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101 <br /> 1 Property. <br /> 26. FDIC is informed. and believes and based thereon alleges <br /> that the groundwater beneath the Tngv's Property and in the <br /> 4 vicinity of the Togo{s: 'property` '" generally moving in a <br /> 8 southerly :d .rection from the Exxon property and towards the <br /> 6 Togo":.s :Property.. <br /> 7 27-: PPIC is further informed and believes, and based <br /> 8 there+cn alleges; . that the petroleums hydrocarbons and, associated. <br /> 9hazardous constituents, and MTBE which have been detected. in the. <br /> to groundwater beneath the: 'Togo's property is due, in part, f' .not. <br /> 11 in. full, to tete. lateral migration of one :or more Co aminated <br /> I groundwater plumes emanating from beneath the Exxon property. <br /> 13 Sihad the Togo's Property is down gradient from the :Exxon <br /> 14 property, the plume or plumes of ,contaminated ground" <br /> ter 'which <br /> AS are emanating from beneath the Exxon property as alleged herein <br /> lb Viii continue to move laterally towards and across the subsurface <br /> 17 of the Togo's Property and will continue to carry additional <br /> 18 contamination into the subsurface of the Togo I's Property. <br /> 19 28 FDIC is informed and believes and ;based thereon alleges <br /> 20 that the subsurface contamination caused: by Defendants as alleged <br /> 21 in paragraphs 24 through 21 above ("subsurface contamination") <br /> 22 has and continues to spread over time, causing new damage to the <br /> 23 soil and groundwater at the Togo's Property. <br /> 24 29. As a result of the subsurface contamination existing at <br /> 21 the Togo's property, City and FDIC haveincurred and continue to <br /> 24incur costs to investigate the scope and extent of the subsurface <br /> 27 contamination,, andcosts to conduct corrective action and <br /> 28 remediation activities at the Togo's Property. Investigation is <br /> -7- <br />