RECEIVED MAR 2 5 2011 CHANCERY DIVISION CHAMBERS FARERFERSKO A Professional Association 600 South Avenue P.O. Box 580 Westfield, NJ 07091-0580 (908) 789-8550 Attorneys for Plaintiffs International Paper Company and Georgia-Pacific Consumer Products LP INTERNATIONAL PAPER COMPANY, a New York corporation, and SUPERIOR COURT OF NEW JERSEY GEORGIA-PACIFIC CONSUMER CHANCERY DIVISION PRODUCTS LP, a Delaware limited HUNTERDON COUNTY partnership, DOCKET NO.: C-14003-11 Plaintiffs, v. Civil Action CROWN PAPER CO., a Virginia corporation, INTERIM ORDER Defendant. THIS MATTER, having been opened to the Court by Farer Fersko, a Professional Association, attorneys for Plaintiffs International Paper Company and Georgia-Pacific Consumer Products LP ("Plaintiffs") (Daniel L. Schmutter, Esq. and David B. Farer, Esq. appearing) for an Order to proceed summarily, for access and to appoint a Receiver empowered to act in certain capacities on behalf of Defendant; and the Court having reviewed the papers and heard the arguments of counsel; and the Court 700139 having found that the Plaintiffs' action before this Court is in the public interest and that the public heath, safety, and welfare requires that Plaintiffs have the ability to complete the environmental work they have been conducting as set forth on the record; and the Court having found that the record before the Court justifies the appointment of a common law receiver for the purpose of executing a deed notice if the timing of events as described below requires such appointment; and for good cause shown; IT IS on this z! day of ~tA, , 2011, hereby ORDERED as follows: 1. Plaintiffs' motion to proceed summarily is granted; 2. Plaintiffs, U. S. Environmental Protection Agency ("U.S. EPA"), and their respective agents, servants and employees are hereby authorized by this Court to have access to and to enter the real property known as Lot 1, Block 17.01 in the Township of Alexandria, Hunterdon County, New Jersey (the "Property"), approximately 10 acres of which comprise the Crown Vantage Landfill Superfund Site (the "Landfill"), in order to undertake any and all environmental and remedial obligations and associated and ancillary work as is or may be required by the U.S. EPA or other environmental authorities, or that is reasonably necessary to effect and complete the remediation obligations of Plaintiffs at the Landfilr 00t"") -MAo(. 'P-tMdtu.t:y _ 6 t- 0 3. If U.S. E.P.A. issues a Record of Decision requiring the establiShm~~ Q t. \-\ r') deed notice as an institutional control with respect to the Landfill and Defendant remains the record owner of the Property, Plaintiffs may apply to the Court on short notice for the immediate appointment of a receiver to execute a deed notice on behalf of Defendant with respect to the Landfill, and the Court shall grant such application forthwi~ \)~ fl"0 ~ 'ff,\t", \-\ O~ 2 700140 4. Plaintiffs shall publish notice of this action and this interim order once in the following newspapers: (1) Courier-News, Somerville, New Jersey and (2) Richmond Times- Dispatch, Richmond, Virginia; 5. Further applications for relief may be made by Plaintiffs on the papers, without the need for an appearance unless otherwise determined by the Court; 6. Disposition of the remainder of Plaintiffs' application is deferred until further order of the Court; 7. This order shall be served upon Defendant by serving The Corporation Trust Companywithin~dayshereof. ~ ~"\'Ul\{OY"\ tl~ ~~~"t. HON. ALLISON E. ACCURSO, J.S.C. 3 700141.