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ANTNONY J. KLEIN <br />RALPH B. WEGIS <br />THOMAS V. DENATALE, JR. <br />JOHN C. HALL <br />GREOORY A. MUIR <br />BARRY L. GOLDNER <br />J. L. HOSENLIES <br />ROBERT A. KRONICK <br />DAVID J. COOPER <br />CLAUDE P. KIMBALL <br />LAURENCE C. HALL <br />DENISE MARTIN <br />DAVID L. SAINE' <br />WILLIAM H. SLOCUMB <br />NED E. DUNPHY <br />ILEIN, WEGIS, DFNATALE, HAPLY <br />MARISA S. vioaURRErA <br />GOLDNER & MUIR <br />BARRY E. ROSENBERG" <br />LAWYERS <br />KIRK S. TRACEY <br />it <br />:A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS �9 <br />JOHN M. PERISICN <br />MANNING W. PUETTr... <br />f ARCO TOWER I} <br />CHRISTOPHER P. BURGER <br />i1 <br />4550 CALIFORNIA AVENUE, SECOND FLOOR <br />CAROL J. KERN <br />PHILIPPE C. COLEMAN <br />EAFCERSFIELD, CA 93309 f i` <br />KEVIN C. FINDLEY <br />k 'i <br />CAROL J. 13ROGAN <br />li MAILING ADDRESS: '� E <br />it <br />LISA A. RYDER <br />P.O. BOX 11172 <br />MICHAEL E. HUGIE <br />BAKERSFIELD, CA 93389-1172 <br />JOSE R. BENAVIDFS <br />- <br />MICHAEL S. ABRIL <br />'� (805) 395-1000 <br />KEN WI5EMAN <br />CHIEF OPERATING OFFICER <br />rt i <br />iS UNITED STATES (800) 221-8537 '. <br />i! CALIFORNIA (800) 221.6536 <br />FAX (805) 326-0418 <br />7 i 1 <br />'ALSO ADMITTED TO COLORADO BAR <br />..ALSO ADMITTED TO NEW YORK AND DISTRICT OF COLUMBIA BARS` <br />"'ALSO ADMITTED TO NORTH CAROLINA BAR <br />February 25, 1994 <br />Ms. Mary Meays 1 <br />Environmental Health division' <br />if <br />San Joaquin County Public Health Services ' <br />P.O. Box 2009 'pF <br />Stockton, CA 95201 <br />RE: Beacon Station No. 610 <br />3300 Waterloo'IRoad, Stockton, CAS' <br />Dear Mary: <br />Please refer to Mr. Kenneth R. Earnest's letter to you da <br />attached) in which he stated that there had been shared responsi <br />remediation at the above referenced site between his company, "E <br />Quentin and Claire Kirsch, ,the landowners. Additionally, <br />scheduling a meeting with my ;clients to discuss the responsibility <br />at the site. v ' <br />The purpose of this letter is to alert you that prior td the tai <br />clients entered into an "Agreement For Tank Replacements and <br />Ultramar, both documents being dated October 6, 1993, which sign <br />relationship as Lessor and Lessee. As a result of these agreements <br />there is any shared responsibility for future assessment andlor rem <br />of the tank closure and over -excavation that was conducted ;t <br />UItramar's sole direction and control, on or about October!! 14, 1! <br />Although we recognize that you and your agency do not <br />%between the various parties who have ownership or operational <br />wanted to make sure that youswere aware of our disagreement a <br />Mr. Earnest's letter. <br />h , <br />II - <br />I� II ( <br />s <br />i 'i <br />BANTA ANA OFFICE <br />PARK TOWER - SUITE 610 <br />200 WEST SANTA ANA BOULEVARD <br />SANTA ANA. CA 9270t <br />(714) 255-0711 <br />FAX (714) 255-9003 <br />ted February 16, 1994 (copy <br />bility for assessment and /or <br />ltramar, Inc. and my clients, <br />he stated that Ultramar was <br />of each party for future work <br />k replacement at the site, my <br />Amendment To Lease" with <br />i ficantly modified their prior <br />, my clients do not agree that <br />ediation of the site as a result <br />y Ultramar's consultants at <br />193. <br />arbitrate or resolve disputes <br />responsibility at a site, we <br />to the position taken in <br />F6 <br />© <br />ted February 16, 1994 (copy <br />bility for assessment and /or <br />ltramar, Inc. and my clients, <br />he stated that Ultramar was <br />of each party for future work <br />k replacement at the site, my <br />Amendment To Lease" with <br />i ficantly modified their prior <br />, my clients do not agree that <br />ediation of the site as a result <br />y Ultramar's consultants at <br />193. <br />arbitrate or resolve disputes <br />responsibility at a site, we <br />to the position taken in <br />