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v <br /> WN, HALL, CLAIR & McKINL <br /> LAW OFFICES <br /> THE FOUNTAINS <br /> 3031 WEST.MARCH LANE, SUITE 230 WEST <br /> STOCKTON, CALIFORNIA 9521.9-6500 <br /> NAT BROWN _-_ (209) 477-8171 <br /> JERRY D.HALL FAX (209) 477-2549 x <br /> STEVEN A.CLAIR ---- -- -- r ?tip <br /> �Q e <br /> JOHN H.McKINLEY = g �}JAd�* { 4� gl <br /> JOSEPH A.VARNI - - -�iF$�Il'J`ih til cf <br /> _ � HEA1 <br /> - January 12, 19 '3 <br /> Public Health. Services - - <br /> . Post Office Box 2009 <br /> s Stockton, California 95201 <br /> Attention: Laurie A. Cotulla,_ REHS, Program Manager <br /> Environmental Health Division <br /> Re: Cecchini, Cecchini a Giovannoni <br /> Site Code: 1699 & 1800 <br /> i <br /> Dear Ms. Cotulla: - - = <br /> =I—represent the partnership of Cecchini, Cecchini & <br /> Giovannoni. The partnership has. requestedthat I respond to <br /> correspondence dated December 21, 1992 -and- December 30; <br /> 1992, respectively, -from your office: In that <br /> correspondence, you indicate that- my-- -clients have a <br /> responsibility to reimburse the. State "Water Resources - <br /> Control Board for a sum not to exceed 150% of the total <br /> amount of site specific oversight costs ' actually incurred <br /> while overseeing the cleanup of the site. <br /> The purpose of this letter is to provide you with some <br /> information that may not presently be available to you. <br /> Cecchini, Cecchini & Giovannoni acquired the property_ <br />-- =--- - refEranced by = your site. � cod-es - on June 3",- T992 The s <br /> acquisition "was as a result -of-- the foreclosure by them on <br /> the property. Delta Truck .Sales had previously filed- a <br /> bankruptcy. - -- _ - <br /> -My clients have no problem with that portion of your <br /> letter which seeks to recover funds for _-expenses incurred <br /> after June 3, 1992. However, for expenses.- incurred prior to <br /> _. that time, it is my clients' position -that -you must look to <br /> the prior owner. -_- - <br />