THE UNITED STATES, ON BEHALF OF THE US EPA, FILED A COMPLAINT IN THIS MATTER PURSUANT TO SECTION 107 OF CERCLA, SEEKING REIMBURSEMENT OF THE 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 SHELLY DITCH REACH 4 SUPERFUND SITE, SHELLY DITCH (REACH 1-3), SUGAR CREEK SITE, AND THE CALUMET CONTAINERS SITE.