SITE INFORMATION AND CORRESPONDENCE

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SWO, *./ Donna Heran August 12, 1993 Page 2 reimbursement and indemnity for cleanup of the subject site. There is a Settlement Conference now set for September 6, 1993, at which I hope to resolve many of the issues relating to how this site will eventually be cleaned up. As it stands, however, it ' s apparent to me that the method by which the site would be cleaned up, is that my clients would make an application to the State Underground Storage Tank Fund, for the money to conduct the cleanup of the site, inclusive of the preparation of proper work plans to remove an free product, and to complete a soil and ground water cleanup. Thus, while I acknowledge on behalf of my clients, your demand for a work plan for investigation of the site by August 23, 1993, my clients cannot meet that deadline. At least, it ' s not likely that they could do so, even if they had the resources to start on it right away. The last work done on the site was done by Falcon Engineering, but Falcon Engineering is the agent and expert for parties other than my client, in the above litigation. That person is the most appropriate party to respond to your demands, but it' s not my client ' s agent and not within their control . Accordingly, over the short term, may I suggest that you extend this deadline at least 30 days, to allow time for the parties in the litigation to work out a settlement. I anticipate, however, that it is most probable that the funds to actually perform any work at the site, including any work plan or assessment, would probably have to come from the State through the Underground Tank Storage Cleanup Fund. I would be happy to discuss this matter further with you by telephone or otherwise, if you think that would be helpful . Yours truly, WILLIAM B. LOOK, JR. Attorney for Yearings WBL: ea