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MICHAEL COLLINS CondenscltT`" %J ]UNE 2, 1994 <br /> Page 49 Page 51 <br /> 1 Q. Yes. 1 site up and that he will be sent a bill from the State <br /> 2 A. Okay. 2 Water Resources Control Board for our oversight. <br /> 3 Q. Have you been retained by Save-Mor to 3 Q. And how does that get compiled? Do you <br /> 4 testify at trial? 4 compile time reports or something? <br /> 5 A. I haven't been notified of that,no. 5 A. Tbat's correct. <br /> 6 Q. Okay. Have you been asked to attend trial? 6 Q. Is Save-Mor billed,also? <br /> 7 A. No. 7 A. Save-Mor has been billed from the very <br /> 8 Q. Have you had any conversations with anybody 8 beginning and it recently became--came to our <br /> 9 representing Save-Mor since--excluding anybody from 9 attention that Mr. Mozeb was the owner of the property. <br /> 10 Quorum or sHN--since October 1993? 10 Q. Okay. Has Save-Mor paid that bill? <br /> 11 A. Could you restate that? 11 A. I'm not aware of whether or not the bill has <br /> 12 Q. I'll make it a little clearer,actually. 12 been paid or not. <br /> 13 Have you had any conversation with counsel 13 Q. If it had been billed,would there be any <br /> 14 for Save-Mor Oil other than today? 14 reason to notify Mr. Mozeb that he's responsible for it? <br /> 15 A. I had an interview with Erickson -- is that 15 MR.PAPAS: Object to the extent that <br /> 16 his name? 16 it calls for speculation. <br /> 17 Q. Grant Erickson? 17 Go ahead,you can answer the question. <br /> 18 A. Grant Erickson. 18 THE WnWESS: Regardless of whether or <br /> 19 Q. Okay. About when was that? 19 not the bill has been paid or not,we need to notify him <br /> 20 A. February 24th, 1994. 20 that he's a responsible party. <br /> 21 Q. What,if anything,did Mr. Erickson tell 21 MR.HASTINGS: Q.Do you know how much <br /> 22 you? 22 the bill is or was? <br /> 23 A. He let me know that there was a lawsuit 23 A. No. <br /> 24 regarding the property,that Mr. Mozeb was filing suit 24 Q. Okay. How would Mr. Mozeb or anybody else <br /> 25 against Save-Mor regarding the disruption of his 12r go about finding out how much they are charging? ; <br /> Page 50 Page 52 <br /> 1 business. 1 A. He could contact our departraciC our <br /> 2 Q. I'm sorry. Was that February 28th? 2 accounting office,specifically aura Campbell. <br /> 3 MR-PAPAS: I think he said the 24th. 3 Q. would she also know if it's been paid? <br /> 4 MR.HASTINGS: Q.So just a few days 4 A. Yea. <br /> 5 before the soil sample was taken of the stockpiled dirt; 5 M&HASM01 Gnat. <br /> 6 is that correct? 6 Thu&you. That's all that 1 have. <br /> 7 A. A few days before. The soil sampling was 7 M3t.PAPA&No questions. <br /> 8 done on February 28th. 8Nb = <br /> 9 MR-HASTINGS: Thank you, Mr. Collins. 9 mazimd for identificatwL) <br /> 10 I don't have any further questions. 10 <br /> I I I I (Deposition concluded at 10:45 an.) <br /> 12 (Brief recess) 12 <br /> 13 13 000- <br /> 14 MR.HASTINGS: You know,I just have a 14 <br /> 15 couple of questions. 15 <br /> 16 Q. Mr. Collins,I think you made mention 16 <br /> 17 earlier at the beginning of your deposition that you 17 <br /> I8 were at least informed that Mr. Mozeb had received a 18 <br /> 19 letter concerning a Notice of Reimbursement. I'll show 19 skgnatwo of Wift= <br /> 20 you what I understand he's recently received. 20 subscribed and sworn to before me <br /> 21 Are you familiar with that? 21 this day of 1944. <br /> 22 A. Yes. 22 <br /> 23 Q. What is that? 23 Notary Public in andorthe county <br /> 24 A. It is a letter informing him that his site 24 of san]oaquin,state of caafornia <br /> 25 is going to be overseen by our department to clean the 25 <br /> PORTALE & ASSOCIATES DEPOSITION REPORTERS Page 49 - Page 52 <br />