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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />FT.] <br />• <br />Scott D. Rishwain, Esq., No. 131952 <br />RISHWAIN & RISHWAIN <br />A Professional Corporation <br />2800 West March Lane, Suite 220 <br />Stockton, California 95219 <br />Telephone: (209) 473-2800 <br />Attorneys for Jeffrey Heitman, Court - <br />Appointed Receiver <br />0 <br />SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br />STANDARD INSURANCE COMPANY, ) Case No. 256361 <br />an Oregon corporation ) <br />PETITION FOR AUTHORIZATION <br />Plaintiffs, ) TO ENTER INTO VOLUNTARY <br />CLEANUP AGREEMENT AND <br />vs. ) ORDER THEREON <br />BAY ASSOCIATES, a partnership, <br />et al., <br />Defendant(s). <br />Petitioner alleges: <br />1. Petitioner was appointed Receiver herein by Order of this Court made and entered on <br />May 4, 1993. <br />2. Pursuant to said Order, Petitioner was authorized to take all actions to preserve and <br />maintain the property with the power, among other things, to take all steps to remediate the existence <br />of any hazardous substances or contamination thereon. <br />3. Petitioner has reviewed the Voluntary Cleanup Agreement proposed by the California <br />Environmental Protection Agency, Department of Toxic Substance Control which provides for the . <br />reimbursement of the Department's oversight costs involved in a determination of the nature and <br />general extent of the release of hazardous substances to the soil and groundwater at the property and <br />further provides for a Preliminary Endangerment Assessment. A true and correct copy of the <br />Voluntary Cleanup Agreement is attached hereto as Exhibit "A". <br />