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MULLEN, SULLIVAN Sc NEWTON, LLP <br /> THOMAS J. NEWTON OF COUNSEL <br /> CRAIG RASMUSSEN ATTORNEYS AT LAW ROBERT H. MULLEN <br /> STEPHEN C. SNIDER IIII WEST TOKAY STREET C. M. 'BUD-SULLIVAN <br /> JAMES V. DEMERA III <br /> BENJAMIN C. MCDONALD R. O. BOX 560 <br /> LODI, CALIFORNIA 95241-0560 <br /> 12091 334-5144 <br /> FAX 12091 333-1034 <br /> March 6, 2003 <br /> Diane Grover (Sent Via Fax (209) 465-0371) <br /> Office of the District Attorney <br /> Environmental Prosecutions Unit <br /> P. O. Box 990 <br /> Stockton, CA. 95201 <br /> RE : Perry Kotsoglou <br /> Kingdon Flight Services <br /> Dear Ms . Grover: <br /> Pursuant to David J. Irey' s letter dated February <br /> 27 , 2003 , this is our statement of facts concerning the <br /> above-referenced Application for Complaint . <br /> First, you should know that effective April 20, <br /> 2003 , Kingdon Flight Services will no longer be operating <br /> the aviation fuel system located at Kingdon Airport. That <br /> fuel service will be operated by the property owner, Mr. Al <br /> Troglin, effective that date . <br /> Mr . Kotsoglou attempted to do his reporting <br /> electronically in February of 2002 as requested by the <br /> County. He stopped by the OES office a year ago December, <br /> paid all the fees and was told that it would be on a two <br /> year reporting program. Not wanting any problems and <br /> because he had experienced problems in the past, he still <br /> reported electronically in December of 2002 . The County <br /> program locked Mr. Kotsoglou' s computer system and caused a <br /> massive crash. He spoke with Michelle Hallowell about <br /> mailing a new version of the County' s program but never did <br /> receive the new program. <br /> On March 4, 2003 , as a result of your letter, Mr. <br /> Kotsoglou talked to Dennis Fields at the OES . He has faxed <br /> the document to Mr. Fields requested by the County. As a <br /> result, it is my understanding now that Kingdon Flight <br /> Services is in complete compliance with Chapter 6 . 95 of the <br /> California Health & Safety Code. If your office or the OES <br /> are in disagreement, I would ask that you notify me <br /> immediately. I do understand that Mr. Kotsoglou has <br /> received a fax confirmation that the required documents <br /> have been filed. <br />