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Anoka County Closure/Post Closure under Ordinances No. 73-1, 82- <br />1, 83-2, 83-3" (for the years 1985 through 1987); and 2. "Less <br />additional closure/post closure payment according to Anoka County <br />License Condition Part E, Item 3" (for 1990 through the present). <br /> <br /> 10. The deducted amounts which are described and identified <br />in paragraphs 8 and 9 of this Complaint have not been paid to any <br />federal, state or local government authority. <br /> <br /> 11. Those deducted amounts which are described and <br />identified in paragraphs 8 and 9 of this Complaint are not <br />properly deductible under the Agreement as "any tax, fee, or <br />surcharge imposed by federal, state or local government <br />authorities upon the disposal of any waste material at the <br />property," nor are the~ deductible under any other provision of <br />the Agreements. <br /> <br /> 12. Defendant's deduction of such amounts breaches its <br />contracts with Plaintiffs and has damaged each of them in excess <br />of $50,000. <br /> <br /> WHEREFORE, Plaintiffs respectfully request judgment as <br />follows: <br /> <br /> 1. Declaring that the payment terms of the Agreements do <br />not permit deductions from gross revenue of amounts estimated to <br />be necessary for closure and post closure obligations for purpose <br />of calculating payments due Plaintiffs. <br /> <br /> 2. Against Defendant for amounts in excess of $50,000, for <br /> <br /> <br />