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c � <br /> - 0 OCT 0 5 1554 <br /> HO KINS RECEIVED O. &6- <br /> 150 ALMADEN BOULEVARD TELEPHONE:(408)286-9800 <br /> FIFTEENTH FLOOR C E TT FACSIMILE:(408)998-4790 <br /> SAN JOSE,CALIFORNIA 95113-2089 1 EASYLINK:62985279 <br /> A LAW CORPORATION <br /> October 4, 1994 <br /> OCT 2 5 1994 <br /> Via Federal Express I ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Patrick D. Riddle, Esq. <br /> Law Offices of Patrick D. Riddle <br /> 7574 Shoreline Drive <br /> Stockton, CA 95219 <br /> Re: Lincoln Properties, Ltd v. Higgins, et aL <br /> Case No, CIV-S-91-760 DFL (GGH) (E.D. Cal.) (Levi, J.) <br /> Dear Pat: <br /> Please find enclosed a draft of the Settling Parties' Joint Summary of Public <br /> Comments and Responses Thereto Regarding the First Final Consent Decree. A complete <br /> package of all of the comments received is attached to this Joint Summary as Exhibit A. Please <br /> review these documents at your earliest convenience. To expedite the preparation and filing of <br /> the joint motion for entry of this consent decree,please contact either my colleague, John Meyer, <br /> or me with your comments on or before October 13, 1994. If these responses meet with your <br /> approval as drafted, please execute and return the enclosed signature page at your earliest <br /> convenience. <br /> As you are aware from our prior conversations, the sole remaining issue regarding <br /> implementation of the court's order resolving disputes about language for the First Final Consent <br /> Decree lies with the County's position that the First Final Consent Decree should expressly <br /> provide that entry of the First Final Consent Decree be deemed not to preempt the applicability <br /> or enforceability of any local ordinance, regulation or other requirements of law enforceable by <br /> the County of San Joaquin. We have not reached a consensus with the County resolving this <br /> issue. We have, however, reached a tentative agreement with Mr. Aronovsky, acting on behalf <br /> of the County, that the County will support the joint motion for entry of the First Final Consent <br /> Decree on the condition that the Settling Parties reserve to the court the issue of whether the First <br /> Final Consent Decree should include their proposed non-preemption language. The parties will <br /> separately move this court for an order resolving this last remaining dispute with the parties <br /> filing simultaneous briefs outlining their respective positions. Toward that end, we are providing <br /> Mr. Aronovsky with a copy of these documents. <br />