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r • <br /> Attorneys At Law <br /> NOVIRECIEVED <br /> 0 8 2002 Karna E. Harrigfeld <br /> kharrigfelcl@herumcrabtree.com <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> November 6, 2002 <br /> VIA OVERNIGHT AIRBORNE EXPRESS <br /> Ms. Barbara L. Evoy, Chief <br /> Underground Storage Tank Cleanup Fund <br /> State Water Resources Control Board <br /> Division of Clean Water Programs <br /> 1001 "I" Street <br /> Sacramento, California 95814 <br /> Re: Claim# 017289 <br /> Site Address: 75 E. Alpine Avenue, Stockton <br /> Dear Ms. Evoy: <br /> The Guido Segarim Trust ("Trust" or "Claimant") applied for reimbursement from <br /> the Underground Storage Tank Cleanup Fund ("Fund") on June 7, 2002 (Application is <br /> attached as Exhibit "N'). The Fund staff, by a letter dated June 21, 2002, found its claim to <br /> be ineligible for placement on the priority list due to the fact that the Trust "was never the <br /> owner or operator of the Underground Storage Tanks." (Fund Letter is attached as Exhibit <br /> `B"). The Trust appealed the Fund Staffs decision to the Fund Manager. The Fund <br /> Manager, by letter dated September 9, 2002, upheld the Staffs decision on the basis that <br /> the Trust was not an owner of the underground storage tanks. (Manager's Letter is <br /> attached as Exhibit"C"). We believe that when looking at all of the surrounding <br /> circumstances, the Trust was an equitable owner at the time the tanks were removed and <br /> therefore should be eligible for reimbursement from the Fund. Therefore, we are hereby <br /> requesting review by the Chief of the UST Division. <br /> The history of the property located at 75 E. Alpine, Stockton, CA("Property") is long <br /> and slightly complicated, but I think that it would be beneficial to outline the history of <br /> ownership and operation of gasoline facilities on the Property. <br /> From our extensive research, we found that the Property was used as a gas station <br /> from at least 1956. In 1956 the site was operated as Chuck and John's Service Gas Station. <br /> In 1957 it was operated as Chuck's Service Gas Station. From 1958 to 1961 it was operated <br /> as Steve & Gene's Gas Station. From 1962 to 1970 it was operated as Woodson Mobil <br /> 2291 Wasf Maeck Laha Strife B100 5fockfor,, CA 95207 <br /> • <br /> Tel 209.472.7700 • Fax 209.472.7986 • Modesfo Tel. 209.525.8444 <br /> A Professional Corporation <br />