the sludge made it inhospitable to live around my residence for weeks.
I am concerned about my daughter's health because her asthma flared and greatly got worse during this time period. In addition, after the dumping of the sludge, my daughter's asthma has been significantly worse than it was prior to the dumping of the sludge.
6. During a several week period after the sludge was dumped, my entire family would get nauseous, have dry heaves,