Laserfiche WebLink
JOHN M . KAPPOS <br /> AY­FORNKY AL LAW <br /> 333 N. SAN JOAQUIN STREET <br /> STOCKTON, CALIFORNIA 95202 <br /> (209) 466-9051 <br /> HAND DELIVERED <br /> July 15 , 1992 p1guyll <br /> Mike Infurna <br /> Diane Hinson <br /> S . J . County Public Health Services <br /> Environmental Health Division 1UL 1 51992 <br /> 445 N . San Joaquin Street <br /> Stockton , CA 95202 ENVIRONMENTAL HEALTH <br /> pERMITI SERVICES <br /> Re : Vintage Car Wash �/OS /)� C <br /> Dear Sirs : <br /> One of the issues that Mr . Giambanco has raised in our audit of <br /> Shaughnessy v . Giambanco , by way of cross - action , is that <br /> Pacific Avenue has some contamination. <br /> I have taken the deposition of Doug Wilson who indicated several <br /> things in regard to any contamination at Pacific Avenue . I <br /> don ' t have the deposition typed up as yet but can make a copy <br /> available for Mr . Wilson to review or for you to review . The <br /> item that is not 100 °% answered at this time that concerns me is <br /> that Mr . Wilson said the alleged contamination found at Pacific <br /> is not sufficiently severe to warrant closure or remediation at <br /> this time and there are no plans that he knows of regarding the <br /> Department taking any action as to Pacific Avenue , absent <br /> further testing . He did , however , say that he is not involved <br /> directly in the department that makes that determination and <br /> that we would have to obtain such a statement from Diane Hinson <br /> to make it official . <br /> I am interest in filing a motion for summary judgment as to <br /> Pacific Avenue , or a request , in effect , to the court to deter - <br /> mine there is no triable issue as to Pacific Avenue Vintage <br /> Car Wash . To do so I either need a declaration from one of <br /> you to the effect as indicated above , or I would have to take <br /> another deposition of one of you . <br /> It would be much faster and more cost efficient if I could <br /> prepare a brief declaration to be executed by the head of <br /> Department IV to the effect that no sanctions will be taken <br /> against Vintage Car Wash on Pacific Avenue , given the state of <br /> h <br />