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Neumiller & Beardslee <br /> A PROFESSIONAL CORPORATION <br /> ROBERT L.BEARDSLEEJACK S.JOHAL MAILING ADDRESS' <br /> THOMAS J,SHEPHARD,SR. MICHAEL J.DYER ATTO1:?NRXS AND COTTNSEI. RS PO, DRAWER 20 <br /> DUNCAN R. MCPHERSON PAUL N.BALESTRACCI STOCKTON, CALIFORNIA 9 52 01-3 02 0 <br /> RUOY V,BILAWSKI STEVEN D.CRABTREE FIFTH FLOOR WATERFRONT OFFICE TOWER II <br /> ROBERT C.MORRISON JEANNE ZOLEZZI 509 WEST WEBER AVENUE <br /> JAMES R,DYKE THOMAS E.JEFFRX JR. REFER TO FILE NO: <br /> JAMES A.ASKEW GERALD C. BE141TO STOCKTON, CALIFORNIA 95203-316S <br /> JOHN W.STOVALL DOUGLAS P.WINTER (209) 846-6200 15380-13889 <br /> STEVEN A HERUM PAUL S.MUDRICH <br /> RICHARD M.ARCHBOLD LORENZO G.FORMOSO TELECOPIER (209) 948-4910 <br /> MICHELLE R.G.TURNER Y <br /> SUSAN M. MURRAY October 4 , 1989 <br /> Lisa Brown, Esq. <br /> San Joaquin County <br /> District Attorney' s Office <br /> 222 East Weber Avenue, Room 202 <br /> Stockton, California 95202 <br /> Re: Conrad Mar 'orie Anne/Foreclosure <br /> Dear Lisa, <br /> Enclosed you will find copies of the relevant materials <br /> from our files regarding the former Major Mart station locat- <br /> ed at 1235 Alpine Road in Stockton. Once you have had an <br /> opportunity to review these materials, please call if you <br /> should have any questions . Also enclosed is a rough "time <br /> line" of events to give you an overview of this complex <br /> matter. <br /> Mrs. Conrady and her husband operated the site until <br /> 1981 , at which time it was sold to Smith-Burton Properties, a <br /> general partnership. At that time, Mrs. Conrady took back a <br /> deed of trust to secure a promissory note in the amount of <br /> $120, 000 .00 . We were informed by Mike Clipka, the former <br /> tenant on the site, that the lines from the tanks to the <br /> pumps were replaced after Smith-Burton purchased the proper- <br /> ty. We have no documentation of this fact. There is no <br /> evidence of any problem with the lines of the tanks until <br /> 1988 . In fact, the County' s records indicate that testing <br /> v undertaken in 1987 showed the tanks in proper working order. <br /> It is our position that there was not a problem at the site <br /> during Mrs. Conrady' s ownership and that she has no liability <br /> regarding the property despite the fact that she is a prior <br /> owner. <br /> As I mentioned to you on the telephone, we would appreci- <br /> ate any help you could give us in resolving the holdup regard- <br /> ing investigation of the site by Mrs . Conrady because of her <br /> unwillingness to voluntarily become a Potentially Responsible <br />