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I JOHN KAPPOS <br /> Attorney at Law <br /> 2 333 N. San Joaquin REUIVEU <br /> Stockton, CA 95202 <br /> 3 (209) 466-9051 MAR 9 1993 <br /> 4 Attorney for Plaintiffs ENVIRONMENTAL HEALTH����I-�-����,�i�� <br /> 5 <br /> 6 <br /> 7 <br /> 8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN <br /> 9 <br /> 10 JOHN C. SHAUGHNESSY, etc. , ) No . 236587 <br /> 11 Plaintiffs , ) STIPULATION THAT SHAUGHNESSY <br /> WILL BE NOTIFIED OF PULLING OF <br /> 12 Vs . ) GAS TANKS AND ALLOWED TO HAVE <br /> HIS EXPERT PHOTOGRAPH <br /> 13 PETER GIAMBANCO, et al. , ) AND TEST SAME <br /> 14 Defendants . ) <br /> ) <br /> 15 <br /> 16 IT IS HEREBY STIPULATED AND AGREED by and between plaintiff <br /> 17 and defendant in the above matter, through their respective <br /> 13 counsel, as follows : <br /> 19 1) That should Mr. Giambanco cause the three gas tanks , or <br /> 20 any of them, located at Gal E. Miner Avenue, Stockton , to be re- <br /> 21 moved from the ground, Mr. Shaughnessy or his counsel will <br /> 22 receive advance notice of the date of such removal. <br /> 23 2 ) Mr. Shaughnessy and his designated expert or experts , <br /> 24 will be allowed entry onto the premises at the time of such re- <br /> 25 moval. <br /> 26 3 ) Mr. Shaughnessy ' s experts will be allowed to photograph <br /> 27 and make such other tests upon the tanks , or any of them, as he <br /> 28 deems appropriate, so long as any holes that may exist in the <br /> - I - <br />