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4 <br /> David R. Isola, Esq. <br /> Patrick D. Riddle, Esq. <br /> LAW OFFICES OF PATRICK D. RIDDLE <br /> June 24, 1994 <br /> Page 2 <br /> We have communicated with you on numerous occasions since <br /> early 1990 . On numerous occasions we have provided <br /> information to you. In August of last year, I met with a <br /> representative of your office and gave him the full and <br /> complete picture of everything that was ongoing at the <br /> site. Within ten (10) days of our meeting, we provided to <br /> your office a complete copy of all the remediation work <br /> that had been undertaken on the site. Yet, despite this, <br /> and despite the unalterable fact that Roek Brothers in no <br /> way contributed to this contamination, you undertook a <br /> variety of legal arguments in an effort to avoid your <br /> clients being listed as additional responsible parties for <br /> the remediation on site. I am not critical of the <br /> lawyering that you have done in this matter; I am <br /> critical, however, of you trying to compress over four and <br /> one-half (4-1/2) years of our efforts to get your clients <br /> to respond to the remediation to a six (6) week period of <br /> time. <br /> Our position has been clear for a long time. Roek <br /> Brothers , despite appeals to the highest level, are not <br /> eligible under the underground storage tank fund. You <br /> have known that for a long time. We have petitioned the <br /> State Water Resources Control Board for determination of <br /> secondary liability; you have objected to that. We have <br /> advised you that we will not go forward to attempt to <br /> qualify for the underground storage tank fund program <br /> since we are ineligible. We have invited you to take over <br /> the clean-up. It looks that only now, at the last moment, <br /> you are attempting to do so. We applaud that and will <br /> assist you. However, it is very late in the game for you <br /> to be undertaking these actions . <br /> When I met with the representative of your office in <br /> August of last year, I was blithely told that the Knowles <br /> would not respond until they were sued. Even so, we <br /> promptly provided you with a complete copy of all of the <br /> documentation relating to remediation work which we had <br /> undertaken on the property. You have not operated in a <br /> vacuum, as we have repeatedly provided you with <br /> information and will continue to do so. <br /> I must admit, though, that I am not as optimistic as you <br /> are that a meeting will "resolve all the issues between <br /> our respective clients . " Hopefully it will; hopefully <br /> F:\LIT\16735\C\IS0LAI.RMA <br /> 75376-16735/CLT/06/24/94/1 <br />