ON OCTOBER 23, 1995, A COMPLAINT WAS FILED FOR WORK PRACTICE AND REPORTING VIOLATIONS OF THE CLEAN AIR ACT AND THE ASBESTOS NESHAP, AND FOR VIOLATIONS OF AN EXISTING CONSENT DECREE. THE DEFENDANT CORPORATION CEASED OPERATING IN MARCH 1996. IN 1997, U.S. EPA'S FINANCIAL ANALYST DETERMINED THAT DEFENDANT WAS UNABLE TO PAY A CIVIL PENALTY. THE CASE WAS THEN RESOLVED VIA A STIPULATION FOR DISMISSAL WITHOUT PREJUDICE EXECUTED BY BOTH PARTIES. THIS ACTION WAS DISMISSED ON MARCH 27, 1997. SEE JANUARY 28, 1997 MEMORANDUM FROM NANCY-ELLEN ZUSMAN, SPECIAL ASSISTANT U.S. ATTORNEY, E.D. WI TO BEN FISHEROW, DOJ AND MAY 8, 1997 MEMORANDUM FROM RANDA BISHLAWI, ORC EPA TO NEWTON ELLENS.