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early May of 1993, supplied with water by a well located on <br />the Premises. On that date, and at that time Defendant <br />Marlowe received a Notice from the San Joaquin County Public <br />Health Services regarding the contamination of the water <br />supplied to Plaintiff by the well. This contamination <br />included, but is not limited to: 1. 1-Dichloroethane 69 partn <br />Per billion (ppb) [Maximum Contaminant Level (MCL) is 5 ppb); <br />1, 2-Dichloroethane 1 ppb. MCL .5 pub; 1, 1-Dichlororethylene <br />230 ppb, MCL 6 ppb; Trichloroethylene 12 Pph, MCL 6 ppb. <br />Plaintiff is ignorant of the exact length of time <br />said contaminants were contained in the well water supplying <br />his business, prior to April 1993, however, Plaintiff is <br />informed and believes, and thereon alleges that said contami- <br />nants were present prior to November of 1991. <br />Plaintiff further alleges that he has ingested water <br />from the well in various forms (Ice, in coffee and as drinking <br />water) on a continual basis for the entire time he hag <br />occuPied the Premises as a tenant, up to and including the <br />months of April 1993 (approximately 25 years). <br />Plaintiff is informed and believes, and thereon <br />alleVes that the. contaminants (above-mentioned in paragraph <br />8 of this complaint.) disnovered in the water supplied to his <br />prem i ses a health r.;1‹ in levels exceeding the Maximum <br />—Contaminant Level and cause or Produce all of the symptoms and <br />ailments Plaintiff has suffered. <br />/ / / <br />1 <br />2 <br />3 <br />4 <br />6 <br />7 <br />a <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 />71. P- THOMAS <br />TTITIMITT AT LAM/ <br />ON No 04411 27 <br />5, 0. DUX 717 <br />1DRRIDGE, CA <br />ga•91,71.7 28 <br />-39) X.4255 poio 369-6288 <br />/1/ <br />ALUM VS.11111.0118 <br />. cUl?U!ltJVK bilICia Page ..4 of 14 <br />(4.(v4 naJ Tr,- Jr1-7,4- 71-7 • mi 171 I '.17 "frin-r-Ual.1