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© V <br /> r LAW OFFICES ' JUN � 3 Ag8s <br /> DoxAzlo, BARNHO13ST & BONAR <br /> A PROFESSIONAL CORPORATION ❑ A` Li EALT1i <br /> HOWARD J. BARNHORST If 438 CAMINO DEL RIO SOUTH, SUITE 8-223 EI�Yif�0FNTSERVICES <br /> F <br /> VIRGINIA G. SONAR P.O. BOX 880209 ERMI-rJ <br /> JOEL L.INCORVAIA TE <br /> LAUREL LEE HYDE SAN DIEGO, CALIFORNIA 92108-0005 MICHAEL DORAZIO,JR. <br /> CYNTHIA J.GLANCY (619) 297-8900 RETIRED <br /> STEVEN P. M{DONALD TELECOPIER (619)297-7649 / <br /> MARTHA O.ANDERSON TELEX 697103 eARNDOR 9 <br /> RORY R.WICKS �� �7 �� <br /> ROBERT J.COLI <br /> MICHAEL D. LIUZZI <br /> KAREN H.CANOFF <br /> CHRISSA N.CORDAY <br /> MARK E.STUTZMAN <br /> DAVID S.COHN ,June 8, 1988 <br /> ROBIN F. LAKE <br /> LAURI CROCE STREETER <br /> GARY G.ALLEN <br /> Ronald L. Valinoti, R.S. <br /> Director, Environmental Health Division <br /> San Joaquin Local Health District <br /> P. 0. Box 2009 <br /> Stockton, California 95201 <br /> Re: Energy Petroleum Underground Storage Tanks <br /> Our File No. 1051. 01 <br /> Dear Mr. Valinoti : <br /> This letter is written on behalf of the Port of Stockton <br /> regarding subject underground storage tanks. We are in receipt <br /> of your letter dated May 27 , 1988 , which fails to take into <br /> consideration the undisputed facts regarding the underground <br /> storage tanks owned by Energy Petroleum and misinterprets state <br /> law regarding such ownership. <br /> By letter to Mr. Moe dated August 14, 1987, we set forth, on <br /> behalf of the Port, a detailed analysis as to the <br /> responsibilities for the underground storage tanks. At that <br /> time, we foresaw that a possible dispute could arise regarding <br /> these underground storage tanks and provided specific authority <br /> under which the Health District could and should have taken <br /> action against either Energy Petroleum or the Bank of Stockton to <br /> resolve this matter. Now, over ten months later, and having <br /> ignored our earlier correspondence as well as our letter dated <br /> March 15, 1988 , the Health District asserts that the <br /> responsibility for these tanks rests with the Port of Stockton, <br /> rather than with Energy Petroleum or its successor-in-interest, <br /> the Bank of Stockton. <br /> In your letter you stated that you had been advised "that under <br /> the law of the State of California, the Port of Stockton became <br /> the owner of those tanks at such time as possession of the real <br />