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/ 4 Ron E. Senner August 11, 1994 Page 3 water contamination decreases the likelihood that this site affected the soil and ground water under the subject Site. We are in the process of obtaining additional information regarding this site filed with the governmental bodies involved. In any case, this additional, information weakens the case for the M & M Automotive site being a source of contamination. All parties agree that additional investigation be performed to clarify the extent and source of the subject contamination. Furthermore, it has been shown that Unocal operated a automobile gas station at the site in excess of 40 years. Given these facts, we believe that Unocal must take a more active role in this matter, including without limitation, the required investigation and satisfying, in a timely manner, the requirements of the County Environmental Services. In addition, we request that Unocal share all documentation in its files with regard to the Unocal's operations on the Site and the location and disposition of the underground tanks located on the Site. If you continue to stonewall the issue we believe you `do so in bad faith. Wells Fargo Bank will actively assert its claims against Unocal with regard to the subject contamination. When it is ultimately determined that Unocal was a source of all or a portion of such contamination, we fully expect Unocal to reimburse and/or indemnify Wells Fargo Bank against damages (including punitive damages) andall costs incurred or to be incurred in the investigation and remediation of the subject contamination. We suggest that you may be in a position to mitigate such claims and damages by undertaking a timely response to this problem. Thank you for your attention in this matter. Very truly yours, Arthur S. Barbour ASB:bm cc: Tom Stoflet Ron Hartwell, Esq. I nb .aa3