The United States of America (United States), on behalf of the Administrator of
the United States Environmental Protection Agency (EPA), filed a complaint in this matter
pursuant to Sections 106 and 107 of the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended (CERCLA), 42 U.S.C. ?? 9606 and 9607.
The United States in its complaint seeks, inter alia: (1) reimbursement of costs
incurred by EPA and the Department of Justice (DOJ) for response actions at the East Helena
Superfund Site in East Helena, Montana (Site), together with accrued interest; and
(2) performance of response actions by the defendants at the Site consistent with the National
Contingency Plan, 40 C.F.R. Part 300 (NCP).