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WILLIAM B. LOOK, JR. <br /> ATTORNEY AT LAW <br /> CASA FUENTE BUILDING <br /> 418 PACIFIC STREET <br /> MONTEREY,CA 93940 <br /> µ0B)372-1371 <br /> FAX!(40B)372-5779 <br /> November 17 , 1990 <br /> Laurie A. Cotulla, REHS <br /> Public Health Services <br /> San Joaquin County <br /> Post Office Box 2009 <br /> Stockton, CA 95201 <br /> Re: 521 North Cherokee Lane <br /> Lodi, CA 952410 <br /> Site Code: 1324 <br /> Dear Ms . Cotulla: <br /> I received a copy of your November 8, 1990 letter on November <br /> 15, 1990 . Please do not contact my clients directly again. They <br /> find your letters extremely upsetting. Since you are well aware <br /> that. I represent them, I see no reason to persist in direct con- <br /> tacts with these elderly and infirm individuals, other than to <br /> try to intimidate and opress them. <br /> In response to your letter, it is completely false to claim <br /> "only one other RP has been identified. " In previous correspon- <br /> dence I provided you with the names of the oil companies who were <br /> responsible for spilling gasoline at the above site. (Lerner Oil <br /> Company, Inc . , La Mesa Energy Corporation and Jardine Petroleum <br /> Corporation. ) Get your facts straight . As I have already warned <br /> you, the county' s approach of harassing my clients is unreason- <br /> able, and a violation of their civil rights . <br /> Specifically, the present owner, Saleem Khan is solvent, has <br /> control of the property, and there is no impediment to enforce- <br /> ment against him. You are also aware that he provided my clients <br /> with an indemnity agreement, and is therefor legally responsible <br /> for all clean-up costs without contribution from my clients . On <br /> the other. hand, Kahn is not an agent or employee of my clients, <br /> they do not have any access to the property, and therefor do not <br /> have control over him nor any means for responding directly to <br /> your demands to clean up the site. For these reasons you must <br /> proceed first against Mr . Khan. <br /> Yours truly, <br /> Will Look, Jr. <br /> WBL:del. <br /> 252 . 2/COTULA2 .LTR <br />