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4723 -1999 9 :06AM <br />FROM SWEENEY LAW FIRM 2235289 P.8 <br />PARTIES <br />5. Third Party Plaintiff, The Schnitzer Site* Group, is a group of responsible parties <br />who has contributed response costs to the Site and who has received assignments from the City of <br />Saint Paul; the Housing and Redevelopment Authority of the City of Saint Paul; the City of <br />Mrnneapolis; the Minneapolis Conununity Development Agency; and the University ofMlnnesota <br />to pursue their claims related to the Site. <br />6. Third Party Plaintiff is a person who has incurred necessary "response" costs as <br />defined in CERCLA § 101(25), 42 U.S.C. § 9601(25) and lvfnm. Stat. § 1158.02, subd. 18. The <br />costs were incurred pursuant to a Response Order by Consent between the State of IvMinnesota <br />through the Minnesota Pollution Control Agency ("MPCA ") and the University of Minnesota, the <br />City of Saint Paul and the City of Minneapolis and a subsequent settlement by Third Party Plaintiff <br />with those parties. <br />7. Third Party Defendant City of Little Canada is a municipality or other organization <br />who is a "person" as defined in CERCLA § 101(21), 42 U.S.C. § 9601(21) and Minn. Stat. § <br />1153.02, subd.12, who arranged, by contract, agreement or otherwise, for disposal or treatment, <br />or transport for disposal or treatment; of hazardous substances at the Schnitzer Site. <br />FACTUAL ALLEGATIONS <br />8. The business address of the Schnitzer Site was 2703 Territorial Road, St. Paul, <br />Minnesota. A portion of the Schnitzer Site was located in the City of Saint Paul, Ramsey County, <br />Minnesota, in the northwest quarter of Section 29, T29N, R23W. The remainder of the Site was <br />located in the City ofMnmeapolis, Hennepin County, Minnesota, in the northeast quarter of <br />Section 30, T29N, R23W. <br />Page 158 <br />