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WILLIAM B. LOOK,JR. RECEIVE <br /> : ATTORNEY AT LAW OCT 1 5 19Qn <br /> CASA FUENTE BUILDING <br /> 448 PACIFIC STREET ENVIRONMENTAL HEALTH <br /> MONTEREY,CA 93940 <br /> (408)an-1371 PERMIT/SERVICES <br /> FAX:(4W)372.5718 <br /> October 10, 1990 <br /> Laurie A. Cotulla, REHS <br /> Environmental Health Division <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 95240 <br /> Site Code: 1324 <br /> Dear Ms . Cotulla: <br /> My client has forwarded a copy of your October 1, 1990 let- <br /> ter, which relates a demand for production of a "work plan" to <br /> investigate the extent of soil and ground water contamination. <br /> You demand that this plan be produced within 14 days, and you <br /> indicate that my clients are "an additional responsible party of <br /> a contaminated underground tank site. " <br /> Contrary to your letter, and as I advised you in previous <br /> correspondence, or as your file should reflect as a result of my <br /> previous correspondence, my clients sold their entire interest in <br /> the subject property in August of 1989 to Mr. Saleem Kahn. My <br /> clients lack possession or control of the subject real property <br /> as a result, and has no ability to enter onto the property to <br /> investigate the extent of any residual contamination, and in any <br /> case, 14 days is not sufficient time to come up with a competent <br /> plan to resolve any problems still remaining at the site. Fur- <br /> thermore, Mr. Saleem Kahn is not, and has never been, an agent, <br /> employee or other person subject to the supervision or control of <br /> my clients, and they have no present ability to compel him to <br /> compose such a plan. Accordingly, it is my clients, position <br /> that Mr. Kahn is on his own with regard to the property, and as <br /> the present owner with custody and control of the property and <br /> the ability to obtain 'the necessary scientific or other informa- <br /> tion In order to investigate the site, or prepare the plan you <br /> demanded, he is the party who will have to comply with your cor- <br /> respondence. <br /> At the same time, my clients are willing to be cooperative <br /> with the county, to the extent they are able, in resolving this <br /> problem. But having severed their legal relationship to the <br />