Amended complaint - PennFuture

Background8. At all times relevant hereto, the Medallises were and are the lawful owners andoccupants of the property located at 1215 Philo Street, Scranton, Pennsylvania18508 (the “Medallis Property”).9. NLD is the developer of the Village of Tripp Park, a residential developmentlocated in Scranton, Pennsylvania (“Tripp Park”).10. Upon information and belief, CJS DEV INC is an affiliate of NLD involved withTripp Park.11. More specifically, CJS DEV INC was issued several notices of violation by thePennsylvania Department of Environmental Protection (“DEP”), in connectionwith development activities at Tripp Park, for failure to implement effective BestManagement Practices, failure to maintain effective Best Management Practices,failure to comply with permit conditions, failure to prevent sediment or otherpollutant discharge into waters of the Commonwealth, and site conditions thatpresent a potential for pollution to waters of the Commonwealth.12. Upon information and belief, Tripp CDC, Inc., is an affiliate of NLD involvedwith Tripp Park.13. More specifically, Tripp CDC, Inc., holds the deed for Tripp Park.14. More specifically, Tripp CDC, Inc., holds NPDES Permit No. PAR10N1161 forthe discharge of stormwater from Tripp Park into the Lackawanna River.15. Upon information and belief, CIDC-1, LLC, is an affiliate of NLD involved withTripp Park.