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STARSKY & KIRK LLP <br /> ATTOP14M AT LAW <br /> SUITE 264 <br /> 601 tYNIVE SM AVENUE <br /> SACRAIMM. CALIFORNIA 95925-6720 <br /> THLEPHON$ (916) 567-39W <br /> TELECOP1T;it (916) %7-3%7 <br /> March 30, 1999 <br /> VIA TELECOPIER 249146$-03141 AND U.S. MAIL <br /> David J. Irey, Esq. <br /> Deputy District Attorney <br /> Environmental Prosecutions Unit " <br /> Office of the District Attorney <br /> San Joaquin County Courthouse <br /> P.O. Box 990 <br /> Stockton, CA 95201 <br /> Re: Unocal- Stockton Service Stations <br /> Dear Mr. Irey: <br /> This is to follow up our telephone conversation of March 24, 1999, wherein we <br /> continued our discussion of the agreement "in principle" reached by San Joaquin County and . <br /> Union Oil Company of California on February 17, 1999. During our conversation, you repeated <br /> your request that as a condition of the settlement, Union Oil withdraw its petition for closure of <br /> the .1665 Pacific Avenue site that is currently before the State Waxer Resources Control Board. <br /> You also asked that I convey your request concerning the petition to Mr. Nierniec again. <br /> Union Oil continues to believe that it has a right to seek a State Board Wiling on <br /> its petition. It also believes that your insistence that it relinquish that right is unreasonable and <br /> inappropriate for the reasons previously stated. We are disappointed to.have gotten this close to <br /> settlement to have it now appear that the parties' efforts may have been wasted. <br /> Nevertheless, we are hopeful that you will reconsider your request and that the <br /> parties can settle these matters on the terms and conditions outlined in my February 17, 1999 <br /> letter: Whatever the State Board's decision, Union Oil will abide by it. If the State Board orders <br /> the site closed, no further action will be required and any violations alleged to have occurred <br /> before closure of the site will be resolved by the settlement. If the State Board does not issue an <br /> order closing the site, Union Oil will continue to perform appropriate corrective action at the site. <br /> EXHIBIT 12 <br />