SITE INFORMATION AND CORRESPONDENCE_1

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Ron Rowe July 1, 1999 Page 2 additional six years. Parmaceast was not notified or consulted in 1985 when the tanks were removed, nor was Parmaceast notified in 1991 when the piping was removed. Apart from the complete absence of any evidence that the tanks leaked prior to their transfer in 1976, Del Monte is solely responsible for the mismanagement in 1985 of the tank removal and subsequent piping removal and for the contamination on the property. Nonetheless, upon learning of the situation from San Joaquin County Public Health Services Environmental Health Division in late 1994, Parmaceast took all possible steps to work with Del Monte to meet the County's directives. Parmaceast continually urged compliance with the County's directives. Attached please find correspondence from February and March 1998 between Parmaceast and Del Monte. These letters are self-explanatory. They reflect our client's exasperation and frustration with Del Monte's stonewalling and unwarranted and patently misguided agenda in refusing to assist the County in bringing the site to closure. Del Monte had and continues to have an agenda which is inconsistent with common sense or any enlightened self-interest. We could not find any common ground with this conduct. Ron, we share this information with you because there is an apparent belief that Parmaceast has not done anything on this property. This is incorrect. For over three years, our client spent a large sum of money trying to reshape Del Monte's agenda and encourage it to comply with the County's directives. As you may know, shortly after Del Monte's March 26, 1998 letter stating that the County should be communicating with Rich Fish and C112M Hill only on behalf of Del Monte, Del Monte filed suit against Parmaceast in San Joaquin County Superior Court. Now that civil litigation has commenced, it is even more difficult to work with Del Monte to ensure that workplans are prepared and the work completed in a timely manner and in accordance with the County's directives. In sum, we have yet to be provided with any evidence justifying the nomination of Parmaceast as a responsible party. Nonetheless, Parmaceast attempted to work with Del Monte for over three years to ensure that the County's directives were being followed and the site was properly characterized. Del Monte, in following its own agenda, has, in every case, obstructed Parmaceast's intentions and the County's directives. Parmaceast objected to this behavior on numerous occasions as you can see in the enclosed letters. We appreciate your taking the time to review the attached correspondence and we hope that this helps to dispel any misconceptions regarding Parmaceast's intentions on this site. 714643.1