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Complaint except as otherwise provided herein. None of the facts stipulated herein shall be <br /> introduced into evidence in any other proceeding regarding nuisance alleged in the Local <br /> Governmental Plaintiffs' Complaint except as otherwise provided herein. It is the intent of the <br /> parties to this Consent Order that it be a final judgment on the merits of this matter. <br /> A. Parties and Background <br /> 1. On the same date as entry of this Consent Order, a Complaint was filed on behalf <br /> of the People of the State of Illinois ex rel. Lisa Madigan, Attorney General of the State of <br /> Illinois, on her own motion pursuant to Section 42(d) and(e) of the Act, 415 ILCS 5/42(d) and <br /> (e) (2014), against CLI. <br /> 2. The Illinois EPA is an administrative agency of the State of Illinois, created <br /> pursuant to Section 4 of the Act, 415 ILCS 5/4 (2014). <br /> 3. On the same date as entry of this Consent Order, a Complaint was filed by the <br /> Local Governmental Plaintiffs against CLI alleging the existence of a nuisance. <br /> 4. At all times relevant to the Complaints, CLI was and is an Illinois corporation in <br /> good standing with the Illinois Secretary of State's Office. <br /> 5. CLI owns and operates a municipal solid waste and special waste landfill located <br /> at 9550 Heritage Road, Clinton, unincorporated DeWitt County, Illinois("Clinton Landfill 3" or <br /> "Facility"). <br /> 6. Clinton Landfi113 consists of two parts: a 135-acre municipal solid waste unit <br /> ("MSWU") and a 22.5-acre portion of Clinton Landfill3 referred to as of the date of entry of this <br /> Consent Order as the Chemical Waste Unit("CWU"), located within the boundaries of the <br /> Facility(and for purposes of this Consent Order, Clinton Landfi113 consists of the land legally <br /> 3 <br />