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2016-08-10_GENERAL DOCUMENTS - M1981185 (2)
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2016-08-10_GENERAL DOCUMENTS - M1981185 (2)
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8/24/2016 6:25:42 PM
Creation date
8/15/2016 8:36:00 AM
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DRMS Permit Index
Permit No
M1981185
IBM Index Class Name
General Documents
Doc Date
8/10/2016
Doc Name
EPA Enforcement
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DRMS
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DMC
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D
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conduct business in this District, the subject property (previously defined as the "Site") is located <br />in this District, and the causes of action alleged in the Complaint arose in this District. <br />3. Claims for Relief. The Complaint states claims upon which relief may be granted <br />pursuant to Sections 301 and 309 of the CWA, 33 U.S.C. §§ 1311 and 1319. <br />III. APPLICABILITY <br />4. Persons Bound. The obligations of this Consent Decree shall apply to and be binding <br />upon Defendants, their officers, directors, agents, employees, and servants, and their successors <br />and assigns, and any person, firm, association, or corporation who is, or will be, acting in concert <br />or participation with either of the Defendants, whether or not such person has knowledge of this <br />Consent Decree. In any action to enforce this Consent Decree against a Defendant, the Defendant <br />shall not raise as a defense the failure of any of its officers, directors, agents, employees or <br />servants, successors, or assigns or any person, firm, or corporation acting in concert or <br />participation with the Defendant, to take any actions necessary to comply with the provisions <br />hereof. <br />5. Transfer of Ownership. Any transfer of ownership or other interest in the Site shall <br />not alter or relieve a Defendant of its obligation to comply with any applicable terms of this <br />Consent Decree. Until such time as this Consent Decree is terminated, at least 15 days prior to <br />any transfer of ownership or other interest in the real property upon which the Site is located, the <br />party making such transfer shall provide written notice and a true copy of the Consent Decree to <br />its successors) in interest and shall simultaneously notify EPA and the United States Department <br />of Justice at the addresses specified in Section XII below that such notice has been given. As a <br />condition to any such transfer, the transferring party shall reserve access rights to ensure <br />—4— <br />Case 1:16-cv-02008-WYD Document 2 Filed 08/08/16 USDC Colorado Page 6 of 82
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