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STARSKY & KIRK, LLP <br /> David I Irey,Esq. <br /> Deputy District Attorney <br /> Environmental Prosecutions Unit <br /> Office of the District Attorney <br /> San Joaquin County Courthouse <br /> March 2, 1999 <br /> Page 2 <br /> referral of the site to your office for enforcement, coming as it did so shortly after the filing of <br /> Unocal's petition,has always been troublesome to Unocal. <br /> This will also confirm that I told you that the workshop on the application, <br /> scheduled for Wednesday, March 3, 1999, has been postponed and that Unocal submitted a. <br /> report on the work performed pursuant to a work plan agreed upon by Unocal and PHS/EHD via <br /> overnight delivery on Friday, February 26, 1999. We believe that the data contained in this <br /> recent report also supports UnocOs position that the site should be closed. <br /> It was, and is, Unocal's understanding that the proposed settlement will resolve all <br /> enforcement matters to the date of the settlement,and if the State Board closes the site, no fin-ther <br /> action will be required and any violations alleged to have occurred prior to the site's closing will <br /> be resolved by the settlement. If the site is not closed, Unocal will continue appropriate <br /> corrective action. <br /> This will also cow that it is our understanding that the proposed settlement is <br /> still viable, that you would like some time to think about your request that the petition for site <br /> closure be withdrawn,and that you will get back to me shortly. <br /> I look forward to hearing from you. <br /> Very truly yours, <br /> Sherri M. Kirk <br /> of STARSKY&IC K, LLP <br /> SMK/nm <br /> cc: Peter J. Niemiec,Esq. (via telecopier) <br />