Acuity Specialty Products Group Inc.

company, ASP. ASP is a Delaware corporation, registered to do business in Georgia.2. The Seaboard facility is a chemical blending facility that manufacturesnumerous detergent and cleaning products which are used for industrial and domesticpurposes. Within the facility were different plants, each of which produces a differenttype of detergent or cleaning product, including liquids, aerosols, powders and acids.3. At all relevant times, Defendant ASP employed an environmentalengineering and compliance manager, also known as the environmental engineer, atthe Seaboard facility. This individual was responsible for ensuring that the Seaboardfacility complied with federal, state and local environmental laws and regulations.The environmental engineer reported to and was supervised by various ASPmanagers, directors and vice presidents employed at the Seaboard facility.4. From in or about September 1998 until in or about August 2003,Employee A was employed at the Seaboard facility. From in or about September1998 until on or about September 30 , 2000, Employee A held the position ofEnvironmental Engineering and Compliance Manager. From on or about October 1,2000 until in or about November 2002, Employee A held the position of Director ofEnvironmental Compliance.From in or about September 1998 until in or aboutNovember 2002, Employee A was ASP's "authorized representative" for purposes ofsigning Self-Monitoring Reports and Permits for the Seaboard facility.2