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1 representatives of John Howard Contractors, business address and telephone number <br /> 2 unknown <br /> 3 Res onse to Interrogatory No 20 21 <br /> 4 <br /> Objection This Interrogatory is impermissibly compound C.0 P § 2030(c)(5) <br /> 5 <br /> 6 Subject to and without waiver of the foregoing objections, Douglas responds to this <br /> 7 Interrogatory as follows Douglas believes that the following persons may have <br /> 8 knowledge regarding the dates of the installation of any underground storage tank, tank <br /> 9 system, pipe or any combination thereof on the subject property during the time period <br /> 10 Douglas held an interest in the property (1) representatives of the City of Lodi, (2) <br /> 11 <br /> representatives of John Howard Contractors, business address and telephone number <br /> 12 <br /> 13 unknown <br /> 14 Response to Interrogatory No 21 (2Z): <br /> 15 Objection This Interrogatory is vague and ambiguous as to the meaning of the <br /> • 16 <br /> phrase "actual location". The Interrogatory is also impermissibly compound C C.P. <br /> 17 <br /> § 2030(c)(5). Subject to and without waiver of the foregoing objections, Douglas <br /> 18 <br /> responds to this Interrogatory as follows The Site Plan produced by TRMI in discovery <br /> 19 <br /> 20 in this action as document with Bate Stamp No 000448 depicts the "actual location" of <br /> 21 the underground storage tanks on the subject property Douglas believes that all <br /> 22 persons and parties to whom this document has been produced may have knowledge <br /> 23 regarding the "actual location" of any underground storage tank, tank system, pipe, or <br /> 24 <br /> any combination thereof on the subject property during the time period Douglas held an <br /> 25 <br /> interest in the property including, but not limited to, representatives of City Thrift and <br /> 26 <br /> 27 Loan Association, 8345 Hayvenhurst, P O Box 2197, Sepulveda, CA 91343, and <br /> 28 representatives of Texaco Refining and Marketing Inc , 10 Universal City Plaza, <br /> 11 �P"�� <br />