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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON <br />IN AND FOR THE COUNTY OF SNOHOMISH <br />STATE OF WASH NGTON, <br />DEPARTMENT OF ECOLOGY, <br />Plaintiff, <br />V. <br />CITY OF EVERETT, <br />Defendant. <br />Na 01 2 03640 6 <br />cohswrvr <br />L JURISDICTION <br />1.1 This court has jurisdiction over the parties and over the subject matter under the <br />Model Toxics Control Act, chapter 70.105D RCW. <br />H. PARTIES <br />2.1 Plaintiff State of Washington Department of Ecology (Ecology) is a state agency <br />charged with the implementation of the Model Toxics-Control Act. <br />2.2 Defendant is the City of Everett. Defendant has agreed to enter into a Consent <br />Decree with Ecology under the Model Toxics Control Act to remedy the release of hazardous <br />substances on Facility. <br />M. FACTUAL ALLEGATIONS <br />3.1 The site is referred to as the Everett Landfill/Tire Fire Site, hereinafter known as <br />the "Facility", as defined in RCW 70.105D.020(4), and is located at 2902-36`h Street East, <br />COMPLAINT <br />1 ATTORNEY GENERAL OF WASHINGTON <br />Ecology Division <br />PO Box 40117 <br />Olympia, WA 98504-0117 <br />FAX (360) 439-7743 <br />