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101 S. Hanley, Suite 1280 <br /> Borgmann, Traeger & Wilson, L.L.C. St. Louis,Missouri 63105 <br /> Attomeys At Law 314-725-5955 (Telephone) <br /> 314-725-0559 (Telefax) <br /> August 27, 1998 <br /> VIA OVERNIGHT MAIL <br /> Mr. Michael J. Inform Jr., Senior REHS <br /> San Joaquin County Environmental Health Division <br /> LOP/Site Mitigation Unit IV <br /> 304 East Weber Avenue, Third Floor <br /> Stockton, CA 95202 <br /> Re: Center Street Parts/Former Kilpatrick's Bakery <br /> 1717 S. Center St. <br /> Stockton, CA 95206 <br /> Dear Mr. Infurna: <br /> I am responding to your June 19, 1998 letter to Mr. Jerry Gregerson, the current <br /> owner of the property located at 1717 S. Center St., Stockton, CA (the "Property") and <br /> Ms. Theresa Lanctot at The Earthgrains Company("Earthgrains"). Your letter requests a <br /> workplan that proposes the installation of at least three (3) monitoring wells to determine <br /> the extent of lateral and vertical contamination at the Property. PHS-EHD has also <br /> requested clarification on the last"operator" of the underground storage tank ("UST") <br /> previously located at the Property for the purposes of determining responsible parties. <br /> You have been copied on previous correspondence from this Firm to Mr. <br /> Gregerson regarding his responsibilities relating to the environmental condition of the <br /> Property. Most recently, The Earthgrains Company contracted with Philip <br /> Environmental to perform further site characterization at the Property and Philip's report <br /> dated June 2, 1998,Preliminary Subsurface Site Investigation Results and Product <br /> Piping Abandonment Completion, was submitted to the San Joaquin County Public health <br /> Services, Environmental Health Division(PHS-EHD). Mr. Gregerson has chosen not to <br /> participate in any of this environmental work requested by PHS-EHD despite his current <br /> status as the owner of the Property and contractual obligations with Earthgrains, <br /> previously Campbell-Taggart Baking Companies, Inc. ("Campbell-Taggart"). These <br /> contractual obligations are derived from a Release Agreement executed by Mr. Gregerson <br /> as President of 1717 South Center Street Properties, Inc. and Gregerson&Associates <br /> ("Guarantor") and transmitted to Campbell-Taggart's outside legal counsel on February <br /> 22, 1995. Mr. Gregerson advised Campbell-Taggart in 1995 that 1717 South Center <br /> Street Properties, Inc. was removed from the title in 1995. <br /> In regards to the historical ownership of the Property, Kilpatrick's Bakeries, Inc. <br /> ("Kilpatrick's sold the Property to Mr. Frank Woodard in January 1988 "As Is", who then <br /> directed ownership of the Property to vest in William Whitman. Upon Whitman's death, <br /> Mr. Whitman's Estate transferred the Property to 1717 South Center Street Properties, <br />