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" WILLIAM B. LOOK, .JR. '"00' <br /> 200 Camino Aguajito,Suite 200 Y <br /> ATTORNEY AT LAW Monterey: V 372-1371 <br /> Monterey,California 93940 1A L HEA(_T11Salinas: 424-7073 <br /> -"h VICE Hollister. 636-2920 <br /> 93 AUSPpb 2: 22 <br /> , FAX: 372-5779 <br /> b <br /> August 12, 1993 <br /> Donna Heran <br /> REHS, Program Manager <br /> Environmental Health Division <br /> Public Health Services <br /> San Joaquin County <br /> P.O. Box 2009 <br /> Stockton, CA 95201 <br /> RE: Site 1324, 521 North Cherokee Lane, Lodi California <br /> Dear Ms . Heran: <br /> I am responding to your letter dated July 30, 1993, in which <br /> you make a number of demands on my clients with regard to the <br /> cleanup of the above site, including a demand for a work plan for <br /> free product removal from the ground water, and a work plan for <br /> investigation of the full extent of soil and ground water <br /> contamination by August 23, 1993 . Your letter also makes a demand <br /> for quarterly reports pursuant to UST regulations . <br /> In a nut shell, my clients response must be, that they do not <br /> have the resources to respond to your demands . They are elderly, <br /> ill, and are subsisting on Social Security income. They are former <br /> owner of the subject site and do not have a right of possession. <br /> Therefore they cannot lawfully enter to carry out any of the tasks <br /> identified in your letter. <br /> I believe the more appropriate party to address your short <br /> term demands is Mohammad Jameel, who is the present title holder <br /> and in possession of the premises . <br /> As an additional issue, as I have commented several times <br /> before, my clients were the lessors of the subject property, which <br /> was operated as a gasoline station, while they owned the property. <br /> The former lessees of the property, several oil companies, are also <br /> responsible parties in this matter, even though your agency and the <br /> State of California, have consistently resisted my effort to have <br /> them named in this action as well . <br /> There is pending litigation in San Joaquin County, Superior <br /> Court Case No: 281859 and 229593 consolidated into Superior Court <br /> Case Number 218859 which concern my clients claims for <br />