SITE INFORMATION AND CORRESPONDENCE

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i 1 Matthew 0. Pacher, State Bar No. 109378 Kathy L. Monday, State Bar No. 209084 2 DAMRELL,NELSON, SCHRIMP, PALLIOS,PACHER& SILVA 3 16011 Street, Fifth Floor Modesto, CA 95354 4 Telephone: (209) 526-3500 Facsimile: (209) 526-3534 5 Attorneys for Petitioner 6 7 STATE WATER RESOURCES CONTROL BOARD 8 9 DECLARATION OF KATHY L. MONDAY IN SUPPORT OF PETITION FOR REVIEW OF 10 DECISION OF LOCAL AGENCY, SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT AND REQUEST FOR STAY 11 12 I, Kathy L. Monday, declare: 13 1. I am an attorney at law duly licensed to practice before all the courts of the 14 State of California and am an associate with the law firm of Damrell,Nelson, Schrimp,Pallios, 15 Pacher & Silva, attorneys of record for Petitioner Mabel Keir. 16 2. On January 21, 2003, I contacted by telephone Mr. Bill Snyder,whom there is 17 no dispute is one of the previous partners of Turnpike Associates who sold the property to the 18 Keirs on April 16, 1986. I explained to Mr. Snyder that Ms. Keir had received a notice of 19 responsibility with regard to the property located at 1601 Turnpike, Stockton, California 20 (hereinafter the"Property"). I asked Mr. Snyder if he had likewise received a notice of 21 responsibility. Mr. Snyder said that he had not. I then asked Mr. Snyder if the underground 22 storage tank (UST)was empty at the time he sold the Property to the Keirs. Mr. Snyder replied, 23 "yes" 24 3. On January 26, 2004, I sent a letter to Victoria L. McCartney of the San 25 Joaquin County Environmental Health Department(SJCEHD) explaining the facts with regard to 26 the Keir's involvement with the Property and that Mr. Snyder had confirmed to me that the UST 27 was empty at the time the Property was purchased by the Keir's. (Attached hereto as Exhibit"A" 28 is a copy of said correspondence.) Ms. McCartney subsequently responded to my DAMRELL,NELSON SCHRIMP,PALLIOS PACHER&SILVA A Professional Corporation 1