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1 June 1, 1968, Douglas held a leasehold interest in the property. Teachers Insurance and 2Annuity Association transferred ownership of the property to Douglas by Grant Deed 3 dated June 1, 1968. Douglas transferred its ownership interest in the property to Texaco 4 5 Inc. by Corporation Grant Deed.dated September 13, 1971 6 Response to Interrogatory No. 18. 7 Objection This Interrogatory is vague and ambiguous as to the meaning of the 8 terms "control' and "gasoline/service station" Subject to and without waiver of the 9 foregoing objections, Douglas responds to this Interrogatory as follows Douglas does 10 not have facts sufficient to respond to this Interrogatory at this time. Investigation and 11 discovery are continuing 12 13 Response to Interrogatory No 19: 14 Objection. This Interrogatory is vague and ambiguous as to the meaning of the 15 term "gasoline/service station". Subject to and without waiver of the foregoing lfi objections, Douglas responds to this Interrogatory as follows Tokay Oil Company, 17 business address and telephone number unknown; William J Tate, business address and 18 19 telephone number unknown, Richard A. Earl, business address and telephone number 20 unknown; and, Harley H. Ehresman, business address and telephone number unknown 2.1 RK§ on to Interro raj o. 22 Objection. This Interrogatory is impermissibly compound C C.P. § 2030(c)(5) 23 Subject to and without waiver of the foregoing objections, Douglas responds to this 24 Interrogatory as follows. Douglas believes that the following persons may have 25 26 knowledge regarding the installation of any underground storage tank, tank system, 27 pipe or any combination thereof on the subject property during the time period Douglas . 28 held an interest in the property: (1) representatives of the City of Lodi; (2) 10. � � ";