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October 29, 1998 <br />Ms. DeeAnne Watkins <br />County Counsel <br />Courthouse, Rm. 711 <br />222 East Weber Avenue <br />Stockton, CA 95202 <br />Re: 23023 Santa Fe Road Riverbank <br />Dear Ms. Watkins: <br />FOUNDED 1882 <br />MARK S. BRAY, OF COUNSEL <br />FRANK D. NICOL (1859.1910) <br />MELVIN H. ORR (1851.1916) <br />W.B. NUTTER (1859-1939) <br />NEWTON RUTHERFORD (1881.1956) <br />0. R. JACOBS (1892.1970) <br />STEPHEN DIETRICH (1908-1971) <br />PHILIP CAVALERO (1907-1992) <br />This letter confirms our conversation of this morning in which I informed you of the following: <br />1. I have visited the site with a surveyor and it appears that the dumping besides the railroad <br />tracks ends before the Subject Property. Therefore, my client does not intend to incur the <br />cost of an unnecessary written survey. <br />2. I observed minor junk on that parcel that San Joaquin County erroneously believed was <br />owned by Mr. Lane. <br />3. I was unable to locate any tires on the Subject Property. <br />4. I was unable to locate the place where Alan Biedermann believes that Linch's contractor <br />(James Dale Steely) allegedly buried a house. I have been unable to make contact with <br />Mr. Steely. <br />5. My clients will expend their own monies to clean the visible surface junk but do not want <br />to incur the cost twice. i.e. Again, are there any other concerns? We will bring out a <br />contractor on or soon after November 16, 1998, unless you advise in writing of any other <br />concerns. <br />Now, we are waiting for the County to fulfill its promises made at the October 5, 1998 meeting. <br />First, Steve Mindt stated that he would be sending a letter confirming the outcome of the October 5, <br />1998 meeting. Second, the County would provide copies of all photographs and reports which support <br />any claim that there has been any illegal dumping on the Subject Property as described in the July 16, <br />1998 letter from Mike Huggins of Public Health Services after 1979. i.e. a "reactivated landfill." <br />SItAY, GEIGER, RUDQUIST & NUSS <br />ATTORNEYS AT LAW <br />' <br />DENNIS DONALD GEIGER"� <br />°• tnt 1 .. �..,. 400 BANK OF STOCKTON BUILDING <br />(( <br />JOHN 8. RUDOUIST <br />•"1 "' ` °� "� 13 311 EAST MAIN STREET <br />JAMES T. C. NUSS <br />STOCKTON, CALIFORNIA 95202-2904 <br />ANTHONY S. GUERRIERI) <br />ALAN R. COON <br />TELEPHONE (209) 948-0434 <br />STEVEN P. EMRICK <br />FACSIMILE (209)948.9451 <br />PETER A. VIRI <br />LAUREEN J. KEEN <br />E-MAIL BGRN®INREACH.COM <br />October 29, 1998 <br />Ms. DeeAnne Watkins <br />County Counsel <br />Courthouse, Rm. 711 <br />222 East Weber Avenue <br />Stockton, CA 95202 <br />Re: 23023 Santa Fe Road Riverbank <br />Dear Ms. Watkins: <br />FOUNDED 1882 <br />MARK S. BRAY, OF COUNSEL <br />FRANK D. NICOL (1859.1910) <br />MELVIN H. ORR (1851.1916) <br />W.B. NUTTER (1859-1939) <br />NEWTON RUTHERFORD (1881.1956) <br />0. R. JACOBS (1892.1970) <br />STEPHEN DIETRICH (1908-1971) <br />PHILIP CAVALERO (1907-1992) <br />This letter confirms our conversation of this morning in which I informed you of the following: <br />1. I have visited the site with a surveyor and it appears that the dumping besides the railroad <br />tracks ends before the Subject Property. Therefore, my client does not intend to incur the <br />cost of an unnecessary written survey. <br />2. I observed minor junk on that parcel that San Joaquin County erroneously believed was <br />owned by Mr. Lane. <br />3. I was unable to locate any tires on the Subject Property. <br />4. I was unable to locate the place where Alan Biedermann believes that Linch's contractor <br />(James Dale Steely) allegedly buried a house. I have been unable to make contact with <br />Mr. Steely. <br />5. My clients will expend their own monies to clean the visible surface junk but do not want <br />to incur the cost twice. i.e. Again, are there any other concerns? We will bring out a <br />contractor on or soon after November 16, 1998, unless you advise in writing of any other <br />concerns. <br />Now, we are waiting for the County to fulfill its promises made at the October 5, 1998 meeting. <br />First, Steve Mindt stated that he would be sending a letter confirming the outcome of the October 5, <br />1998 meeting. Second, the County would provide copies of all photographs and reports which support <br />any claim that there has been any illegal dumping on the Subject Property as described in the July 16, <br />1998 letter from Mike Huggins of Public Health Services after 1979. i.e. a "reactivated landfill." <br />