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THEODORE K. MARTIN <br /> ATTORNEY AT LAW NOV 3 0 1992 <br /> 333 EAST FOOTHILL BOULEVARD <br /> ARCA DIA, CALIFORNIA 2510 ENVIRONMENTAL HEALTH <br /> TELEPHONE (818) 357-5297-52911 <br /> FAX (818) 357-3754 <br /> November 25, 1992 C ��f 17 1�• Nr\11^ 1 <br /> G. S. Garrison, Esquire <br /> P. O. Box 280 <br /> Half Moon Bay, CA 94019 <br /> Re: Your Clients: John Marci and Robert Marci <br /> Our Clients: John L. Ruan and Jim A. Stafford <br /> Property: 2959 Loomis Road, Stockton, California <br /> Subject: Proposed meeting of December 4, 1992 <br /> Dear Mr. Garrison: <br /> Your letter to me dated November 19 arrived at my office on <br /> November 24 . I became aware of its purpose on November 20 as a <br /> result of returning your telephone call and talking with your <br /> secretary. <br /> I am unaware of any statutory or regulatory provision for your <br /> suggested meeting. It does not appear that is a "county meeting" <br /> as indicated in your letter. On the other hand, this seems to be <br /> an attempt on your part of obtain some voluntary commitment for <br /> participation by my clients in defraying the expense your clients <br /> have been incurring in connection with the alleged leakage from the <br /> underground storage tank (or tanks) at the property referred to <br /> above, or, in other words, what would amount to a settlement <br /> between these allegedly responsible parties as to the nature and <br /> extent of their respective responsibilities here. <br /> Although something along the lines of such a settlement effort <br /> might well become appropriate, the time for that has not as yet <br /> arrived. We simply do not have sufficient information even to <br /> discuss the matter of the allocation of responsibility. It would <br /> be necessary for us to receive in advance copies of the essentially <br /> the entire record on the matter, and most particularly all reports <br /> of tests and analyses concerning the problem, and documentary <br /> support concerning the expenditures already made. If there has <br /> been any analysis or even a rough estimate concerning what would <br /> be required by way of a clean-up, as well as to the matter of any <br /> potential liability for the effects of any contamination, we would <br /> need that information as well. I asked for this some time ago, and <br /> never received anything. <br /> You state in your letter that the Public Health Service records <br /> will be made available at the meeting. I expect that your clients <br />