EPA incurred CERCLA response costs at both sites. NVF owns both sites and filed for bankruptcy. DOJ filed a proof of claim on EPAÂs behalf seeking reimbursement of CERCLA response costs for both sites. The debtor and US negotiated a settlement under which an unsecured, non-priority claim for both sites combined. This agreement took the form of a stipulation which was signed by the Bankruptcy Court on April 15, 2011. The settlement did not guarantee payment of this amount; rather it guaranteed payment of a percentage of this amount corresponding to the percentage assigned to general unsecured creditors.