MR KAPP, MR KASTER, AND MR WEBB WON A JUDGMENT AGAINST RAYMARK YEARS AGO, AND TO SECURE THEIR $100,000 JUDGMENT, PUT A LIEN AGAINST THE RAYMARK FACILITY. EPA LATER PUT ITS OWN LIEN AGAINST RAYMARK AND FORECLOSED ON ITS LIEN. IN ORDER TO SELL THE FACILITY AND OBTAIN SOME OF THE MONEY OWED TO IT, EPA NEEDED TO RESOLVE THE FIRST LIEN, COMMONLY REFERRED TO AS THE JACOBS & CRUMPLER LIEN AFTER THE NAME OF THE LAW FIRM REPRESENTING THE THREE MEN WITH THE EARLIER CLAIM AGAINST RAYMARK. THE THREE MEN AGREED TO RELEASE THEIR LIEN IN EXCHANGE FOR A PAYMENT OF $750,000 FROM EPA. EPA DOES NOT CONSIDER THE THREE MEN TO BE PRPS, BUT LODGED A COMPLAINT ONLY AS A MEANS TO BRING THE PROPOSED SETTLEMENT BEFORE THE COURT FOR ITS APPROVAL.