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r <br /> JOHN Office of the District Attorney <br /> PHII.IIIPS San Joaquin County Courthouse, Rm. 202 <br /> 222 E Weber Ave.Stockton, California 95202 <br /> DISTRICT ATTORNEY P.O.Box 990,Stockton. California 95201 <br /> San Joaquin County Telephone:(209)468-2400 <br /> January 31, 1991 <br /> FED1 kms„ <br /> �J11•,1���,'�l r � <br /> Frank Enright MfT� Ll f pt TH <br /> Diehl, Steinheimer, et al . <br /> P. O. Box 201072 <br /> Stockton, CA 95201-3022 <br /> Re: People v. Joe Bryson, Sr. <br /> Dear Mr. Enright: <br /> Regarding the civil case and the underground tanks, I made the <br /> generous offer of settling for $250 . 00 based upon facts you <br /> presented i . e. the tanks had not been moved only uncovered so <br /> that a contractor could give Mr. Bryson an estimate on removal. <br /> Upon discussing this with the Health Department, I was told the <br /> following: <br /> 1) when first discovered, the tanks were uprooted and in a <br /> vertical position. By the time photos were taken they had <br /> been replaced in a horizontal position. <br /> 2) Contractors do not require tanks to be uncovered because <br /> size of the tank does not affect removal costs . None of the <br /> cbntractors Health has dealt with have required owners to do <br /> this. <br /> 3 ) Bryson admitted rinsing out the tanks and washing the <br /> rinseate down the drain (hazardous waste disposal) . <br /> I am willing to stand by the previous offer, but in light of the <br /> above, only for a short period of time. The Stipulation must be <br /> signed and returned and the closure plan approved and fees paid <br /> by February 15 or the offer will be revoked. <br /> We interviewed Ned Kubitz regarding the 13 drums left on the <br /> property. He admitted purchasing the 8 drums of adhesive product <br /> in 1988 when he was trying to put together a deal with Imperial <br /> Marking. However, Imperial never went for the deal so he just <br /> became a salesman for them. The 5 drums of waste he thinks are <br /> from his previous business pre 1987 , the assets of which were <br /> given to Bryson during the 1987 bankruptcy proceedings in lieu of <br />