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Ms. Carol Browner <br /> Hon. Pete Wilson <br /> Ms. Felicia Marcus, et al. <br /> October 9, 1995 <br /> Page 3 <br /> Accordingly, Union Oil Company of California ("Union Oil") hereby gives <br /> notice that it intends to commence an action against the City of Stockton, L&M Petroleum, <br /> Roy H. Leabo, Billy W. McKinnon, Morton Paint Company ("Morton Paint"), and Alco <br /> Industries, Inc. ("Alco") not less than 90 days from the date of this notice under Section <br /> 7002(a)(1)(B) of the SWDA, 42 U.S.C. § 6972(a)(1)(B). <br /> Union Oil will bring this action against the above named entities and persons <br /> based upon their status as owners and operators of treatment, storage and/or disposal <br /> facilities, and as transporters and generators of solid wastes and upon their contribution to <br /> the past handling, storage, treatment, transportation, and/or disposal of solid wastes which <br /> may present an imminent or substantial endangerment to health or the environment near <br /> three parcels of property located in Stockton, California and described as follows: <br /> Site 1: The property bounded by West Weber, North Harrison, West Main and <br /> North Edison streets. <br /> Site 2: The property bounded by West Weber, North Lincoln, West Main, and <br /> North Harrison streets. <br /> Site 3: The property bounded by West Main, North Lincoln, West Market, <br /> and North Harrison streets. <br /> I. Background <br /> The City of Stockton is the current owner and operator of Sites 1 and 2. Prior <br /> to the City of Stockton's ownership, Site 1 was owned by L&M Petroleum, Mr. Leabo, <br /> and Mr. McKinnon. During their respective ownerships and operations at and around Site <br /> 1, the City of Stockton, L&M Petroleum, Mr. Leabo, and Mr. McKinnon generated, <br /> handled, stored, transported, managed, and/or disposed of solid wastes which may now <br /> present an imminent and substantial endangerment to health or the environment. <br /> 59543.1 <br />