Researched and prepared an Expert Report on the history of EPA/State response actions at a Western NPL site and the historical composition of the site prior to NPL inclusion.  Report demonstrated that site involved multiple units even prior to NPL listing and that Superfund program response has been continuous and uninterrupted since 1982.  Report was used to counter plaintiff’s position on the issue of late notice to the carrier.  Court granted carriers’ Summary Judgement motion.