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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />• <br />C. The Property sought to be acquired is necessary for <br />the project; and <br />d. The offer required by Government Code section 7267.2 <br />has been made to the owners of record. <br />10. The object of the action is to allow plaintiff to acquire <br />the interest of the defendants in the real property as described <br />herein pursuant to Eminent Domain Law to provide solid waste disposal <br />services essential to the health, safety, and welfare of the citizens <br />of the City of Stockton. The project for the Property and property <br />interests being acquired is the construction of a landfill/solid <br />waste disposal facility, the Austin Road Landfill Expansion Project. <br />11. All of the parties in this litigation are set forth in the <br />above title to the action. The named defendants appear as record <br />owners and are known to plaintiff to have or claim some interest in <br />the Property. For the convenience of the court and the parties, and <br />not as allegations by which plaintiff is bound, defendants' possible <br />interests are set forth below: <br />Defendant <br />Albert Brocchini Farms, Inc. <br />Franco Blanco (an employee of Albert <br />Brocchini Farms, Inc.) and his wife, <br />Virginia Blanco <br />Irene M. Young <br />Arthur E. Salmon <br />Ida M. Geiger Hailey <br />Frances C. Williams <br />Elzora I. Bunch <br />Property Interest <br />Owner in fee <br />Tenants <br />Right-of-way <br />Mineral rights <br />Mineral rights <br />Mineral rights <br />Mineral rights <br />WHEREFORE, plaintiff prays judgment as follows: <br />FBS&D:RJD:VG:01/05/96 4 <br />