THE AGENCY REQUESTS THAT THE DEPARTMENT OF JUSTICE FILE, IN THE PROPER COURT, A COMPLAINT AND A MOTION FOR AN ORDER IN AID OF IMMEDIATE ACCESS GRANTING THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY AND ITS REPRESENTATIVES ACCESS TO THE SADD TROUSDALE ROAD SITE (THE SITE ), WHICH PROPERTY IS OWNED BY ELLIS AND KATHY SAAD, THE DEFENDANTS. ACCESS IS NEEDED FOR THE PURPOSE OF CONTINUING AND CONCLUDING A REMOVAL ACTION AT THE SITE. THE AGENCY IS ALSO REQUESTING THAT CIVIL PENALTIES BE SOUGHT IN THE ACTION. THE SITE IS LOCATED AT 3655 TROUSDALE ROAD, NASHVILLE, TENNESSEE, AS PRESENTED IN THE SITE LOCATION MAP ATTACHED HERETO AS EXHIBIT 1. THE IMMEDIATE VICINITY IS AN INDUSTRIAL AREA OF NASHVILLE WITH THE ALLIED INDUSTRIAL PARK TO THE NORTHEAST AND THE SITE ITSELF WITHIN THE EAST RADNOR INDUSTRIAL SUBDIVISION. THE SITE COVERS APPROXIMATELY 0.4 ACRES OF PROPERTY AND INCLUDES AN ONSITE BUILDING WHICH IS USED FOR STORAGE. THE SITE IS BOUNDED ON THE NORTH BY KLEIN'S CUSTOM COACH CO., INC., ON THE SOUTH BY FRANKLIN BRICK CO., ON THE EAST BY TROUSDALE ROAD, AND ON THE WEST BY THE CSX RAILROAD RADNOR YARD PROPERTY, AS DEPICTED IN THE SITE MAP ATTACHED HERETO AS EXHIBIT 2. THE LEGAL DISCRIPTION FOR THE SITE PROPERTY OWNED BY DEFENDANTS IS SET FORTH ON A DEED EXECUTED ON AUGUST 18, 1988, ATTACHED HERETO AS EXHIBIT 3. JOHN P. SAAD & SONS, INC., OPERATED