SITE INFORMATION AND CORRESPONDENCE_FILE 1

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Ms. Laurie Casias Page 2 September 10 , 1993 Consequently, Roek's counsel's statement that "Thus far, NONE of the parties responsible for the contamination have made an effort to cooperated [sic] with us, " is not entirely accurate. During our meeting on August 18, 1993 , we requested that the Knowles be provided with all technically-oriented documents which have been generated to date by Roek's consultants, as well as copies of all correspondence between Roek and the San Joaquin County authorities. The Knowles' stated goal for obtaining these documents was to determine whether it would be fruitful to work with San Joaquin County authorities for purposes of re-defining the contemplated groundwater investigation. The requested documents were received by our office on August 28, 1993 , and were thereafter forwarded on September 8, 1993 to a consultant retained by the Knowles for purposes of evaluating this matter. Once the Knowles' consultant has had an opportunity to review the documents and report his findings, it is anticipated that discussions will ensue with local authorities and Roek's counsel. In light of the foregoing, the Knowles concur with two of the requests in the Roek's Petition, and take issue with two others. Specifically, based upon the preliminary data which we have reviewed and based upon our current knowledge of the situation at the site, the Knowles would agree that "Adjacent Landowners" should be named as additional responsible parties, especially where the nature of the contamination and the hydrogeologic characteristics of the area suggest that problems with the groundwater in the area appear to be originating from an adjacent parcel, namely, 101 S. Wilson Way. The Knowles also concur with Roek Brothers' request that the implementation of a work plan be authorized to investigate and confirm the relationship between the soil and groundwater contamination, and upon appropriate findings, that San Joaquin County authorities abandon requests for a groundwater investigation. The Knowles take issue with Roek's request that the State Board declare Roek to be secondarily liable for remediating contamination. Just as there is allegedly currently no direct evidence linking Roek with the contamination, there is similarly no direct evidence establishing the presence of contamination at the site during the Knowles' ownership. For this reason, there would not appear to be any basis for apportioning responsibility among