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Ms. Diane Hinson <br /> Ms . Linda Turkatte <br /> May 18, 1994 <br /> Page 2 <br /> The conclusion reached in your letter places Roek <br /> Bros. in a difficult position. In order to gain approval <br /> of a workplan which is necessary for it to obtain the <br /> information required to pursue its rights under the law <br /> against responsible parties, you would have Roek Bros . <br /> waive its rights to appeal the decision of the local <br /> agency to the State Board. We cannot imagine that this <br /> would be the intention of San Joaquin County. <br /> The information sought to be gathered by the workplan <br /> currently before you is completely unrelated to any <br /> additional workplan for investigation of the on-site <br /> contamination. The two purposes cannot be confused. <br /> You confirm in your letter that the scope of work <br /> proposed by Roek Bros . in the workplan would accomplish <br /> our stated purpose. As such, we respectfully request that <br /> you approve our workplan and issue the corresponding <br /> permits because the purpose of the investigation is to <br /> reassess the direction of the groundwater flow and our <br /> proposed workplan will accomplish this purpose . <br /> Please respond to our request by May 25, 1994 . <br /> Should you have any questions or concerns in the meantime, <br /> please feel free to contact me. <br /> Very truly yours, L <br /> `� /. A — `l� <br /> KARNA E. HARRIGFELD <br /> Attorney-at-Law <br /> KEH:cjm <br /> cc : Ms . Beth Thayer, Esq. <br /> Ms . Lori Casias <br /> Mr. Donald Roek <br /> Mr. John Donlon <br /> Mr. Gerry Nakano <br /> F:\TRN\16735\C\ROEK9.KEH <br /> 75376-16735/cjm/OS/18/94/1 <br />