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a <br /> Law offices of <br /> FREEMAN, BROWN & SPERRY <br /> Professional Corporation <br /> Maxwell M.Freeman <br /> James Belford Brown <br /> Gerald A.Sperry <br /> Judy A.Lovett <br /> A.Peter Rausch,Jr. <br /> Ronald J:D'Aiuto <br /> July 31, 19 'x ' 7; <br /> AUG U 2 <br /> ENVIRONMENTAL HEALTH <br /> Mr. Richard Archbold PLERMIT/SERVICES <br /> Neumiller & Beardslee <br /> 509 W. Weber, 5th Floor <br /> Stockton, CA 95202 <br /> Re: Auto Investment Co. Associates <br /> Alleged Contamination -- PRP <br /> Dear Dick: <br /> I read with interest your letter of July 30, 1990 . <br /> Unfortunately, your legal conclusions as to the PRP (Potentially <br /> Responsible Party) are not supported by the facts or the law. <br /> Bob Chase and Bill Chase are the general partners of Auto <br /> investment Co. Associates, the owner of the real property (the <br /> "Site" ) targeted by San Joaquin County Environmental Health <br /> Department as being contaminated . King Chase, Bob and Bill ' s <br /> father, constructed the buildings on the Site and installed at <br /> least three underground tanks, two for fuel and one for the <br /> storage of used crankcase oil. In 1965, ' Union Oil Company <br /> ' installed additional underground tanks . In 1986, Stockton <br /> Service Station Co. , Inc, at the direction of Union Oil, removed <br /> ° all of Union Oil' s tanks . The tanks originally installed by King <br /> Chase, while still on the Site, were taken out of service prior <br /> to 1986 and have remained out of service. <br /> On January 7 , 1987 , Auto Investment Co. Associates (Auto <br /> Investment) , Robert A. Chase, William K. Chase and Chase <br /> Chevrolet Company, Inc. , entered into a comprehensive integrated <br /> settlement agreement. in which all parties released all other <br /> parties from "any contracts, releases, claims, demands, <br /> ' liabilities, causes of action, ' obligations, costs, expenses, <br /> fees, of whatever kind or nature; whether known or unknown. " As <br /> any alleged contamination caused by leaking underground storage <br /> tanks occurred prior to January 7 , 1987 , Bob Chase and Auto <br /> Investment have relinquished any right to seek indemnification <br /> from Bill Chase or Chase Chevrolet. <br /> Any action by a regulatory agency will be against the owner <br /> or owners of the Site and any orders for cleanup will be directed <br /> 1818 Grand Canal Blvd. Reno Nevada Office <br /> Stockton, CA 95207 147 East Liberty Street <br /> 209 474 1818 Reno, Nevada 89501 <br /> Telecopier: 209 474 1245 702 322 0606 <br />