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JOHN Office of the District Attorney <br /> PHILLIPS San Joaquin County Courthouse,Rm.202 <br /> DISTRICT ATTORNEY 222 E Weber Ave.Stockton, California 95202 <br /> P.O.Box 990,Stockton, California 95201 <br /> San Joaquin County Telephone:(209)468-2400 <br /> February 5, 1992 <br /> Stephen T. Holzer <br /> Parker, Milliken et al. <br /> 333 South Hope Street, 27th Floor <br /> Los Angeles, CA 90071-1488 <br /> Re: People V. Rainbow Baking Company and Merico Inc <br /> San Joaquin County Superior Court No. 231328 <br /> Dear Mr. Holzer: <br /> I was quite disturbed to learn from Fish and Game Warden Dennis <br /> De Anda the following: <br /> 1) No reports have been received from Groundwater Technology, <br /> further, <br /> 2) An inspection of the site indicated no work has been done, <br /> the soil still has oil contamination and the cistern still <br /> contains solids, <br /> 3) There was a "blow out" of the temporary containment of the <br /> drainage ditch. <br /> As I informed on June 20, Warden De Anda approved the work plan <br /> in June, yet, nothing has been done since then. Critical to our <br /> agreement was that clean up be completed before the fall of 1991 <br /> and its rainfall. <br /> Our offer to settle is withdrawn. If clean up is not completed <br /> within 30 days, we will file a motion for preliminary injunction <br /> and file the At Issue Memorandum requesting that a trial date be <br /> set. <br /> Sincerely, <br /> OFFI E OF THE DISTRICT ATTORNEY <br /> (4AF BROWNty District Attorney <br /> E ronmental Prosecutions Unit <br /> LFB/ew <br />