SITE INFORMATION AND CORRESPONDENCE_FILE 1

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Law Offices of Patrick D. Riddle ENV; POMMENTAI HEALTH Patrick D. Riddle 7574 Shoreline Drive David R. Isola 93 SEP 14 PM 2W2on, California 95219 Attorneys at Law Telep one: (209) 952-6262 Fax: (209) 952-2331 September 10, 1993 Ms. Laurie Casias Underground Storage Tank Program CALIFORNIA STATE WATER RESOURCES CONTROL BOARD P.O. Box 944212 Sacramento, CA 94244-2120 RE: Petition for Review by State Board Roek Brothers/102 S. Wilson Way, Stockton San Joaquin County Site No. 9031 Our Clients: Knowles Dear Ms. Casias: This office represents the Knowles family ("Knowles") with respect to their status as "Responsible Parties" concerning alleged petroleum contamination located at 102 South Wilson Way, Stockton, California, ("site") . This correspondence is in response to the Petition for Review submitted by counsel for Roek Brothers on September 3 , 1993. By way of background, the Knowles owned and operated a gasoline service station at the site for a period of approximately 30 years. On or about August 5, 1977, the Knowles sold all of their interest in the property to Pepsi-Cola Bottling Company of Stockton, Inc. , ("Pepsi") which in-turn allegedly obtained the permits to remove the underground storage tanks approximately one year after having purchased the site. For some inexplicable reason, the permits were erroneously issued in the Knowles' name instead of in the rightful owner's name, which was Pepsi. Pepsi's successor-in-interest at the site, Roek Brothers, was allegedly in the process of selling a portion of the site when contamination was discovered. On more than one occasion Roek Brothers has requested that Knowles and Pepsi participate in investigative and remedial activities at the site. These requests ultimately culminated in Knowles and Pepsi being named as "Additional Responsible Parties" by the San Joaquin County Department of Health's Environmental Health Division. There have been discussions over the past few months between counsel for Roek and our office, and a meeting was in fact held between counsel for Roek and our office on August 18, 1993 .