definiens: means any and all administrative or judicial actions, suits, Orders, claims, liens, written notices, written notices of violations, written notices of investigations, complaints, requests for information or other written comm unication, whether criminal or civil, -5- < PAGE > pursuant to or relating to any applicable Environmental Law by any Person based upon, alleging, asserting or claiming any actual or potential ( i ) violation of or liabi lity under any Environmental Law, ( ii ) violation of any Environmental Permit or ( iii ) liability for investigatory costs, cleanup costs, removal costs, remedial costs, response costs, natural resource damages, property damage, personal injury, medical monit oring costs or expenses, fines or penalties arising out of, based on, resulting from or related to the presence, Release, or threatened Release into the Environment, of any Hazardous Materials at any location, including at any off -Site location to which Ha zardous Materials were sent for handling, storage, treatment or disposal