IN 1991, DEFENDANT ADOPTED A VOLUNTARY PLAN OF DISSOLUTION AND LIQUIDATION. OM MAY 9, 1994, THE DEBTOR FILED PETITIONS UNDER CHAPTER 11 OF THE BANKRUPTCY CODE IN THE U.S. BANKRUPCTY COURT FOR THE EASTERN DISTRICT OF NY. EPA IS REFERRING THE CASE TO DOJ FOR THE FILING OF A PROOF OF CLAIM IN THE DEBTOR'S BANKRUPTCY PROCEEDING TO OBTAIN RECOVERY FROM THE DEBTOR'S BANKRUPTCY ESTATE OF THE COSTS INCURRED BY EPA AT THE SITE.