THE LITIGATION REPORT IS PREPARED UNDER SECTIONS 106(B) AND 107(A) OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980, AS AMENDED ( CERCLA ). THE FIRST CALIM IS FOR PENALTIES UNDER SECTION 106(B) OF CERCLA IN THE AMOUNT OF $13,000,000 EACH AGAINST SIXTEEN PARTIES FOR FAILURE TO COMPLY WITH AN ADMINISTRATIVE ORDER FOR REMEDIAL ACTION ( ORDER ) ISSUED BY THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION III ( EPA ) PURSUANT TO SECTION 106(A) OF CERCLA. THE SECOND CLAIM, PURSUANT TO SECITON 107(A) OF CERCLA IS FOR RECOUPMENT OF APPROXIMATELY $2,238,987.54 FROM THIRTY- SEVEN POTENTIALLY RESPONSIBLE PARTIES FOR MONIES SPENT BY EPA IN PERFORMING RESPONSE ACTIVITIES AT THE THE C&R BATTERY SITE IN ADDITION TO A DECLARATORY JUDGMENT FOR FUTURE LIABILITY.