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1 discussions to take place. On June 27., 1934, plaintiff's counsel <br /> 2 forwarded to defendants' counsel copies of the analytical results <br /> :for soil and.. groundwater samples collected from the Site:.. <br /> 4 <br /> Fur . ;FDIC * consultant continues its invest .gation. of the <br /> 5 soil and groundwater contamination at the site, 'and is in the <br /> b <br /> process of preparing a :further Envronm+ ntal Assessment Re <br /> port <br /> .7 for the bite. <br /> 8 On July 260 1394, plaintiff-s counsel sent. counsel ;for each <br /> 9 defendant :a letter in which plaintiff's counsel. proposes that a <br /> 10 meeting of all counsel. be arranged to further discuss tie issues <br /> 11 ihthibcase. and the possibility of early settlement:, A`s of the <br /> 12 filing Q.. this Status Conference Report, only counsel for <br /> 11 defendant Douglas has responded to this 1ett+er.. <br /> 14 :In this regard, since it is likelyi the San Joaquin County <br /> 15 Environmental. Health Division and/or the Regional Water Quality <br /> 16 Control Board will requre: addtional investigation of the <br /> 17 groundwater contamination at the Site, and may require <br /> 18 groundwater remediation by the; former and present owners and <br /> 19 operators at the Site and/or neighboring site(s) , plaintiff <br /> 20 reiterates its proposal: made in plaintiff's .Apri2 17 1994 Status <br /> 21 Conference Report that the parties consider a cost-sharing <br /> 2:2 arrangement for the costs related to the investigation of the: <br /> 23 scope; aind extent of soil. and groundwater contamination, and,.. <br /> 24 necessary, costs: of remediation at the site. <br /> 25 2; pr9 oD sed. DAt <br /> 2 + In light of the fore o'in FDIC ` <br /> 4 9 g� propcse;s the fc�llowgng <br /> 2?` Discovery Cut-Off: March ij 1994 <br /> 28 Expert this. Cut-Off: April 30, 199.4 <br /> -6- <br /> . <br />