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Patrick D. Riddle Theodore E. Job <br /> Attorneys At Law 7574 Shoreline Drive <br /> Stockton, California 95219 <br /> Telephone: (209) 952-6262 <br /> Fax: (209) 952-2331 <br /> 10 April 1992 <br /> Laurie A. Cotulla, RENS, APR 9 3 '092 <br /> Program Manager <br /> Environmental Health Division ENVIRONMENTAL HEALTH <br /> Public Health Services <br /> San Joaquin County <br /> Post Office Box 2009 <br /> Stockton, CA 95201 <br /> RE: Roark Bros. Construction Property <br /> 102 South Wilson Way, Stockton, CA <br /> Dear Laurie Cotulla: <br /> I have read and reviewed your letter which we received April <br /> 7, 1992 regarding Site Code: 9031 at the above referenced address. <br /> our information indicates that the Knowles are not a properly named <br /> responsible party. <br /> Apparently there is a petroleum problem in the area, extending <br /> to groundwater, which to our knowledge has never been identified as <br /> coming from this site. There are other sites in the area of <br /> previously owned gas stations with aquifers, which if contaminated, <br /> would give a positive reading vis-a-vis the groundwater underneath <br /> this site. The Knowles neither owned the property nor operated the <br /> property at the time that groundwater contamination was discovered <br /> through a routine Phase II study. <br /> To my knowledge, no California law or federal law would find <br /> the Knowles to be a PRP, under these facts. No law holds an owner <br /> of property liable as a PRP where the contamination drifted onto or <br /> under his property from off-site with groundwater. Therefore, we <br /> respectfully, on behalf of the Knowles, object to your notification <br /> to them. The Knowles should pay no fees in connection to this <br /> matter until they are properly named, if they are ever named <br /> properly at all. <br /> If you have any questions regarding this matter, or any facts <br /> which support your naming them as PRPs, do not hesitate to give me <br /> a call. We would be happy to discu this at length by telephone. <br /> Ve y�rs, <br /> Patrick D. Riddle <br /> PDR:mdr <br /> cc: Client <br />