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Lisa F. Brown, Esq. <br /> July 13 , 1988 <br /> Page 2 <br /> Stockton's ("Bank") claim filed in the EP bankruptcy or other <br /> court orders concerning the bankruptcy, for which you asked. <br /> However, please feel free to contact us if we can be of further <br /> assistance. <br /> Under separate cover, we will soon send you a detailed analysis of <br /> the Bank's liability for the EP tanks. In addition, we will rebut <br /> Mr. Hoslett's analysis, received today, of the Port's <br /> responsibility for the EP tanks. We will also respond to the <br /> questions in your July 8, 1988 letter. <br /> I want to emphasize the Port's position that the ISC and EP <br /> problems are closely analogous and inextricably linked. In both <br /> cases, the Port tenants are initially the appropriate parties on <br /> whom to place responsibility -- the Port should not be held <br /> responsible for problems it did not create. Thus, certainly ISC <br /> should be required to investigate the conditions on its property. <br /> Conversely, the Port understands that EP does not have the <br /> resources fully to finance the removal .if its underground storage <br /> tanks. if your office and the Health Department will take <br /> appropriate action with regard to ISC, the Port will cooperate <br /> fully with you in reaching an equitable resolution of the EP <br /> matter. <br /> Please call me if any of the statements in this letter do not <br /> conform with your understanding of our conversation or if you have <br /> any questions. ` <br /> Sincerely, <br /> &� <br /> Gary G. Allen <br /> DORAZIO, BARNHORST & BONAR <br /> GGA:jln <br /> 34/1051:01 <br /> cc: Mr. Alexander Krygsman <br /> Jogi Khanna, M.D. , M.P.H. <br /> Ronald L. Valinoti, R.S. <br /> Mr. Robert Niblack <br /> i <br />