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THE KIRK LAW FIRM <br /> Ms. Lori Casias <br /> Associate Government Program Analyst <br /> State of California <br /> Water Resources Control Board <br /> Division of Clean Water Programs <br /> June 3, 1999 <br /> Page 10 <br /> conscious interference with the State Board appeals process by requiring new or additional work <br /> at a site where a petition for review and closure of the site is being considered by the State Board. <br /> PHS/EHD's May 4, 1999 letter is clearly an attempt to impede and interfere with Unocal's <br /> efforts to exercise its First Amendment and statutory rights to petition the state government for <br /> an airing of its grievances. PHS/EHD's letter, when considered in light of the District Attorney's <br /> insistence that Unocal dismiss its petition for closure to the State Board, is also an obvious <br /> attempt to prevent the State Board from reviewing PHS/EHD's actions. For these reasons, the <br /> local agency's action raises significant issues that should be addressed by the State Board. <br /> For all of the foregoing reasons, Unocal respectfully requests that the State Board <br /> review PHS/EHD's May 4, 1999 directive and stay any further action on the matters contained in <br /> the directive pending the State Board's review of this Petition for Review of Local Oversight <br /> Program Action and for Stay Order and the June 13, 1997 petition for closure. <br /> Should you have any questions regarding this Petition for Review of. Local <br /> Oversight Program Action and Request for Stay Order,please call me. <br /> Respectfully submitted, <br /> Sherri M. Kirk <br /> of THE KIRK LAW FIRM <br /> SNWMWS <br /> Attachments <br /> CC" Margaret Lagorio, San Joaquin County Public Health Services,Environmental Health Division <br /> Mark List, Central Valley Regional'Water Quality Control Board <br /> David Deaner, State Water Resources Control Board, Division of Clean Water Programs <br /> Ms.Helen McCrary <br /> Brooke Birkie,Esq. <br /> David J.Irey, Esq., San Joaquin County District Attorney's Office <br />