THIS IS A REFERRAL TO DOJ ASKING THAT A CLAIM BE FILED IN BANKRUPTCY COURT. THE MATTER ARISES FROM A PREVIOUS ACTION FILED AGAINST ARDEN PROPERTIES AND SEVERAL OTHER PARTIES FOR THEIR CONTRIBUTION OF PCE AND TCE CONTAMINANTS TO THE GROUNDWATER AT THE INDIAN BEND WASH SUPERFUND SITE. ARDEN PROPERTIES IS AN ARIZONA S-CORPORATION WHOSE SOLE ASSET IS IMPROVED, BUT CONTAMINATED REAL PROPERTY IT ACQUIRED IN 1994. THAT PROPERTY IS CONSIDERED TO BE A SUB-SITE OF THE LARGER INDIAN BEND WASH SUPERFUND SITE. THE CERCLA ACTION AGAINST ARDEN SEEKS PAST AND FUTURE RESPONSE COSTS FOR SITE CLEANUP, AS WELL AS THE VOIDING OF CERTAIN FRAUDULENT LAND CONVEYANCES. EPA'S TOTAL CLAIM IS APPROXIMATELY $34,000,000. BECAUSE ARDEN HAS NOW FILED FOR BANKRUPTCY, EPA SEEKS TO PRESERVE ITS CLAIM TO ARDEN'S ASSETS FOR SATISFACTION OF RESPONSE COSTS.