ARCHIVED REPORTS_XR0003135 - Laserfiche WebLink

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1 (1) 280 gallon underground storage tank. 2 Response to Interrogatory No 30 31 3 Objection This Interrogatory is impermissibly compound The Interrogatory is 4 also vague and ambiguous as to the meaning of the term "contents". Subject to and 5 I6 without waiver of the foregoing objections, Douglas responds to this Interrogatory as 7 follows Douglas is informed and believes that regular gasoline, premium gasoline and 8 ethyl gasoline were stored in the gasoline storage tanks on the property Douglas is 9 further informed and believes that waste oil may have been accumulated in the waste oil 10 tank at the property prior to its disposal off-site. 11 Response to Interrogatory No 31 (32)- 12 13 Objection This Interrogatory is vague and ambiguous as to the meaning of the 14 term "reasons" The Interrogatory is also impermissibly compound. C C.P § 2030(c)(5) • 15 Furthermore, the Interrogatory lacks foundation and assumes facts not in evidence. 16 Douglas has no information or belief that any underground storage tank, tank system, 17 pipe or any combination thereof was removed from the property during Douglas' 18 ownership or operation of the property Subject to and without waiver of the foregoing 19 20 objections, Douglas responds to this Interrogatory as follows Not applicable. 21 Response to Interrogatory No 32 (33) 22 Objection This Interrogatory is impermissibly compound C C P. § 2030(c)(5). 23 Furthermore, the Interrogatory lacks foundation and assumes facts not in evidence 24 Douglas has no information or belief that any underground storage tank, tank system, 25 26 pipe or any combination thereof was removed from the property during Douglas' 27 ownership or operation of the property. Subject to and without waiver of the foregoing • 28 objections, Douglas responds to this Interrogatory as follows Not applicable. 16. �..t� a