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Affidavit of Peter J.Niemiec <br /> Page 2 <br /> 7. Based upon the course of dealings between, on the one hand, PHS/EHD and the San Joaquin <br /> District Attorney's Office and, on the other hand, Unocal and its consultants, it is my expectation <br /> that both PHS/EHD and the San Joaquin County District Attorney's Office will continue to press <br /> for Unocal to accede to the request of PHS/EHD for extensive investigation at the Site. This will <br /> put Unocal in the difficult position of either complying with the request of PHS/EHD, thereby <br /> incurring substantial cost and losing the benefit of its Petition for Review, or risk enforcement <br /> action by the San Joaquin County District Attorney's Office. A Stay Order issued by the Board is <br /> necessary to protect Unocal from this unreasonable risk. <br /> I declare under penalty of perjury under the laws of the State of California that the foregoing <br /> is true and correct. <br /> DATED this 9" day of January, 1998 at Brea, Calif a. <br /> Pr J. <br />