The United States of America (?United States?), on behalf of the Administrator of
the U.S. Environmental Protection Agency (EPA), filed a complaint in this matter pursuant to
Section 107 of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended, seeking reimbursement of response costs incurred or to be incurred for
response actions taken at or in connection with the release or threatened release of hazardous
substances at the Ogden Swift Building Superfund Site in Ogden, Utah (the ?Site?).