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ONE KAISER PLAZA, <br /> MILLER <br /> SUITE 1600, <br /> STARR& OAKLAND, <br /> REGALIACALIFORNIA 94612 R Irn �° ^ WALNUT CREEK OFFICE <br /> A PROFESSIONAL FACSIMILE (510) 465-1202 hcC .41,E (510)933-4126 <br /> LAW CORPORATION TELEPHONE (510) 465-3800 TELEPHONE (510)935-9400 <br /> LAURENCE W. PARADIS <br /> March 2, 1994 <br /> Michael Collins <br /> Public Health Services' <br /> San Joaquin County <br /> P. O. Box 2009 <br /> Stockton, California 95201 <br /> Re: 595 E. Eleventh Street <br /> Tracy, CA 95376 <br /> Your Site Code: 1933 <br /> Dear Mr. Collins: <br /> Enclosed please find the report for the second <br /> quarterly ground water sampling event which took place on January <br /> 4, 1994 at the above-referenced property. <br /> .As we discussed on February 28, 1994, the current j <br /> owners of the property, Jack Vaughn, Sharon Vaughn, and Darlene E <br /> Christensen as trustee of the Christensen Family Trust, are <br /> unable financially to install additional wells at this time to <br /> further define the extent of the contamination. We are currently <br /> in litigation with the prior owners to obtain their participation <br /> in the cost of investigating and remediating the contamination. <br /> Your office recently added one of the prior owners, Elroy Cox, as <br /> a responsible party. We have a trial date _of May, 1994 ,in the <br /> United States District Court for the Eastern District of <br /> California and -hope that that trial will resolve the situation <br /> which currently prevents us from undertaking the additional" <br /> investigation that your office has requested.' <br /> We are also in the process of completing the <br /> application for funding from SB2004. If we obtain some funding <br /> from the underground storage tank cleanup fund, we can then <br /> develop and implement a work plan for additional monitoring. <br /> ' You should know that the other defendant in the suit, <br /> aside from Elroy Cox, is Emily Cox, the widow of Elroy Coxes' <br /> brother Claude. Emily Cox has stipulated that she succeeded to <br /> Claude Coxes' liability as a prior owner of the property. <br />