My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
SITE INFORMATION AND CORRESPONDENCE
Environmental Health - Public
>
EHD Program Facility Records by Street Name
>
E
>
EIGHT MILE
>
15135
>
3500 - Local Oversight Program
>
PR0544644
>
SITE INFORMATION AND CORRESPONDENCE
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
7/10/2019 11:28:28 PM
Creation date
7/10/2019 4:43:31 PM
Metadata
Fields
Template:
EHD - Public
ProgramCode
3500 - Local Oversight Program
File Section
SITE INFORMATION AND CORRESPONDENCE
RECORD_ID
PR0544644
PE
3529
FACILITY_ID
FA0005287
FACILITY_NAME
H & H MARINA
STREET_NUMBER
15135
Direction
W
STREET_NAME
EIGHT MILE
STREET_TYPE
RD
City
STOCKTON
Zip
95219
APN
06908021
CURRENT_STATUS
02
SITE_LOCATION
15135 W EIGHT MILE RD
P_LOCATION
99
P_DISTRICT
004
QC Status
Approved
Scanner
SJGOV\wng
Tags
EHD - Public
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
164
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
Mr. David M. Smith, President <br /> Herman &Helen's Marine <br /> March 3, 1999 <br /> PBas-3 <br /> want. My client does not want to be litigious; however, a failure t,> <br /> toll the statute may require a filing of a suit upon discovery of the <br /> Presence of contamination without such a tolling. <br /> I have never heard of an instance where insurance compare les <br /> were not in favor of a tolling agreement, if there was an option oth er <br /> than a lawsuit to resolve a matter. Furthermore, I have not run it ito <br /> this issue with any other client. I have checked with other attorn,!ys <br /> who work in this field and none have run across a similar issue. 'fou <br /> may want to re-think your position on this matter. If there is son-e <br /> fact that is part of your decision about which I need to be informe i in <br /> order to •anderstsnd. your romenning, I would be more than willing to <br /> consider it. <br /> As it stands right now, without the tolling provision, my cli !nt <br /> has no incentive to allow you to enter onto its property to take <br /> samples. If you want, we can enter a separate tolling agreement <br /> simultaneously with this right of entry that specifically addresses the <br /> statutory language for such an agreement. You may want to revic w <br /> the language of Section 360.5 of the Code of Civil Procedure. As I <br /> read it, it allows us to toll for a period of four years with the <br /> possibility of entering a successive agreement (one time) prior to t ie <br /> termination of the original agreement for additional term of four <br /> Years- This tolling would give you the time to conduct your <br /> investigation without the imminent threat of litigation. Let me kn 3w <br /> your thoughts on this matter as well. <br /> If you should have any questions, do not hesitate to call. <br /> Very truly yours, <br /> /..r <br /> Brooke K. Birkie <br /> Attorney at Law <br /> Cc: Walt Wolterstorff <br />
The URL can be used to link to this page
Your browser does not support the video tag.