Opening Statement

1. Opening Statement Harz, et al. v. California Capital Insurance Company

2. U.S. Post Office San Roque Station From State Street

3. The Site

4. U.S. Post Office and One Hour Martinizing Locations From State Street

5. Dutch Maid Cleaners, Facing Toward the Front, the Alley Is On the Opposite Side

6. The Site

7. U.S. Post Office Location, Rear Parking Lot

8. Alley Between U.S. Post Office and Dutch Maid Cleaners, Looking Toward State Street

9. Standard Pollution Exclusion With an Exception for Sudden and Accidental Events “This insurance does not apply: . . . (f) to bodily injury or property damage arising out of the discharge, dispersal, release or escape of smoke, vapors, soot, fumes, acids, alkalis, toxic chemicals, liquids or gases, waste materials or other irritants, contaminants or pollutants into or upon land, the atmosphere or any water course or body of water; but this exclusion does not apply if such discharge, dispersal, release or escape is sudden and accidental.” (Emphasis added.)

13. Concentration of PCE in Groundwater – Nov. 1999

33. Q. And so you estimate that, three to four time, to the best of your recollection, between ’78 and ’82, that you lost al perc that was in the holding tanks due to a boot failure, correct? A. Correct. -- Zell Testimony 128:2-5, 5/1/97

45. The Site

46. Claims Against the Harz Family – Same or Less Than in Richard Cross-Complaint

47. Allegations of How the Harz Family Caused Contamination – Same or Less Than in Richard Cross-Complaint