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Mf <br /> LAW OFFICES OF fl 1 <br /> MEHLHAFF & HAY <br /> Robert Mehlhaff 23950 South Chrisman Road, Suite A Tel: (209) 835-3232 <br /> Dennis L. Hay P.O. Box 1129 it Fax: (209) 835-4792 <br /> Tracy, California 95378-11 1 29 <br /> June 19, 2002 <br /> JUN 2 4 2002 <br /> ENVIRONMENT HEALTH <br /> Brian Millman, Staff Geologist <br /> PERMIT/SERVICES <br /> Advanced GeoEnvironmental, Inc. <br /> 837 Shaw'Road. <br /> Stockton, California 95215 <br /> Re: San Joaquin Valley Hay Growers Association and Strong Property <br /> Investigation <br /> Itl <br /> Dear Mr. Millman: <br /> This office is legal counsel for the San Joaquin Valley <br /> y ay,�Growers Association <br /> and we have been asked to involve ourselves in the above-rederenced matter, especially <br /> as to the issue of access onto our client's property and the imputed liability and listing of <br /> our client's property as being contaminated should our client refuge to allow access by <br /> Your company onto their property for purposes of exploration. <br /> It is my understanding that a leak and ground water:'contamination was detected <br /> on the Strong property which is directly adjacent to our cli6nt's property and that wells <br /> were installed and have been monitored for quite a period of time. The data collected <br /> L from the test wells on the Strong property not only confirms the existence of groundwater <br /> contamination-but-that the.direction of the.-plume..is-in-the direction of our client's <br /> property. It is further my understanding that this is what prompted the Strongs, your <br /> company and the Department of Environmental Health to contacCour client and after <br /> some discussions with our client's general manager the aforementioned threats were <br /> made. If, in fact, the plume is flowing in the direction of our client's property, it is our <br /> position that any contamination of groundwater by the same would be a trespass and a <br /> nuisance resulting in damage to our client that could be reco'vered4n a lawsuit. <br /> Although it is our considered opinion that no imputed liability or assumption of <br /> clean up costs results from our client's refusal to grant your",company or anyone else carte <br /> blanche to perform exploratory investigations on our client's property, our client would <br /> be willing to allow access to your company to install test wells onl4ts property, provided: <br /> 1) Ms. Strong would be responsible for any and all costs associated with <br /> i. <br /> such investigations. <br /> Ji <br />