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® 0 <br /> f <br /> 8 <br /> BRAY, GEIGER, RUDQUIST & NUSS <br /> ATTORNEYS AT LAW <br /> DENNIS DONALD GEIGER 400 BANK OF STOCKTON BUILDING _ FOUNDED 1882 <br /> JOHN B.RUDOUIST 311 EAST MAIN STREET <br /> MARK S.BRAY,Of COUNSEL <br /> JAMES T.C.NUSS <br /> ANTHONY S.GUERRIERO STOCKTON, CALIFORNIA 95202-2904 FRANK D.NICOL(1859.1910) <br /> ALAN R.COON MELVIN H.ORR(1851.1916) <br /> STEVEN P.EMRICK TELEPHONE(209)948.0434 W.B.NUTTER(1859-1939) <br /> PETER A.VIRI FACSIMILE (209)948-9451 NEWTON RUTHERFORD(1881.1956) <br /> LAUREEN J.KEEN E-MAIL BGRN@INREACH.COM D.R.JACOBS(1892.1970) <br /> STEPHEN DIETRICH(1908-1971) <br /> PHILIP CAVALERO(1907-1992) <br /> July 31, 1998 <br /> Ms. DeeAnne Watkins <br /> County Counsel <br /> Courthouse, Rm. 711 <br /> 222 East Weber Avenue <br /> Stockton, CA 95202 <br /> Dear Ms. Watkins: <br /> This will confirm my conversation with you on Monday, July 27, 1998. In that conversation I <br /> related to you that my client, Cal State Mortgage,had received a letter on July 27, 1998, although dated <br /> July 16, 1998, from Mike Huggins of Public Health Services in which Mr. Huggins advises that he and <br /> representatives of the San Joaquin County Environmental Health Division, San Joaquin County Code <br /> Enforcement and the California Integrated Waste Management Board performed an inspection on the <br /> property located at 23023 S. Santa Fe Road on July 3, 1998. Unfortunately, our client was not able to <br /> attend that meeting,nor was he advised of the apparent trespass and inspection. A copy of that letter is <br /> attached hereto. <br /> Please also find attached a chronology of the telephone conversations, correspondence and other <br /> pertinent facts regarding the subject property and various county officials. I believe that chronology is <br /> self-explanatory. <br /> Furthermore, and contrary to your statements to me on Monday, July 27, 1998, it appears that the <br /> term "inspection" does have a specific meaning to Mr. Huggins at Public Health Services. More <br /> importantly, my client has yet to have the opportunity to learn about what "solid wastes have been and <br /> are currently being illegally disposed of at this site" although making repeated requests to do so, while at <br /> the same time requesting guidance on clean-up, if necessary. Instead, Cal State receives a letter dated <br /> July 16, 1998, indicating the staff will not have time until "August" (no other date given)to schedule a <br /> meeting. In other words, your client has specifically refrained from discussing this matter other than <br /> sending a "cease and desist" order. I am not surprised. <br /> As you also know, Cal State obtained this property through foreclosure and was not aware of the <br /> existing inspection, investigation or previous cleanup. Instead, and after the foreclosure, San Joaquin <br /> County unsuccessfully attempted to attach a sizeable lien against the property although failing to give <br /> proper notice. Now, it appears that the County is attempting to recover on that mistake at the expense of <br /> my client who obtained the property without notice or knowledge of any problems. Furthermore, it also <br />